3
Site-Specific Analyses of Major Secondary Waste Issues

Chapter 3 presents a discussion and analysis of the main secondary waste streams generated at each of the four baseline incineration chemical agent disposal facility sites,1 as well as the waste streams generated at the Newport Chemical Agent Disposal Facility (NECDF) neutralization disposal facility for bulk VX. There are significant similarities among the secondary wastes generated at the four incineration facilities despite some differences in the inventories of specific weapons and chemicals to be disposed of at each facility. There is, however, a difference in the way each facility approaches the management of these wastes, largely because of the regulatory and permitting differences (see Chapter 1). Stakeholder involvement, another highly important part of the regulatory and management process for chemical agent secondary waste at each site, is discussed later in this chapter.

The main waste streams generated at chemical agent disposal facilities and examined in detail in this report with respect to their waste characterization and disposal requirements are as follows:

  • Spent activated carbon;

  • Brine solutions or brine salts;

  • Dunnage, consisting primarily of wooden pallets;

  • Metal from munitions or ton containers;

  • Plastics, particularly spent personal protective equipment (PPE); and

  • Spent decontamination solutions.

Many of these wastes are effectively disposed of during operations. However, current permit requirements and other process limitations have resulted in significant quantities of these wastes accumulating on-site. Hydrolysate from the neutralization of the VX stockpile at Newport, a unique liquid waste stream among the wastes generated at the active chemical agent disposal facility sites, has also accumulated on-site. Specific quantities, issues, and comparisons associated with each of the main waste streams generated at the active disposal facilities are detailed in the remainder of this chapter.

OVERVIEW OF SECONDARY WASTE INVENTORIES

Significant amounts of secondary wastes are generated at each site as a result of operations, and additional quantities of wastes will be generated during closure operations. Closure wastes will be discussed separately in Chapter 4. In Chapter 3, the secondary wastes generated as a result of operations are identified by type, followed by a discussion of the challenges faced by each site.

The secondary wastes at chemical agent disposal facilities were summarized in Chapter 1 and profiled in Table 1-2. Some of them, depending on the site, are disposed of concurrently with the operations to

1

These are the Anniston Chemical Agent Disposal Facility (ANCDF), the Pine Bluff Chemical Agent Disposal Facility (PBCDF), the Tooele Chemical Agent Disposal Facility (TOCDF), and the Umatilla Chemical Agent Disposal Facility (UMCDF).



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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 3 Site-Specific Analyses of Major Secondary Waste Issues Chapter 3 presents a discussion and analysis of the main secondary waste streams generated at each of the four baseline incineration chemical agent disposal facility sites,1 as well as the waste streams generated at the Newport Chemical Agent Disposal Facility (NECDF) neutralization disposal facility for bulk VX. There are significant similarities among the secondary wastes generated at the four incineration facilities despite some differences in the inventories of specific weapons and chemicals to be disposed of at each facility. There is, however, a difference in the way each facility approaches the management of these wastes, largely because of the regulatory and permitting differences (see Chapter 1). Stakeholder involvement, another highly important part of the regulatory and management process for chemical agent secondary waste at each site, is discussed later in this chapter. The main waste streams generated at chemical agent disposal facilities and examined in detail in this report with respect to their waste characterization and disposal requirements are as follows: Spent activated carbon; Brine solutions or brine salts; Dunnage, consisting primarily of wooden pallets; Metal from munitions or ton containers; Plastics, particularly spent personal protective equipment (PPE); and Spent decontamination solutions. Many of these wastes are effectively disposed of during operations. However, current permit requirements and other process limitations have resulted in significant quantities of these wastes accumulating on-site. Hydrolysate from the neutralization of the VX stockpile at Newport, a unique liquid waste stream among the wastes generated at the active chemical agent disposal facility sites, has also accumulated on-site. Specific quantities, issues, and comparisons associated with each of the main waste streams generated at the active disposal facilities are detailed in the remainder of this chapter. OVERVIEW OF SECONDARY WASTE INVENTORIES Significant amounts of secondary wastes are generated at each site as a result of operations, and additional quantities of wastes will be generated during closure operations. Closure wastes will be discussed separately in Chapter 4. In Chapter 3, the secondary wastes generated as a result of operations are identified by type, followed by a discussion of the challenges faced by each site. The secondary wastes at chemical agent disposal facilities were summarized in Chapter 1 and profiled in Table 1-2. Some of them, depending on the site, are disposed of concurrently with the operations to 1 These are the Anniston Chemical Agent Disposal Facility (ANCDF), the Pine Bluff Chemical Agent Disposal Facility (PBCDF), the Tooele Chemical Agent Disposal Facility (TOCDF), and the Umatilla Chemical Agent Disposal Facility (UMCDF).

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 3-1 Projected Secondary Waste Inventories in Storage at End of Agent Disposal Operations (tons)a Secondary Waste Stream ANCDF PBCDF UMCDF TOCDF NECDF Total Across All Sites Spent carbon from filters 169 640 761 274 136 1,980 Containerized combustible solidsb 163 18 1327 199 17 1,724 Containerized miscellaneous solids 96 8 27 3 19 153 Containerized DPE/PPE/TAP gear 157 22 80 535 52 846 Metalsc 175 15 0 51 12 253 Subtotal solids 760 703 2,195 1,062 236 4,956 Spent decontamination solutionb 0 0 0 0 318 318 Miscellaneous liquids 8 0 18 40 10 76 Subtotal liquidsd 8 0 18 40 328 394 Total 768 703 2,213 1,102 564 5,350 NOTE: ANCDF, Anniston Chemical Agent Disposal Facility; DPE, demilitarization protective ensemble; NECDF, Newport Chemical Agent Disposal Facility; PBCDF, Pine Bluff Chemical Agent Disposal Facility; PPE, personal protective equipment; TAP, chemical protective clothing made primarily of butyl rubber; TOCDF, Tooele Chemical Agent Disposal Facility; and UMCDF, Umatilla Chemical Agent Disposal Facility. aSite managements’ best estimates as of January 2007. bExcludes solids or liquids treated on-site in metal parts furnace or shipped off-site for treatment and disposal. cExcludes metals to smelter recycle or off-site landfill disposal. dExcludes Newport hydrolysate. SOURCE: Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, December 11, 2006. destroy the chemical weapons stockpile. Disposal is either off-site at a permitted treatment, storage, and disposal facility (TSDF) or by treatment on-site when the facilities are not engaged in the primary mission of agent and munitions destruction. The projected profile and quantities of secondary wastes remaining in inventory at the end of operations at each of the five currently operating chemical agent disposal facilities, based on current disposal practices, are shown in Table 3-1. A profile of secondary wastes currently shipped off-site for treatment and the disposal methods are given in Table 3-2. GENERAL WASTE CHARACTERIZATION CONSIDERATIONS Generator knowledge may be used to make a determination that a waste from a chemical agent disposal facility never came into contact with agent and therefore is not agent-contaminated when it is declared a waste. In that case, these secondary wastes are designated not as hazardous wastes but as solid wastes unless they possess some other characteristic of a hazardous waste or are a listed waste. Where a waste material was in an environment in which contact with chemical agent could have occurred, the waste must be characterized before it may be shipped off-site. Agent-contaminated waste streams may be certified as chemical-agent-free (1) if analysis show levels not greater than or equal to the applicable waste control limits (WCLs) or (2) if the waste has been subjected to thermal treatment at 1000°F for 15 minutes. Waste Control Limits and Vapor Screening Level The Resource Conservation and Recovery Act (RCRA) permits for all of the baseline incineration facilities specify a WCL below which a specific waste may be shipped off-site for additional treatment or ultimate disposal.2 Generally, if the extractive analysis of a waste shows the concentration of agent to be not greater than or, at most, equal to the WCL, the waste is considered nonhazardous for chemical agent and may be disposed of off-site. The WCL is defined as 20 parts per billion (ppb) for GB and VX and 200 ppb 2 Permitted methods for off-site disposal of secondary waste vary from case-to-case, factoring in environmental considerations such as the potential environmental persistence of waste contaminants. Discussion of degradation rates for trace amounts of chemical agents under a variety of conditions are available in Waysbort et al. (2004), Bartelt-Hunt et al. (2006), and Columbus et al. (2006). Land disposal of hazardous waste is governed by Subtitle C of RCRA (40 CFR Parts 264/265). For landfill requirements, see 40 CFR Parts 264/265, Subpart N.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 3-2 Treatment and Disposal Methods Used for Secondary Wastes Shipped Off-site During Agent Disposal Operations Waste Category Secondary Waste Stream Primary Off-site Treatment/Disposal Method Site ANCDF PBCDF UMCDF TOCDF NECDF Containerized solids Refractory brick, slag, or furnace ash Stabilization/ landfill X X X X   PAS solids and spent filter media Landfill   X X X   Miscellaneous debris Incineration   X X   X Containerized liquids Laboratory waste Incineration X X X   X Paint-related waste Incineration X X X X X Bulk solids Metal Smelting or landfill X X X X X Dunnage Landfill X   X     Brine salt Landfill     X     Bulk liquids Brine liquid Stabilization/ landfill X X   X   Decontamination solution Incineration   X     X NOTE: ANCDF, Anniston Chemical Agent Disposal Facility; NECDF, Newport Chemical Agent Disposal Facility; PAS, pollution abatement system; PBCDF, Pine Bluff Chemical Agent Disposal Facility; TOCDF, Tooele Chemical Agent Disposal Facility; and UMCDF, Umatilla Chemical Agent Disposal Facility. SOURCE: Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, December 11, 2006. for HD at all chemical agent disposal facilities except UMCDF3 (ADEM, 2006; ADEQ, 2006; ODEQ, 1997; UDEQ, 2004). These values were originally derived from Army chemical agent regulations for workforce drinking water standards. Most chemical agent disposal facility RCRA permits have adopted the procedures set forth in U.S. Environmental Protection Agency (EPA) Publication SW-846 as the primary analytical methodology for waste stream characterization. However, in cases where there is the potential for the waste to be agent-contaminated, some methodologies used by individual facilities have been specifically approved for certain wastes. For liquid wastes, or wastes that can yield a liquid “leachate,” the EPA-approved methodology is the toxicity characteristic leaching procedure (TCLP). Other methodologies may be used if approved by the EPA or the state regulatory agency. In addition to extractive analysis techniques, other analytical and process metrics are routinely used to characterize and profile the hazard level of chemical agent in secondary waste at chemical agent disposal facilities. These include the short-term exposure limit (STEL), the vapor screening level (VSL), the short-term limit (STL), and the Army’s 0, 1X, 3X, and 5X designations for various levels of agent contamination. These metrics are explained briefly below and summarized in Table 3-3. The STEL is defined as the maximum vapor concentration to which unprotected workers can be exposed for up to 15 minutes (as often as four times in an 8-hour workday) without any adverse health effect. Exposure limits are measured in milligrams of agent per cubic meter of air and are set for each specific agent. STELs and other health-based concentration standards were established by the Army in coordination with the Centers for Disease Control and Prevention (CDC) and are used to establish industrial hygiene guidelines and monitoring standards for worker safety. Monitoring is conducted using equipment capable of measuring the chemical agent level in real time or near real time, ensuring the 15 minutes associated with the STEL is 3 The UMCDF permit refers to this not as a WCL but as a permit compliance concentration (PCC). The PCCs at UMCDF are slightly lower than the WCLs used at other chemical agent disposal facilities and are discussed later in this chapter and listed in Table 3-8.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 3-3 Waste Control Limit Screening Criteria for Off-site Management of Chemical Agent Disposal Facility Secondary Waste Agent Contaminant Direct Measurement (Extraction)a (ppb) VSL (Vapor Screening Level)b Process Decontamination Historyc GA, GB 20 1 STLd (0.0001 mg/m3) 5X VX 20 1 STL (0.00001 mg/m3) 5X HD 200 1 STL (0.003 mg/m3) 5X aAnalytical methods defined in site waste analysis plan: ppb, parts per billion by volume (1 molecule in 1 billion). bVSL ≥ 1 short-term limit (STL) used via permit modification; STL, short-term exposure limit without the time component. c5X, agent-free based on thermal decontamination at 1000°F for 15 minutes. Site-specific permit modifications allow different waste control limits to be used. dSTL, short-term limit. SOURCE: Rob Malone, CMA Task Manager for Closure and Secondary Waste Disposal, “Secondary waste background and management criteria by site,” Presentation to the committee, August 2, 2006. not exceeded. The STL is a concentration typically expressed in terms of milligrams of a specific agent per cubic meter of air. It is similar in numerical value to the exposure limits found in the STEL but without the 15-minute time component. A VSL is a control limit used to clear materials for off-site shipment based on agent concentration in the atmosphere above the packaged waste materials. A VSL has been incorporated into the RCRA permits for ANCDF and PBCDF for use in characterizing solid waste streams that are not amenable to other analysis methodologies. A VSL is also used at TOCDF and NECDF to group and classify various wastes. The VSL in the PBCDF RCRA permit is currently <1 STEL (ADEQ, 2006). The VSL in the ANCDF RCRA permit is currently established at ≤1 STL (ADEM, 2006). The Army also uses the designations 0, 1X, 3X, or 5X (defined in Box 3-1) to characterize and classify the agent contamination level of exposed materials. These nonanalytical designations reflect the decontamination treatment a specific waste has received. Due to the toxicity of the nerve and mustard agents and the hazard and risk associated with them, the Army has developed specific criteria based on the concentration of agent vapors in air to determine the potential for equipment to be agent contaminated. These criteria are covered in detail in an Army policy guidance document (U.S. Army, 2004). Site-Specific Characterization According to Permit Requirements Anniston The Anniston Chemical Agent Disposal Facility (ANCDF) RCRA permit language defines “chemical agent free” as agent concentrations below the lowest achievable method detection limits as specified by the analytical method used. In addition, at ANCDF, under a recent permit modification, certain solid wastes not exposed to chemical agent liquids or to vapors >1 STL are deemed to be nonhazardous with respect to chemical agent and may be disposed of off-site in accordance with the applicable solid waste regulations. Under the ANCDF waste analysis plan, where an EPA analytical methodology exists, it must be used to determine whether a sample contains agent or other toxic constituents. Methods developed by the Army will be used for those materials with no EPA methods. The ANCDF waste analysis plan was amended in June 2006 to establish a nonextractive analysis to determine chemical agent contamination for certain waste streams deemed potentially suitable for off-site treatment and disposal. According to the Alabama Department of Environmental Management (ADEM) approved methodology, chemical agent vapor monitoring with the automatic continuous air monitoring system (ACAMS), the depot area air monitoring system (DAAMS), or the miniature continuous air monitoring

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements BOX 3-1 U.S. Army Decontamination Metrics for Potentially Exposed Materials Not agent contaminated 0 (zero) indicates an item, although located in an area with liquid agent and/or agent vapor, has not been contaminated (for example, it does not present an agent hazard through contact or presence of vapor). Decontamination level 1X (X) indicates the item has been partially decontaminated of agent. Further decontamination processes are required before the item is moved or any maintenance or repair is performed without the use of chemical protective clothing and equipment. This degree generally shall be applied to the item as it stands used and subjected only to routine cleaning after use. Decontamination level 3X (XXX) indicates that the item has been surface decontaminated by locally approved procedures, has been bagged or contained in an agent-tight barrier (plastic bags may be used if they have been tested and found to be effective for the purpose) of sufficient volume to permit an air sample to be withdrawn while minimizing dilution with incoming air, and/or appropriate tests/monitoring have verified that concentrations are not above 0.0001 mg/m3 for agents GA/GB, 0.00001 mg/m3 for agent VX, 0.003 mg/m3 for H or lewisite, or 0.00003 mg/m3 for agent GD (unmasked worker AEL values for other covered chemicals). Monitoring is not required for completely decontaminated and disassembled parts that are shaped simply (no crevices, threads, or the like) and are made of essentially impervious materials (such as simple lab glassware and steel gears). Decontamination level 5X (XXXXX) indicates an item has been decontaminated completely of the indicated agent and may be released for general use or sold to the general public in accordance with all applicable federal, state, and local regulations. An item is decontaminated completely when it has been subjected to procedures that are known to completely degrade the agent molecule or when analyses, submitted through MACOM and DA channels for approval by the DDESB, have shown that the total quantity of agent is less than the minimal health effects dosage as determined by the Surgeon General. 5X condition must be certified by the commander or DA PAM 385-designated representative. One approved method is heating the item to 538°C (1000°F) for 15 minutes. This is considered sufficient to destroy chemical agent molecules.    NOTE: AEL, airborne exposure limit; DA, Department of the Army; DDESB, Department of Defense Explosives Safety Board; and MACOM, major Army command. SOURCE: Adapted from U.S. Army, 2002, pp. 18-19. system (also known as Mini-CAMS) may be conducted on nonporous waste streams that have been exposed to liquid chemical agent or chemical agent vapor concentrations >1 STL to determine their suitability for off-site shipment.4 Under the modified ANCDF waste analysis plan, specific waste streams will be screened based on the STL values for chemical agent (ADEM, 2006). These wastes may be shipped to an off-site TSDF if the concentrations are <1 VSL.5 Wastes shown by monitoring to contain <1 STL of GB and/or VX may be disposed of at an off-site thermal treatment facility. Only nonporous solid wastes that are combustible in nature or objects that do not possess internal cavities will be evaluated for off-site disposal using chemical agent vapor monitoring (ADEM, 2006). Pine Bluff At the Pine Bluff Chemical Agent Disposal Facility (PBCDF), process knowledge, quality assurance data, and analytical data are used to make waste characterization decisions. Under the PBCDF RCRA permit, the term “chemical agent free” refers to contaminated or potentially contaminated solid materials that have been tested per the PBCDF waste analysis plan and found to be below the WCL or to have been thermally treated for 15 minutes at 1000°F. Under the waste analysis plan, waste may be shipped off-facility for treatment and/or disposal only if The waste was not agent contaminated, or The waste meets the criteria for chemical agent free, or The waste has been decontaminated and/or monitored to a vapor concentration equivalent to less than the STEL for agent. Under the PBCDF waste analysis plan, each batch of waste from areas where chemical agent may be present will either be sampled and tested for agent or the vapor space above the waste will monitored for 4 ACAMS and Mini-CAMS are automated, near-real-time air-monitoring systems used in chemical agent disposal facilities since 1990. DAAMS is a manual monitoring system, used primarily to confirm an agent alarm, and has been in use since 1988. More in-depth information can be found in Chapter 4 of NRC, 2005. 5 Rob Malone, SAIC, “Secondary waste background and management criteria by site,” Presentation to the committee, August 2, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 3-4 UMCDF Permit Compliance Criteria for Off-site Disposal Matrix Type Waste Stream Permit Compliance Concentration (ppb) GB VX HD WML/WSS Brines 13 8 127 WML/WSS Spent hydraulic fluid 13 8 127 WML/WSS CHB sump liquids of known origin 13 8 127 WIL Lubricating oil 16 15 177 WIS LIC slag 16 13 152 WIS DFS ash 16 13 152 WIS DFS cyclone residues 16 13 152 WIS MPF ash 16 13 152 WIS Non-RCRA empty munition casings 16 13 152 WIS Wood pallet material 16 13 152 WIS PAS residue 16 13 152 WIS PAS mist eliminator candles 16 13 152 WIS Brine tank sludge solids 16 13 152 WIS RCRA empty munition casings 16 13 152 NOTE: CHB, container handling building; WIL, water-immiscible liquid; WIS, water-insoluble solid; WML, water-miscible liquid; and WSS, water-soluble solid. SOURCE: ODEQ, 1997. agent. For those batches characterized by sampling and analysis, the TCLP extraction method will be used to determine parameter concentrations. Agent vapor space monitoring is performed by placing the wastes in a container (e.g., drum or bag) and allowing at least 4 hours at 70°F for the agent vapor in the container to reach equilibrium. After equilibrium is reached, the concentration of agent in the vapor space will be measured using near-real-time monitoring (e.g., ACAMS). The specific characterization analysis methodology to be used for each secondary waste stream destined for off-site shipment is detailed in the waste analysis plan (ADEQ, 2006). Umatilla At the Umatilla Chemical Agent Disposal Facility (UMCDF) any nerve, military, and chemical agents or any residues from demilitarization, treatment, and testing of nerve, military, and chemical agents (e.g., secondary waste) is, by Oregon regulations, a state listed hazardous waste (i.e., Oregon waste codes P999/P998 and F999/F998). Under the UMCDF waste analysis plan, wastes must be agent-free prior to shipment to an off-site facility. Samples will be considered agent-free if they are below the established permit compliance concentrations (PCCs), as shown in Table 3-4. The PCCs included in the UMCDF permit were selected based on process knowledge, previous results for similar waste streams at the Johnston Atoll Chemical Agent Disposal System (JACADS) or TOCDF, and existing RCRA land disposal restriction (LDR) notification requirements. These values are modestly lower than the 20 ppb criterion for GB and VX at the other disposal facilities. Under the UMCDF waste analysis plan, waste stream compliance concentrations are determined using EPA SW-846 unless another characterization methodology is approved. For the detection of chemical agent, UMCDF standard operating procedure UM-0000-M-559, “Agent Extraction and Analyses” is used. This procedure tailors the analyses to different sample matrices; if a process stream is not listed, the matrix that the sample most resembles is to be used (ODEQ, 1997). Tooele Under the Tooele Chemical Agent Disposal Facility (TOCDF) waste analysis plan, only secondary wastes having a chemical agent concentration below the WCL of 20 ppb for GB and VX and 200 ppb for mustard agent may be transported to an off-site RCRA TSDF. These wastes are designated as process wastes (i.e., Utah F999). Wastes above the WCL are designated as acute wastes (Utah P999). For certain other wastes, such as

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements demilitarization protective ensemble (DPE) suits, discussed later in this chapter, vapor monitoring for agents is used to determine if a waste (1) is designated as a Utah process waste (Utah F999) and allowed to be shipped off-site for treatment and ultimate disposal if it meets the WCL or (2) is an acute waste (Utah P999), which must be treated on-site (UDEQ, 2004). Newport At the Newport Chemical Agent Disposal Facility (NECDF), chemical agents are, by Indiana regulations, a state listed hazardous waste (i.e., Indiana waste code I001). Under the NECDF waste analysis plan, secondary wastes may be determined to contain agent and may therefore also be listed hazardous wastes. These wastes may or may not have other hazardous waste characteristics associated with them, as determined in the NECDF waste analysis plan. Hydrolysate, for example, is designated as an Indiana listed waste (I001) and is also considered to be corrosive (D002) and ignitable (D001). On the other hand, spent carbon is a listed waste (I001) but does not contain enough agent to generate sufficient vapors to present a danger to human health or the environment and is therefore not determined to be a reactive waste (D003). Under the NECDF waste analysis plan, wastes that cannot be initially decontaminated to the Army’s 3X decontamination level are to be placed into containers and stored until additional on-site decontamination or treatment can be provided or shipped off-site to a commercial TSDF for treatment and/or disposal.6 Under the RCRA permit for NECDF, process knowledge and analytical sampling are also used to identify and characterize wastes. NECDF performs agent-related analysis and headspace screening of agent-contaminated materials, using state regulatory approved analytical methods. As part of the NECDF waste characterization, any applicable RCRA waste codes, LDR waste codes, and underlying hazardous constituents for the D001, D002, and D003 wastes must also be determined. Where process knowledge is not sufficient for waste characterization, nonroutine samples will be collected as necessary for off-site analysis. For liquid wastes, EPA-approved sampling methods are used and sampling activities conform to EPA’s SW-846 requirements. Solid wastes such as PPE, components and parts, glassware, disposable items, and filters are decontaminated with caustic or hypochlorite solutions and then monitored for compliance with the Army’s 3X decontamination level. Under the NECDF waste analysis plan, off-site commercial TSDFs will provide any required treatment to achieve LDR treatment standards (IDEM, 2006). Analysis of Waste Categorization Situation Across Sites Various measurements are used at the different sites to characterize and classify secondary waste streams for possible shipment to off-site TSDFs. These categories and characterizations are often dictated by the types of waste material involved, the permit requirements, and the availability of an approved, reliable, direct analytical technique. Because some heterogeneous wastes and some porous waste materials do not yield reliable measurements by current analytical techniques deployed at the sites, conservative classifications and or indirect analytical techniques have been used in permit provisions for establishing off-site shipment parameters and requirements. For example, residual chemical agents can be strongly bound to the surfaces or internal pores of materials, which in turn can make identification and quantification difficult or impossible. Rates of release can only be estimated using transport modeling, which provides an estimate of what is possible but cannot be effectively validated. Given this situation and the rapidly evolving field of analytical instrumentation, investments in developing additional analytical techniques for heterogeneous or porous materials could prove beneficial.7 The Army’s use of X designations for classifying waste streams is unique to the chemical agent disposal facilities and is language not commonly used by regulators, the public, or the scientific community. These designations are sometimes confusing and counterintuitive. For example, in the case of PBCDF, the STL, 6 NECDF management defined decontamination levels as X = agent-contaminated waste with VSL >0.7 STEL; 3X = agent-contaminated waste with VSL <0.7 STEL; 5X = waste decontaminated completely when subjected to procedures known to completely degrade the agent molecule (such as 1000°F for 15 minutes). 7 Methods such as static secondary ion mass spectrometry and desorption electrospray ionization are cited in recent technical literature for detection of chemical agent. These and other recent advances in analytical techniques are reported in NRC, 2005.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements VSL, and X designations are all used in various contexts to describe the same waste streams and the permit parameters. The Army’s Chemical Materials Agency (CMA) directs the chemical stockpile disposal program and in recent years has attempted to move away from the X designations to a consistent characterization system that is based on treatment history. Under the ANCDF permit, the WCL for off-site disposal is agent concentrations of less than 20 and 200 ppb for nerve agent and mustard agent, respectively (ADEM, 2006). Ideally, extraction followed by laboratory analysis would be used to determine whether or not a waste had agent concentrations above or below these levels. However, ANCDF managers have deemed this measurement approach impractical because non-homogeneity in the contents of the (drummed) wastes makes it impossible to obtain a statistically meaningful sample. Instead, they have requested that headspace monitoring and STLs be used in lieu of extraction analysis methodologies. ANCDF management filed a permit modification request to the ADEM, asking for certain wastes to be characterized based on vapor screening methodologies, with VSLs of 8 STL for GB, 6 STL for VX, and 2 STL for HD/HT. The permit modification granted to date by the ADEM allows off-site shipment of wastes that monitor at agent concentrations of <1 STL for GB and/ or VX agent. The permit modification request limited the use of this methodology to nonporous solid wastes that are combustible and/or objects that do not possess internal cavities. The permit modification granted by ADEM contained the same limits for these specific materials. ADEM continues to consider the pending permit modification application to allow the same limitations for certain types of 8, 6, and 2 STL waste. To date, approximately 650 drums of waste meeting the approved VSL of <1 STL have been shipped to Texas for incineration.8 This vapor screening methodology involves measuring agent concentrations in the head space of the drums after thermal equilibration at 70°F, which would provide a measure of the potential for exposure for an individual who might come into contact with the drum’s atmosphere. The supporting documentation for the modification request used the EPA acute exposure guideline levels for GB, VX, and HD/HT to determine that the 8 STL, 6 STL, and 2 STL limits assure protection of human health and the environment.9 Calculations linking headspace monitoring directly to residual agent concentration have been made by ANCDF staff. However, the head space measurement cannot be correlated with residual agent in the condensed phases of the drum contents, because phase partitioning is not accurately known. Furthermore, even for agent concentrations measured in the head space, it is certainly likely that temperatures inside the drums will at times exceed 70°F, which could produce agent concentrations higher than those indicated by the monitoring test. The vapor pressures for chemical agents increase steeply with increasing temperature. The ANCDF proposal for off-site disposal of secondary waste with a designated maximum allowable agent vapor concentration of up to 8 STL for GB and 6 STL for VX also involves the following proposed requirements and restrictions: Special waste packaging requirements, Designated restrictions on disposal technique at the permitted TSDF, Disallowing certain classes of secondary waste for off-site shipment, Requirement for agent air monitoring at the TSDF, Limited handling and direct burn of the drums, Documentation of specific requirements for transportation, and Involvement of public stakeholders. The desire to increase off-site shipment and disposal of wastes by chemical agent disposal facilities is also driven by the limited capacity to process secondary waste on-site during operations and a desire to minimize the amount of secondary waste remaining to be disposed of during closure. The CMA gave the committee a summary of on-site capacity for processing secondary waste at select chemical agent disposal facilities, based on site experience (see Table 3-5). The capacity to manage similar wastes at a single off-site commercial hazardous waste incineration facility visited by the committee is estimated to be well over 8 Rob Brooks, ANCDF, “Rationale for selection of headspace monitoring levels for off-site shipment of secondary waste,” Presentation to the committee, October 16, 2006. 9 Timothy Garrett, Site Manager, ANCDF, “Protection of the on-site and off-site worker handling drums containing GB and VX waste using headspace monitoring,” Memorandum to ADEM, December 19, 2005.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements TABLE 3-5 Demonstrated Capacities to Process Secondary Waste During Operations (tons/day)   ANCDF TOCDF JACADS   Secondary Waste Processing Period Average Best Average Best Average Best Clean Harbors Aragonitea During operations 0.2 1         312 During changeovers in disposal campaigns 0.2 0.5 0.1 0.3       During closure         2 3   aA commercial hazardous waste incineration facility in the state of Utah. Full permitted operating capacity is 312 tons/day. Actual operating capacity is waste specific. SOURCE: UDEQ, 2003; Rob Malone, CMA Task Manager for Closure and Secondary Waste Disposal, “Secondary waste background and management criteria by site,” Presentation to the committee, August 2, 2006. 10 times the capacity of any one of the chemical agent disposal facilities.10 The CMA has issued program-wide secondary waste recommendations on restrictions and requirements for each facility to follow in pursuit of potential permit modifications that would allow off-site shipments of contaminated waste. These restrictions are the same as the ANCDF-proposed restrictions and include guidelines on packing, monitoring, shipping, transport, disposal techniques, and stakeholder involvement, as outlined above.11 The operating contractor and CMA personnel should also continue to audit the TSDFs being used to receive secondary wastes, to ensure that they are compliant. Finding 3-1. In the absence of better techniques for measuring agent concentrations on certain heterogeneous, porous, and permeable materials, indirect measurements leading to conservative classifications of waste materials are being used at chemical agent disposal facilities. Recommendation 3-1. The Chemical Materials Agency should develop improved analytical techniques for heterogeneous, porous, and permeable materials. Better analytical techniques could enable more exact quantification of agent contamination to meet off-site shipping criteria and help reduce waste remaining on-site at the end of munitions destruction operations. Finding 3-2. Currently, permit provisions at the various sites require the use of a variety of parameters (including the short-term exposure limit, the short-term limit, the waste control limit, the permit compliance concentration, the vapor screening level, and the Army’s X-based notations) for characterizing secondary waste from the chemical agent disposal processes. This inconsistency inhibits clear communication with and understanding by the broader population. Recommendation 3-2. The Chemical Materials Agency should continue to move away from the Army’s X-based notation for agent contamination levels and encourage the use of waste contaminant level (ppb) or vapor space concentration (mg/m3) classifications where appropriate. The CMA should seek to move toward a more uniform means of designating levels of agent contamination when applying for site permits and permit modifications. Finding 3-3. The availability and capacity of equipment for the concurrent treatment of secondary waste during agent disposal operations or changeovers at chemical agent destruction facilities is severely limited in comparison with the capacity available at off-site commercial treatment facilities that could process the waste. Recommendation 3-3. The committee encourages the CMA to continue the pursuit of off-site shipment and disposal of >1 STL secondary waste. The committee believes this can be done safely in a ramp-up fashion, based on the use of double bags and containerized packing, truck loading restrictions, designated handling and shipping routes, air monitoring at the receiving TSDF, and restrictions on the disposal technique. Appropriate 10 Committee visit to Clean Harbors Aragonite, LLC, Aragonite, Utah, on September 27, 2006. 11 “Off-site shipping and commercial treatment of greater than 1 vapor screening level (VSL) chemical agent contaminated secondary waste,” Memorandum from Kevin 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 details, including permit modifications, must be worked out in conjunction with the local regulatory agencies and local stakeholders for the practice to be allowed. SPENT ACTIVATED CARBON WASTE Banks of activated carbon are used to capture and remove any trace residual semivolatile organics that might be contained in exhaust gases and air streams from all parts of the process before release to the environment. The carbon beds are continuously monitored for organic breakthrough between individual trays of carbon, indicating when beds need to be replenished with fresh carbon. These carbon beds, along with redundant air monitoring systems, ensure that no organics are emitted above the permitted levels. The activated carbon filtration systems for reducing emissions from chemical agent incineration facilities, including fundamentals of adsorption, were reviewed in an earlier NRC report (NRC, 1999). Spent activated carbon waste streams are generated at facilities employing both the baseline incineration system and the chemical neutralization (hydrolysis) process. Depending on the organic contaminants adsorbed, spent carbon may be classified as hazardous or nonhazardous. Other minor sources of activated carbon will be added to the main carbon filter stream for disposal. General Carbon Waste Issues Across Sites Spent activated carbon is the most problematic waste for disposal. It is used at all the chemical agent disposal facilities, but its adsorption properties make it difficult to directly measure its contamination by agent using current techniques. Generator knowledge and direct measurements of process streams, before and after the carbon beds, are indirect methods used to determine whether the carbon is spent or not. Spent, agent-contaminated carbon may also be contaminated with semivolatile organics. At TOCDF and UMCDF the carbon may also become mercury-contaminated when bulk mustard is being destroyed. The rate at which spent activated carbon is generated varies from site to site depending on factors such as filter configuration, agents processed, and change-out cycles dictated by the individual site RCRA permits. Spent activated carbon is generated at the estimated rates of from 25 tons per year at NECDF to more than 75 tons per year at UMCDF during certain phases of operation. An estimated cumulative 1,980 tons of spent activated carbon are currently projected to remain in inventory for disposal at the end of operations at all sites. Spent Activated Carbon Practices and Permit Requirements: Commonalities and Differences As discussed above, ANCDF recently obtained a permit modification to allow off-site shipments of certain solid, noncombustible wastes having headspace concentrations of <1 STL. The original permit modification application, however, is still pending; it requested a provision for off-site shipments of solid wastes with agent concentrations of <8 STL for GB, <6 STL for VX, and <2 STL for HD/HT.12 However, as stated above, only nonporous solid wastes that are combustible and/or objects that do not possess internal cavities will be evaluated for off-site disposal using chemical agent vapor monitoring. Spent carbon that is agent-contaminated is currently either disposed of onsite by combustion in the metal parts furnace (MPF) or stored on-site for future treatment and disposal. ANCDF management has identified a need to develop better analytical methods for porous materials, to help facilitate additional off-site carbon disposal.13 The current ANCDF operating permit states that the spent carbon will be evaluated for chemical agent contamination if it has been exposed to agent concentrations of ≥1 STL. If generator knowledge is not sufficient to establish the exposure history, extractive analysis can be used to measure the level of chemical agent if the waste is being considered for off-site disposal. Spent carbon that experiences breakthrough of >1 STL will not be sampled and is to be treated on-site. Spent carbon considered for off-site disposal is also required to be tested for EPA’s TCLP organics and TCLP metals. The means and permit requirements for managing spent activated carbon disposal at PBCDF are currently similar to those at ANCDF. The PBCDF waste analysis plan states that agent-contaminated carbon will be incinerated on-site in an appropriate manner. Spent 12 “CMA secondary waste management,” Presentation to the CMA committee, December 6, 2006. 13 Timothy Garrett, ANCDF Site Manager, “ANCDF secondary waste initiative,” Presentation to a fact-finding team of the committee on October 16, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements carbon that has not been exposed to agent is managed by off-site disposal. The TOCDF permit currently requires on-site carbon micronization and incineration as the only allowable disposal option (UDEQ, 2004). Micronization is a process in which carbon is ground to a fine powder in order to improve the carbon burnout achieved during combustion. The process of micronization and incineration was used in the JACADS closure operation to dispose of spent activated carbon (Jordan and Kaminski, 2001). Many difficulties were experienced with the carbon micronization technologies at JACADS and are discussed in various JACADS lessons-learned reports issued by the systems contractor, Washington Group. Based on that experience, micronization followed by incineration would appear to be a highly problematic disposal choice for future use. However, an on-site alternative to the micronization technology has not yet been defined and tested. Spent activated carbon is accumulating at the TOCDF site. The mercury contamination of significant amounts of mustard agent stockpiled at TOCDF is another factor influencing potential carbon disposition. TOCDF is implementing a pollution abatement system filtration system (PFS) that will trap mercury on carbon. The resulting secondary waste stream consisting of carbon with adsorbed mercury will present a unique disposal problem.14 Mustard agent accounts for the largest fraction of chemical agent yet to be processed at UMCDF. Management of the spent carbon from the HD campaign at UMCDF will be similar to the practices developed at TOCDF for its HD campaign. UMCDF also plans to follow the TOCDF lead on any plans for the disposal of carbon waste that is potentially mercury-contaminated. The UMCDF waste analysis plan requires carbon to be treated on-site and simply states that the treatment method for spent carbon has not yet been determined (ODEQ, 1997). The spent carbon generated at NECDF originates from three parallel trains of carbon adsorbers that are used to clean the exhaust gases from the destruction facility. Gaseous effluent from the reactor first encounters a prefilter, then a high-efficiency particulate air filter, then the first of the six serial activated carbon beds. The NECDF carbon can be divided into two categories: 0X15 carbon has not been exposed to VX (determination based on process knowledge and prefilter analytical monitoring). The expectation is that a carbon vendor will take back this material, or that an off-site contractor will regenerate it. For the 1X carbon that has been exposed to VX, the anticipation is that it will be disposed of off-site by an incineration process. At the date of this report, NECDF has 7 tons of >1 VSL carbon in storage on-site and is projected to generate 135 tons over the course of its operation.16 NECDF management intends to ship spent activated carbon for final treatment, using head-space measurements to determine that the material is acceptable for shipping.17 Analysis of Spent Activated Carbon Waste Practices Across Sites Spent activated carbon is generated and is accumulating at each of the five chemical agent disposal facilities. It represents one of the largest secondary waste streams currently projected to remain in storage at the end of munitions destruction operations. The disposal of contaminated activated carbon in the JACADS facility used a micronization process followed by incineration. Communications from technical managers involved with this process stated that the micronization and incineration disposal process presented many technical challenges and required a significantly longer investment of time and effort to complete than anticipated.18 No alternative to on-site micronization has been identified, but one is likely to be needed at both TOCDF and UMCDF. The ability to ship agent-contaminated carbon to off-site disposal facilities has also been shown to significantly reduce the time and effort required to accomplish site closure. The recent closure of the Aberdeen Chemical Agent Disposal Facility (ABCDF) 14 Wastes contaminated with more than 0.2 mg/L of mercury are hazardous wastes (D009). Mercury-contaminated hazardous wastes must meet the LDR of 0.025 mg/L (for nonwastewater) prior to disposal. 15 “0X” is the same as “not agent contaminated 0,” defined in Box 3-1. “0X” is the term used by NECDF staff. 16 Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, December 11, 2006. 17 Information gathered from committee site visit, November 20-21, 2006. 18 Information provided to the committee by Steven Bushman, CMA Chief, Closure and Contract Team, February 2, 2007.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements at Edgewood, Maryland, demonstrated safe shipment and treatment of waste contaminated with HD agent at up to 6-8 STL from its closure operation. The wastes were transported and disposed of at the same Texas location proposed for use by ANCDF. Over 2,500 drums of Aberdeen waste, including spent activated carbon waste, have been handled in this fashion. ANCDF has modeled its off-site waste shipment and disposal restrictions on those used at ABCDF. The use of incineration to dispose of secondary waste off-site is a very reasonable disposition plan if the off-site shipping recommendations suggested by the ABCDF experience are used and adhered to. These practices, which are the same as those proposed by ANCDF, included: Special waste packaging requirements, Designated restrictions on disposal technique at the permitted TSDF, Disallowing certain classes of secondary waste for off-site shipment, Requirement of agent air monitoring at the TSDF, Limited handling and direct burn of the drums, Documentation of specific requirements for transportation, and Involvement of public stakeholders. Finding 3-4. Contaminated activated carbon from the treatment of several different waste streams is a major waste disposal problem at all chemical agent disposal facility sites. The micronization pretreatment of activated carbon in preparing it to be destroyed by on-site incineration has been shown to be a highly problematic process option. Recommendation 3-4. The Chemical Materials Agency should select an alternative to on-site micronization followed by incineration for decontamination and/or destruction, and ultimate disposal of contaminated activated carbon. Off-site decontamination, and/or destruction and disposal of contaminated activated carbon should be pursued whenever possible. Finding 3-5. Some of the mustard agent to be processed at the Tooele Chemical Agent Disposal Facility and the Umatilla Chemical Agent Disposal Facility is mercury-contaminated and will result in some of the activated carbon from the pollution abatement system also being contaminated with mercury. Special treatment may be required or additional challenges may be faced in disposing of this carbon. Recommendation 3-5. The Chemical Materials Agency should evaluate and select appropriate methods for the treatment and disposal of mercury-contaminated carbon. Mercury-contaminated carbon should not be intermingled with other contaminated carbons during storage. BRINE SOLUTIONS AND BRINE SALTS WASTE Scrubber brine wastes result from treating the process gases coming from the incinerators in the PAS to remove acid gases and particulates. Spent brine contains water, dissolved salts, suspended solids, and trace amounts of heavy metals and is characterized as a hazardous waste. The brine is either transferred to storage tanks for shipment to a permitted TSDF, or is further treated on-site to produce a salt. That salt is then disposed of off-site in an approved TSDF. Description of Waste Brine Solutions and Salt Issues Across Sites Brine waste represents the largest waste stream at baseline incineration sites. The total volume is estimated to be as much as 24,000 tons per year at ANCDF, PBCDF, and TOCDF.19 At UMCDF, a thermal evaporation brine reduction process is used to concentrate the brine solution to brine salts before disposal. Analytical procedures exist for the characterization of brine solutions and brine salt waste. The procedures are detailed in the waste analysis plan for each site. Most brine waste streams, either liquid or salt, are characterized and shipped off-site for disposal at a permitted TSDF. Therefore, while brine waste is a large stream, readily available off-site disposal options exist for both the spent brine solutions and the brine salts. No brine waste exists at NECDF. Brine Waste Practices and Permit Requirements: Commonalities and Differences ANCDF, PBCDF, and TOCDF have similar procedures and permit requirements for characterization, 19 Personal communication from Raj Malhotra, CMA Deputy, Technical Support Directorate, to Billy Williams, NRC study director, December 11, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements management, and disposal of brine. In general, the permits allow the PAS scrubber liquid brines to be treated in the brine reduction area (BRA) evaporator and drum dryers or shipped off-site to a RCRA TSDF. Each tank of brine is analyzed for chemical agent, which must not be present in the brine at greater than the WCL before it is shipped off-site or before processing through the BRA. Brine samples are to be analyzed for the EPA’s TCLP metals and TCLP organics as necessary to characterize the brine for shipment. Agent-derived brines will be sampled batchwise and analyzed for chemical agent to ensure the brine salt meets the appropriate WCLs prior to shipment. All UMCDF PAS brines must be processed in the UMCDF BRA (ODEQ, 1997). Brine salts from UMCDF are currently disposed of in a hazardous waste landfill. An exception is made if there is a shortage of BRA processing capacity and/or brine storage capacity. In this case, agent-derived brines can be shipped to a TSDF for treatment if UMCDF shows that: Brine processing will inhibit the destruction of chemical agent or chemical agent munitions/bulk items; Reasonable measures are taken to minimize the quantities of brine generation; Reasonable measures are taken to maximize the BRA processing and/or storage capacity; and Agent concentration is less than the PCC of 13 ppb. Analysis of Waste Brine Requirements and Practices Across Sites The RCRA permit requirements and practices for disposal of brine are fairly uniform across the four baseline sites. There are no analytical issues preventing the accurate characterization of brines, and sites have had no problem meeting the waste control limits. Disposal options for brine solution and brine salts at off-site TSDFs are also readily available and utilized. A stricter requirement for on-site brine salt evaporation is enforced at UMCDF but has not impeded the overall waste management program at that site. Finding 3-6. Brine solutions are shipped for off-site disposal from chemical agent disposal facilities upon meeting the permit criteria for the particular agent at the respective sites. Recommendation 3-6. The Chemical Materials Agency should, in conjunction with the concurrence of regulators, continue to actively dispose of as much brine solution or brine salts off-site as possible, as either a hazardous or nonhazardous waste, as appropriate. DUNNAGE WASTE Wood dunnage is primarily the wood packing used to store the munitions. The quantity of wood dunnage varies considerably across sites, depending on the number and types of munitions originally stored on wooden pallets. In a few cases, the dunnage will amount to more than 200 tons/year at an individual site. Options for dunnage disposal will depend on its exposure history and site permit requirements. Description of Dunnage Waste Issues Across Sites Classification of dunnage as hazardous or non-hazardous is primarily based on generator knowledge and its history of potential exposure to agent. In general, wood dunnage is not a hazardous waste unless there is reason to believe (by way of generator knowledge or environmental monitoring) it has come into contact with agent or agent vapors. The classification of non-agent-exposed dunnage varies by permit, and in the case of TOCDF and UMCDF, all dunnage is classified as hazardous until proven otherwise by monitoring. Because the contamination is likely to be nonuniform, there are no simple, direct, and reliable analytical techniques for determining contaminants that may be adsorbed into the dunnage. Dunnage Waste Practices and Permit Requirements: Commonalities and Differences Dunnage that is agent-contaminated above the WCL requires on-site treatment at all sites. However, the permit requirements and management practices that apply to non-agent-exposed dunnage vary across the sites. At ANCDF, packaging materials such as wood crates and metal containers that were used for storage of chemical agent munitions are not handled as a hazardous waste unless there is reason to believe liquid has leaked from the chemical agent munitions and the packaging container has come into contact with agent. If deemed necessary, headspace sampling and analysis is performed for proper classification. Uncontaminated

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements packaging is handled as a nonregulated solid waste (ADEM, 2006). At PBCDF, all dunnage generated in the toxic maintenance area with a decontamination level X is required to be treated as hazardous waste and processed in the MPF. However, dunnage originating from areas other than the toxic maintenance area, which is contaminated or potentially contaminated with chemical agent, can be characterized for off-site shipment. For instance, dunnage waste generated in an environment where (1) no liquid or aerosol contact with chemical agent was possible and (2) real-time or near-real-time monitoring was conducted during the full duration of the exposure period showing chemical agent concentration was always less than the STEL is not agent-contaminated and may be disposed of as solid waste (ADEQ, 2006). At UMCDF, for wood pallets originating from igloos without a record of leakers, the enhanced on-site containers20 for transferring the pallets are monitored using DAAMS or ACAMS for the agent associated with the munition/bulk container. If no agent is detected at or above 1.0 worker protection limit (as stipulated in the UMCDF waste analysis plan), the pallet material is considered agent-free and may be shipped off-site for disposal as a hazardous waste at a permitted facility. If agent is detected in the enhanced on-site container at or above 1.0 worker protection limit and cannot be refuted using DAAMS, the pallets are either (1) treated on-site without further sampling being required or (2) sampled and analyzed in order to determine if they are an agent-free. If the sample is determined to qualify as agent-free, the pallets are likewise considered agent-free and may be shipped off-site for disposal as a hazardous waste at a permitted facility.21 If the sample is not agent-free or an agent-free determination cannot be made, the pallet or pallets must be treated on-site. Pallets from igloos that contain leakers and that are suspected of being contaminated must be further assessed by sampling and analysis to determine how they are to be handled and disposed of. If the sampling establishes that the pallet group is to be considered agent free, the pallets may be shipped off-site for disposal as a hazardous waste at a permitted facility. If the sampling shows that the pallet group is not agent free, or an agent-free determination cannot be made, the pallets from that pallet group must be treated on-site in the MPF (ODEQ, 1997). At TOCDF, dunnage is considered an acute hazardous waste (i.e., P999) that must be treated on-site if it (1) was held within an on-site container or munitions overpack found to contain leaking munition(s)22 or (2) the extract prepared from a representative sample is found to contain agent at concentrations equal to or greater than the WCL. If the on-site container or the munitions overpack is monitored at less than 0.5 VSL, the dunnage must be sampled. If the analysis shows the agent concentration is below the WCL and the dunnage exhibits no other hazardous waste characteristics or listings, the dunnage is not considered a listed hazardous waste and may be disposed of as nonhazardous waste (UDEQ, 2004). Analysis of Dunnage Waste Practices Across Sites Practices concerning the handling, treatment, and disposition of dunnage are similar across the chemical agent disposal facility sites. Dunnage is initially segregated based on generator knowledge and exposure history. In some cases this is followed by analytical characterization to establish the level of contamination and to determine the ultimate disposal method: by incineration or in a hazardous waste landfill. While analytical characterization by sampling and extractive analysis is accurate for the sample taken, the sample taken may not be sufficiently representative to accurately profile the entire batch of dunnage. In cases such as this, conservative judgments are made, and disposal by either incineration or permitted burial in a hazardous waste landfill should continue to be preferred. The committee’s Finding 3-1 and Recommendation 3-1, 20 The enhanced on-site container is an improved second-generation version of the original design and features an improved latching system that makes sealing the container more efficient. 21 The specific sampling spots are to be picked with bias at the location of any staining indicating the wood or porous material has previously been in contact with liquids as opposed to vapors. A wood plane or other tool capable of taking flat surface samples of generally consistent thickness will be used to collect wood shavings at an average thickness of 2 mm or less from the surface of two pallet corners, and those shavings will be composited with the shavings from the other pallets in the pallet group. If a sample contains multiple pallets, approximately equal contributions from each pallet will be used for the composite sample. Stained areas, if evident, will be given priority for sampling over unstained areas. Using UMCDF analytical procedure UM-0000-M-559, a minimum of 6 g total of composited sample must be collected for homogenization and analysis for chemical agents. 22 As evidenced by monitoring of the air within the sealed on-site containers or overpack that shows agent at 0.5 VSL or above.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements discussed earlier in this chapter, also apply to dunnage waste. SCRAP METAL WASTE Scrap metal generated at stockpile disposal facilities comes from the treatment of metal munitions casings and bulk ton containers (TCs) in the MPF or deactivation furnace system (DFS) after the agent has been drained. Drained bulk containers and munition casings with energetic materials removed and metal munition components are treated in the MPF to destroy any agent residues. After treatment, the metal parts are allowed to cool, vacuumed to remove loose paint flakes and ash residue, and stored temporarily prior to shipment off-site. Metal Waste Issues Across Sites Scrap metal is generated at up to 300 tons per year per site. The volume varies depending on the type of original munitions in the individual site stockpiles. In general, scrap metal parts are classified and managed either as a hazardous waste for disposal at an approved TSDF or as scrap metal for recycling. The hazardous waste regulations in all five states with operating chemical disposal facilities have provisions that exempt scrap metal from RCRA regulation (adopted from the federal regulatory scheme) and allow scrap metal, contaminated or not, to be recycled. Hazardous scrap metal that is not recycled must be disposed of as hazardous waste—for example, in a permitted hazardous waste landfill (40 CFR 261.4(a)(13) and 261.6(a)(3)(ii)). However, the characterization and disposition of scrap metal generated at chemical agent disposal facilities is specifically addressed in the RCRA permit of each facility. The waste permit classification of similar metal waste varies from site to site. Scrap metal sent for recycle from all chemical agent disposal facilities must first be decontaminated, unlike recycle exemptions sometimes allowed in industry. This is a restriction that is imposed by the Army, as well as the site RCRA permits, to ensure that chemical agent is managed appropriately. Metal Waste Practices and Permit Requirements: Commonalities and Differences At ANCDF, the Army verified through testing that metal scrap from the operation of the deactivation furnace system (DFS) or the MPF is thermally decontaminated.23 Therefore the ANCDF RCRA permit provides that scrap metal (bulk containers, projectiles, mortar rounds, etc.) that has been thermally decontaminated and further cleaned to remove any remaining loose residue may be recycled as a feedstock for steelmaking (i.e., smelting) (ADEM, 2006). Similarly, PBCDF agent-contaminated scrap metal that has been thermally decontaminated and further cleaned to remove loose residue may be managed as a hazardous waste and disposed of at a permitted RCRA TSDF or, alternatively, managed as scrap metal and recycled exclusively by smelting (ADEQ, 2006). UMCDF is unique in that all waste generated that has potentially been exposed to agent is considered hazardous notwithstanding the permit provisions. Under the UMCDF permit, munition casings that previously contained chemical agent GB and that (1) have undergone standard thermal treatment in the MPF at 1000°F for 15 min and (2) had all loose exterior and interior residue removed may be considered empty containers under RCRA regulation 40 CFR 261.7(b)(3)(ii). Munition casings that qualify as empty containers can be recycled directly to a recycling smelter. Munition casings that do not meet these requirements are not considered empty containers and must be managed as an Oregon listed hazardous waste and sent to a RCRA-permitted, Subtitle C hazardous waste smelting or disposal facility. Additionally, no munition casings may be sent off-site until they are confirmed agent-free by grab sample of the casing internal residue. UMCDF has shipped over 2.6 million pounds decontaminated scrap metal for recycling (ODEQ, 1997).24 At TOCDF, treated scrap metal must be managed as a hazardous waste until verification testing has been accepted. Treated scrap metal is defined in the permit as metal from bulk containers, projectiles, and mortar rounds that has undergone thermal decontamination in the MPF under normal operating parameters and has no residue, internally or externally. Before shipment of treated scrap metal, residue in the interior and on 23 Heated to 1000°F for at least 15 minutes. 24 Personal communication between Mike Strong, UMCDF Deputy Project Manager, and Billy Williams, NRC study director, February 2007.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements the exterior of the scrap metal must be removed (by vacuuming, for example) and visually verified as clean. After treatment and verification, TOCDF personnel may then manage scrap metal by recycling exclusively for smelting or as a hazardous waste with disposal in a RCRA-permitted landfill. However, any treated scrap metal that contains residue that cannot be removed is considered a Utah hazardous waste (F999) and must be managed as a hazardous waste for disposal at an off-site TSDF (UDEQ, 2004). NECDF metal waste consists primarily of empty TCs. As of December 2006, a total of 272 TCs out of 1,690 had been processed through the TC thermal decontamination unit. Empty TCs are heated to 1000°F in this unit, which produces decontamination equivalent to the Army designation 5X (agent free or decontaminated potentially agent-contaminated waste). TCs decontaminated to this level at NECDF are routinely recycled to metal processors as scrap metal for smelting and reprocessing. Analysis of Metal Waste Disposal Practices Across Sites Scrap metal waste disposal practices and permit requirements across sites are very similar. All involve some method of thermal decontamination for achieving agent-free designation, either 1000°F for at least 15 minutes in the MPF or DFS, or the same time and temperature in the TC thermal decontamination unit. All sites are allowed to recycle the decontaminated metal by sending it to smelters. In one case, however, the designation of the decontaminated metal as hazardous caused concern on the part of the recyclers and interfered with acceptance of the scrap metal. This concern was later resolved through exercising the scrap metal exemption within the RCRA regulations (40 CFR 261.4). Finding 3-7. Scrap metal from chemical agent disposal facilities is subject to regulatory requirements not imposed on commercial scrap metal generators. However, thermally treated and decontaminated scrap metal from all five sites is acceptable for off-site disposal and recycling. Recommendation 3-7. Each site should continue to work with the local regulatory authority to maintain and enhance acceptance of criteria allowing for off-site disposal or recycling of thermally treated and decontaminated scrap metal. PLASTIC DEMILITARIZATION PROTECTIVE ENSEMBLES AND PERSONAL PROTECTIVE EQUIPMENT WASTE Demilitarization protective ensemble (DPE) suits are encapsulating, supplied-air PPE worn by personnel required to enter areas where chemical agent liquid or vapor is known to exist. Each suit is decontaminated and monitored for chemical agent vapor before being removed from the worker. Description of DPE and Plastic Waste Issues Across Sites Waste DPEs and PPE are a waste stream common to all chemical agent destruction facilities. The waste products have generally been exposed to agent and have been packaged and stored on-site for further treatment and disposal by incineration either on-site or off-site. The main issue with waste DPEs is obtaining representative samples for analysis, given the nonuniform deposition of any residual agent, and meeting the current waste characterization and permit requirements for off-site disposal. DPE Waste Practices and Permit Requirements: Commonalities and Differences Waste DPE material is managed in very similar fashion at ANCDF and PBCDF. Normally, DPE suits are worn once, decontaminated with decontamination solution, and double-bagged. At ANCDF, the DPE suits are monitored using the vapor screening monitoring methodology established in the site’s modified permit (see discussion earlier in this chapter). The waste DPE suits that monitor at less than 1 STL for GB or VX may then be sent to an off-site thermal treatment facility (ADEM, 2006). At PBCDF, DPE suits with decontamination level X are managed on-site as hazardous wastes and processed in the MPF. Alternatively, decontaminated DPE suits can be bagged in drum containers (typically a double plastic bag, with two to three suits per container), and the vapor space is monitored for agent. The bags must be large enough to permit sample air to be withdrawn while minimizing dilution with incoming air. The air within the bag is sampled for agent using the ACAMS to determine the vapor concentration of agent. Owing to the thoroughness of the initial decontamination of the DPE suits, it is expected that the concentration of agent

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements in the vapor space will be <1 STEL. Waste DPE suits with vapor space monitoring results <1 STEL for agent are not characteristic waste due to agent contamination and may be either sent to a permitted off-site TSDF or incinerated on-site (ADEQ, 2006; U.S. Army, 2006). At UMCDF, all discarded DPE suits are containerized and placed into a permitted storage area until treated at the site’s MPF. Under the UMCDF permit, the physical state of the DPE suits prevents the collection of a representative sample. These materials are weighed and then treated in the MPF (ODEQ, 1997). At TOCDF, DPE suits are packaged, stored, and characterized based on generator knowledge, agent monitoring, and analysis of samples. Suits having agent-monitoring results ≥0.2 VSL are characterized as acute Utah listed hazardous waste (P999) and may not be shipped off-site. These are currently designated for on-site incineration in the MPF. Suits with an agent concentration of <0.2 VSL (designated as Utah listed process waste, or F999) or that have an agent concentration in the waste below the WCL (20 ppb for GB and VX and 200 ppb for mustard) may be shipped off-site to a RCRA-permitted TSDF (UDEQ, 2004). Analysis of DPE and Plastic Waste Practices Across Sites The packaging, storage, and characterization of DPE waste is similar across sites. Some sites use only headspace analysis for primary characterization, while others use both headspace and direct sampling while recognizing the limits and nonuniformity of direct sampling results. All baseline sites use incineration as the primary method for disposal of materials considered to be agent-contaminated, with the main difference being whether it is performed on-site or off.25 Capacity limitations for on-site disposal of DPE suits and other secondary waste during munitions processing is a factor at most locations, as discussed earlier in this chapter and referenced in Table 3-5. NECDF does not have on-site capability for disposal, so the decontaminated suits are shipped off-site for incineration. Finding 3-8. The waste management practices for demilitarization protective ensemble suits and other plastics are limited by the on-site capacity for treatment and, at some sites, by the regulatory restrictions for off-site disposal. Recommendation 3-8. The Chemical Materials Agency should actively pursue off-site shipment and disposal of waste plastic and personal protective equipment such as demilitarization protective ensemble suits from all sites based on adherence to and enforcement of packing, shipping, monitoring, and treatment restrictions. SPENT DECONTAMINATION SOLUTION WASTE Spent decontamination solution (SDS) consists of caustic or bleach-based aqueous solutions that have been used in the decontamination of personal protective clothing or the operations areas. SDS may also result from rinsing drained TCs or munition cavities. These solutions are captured and stored for treatment and disposal, either on-site or off-site. SDS typically contains less than 1 percent levels of sodium chloride and organic decomposition products from agent hydrolysis. Description of SDS Waste Issues Across Sites SDS is a common waste across baseline incineration and neutralization facilities. The volumes are small, however, compared with those of other waste streams. The volume of decontamination solution from NECDF is estimated at 150 tons per year. Direct analytical methods are used to characterize this liquid waste and are outlined in each site’s waste analysis plan. SDS Waste Practices and Permit Requirements: Commonalities and Differences SDS at all sites in this study is characterized and managed according to the hazardous waste limits for chemical agents (mustard, GB, VX), as well as other hazardous waste characteristics. The SDS is containerized and stored in a permitted storage area prior to treatment and disposal. At ANCDF, spent decontamination solution is characterized and managed according to the hazardous 25 The incineration of DPE suits (which are made of a mixture of polyvinyl chloride, chlorinated polyethylene, resins, plasticizers, and metal stabilizers) is subject to the same dioxin emission limits at industrial incineration facilities as they are at chemical agent disposal facilities. Thus the waste feed load and incineration burn conditions for any of these chlorinated materials into incineration units may be regulated to meet air emission control requirements. These emission control limits and resulting incineration performance requirements are spelled out in the RCRA and Clean Air Act Title 5 permits for each site.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements waste codes applicable to chemical agents (mustard, GB, VX). It is containerized and stored prior to on-site treatment by incineration (ADEM, 2006). At PBCDF and TOCDF, if the chemical agent concentration is below 20 ppb for GB, 20 ppb for VX, or 200 ppb for HD, it may be shipped for off-site disposal (UDEQ, 2004; ADEQ, 2006). At PBCDF, if the chemical agent concentration is equal to or above the WCL, additional decontamination solution will be added to the tank, the contents of the tank will be mixed, and another sample will be analyzed for chemical agent. Also, off-site management must ensure that the SDS is directly fed into an incinerator from either the tanker truck or tanks dedicated to storing only this waste stream (ADEQ, 2006). At UMCDF, SDS will be analyzed for chemical agent, total metals, total organics, and chlorine in accordance with EPA analysis guidance. If chemical agent is detected above the WCL, additional decontamination solution will be added to the tank, the contents of the tank will be mixed, and another sample will be analyzed for chemical agent. The UMCDF permit also has special requirements for treating SDS in the on-site liquid incinerator (ODEQ, 1997). Analysis of SDS Waste Practices Across Sites Practices and regulatory requirements for managing SDS are consistent across each of the five sites included in this study, with either on-site feed to an incinerator or off-site disposal at a permitted TSDF. Direct analytical techniques exist for the exact characterization and disposition of this waste. Disposal of SDS does not currently represent a significant issue for the sites and does not require new technology, practices, or permit modifications. HYDROLYSATE The liquid waste stream from the first step of the VX neutralization process at NECDF is called hydrolysate. Hydrolysate is the solution resulting from the treatment of the VX agent with an aqueous NaOH solution. It is a high-pH mixture that consists of two phases, aqueous and organic. The organic phase may represent up to 5 percent by volume of the total mixture. This hydrolysate process waste stream must be destroyed for compliance with the Chemical Weapons Convention treaty (NRC, 1998). Approximately 33 percent of the original VX stockpile at NECDF has been neutralized as of January 2007, resulting in the accumulation of 500,000 gallons of hydrolysate. The hydrolysate is stored on-site at NECDF in intermodal shipping containers after analytical results confirm that a destruction and removal efficiency (DRE) of 99.9999 percent has been achieved and that VX has not been detected at the analytical detection limit. Several plans for on-site and off-site treatment and disposal of hydrolysate have been considered, the most recent being off-site chemical and biological treatment and disposal by a commercial TSDF. A treatment and disposal option for VX hydrolysate involving pretreatment oxidation and precipitation, followed by biological decomposition and disposal, has been proposed by DuPont, with subsequent follow-up evaluations by the EPA and the CDC (DuPont, 2004; CDC, 2005, 2006). These evaluations found that the treatment proposed by DuPont was technically feasible and provided a safe and effective off-site treatment and disposal option for NECDF VX hydrolysate. However, due to public opposition, plans for hydrolysate treatment and disposal are now being reexamined by the CMA. VX neutralization continues at NECDF while the reexamination is under way. Hydrolysate from VX neutralization continues to accumulate in storage containers.26 Complete neutralization of the VX stockpile will generate approximately 1.5 million gallons of hydrolysate for treatment and disposal. Finding 3-9. As of January 2007, over 500,000 gallons of VX hydrolysate generated by the neutralization destruction of bulk nerve agent VX at the Newport Chemical Agent Disposal Facility was being stored in more than 140 intermodal storage containers. It is anticipated that 1.5 million gallons of VX hydrolysate will eventually be generated. Studies by outside government agencies and technical organizations have found that safe, environmentally sound, off-site disposal of VX hydrolysate (such as that proposed by DuPont) is technically feasible. Recommendation 3-9. The Chemical Materials Agency should evaluate and select an appropriate method to dispose of the VX hydrolysate currently being stored at the Newport, Indiana, site, with preference for off-site disposal. 26 The disposition of the Newport hydrolysate recently changed. As of May 1, 2007, the Army was shipping Newport hydrolysate to a commercial TSDF incinerator. Since this change occurred after the report was completed but before it was published, the committee is unable to comment.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements STAKEHOLDERS AND STAKEHOLDER INVOLVEMENT IN SECONDARY WASTE PRACTICES AT CHEMICAL AGENT DISPOSAL SITES Stakeholder involvement is an important aspect of the regulatory and management process for chemical agent secondary waste at each chemical agent disposal site. Federal guidelines and state governments offer formal opportunities for public comment and direct involvement in the regulatory permit process. Each state where chemical agent disposal facilities are located has also established a local Citizens Advisory Commission (CAC) for its chemical demilitarization activities. A CAC is appointed by the state governor and reports state and public concerns and opinions about the chemical agent disposal program to the Army. The local CAC is also a key stakeholder with an important voice in the permitting process that takes place with state regulatory agencies. It serves as a direct and formal communications link between the facility and local citizens on critical issues such as secondary waste disposal plans. In Oregon, a local sovereign tribal nation, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR), is a key stakeholder community and is included in site-specific secondary waste disposal discussions and decisions. The committee held discussions with representatives of the local CACs (and in Oregon with the CTUIR) to gain local public input and to gauge perceptions on site-specific secondary-waste-related issues. Communications channels were found to be well established and frequently used. The public outreach offices and site leaders at each location appear to be very effective in establishing an atmosphere of transparency and trust with the local public. Because the long-term fate and status of the UMCDF site remains of great interest to them, the CTUIR expressed additional concerns about the transfer of waste across their land as well as the speed of closure of UMCDF operations, which may be impacted by secondary waste disposal. The committee found, based on discussions with the local CACs, state regulators, and site managers, that the outreach programs include ongoing discussion of operations and potential changes. All the site managers and contractors follow an open-door policy for communicating with local stakeholders. These efforts at continuous communication and open dialog are important for maintaining public acceptability of the agent disposal program and help to minimize issues when changes, including permit modifications, are necessary. Finding 3-10. Each chemical agent disposal facility in this study has established open and effective communication channels and has regular dialogue with its Citizens Advisory Commission and other local stakeholders. The input of these stakeholders is also sought by regulatory officials and is an important factor in negotiating permit modifications concerning secondary waste disposal practices. Recommendation 3-10. The Chemical Materials Agency should continue its support for and emphasis on local stakeholder input and involvement as mission-critical elements when acceptable secondary waste disposal practices are being defined and regulatory permit requirements are negotiated. HAZARDOUS WASTE MANAGEMENT PRACTICES AT INDUSTRIAL FACILITIES Commercial hazardous waste TSDFs, like permitted chemical agent disposal facilities, must manage all hazardous waste according to federal and state regulations and the specific provisions of their permits. As noted previously, and similar to the practice at chemical agent disposal facilities, the characterization of wastes, including acceptable analytical methodologies and management and disposal options for specific wastes or types of wastes, is guided by the facility’s RCRA permit and associated waste analysis plan. Generally, commercial TSDFs receive waste from off-site generators. The generator provides documentation based on either chemical analysis or generator knowledge. Each generator’s waste is initially sampled to verify the hazardous waste classification, as well as to determine the underlying contaminants listed in the generator’s LDR certificate.27 This waste profile is then applied to the management and ultimate disposal of the waste stream. 27 LDRs require that before a hazardous waste can be land-disposed, treatment standards specific to that waste material must be met. A facility may meet such standards by either (1) treating the hazardous chemical constituents in the waste to meet required treatment levels or (2) treating the hazardous waste using a treatment technology specified by the EPA. A certificate must accompany each hazardous waste shipment showing the applicable treatment level or treatment technology and any underlying constituents of the waste.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Chemical agent disposal facilities differ from commercial TSDFs in that the wastes being treated at the former and the treatment residues being generated there are chemical warfare agent wastes. No commercial facility manages or treats chemical warfare agent in bulk quantities. Whether some or all of the chemical agent secondary waste exhibit any of the RCRA characteristics has been a subject of debate. In only one state (Indiana) agent residue waste is designated as a characteristic waste (D003) by regulation. In other states, the permit may assign hazardous waste codes. In the regulations of only three states (Indiana, Oregon, and Utah) are the wastes, and the residues from their treatment, specifically designated as state listed hazardous wastes. In addition, no state has adopted land disposal restrictions for chemical-agent-derived secondary wastes from chemical agent destruction processes. Two leading companies with RCRA-regulated facilities provided comments on their own waste characterization and handling practices, as summarized below. Dow Chemical Company Waste Management Experience RCRA-regulated facilities operated by the Dow Chemical Company characterize all hazardous and nonhazardous wastes generated on-site or received from off-site locations according to a waste analysis plan as required by RCRA and prepared in accordance with federal and state regulations.28 The waste analysis plan is a part of the RCRA permit for the facility and describes the procedures used to collect information needed for the storage, treatment, and disposal of waste either on-site or at an off-site facility. Specified in the waste analysis plan are the following elements: Analytical procedures, Sampling methods, Frequency of evaluation, and Analytical requirements for complying with land disposal restrictions. The following information is documented for each waste: Physical state of the waste, Substance composition and properties, Waste handling and transportation requirements, Reactive chemical properties, Safety and exposure hazards, and Required worker personal protective equipment. Dow Chemical must also comply with the feed-stream analysis plan required under the Hazardous Waste Combustor Maximum Achievable Control Technology Standard for incinerators, which is very similar to the site waste analysis plan and describes the information necessary to burn wastes in an incinerator. Dow uses the following approved methodologies to characterize hazardous waste: The sampling equipment and methods used are those listed in 40 CFR 261, Appendix I, and the associated references. The analytical methods that can be used are from Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods (SW-846, EPA-600/4-79/020); Standard Methods for Chemical Analysis of Water and Wastes (EPA-600/4-79/020); Standard Methods for the Examination of Water and Wastewater; or American Society for Testing and Materials Standard Methods. These methods will change over time depending on EPA revisions, updates, and/or technology improvements. The above procedures are specified in the site’s waste analysis plan and RCRA permit and thus are required by law. For Dow Chemical Company sites that use off-site facilities for treatment and disposal, these same protocols are generally used because of the requirements established by the off-site facilities’ permits or regulatory requirements for receipt of hazardous wastes. DuPont Sabine River Works The E.I. du Pont de Nemours and Company (DuPont) Sabine River Works incinerator characterizes hazardous waste primarily using the facility waste analysis plan, which is required by RCRA; the feed stream analysis plan, which is required by the Hazardous Waste Combustor Maximum Achievable Control Technology Standard; or LDRs.29 The incinerator also must comply with the Occupational Safety and Health Administra- 28 Based on information received from the Dow Chemical Company in response to the committee’s request. 29 Based on information received from E.I. duPont de Nemours and Company in response to the committee’s request.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements tion requirements for safety reviews. DuPont has also completed stack testing for state-mandated risk assessment as part of the RCRA permit renewal. Based on the derived-from rule, items such as PPE are normally incinerated since these contaminated materials carry the same EPA waste codes as the waste with which they came into contact. However, on-site incineration is often done as a matter of convenience rather than because of specific risk assessments or regulatory requirements. The analytical protocols used to characterize hazardous wastes are primarily the EPA-approved methodologies found in their publication Test Methods for the Evaluation of Solid Waste, Physical/Chemical Methods, SW-846. Because these methodologies are a part of the waste analysis plan and the feed-stream analysis plan, they are required by the facility’s RCRA permit. In the case of the feedstream analysis plan and the LDRs, adherence is required to meet specific regulatory requirements. Occasionally, DuPont will analyze streams for hazardous constituents or properties other than those required under the permit or regulations in order to address a specific issue (e.g., to determine if the stream can be recycled). Analyses like these should be considered not as an industrial best practice but only as an internal planning aid. Each waste stream, including derived-from waste, is required to be considered on a case-by-case basis, both for management practices as well as analytical requirements. Regulatory requirements such as the LDRs are used to determine the appropriate management and treatment practices to apply. COMPARISON OF WASTE MANAGEMENT REQUIREMENTS, PRACTICES, AND IMPLEMENTATION BY THE U.S. ARMY AND INDUSTRY Based on information gathered and analyzed by the committee and described above, there is little difference between the application of regulatory conditions and requirements at industrial TSDFs and chemical agent disposal facilities. A few specific exceptions were found and have been cited, such as the requirements for scrap metal decontamination before recycle at smelting operations and the requirement at UMCDF that all waste from the site be considered hazardous, wherein the regulatory requirements or the Army’s self-imposed restrictions for chemical agent disposal facilities were more stringent than those at commercial facilities. In general, differences arise from the fact that commercial TSDFs manage and treat wastes that are clearly characterized or listed under federal and state regulatory management protocols—that is, they clearly meet hazardous waste characteristics based on methodologies set forth in EPA SW-846 and have distinct regulatory treatment limitations and disposal criteria (e.g., the derived-from rule and LDRs). However, the characterization, management, and disposal of chemical agents and the related secondary wastes at chemical agent disposal facilities are not specifically addressed in federal or state regulations and must therefore be addressed in the individual chemical agent disposal facility permit. This results in the differences seen between the management and disposal requirements at each chemical agent disposal facility, since each permit is based on an individual state’s regulatory interpretation of the limits necessary for these distinctive wastes. REFERENCES ADEM (Alabama Department of Environmental Management). 2006. ANCDF Hazardous Waste Facility Permit, Mod 27, July 21. Montgomery, Ala.: Alabama Department of Environmental Management. ADEQ (Arkansas Department of Environmental Quality). 2006. Permit for a Hazardous Waste Management Facility, Pine Bluff Arsenal, RCRA Permit Number 29-H, Revision 16, October 20. Little Rock, Ark.: Arkansas Department of Pollution Control and Ecology. Bartelt-Hunt, S.L., M.A. Barlaz., D. Knappe, and P. Kjeldsen. 2006. Fate of chemical warfare agents and toxic industrial chemicals in landfills. Environmental Science and Technology 40(13):4219-4225. CDC (Centers for Disease Control and Prevention). 2005. Review of the U.S. Army Proposal for Off-site Treatment and Disposal of Caustic VX Hydrolysate from the Newport Chemical Agent Disposal Facility: A Report to Congress, April. Atlanta, Ga.: Centers for Disease Control and Prevention. CDC. 2006. Review of the Revised Plan for Off-site Treatment of Newport Chemical Agent Disposal Facility’s Caustic VX Hydrolysate at DuPont Secure Environmental Treatment Facility in Deepwater, New Jersey: Corrected Version, July. Atlanta, Ga.: Centers for Disease Control and Prevention. Columbus, I., D. Waysbort, L. Shmueli, I. Nir, and D. Kaplan. 2006. Decomposition of adsorbed VX on activated carbons studied by 31P MAS NMR. Environmental Science and Technology 40(12):3952-3958. DuPont (E.I. du Pont de Nemours and Company). 2004. DuPont Technical Assessment on U.S. Army Newport (Indiana) Project, March 3. Wilmington, Del.: E.I. du Pont de Nemours and Company. IDEM (Indiana Department of Environmental Management). 2006. Hazardous Waste Management Permit, Newport Chemical Depot, June 21. Indianapolis, Ind.: Indiana Department of Environmental Management. Jordan, K., and R. Kaminski. 2001. Status of JACADS: Carbon Micronization System (CMS). Technical Bulletin January-March:15-17. NRC (National Research Council). 1998. Using Supercritical Water Oxidation to Treat Hydrolysate from VX Neutralization. Washington, D.C.: National Academy Press. NRC. 1999. Carbon Filtration for Reducing Emissions from Chemical Agent Incineration. Washington, D.C.: National Academy Press. NRC. 2005. Monitoring at Chemical Agent Disposal Facilities. Washington, D.C.: The National Academies Press.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements ODEQ (Oregon Department of Environmental Quality). 1997. UMCDF RCRA Hazardous Waste Treatment and Storage Permit. Available online at http://www.deq.state.or.us/umatilla/RCRApermit.htm. Last accessed February 13, 2007. UDEQ. 2003. Title V Operating Permit for Clean Harbors Aragonite LLC, September 20. Salt Lake City, Utah: Utah Department of Environmental Quality, Division of Air Quality. UDEQ. 2004. TOCDF RCRA Hazardous Waste Permit, May 3. Available online at http://www.hazardouswaste.utah.gov/HWBranch/CDSection/ CDS_TOCDF_PERM.htm#intro. Last accessed August 8, 2006. U.S. Army. 2002. Department of the Army Pamphlet 385−61, Safety: Toxic Chemical Agent Safety Standards, March 27. Available online at http:// www.army.mil/usapa/pdf/ p385_61.pdf. Last accessed June 7, 2007. U.S. Army. 2004. Implementation Guidance Policy for Revised Airborne Exposure Limits for GB, GA, GD, GF, VX, H, HD, and HT, June 18. Washington, D.C.: Office of the Assistant Secretary of the Army Installations and Environment. U.S. Army. 2006. Pine Bluff Chemical Agent Disposal Facility Waste Analysis Plan (WAP), Revision 5, July. Pine Bluff, Ark.: Pine Bluff Chemical Agent Disposal Facility. Waysbort, D., E. Manisterski, H. Leader, B. Manisterski, and Y. Ashani. 2004. Laboratory set-up for long-term monitoring of the volatilization of hazardous materials: Preliminary tests of O-ethyl S-2- (N,N-diisopropylamino)ethyl methylphosphonothiolate on asphalt. Environmental Science and Technology 38(7):2217-2223.