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4 Management of Process and Nonprocess Pine Bluff Non-Stockpile Facility Secondary Wastes For purposes of preparing the environmental assessment for the PBNSF, it was estimated that about 1.6 million lb of liquid hazardous waste, 110,000 lb of spent carbon and fil- ters, 30,000 lb of decontaminated metal parts, and lesser amounts of other solid hazardous wastes would be produced over the entire period of PBNSF operation (U.S. Army, 2002b). The environmental assessment states that essentially all materials processed in the PBNSF, as well as many sys- tem effluents, will be regulated hazardous wastes. All pro- cess and storage tanks, except raw material supply tanks, will be subject to Resource Conservation and Recovery Act (RCRA) requirements. Also, all neutralents are expected to be classified as corrosive hazardous wastes based on the highly alkaline nature of their treatment reagents, monoethanolamine (MEA) or caustic, unless the pH has been adjusted to less than 12.5. Effluents from treatment of ar- senic-containing agents will contain arsenic (>5 ppm) and other RCRA hazardous materials, requiring them to be clas- sified as a toxic hazardous waste. These streams, and the spent decontamination solutions resulting from the cleaning of equipment and munition parts that have been in contact with these streams, will also carry RCRA waste codes (U.S. Army, 2003a). The major liquid and solid waste streams are identified in Tables 4-1 and 4-2 (U.S. Army, 2003d). The primary treat- ment operations in PBNSF will treat arsenicals using caustic as the neutralizing agent, nitrogen mustard using MEA as the neutralizing agent, and sulfur mustard again using MEA as the neutralizing agent. As shown in Table 4-1, the neutralents from these three operations will be significant waste streams, with the sulfur mustard neutralent dominat- ing at 420,000 lb over the life of the campaign. The spent decontamination solutions from the three campaigns will be much larger streams, with that from the sulfur mustard stream again dominating at 840,000 lb over the life of the campaign. MEA will be the major component of the two mustard neutralents, while water and caustic will be the ma- jor components of the arsenicals neutralent. 40 Various Environmental Protection Agency RCRA waste codes will be assigned to the streams listed in Tables 4- 1 and 4-2 as a consequence of the agents being treated and some of the agent degradation products. These degradation products, their RCRA-allowed levels, and their Environmental Pro- tection Agency RCRA waste codes are given in Table C- 1 -2 of the PBNSF RCRA permit application (U.S. Army, 2003a). This table also describes in detail how each stream will be generated and stored before transportation and treatment or disposal. Other liquid streams and their estimated volumes are as follows: Miscellaneous paint: amount to be determined Unused liquid 5 percent bleach Unused liquid 20 percent caustic Flammable industrial waste: amount to be determined Spent hydraulic fluid: 40 lb Spent lube oil: 40 lb Miscellaneous laboratory liquids: 10 gallons per month, 2006-2007 Other solid streams: Lead acid batteries: amount to be determined Used instrumentation: amount to be determined Miscellaneous laboratory supplies: one drum per month, 2006-2007 Miscellaneous maintenance debris: amount to be de- termined Miscellaneous solids from process tanks and filters: 7,500 lb (U.S. Army, 2003a). (The committee pre- sumes that this includes corroded steel particles from the carbon dioxide blast station and steel saw chips from the metal cutting stations.) A hazardous waste landfill is located at the northwest corner of the Pine Bluff Arsenal (PBA) (U.S. Army, 2002b).

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MANAGEMENT OF PROCESS AND NONPROCESS PINE BLUFF NON-STOCKPILE FACILITY SECONDARY WASTES TABLE 4-1 Major Liquid Secondary Waste Streams from the Treatment Process 41 Total Quantity Description of Stream Generated (lb) Components Neutralized waste from 44,000 Caustic ~20 wt %, water ~80%, sodium chloride <3%. Less than 1 wt % each of sodium arsenite, arsenicals benzene, diphenylarsene oxide, thiodiglycol, chlorohydrin, monosodium thiodiglycolate, ether-thioether oligomer, and vinylthioethanol. Neutralized waste from 11,000 MEA 76 wt %, water 9.5%, monoethanolamine hydrochloride 8.5%, 1-(hydroxyethylaminoethyl)4- nitrogen mustard (HN) hydroxyethylpiperazine 6.0%, trace volatile organic compounds <0.1%. Neutralized waste from 420,000 MEA 87.4 wt %, water 10%, N-(2-hydroxyethyl)-thiomorpholine 0.9%, bis[2-(2-hydroxyethylamine) sulfur mustard (HD) ethyl]sulfide 0.3%, MEA hydrochloride 0.3%, trace volatile organic compounds <0.1%. Spent decon solution from 220,000 Sodium hydroxide ~10 wt %, water ~90%, less than 1% of sodium arsenite, benzene, diphenylarsene arsenicals campaign oxide, thiodiglycol, chlorohydrin, monosodium thiodiglycolate, ether-thioether oligomer, and vinylthioethanol. Spent decon solution from 90,200 nitrogen mustard campaign Spent decon solution from sulfur mustard campaign Sodium hydroxide 9.9 wt %, water 89.8%, sodium chloride 0.2%, N-ethyldiethanolamine 0.1%. 840,000 Sodium hydroxide 16.3 wt %, water 83.2%, thiodiglycol 0.3%, sodium chloride 0.2%. SOURCE: U.S. Army (2003g). TABLE 4-2 Major Solid Secondary Waste Streams from the Treatment Process Description of Stream Total Quantity Generated Components Spent carbon from process vent filters; heating, ventilation, and air conditioning filters; and storage tank vent filters. Spent high-efficiency 15,000 lb particulate air filters and pre-filters from process vent filters; heating, ventilation, and air conditioning filters; and storage tank vent filters. Decontaminated personal protective equipment. 95,000 lb May contain up to 0.5 wt % organic loading. Organics may include sulfur mustard, nitrogen mustard, MEA, N-(2-hydroxyethyl)-thiomorpholine, bis [2-(2-hydroxyethylamine) ethyl] sulfide, MEA hydrochloride, 1-(hydroxyethylaminoethyl)4-hydroxyethylpiperazine, thiodiglycol, arsenical compounds, and trace volatile organic compounds. May contain sulfur mustard, nitrogen mustard, monoethanolamine, N-(2-hydroxyethyl)-thiomorpholine, bis[2-(2-hydroxyethyl-amine)ethyl]sulfide, monoethanolamine hydrochloride, 1-(hydroxyethylaminoethyl)- 4-hydroxyethylpiperazine, thiodiglycol, arsenical compounds, and trace volatile organic compounds. 1,300 suits May contain residual agent, including sulfur mustard, nitrogen mustard, and arsenicals. SOURCE: U.S. Army (2003g). Some hazardous waste from Pine Bluff operations is now disposed of at this landfill. However, the environmental as- sessment states that no hazardous waste resulting from the operation of the PBNSF will be disposed of at this landfill. No reason is given. Other hazardous waste from PBA is transported off-site by a contractor and disposed of through the Defense Reutilization and Marketing office. The Army's overall philosophy in managing these streams is that they should be treated on site only to the point that they can be safely shipped to off-site commercial treat- ment, storage, and disposal facilities (TSDFs) for final treat- ment and disposal.] This reduces the scope of operations IJoseph Cardito, Program Manager, Shaw, Stone & Webster, Inc., "Pro- cess Design and Equipment Fabrication for PBNSF Overview and Status," briefing to the committee on March 19, 2003.

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42 involving hazardous materials at the Pine Bluff site, and the committee expects that the local stakeholders would prefer this strategy over more extensive handling of hazardous materials. While substantial in volume, the quantities will be small in comparison with those routinely handled by com- mercial TSDFs. Thus, the costs associated with managing the streams on-site would be greater than the costs of man- agement at commercial TSDFs. Treatment goals for agent destruction are discussed in Chapter 5. Many uncertainties surrounded the generation and dis- posal of spent activated carbon as this report was being gen- erated. The lack of a firm design for the carbon bed filtration system for the currently envisioned process is mentioned in Chapter 2. The regulatory and technical issues surrounding sampling for agent in spent activated carbon are discussed in Chapter 3. A possible reduction in the amount of spent acti- vated carbon generated if the Army elects to employ ex- panded use of explosive destruction systems (EDSs) is discussed later in this chapter. The specific means by which the Army plans to dispose of secondary waste from PBNSF at off-site locations is a waste management contract that was awarded to Shaw Envi- ronmental, Inc., in July 2003 and that will end in December 2005 (U.S. Army, 2003d). The contractor is responsible for teaming with one or more commercial hazardous waste TSDFs to transport and dispose of hazardous secondary and neutralent wastes from the various Non-Stockpile Chemical Materiel Product projects, including PBNSF. The contract states that nonincineration treatment technology is preferred to incineration.2 However, Shaw Environmental is required to compare and present the costs of treating the waste using both incineration and nonincineration technologies for each waste stream generated. The Army considers deep well dis- posal and fuel blending to be comparable to incineration in terms of viability.3 The TSDF team membered) chosen by Shaw Environmental must be capable of (1) using an exist- ing nonincineration technology or (2) developing and using a new nonincineration technology. Upon receipt of cost, schedule, and risk information, the government will decide whether to use an incineration or a nonincineration approach for the treatment and disposal of each waste stream. If a nonincineration approach is chosen, the type or types of tech- nology to be employed are to be negotiated with the govern- ment. If technology development or addition of capacity is needed for the nonincineration approach, this is also to be negotiated. In either case, the TSDF(s) will be responsible 2The indicated preference for nonincineration technology is consistent with trends over the past several decades, first to incineration as a preferred treatment technology, then away from incineration (NRC, 1994; 2002a). 3Joseph Cardito, Program Manager, Shaw, Stone & Webster, Inc., "NSSCII Task: Waste Management Support Task Status," briefing to the Non-Stockpile Chemical Matenel Program (NSCMP) Core Group Tech- nology Subcommittee arid Ad Hoc Next Steps Group Meeting on August 27, 2003. ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY for obtaining any needed RCRA permits or permit modifica- tions, with the costs reimbursed by the Army. Also, in either case, the TSDF(s) must be ready to process waste no later than October 2005. Presumably, this date applies to newly installed or expanded capacity; the contract with Shaw Envi- ronmental calls for treatment of waste from ongoing and fu- ture non-stockpile chemical warfare materiel treatment op- erations, including PBNSF, to be begun in October 2003 (U.S. Army, 2003e). Public interactions are to be coordi- nated with and approved by Non-Stockpile Chemical Mate- riel Product management and the public affairs office. The contract with Shaw Environmental does not recom- mend any alternative technologies or discourage offerors from featuring certain technologies. It does provide reports evaluating alternative technologies, leaving it up to the offerors to study them and come to conclusions regarding their applicability and appropriateness. A list of waste treat- ment facilities using Zimpro's wet air oxidation technology was made available to potential offerors. However, these facilities typically treat only sewage sludge or spent caustic and may not be of direct use to potential offerors. Whether any of these facilities would be able to accept and treat wastes from PBNSF was not clear. Under the contract, Shaw Environmental is to provide and periodically update pricing for disposing of waste using nonincineration technologies that might need to be devel- oped. No quantity guarantees are provided by the Army. It is anticipated by the Army that the TSDFs would find other users of the disposal technology. However, the committee expects that any new facilities developed under this program will be too small to be practical for commercial operation after the wastes from PBNSF have been treated. Therefore, the costs associated with closure might also have to be cov- ered by the Army. The committee judges that disposal of secondary wastes by incineration and deep welling is to be avoided if at all possible and practical. If the current waste management con- tract does not result in disposal costs that are considered ac- ceptable by the Army, incremental funding for the process development effort might need to be supplied by the Army. Considerable effort has already been devoted to process de- velopment, and the most promising technologies have been identified and explored. Incremental effort might be needed to make one or more of these technologies available at an acceptable cost. Alternatively, and especially in consider- ation of the small volumes involved, the Army might have to reconsider what is an acceptable cost. Finding 4-1: Under the waste management contract issued to Shaw Environmental, Inc., costs are provided by the con- tractor for disposal of liquid secondary wastes by means of incineration or nonincineration technologies. Whether nonincineration technologies will ultimately be selected by the Army could not be determined by the committee at the time this report was prepared.

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MANAGEMENT OF PROCESS AND NONPROCESS PINE BLUFF NON-STOCKPILE FACILITY SECONDARY WASTES Recommendation 4-1: The Army should continue to pur- sue alternatives to incineration and deep welling of liquid hazardous wastes. If the current waste management contract does not result in costs that are acceptable to the Army for disposal using nonincineration technologies, alternative ap- proaches to disposal using nonincineration technologies should be identified and pursued. Three options are being considered for the management of an expected 30,000 lb of contaminated metal parts (U.S. Army, 2002b): 1. Decontamination to a 3X level at PBNSF, followed by transport to a commercial TSDF for recycling or land- fill disposal. Metal parts that have been so treated could be released to a commercial TSDF under con- tract with the U.S. government (U.S. Army, 2003a). Decontamination to a 3X level at PBNSF, followed by transport to the Rock Island Arsenal smelter, where they would be smelted for recycle, with 5X decon- tamination as a consequence of the process. Decontamination to a 3X level at PBNSF, followed by decontamination to a 5X level in an existing PBA fur- nace and disposal in a landfill or sale for recycling. 3. The Army plans to build metal decontamination units for treatment of the contaminated metal parts. The parts will be placed in chambers and exposed to high-pressure 10 percent caustic spray, followed by rinsing with water and air drying. The air in the chamber will be sampled to verify the 3X decontamination level of the metal pieces. Once this is ac- complished, the pieces will be packaged in containers and shipped off-site to an approved smelter or furnace for metal recovery (U.S. Army, 2003a). Munition overpacks that held leaking munitions will be decontaminated to a 3X level, cut into pieces, and managed like other decontaminated metal parts. Nonhazardous solid waste from all of PBA is now dis- posed of at the Jefferson County municipal landfill, located 3 miles west of the arsenal (U.S. Army, 2002b). The Army plans to dispose of nonhazardous solid wastes from PBNSF at this landfill. These wastes would consist primarily of dun- 43 nage from the delivery of munitions and supplies. The amount generated would be small in comparison with the amount of nonhazardous solid waste generated by other PBA operations and would result in no appreciable effect on Jefferson County landfill operations. The committee does not expect that expanding the use of EDSs, described in Chapter 6, would greatly affect the com- position of the waste streams. However, if EDSs are used extensively and if they are used with multiple rounds per shot, especially if six or nine rounds per shot are employed in the EDS-2, the volume of liquid wastes, neutralents, and rinses might be reduced significantly. The Army has stated that additional rounds can be fired in each EDS shot without increasing the volume of liquid waste produced.4 The EDS- 1 produces actual average volumes of less than 125 gallons per munition in single-shot operation (U.S. Army, 2003f). The committee was not aware of analogous information for the EDS-2. As a rough approximation, one round per shot operation on 1,245 munitions (Table 1-1) would produce less than 125 x 1,245 = 156,000 gallons of liquid waste, or less than 1.3 million lb. This compares reasonably well to the 1.6 million lb indicated for PBNSF in Table 4-1. Operation on a three-rounds-per-shot basis in EDS-ls could reduce the amount to less than about 430,000 lb, a major reduction. Another difference might be a significant reduction in the quantity of activated carbon to be disposed of, especially if the EDS-2 is used and operated with six or nine rounds per shot. The activated carbon filters used on the EDS-1 would normally be changed after each shot. The EDS- 1 uses either two 10-lb filters or a single 20-lb filter (U.S. Army, 2003f). Presumably, this amount of carbon would be used in either a single-round shot or a triple-round shot. For single-round- per-shot operation, the amount of waste activated carbon to be disposed of would be about 1,245 x 20 = 24,900 lb, which compares reasonably well with the 95,000 lb shown for PBNSF in Table 4-2. Presumably, multiple-rounds-per-shot operation would reduce the quantity of carbon waste even further. The committee was not aware of similar information for the EDS-2. The containment system for the EDS also has an activated carbon filter bank (U.S. Army, 2003f). For the EDS-1, this filter bank contains 800 lb of carbon. However, replacement is expected to be infrequent. 4Darryl Palmer, Non-Stockpile Chemical Materiel Product, e-mail to the committee, August 25, 2003.