The comparison with industry practices includes, but is not limited to the following areas:

  • the degree of characterization necessary for secondary waste (chemical agent and non-agent) produced during the stockpile disposal and/or storage operations, which is treated on-site or handled and shipped off-site for further treatment or disposal;

  • the number and types of trial burns/compliance tests for chemical stockpile incineration-based disposal facilities and the neutralization-based disposal facility on both a site-by-site basis and programmatically recognizing that the Resource Conservation and Recovery Act has provisions for using prior data;

  • feed-rate restrictions to which chemical agent disposal facilities are subject for post trial burns;

  • the extent and number of health risk assessments deemed necessary;

  • criteria being considered for shipment of agent contaminated wastes for final treatment/disposal;

  • facility closure requirements; and

  • the comparison will address site-specific situations concerning CDFs as well as program-wide considerations of the Chemical Materials Agency with regard to stockpile disposal operations.

The membership of the Committee on Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements included experts in environmental chemistry, hazardous waste management, transportation safety, risk analysis, toxicology, civil engineering, environmental law, chemical process engineering, industrial process technology, environmental management, chemistry, and chemical engineering. Biographical sketches for committee members are presented in Appendix A.

During the course of the study, presentations and written information on secondary waste practices and regulatory requirements were received from a multitude of organizations that included individual Army facilities, Army contractors, industrial facilities, regulatory authorities, and other organizations involved with waste management.

The committee met in Washington, D.C. (August 2006); Tooele, Utah (September 2006); Washington, D.C. (December 2006); Irvine, California (January 2007); and Washington, D.C. (February 2007). In addition to these full committee meetings, small teams of four to six people from the committee also conducted fact-finding site visits to chemical agent disposal facilities in Anniston, Alabama (October 2006); Umatilla, Oregon (November 2006); and Newport, Indiana (November 2006). Visits and discussions on hazardous waste practices also took place at the Clean Harbors Aragonite hazardous waste incineration facility (Aragonite, Utah) and at the Chemical Waste Management of the Northwest, Inc., landfill (Arlington, Oregon). Additional details on the committee’s meetings and activities are included in Appendix B.

Representatives from the committee also met with state regulatory officials in Alabama, Indiana, Oregon, and Utah during the site visits. Their discussions centered on state regulatory requirements impacting local facilities and any perceived secondary waste issues for the chemical agent disposal facilities. Committee members also met with representatives from the Confederated Tribes of the Umatilla Indian Reservation, representatives from three local Citizens Advisory Commissions (CACs) in Newport, Tooele, and Umatilla, and other public officials (Anniston) to gauge local public perception of secondary waste practices, regulatory requirements, and any associated issues that might emerge at the disposal facilities.

Organization of the Report

Chapter 1 provides a background overview of the issues surrounding management of secondary waste at chemical agent disposal facilities. The report focuses on the four operating facilities that are based on incineration as the primary destruction technology. It also covers the one other active facility, which uses neutralization (hydrolysis) as the primary destruction technology.3 Chapter 1 also briefly describes the chemical processes in these chemical agent disposal facilities and the types, sources, and volumes of secondary waste handled. Importantly, Chapter 1 also summarizes federal and state regulatory requirements for managing the hazardous waste from both the Army’s facilities and similar industrial facilities, as well as site-specific permits requirements. Key issues and comparisons central to this report are addressed in the two chapters that follow. Chapter 2 addresses trial burns and health risk assessment. It compares the experience of the Army’s chemical agent disposal facilities with that of industrial facilities practicing similar technologies. Chapter 3 characterizes the

3

The terms “neutralization” and “hydrolysis” are often used interchangeably in the literature on chemical agent demilitarization. Hydrolysis is the more appropriate term from a chemical process perspective. Neutralization is more in keeping with the notion of neutralizing and thereby rendering innocuous. It may be found in the literature to refer to hydrolysis in either aqueous or no naqueous media.



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