908R94002
HAZARDOUS WASTE INCINERATORS
I \	BOILERS AND INDUSTRIAL FURNACES
- ^	UPDATE #4
United States Environmental
Protection Agency
Region VIII	DENVER, COLORADO • JUNE 1994
INTRODUCTION
This is the fourth in a series of information updates from the
U.S. Environmental Protection Agency (EPA) regarding pro-
posed incineration activities in Region VIII. These updates are
developed with the cooperation of state environmental agencies
in Region VIII. The purpose of these updates is to keep interest-
ed parties informed of possible incineration activity in their
communities. This document summarizes the Army's proposed
method for destruction of stockpiled chemical munitions and
gives the status of combustion facilities in Region VIII.
SUMMARY OF CHEMICAL MUNITIONS
DESTRUCTION PROGRAM
111 » report to Congress released last month, the Army identified
deration as the best available method for destroying the
on's aging stockpile of chemical weapons. In the same
report, the Army also announced plans to conduct a research and
development (R&D) program to evaluate alternative
technologies' to incineration, tests of a stack filter system
designed to reduce toxic air emissions from incineration, and
outreach efforts to provide more information and increase the
public's involvement in the decision-making process surrounding
the chemical munitions destruction program.
BACKGROUND
The Army currently stockpiles some 24,800 tons of unitary
chemical warfare agents, manufactured between about 1942 and
1968. These chemicals consist of two types of nerve agents and
three forms of a mustard compound (a blistering agent or
vesicant). The agents are in a variety of munitions, including
artillery shells, rockets, and land mines, as well as in bulk
containers. These weapons are stored at eight sites in the
continental U.S. and on Johnston Atoll in the Pacific Ocean, 700
miles southwest of Hawaii. Two of the storage sites are in EPA
Region VIII (Tooele Army Depot in Tooele County, Utah, and
the Pueblo Depot Activity in Pueblo County, Colorado), and
together comprise more than half of the total stockpile.
this stockpile continues to age and deteriorate, the threat of
iccidental release (due to corrosion and leaking of the con-
tainers or decomposition of the chemicals) is likely to become
more and more serious. In 1992, Congress directed the Army to
dispose of the entire unitary chemical weapons stockpile by
December 31, 2004. Also, the 1993 Chemical Weapons
Convention (CWC) international treaty, signed by the U.S. and
awaiting ratification by Congress, calls for the permanent
destruction of all unitary and binary chemical weapons.
Prior to 1969, the Army disposed of its chemical weapons by
methods such as land burial, open burning, and deep ocean
dumping. During the 1970s several technologies, including
controlled incineration and neutralization, were tested for the
permanent and safe destruction of these materials. In 1982, the
Army selected component disassembly and incineration as the
preferred baseline system for disposal of the chemical weapons
stockpile; a 1984 report by the National Research Council
(NRC) reviewed and agreed with the Army's selection. The
baseline system was tested at Johnston Atoll during the 1980s,
and the Army proposed building disposal facilities using this
system at the eight mainland storage sites. The Tooele facility
was completed last year, and has begun operational testing with
non-lethal substitutes for chemical agents; the Army plans to
begin full-scale disposal operations at Tooele next year. Public
opposition to the incineration of chemical weapons and other
hazardous wastes in the U.S. has raised questions about the
safety of the baseline system and spurred a quest for alternative
technologies which might be as safe and effective as incineration
agd which could be implemented in time to meet legislative and
treaty deadlines.
•	Army stockpiles include about 25,000 tons of chemical
weapons.
•	Region VIII chemical weapons storage sites are Tooele
Army Depot, Utah and Pueblo Depot Activity, Colorado.
These sites store over half the nation's total chemical
weapons.
•	Threat of accidental release increases with age of
deteriorating weapons.
•	Component disassembly and incineration = Army's
preferred baseline system of disposal.
•	Army plans to begin disposal operations at Tooele in 1995.
'Words shown in bold on the first mention are defined in the glossary on page 3.

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BASELINE SYSTEM
The current baseline system, as used at Johnston Atoll and
constructed at Tooele, consists of several steps. Most of the
procedures are performed automatically by machines. Weapons
are first unpacked, disassembled, and the chemical agents and
other hazardous components, such as fuses, detonators, explo-
sives, and propellants (collectively known as energetic
materials), are removed from the casings. All components of
the weapon, including outer packaging materials, are potentially
contaminated with chemical agents and must be treated. Metal
parts are heated in a furnace to burn off residual agent. The
liquid chemical agents, energetic materials, and packaging are all
incinerated separately in high-temperature furnaces. Vapors and
flue gases from these furnaces pass through afterburners to
complete the destruction of any residual chemical agents. The
air leaving the afterburners then proceeds through a series of
quenchers, scrubbers, and demisters to remove corrosive vapors
and particulate matter before it is vented to the outside.
Building air is treated by activated carbon filters before release.
Furnace ashes, scrubber residues, and the building air carbon
filters are treated and disposed of as hazardous wastes.
Some critics of this system contend that the air vented from the
furnaces and afterburners may still contain traces of chemical
agents or other hazardous vapors. The Army's report addresses
this concern by recommending that tests be conducted to deter-
mine the effectiveness of adding activated carbon filters to the
incineration stack; these filters are designed to adsorb remaining
chemicals from the air stream. The Army's report estimated that
addition of carbon filters to the baseline system will add $260
million to the cost of the chemical weapons disposal program.
Another concern about the baseline system is that it might have
been chosen without adequately considering alternative
technologies that may be safer, more efficient, or less costly.
This question was the subject of two reports written by the NRC
in 1993 and 1994, discussed below.
ALTERNATIVE TECHNOLOGIES
The two NRC reports addressed the issue of alternative
technologies to the baseline system for chemical weapons
destruction. The first report identified a number of possible
combinations of technologies which could conceivably replace
incineration; the second evaluated these alternative technologies
against the baseline system and made several recommendations.
Tlie goal of these recommendations was to minimize the total
risk involved in the chemical weapons disposal program (for
example, the risks posed by incineration versus continued storage
of deteriorated weapons). The NRC concluded that the program
should continue without delay using the baseline system. Last
month's report by the Army incorporated most of the recommen-
dations made in the second NRC report.
Any proposed alternative technology for chemical weapons must
meet several requirements. Legislation passed by Congress
1992 requires that an alternative technology must be significan
safer (protective of human health and the environment) and at
least as cost-effective as the baseline system if it is to be used.
A new technology must also meet the deadlines and technical
requirements of state and federal regulations, as well as the
CWC treaty.
The NRC reports that neutralization of the chemical agents
appears to be the most promising alternative to incineration. In
its report, the Army says that two processes based on this
technology-stand-alone neutralization, and neutralization
followed by biological treatment-will be investigated in an
accelerated R&D effort. Whether or not a viable alternative
technology emerges for destruction of the chemical agents, the
other weapon components and packaging materials would still
need to be incinerated, since no other safe processes have been
identified for the cleanup or disposal of these substances.
•	NRC reports conclude that total risk of baseline system is
less than using alternative technologies; however, NRC
recommends testing of carbon filters on incineration
stacks.
•	No alternative technology has met all the criteria set out
by statute, regulations, and international treaty.
•	Neutralization is the most promising alternative
technology; research and development efforts have been
accelerated.
PUBLIC COMMENT AND OUTREACH PROGRAM
In an effort to improve communication with the public and
encourage greater community involvement in technology selec-
tion, oversight of operations, and decommissioning of facilities,
the Army report states that it will continue supporting and meet-
ing with local Citizens' Advisory Commissions (CACs) and will
open public information centers near each facility. CACs and
interested individuals have 60 days from the date of the Army
report (until June 11,1994) to submit comments on the report to
Congress. Comments on the Army's program can be addressed
to: Honorable Sam Nunn
Chairman, Senate Armed Services Committee
U.S. Senate
Washington, D.C. 20510-6050
or
Honorable Ronald V. Dellums
Chairman, House Armed Services Committee
U.S. House of Representatives
Washington, D.C. 20515-6035
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^UTURE ACTIVITIES
In addition to R&D on alternative technologies, the Army plans
to conduct updated risk analyses of the disposal program at each
facility. These assessments will be conducted using both the
baseline system and the alternative technologies being research-
ed. Schedules and operations of the disposal program will be
modified as indicated by the results of the updated risk analyses.
One important aspect of the new risk analyses will be to assess
the relative risks of storage, handling, and disposal of chemical
weapons at each facility. Some of the chemical weapons stock-
pile includes rockets whose propellant charge decomposes over
time. Once the propellant stabilizer becomes depleted to a
critically low level, the risk increases that one of these rockets
could spontaneously ignite. No one knows for sure how much
longer the weapons stockpile will remain stable, but chemical
agent will eventually leak from stored weapons. The threats of
leakage and spontaneous ignition are reasons why both the Army
and the NRC reports urge that disposal using the baseline system
proceed without delay while the search for an alternative
technology continues.
•	Army will conduct risk analyses on disposal program.
•	If storage is continued for the long-term, some weapons
ultimately may leak or ignite spontaneously.
FURTHER READING
The 1993 NRC report, "Alternative Technologies for the
Destruction of Chemical Agents and Munitions," identifies a
number of alternative technologies which might replace
incineration as a means of destroying chemical weapons. The
1994 NRC report, "Recommendations for the Disposal of
Chemical Agents and Munitions," evaluates the alternatives
identified in the 1993 NRC report against the baseline system
and makes a number of recommendations concerning the Army's
chemical demilitarization program.
The Army's report to Congress, "U.S. Army's Alternative
Demilitarization Technology Report for Congress," Was issued
on April 11, 1994. It responds to the 1992 Congressional
legislative requirements with an analysis of the NRC reports and
the NRC's recommendations concerning alternative technologies.
The Army report also provides an overview of chemical
demilitarization technology in the former Soviet Union.
AH three reports are available for public viewing at the informa-
¦jn repositories at Salt Lake City and Tooele, Utah and Pueblo
Ad Boone, Colorado. (See page 5 for information repository
locations.)
GLOSSARY
Agent (or chemical agent): The lethal ingredient in a chemical
weapon.
Alternative Technologies: Processes, aside from the baseline
system of incineration, which might be used to destroy chemical
agents.
Baseline System: The currently selected method for destruction
of the U.S. chemical weapons stockpile, consisting of
disassembly of the munitions, high-temperature decontamination
of the salvageable metal parts, and incineration of the chemical
agents, explosives, propellants, and contaminated packaging
materials.
Binary: A type of chemical weapon in which two relatively
safe chemicals are loaded, to be mixed to form a lethal agent
after the weapon is fired or released.
Energetic Materials: Fuses, detonators, high explosives, rocket
propellants, etc., present in assembled weapons and which will
ignite or detonate readily.
Mustard: A reactive compound with a garlic-like odor, used in
chemical weapons. Mustards cause painful skin blisters and
severe damage to mucous tissues (eyes, nose, lungs, etc.) when
inhaled or adsorbed into the skin.
National Research Council: An independent committee of
experts from U.S. academic institutions and industry, which
advises the Federal government on scientific and technical issues.
Nerve Agent: A class of compounds used in chemical weapons,
which can quickly cause death when the vapors are inhaled or
adsorbed into the skin. (Popularly called a nerve gas, although
these chemicals are actually liquids.) Nerve agents are lethal
because they block the signals from the body's nervous system
to the heart and lungs, resulting in cardiac arrest and respiratory
failure.
Neutralization: A chemical reaction which converts a
hazardous material to a non-hazardous or less hazardous
compound; suggested as an alternative to incineration of
chemical agents.
Unitary: A type of chemical weapon which does not need to be
mixed to form a lethal agent before being released.
Vesicant: A chemical which causes blistering of the skin.
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STATUS OF HAZARDOUS WASTE
INCINERATORS AND BOILERS & INDUSTRIAL FURNACES (BIFs) IN REGION VIII
UTAH
1.	APTUS. Inc.. Tooele County. UT
APTUS is a commercial facility that has been incinerating
hazardous waste, including polychlorinated biphenyls (PCBs),
since January 1992. The stack testing (trial burn) was
conducted in the spring of 1992 and the trial burn report has
been reviewed by the State of Utah and EPA. Based on the
trial burn report, the State of Utah and EPA have specified
final operating conditions with which the facility must
comply.
2.	USPCI Clive Incineration Facility. Tooele County. UT
USPCI is a commercial facility that was approved by the
State of Utah in March 1994 to begin receiving hazardous
waste for storage. After the State has approved USPCI's
construction certification for the incinerator system, inciner-
ator shakedown with hazardous waste could begin during the
summer of 1994. EPA's Toxics Division has recently issued
a draft Demonstration Approval that would allow USPCI to
store and incinerate PCBs in addition to hazardous wastes
regulated under the State of Utah's RCRA permit. The State
of Utah and EPA have reviewed USPCI's trial burn plan and
are currently in the process of approving it. The trial burn
test is scheduled to be conducted in the autumn of 1994.
3.	United States Department of the Army. Tooele Armv Depot -
South:
(a)	Chemical Demilitarization Facility (CDF)
CDF is a nerve agent incineration facility that will destroy
stockpiled nerve agents stored at the Tooele Army Depot.
Systems check-out of the five separate incinerators at CDF is
continuing. In addition, design and operating procedures
modifications based on lessons learned at the Army's
Johnston Atoll nerve agent incinerator (JACADS) are being
incorporated at CDF. After the State of Utah and EPA have
approved systems check-out and required modifications are
completed, a trial burn will be conducted on each incinerator,
first with non-nerve agent chemicals and then with nerve
agents. Trial burn plans for testing with non-nerve agent
chemicals are currently being reviewed by the State of Utah
and EPA. Comments on some of the plans have already been
prepared and will be sent to the Army for its response.
(b)	Chemical Agent Munitions Disposal System (CAMDS)
CAMDS is a research facility currently treating nerve agent
waste that was stored at the Tooele Army Depot. CAMDS
has a Research, Demonstration, and Development (RD&D)
permit issued by the State of Utah in May 1991. A trial burn
is scheduled for the summer of 1994 on the metal parts
furnace at CAMDS.
4. United States Department of the Armv Tooele Armv Depot -
North: Deactivation Furnace
The deactivation furnace destroys the obsolete ammunition
and propellant stored at the Tooele Army Depot. A trial burn
test was conducted on the furnace in August 1993 and a trial
burn report has been submitted to the State of Utah for
review and approval. Initial review has determined that the
furnace did not meet all required performance standards. The
Army is reviewing operational changes, and plans to retest the
furnace, which is not currently in operation.
COLORADO
1.	Waste-Tech Services. Inc.. Golden. CO
A permit was issued for this facility in February 1989 by the
State of Colorado. The Waste-Tech unit is a small fluidi?
bed incinerator used for research.
2.	Rocky Mountain Arsenal. Submerged Quench Incinerator
(SOI). Commerce Citv. CO
The SQI treats liquid wastes that were stored at the Rocky
Mountain Arsenal in a surface impoundment called Basin F.
The SQI is part of the Superfund cleanup actions ongoing at
the Arsenal. The trial burn report has been reviewed and
approved by EPA and the State of Colorado. Based on the
trial burn report, EPA and the State of Colorado have
specified operating conditions that the facility must comply
with until incineration operations are completed in the autumn
of 1995. To date, the SQI has treated almost 4 million
gallons of Basin F liquid.
PART B APPLICATIONS RECEIVED (PROPOSED)
United States Department of the Armv. Pueblo Depot Activity
In July 1992 a permit application was submitted by the Army to
the State of Colorado and EPA. The Army has proposed
building an incineration facility that will destroy stockpiled
mustard blister agents stored at the Pueblo Depot Activity. A
permit must be issued by the State of Colorado and a Certified
of Designation (CD) issued by Pueblo County bef
construction can begin.
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Ash Grove Cement. Montana City. Montana
. May 1993 a permit application was submitted by Ash Grove
to the State of Montana and EPA. Ash Grove has proposed
using non-liquid hazardous wastes in its existing cement kiln as
a fuel supplement. A permit must be issued by the State of
Montana and EPA before hazardous wastes can be burned in the
kiln. EPA and the State of Montana jointly issued an initial
Notice of Deficiency (NOD) in December 1993. The NOD
requests additional information that must be included in the
application. To date, Ash Grove has not submitted a response
to the NOD to EPA or the State of Montana.
If you have technical questions or questions related to Federal
regulations, you may contact:
Carl Daly, Regional Combustion Specialist
U.S. EPA, Region VIII
999 18th Street
Denver, Colorado 80202-2466
(303) 293-1500
You may also contact the following state representatives:
Colorado
Montana
ve Waltz
Richard Knatterud
ablic Health Engineer
Environmental Specialist
Hazardous Waste Control
Department of Health and
Colorado Dept. of Health
Environmental Sciences
4300 Cherry Creek Dr. So.
836 Front Street
Denver, CO 80222
Helena, MT 59620
(303) 692-3360
(406) 444-1430
North Dakota
South Dakota
Neil Knatterud
Vonnie Kallemeyn
Acting Director
Natural Resources Program Scientist
Waste Management
Department of Environmental & Natural
Department of Health
Resources
1200 Missouri Avenue
Office of Waste Management
Room 302
319 South Coteau
Bismarck, ND 58520
Pierre, SD 57501
(701) 221-5166
(605) 773-3153
Utah
Wyoming
Scott Anderson
David Finley
Chief, Commercial/Federal
Administrator
Facilities Branch
Solid and Hazardous Waste Division
Utah Department of
Wyoming Dept. ofEnvironmental Quality
Environmental Quality
Herschler Building, 122 W. 25th
P.O. Box 144880
Cheyenne, WY 82002
>lt Lake City, UT
(307) 777-7938
4114-4880
vo01) 538-6170
If you would like general background information or publications on
incineration of hazardous waste, contact:
Harold Dunning, Office of External Affairs
U.S. EPA Region VIII
999 18th Street
Denver, Colorado 80202-2466
(303) 294-1142
LOCATION OF REPOSITORIES
General information, background publications and these updates on
incineration of hazardous waste have been placed at the following
locations and are available to the public:
•	Boone Town Hall, Boone, CO
•	Boulder Public Library, Boulder, CO
•	Burlington Public Library, Burlington, CO
•	U.S. EPA Library, 999 18th Street, Denver, CO
•	Florence Public Library, Florence, CO
•	Ft. Collins Public Library and
Colorado State University Library, Ft. Collins, CO
•	Mesa County Public Library,
Grand Junction, CO
•	Lyons Depot Library, Lyons, CO
•	McClelland Library and Barkman Branch Library,
Pueblo, CO
•	Stratton Public Library, Stratton, CO
•	Montana State University, Bozeman, MT
•	Lewis & Clark County Library, Helena, MT
•	Three Forks Public Library, Three Forks, MT
•	Rapid City Public Library, Rapid City, SD
•	Delta City Library, Delta, UT
•	Marriott Library, University of Utah,
Salt Lake City, UT
•	Tooele City Public Library, Tooele, UT
•	Albany County Public Library, Laramie, WY
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Incinerators/BIFs
(a) Aptus - Aragonite, UT
A USPCI - Clive, UT
EPA Region VIII
Hazardous Waste Incinerators
and
Boilers and Industrial Furnaces
• Helena
r Salt Lake
A^Tooele

enver
• Pueblo
© Tooele Deactivation Furnace - Tooele, UT
©Chemical Agent Munitions
Disposal System (CAMDS) - Tooele, UT
Chemical Demilitarization Facility
^ (CDF) - Tooele, UT
<$>
Pueblo Depot - Pueblo, CO
(G) Rocky Mountain Arsenal - Denver, CO
Waste Tech - Golden, CO
Ash Grove Cement Co.
~
Facility Status
O EXISTING/OPERATING
^ EXISTING/NOT OPERATING
<^> APPLICATION SUBMITTED
Clancy, MT
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MAILING LIST
EPA maintains a mailing list of people interested in incineration
activities in Region VIII. If you did not get this Update by mail
and want your name added to that mailing list, please fill out this
form and mail it to:
Harold Dunning
Office of External Affairs (80EA)
U.S. Environmental Protection Agency
999 Eighteenth Street, Suite 500
Denver, CO 80202-2466
(please print or type)
NAME
AFFILIATION (if any)
ADDRESS	
CITY	 STATE	 ZIP CODE
Please delete my name from the mailing list:	
Are you interested in a specific facility? 	No 	Yes
If yes, name/location of facility		
Note: Reuse/Recycle
Please pass this form on to someone you think would be interested in hazardous waste incineration if you do not wish to use the form at this time.
U.S. Environmental Protection Agency
Office of External Affairs (80EA)
999 Eighteenth Street
Suite 500
Denver, CO 80202-2466
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