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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements
demilitarization protective ensemble suits from all sites based on adherence to and enforcement of packing, shipping, monitoring, and treatment restrictions.
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.
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.
Finding 4-1. Closure planning and the time to achieve closure for chemical agent disposal facilities are both very dependent on the extent of waste treatment and disposal that occurs during agent disposal operations—that is, on the degree of concurrent waste minimization that takes place. However, there is only limited treatment capacity for secondary waste during agent disposal operations and changeovers at chemical agent disposal facilities.
Recommendation 4-1. The Chemical Materials Agency should use off-site disposal concurrent with ongoing agent disposal operations wherever possible, practical, and environmentally sound for all secondary and closure wastes generated during operations.
Finding 4-2. An analytical methodology for establishing agent contamination levels in porous wastes generated during closure, such as concrete scrabble, is not available.
Recommendation 4-2. The Chemical Materials Agency should develop appropriate analytical methods for establishing agent levels in porous materials and have them certified at the earliest possible time as a means of minimizing closure costs.