REVIEW OF CHEMICAL AGENT SECONDARY WASTE DISPOSAL AND REGULATORY REQUIREMENTS
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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.
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THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
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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
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
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:
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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;
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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;
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feed-rate restrictions to which chemical agent disposal facilities are subject for post trial burns;
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the extent and number of health risk assessments deemed necessary;
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criteria being considered for shipment of agent contaminated wastes for final treatment/disposal;
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facility closure requirements; and
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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
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
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.
Contents
Tables, Figures, and Boxes
TABLES
1-1 |
Chemical Agent Disposal Facility Start-up History and Progress, |
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1-2 |
Site-Generated Waste Streams, |
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1-3 |
Projected Secondary Waste Inventories in Storage Across Sites at End of Operations According to Vapor Screening Levels, |
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2-1 |
Typical Trial Burn Critical Emissions and Performance Standards, |
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2-2 |
Completed and Still-Scheduled Trial Burns Across Operating Chemical Agent Disposal Facilities, |
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2-3 |
Trial Burn Data for Certain Industrial Facilities and CMA in the 1990s, |
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2-4 |
Comparison of Trial Burn Experience at Industrial Facilities and UMCDF, |
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3-1 |
Projected Secondary Waste Inventories in Storage at End of Agent Disposal Operations, |
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3-2 |
Treatment and Disposal Methods Used for Secondary Wastes Shipped Off-site During Agent Disposal Operations, |
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3-3 |
Waste Control Limit Screening Criteria for Off-site Management of Chemical Agent Disposal Facility Secondary Waste, |
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3-4 |
UMCDF Permit Compliance Criteria for Off-site Disposal, |
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3-5 |
Demonstrated Capacities to Process Secondary Waste During Operations, |
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4-1 |
Projected Waste Quantities Generated During Closure According to Vapor Screening Levels, |
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4-2 |
Projected Total Waste Quantities Generated During Closure, |
FIGURES
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
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