As a regular user in NAV2009R2, attempting to Send a BizTalk
document resulted in the error message.
This message is for C/AL programmers: The call to member Send
failed: The handle is invalid

But I could send if the user happened to be in the network
Administrators group.
The solution turned out to be due to permissions to the
folder
C:\Documents and Settings\All Users\Application
Data\Microsoft\Crypto\RSA\MachineKeys
Once I added read permissions to the user group "Everyone" I
could send from NAV to BizTalk.
Looks like this folder is created by NAV but permissions are not
inherited. I say this because other folders above and at the same
level as MachineKeys had Read permissions for "Everyone"
As far as I can tell. The COM object being run by the NST needs
to encrypt the message before it sends to the Commerce Gateway
Requestor Service. Is was the encryption that was failing during
the send.