2
Trial Burns, Compliance Testing, and Health Risk Assessments

INTRODUCTION

Hazardous waste combustors, which include incinerators, boilers, and industrial furnaces, are regulated by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA), and in some cases, the Toxic Substances Control Act (TSCA). These regulations define an incinerator as an enclosed device that uses controlled flame combustion (40 CFR 260.10). The nomenclature used to describe certain components of the Army’s baseline incineration system notwithstanding (e.g., metal parts furnace), the processes at chemical agent disposal facilities using combustion technology are considered hazardous waste incinerators. Consequently, the discussion in this chapter is generally restricted to issues that concern incinerators. Health risk assessments and transportation risk assessments are also discussed.

Properly conducted, incineration effectively destroys (to 99.9999 percent) toxic organic compounds contained in hazardous waste, reducing or eliminating their toxicity. The products of incineration consist primarily of carbon dioxide and water. Depending on the feed composition, small quantities of carbon monoxide, nitrogen oxides (NOx), HCl, and other products of combustion may form. If combustion is not complete, compounds known as products of incomplete combustion are emitted. Some ash may be carried through the incinerator as small particles along with the gases.

The EPA’s principal measure of incinerator performance is destruction and removal efficiency (DRE). The DRE is determined by measuring the amount of a principal organic hazardous constituent (POHC) destroyed in the incineration process. A formula for calculating the DRE of a system’s performance is given in Box 2-1. Under RCRA regulations, a DRE of 99.99 percent is required for all wastes other than those identified as presenting significant threats to human health or the environment. In these cases, for example dioxin-containing wastes, a DRE of 99.9999 percent has been established as a requirement. A DRE of 99.9999 percent (also called “six nines”) means that one molecule of a POHC is emitted into the air for every one million molecules of a POHC entering the incinerator (EPA, 2000). The RCRA operating permits for all chemical agent disposal facility incinerators specifically require a DRE of 99.9999 percent for agent and agent-contaminated wastes.

BACKGROUND ON REGULATORY REQUIREMENTS FOR TRIAL BURNS

Resource Conservation and Recovery Act

An incinerator regulated under RCRA must conduct a trial burn and submit the trial burn plan or results of a trial burn as part of a permit application for a facility (40 CFR 270.19(b)).1 Before conducting the trial burn, the facility must submit a trial burn plan that covers all

1

The RCRA permit life for the chemical agent disposal facilities in this study, once granted, is 10 years, the same length of time that is standard for similar industrial facilities.



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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 2 Trial Burns, Compliance Testing, and Health Risk Assessments INTRODUCTION Hazardous waste combustors, which include incinerators, boilers, and industrial furnaces, are regulated by the U.S. Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA), and in some cases, the Toxic Substances Control Act (TSCA). These regulations define an incinerator as an enclosed device that uses controlled flame combustion (40 CFR 260.10). The nomenclature used to describe certain components of the Army’s baseline incineration system notwithstanding (e.g., metal parts furnace), the processes at chemical agent disposal facilities using combustion technology are considered hazardous waste incinerators. Consequently, the discussion in this chapter is generally restricted to issues that concern incinerators. Health risk assessments and transportation risk assessments are also discussed. Properly conducted, incineration effectively destroys (to 99.9999 percent) toxic organic compounds contained in hazardous waste, reducing or eliminating their toxicity. The products of incineration consist primarily of carbon dioxide and water. Depending on the feed composition, small quantities of carbon monoxide, nitrogen oxides (NOx), HCl, and other products of combustion may form. If combustion is not complete, compounds known as products of incomplete combustion are emitted. Some ash may be carried through the incinerator as small particles along with the gases. The EPA’s principal measure of incinerator performance is destruction and removal efficiency (DRE). The DRE is determined by measuring the amount of a principal organic hazardous constituent (POHC) destroyed in the incineration process. A formula for calculating the DRE of a system’s performance is given in Box 2-1. Under RCRA regulations, a DRE of 99.99 percent is required for all wastes other than those identified as presenting significant threats to human health or the environment. In these cases, for example dioxin-containing wastes, a DRE of 99.9999 percent has been established as a requirement. A DRE of 99.9999 percent (also called “six nines”) means that one molecule of a POHC is emitted into the air for every one million molecules of a POHC entering the incinerator (EPA, 2000). The RCRA operating permits for all chemical agent disposal facility incinerators specifically require a DRE of 99.9999 percent for agent and agent-contaminated wastes. BACKGROUND ON REGULATORY REQUIREMENTS FOR TRIAL BURNS Resource Conservation and Recovery Act An incinerator regulated under RCRA must conduct a trial burn and submit the trial burn plan or results of a trial burn as part of a permit application for a facility (40 CFR 270.19(b)).1 Before conducting the trial burn, the facility must submit a trial burn plan that covers all 1 The RCRA permit life for the chemical agent disposal facilities in this study, once granted, is 10 years, the same length of time that is standard for similar industrial facilities.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements BOX 2-1 Definition of Destruction and Removal Efficiency DRE = 100 × [(Feed rate − Emission rate) /Feed rate] where emission rate is the rate at which the selected POHC exits the process in the exhaust gas stream. The DRE thus focuses on air emissions. hazardous wastes slated to be treated in the hazardous waste incinerator. Based on the waste analysis data in the trial burn plan, the state regulatory agency will specify the POHCs for which DREs must be calculated during the trial burn. POHCs are selected based on their high concentration in the waste stream to be processed or the greater difficulty of destroying them in comparison to other waste stream constituents. If the unit achieves the required DRE for the POHCs, it is presumed that it will achieve the same or better DRE for all other easier-to-burn organics in the waste streams covered in the trial burn plan. At least one POHC is selected for each waste stream. After completing the trial burn in accordance with the trial burn plan, a hazardous waste facility submits the results along with all data collected during any trial burn. Based on the results of the trial burn, the state agency sets the incinerator’s operating parameters in the final (or modified) RCRA permit. For the purposes of allowing a hazardous waste incinerator to operate following completion of the trial burn, and prior to any final modifications of the permit conditions to reflect the trial burn results, the agency may establish temporary permit conditions. These conditions may include, but are not limited to, setting waste feeds and operating conditions (such as feed rates) that allow operation prior to issuance of the final permit. The RCRA permits for all baseline system chemical agent disposal facilities prohibit the incineration of any chemical agent or any waste containing chemical agent for which treatment has not been successfully demonstrated through a trial burn. An individual trial burn plan for each different chemical agent must be submitted by the facility’s management for each of its incinerators and is considered as a request for a major permit modification. Agent-specific trial burn plans must be approved by the state agency prior to the start of the shakedown period for the respective trial burns. RCRA permit conditions preclude chemical agent disposal facilities from feeding more than one agent at a time into the incinerators. Thus, unlike a commercial treatment, storage, and disposal facility (TSDF), which can obtain approval to process many different waste streams in one trial burn, at the chemical agent disposal facilities, a separate trial burn is conducted for each individual agent. Under RCRA regulations, performance data from one incinerator can be submitted in lieu of conducting a trial burn on a second incinerator. The permit submittal to accomplish this is similar to that described above and requires the following (40 CFR 270.19(c)): A detailed engineering description of the proposed incinerator and the incinerator from which previous trial burn data are being provided, An analysis of each waste, A detailed description of sampling and monitoring procedures, A description of the results of the previous trial burn from which data are being provided, Planned procedures for normal and off-normal operating conditions, and Any other relevant information. The Chemical Materials Agency (CMA) and the state regulators have not used the data-in-lieu-of-a-trial-burn mechanism provided for by RCRA, with the exception of twice at the Tooele Chemical Agent Disposal Facility (TOCDF). This resulted from an understandable desire to be conservative in managing risks given the initial lack of experience with baseline system incinerators, and the learning curve needed by both the chemical agent disposal facility staff and the state regulatory staff. Most regulators told the committee they would consider such an approach and, in at least one case, said they anticipated such an approach would be pursued. Toxic Substances Control Act The EPA has issued a “national permit” to the U.S. Army’s chemical agent disposal facilities that governs the disposal of polychlorinated biphenyls (PCBs) under TSCA. The EPA’s regional administrator or the director of the National Program Chemical Division may determine that a trial burn must be conducted based

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements on a submitted trial burn plan. At a minimum, the plan must include: Date trial burn is to be conducted; Quantity and type of PCBs and PCB items to be incinerated; Parameters to be monitored and location of sampling points; Sampling frequency and methods and schedules for sample analyses; and Name, address, and qualifications of persons who will review analytical results and other pertinent data and who will evaluate the technical effectiveness of the trial burn. Similar to RCRA, once the trial plan has been approved, a trial burn will be conducted and the results reported to the regional administrator or the director, National Program Chemical Division, for approval. At TOCDF, trial burns were conducted in accordance with RCRA and TSCA protocols for certain M55 rockets. The acceptance criteria for the RCRA trial burn of the liquid incinerators, the deactivation furnace system (DFS), and the metal parts furnace were met. A second test of the DFS destruction efficiency for PCBs showed that emissions levels meet TSCA criteria (NRC, 1999). Maximum Achievable Control Technology Comprehensive Performance Test Requirements In October 2005, the EPA issued a final rule updating the RCRA emission standards for hazardous waste incinerators based on maximum achievable control technology (MACT) that is commonly employed under the CAA. Therefore, hazardous waste incinerators are subject to MACT combustion unit performance standards and operating requirements, in addition to RCRA standards. The general provisions of the MACT standards are contained in CAA regulations (40 CFR 63 Subpart A). Sources of hazardous air pollutants are required to demonstrate compliance with emission limitations by conducting a comprehensive performance test (CPT). If compliance is demonstrated, the facility’s management files a notice of compliance (NOC) with the state regulatory body. Sources can use any combination of control technologies to achieve the emission standards. The MACT rule has more stringent emissions standards than RCRA for dioxins and furans, including a concentration limitation. In addition, if dioxins or furans are in the feed, a 99.9999 percent DRE applies. There are also numeric limitations for particulate matter, hydrocarbons, and carbon monoxide. For HCl and chlorine gas, emissions must not exceed specific concentration limits. Under MACT, there are numerical emission standards for three categories of metals: mercury, low-volatile metals (arsenic, beryllium, and chromium), and semivolatile metals (lead and cadmium). In addition, a DRE of either 99.9999 or 99.99 percent must be achieved for each POHC designated for the proposed waste feed. As with RCRA, POHCs are specified from the list of hazardous air pollutants on the basis of the degree of difficulty of incineration for the organic constituents in the waste stream or streams, and on their concentration or mass in the waste feed (40 CFR 63.1203). Once a facility successfully completes a CPT that demonstrates compliance with MACT standards and submits an NOC to state regulators, it may operate within guidelines consistent with emissions limits in the facility’s current permit. Under the MACT rule, a CPT to demonstrate compliance with MACT standards is required every 5 yearsin—comparison to a 10-year interval for trial burns under RCRA. In addition, any change in operations or equipment outside the original CPT limits requires a new CPT to be conducted, and operations under the new operating parameters may not commence until CPT results and an NOC have been received by the regulatory authority. Approximately 30 months after each periodic CPT, less comprehensive confirmatory tests are performed to demonstrate continued compliance with MACT standards by collecting gas samples to determine the presence of any dioxins. Under the new RCRA/MACT regulations, when a RCRA incinerator facility demonstrates compliance with MACT air emission standards and limitations by conducting a CPT and submitting an NOC, duplicate RCRA emission requirements no longer apply. Nevertheless, the state agency may continue to apply the RCRA permit emission provisions on a case-by-case basis for purposes of information collection. RCRA permit provisions for all other aspects of the combustion unit and the facility are still applicable (40 CFR 270.10(k) and 270.32(b)(2)). To remove the duplicative air emission/combustion requirements from a RCRA permit prior to its expiration and reissuance, a chemical agent disposal facility would have to request a major RCRA permit modifica-

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements tion (see Box 2-2). This may be done after the facility has successfully completed a CPT and submitted an NOC documenting compliance with the MACT standards. The MACT conditions will then be incorporated into the facility’s CAA Title 5 air permit. However, any terms or conditions that are more stringent or extensive than the MACT requirements will be retained in the RCRA permit if they are necessary to ensure protection of human health and the environment (EPA, 2006). At the time this report was prepared, the state agencies had maintained the requirements and operating parameters established in the existing RCRA permits for all of the baseline incineration system chemical agent disposal facilities, rather than modifying the RCRA permits to eliminate the duplicate RCRA emissions standards and issuing a separate or modified permit under the MACT regulations (i.e., CAA Title 5 permit). Therefore, the incinerators at chemical agent disposal facilities currently must meet both the air emissions requirements in the facility RCRA permits, as well as the requirements under the new MACT regulations, whichever are more stringent. The state agencies maintain that they have incorporated the MACT standards into their regulatory schemes in a manner that will not result in duplication of effort or conflicting regulatory requirements by adopting the MACT emission criteria into the RCRA permit in coordination with the state CAA permitting division. TRIAL BURN PROCEDURES AT CHEMICAL AGENT DISPOSAL FACILITIES Overview At chemical agent disposal facilities, the first trial burns performed are those that use surrogate chemicals that are more difficult to destroy than the chemical agent they simulate. These trial burns are called surrogate trial burns (STBs). STBs are subsequently followed by agent trial burns (ATBs) that use actual chemical agent. Thus, all chemical agent disposal facilities with a baseline system hazardous waste incinerator have completed STBs and ATBs for each agent that has been or is currently being treated.2 The facility permits have been BOX 2-2 RCRA Permit Modification Classification and Public Comment A RCRA permit may be modified at the discretion of EPA or the authorized state or upon the request of the facility management. There are three classes of permit modifications initiated by the permittee: Class 1 permit modification. Initiated for routine changes such as upgrading plans and records maintained at the facility. Class 2 permit modification. Initiated for a technical advancement, a minor process change, changes in the type or quantity of waste managed, or a change necessary to comply with new regulations without substantial change to design specification. Class 3 permit modification. Initiated for major changes that substantially alter the facility or its operations. All three classes of modifications require that the permittee send a notice of the modification to all persons on the facility mailing list. Inclusion on a RCRA facility mailing list is typically accomplished by submitting a written request. Class 2 and 3 permit modifications trigger requirements for public notice, solicitation of comments, and, in some cases, a public meeting. SOURCE: 40 CFR 270.42; 40 CFR 124. issued or modified to contain specific air emission limitations and operating parameters based on the results of those STBs and ATBs. Table 2-1 shows the critical pollutant emissions measured during trial burns. Under RCRA regulations, a trial burn must be conducted prior to initial start-up and whenever a new waste stream or new operating parameter is proposed. The RCRA trial burn plan submitted for regulatory agency approval under either a permit application or permit modification application must contain the following (40 CFR 270.62): A detailed description and analysis of each waste, A detailed engineering description of the incinerator, A detailed description of sampling and monitoring procedures, 2 As explained in more detail in the following sections, an STB uses a surrogate material to represent the chemical agent or surrogate POHC. The surrogate is a chemical that is more difficult to burn (break the bonds).

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 2-1 Typical Trial Burn Critical Emissions and Performance Standards Performance Standards Agent Trial Burn Minimum DREs for applicable principle organic hazardous constituents 99.9999% (LIC, agent) 99.9999% (MPF, agent) for heels greater than 5% or 99.99% for heels equal to or less than 5% 99.99% (DFS, agent) 99.99% (DFS, agent) 99.99% (DFS; propellant, explosive, and pyrotechnic feed) Particulate matter emission limit 0.013 grains/dscfa (29.75 mg/dscmb) at 7% O2 Mercury 130 μg/dscm at 7% O2 Semivolatile metals (Pb, Cd) 230 μg/dscm at 7% O2 Low-volatility metals (As, Be, Cr) 92 μg/dscm at 7% O2 Hydrogen chloride/chlorine (HC1/C12) emission limit 32 ppmv total HC1 and C12 expressed as HC1 equivalents at 7% O2 Toxic metals emission limits At levels determined by the regulatory agency to be protective of human health and the environment Dioxins and furans TEQc 0.4 ng/dscm at 7% O2 CO emission limit, 60-min rolling average 100 ppmv at 7% O2 Emission limits for chemical agents   GB 0.0003 mg/m3 H/HD/HT 0.03 mg/m3 VX 0.0003 mg/m3 adscf, dry standard cubic foot. bdscm, dry standard cubic meter. cToxic equivalency quotient (TEQ) is the amount of 2,3,7,8-TCDD (2,3,7,8-tetrachlorodibenzo-p-dioxin) with toxicity equivalent to a complex mixture of 210 dioxin and furan isomers with 4 to 8 chlorine atoms found in flue gases. This equivalency is based on the International Toxic Equivalence Factor scheme adopted by the EPA and most countries to simplify the reporting of dioxin emissions. SOURCE: Adapted from UDEQ, 2001. A detailed test schedule and protocol, and A description of planned procedures for both normal and off-normal operating conditions. According to 40 CFR 63.1207(f), a MACT CPT must include An analysis of each feed stream, including hazardous waste and other fuels, A highly detailed treatment of certain organic hazardous air pollutants, A detailed engineering description of the incinerator, A detailed description of sampling and monitoring procedures, A detailed test schedule and protocol for each hazardous waste, A description of planned procedures for both normal and off-normal operating conditions, and Additional detailed technical and procedural information. In general, state agencies may accept RCRA trial burn results for a facility’s initial CPT, and the next CPT would be required within 61 months of the date of that RCRA trial burn. Trial Burn Phases The following information from the RCRA permit for the Umatilla Chemical Agent Disposal Facility (UMCDF) is based on 40 CFR 264.343(c) and is typical of the permits for other baseline incinerator disposal facility sites. The phases apply to each incinerator at each site, except as noted in the discussion below. Shakedown Period A shakedown period is the time during which an incinerator is brought to a state of operational readiness necessary to conduct a trial burn. The shakedown period is initially limited to 720 hours of operating time; if needed, an additional 720 hours can be requested.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Surrogate Trial Burn Because chemical warfare agents are extremely toxic, incinerator performance must be demonstrated for each incinerator before a chemical agent is introduced. This is accomplished by a trial burn using a surrogate material (surrogate POHC) to represent the chemical agents. Perchloroethylene and monochlorobenzene are two of the surrogate POHCs used at chemical agent disposal facilities. One STB is required per incinerator. The objectives of the STBs are to Establish that the incinerator can process chemicals that are more difficult to destroy than the actual waste chemicals they will process, Demonstrate a DRE of 99.9999 percent, Verify that the particulate matter emissions do not exceed 0.015 grains per dry standard cubic foot, Establish maximum chlorine feed rates while maintaining HCl emissions below permit levels, Verify that emission levels of products of incomplete combustion, such as carbon monoxide, do not exceed the specified limit, Establish maximum metal feed rates, and Establish maximum surrogate feed rates. The primary regulatory and permit limits with which a facility must comply under RCRA are the POHC DRE and emissions limits for NOx, HCl, dioxins and furans, metals, particulate matter, and carbon monoxide. STBs are conducted under three conditions, each requiring three separate test runs. The first condition is a low-temperature test for the purpose of demonstrating that the DRE of two POHCs meets or exceeds 99.9999 percent when they are processed at lower temperatures. The second condition is a high-temperature test (HTT) using the same POHCs designated for the low-temperature test, plus ethylene glycol and 21 metal oxides to determine metal emissions. The third condition is an HTT using the pollution abatement system filtration system (PFS). Both HTT conditions use the same surrogates and additives, but additional metal oxides are fed in this third condition test to determine the metal removal efficiency of the PFS. Agent Trial Burn An agent trial burn (ATB) is conducted prior to processing each new agent at a chemical agent disposal facility. During the ATB, actual chemical agent is burned under the most severe case operating parameters, e.g., maximum feed rates and off-normal operating parameters that will still allow demonstration of the incinerator’s compliance with regulations and pertinent permit requirements. If compliance is successfully demonstrated under such nonideal conditions, it is assumed that compliance can be achieved during normal operations. Post-Trial-Burn Operation Following an ATB, an incinerator’s feed rate is restricted to 50 percent of the feed rate used during the ATB until regulatory approval of the preliminary ATB data is provided. Upon approval, feed rates may be increased to 75 percent of the ATB feed rate. This preliminary approval typically takes approximately 30 days. The facility must await regulatory approval of the final ATB report before moving to 100 percent of the ATB feed rate. This is a lengthy process, and in some instances, the disposal facilities have completed destroying a given chemical agent without ever obtaining final approval for 100 percent feed rate operations. There are three primary reasons for the lengthy regulatory approval process. First, the ATB reports are very long and complicated and may contain as many as 20,000 pages. The site verifies and validates the documents in detail (ensures that all the data are accurate and consistent) before submitting them to the state regulators. Next, once the report has been submitted, the regulators review it in detail and issue a letter noting any and all deficiencies in the report, essentially constituting a RCRA notice of deficiency. And finally, extensive communications that can take months to complete then ensue between the site and the regulators.3 Once an ATB is complete and the trial burn report and data have been submitted to the state, the state’s approval of the move to full-rate operations depends on its regulatory staff ’s experience with and confidence in the operating facility. If a health risk assessment (HRA) is required, still more time will be required to obtain approval to move to the full-rate operations. 3 Personal communication between Mike Strong, UMCDF Deputy Site Project Manager, and Billy Williams, NRC study director, December 4, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 2-2 Completed and Still-Scheduled Trial Burns Across Operating Chemical Agent Disposal Facilities Site LIC 1 LIC 2 DFS MPF Totals (C + S) STB GB VX H/HD STB GB VX H/HD STB GB VX H/HD TSCA STB GB VX H/HD 2nda JACADSb   C             C       4C       C C 8 TOCDF C C D D C C C C C C C   2C C C C S 3C 18 ANCDF C C S S         C C S S C C C S S C 14 UMCDF C C S S C C S S C C S S C C C S S C 18 PBCDF C C S S         C C C S C C S S S S 14                                       72 NOTE: ANCDF, Anniston Chemical Agent Disposal Facility; C, completed burns; D, indicates data used in lieu of a trial burn; DFS, deactivation furnace system; GB, a nerve agent, also known as sarin; H, mustard agent, a blistering agent; HD, distilled mustard agent, a blistering agent; JACADS, Johnston Atoll Chemical Agent Disposal System; LIC, liquid incinerator; MPF, metal parts furnace; PBCDF, Pine Bluff Chemical Agent Disposal Facility; S, scheduled burns; STB, surrogate trial burn; TOCDF, Tooele Chemical Agent Disposal Facility; TSCA, Toxic Substances Control Act; UMCDF, Umatilla Chemical Agent Disposal Facility; and V X, an organophosphate nerve agent. aThis column is for a second set of waste trial burns to meet new requirements and which are being added through permit modifications. bJACADS requirements were set prior to issuance of the EPA’s 1993 Hazardous Waste Combustion Strategy. SOURCE: Adapted from a chart provided to the committee by the U.S. Army Chemical Materials Agency on August 1, 2006, and updated in January 2007. CHEMICAL AGENT DISPOSAL FACILITY EXPERIENCE TO DATE WITH TRIAL BURNS The committee obtained trial burn information for each chemical agent disposal facility. This information is summarized in Table 2-2, which provides the CMA’s anticipated trial burn activity and plans as of September 2006. In general, STBs and ATBs for nerve agent GB were the first trial burns to be performed. This is because risk assessments have shown GB munitions pose the greatest risk to the public. The requirements and trial burn experiences for each site are discussed in the sections that follow. Anniston Trial Burn Experience Prior to agent operations, STBs were carried out for each of the three furnaces at the Anniston Chemical Agent Disposal Facility (ANCDF): the liquid incinerator (LIC), the deactivation furnace system (DFS), and the metal parts furnace (MPF). GB ATBs were conducted for the LIC and DFS in 2003 and for the MPF in 2005. In 2006, VX ATBs were conducted for the LIC and DFS. A DRE performance test was conducted on the MPF in 2006, and MPF VX ATBs are planned for 2007.4 After an ATB, the Alabama Department of Environmental Management allows ANCDF to operate at 50 percent of the ATB feed rate for 30-45 days. ANCDF then operates at 75 percent of the ATB feed rate until the trial burn report is reviewed and approved, which takes about 6 months. No special testing is done to support HRAs. Instead, HRAs are conducted with emissions data gathered at the maximum feed rates during the ATBs. Pine Bluff Trial Burn Experience STBs were conducted for the three Pine Bluff Chemical Agent Disposal Facility (PBCDF) incinerators: the DFS, the LIC, and the MPF. These were followed by GB ATBs that were conducted between mid-October and early November 2005. VX ATBs are scheduled to occur in April 2008. CMA has negotiated with Arkansas state regulators to include only a DRE test in the VX ATBs. Mustard agent ATBs are currently scheduled to occur between late December 2009 and early January 2010.5 Umatilla Trial Burn Experience STBs were begun in early 2003 and have been completed for the four incinerators at UMCDF: LIC1, LIC2, DFS, and MPF. GB LIC1 shakedown runs began in October 2004, followed by GB ATBs in June and 4 Tracy Smith, Compliance Engineer, Washington Group International, “ANCDF secondary waste incineration tests,” Presentation to the committee on October 16, 2006. 5 Personal communication between Clara Moraga, PBCDF Deputy Project Manager, and James Myska, NRC staff, December 22, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements July 2005 for LIC1 and the DFS, in March 2006 for the MPF, and in June 2006 for LIC2. The shakedown runs for processing secondary waste in the MPF began in October 2006, and the secondary waste trial burn was completed in January 2007. VX ATBs are anticipated for January 2008.6 Tooele Trial Burn Experience STBs and ATBs for nerve agent GB were conducted on each of the four incinerators at TOCDF (one DFS, one MPF, and two LICs) when the facility started up in the mid-1990s. The STBs were used to demonstrate that the incinerators were operationally ready to begin feeding agent rather than to establish incinerator operating parameters and were required to be conducted only once before GB operations commenced. TOCDF has since conducted separate ATBs for each of the stockpile chemical agents stored at Deseret Chemical Depot. An ATB was performed on only one of the two LICs when TOCDF began VX destruction operations. The ATB results from LIC2 were used as data in lieu of performing a VX ATB on LIC1. The VX ATBs for LIC2 were performed under two trial burn conditions, high and low temperature, requiring a total of six test runs (three test runs under each condition). The same LIC ATB permitting approach was used in the mustard agent disposal campaign. The mustard agent ATBs were performed as follows: A single condition was used for the LIC ATB for a total of three test runs. Two conditions were used for the MPF ATB, three test runs to establish the DRE and three test runs to determine the emissions associated with the incineration of solid agent heels. An ATB for the DFS was not required for the mustard agent campaign, as no energetics will be fed through the DFS, but a MACT-rule CPT was required for the DFS. After the PFS is installed at TOCDF, a demonstration of its ability to control mercury emissions will be required. This will not be a trial burn in the strict sense because there is no requirement to demonstrate attainment of a required POHC DRE.7 COMPARISON WITH TRIAL BURN EXPERIENCE IN COMMERCIAL INDUSTRY OPERATIONS Trial burns at both commercial incinerators and the Army’s chemical agent disposal facilities are tailored to meet proposed operational requirements at their specific sites, under the applicable regulations governing that site. In response to a committee query, a DuPont and Company environmental manager replied as follows: Each incinerator test burn is unique and specific to the regulation being addressed. Each component of the test burn is determined by the test objectives and is unique from sampling requirements to test methods to data reporting, and is in many cases all or in part determined by the specific regulation.8 This is also true for trial burns at the U.S. Army’s chemical agent disposal facilities. Table 2-3 shows representative data on industry trial burns, and trial burns at the Johnston Atoll Chemical Agent Disposal System (JACADS) and TOCDF from the 1990s.9 As can be seen in the table, both the commercial facilities and the chemical agent disposal facilities conducted several trial burns under a variety of operating conditions. When conditions were changed, a new trial burn was conducted. For most of the commercial facilities, trial burns were conducted again after several years. At one company, Waste Technologies Industries, annual performance tests were required over a 4-year period. At baseline incineration facilities, CMA has conducted separate campaigns to dispose of each chemical agent and munition type because of monitoring and processing constraints. This approach is reflected in the provisions of the site-specific RCRA permits. In all cases, trial burns have been conducted for each agent destruction campaign at each chemical agent disposal facility. Commercial and industrial incinerators test a range of materials during their trial burns to account for the maximum anticipated feed rates and all the wastes that are slated for incineration in the unit according to the 6 UMCDF RCRA/MACT trial burn history (updated October 30, 2006), provided to the committee by CMA, October 31, 2006. 7 Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, October 17, 2006. 8 DuPont response to committee questions about industrial best practices, September 26, 2006. The DuPont Sabine River Works facility practicing incineration technology is located in the state of Texas. 9 JACADS was the first baseline incineration system disposal facility and was located on Johnston Atoll, approximately 700 miles southwest of Hawaii. Disposal operations at JACADS lasted approximately 10 years and were completed in 2000, after which the facility was closed.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 2-3 Trial Burn Data for Certain Industrial Facilities and CMA in the 1990s Organization Location Trial Burn Dates Trial Burn Purpose Waste Technologies Industries East Liverpool, Ohio Annual performance tests in 1997, 1998, 1999, and 2000   Quarterly tests in 1994 and 1995   Safety Kleen Aragonite, Utah 6/1/2001 Operating limits on all constituents 5/1/1992 Maximum liquid and direct burn feed rate 3/1/1992 Maximum sludge feed rate 3/1/1992 Maximum kiln heat input Ross Environmental Grafton, Ohio 10/1/2000 Low-temperature DRE, high solids, air pollution control device detuned 3/1/1993 Air test, normal operation 3/1/1992 Trial burn DuPont Sabine River Works Orange, Tex. 7/1/2000 Trial risk burn, DRE and metals 8/1/1990 Trial burn, medium temperature, typical operating parameters 8/1/1990 Trial burn, maximum temperature/maximum waste Bayer Corp. New Martinsville, W. Va . 5/1/1992 Trial burn, maximum liquid feed and ash input 5/1/1992 Trial burn, maximum heat input GlaxoSmithKline Research Triangle Park, N.C. 4/1/1999 Trial burn, high-temperature for liquid mode operation 4/1/1999 Trial burn, high-temperature for solid mode operation 8/1/1993 Trial burn, reduced liquid waste feed 8/1/1992 Trial burn, maximum liquid waste feed/maximum heat Upjohn Kalamazoo, Mich. 12/1/1990 Trial burn, part./metals testing, high-solids feed U.S. Army Johnston Atoll 3/1/1992 Trial burn, nominal conditions 4/1/1997 Trial burn, agent GB 12/1/1990 Trial burn, nominal conditions 8/1/1992 Steady-state conditions 2/1/1998 Trial burn, GB U.S. Army Tooele, Utah 6/30/1995 Surrogate trial LIC 1 9/30/2005 Surrogate trial DFS 1/29/1996 Surrogate trial LIC 2 6/4/1996 Surrogate trial MPF 1/7/1997 Trial burn agent GB in DFS 2/26/1997 Trial burn agent GB in LIC 1 4/4/1997 Trial burn agent GB in MPF 8/20/1997 Trial burn agent GB in LIC 2 NOTE: DFS, deactivation furnace system; DRE, destruction and removal efficiency; LIC, liquid incinerator; and MPF, metal parts furnace. SOURCE: EPA, Undated. facility’s permit application and trial burn plan. Their permits usually require that air pollution control equipment and other operating parameters remain the same during operations as they were during the trial burn. In contrast, at chemical agent disposal facilities, trial burns have been conducted whenever an operating incinerator is to begin destruction of a different chemical agent. Such a switch requires the chemical agent disposal facility to change and recalibrate the process and ventilation monitors for the new agent; equipment capable of multiagent monitoring is not available at this time. This changeover is a lengthy process, taking many weeks. In other respects, the general conditions governing the need for and conduct of trial burns at commercial incinerators and chemical agent disposal facilities are quite similar. For both chemical agent disposal facility incinerators and commercial incinerators, a trial burn plan must be submitted and receive regulatory approval prior to conducting the trial burn. A trial burn is then conducted

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 2-4 Comparison of Trial Burn Experience at Industrial Facilities and UMCDF (months)     UMCDF Time Period CRWI Industrial Experience Average Experience Experience Range Trial burn plan submittal to trial burn start 9 (goal); 17 (actual) 10 3-17 Trial burn plan submittal to end of trial burn 15 8 6-10 End of trial burn to trial burn report submission 3 3 2-3 NOTE: CRWI, Coalition for Responsible Waste Incineration; and UMCDF, Umatilla Chemical Agent Disposal Facility. SOURCES: Letter from Melvin E. Keener, Executive Director, CRWI, to Donald Arbuckle, Acting Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget, June 7, 1999. Available online at http://www.crwi.org /textfiles/omb.htm; data provided to the committee by UMCDF, October 31, 2006. and, if it is successful, the disposal facility or the commercial incinerator can proceed over time to full-rate operations. A general notional timeline for the trial burn process at commercial incinerators, obtained from the Coalition for Responsible Waste Incineration (CRWI), suggests the following milestones for the trial burn process:10 Submission of trial burn plan 1 year before the trial burn, Approval of trial burn plan by regulators within 9 months of plan submission, Conduct trial burn within 6 months of plan approval, and Trial burn report to agency within 3 months of trial burn completion. Given the quantity of data that must be analyzed, regulatory agencies in states with multiple incinerators would in the past have had difficulty approving a trial burn plan for commercial facilities within 9 months. CRWI gives some examples of trial burn proposal approval periods that ranged from 5 to 50 months, with an average of 17 months from submission until regulator approval. These data show that in the 1990s, approval for commercial facility trial burns frequently took longer than the target times established by the regulatory agencies. Table 2-4 compares the experience at UMCDF with that cited in the CRWI data. Industrial incinerator permitting time frames seem similar to those at UMCDF. Based on the committee’s information gathering, the use of data in lieu of a trial burn, as allowed under RCRA regulations, has occurred only in industrial operations where similar furnaces are started up at the same location.11 At one Dow Chemical Co. site, data were used in lieu of trial burns for three identical boilers that burn RCRA hazardous waste. The request to do so was submitted as a part of the trial burn plan for one of the three boilers and was approved by the state regulators. Data from the trial burn for one unit were used in lieu of trial burns for the other two identical units. At three other Dow sites, data in lieu of RCRA trial burns and burns for HRAs (discussed later) have been used for boilers and industrial furnaces regulated under RCRA. Each of the three sites had two identical boilers. These requests were granted by either the state or the EPA region depending on which agency was the lead at the time. Dow does not have any examples of data being used in lieu of trial burns for combustion units that are not colocated.12 The committee also found examples where Reilly Chemicals was successful in using data in lieu of trial burns for conducting RCRA certification and compliance on two of three boilers. The three boilers were located at the same facility. Examples of the data presented to make the successful case for data in lieu of trial burns for this commercial facility are provided in a publicly available technical paper (Drake et al., 2000). The company was able to show enough similarity for 10 Melvin E. Keener, Executive Director, CRWI, letter to Donald Arbuckle, Acting Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget, June 7, 1999. Available at http://www.crwi.org/textfiles/omb.htm. 11 Committee sources on data in lieu of trial burns included information from Melvin E. Keener, Executive Director of the CRWI, an industrial group representing 26 companies practicing incineration technology in the United States. 12 Dow response to committee questions regarding industrial best practices, September 26, 2006. Dow Chemical facilities with incineration, boiler, or industrial furnace technology are located in the states of California, Louisiana, Michigan, and Texas.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements three nonidentical units by comparing the process feed streams, the combustion unit design, process operating conditions, process monitoring devices, and maintenance profiles. In the case of chemical agent disposal facilities, when an incinerator begins destruction of a different agent, the same equipment is used except the monitoring devices are recalibrated for the specific agent. Using the previous operating data on this incinerator in conjunction with operating data from a similar incinerator at the same or another site for the same agent appears to be a proper application of the data in lieu of a trial burn regulatory mechanism available under RCRA. Oregon regulators responsible for UMCDF have said they expected such an approach from the Army. Considerable time is sometimes required to obtain approval and proceed to full-rate incinerator operations after submission of trial burn results. Because of the size and complexity of the task for trial burn report review and approval, increased resources and specific trial burn and regulatory skills could greatly speed the process. It is an accepted practice to provide funding to a regulatory agency so that it can hire a third party to support regulatory reviews.13 Generally, industrial facilities do not ramp up feed rates prior to receiving approval of trial burn results. They proceed to full-rate operations upon receiving regulatory approval. Prior to approval, they continue to operate under their existing permit limitations. On the other hand, the ramp-up provisions found in RCRA permits for all chemical agent disposal facility incinerators allow the chemical agent disposal sites to process the new agent prior to obtaining final approval of the agent trial burn results, something not done in industry. All commercial TSDFs and all chemical agent disposal facilities must adhere to permit operating parameters, including feed rates, temperatures, and other combustion criteria. In addition, all commercial TSDFs and chemical agent disposal facilities must meet both the RCRA and the MACT air emission limitations. There is little difference in the treatment of commercial TSDFs and chemical agent disposal facilities under MACT. Under the RCRA regulations for trial burns, both TSDFs and chemical agent disposal facilities must conduct trial burns for initial start-up and whenever there is a process change or when a new waste stream or a higher feed limit for a waste contaminant is requested. Finding 2-1. An examination of the situation concerning trial burn requirements for incinerators at chemical agent disposal facilities has led to several observations: Surrogate trial burns demonstrate that incinerators at chemical agent disposal facilities can operate safely. The requirement to perform surrogate trial burns at these facilities is consistent with the initial start-up procedures followed at commercial hazardous waste incineration facilities. In the earlier phases of the Army’s Chemical Stockpile Disposal Program, an agent trial burn conducted for each incinerator with each agent to be processed was an appropriate way for disposal facility staff and state regulatory staff to gain operational experience and confidence in the performance of the incinerators. As the Chemical Stockpile Disposal Program has matured, there has been only limited use of the data-in-lieu-of regulatory mechanism provided for in the Resource Conservation and Recovery Act. This provision, if applied more extensively to chemical agent disposal facilities, could allow data from other similar incinerators at chemical agent disposal facilities to be used in lieu of conducting additional agent trial burns. Recommendation 2-1. The Chemical Materials Agency should vigorously pursue the application of the Resource Conservation and Recovery Act provision for using trial burn data from other similar chemical agent disposal facility incinerators in lieu of conducting trial burns for additional agents. This is a reasonable way to proceed now that (1) at least one agent trial burn has occurred for each type of agent in each type of incinerator at all the chemical agent disposal facilities and (2) a surrogate trial burn and an initial agent trial burn have occurred for each incinerator at all sites. Finding 2-2. The time required to obtain state regulatory approval to proceed to a full feed rate following submission of agent trial burn data for incinerators at chemical agent disposal facilities can be lengthy. This 13 For example, there is a memorandum of understanding (MOU) for direct funding of regulatory review efforts: memorandum from William J.B. Pringle, Chief, Environmental and Monitoring Office, Program Manager for Chemical Demilitarization to John L. Matthews, Utah Office of Planning and Budget, February 23, 1999.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements is a consequence of the volume and complexity of the documents filed, as well as limited state regulatory agency resources to review and analyze them. Recommendation 2-2. The Chemical Materials Agency should seek to provide funding to state authorities for third-party or other support to facilitate the analysis and disposition of trial burn data. This would shorten the time needed to obtain approval for incinerators at chemical agent disposal facilities and allow them to proceed more rapidly to a full processing rate. HEALTH RISK ASSESSMENTS HRAs are a means of estimating the potential for an adverse effect on a select population upon exposure to a single chemical or mixture of chemicals. This risk is generally defined as a function of the concentration of chemical(s) to which an individual of known size and specified characteristics is exposed, for a given period of time, via ingestion, inhalation, or dermal contact. HRAs are performed for acute and chronic exposures of both on-site and off-site populations. Regulatory Basis for Health Risk Assessments Federal Regulatory Requirements There is no federal statutory or regulatory requirement to conduct HRAs for hazardous waste incinerators. However, the 2005 final MACT rule added language to the RCRA regulations to provide authority for state permitting agencies to require HRAs on a case-by-case basis and add conditions to RCRA permits based on HRA results (40 CFR 270.10(l) and 270.32(b), respectively). Prior to this change, HRAs could be required by permitting agencies based on the general RCRA “omnibus authority.” State-Specific and Permit-Specific Requirements The hazardous waste regulations of Alabama, Arkansas, Oregon, and Utah do not require an HRA as a condition for obtaining a RCRA hazardous waste incinerator permit. However, state authorities have required HRAs at each of the chemical agent disposal facilities based on the RCRA omnibus authority. The RCRA permits for ANCDF, PBCDF, UMCDF, and TOCDF all require that an HRA or an HRA addendum be submitted after each trial burn or performance test. Indiana, as a condition of granting a permit for an incinerator that generates or treats a hazardous waste associated with chemical munitions, by statute, requires proof from the facility that its emissions, alone or in combination with other substances, pose no risk of an acute or chronic human health effect or of adverse environmental effect (Indiana Code 13-22-3-10(a)(2)). However, neither the Indiana Department of Environmental Management regulations nor the Newport Chemical Agent Disposal Facility (NECDF) permit specifically calls for submission of an HRA.14 Site-specific HRAs have been performed for the vast majority of commercial hazardous waste incinerators15 and for all of the chemical agent disposal facilities. The data necessary to conduct an HRA are obtained from trial burns (40 CFR 271.19, 264.342, and 264.343). If an HRA is to be developed prior to trial burns at either industrial facilities or chemical agent disposal facilities, data from comparable facilities or the MACT standards could be used. The Hazardous Waste Combustion MACT rule states that a site-specific risk assessment is recommended for a specific site if the MACT controls do not sufficiently protect human health. If the MACT standards are sufficiently protective of health and the emissions are below the MACT standards, a new HRA is not typically required. Chemical Agent Disposal Facility Health Risk Assessments Because chemical agent disposal facilities are based on one of two general categories of technology, incineration or neutralization (hydrolysis), it is necessary to address the HRAs for these facilities in a manner that recognizes these technological differences. Incineration-Based Chemical Agent Disposal Facilities Each incinerator at a chemical agent disposal facility presents a potential source for worker and public 14 The reader is reminded here that NECDF uses a neutralization (caustic hydrolysis) process to destroy the bulk VX stored at the Newport Chemical Depot. An incinerator is not part of the process. 15 The committee’s information gathering on industrial facilities for this report, including the 26 facilities represented by the CRWI, found only one facility, located in a very remote geographic region and with no significant receptors, that was not required to conduct an HRA.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements exposure to the products of incineration. The HRA risk calculations for this type of facility are carried out according to recommended EPA methods. State regulators also strongly influence how HRAs are conducted at chemical agent disposal facilities, which means that HRA requirements for sites using incineration technology can vary from state to state. Before any incinerator operations begin, an original, or baseline, HRA is conducted.16 This baseline is then updated upon completion of ATBs for each agent campaign. Only minor differences in risk estimates have been found between baseline HRAs and later updates based on actual emissions data. This is true for all four chemical agent disposal facilities using the Army’s incineration technology. For each potential exposure source, various exposure scenarios and populations are examined. For the HRA for TOCDF, for instance, these included subsistence ranchers, residents, workers, and people engaged in various nearby recreational activities. Potential emissions release into, and transport through, the environment are modeled considering all applicable media, e.g., air, water, and solids, to provide exposure estimates.17 Potential chemicals of concern resulting from incineration operations are identified prior to any trial burns, as part of the permitting process. Typically, a few hundred chemicals of concern are identified, but only a small sampling are actually present in incinerator emissions. Since actual emissions data were not initially available from disposal facility sites in the continental United States, data from JACADS operations were used until site-specific emissions data became available. Also, if a given chemical of concern is not detected in site emissions, then it is assumed to be present at the minimum detection limit concentration, whether or not it is actually there. Finding 2-3. The same requirements concerning health risk assessments apply to chemical agent disposal facilities and industry. Although the currently applicable laws do not specifically require health risk assessments, state regulatory agencies frequently require them under the authority granted to them by either the new Resource Conservation and Recovery Act/Maximum Achievable Control Technology provisions or general omnibus provisions. Requirements concerning health risk assessments are typically expressed in each site’s RCRA operating permit provisions. Neutralization-Based Chemical Agent Disposal Facility NECDF uses neutralization (hydrolysis) technology instead of incineration. Air emissions were determined to be the only potential source of risk to the surrounding population. The risk assessment approach developed for NECDF concluded that, based on the samples collected, no risk from air emissions exists at this site. Forty-eight chemicals of concern were expected to be present at trace levels. Four sampling events occurred during which none of the chemicals of concern were detected, nor were any volatile organic compounds detected (Rowden et al., 2006). As NECDF is unique among the operating chemical agent disposal facilities in using neutralization instead of incineration, no monitoring data from a comparable hazardous waste facility were available when the permitting process took place. Pursuant to Indiana Code 13-22-10(a)(2), a risk assessment and air monitoring approach had to be developed in conjunction with the Indiana Department of Environmental Management. The Indiana statute requiring a health and environmental risk assessment for NECDF is similar to the Indiana statute requiring risk assessments for gaseous emissions from a PCB incinerator (Indiana Code 13-22-9) and is based on EPA guidelines for HRAs. A full report on the NECDF risk assessment approach is available (Rowden et al., 2006). Finding 2-4. The requirements for conducting a health and environmental risk assessment for the Newport Chemical Agent Disposal Facility are similar to the state of Indiana requirements for a risk assessment of gaseous emissions from a commercial PCB incinerator. These requirements, which are similar to EPA guidelines for health risk assessments, are a reasonable approach to assessing the health risk posed by the NECDF. 16 As mentioned earlier, if the HRA is to be developed prior to trial burns at either industrial facilities or chemical agent disposal facilities, data from comparable facilities or the MACT standards can used in the risk calculations. 17 An example full risk assessment protocol including both health and ecological considerations may be found at http://www.hazardouswaste.utah.gov/HWBranch/CDSection/CDS_Risk_Page.htm.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TRANSPORTATION RISK ASSESSMENTS FOR SECONDARY WASTE U.S. Department of Transportation (DOT) regulations (10 CFR 49) for transporting hazardous materials have been developed over many years and continue to be modified as necessary to protect the public. Adherence to the DOT regulations provides an appropriate level of safety for materials from chemical agent disposal facilities with low levels of agent contamination. DOT regulations do not require or recommend a risk assessment for shippers or carriers of hazardous materials. However, in the case of hazardous waste shipped from chemical agent disposal facilities, a transportation risk analysis can lead to insights for increased risk mitigation commensurate with the levels of residual agent contamination. Risk mitigation considerations include routing to reduce the mileage, population along the route, and/or crash likelihood; additional physical barriers to an uncontrolled release; and control of ambient and/or postaccident environments. To transport a hazardous waste such as dilute caustic solutions, both commercial facilities and Army chemical agent disposal facilities must comply with DOT regulations, including standards for packaging, marking, placarding, vehicular safety, and driver qualification. Although as just mentioned, no explicit risk assessment or safety plan is required by DOT regulations, in the case of NECDF, Indiana Code 13-22-3-7.5 requires an evaluation of potential transportation risks and a transport safety plan for either VX or the hazardous waste derived from the bulk neutralization of VX, currently interpreted as consisting only of the hydrolysate. The committee is aware of three transportation risk assessments involving materials from chemical agent disposal facilities: Hydrolysate from NECDF to satisfy National Environmental Policy Act requirements (Zimmerman et al., 2003), Hydrolysate from NECDF to support a transport safety plan (DuPont, 2004), and 1X wastes from the Aberdeen Chemical Agent Disposal Facility to support the decision to ship wastes off-site (Hessian and Myriski, 2005). Recently, the CMA issued a requirement for sites to perform and document their consideration of transportation risk assessment requirements when evaluating off-site shipping of secondary waste contaminated with more than 1 VSL of agent.18 The committee did not evaluate the above reports in detail but did note one major transportation risk parameter that showed significant variability: the truck crash rate. The difference between the crash rates per mile in the first two reports is due to the use of a bounding rate (using general data) in the first report and a carrier-specific rate in the second report. The third report derived a truck crash rate per billion ton-miles, based on Federal Motor Carrier Safety Administration data for the number of commercial vehicle hazmat crashes divided by the number of commercial vehicle ton-miles. The commercial vehicle accident rate per ton-mile value was multiplied first by 0.59 and then by 0.013 to account for the number of ton-miles for for-hire commercial vehicles and for Class 6 poisons, respectively. These adjustments to the accident rate are inappropriate without consideration of the corresponding hazmat crashes, for which no data were used. The total accident scenario probabilities may be conservative (too high), however, when the probabilities of fire occurring, impact forces sufficiently high, etc. are considered. These probabilities do not appear to have been addressed, and the committee did not review the reports at that level of detail. Finding 2-5. The committee’s examination of how transportation risk assessments for agent-contaminated waste materials are conducted at chemical agent disposal facilities indicated that widely differing models and parameters have been used. A specific problem identified by the committee is that the methodology used for general ton-mile data in transportation risk assessments to achieve a Class 6 ton-mile value is not consistent. Recommendation 2-5. The Chemical Materials Agency should establish consistent and detailed criteria for conducting whatever transportation risk assessments are required to ensure accuracy and uniformity in the expression of results. Finding 2-6. The state of Indiana requirements for an evaluation of transportation risks and for preparing a 18 Off-site shipping and commercial treatment of secondary waste contaminated with greater than 1 vapor screening level (VSL) chemical agent. Memorandum from Kevin J. Flamm, Program Manager for the Elimination of Chemical Weapons, February 6, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements transport safety plan for hazardous waste derived from the neutralization and destruction of bulk VX exceed the regulatory requirements for the transportation of hazardous waste by industry. Recommendation 2-6. The Chemical Materials Agency should continue to perform transportation risk assessments for shipping any secondary wastes from chemical agent disposal facilities with agent contaminant levels >1 VSL, despite the fact that doing so is not a DOT requirement. REFERENCES Drake, J., L. Douglas, and J. Jones. 2000. Reducing the Burdens of Compliance Testing Under Increasing Regulatory Requirements. Presented at the 2000 International Conference on Incineration and Thermal Treatment Technologies, Portland, Oregon, May 8-12. Available online at http://www.cs2inc.com/downloads/Reducing_Burdens.doc. Last accessed March 7, 2007. DuPont (E.I. du Pont de Nemours and Company). 2004. DuPont Technical Assessment on U.S. Army Newport (Indiana) Project: Executive Summary, March 3. Wilmington, Del.: E.I. du Pont de Nemours and Company. EPA (U.S. Environmental Protection Agency). Undated. Data Summary: Incinerators, Semi Volatile Metals. Available online at www.epa.gov/epaoswer/hazwaste/combust/finalmact//sumshtpdf/incn/inc-svm-07-05.pdf. Last accessed March 6, 2006. EPA. 2000. RCRA, Superfund and EPCRA Hotline Training Module: Introduction to Hazardous Waste Incinerators (40 CFR Parts 264/265, Subpart O), EPA 530-R-99-052, February. Washington, D.C.: EPA Office of Solid Waste and Emergency Response. EPA. 2006. Hazardous Waste Combustion NESHAP Toolkit. Available online at http://www.epa.gov/epaoswer/hazwaste/combust/toolkit/permit.htm. Last accessed March 6, 2007. Hessian, R.T., Jr., and M. Myriski. 2005. 1X Waste Ground Transportation Risk Assessment, Rev. 0, May 2. Aberdeen Proving Ground, Md.: U.S. Army Chemical Materials Agency. NRC (National Research Council). 1999. Tooele Chemical Agent Disposal Facility: Update on National Research Council Recommendations. Washington, D.C.: National Academy Press. Rowden, S., J. Brubaker, and R. Irvine. 2006. Risk Assessment Approach to Evaluation of Airborne Releases from a Chemical Demilitarization Facility, March 2. Newport, Ind.: Newport Chemical Agent Disposal Facility. UDEQ (Utah Department of Environmental Quality). 2001. Title V Operating Permit for Deseret Chemical Depot, June 19. Salt Lake City, Utah: Utah Department of Environmental Quality, Division of Air Quality. Zimmerman, G.P., J.T. Ensminger, and J.W. Saulsbury. 2003. Transportation Analysis for the Off-site Shipment of Liquid Process Effluent from the Newport Chemical Agent Disposal Facility at the Newport Chemical Depot, Indiana, December. Aberdeen Proving Ground, Md.: U.S. Army Chemical Materials Agency.