Hermiston Herald
December 31, 2002

Depot waste plan remains unsettled

By Frank Lockwood
Staff writer

HERMISTON - Despite alleged shortcomings of Brine Reduction Area (BRA)
technology, the DEQ is seeking to ensure that the Army will use the BRA to
process hazardous waste at UMCDF.

The DEQ has proposed permit changes that will require the Army to operate
its Brine Reduction Area to process liquid wastes when the Army incinerates
chemical weapons at Umatilla Chemical Agent Disposal Facility beginning in
2003.

Back in 1997, DEQ and the Environmental Quality Commission believed that all
brines generated by each incinerator pollution abatement system (PAS) would
be treated in the Brine Reduction Area, but the permit did not explicitly
require that all brines be treated in the BRA, and environmental groups
distrusted the BRA from the start. The DEQ is now concerned that the BRA
"may not be fully operational to support the planned start of chemical
agent operations."

The proposed permit modifications would allow UMCDF to continue shipping
brines generated during surrogate operations off-site for disposal at a
permitted hazardous waste management facility. The permit will still require
the BRA to be ready to process all brines from actual chemical agent
operations.

To date no site has used a BRA extensively, and the DEQ is uncertain of its
effectiveness.

If the BRA eventually has a lower treatment capacity than expected, the
options will be to increase on-site brine storage capacity, increase BRA
operational capacity, reduce chemical agent destruction rates, or ship
brines off site.

A BRA is not used at the Tooele Utah facility, which is similar to the
operation here. The Army appears not to plan to use the BRA in Alabama nor
in Arkansas, According to the DEQ's Stephanie Hallock's Feb. 8 letter to
PMCD's James Bacon, "Not using the Brine Reduction Area means shipping
millions of gallons of liquid wastes off-site for further treatment or
disposal. The Army has always assured the citizens of Oregon that all liquid
wastes will be treated on-site, and yet just recently UMCDF informed the
Department that liquids generated during surrogate testing will, in fact,
be shipped to an off-site facility." Hallock said the DEQ and EQC were
"disappointed."

A letter from Karyn Jones to the DEQ says that failings of the BRA should
have been apparent during the drafting of the permit, and that the BRA
debunked the notion of UMCDF as a tried and proven system. In 1997, Jones'
groups warned the DEQ that the BRA, or Brine Reduction Area, would not work.
Jones wrote on behalf of herself, the organizations of G.A.S.P. and of
Oregon Wildlife Federation, and a number of other individuals, saying, "We
documented the failings of the BRA to the department in our April 14, 1997
Petition for Reconsideration." Jones and her groups had advised the
commission that the BRA as planned by the Army would not function, and
claimed that facilities other than the BRA would be required to dispose of
incineration wastes.

The DEQ and the Army over the years have repeatedly proclaimed that all
waste in Umatilla would be treated on site, a promise that presumably would
require the use of the BRA.

However, Jones says, "To now force operation of the BRA may in fact increase
public risks because additional handling, storage, and disposal actions are
required." Jones called the situation a "quandary" for the DEQ because the
BRA was certified by the DEQ and confirmed by the Environmental Quality
Commission as mature and proven, best available technology.

The BRA has undergone major modifications without a thorough report
describing those changes, Jones wrote. Jones called for a Class III process
where more information is revealed and analyzed. "It is unfortunate that
this type of analysis wasn't conducted when we brought our BRA concerns to
the department in 1997," Jones wrote.

Jones also questioned why the meetings of the Secondary Waste Integrated
Process Teams, formed several years ago to discuss secondary waste issues
including BRA, had been closed to the public.

Jones also suggested:

• Permit information has not been available at the designated repositories
  where it is supposed to be found. (The Hermiston Herald confirmed this
  independently at the Hermiston library last week, when the proposed permit
  modification could not be found, even with the help of the librarian.)
  
• "What Changes Are Proposed" should occupy a more prominent place, on the
  front page, of permit change proposals.
  
• Permitting documents should be available on the World Wide Web.
  
• The definition of "maximum protection" should emphasize safety over
  schedule.

Jones' letter to the DEQ was a response to a call for comments on a permit
modification concerning the required operation of the Brine Reduction Area
(BRA). The comment period ended on Dec. 23.