Chemical Materials Agency

The committee was also asked to evaluate the trial burn practices at the incineration-based facilities and compare them with similar practices in industry. Each Chemical Materials Agency (CMA) incineration facility has several types of incinerators and each has been required, by permit, to carry out a surrogate burn on all of its furnaces after start-up and before feeding any agent. A surrogate trial burn is required to demonstrate the ability of the unit to achieve a 99.9999 percent ( six nines ) destruction and removal efficiency and unit operability. They have then been required to carry out a trial burn with each agent. After the trial burn, the feed rates are reduced to 50 percent until the trial burn data... 

Recommendation 2-2. The Chemical Materials Agency should seek to provide funding to state authorities for third-party or other support to facilitate the analysis and disposition of trial bum data. This would shorten the time needed to obtain approval for incinerators at chemical agent disposal facilities and allow them to proceed more rapidly to a full processing rate. 

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

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

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

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

Recommendation 3-8. The Chemical Materials Agency should actively pursue off-site shipment and disposal of waste plastic and personal protective equipment such as... 

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

Recommendation 3-10. The Chemical Materials Agency should continue its support for and emphasis... 

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

Recommendation 4-2. The Chemical Materials Agency should develop appropriate analytical methods for establishing agent levels in porous materials and have them certified at the earliest possible time as a means of minimizing closure costs. 

SOURCE Adapted from a chart provided to the committee by the U.S. Army Chemical Materials Agency on August 1, 2006, and updated in January 2007. 

Recommendation 2-6. The Chemical Materials Agency should continue to perform transportation risk assessments for shipping any secondary wastes from chemical agent disposal facilities with agent contaminant levels >1VSL, despite the fact that doing so is not a DOT requirement. 

Hessian, R.T., Jr., and M. Myriski. 2005. IX Waste Ground Transportation Risk Assessment, Rev. 0, May 2. Aberdeen Proving Ground, Md. U.S. Army Chemical Materials Agency. 

VSL, and X designations are all used in various contexts to describe the same waste streams and the permit parameters. The Army s Chemical Materials Agency (CMA) directs the chemical stockpile disposal program and in recent years has attempted to move away from the X designations to a consistent characterization system that is based on treatment history. 

Recommendation 3-2. The Chemical Materials Agency should continue to move away from the Army s X-based notation for agent contamination levels and encourage the use of waste contaminant level (ppb) or vapor space concentration (mg/m3) classifications where appropriate. The CMA should seek to move toward a more uniform means of designating levels of agent contamination when applying for site permits and permit modifications. 

Recommendation 3-6. The Chemical Materials Agency should, in conjunction with the concurrence of regulators, continue to actively dispose of as much brine solution or brine salts off-site as possible, as either a hazardous or nonhazardous waste, as appropriate. 

Recommendation 3-10. The Chemical Materials Agency should continue its support for and emphasis on local stakeholder input and involvement as mission-critical elements when acceptable secondary waste disposal practices are being defined and regulatory permit requirements are negotiated. 

Johnston Atoll Chemical Agent Disposal System (JACADS) Periodic Closure Production Report, December 1, 2001, through May 3, 2002, CL-070, provided to the Chemical Materials Agency by the contractor, the Washington Group. 

Recommendation 2-1. The Chemical Materials Agency should vigorously pursue the application of the Resource Conservation and Recovery Act provision for using trial burn data from other similar chemical agent... 

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