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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 5 Findings and Recommendations Finding 2-1. An examination of the situation concerning trial burn requirements for incinerators at chemical agent disposal facilities has led to several observations: Surrogate trial burns demonstrate that incinerators at chemical agent disposal facilities can operate safely. The requirement to perform surrogate trial burns at these facilities is consistent with the initial start-up procedures followed at commercial hazardous waste incineration facilities. In the earlier phases of the Army’s Chemical Stockpile Disposal Program, an agent trial burn conducted for each incinerator with each agent to be processed was an appropriate way for disposal facility staff and state regulatory staff to gain operational experience and confidence in the performance of the incinerators. As the Chemical Stockpile Disposal Program has matured, there has been only limited use of the data-in-lieu-of regulatory mechanism provided for in the Resource Conservation and Recovery Act. This provision, if applied more extensively to chemical agent disposal facilities, could allow data from other similar incinerators at chemical agent disposal facilities to be used in lieu of conducting additional agent trial burns. Recommendation 2-1. The Chemical Materials Agency should vigorously pursue the application of the Resource Conservation and Recovery Act provision for using trial burn data from other similar chemical agent disposal facility incinerators in lieu of conducting trial burns for additional agents. This is a reasonable way to proceed now that (1) at least one agent trial burn has occurred for each type of agent in each type of incinerator at all the chemical agent disposal facilities and (2) a surrogate trial burn and an initial agent trial burn have occurred for each incinerator at all sites. Finding 2-2. The time required to obtain state regulatory approval to proceed to a full feed rate following submission of agent trial burn data for incinerators at chemical agent disposal facilities can be lengthy. This is a consequence of the volume and complexity of the documents filed, as well as limited state regulatory agency resources to review and analyze them. Recommendation 2-2. The Chemical Materials Agency should seek to provide funding to state authorities for third-party or other support to facilitate the analysis and disposition of trial burn data. This would shorten the time needed to obtain approval for incinerators at chemical agent disposal facilities and allow them to proceed more rapidly to a full processing rate. Finding 2-3. The same requirements concerning health risk assessments apply to chemical agent disposal facilities and industry. Although the currently applicable laws do not specifically require health risk assessments, state regulatory agencies frequently require them under the authority granted to them by either the new Resource Conservation and Recovery Act/Maximum Achievable Control Technology provisions or general
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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements omnibus provisions. Requirements concerning health risk assessments are typically expressed in each site’s RCRA operating permit provisions. Finding 2-4. The requirements for conducting a health and environmental risk assessment for the Newport Chemical Agent Disposal Facility are similar to the state of Indiana requirements for a risk assessment of gaseous emissions from a commercial PCB incinerator. These requirements, which are similar to EPA guidelines for health risk assessments, are a reasonable approach to assessing the health risk posed by the NECDF. Finding 2-5. The committee’s examination of how transportation risk assessments for agent-contaminated waste materials are conducted at chemical agent disposal facilities indicated that widely differing models and parameters have been used. A specific problem identified by the committee is that the methodology used for general ton-mile data in transportation risk assessments to achieve a Class 6 ton-mile value is not consistent. Recommendation 2-5. The Chemical Materials Agency should establish consistent and detailed criteria for conducting whatever transportation risk assessments are required to ensure accuracy and uniformity in the expression of results. Finding 2-6. The state of Indiana requirements for an evaluation of transportation risks and for preparing a transport safety plan for hazardous waste derived from the neutralization and destruction of bulk VX exceed the regulatory requirements for the transportation of hazardous waste by industry. Recommendation 2-6. The Chemical Materials Agency should continue to perform transportation risk assessments for shipping any secondary wastes from chemical agent disposal facilities with agent contaminant levels >1 VSL, despite the fact that doing so is not a DOT requirement. 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 details, including permit modifications, must be worked out in conjunction with the local regulatory agencies and local stakeholders for the practice to be allowed. Finding 3-4. Contaminated activated carbon from the treatment of several different waste streams is a major
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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 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. 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. 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. 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. 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.
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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 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.
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