REVIEW OF CHEMICAL AGENT SECONDARY WASTE DISPOSAL AND REGULATORY REQUIREMENTS

Committee on Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements

Board on Army Science and Technology

Division on Engineering and Physical Sciences

NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES

THE NATIONAL ACADEMIES PRESS

Washington, D.C.
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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements REVIEW OF CHEMICAL AGENT SECONDARY WASTE DISPOSAL AND REGULATORY REQUIREMENTS Committee on Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Board on Army Science and Technology Division on Engineering and Physical Sciences NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES THE NATIONAL ACADEMIES PRESS Washington, D.C. www.nap.edu

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements THE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This study was supported by Contract No. W911-NF-06-C-0067 between the National Academy of Sciences and the U.S. Army. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the views of the organizations or agencies that provided support for the project. International Standard Book Number-13: 978-0-309-10610-8 International Standard Book Number-10: 0-309-10610-9 Limited copies of this report are available from Board on Army Science and Technology National Research Council 500 Fifth Street, N.W., Room 940 Washington, DC 20001 (202) 334-3118 Additional copies are available from The National Academies Press 500 Fifth Street, N.W. Lockbox 285 Washington, DC 20055 (800) 624-6242 or (202) 334-3313 (in the Washington metropolitan area) Internet, http://www.nap.edu Copyright 2007 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Charles M. Vest is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council. www.national-academies.org

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements COMMITTEE ON REVIEW OF CHEMICAL AGENT SECONDARY WASTE DISPOSAL AND REGULATORY REQUIREMENTS PETER B. LEDERMAN, Chair, New Jersey Institute of Technology (retired), New Providence, New Jersey ROBIN L. AUTENRIETH, Texas A&M University, College Station RICHARD J. AYEN, Waste Management, Inc. (retired), Jamestown, Rhode Island JOHN D. GLASS, U.S. Army Corps of Engineers (retired), Hampton, Virginia CHRISTINE S. GRANT, North Carolina State University, Raleigh GARY S. GROENEWOLD, Idaho National Laboratory, Idaho Falls REBECCA A. HAFFENDEN, Los Alamos National Laboratory, Santa Fe PETER C. HSU, Lawrence Livermore National Laboratory, Livermore, California LOREN D. KOLLER, Oregon State University (retired), Corvallis WILLIAM R. RHYNE, ABS Consulting (retired), Kingston, Tennessee SUBHAS K. SIKDAR, U.S. Environmental Protection Agency, Cincinnati JACK SOLOMON, Praxair, Inc. (retired), East Hampton, Connecticut WALTER J. WEBER, JR., University of Michigan, Ann Arbor Staff BILLY M. WILLIAMS, Study Director HARRISON T. PANNELLA, Senior Program Officer MARGARET N. NOVACK, Senior Program Officer JAMES C. MYSKA, Senior Research Associate SARAH PELLEGRIN, Senior Program Assistant

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements BOARD ON ARMY SCIENCE AND TECHNOLOGY MALCOLM R. O’NEILL, Chair, Lockheed Martin Corporation (retired), Vienna, Virginia ALAN H. EPSTEIN, Vice Chair, Massachusetts Institute of Technology, Cambridge RAJ AGGARWAL, Rockwell Collins, Cedar Rapids, Iowa SETH BONDER, The Bonder Group, Ann Arbor, Michigan JAMES CARAFANO, The Heritage Foundation, Washington, D.C. ROBERT L. CATTOI, Rockwell International Corporation (retired), Dallas, Texas DARRELL W. COLLIER, U.S. Army Space and Missile Defense Command (retired), Leander, Texas ROBERT R. EVERETT, MITRE Corporation (retired), New Seabury, Massachusetts PATRICIA K. FALCONE, Sandia National Laboratories, Livermore, California WILLIAM R. GRAHAM, National Security Research, Inc. (retired), Arlington, Virginia PETER F. GREEN, University of Michigan, Ann Arbor CARL GUERRERI, Electronic Warfare Associates, Inc., Herndon, Virginia M. FREDERICK HAWTHORNE, University of Missouri, Columbia MARY JANE IRWIN, Pennsylvania State University, University Park CLARENCE W. KITCHENS, Science Applications International Corporation, Vienna, Virginia LARRY LEHOWICZ, Quantum Research International, Arlington, Virginia JOHN W. LYONS, U.S. Army Research Laboratory (retired), Ellicott City, Maryland EDWARD K. REEDY, Georgia Tech Research Institute (retired), Atlanta DENNIS J. REIMER, DFI International, Washington, D.C. WALTER D. SINCOSKIE, Telcordia Technologies, Inc., Morristown, New Jersey JUDITH L. SWAIN, University of California, San Diego WILLIAM R. SWARTOUT, Institute for Creative Technologies, Marina del Rey, California EDWIN L. THOMAS, Massachusetts Institute of Technology, Cambridge ELLEN D. WILLIAMS, University of Maryland, College Park Staff BRUCE A. BRAUN, Director DONNA RANDALL, Administrative Coordinator CHRIS JONES, Financial Associate DEANNA P. SPARGER, Senior Administrative Assistant

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Preface The U.S. Army’s Chemical Materials Agency (CMA) is charged with disposing of all chemical munitions and chemical agents in accordance with congressional mandates and in compliance with the Chemical Weapons Convention treaty. In fulfilling part of that mission, the CMA currently operates five facilities to dispose of stockpile munitions and agent. Large quantities of waste result during the disposal operations. This report addresses the challenges of managing these wastes safely and effectively as agent disposal operations proceed. The efficient disposal of the wastes generated as a result of the disposal operations, termed “secondary wastes,” can enable a more timely and cost-effective closure of the facilities after agent disposal operations are complete. This report on the management of these secondary wastes was initiated by the National Research Council (NRC) at the request of the CMA, the agency managing the disposal of chemical weapons. The statement of task for the Committee on Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements is as follows: The NRC will conduct an examination of the environmental, regulatory and permit requirements that chemical agent disposal facilities (CDFs) are subject to, on a federal and state basis, concerning the treatment, storage, and/or handling and shipping of secondary wastes (chemical agent and non-agent related). The NRC will compare the requirements for CDFs with those to which similar facilities in industry that treat, store, and/or handle and ship secondary wastes are subject, with particular emphasis on industrial best practices. 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. As the chair of the committee, I wish to express my appreciation to the committee members for their contributions to the preparation of this report, which included interviewing, visiting, collecting, and analyzing significant information and issues, not only at the disposal sites but also at industrial facilities and state regulatory agencies. The efforts of the writing team

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements leaders, Gary Groenewold, Rebecca Haffenden, and Loren Koller, are particularly appreciated. The committee in turn is grateful to the CMA, its staff, field offices, and the site contractors for the timely and useful information they provided. The committee also thanks the management and environmental regulatory staff of Dow Chemical Company, E.I. du Pont de Nemours and Company, Clean Harbors Aragonite, Inc., Chemical Waste Management of the Northwest, and the Coalition for Responsible Waste Incineration for their openness in discussing industrial waste management best practices. It also greatly appreciates the support and assistance of the NRC staff who ably assisted the committee in its fact-finding activities and in the production of the report. The Board on Army Science and Technology (BAST) members listed on page vi were not asked to endorse the committee’s conclusions or recommendations, nor did they review the final draft of this report before its release, although board members with appropriate expertise may be nominated to serve as formal members of study committees or as report reviewers. BAST was established in 1982 by the National Academies at the request of the Army. It brings to bear broad military, industrial, and academic scientific, engineering, and management expertise on Army technical challenges and other issues of importance to senior Army leaders. BAST also discusses potential studies of interest; develops and frames study tasks; ensures proper project planning; suggests potential committee members and reviewers for reports produced by fully independent, ad hoc study committees; and convenes meetings to examine strategic issues. Peter B. Lederman, Chair Committee on Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Acknowledgment of Reviewers This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the National Research Council’s (NRC’s) Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Richard A. Conway, Union Carbide Corporation (retired), Elizabeth M. Drake, Massachusetts Institute of Technology (retired), Todd A. Kimmell, Argonne National Laboratory, Nelline K. Kowbel, Malcolm Pirnie, Inc., Joann Slama Lighty, University of Utah, W. Leigh Short, Woodward-Clyde, Inc. (retired), Calvin C. Willhite, California Environmental Protection Agency, and Jeffery J. Wong, California Environmental Protection Agency. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by R. Stephen Berry, University of Chicago. Appointed by the NRC, he was responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Contents     SUMMARY   1 1   SECONDARY WASTE GENERATION AT CHEMICAL AGENT DISPOSAL FACILITIES   6      Introduction,   6      Statement of Task,   6      Organization of the Report,   7      Chemical Stockpile Disposal Program,   8      Overview,   8      Process Descriptions,   8      Secondary Waste from Chemical Agent Disposal Facilities,   11      Types of Secondary Waste,   11      Sources of Secondary Waste,   12      Quantities of Secondary Waste,   15      Regulatory Framework and Considerations,   16      Overview of Federal Resource Conservation and Recovery Act Requirements,   16      Overview of State-Specific Regulatory Requirements,   17      Overview of Site-Specific Permits,   18      Comparison of Broad Regulatory Requirements for Chemical Agent Disposal Facilities and Industrial Facilities,   19      References,   20 2   TRIAL BURNS, COMPLIANCE TESTING, AND HEALTH RISK ASSESSMENTS   21      Introduction,   21      Background on Regulatory Requirements for Trial Burns,   21      Resource Conservation and Recovery Act,   21      Toxic Substances Control Act,   22      Maximum Achievable Control Technology Comprehensive Performance Test Requirements,   23      Trial Burn Procedures at Chemical Agent Disposal Facilities,   24      Overview,   24      Trial Burn Phases,   25      Chemical Agent Disposal Facility Experience to Date with Trial Burns,   27

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements      Anniston Trial Burn Experience,   27      Pine Bluff Trial Burn Experience,   27      Umatilla Trial Burn Experience,   27      Tooele Trial Burn Experience,   28      Comparison with Trial Burn Experience in Commercial Industry Operations,   28      Health Risk Assessments,   32      Regulatory Basis for Health Risk Assessments,   32      Chemical Agent Disposal Facility Health Risk Assessments,   32      Transportation Risk Assessments for Secondary Waste,   34      References,   35 3   SITE-SPECIFIC ANALYSES OF MAJOR SECONDARY WASTE ISSUES   36      Overview of Secondary Waste Inventories,   36      General Waste Characterization Considerations,   37      Waste Control Limits and Vapor Screening Level,   37      Site-Specific Characterization According to Permit Requirements,   39      Analysis of Waste Categorization Situation Across Sites,   42      Spent Activated Carbon Waste,   45      General Carbon Waste Issues Across Sites,   45      Spent Activated Carbon Practices and Permit Requirements: Commonalities and Differences,   45      Analysis of Spent Activated Carbon Waste Practices Across Sites,   46      Brine Solutions and Brine Salts Waste,   47      Description of Waste Brine Solutions and Salt Issues Across Sites,   47      Brine Waste Practices and Permit Requirements: Commonalities and Differences,   47      Analysis of Waste Brine Requirements and Practices Across Sites,   48      Dunnage Waste,   48      Description of Dunnage Waste Issues Across Sites,   48      Dunnage Waste Practices and Permit Requirements: Commonalities and Differences,   48      Analysis of Dunnage Waste Practices Across Sites,   49      Scrap Metal Waste,   50      Metal Waste Issues Across Sites,   50      Metal Waste Practices and Permit Requirements: Commonalities and Differences,   50      Analysis of Metal Waste Disposal Practices Across Sites,   51      Plastic Demilitarization Protective Ensembles and Personal Protective Equipment Waste,   51      Description of DPE and Plastic Waste Issues Across Sites,   51      DPE Waste Practices and Permit Requirements: Commonalities and Differences,   51      Analysis of DPE and Plastic Waste Practices Across Sites,   52      Spent Decontamination Solution Waste,   52      Description of SDS Waste Issues Across Sites,   52      SDS Waste Practices and Permit Requirements: Commonalities and Differences,   52      Analysis of SDS Waste Practices Across Sites,   53      Hydrolysate,   53      Stakeholders and Stakeholder Involvement in Secondary Waste Practices at Chemical Agent Disposal Sites,   54      Hazardous Waste Management Practices at Industrial Facilities,   54      Dow Chemical Company Waste Management Experience,   55      DuPont Sabine River Works,   55      Comparison of Waste Management Requirements, Practices, and Implementation by the U.S. Army and Industry,   56      References,   56

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements 4   CLOSURE WASTES   58      Closure Wastes from Baseline Incineration Facilities,   59      Newport Closure Wastes,   61      Findings and Recommendations,   61      Reference,   61 5   FINDINGS AND RECOMMENDATIONS   62     APPENDIXES          A  Biographical Sketches of Committee Members   69      B  Committee Meetings and Site Visits   73

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Tables, Figures, and Boxes TABLES 1-1   Chemical Agent Disposal Facility Start-up History and Progress,   9 1-2   Site-Generated Waste Streams,   13 1-3   Projected Secondary Waste Inventories in Storage Across Sites at End of Operations According to Vapor Screening Levels,   15 2-1   Typical Trial Burn Critical Emissions and Performance Standards,   25 2-2   Completed and Still-Scheduled Trial Burns Across Operating Chemical Agent Disposal Facilities,   27 2-3   Trial Burn Data for Certain Industrial Facilities and CMA in the 1990s,   29 2-4   Comparison of Trial Burn Experience at Industrial Facilities and UMCDF,   30 3-1   Projected Secondary Waste Inventories in Storage at End of Agent Disposal Operations,   37 3-2   Treatment and Disposal Methods Used for Secondary Wastes Shipped Off-site During Agent Disposal Operations,   38 3-3   Waste Control Limit Screening Criteria for Off-site Management of Chemical Agent Disposal Facility Secondary Waste,   39 3-4   UMCDF Permit Compliance Criteria for Off-site Disposal,   41 3-5   Demonstrated Capacities to Process Secondary Waste During Operations,   44 4-1   Projected Waste Quantities Generated During Closure According to Vapor Screening Levels,   59 4-2   Projected Total Waste Quantities Generated During Closure,   59 FIGURES 1-1   Baseline incineration system block diagram indicating major secondary waste streams,   10 1-2   NECDF neutralization process block diagram indicating major secondary waste streams,   10 1-3   Major secondary waste distribution across chemical agent disposal facilities,   12

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements BOXES 1-1   Definition of “Generator Knowledge,”   11 2-1   Definition of Destruction and Removal Efficiency,   22 2-2   RCRA Permit Modification Classification and Public Comment,   24 3-1   U.S. Army Decontamination Metrics for Potentially Exposed Materials,   40

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements Acronyms and Abbreviations 1X Army designation for agent-contaminated waste 3X Army designation for potentially agent-contaminated waste 5X Army designation for agent-free or decontaminated potentially agent-contaminated waste ABCDF Aberdeen Chemical Agent Disposal Facility ACAMS automatic continuous air monitoring system ADEM Alabama Department of Environmental Management ADEQ Arkansas Department of Environmental Quality ANCDF Anniston Chemical Agent Disposal Facility ATB agent trial burn BRA brine reduction area CAA Clean Air Act CAC Citizens Advisory Commission CDC Centers for Disease Control and Prevention CDF Chemical Agent Disposal Facility CMA U.S. Army Chemical Materials Agency CPT comprehensive performance test CRWI Coalition for Responsible Waste Incineration CTUIR Confederated Tribes of the Umatilla Indian Reservation CWC Chemical Weapons Convention CX phosgene oximine DAAMS depot area air monitoring system DFS deactivation furnace system DOT U.S. Department of Transportation DPE demilitarization protective ensemble DRE destruction and removal efficiency EPA U.S. Environmental Protection Agency GA nerve agent, also known as tabun GB nerve agent, also known as sarin GD nerve agent, also known as soman H sulfur mustard, a blister agent, also known as yperite HD distilled mustard, a blister agent HL mustard/lewisite mix, a blister agent HN nitrogen mustard, a blister agent HRA health risk assessment HT mustard mixed with bis(2-chloroethylthioethyl) ether, a blister agent HTT high-temperature test IDEM Indiana Department of Environmental Management

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Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements JACADS Johnston Atoll Chemical Agent Disposal System L liter LDR land disposal restriction LIC liquid incinerator m3 cubic meter MACT maximum achievable control technology mg milligram MPF metal parts furnace NaOH sodium hydroxide NECDF Newport Chemical Agent Disposal Facility NOC notice of compliance NRC National Research Council ODEQ Oregon Department of Environmental Quality PAS pollution abatement system PBCDF Pine Bluff Chemical Agent Disposal Facility PCB polychlorinated biphenyl PCC permit compliance concentration PFS pollution abatement system filtration system POHC principal organic hazardous constituent ppb part per billion PPE personal protective equipment RCRA Resource Conservation and Recovery Act SDS spent decontamination solution STB surrogate trial burn STEL short-term exposure limit STL short-term limit T bis(2-chloroethylthioethyl) ether, a chemical sometimes mixed with H TC ton container TCLP Toxicity Characteristic Leaching Procedure TOCDF Tooele Chemical Agent Disposal Facility TSCA Toxic Substances Control Act TSDF treatment, storage, and disposal facility UDEQ Utah Department of Environmental Quality UMCDF Umatilla Chemical Agent Disposal Facility VSL vapor screening level VX nerve agent WCL waste control limit