The issues surrounding the effects on closure operations from waste generation and management before and after completion of stockpile disposal operations are also considered.

While the waste streams are essentially the same for all facilities, the way they are managed is not. The chemical agent disposal facilities are all regulated under the Resource Conservation and Recovery Act (RCRA) by the respective state regulatory authorities, and each facility operates under a RCRA permit. These permits were initially negotiated prior to facility construction, when waste types but not quantities were generally known. The permits were therefore modified to a greater or lesser extent as disposal operations proceeded, depending on the local situation. Thus, local regulations and stakeholder concerns play a role in what any facility can do. In three states, for example, the wastes generated from the operation of the chemical agent disposal facility are “listed hazardous wastes,” while in the other two states they are not. This has a significant influence on how the wastes can be managed. Listed wastes and wastes derived from listed wastes must be treated as hazardous even if they do not exhibit hazardous characteristics, with the exception that they may be delisted.

Permit conditions will also affect the disposition of waste. For example, in Oregon all waste, with some minor exceptions, must be treated on-site. This significantly inhibits the options for disposal of the wastes off-site. Treatment on-site is limited by the capacity of the metal parts furnace (MPF) and its availability when it is not processing the munitions. Permits at the other locations are not as restrictive as in Oregon, which requires on-site treatment of secondary waste. The detailed differences in operations are discussed in Chapter 3 of the report.

The committee was also asked to evaluate the trial burn practices at the incineration-based facilities and compare them with similar practices in industry. Each Chemical Materials Agency (CMA) incineration facility has several types of incinerators and each has been required, by permit, to carry out a surrogate burn on all of its furnaces after start-up and before feeding any agent. A surrogate trial burn is required to demonstrate the ability of the unit to achieve a 99.9999 percent (“six nines”) destruction and removal efficiency and unit operability. They have then been required to carry out a trial burn with each agent. After the trial burn, the feed rates are reduced to 50 percent until the trial burn data have been submitted, and to 75 percent until the data have been accepted. This is a lengthy process.

While industrial practice requires a trial burn and a facility may not operate until the data are accepted, industrial facilities obtain approval to process many different waste streams based on a single trial burn. In special situations, particularly with toxic materials such as polychlorinated biphenyls, both a surrogate burn and a trial burn would be required. RCRA regulations offer the option of allowing the use of data from another facility, under certain conditions, in lieu of a trial burn. However, industry has used this mechanism at only a few sites with similar units. It has been used twice by the CMA for the Tooele, Utah, disposal facility. The CMA should pursue this mechanism with the respective regulatory authorities. The committee believes that chemical agent disposal facilities are treated similarly to industrial facilities with respect to the conduct of trial burns.

The committee’s study of site-specific secondary waste practices and requirements focused on the six major waste streams produced by the chemical agent disposal operations. Of the six, brine and brine salts are treated and disposed of off-site during operations at permitted treatment, storage, and disposal facilities. At the Umatilla site, brine solutions are thermally treated to produce a solid salt, which is then shipped off-site to a hazardous waste landfill. However, brine solution may be disposed of off-site if thermal treatment to produce a brine salt impedes the main mission of the agent disposal operation. Brine and brine salts must meet the established waste control limit for off-site disposal—that is, the agent concentration must be below the permit limit for materials containing agent.

Of the five remaining major waste streams, spent activated carbon is being stored at each facility for later disposal. Munitions bodies and other scrap metal are sent to off-site smelters after being thermally treated to a clean condition in the MPF at the four incineration-based facilities. Because on-site secondary waste processing capacity is limited, demilitarization protective ensemble suits are shipped off-site or stored until they can be treated on-site in the MPF when it has an opening in its schedule or at the end of agent destruction operations.

Wood dunnage is separated into that which has not been exposed to agent and that which may have been exposed. This segregation is based on generator knowledge and vapor monitoring. Unexposed dunnage is

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