Secondary Waste from Chemical Agent Disposal Facilities

SECONDARY WASTE FROM CHEMICAL AGENT DISPOSAL FACILITIES... 

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. 

Like other industrial waste, secondary wastes from chemical agent disposal facilities are either hazardous or nonlrazardous. A particttlar waste is classified into one or the other of these categories by laboratory analysis or by generator knowledge of the material s source, use, and history of exposure. 

Recommendation 6-2. The PMACWA should formally require a quantitative transportation risk assessment for the shipment of secondary waste with agent contamination >1 VSL from chemical agent disposal facilities even though the Department of Transportation has no such regulation. 

The U.S. Army s chemical agent disposal facilities, like many industrial facilities, produce wastes in the course of plant operations. For the purposes of this report, secondary waste is defined as any waste associated with the storage or destruction of chemical agent. Like other industrial waste, these wastes are either hazardous or nonhazardous. A particular waste is classified into one or the other of these categories by either laboratory analysis or generator knowledge of material source, use, and exposure (Box 1-1). The wastes discussed in this report are called secondary wastes to distinguish them from the chemical munitions that are... 

Generator knowledge may be used to make a determination that a waste from a chemical agent disposal facility never came into contact with agent and therefore is not agent-contaminated when it is declared a waste. In that case, these secondary wastes are designated not as hazardous wastes but as solid wastes unless they possess some other characteristic of a hazardous waste or are a listed waste. 

Each state has a program for granting permits for the construction and operation of treatment, storage, and disposal facilities (TSDFs). Pennits establish appropriate site-specific conditions for all aspects of the hazardous waste management and destruction processes used. Secondary waste from the two chemical agent disposal facilities covered... 

In the section Transportation Risk Assessments in Chapter 4. it was reported that the Army s Chemical Materials Agency (CMA) had written specific guidance for offsite shipments of selected secondary wastes from currently operating chemical agent disposal facilities. This guidance, wliich the Assembled Chemical Weapons Alternatives (ACWA) program expects to follow, includes the following ... 

The Army has been disposing of secondary wastes to offsite facilities from all of tire currently operating chemical agent disposal facilities and continues to do so. Of particular interest are tire experience at the ABCDF in Maryland with mustard agent hydrolysate and the experience at the NECDF in Indiana with VX hydrolysate. 

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