developed specifically for the chemical agent destruction program. These methods are indicated by the inclusion of the PCAPP method number (e.g., PCAPP-204).

The secondary waste streams anticipated during normal operations for PCAPP, which only has munitions containing mustard agent, are summarized in Table 3-1. Table 3-2 shows the anticipated secondary waste expected from closure of PCAPP. The corresponding secondary wastes expected from BGCAPP are presented in Tables 3-3, 3-4, and 3-5. The waste streams are divided into “agent contaminated” (>1 VSL) and “clean” (<1 VSL) based on the airborne exposure limits (AELs) and vapor screening levels (VSLs) detailed in Tables 2-1 and 2-2. The distinction between “agent- contaminated” and “clean” is important because it determines the type of handling required and the type of waste treatment, storage, and disposal facility (TSDF) to which the material can be sent.

At the time this report was prepared, PCAPP was further along on construction than BGCAPP and had an approved waste analysis plan (WAP) in place.2 A draft WAP submitted by BGCAPP as part of its Resource Conservation and Recovery Act (RCRA) permit application for BGCAPP had not been approved at the time of this writing. From a monitoring perspective, the only major difference between the two WAPs anticipated by the committee is that at BGCAPP, a sequence of agents needs to be monitored as the different agents are processed. The guiding principle for handling waste that may be agent-contaminated was summarized on page 34 in NRC, 2008a:

Under the WAP filed with the Colorado Department of Public Health and Environment (CDHPE), PCAPP will use generator knowledge as the primary means of characterization, with direct sampling and analysis used to verify process knowledge. Agent monitoring is conducted in accordance with the Army’s AEL guidance dated June 18, 2004). There are three approaches for classifying and disposing of secondary waste relative to its contamination by agent:

1.  The waste is containerized and its headspace is monitored to determine the appropriate classification: or

2.  The waste is assumed to be agent-contaminated and is decontaminated in accordance with the RCRA permit or regulations; adequate decontamination (<1.0 VSL) is verified via monitoring at the SDU [supplemental decontamination unit] or autoclave, whereupon it is reclassified as “clean and shipped offsite; or

3.  The waste is assumed to be agent-contaminated and is shipped offsite to a facility permitted to receive such wastes.

For the purposes of this report, the committee again notes that the Army’s currently accepted means of characterizing agent-contaminated waste are generator knowledge or the AELs established by the Army as described in Chapter 2. The AELs are the basis for (1) quantifying the agent contamination measurements known as VSLs for wastes subjected to controlled air monitoring and for (2) the established waste control limits (WCLs) for wastes that must be analyzed by extractive procedures.

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2For example, see http://www.cdhpe.state.co.us/hm/pcd/adminrecord.htm, accessed on September 12, 2011.



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