Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements (2007) / Chapter Skim
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3 Site-Specific Analyses of Major Secondary Waste Issues
3 Site-Specific Analyses of Major Secondary Waste Issues
Pages 36-57
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From page 36... ...
The secondary wastes at chemical agent disposal 1 These are the Anniston Chemical Agent Disposal Facil- facilities were summarized in Chapter 1 and profiled ity (ANCDF) , the Pine Bluff Chemical Agent Disposal Facility in Table 1-2.
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From page 37... ...
thermal treatment at 1000°F for 15 minutes. The projected profile and quantities of secondary wastes remaining in inventory at the end of operations Waste Control Limits and Vapor Screening Level at each of the five currently operating chemical agent disposal facilities, based on current disposal practices, The Resource Conservation and Recovery Act are shown in Table 3-1.
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From page 38... ...
facilities. These include the short-term exposure limit Most chemical agent disposal facility RCRA permits (STEL)
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From page 39... ...
The Anniston Chemical Agent Disposal Facility A VSL is a control limit used to clear materials for (ANCDF) RCRA permit language defines "chemical off-site shipment based on agent concentration in the agent free" as agent concentrations below the lowest atmosphere above the packaged waste materials.
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From page 40... ...
Decontamination level 3X (XXX) indicates that the item has Pine Bluff been surface decontaminated by locally approved procedures, has been bagged or contained in an agent-tight barrier (plastic bags At the Pine Bluff Chemical Agent Disposal Facility may be used if they have been tested and found to be effective for (PBCDF)
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From page 41... ...
is, by Oregon regulations, a state listed Under the Tooele Chemical Agent Disposal Facility hazardous waste (i.e., Oregon waste codes P999/P998 (TOCDF) waste analysis plan, only secondary wastes and F999/F998)
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From page 42... ...
Under the NECDF waste analysis plan, off-site commercial TSDFs will Newport provide any required treatment to achieve LDR treat At the Newport Chemical Agent Disposal Facility ment standards (IDEM, 2006)
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From page 43... ...
ADEM continues to consider the pending The desire to increase off-site shipment and disposal permit modification application to allow the same of wastes by chemical agent disposal facilities is also limitations for certain types of 8, 6, and 2 STL waste. driven by the limited capacity to process secondTo date, approximately 650 drums of waste meeting the ary waste on-site during operations and a desire to approved VSL of <1 STL have been shipped to Texas minimize the amount of secondary waste remaining for incineration.8 to be disposed of during closure.
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From page 44... ...
Currently, permit provisions at the various 10 times the capacity of any one of the chemical agent disposal facilities.10 sites require the use of a variety of parameters (includ The CMA has issued program-wide secondary waste ing the short-term exposure limit, the short-term limit, recommendations on restrictions and requirements for the waste control limit, the permit compliance coneach facility to follow in pursuit of potential permit centration, the vapor screening level, and the Army's modifications that would allow off-site shipments of x-based notations) for characterizing secondary waste contaminated waste.
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From page 45... ...
12"CMA secondary waste management," Presentation to the CMA committee, December 6, 2006. Spent activated carbon is generated at the estimated 13Timothy Garrett, ANCDF Site Manager, "ANCDF secondary rates of from 25 tons per year at NECDF to more than waste initiative," Presentation to a fact-finding team of the commit75 tons per year at UMCDF during certain phases of tee on October 16, 2006.
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From page 46... ...
TOCDF is lating at each of the five chemical agent disposal faciliimplementing a pollution abatement system filtration ties. It represents one of the largest secondary waste system (PFS)
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From page 47... ...
Some of the mustard agent to be pro- ANCDF, PBCDF, and TOCDF have similar procecessed at the Tooele Chemical Agent Disposal Facility dures and permit requirements for characterization, and the Umatilla Chemical Agent Disposal Facility is mercury-contaminated and will result in some of the 19Personal communication from Raj Malhotra, CMA Deputy, activated carbon from the pollution abatement system Technical Support Directorate, to Billy Williams, NRC study direcalso being contaminated with mercury. Special treat- tor, December 11, 2006.
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From page 48... ...
age of chemical agent munitions are not handled as a hazardous waste unless there is reason to believe liquid Finding 3-6. Brine solutions are shipped for off-site has leaked from the chemical agent munitions and the disposal from chemical agent disposal facilities upon packaging container has come into contact with agent.
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From page 49... ...
If the sample is determined to qualify disposition of dunnage are similar across the chemical as agent-free, the pallets are likewise considered agent- agent disposal facility sites. Dunnage is initially segfree and may be shipped off-site for disposal as a haz- regated based on generator knowledge and exposure ardous waste at a permitted facility.21 If the sample is history.
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From page 50... ...
.24 metal sent for recycle from all chemical agent disposal At TOCDF, treated scrap metal must be managed facilities must first be decontaminated, unlike recycle as a hazardous waste until verification testing has been exemptions sometimes allowed in industry. This is a accepted.
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From page 51... ...
Scrap metal from chemical agent dis are managed on-site as hazardous wastes and processed posal facilities is subject to regulatory requirements in the MPF. Alternatively, decontaminated DPE suits not imposed on commercial scrap metal generators.
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From page 52... ...
to be agent-contaminated, with the main difference The volume of decontamination solution from NECDF being whether it is performed on-site or off.25 Capacity is estimated at 150 tons per year. Direct analytical limitations for on-site disposal of DPE suits and other methods are used to characterize this liquid waste and secondary waste during munitions processing is a fac- are outlined in each site's waste analysis plan.
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From page 53... ...
Direct analytical destruction of bulk nerve agent Vx at the Newport techniques exist for the exact characterization and Chemical Agent Disposal Facility was being stored disposition of this waste. Disposal of SDS does not in more than 140 intermodal storage containers.
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From page 54... ...
It serves as a direct HAZARDOUS WASTE MANAGEMENT PRACTICES and formal communications link between the facility AT INDUSTRIAL FACILITIES and local citizens on critical issues such as secondary waste disposal plans. In Oregon, a local sovereign tribal Commercial hazardous waste TSDFs, like permitnation, the Confederated Tribes of the Umatilla Indian ted chemical agent disposal facilities, must manage all Reservation (CTUIR)
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From page 55... ...
by regulation. In other states, similar to the site waste analysis plan and describes the the permit may assign hazardous waste codes.
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From page 56... ...
and the related secondary wastes at chemical agent dis The analytical protocols used to characterize haz- posal facilities are not specifically addressed in federal ardous wastes are primarily the EPA-approved meth- or state regulations and must therefore be addressed in odologies found in their publication Test Methods the individual chemical agent disposal facility permit. for the Evaluation of Solid Waste, Physical/Chemical This results in the differences seen between the manMethods, SW-846.
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From page 57... ...
2006. Pine Bluff Chemical Agent Disposal Facility Waste September 20.
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