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 WASTECHARACTERIZATION 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
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.