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.
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.
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.
NRC (National Research Council). 2002. Closure and Johnston Atoll Chemical Agent Disposal System. Washington, D.C.: National Academy Press.