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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