4
Closure Wastes

Closure plans are required for all treatment, storage, and disposal facilities (TSDFs) authorized under the Resource Conservation and Recovery Act (RCRA) as a condition of obtaining a permit.1 As chemical agent disposal facilities are regulated the same as commercial TSDFs, facility closure plans have been filed with the state regulatory agency for each of the chemical agent disposal facilities. These plans were submitted as part of a facility’s permit application and are likely to change as conditions of closure are finalized.

During a closure operation, all contaminated equipment, structures, and soils must be properly disposed of or decontaminated. The act of removing any hazardous wastes or hazardous constituents during closure results in the owner or operator becoming a generator of hazardous waste. The waste must be managed in accordance with all applicable RCRA requirements (e.g., characterization and disposal as appropriate).

The closure of the baseline incineration system chemical agent disposal facilities will generate significant wastes. In most instances, these wastes will be similar to the wastes that were generated during the closure of the Johnston Atoll Chemical Agent Disposal System (JACADS) on Johnston Island. Most of the wastes generated during closure of the Newport Chemical Agent Disposal Facility (NECDF) will be similar to those generated during the closure of the baseline incineration facilities but with the added challenge that there will not be any large furnaces available for thermal decontamination. In this regard, the closure waste experiences at NECDF will be most similar to the experiences at the Aberdeen Chemical Agent Disposal Facility (ABCDF). This chapter discusses the wastes that can be expected to be generated during closure of each of the five presently operating chemical agent disposal facilities and the current proposed plans for disposition of those wastes.2 A more detailed closure analysis will be required as detailed closure plans for each site become available. However, the main waste streams have been identified based on the JACADS and ABCDF closure experiences.

1

A TSDF closure plan must include a detailed description of the methods for removing, transporting, treating, storing, or disposing of all (legacy) hazardous wastes prior to closure and a detailed description of the steps needed to remove or decontaminate all hazardous waste residues and contaminated containment system components, equipment, structures, and soils during partial and final closure. The plan descriptions must include, but are not limited to, procedures for cleaning equipment and removing contaminated soils, methods for sampling and testing surrounding soils, and criteria for determining the extent of decontamination required to minimize the need for further maintenance and to control, minimize, or eliminate to the extent necessary to protect human health and the environment, postclosure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to the ground or surface waters or to the atmosphere (40 CFR 264.111; 264.112; and 264.114).

2

The NRC has issued a report on chemical agent disposal facility closure considerations using JACADS as an example (NRC, 2002).



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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 4 Closure Wastes Closure plans are required for all treatment, storage, and disposal facilities (TSDFs) authorized under the Resource Conservation and Recovery Act (RCRA) as a condition of obtaining a permit.1 As chemical agent disposal facilities are regulated the same as commercial TSDFs, facility closure plans have been filed with the state regulatory agency for each of the chemical agent disposal facilities. These plans were submitted as part of a facility’s permit application and are likely to change as conditions of closure are finalized. During a closure operation, all contaminated equipment, structures, and soils must be properly disposed of or decontaminated. The act of removing any hazardous wastes or hazardous constituents during closure results in the owner or operator becoming a generator of hazardous waste. The waste must be managed in accordance with all applicable RCRA requirements (e.g., characterization and disposal as appropriate). The closure of the baseline incineration system chemical agent disposal facilities will generate significant wastes. In most instances, these wastes will be similar to the wastes that were generated during the closure of the Johnston Atoll Chemical Agent Disposal System (JACADS) on Johnston Island. Most of the wastes generated during closure of the Newport Chemical Agent Disposal Facility (NECDF) will be similar to those generated during the closure of the baseline incineration facilities but with the added challenge that there will not be any large furnaces available for thermal decontamination. In this regard, the closure waste experiences at NECDF will be most similar to the experiences at the Aberdeen Chemical Agent Disposal Facility (ABCDF). This chapter discusses the wastes that can be expected to be generated during closure of each of the five presently operating chemical agent disposal facilities and the current proposed plans for disposition of those wastes.2 A more detailed closure analysis will be required as detailed closure plans for each site become available. However, the main waste streams have been identified based on the JACADS and ABCDF closure experiences. 1 A TSDF closure plan must include a detailed description of the methods for removing, transporting, treating, storing, or disposing of all (legacy) hazardous wastes prior to closure and a detailed description of the steps needed to remove or decontaminate all hazardous waste residues and contaminated containment system components, equipment, structures, and soils during partial and final closure. The plan descriptions must include, but are not limited to, procedures for cleaning equipment and removing contaminated soils, methods for sampling and testing surrounding soils, and criteria for determining the extent of decontamination required to minimize the need for further maintenance and to control, minimize, or eliminate to the extent necessary to protect human health and the environment, postclosure escape of hazardous waste, hazardous constituents, leachate, contaminated run-off, or hazardous waste decomposition products to the ground or surface waters or to the atmosphere (40 CFR 264.111; 264.112; and 264.114). 2 The NRC has issued a report on chemical agent disposal facility closure considerations using JACADS as an example (NRC, 2002).

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements CLOSURE WASTES FROM BASELINE INCINERATION FACILITIES The closure wastes at JACADS included significant amounts of legacy wastes that were generated during operations and stored awaiting disposal at the end of the munitions disposal campaigns. At the five currently operating disposal sites, much of this waste is being managed and disposed of during the operations phase and therefore will not be part of the closure. Other than the wastes from operations, the material generated during closure of the four baseline sites will be similar in type and quantity to those generated at JACADS with two notable exceptions, which are discussed below. Definitive estimates of the quantities and methods for disposal of closure wastes had not been finalized by the Army when this report was being prepared. However, rough projections of waste that will be generated during closure were available. These are summarized in Tables 4-1 and 4-2. The ultimate end use of each site TABLE 4-1 Projected Waste Quantities Generated During Closure According to Vapor Screening Levels   Total Across All Sites (tons)a Secondary Waste Stream Above VSLs Below VSLs Spent carbon from filters 741 154 Containerized combustible solids 45 2 Containerized miscellaneous solids 30 40 Containerized DPE/PPE/TAPb gear 500 69 Metals 469 3,326 Bulk solids: concrete and soilsc 1,670 803 Subtotal solids 3,455 4,394 Spent decontamination solution 3,944 0 Miscellaneous liquids 14 3 Subtotal liquids 3,958 3 Total 7,413 4,397 aSite managements’ best estimates as of January 2007. bDPE, demilitarization protective ensemble; PPE, personal protective equipment; TAP gear, protective clothing made mostly of butyl rubber. cFinal end state for bulk solid wastes at the Anniston Chemical Agent Disposal Facility (ANCDF) and NECDF is yet to be determined, so these two sites are not included in estimate. SOURCE: Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, December 11, 2006. TABLE 4-2 Projected Total Waste Quantities Generated During Closure (tons)a Secondary Waste Stream ANCDF PBCDF UMCDF TOCDF NECDF Total Across All Sites Spent carbon from filters 160 161 275 220 79 895 Containerized combustible solids 45 2       47 Containerized miscellaneous solids   1 2 2 65 70 Containerized DPE/PPE/TAPb gear 145 27 126 167 104 569 Metals 469 1,285 878 878 285 3,795 Bulk solids: concrete and soilsc   803 835 835   2,473 Subtotal solids 819 2,279 2,116 2,102 533 7,849 Spent decontamination solution 1,202 0 1,371 1,371   3,944 Miscellaneous liquids 0 1 6 6 4 17 Subtotal liquids 1,202 1 1,377 1,377 4 3,961 Total 2,021 2,280 3,493 3,479 537 11,810 aSite managements’ best estimates as of January 2007. bDPE, demilitarization protective ensemble; PPE, personal protective equipment; TAP gear, protective clothing made mostly of butyl rubber. cFinal end state for ANCDF and NECDF is yet to be determined, so it is not possible to estimate the quantities of bulk solids for these two sites. SOURCE: Personal communication between Raj Malhotra, CMA Deputy, Technical Support Directorate, and Billy Williams, NRC study director, December 11, 2006.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements will have some effect on the estimates, but probably not a significant one. The most significant closure wastes at the incineration sites will be concrete and other rubble; metal, including piping, pumps, and other process equipment; decontamination solution; and activated carbon. These projections assume that the majority of wastes being generated during operations are going to be managed and disposed of in the course of the agent disposal operations. While every effort is presently being made to accomplish this goal, it remains to be seen if scheduling and other disposal arrangements will allow that, as discussed below. Depending on the particular site of the baseline incineration system, some wastes are being managed through the metal parts furnace for decontamination and disposal. Other wastes are being shipped off-site, as was discussed in Chapter 3. These two approaches are very dependent on circumstances at the particular site. In many cases, off-site disposal issues are yet to be resolved, but the goal is to minimize the amount of wastes that must be handled during closure. From the perspective of minimizing cost, it is important that as much as possible of the wastes generated during operations be handled during the munitions disposal operations rather than during closure, either through decontamination on-site followed by final disposal or by disposal to an appropriate off-site commercial TSDF. The three most voluminous closure wastes at the incineration sites are metals, spent activated carbon, and rubble or debris. Of these, contaminated metal is probably the easiest to manage as it will most probably be cut up and put through the metal parts furnace for decontamination and disposal. Provisions for recycling treated scrap metal have already been included in the RCRA permits for each site. A review is needed prior to closure to ensure that scrap metal from closure operations can be handled in the same fashion and that proper analytical and on-site decontamination procedures are in place to clear the metal for shipment. Rubble or debris will fall into two categories. Although the amount of concrete rubble that will have to be scabbled3 from the currently operating disposal facilities to remove any contamination will be less than at JACADS because of better housekeeping and the thinner concrete layer to be removed, it will still be a significant waste stream and will require analytical characterization for off-site disposal. The earlier the analytical techniques are developed and any alternative methodology or waste control limits for off-site disposal are negotiated with state regulators, the more efficient will be the handling of these large amounts of waste. Analytical procedures at JACADS for secondary waste generated during operations were not always acceptable to the regulatory agency for application there to closure waste.4 Whatever concrete is determined, by sampling and analysis, not to be contaminated will not require scabbling before it is deconstructed into rubble. However, the criteria for classifying rubble as noncontaminated must be negotiated with each state. Activated carbon used in the baseline incineration facilities was disposed of at JACADS by using a micronization process developed for the Army that produced a fine powder that was then fed to the deactivation furnace system for treatment, resulting in an uncontaminated powder.5 The micronization process proved difficult to operate, and throughputs were much lower than expected. In addition, while being transported in pipes from the micronizer to the deactivation furnace system, the resulting powder could under some circumstances become an explosive mixture. Fortunately, no explosive event happened at JACADS, but the possibility is real and must be considered. A prudent course now would be for the Chemical Materials Agency to immediately pursue alternative disposal options for treating spent activated carbon resulting from current operations as well as for the large amounts of spent activated carbon that will generated during closure operations. In the case of the Tooele Chemical Agent Disposal Facility (TOCDF), and probably the Umatilla Chemical Agent Disposal Facility (UMCDF), a portion of the carbon will be contaminated with mercury in some 3 Scabbling is the scarification process used to remove concrete surfaces. Scabblers utilize several piston heads that contain tungsten carbide cutters to cut or chip away concrete surfaces. 4 Johnston Atoll Chemical Agent Disposal System (JACADS) Periodic Closure Production Report, December 1, 2001, through May 3, 2002, CL-070, provided to the Chemical Materials Agency by the contractor, the Washington Group. 5 The carbon micronization system at JACADS recovered and destroyed agent-contaminated charcoal from heating, ventilation, and cooling system filter trays; agent collection system tank vent filters; mask canister filters; and miscellaneous small filters. The system micronized the carbon and destroyed it in the deactivation furnace system burner. The carbon micronization system consists of delivering the drums of charcoal (filter trays and bulk), unpacking the drums, emptying the drums and filter trays, and pulverizing the charcoal.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements form. This waste stream will require special handling. Planning for the management of this waste should be done long before closure operations begin. TOCDF faces a particular challenge concerning the management of spent activated carbon wastes. The permit under which it operates stipulates that micronization is to be used to manage the activated carbon waste, the result of a requirement to use proven technologies that were available at the time the permit was issued. As discussed previously, however, micronization has not proven to be a viable treatment process. An alternative needs to be demonstrated to and accepted by the regulatory community at the earliest possible time in order to avoid an extended closure period and the attendant added costs. NEWPORT CLOSURE WASTES The closure of NECDF will result in much less waste than the closure of baseline incineration systems (Table 4-2). However, it will still entail significant amounts of waste metal scrap from the process equipment as well as spent activated carbon, waste plastics, demilitarization protective ensemble suits, and debris. The specific option chosen for the treatment of VX hydrolysate may also significantly impact the amount and type of closure waste. The experience of managing closure waste from the now closed ABCDF should provide sound guidance for NECDF. ABCDF was successful in negotiating permit modifications and arranging for shipping large quantities of closure wastes, including waste activated carbon, for off-site disposal. There are no commercial TSDFs in Indiana to support NECDF’s closure activities. To date, NECDF has been permitted to ship limited quantities of its secondary wastes to out-of-state permitted disposal facilities. However, additional quantities need to be shipped while bulk VX disposal operations are still ongoing so that the wastes from agent destruction operations do not accumulate and become problematic when NECDF begins closure. Early negotiations with the Indiana regulators and potential receiving states would appear to be in order so that disposal of wastes from this facility will not become a last-minute challenge. FINDINGS AND RECOMMENDATIONS 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. REFERENCE NRC (National Research Council). 2002. Closure and Johnston Atoll Chemical Agent Disposal System. Washington, D.C.: National Academy Press.