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

Committee on Review Chemical Agent Secondary Waste Disposal and Regulatory Requirements

Review Chemical Agent Secondary Review Chemical Agent Secondary Waste Disposal and Regulatory Waste Disposal and Regulatory

RequirementsRequirements

July 26, 2007July 26, 2007Public BriefingPublic Briefing

Briefing by:Briefing by:Peter B. Lederman, Committee ChairPeter B. Lederman, Committee ChairRebecca A. Haffenden, Committee MemberRebecca A. Haffenden, Committee Member


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Study OriginStudy Origin

The director of the U.S. Army Chemical The director of the U.S. Army Chemical Materials Agency asked the NRC to Materials Agency asked the NRC to evaluate practices for managing evaluate practices for managing secondary waste at the Army’s Chemical secondary waste at the Army’s Chemical Disposal Facilities (June, 2006).Disposal Facilities (June, 2006).


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Statement of TaskStatement of Task 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 to those 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 to 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.


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Membership And ExpertiseMembership And ExpertiseDr. Peter B. Lederman, ChairDirector Hazardous Substance Mgmt Research Center, NJIT (retired)(Chem. engr., enviro./ haz. waste mgmt, mechanical engineering)

Dr. Robin L. AutenriethProf. Civil and Envr. Engr, Texas A&M University(Industrial health and safety; Industrial best practices)

Dr. Richard J. AyenDirector of Technology, Waste Management, Inc.(Hazardous waste management and remediation)

Mr. John D. GlassU.S. Army Engineer (Ret.)(Envr. regs, haz. waste mgmt. and remediation)

Dr. Christine S. GrantProf. ChE., North Carolina State University(Chemical engineering and environmental restoration)

Dr. Gary S. GroenewoldScientist, Idaho National Laboratory(Chemistry)

Rebecca A. Haffenden, J.D.Los Alamos National Laboratory(Environmental and Regulatory Law)

Dr. Peter HsuDemil Prgm. Ldr., Lawrence Livermore National Laboratory(Chem. engineering and waste treatment processes)

Dr. Loren D. KollerPresident, Loren Koller & Associates, LLC(Risk assessment and toxicology)

Dr. William R. RhyneABS Consulting, Inc. (Ret.)(Risk assessment and safety analysis)

Dr. Subhas K. SikdarAssociate Director for Science, US EPA(Envir. restoration; haz. waste mgmt and remediation)

Dr. Jack SolomonDirector of Technology Planning, Praxair, Inc. (retired)(Chemical Industry)

Dr. Walter J. Weber, Jr. (NAE)Professor, University of Michigan(Chemical and civil engineering)


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Study ApproachStudy Approach Initial meeting with background briefings Initial meeting with background briefings

Extensive data gatheringExtensive data gathering

Visits to 4 chemical demilitarization sitesVisits to 4 chemical demilitarization sites

Visits to 2 industrial hazardous waste Visits to 2 industrial hazardous waste management facilities management facilities


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Data GatheringData Gathering Site visits at TOCDF, UMCDF, ANCDF and NECDF. Site visits at TOCDF, UMCDF, ANCDF and NECDF.

Phone discussions with PBCDFPhone discussions with PBCDF

Best practices discussions with industrial leaders Best practices discussions with industrial leaders

Discussion with Regulatory OfficialsDiscussion with Regulatory Officials Discussions with Citizens’ Advisory Commissions Discussions with Citizens’ Advisory Commissions

Discussion with the Confederated Tribes of Discussion with the Confederated Tribes of Umatilla Indian Reservation (Oregon) Umatilla Indian Reservation (Oregon)


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Areas of Specific InterestAreas of Specific Interest Problematic and accumulating wastesProblematic and accumulating wastes

Current and future disposal options and criteria Current and future disposal options and criteria for off-site disposalfor off-site disposal

Incineration practices, including feed-rate ramp Incineration practices, including feed-rate ramp up and high number of required trial burnsup and high number of required trial burns

Risk assessment requirementsRisk assessment requirements

Any perceived issues by regulators or local Any perceived issues by regulators or local stakeholdersstakeholders


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Principal WastesPrincipal Wastes Spent activated carbon and spent particulate Spent activated carbon and spent particulate

filter media from the pollution abatement system;filter media from the pollution abatement system; Brine solutions or brine salts resulting from Brine solutions or brine salts resulting from

evaporation of the brine;evaporation of the brine; Dunnage, consisting primarily of wooden pallets;Dunnage, consisting primarily of wooden pallets; Scrap metal from munitions or ton containers;Scrap metal from munitions or ton containers; Plastics, particularly used demilitarization Plastics, particularly used demilitarization

protective ensemble (DPE) suits and other protective ensemble (DPE) suits and other personal protective equipment (PPE); and personal protective equipment (PPE); and

Spent decontamination solution.Spent decontamination solution.


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Summary Report MessagesSummary Report Messages

Treat secondary waste off-site as much as possible (using Treat secondary waste off-site as much as possible (using proper precautions)proper precautions)

Reduce number of remaining trial burns by using “data-in-Reduce number of remaining trial burns by using “data-in-lieu-of”lieu-of”

Identify and test alternative to carbon micronization Identify and test alternative to carbon micronization

Off-site treatment of Newport hydrolysate is preferredOff-site treatment of Newport hydrolysate is preferred

Standardize transportation risk assessmentsStandardize transportation risk assessments

Continue strong local public outreachContinue strong local public outreach


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Key Findings and RecommendationsKey Findings and Recommendations

Trial BurnsTrial Burns Finding 2-1. Finding 2-1. An examination of the situation concerning An examination of the situation concerning

trial burn requirements for incinerators at chemical agent trial burn requirements for incinerators at chemical agent disposal facilities has led to several observations as follows:disposal facilities has led to several observations as follows:

– Surrogate trial burns provide a demonstration that incinerators Surrogate trial burns provide a demonstration that incinerators at chemical agent disposal facilities can operate safely. The at chemical agent disposal facilities can operate safely. The requirement to perform surrogate trial burns at these requirement to perform surrogate trial burns at these facilities is consistentfacilities is consistent with the initial start-up procedures with the initial start-up procedures followed at commercial hazardous waste incineration facilities. followed at commercial hazardous waste incineration facilities.

– In the earlier phasesIn the earlier phases of the Army’s Chemical Stockpile of the Army’s Chemical Stockpile Disposal Program, an agent Disposal Program, an agent trial burn conducted for each trial burn conducted for each incineratorincinerator with each agent to be processed with each agent to be processed was an was an appropriate meansappropriate means by which to develop operational by which to develop operational experience and confidence in the performance of incinerators experience and confidence in the performance of incinerators among disposal facility staff and state regulatory staff.among disposal facility staff and state regulatory staff.


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Trial Burns – cont’dTrial Burns – cont’d

(Finding 2-1)(Finding 2-1)– As the Chemical Stockpile Disposal Program has matured, As the Chemical Stockpile Disposal Program has matured,

there has been only there has been only limited use of a “data in lieu of”limited use of a “data in lieu of” regulatory mechanism provided for in the Resource regulatory mechanism provided for in the Resource Conservation and Recovery Act. This provision, if applied more Conservation and Recovery Act. This provision, if applied more extensively to chemical agent disposal facilities, could allow extensively to chemical agent disposal facilities, could allow data from other similar incinerators at chemical agent disposal data from other similar incinerators at chemical agent disposal facilities to be used in lieu of collecting performance data from facilities to be used in lieu of collecting performance data from conducting additional agent trial burns to meet regulatory conducting additional agent trial burns to meet regulatory permitting requirements.permitting requirements.


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Trial Burns – cont’dTrial Burns – cont’d Recommendation 2-1.Recommendation 2-1. The Chemical Materials Agency The Chemical Materials Agency should should

vigorously pursuevigorously pursue the application of the provision in the the application of the provision in the Resource Conservation and Recovery Act for usingResource Conservation and Recovery Act for using trial burn trial burn data from other similar chemical agent disposal facility data from other similar chemical agent disposal facility incinerators in lieu of conducting trial burnsincinerators in lieu of conducting trial burns for additional for additional agents. This is reasonable now that (1) at least one agent trial agents. This is reasonable now that (1) at least one agent trial burn has occurred for each type of agent in each type of burn has occurred for each type of agent in each type of incinerator among those located at chemical agent disposal incinerator among those located at chemical agent disposal facilities, and (2) a surrogate trial burn and an initial agent trial facilities, and (2) a surrogate trial burn and an initial agent trial burn have occurred for each incinerator at all sites.burn have occurred for each incinerator at all sites.


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Trial BurnsTrial Burns Finding 2-2.Finding 2-2. The The time required to obtain regulatory approvaltime required to obtain regulatory approval to to

proceed to a full feed rate following submission of agent trial burn data for proceed to a full feed rate following submission of agent trial burn data for incinerators at chemical agent disposal facilities incinerators at chemical agent disposal facilities can be lengthy.can be lengthy. This is a This is a consequence of the volume and complexity of the documents filed, as well consequence of the volume and complexity of the documents filed, as well as limited state regulatory resources to review and analyze them.as limited state regulatory resources to review and analyze them.

Recommendation 2-2.Recommendation 2-2. The Chemical Materials Agency shouldThe Chemical Materials Agency should seek to seek to provide funding to state authorities for third-party or other provide funding to state authorities for third-party or other supportsupport to facilitate the analysis and disposition of trial burn data to facilitate the analysis and disposition of trial burn data submissions as a means of shortening the period of time necessary to submissions as a means of shortening the period of time necessary to obtain approval for incinerators at chemical agent disposal facilities to obtain approval for incinerators at chemical agent disposal facilities to proceed to a full processing rate.proceed to a full processing rate.


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Transportation Risk AssessmentsTransportation Risk Assessments

Finding 2-5. Finding 2-5. The committee’s examination of how transportation risk The committee’s examination of how transportation risk assessments for agent-contaminated waste materials are conducted at assessments for agent-contaminated waste materials are conducted at chemical agent disposal facilities indicated that widely chemical agent disposal facilities indicated that widely differing models differing models and parameters have been usedand parameters have been used. A specific problem identified by the . A specific problem identified by the committee is that the methodology used for general ton-mile data in committee is that the methodology used for general ton-mile data in transportation risk assessments to achieve a Class 6 ton-mile value is not transportation risk assessments to achieve a Class 6 ton-mile value is not consistent.consistent.

Recommendation 2-5.Recommendation 2-5. The Chemical Materials Agency should The Chemical Materials Agency should establish establish consistent and detailed criteria forconsistent and detailed criteria for conducting whatever conducting whatever transportation risk assessmentstransportation risk assessments are required to ensure accuracy and are required to ensure accuracy and uniformity in the expression of results.uniformity in the expression of results.


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Waste CharacterizationWaste Characterization

Finding 3-1. Finding 3-1. In the absence of better techniques for measuring agent In the absence of better techniques for measuring agent concentrations on certain heterogeneous, porous, and permeable concentrations on certain heterogeneous, porous, and permeable materials, materials, indirect measurementsindirect measurements leading to leading to conservative conservative classificationsclassifications of waste materials of waste materials are being usedare being used at chemical agent at chemical agent disposal facilities.disposal facilities.

Recommendation 3-1.Recommendation 3-1. The Chemical Materials Agency should The Chemical Materials Agency should develop develop improved analytical techniques for heterogeneous, porous, and improved analytical techniques for heterogeneous, porous, and permeable materialspermeable materials. Such improved analytical techniques could enable . Such improved analytical techniques could enable more exact quantification of agent contamination to meet off-site shipping more exact quantification of agent contamination to meet off-site shipping criteria and help reduce waste remaining on-site at the end of munitions criteria and help reduce waste remaining on-site at the end of munitions destruction operations.destruction operations.


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On-site Capability and Off-site Shipment CriteriaOn-site Capability and Off-site Shipment Criteria

Finding 3-3.Finding 3-3. The The availability and capacityavailability and capacity of equipment for the of equipment for the concurrent treatmentconcurrent treatment of secondary waste during agent disposal of secondary waste during agent disposal operations or changeovers at chemical agent destruction facilities operations or changeovers at chemical agent destruction facilities is is severely limitedseverely limited in comparison to the capacity available at commercial in comparison to the capacity available at commercial treatment facilities that could process the waste.treatment facilities that could process the waste.

Recommendation 3-3. Recommendation 3-3. The committee encourages the CMA to The committee encourages the CMA to continue continue the pursuit of off-site shipment and disposal of > 1STL secondary the pursuit of off-site shipment and disposal of > 1STL secondary wastewaste. The committee believes this can be done safely in a ramp-up . The committee believes this can be done safely in a ramp-up fashion, based on the use of double bag and containerized packing, truck fashion, based on the use of double bag and containerized packing, truck loading restrictions and limitations, designated handling and shipping loading restrictions and limitations, designated handling and shipping routes, air monitoring at the receiving TSDF, and restrictions on the routes, air monitoring at the receiving TSDF, and restrictions on the disposal technique. Appropriate details, including permit modifications, disposal technique. Appropriate details, including permit modifications, must be worked out in conjunction with the local regulatory agencies and must be worked out in conjunction with the local regulatory agencies and local stakeholders for the practice to be allowed.local stakeholders for the practice to be allowed.


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Activated Carbon WasteActivated Carbon Waste

Finding 3-4. Finding 3-4. Contaminated activated carbon from the treatment of Contaminated activated carbon from the treatment of several different waste streams comprises a major waste disposal problem several different waste streams comprises a major waste disposal problem at all chemical agent disposal facility sites. Previous experience in using at all chemical agent disposal facility sites. Previous experience in using micronization pretreatment of activated carbonmicronization pretreatment of activated carbon in preparing it to be in preparing it to be destroyed by on-site incineration has shown this to be destroyed by on-site incineration has shown this to be a highly a highly problematicproblematic process option. process option.

Recommendation 3-4. Recommendation 3-4. The Chemical Materials Agency should The Chemical Materials Agency should select an select an alternative method to on-site micronizationalternative method to on-site micronization followed by incineration followed by incineration for decontamination and/or destruction, and ultimate disposal of for decontamination and/or destruction, and ultimate disposal of contaminated activated carbon. Off-site disposal, decontamination, and/or contaminated activated carbon. Off-site disposal, decontamination, and/or destruction of contaminated activated carbon should be pursued whenever destruction of contaminated activated carbon should be pursued whenever possible. possible.


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Activated Carbon WasteActivated Carbon Waste

Finding 3-5.Finding 3-5. Some of the mustard agent to be processed at the Tooele Some of the mustard agent to be processed at the Tooele Chemical Agent Disposal Facility and the Umatilla Chemical Agent Disposal Chemical Agent Disposal Facility and the Umatilla Chemical Agent Disposal Facility is mercury contaminated and will result in some of the pollution Facility is mercury contaminated and will result in some of the pollution abatement system abatement system activated carbon activated carbon being alsobeing also contaminated with contaminated with mercury.mercury. This may result in special treatment being required or additional This may result in special treatment being required or additional challenges being involved in disposing of this carbon. challenges being involved in disposing of this carbon.

Recommendation 3-5.Recommendation 3-5. The Chemical Materials Agency should evaluate The Chemical Materials Agency should evaluate and and select appropriate methods for the treatment and disposal of select appropriate methods for the treatment and disposal of mercury-contaminated carbon.mercury-contaminated carbon. Mercury contaminated carbon should Mercury contaminated carbon should not be intermingled with other contaminated carbons during storage.not be intermingled with other contaminated carbons during storage.


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Newport Hydrolysate Disposal Newport Hydrolysate Disposal

Finding 3-9. Finding 3-9. As of January 2007, over 500,000 gallons of VX hydrolysate As of January 2007, over 500,000 gallons of VX hydrolysate being produced by the neutralization destruction of bulk nerve agent VX at being produced by the neutralization destruction of bulk nerve agent VX at the Newport Chemical Agent Disposal Facility is being stored in more than the Newport Chemical Agent Disposal Facility is being stored in more than 140 intermodal storage containers. The final anticipated amount of VX 140 intermodal storage containers. The final anticipated amount of VX hydrolysate to be produced is 1.5 million gallons. Studies by outside hydrolysate to be produced is 1.5 million gallons. Studies by outside governmental agencies and technical organizations have found that governmental agencies and technical organizations have found that safe, safe, environmentally sound,environmentally sound, off-site means of disposal of VX off-site means of disposal of VX hydrolysatehydrolysate (such as that proposed by DuPont) (such as that proposed by DuPont) are technically are technically feasible.feasible.

Recommendation 3-9.Recommendation 3-9. The Chemical Materials Agency should evaluate The Chemical Materials Agency should evaluate and select an appropriate method to and select an appropriate method to dispose of the VX hydrolysatedispose of the VX hydrolysate currently being stored at the Newport, Indiana site, currently being stored at the Newport, Indiana site, with preference for with preference for off-site disposal.off-site disposal.


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Concurrent Secondary Waste Disposal Off-SiteConcurrent Secondary Waste Disposal Off-Site

Finding 4-1. Finding 4-1. Closure planning and the Closure planning and the time to achieve closuretime to achieve closure for for chemical agent disposal facilities are both chemical agent disposal facilities are both very dependent on the very dependent on the extent extent ofof waste treatment and disposal that occurs during agent disposal waste treatment and disposal that occurs during agent disposal operationsoperations, i.e., the degree of concurrent waste minimization that takes , i.e., the degree of concurrent waste minimization that takes place. There is only limited treatment capacity for secondary waste during place. There is only limited treatment capacity for secondary waste during agent disposal operations and changeovers at chemical agent disposal agent disposal operations and changeovers at chemical agent disposal facilities. facilities.

Recommendation 4-1Recommendation 4-1. The Chemical Materials Agency should . The Chemical Materials Agency should use off-use off-site disposal concurrent with ongoing agent disposal operationssite disposal concurrent with ongoing agent disposal operations wherever possible, practical, and environmentally sound for all secondary wherever possible, practical, and environmentally sound for all secondary and closure wastes generated during operations. and closure wastes generated during operations.


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Report Summary and Conclusions Report Summary and Conclusions

The Nation’s interests will be best met through the safe and The Nation’s interests will be best met through the safe and expeditious disposal of the chemical weapons stockpile and its expeditious disposal of the chemical weapons stockpile and its associated secondary wastes.associated secondary wastes.

Off-site disposal of secondary wastes from the chemical agent Off-site disposal of secondary wastes from the chemical agent disposal process should be pursued (with appropriate safety, disposal process should be pursued (with appropriate safety, environmental, regulatory and stakeholder review).environmental, regulatory and stakeholder review).

Opportunities exist for potentially speeding the trial burn process Opportunities exist for potentially speeding the trial burn process at chemical agent disposal facilities, resulting in more expedient at chemical agent disposal facilities, resulting in more expedient stockpile disposal.stockpile disposal.

The overall regulatory requirements for managing secondary The overall regulatory requirements for managing secondary waste from chemical agent disposal are similar to those waste from chemical agent disposal are similar to those experienced in industry for chemicals of special concern. A few experienced in industry for chemicals of special concern. A few minor exceptions were noted where CDFs are more stringently minor exceptions were noted where CDFs are more stringently regulated.regulated.


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Q & AQ & A

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Documents

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