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Disposal of Activated Carbon from Chemical Agent Disposal Facilities 2 Uses and Management of Activated Carbon at Chemical Agent Disposal Facilities USED CARBON SOURCES Activated carbon is used at every site where chemical weapons are being destroyed in the United States. Its usefulness derives from its adsorptive properties that readily remove agent or other toxic chemicals from the air. Activated carbon is used at chemical agent disposal facilities to filter all air leaving agent-contaminated areas where remote processing of agent and munitions takes place and all vent gas streams from processing vessels. Activated carbon is used for other reasons as well: To filter ventilation air supplied to occupied work areas that are normally free of agent; To capture any agent vapors from leaking weapons in chemical weapon storage bunkers; and To protect all personnel working within the chemical limited area at each facility; it is contained in a canister that is inserted into a face mask.1 The activated carbon, which is granular, is used in three configurations: Filter trays that are used in all air filter units except the pollution abatement system (PAS) filtration system (PFS) and the M-40 gas mask canisters; In bulk form in horizontal filter beds in the PFS units; and In canister filters attached to M-40 protective masks. Figure 2-1 is a picture of the nine filter units (“filter farm”) for the air leaving a munitions demilitarization building (MDB) heating, ventilation, and air conditioning (HVAC) system. At least one of the filter units in the filter farm is a spare, which allows a filter tray changeout during operations by shutting down and isolating the unit where changeout is taking place. Figure 2-2 is a schematic of the airflow through the six filter banks that typically comprise each operational MDB HVAC filter unit. The automatic continuous air monitoring system (ACAMS) and the depot area air monitoring system (DAAMS) (not shown in Figure 2-2), which are located between Banks 1 and 2, 2 and 3, 3 and 4, and 4 and 5, monitor for the presence of agent. A filter tray is depicted in Figure 2-3, and the flow of air through the filter tray is shown in Figure 2-4. This filter tray is used in all filtering units except the PFS filters and the M-40 mask canisters. Figure 2-5 shows a PFS. Figure 2-6 is a schematic of the PAS/PFS flow configuration including the PFS units, and Figure 2-7 is a schematic of the combustion gas flow through the PFS. The PFS beds, shown in a vertical orientation in the schematic, are actually horizontal in the PFS; however, the flow path sequence is as shown in Figure 2-7. Figure 2-8 shows an M-40 protective mask with the filter canister attached. 1 The “chemical limited area” is the fenced-in area at a facility subject to surety monitoring due to the presence of chemical agent(s).
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-1 The nine activated carbon filter units for the MDB HVAC system. SOURCE: Robie Jackson, Waste Management Manager, ANDCF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. A list of typical uses for carbon filter units in a chemical agent disposal facility using incineration for agent destruction is given in Table 2-1. The used carbon from most processes is not expected to be contaminated with agent. The only two places where used carbon is expected to become exposed to agent during normal operations are the unit filters for the agent collection system (ACS) and Banks 1 and 2 of the MDB HVAC filters. The semicontinuous monitoring (noted in Table 2-1) by a combination of near-real-time ACAMS and DAAMS after Banks 1, 2, 3, and 4 establishes that there is no exposure to agent beyond Bank 2.2 This conclusion does not preclude plant management from changing out filters from Banks 1 and 2 for other reasons, e.g., to measure conditions of the carbon. As indicated in Table 2-1, changeout of the carbon in Banks 1 and 2 would take place if agent breakthrough above the short-term limit is detected between Banks 2 and 3 at the Tooele, Anniston, and Pine Bluff Chemical Agent Disposal Facilities (TOCDF, ANCDF, and PBCDF). At Umatilla Chemical Agent Disposal Facility (UMCDF), the policy is that changeout would occur if agent breakthrough above the short-term limit is detected between Banks 3 and 4. However, as has been and continues to be the case at the other sites, the committee does not expect that it would ever become necessary for MDB HVAC Bank 3 carbon at UMCDF to be changed out due to contamination. For this reason, for each site covered in this report the first two banks of MDB HVAC carbon will be considered to be exposed to agent and the last four banks will be considered to be unexposed carbon. The PFS filters are not expected to be exposed to agent during normal operation of the liquid incinerator (LIC), the metal parts furnace (MPF), or the deactivation furnace system (DFS) and their respective PAS units. The PFS units at the more recently constructed ANCDF, PBCDF, and UMCDF were not required by the regulations applicable to these facilities that implement the Resource Conservation and Recovery Act (RCRA), but they were included in the design of these facilities as an extra precaution to relieve public concerns about the possibility of uncontrolled gaseous emissions. The report Carbon Filtration for Reducing Emissions from Chemical Agent Incineration examined various technical and risk-related aspects surrounding the use of PFSs at chemical agent disposal facilities (NRC, 1999). From the start of operations in 1996, TOCDF has operated without a PFS but was adding units downstream of the two LICs and the MPF as this report was being prepared. Sulfur-impregnated carbon is being installed in these units to capture mercury from the incineration of mercury-containing mustard agent. The PFS at ANCDF, PBCDF, and UMCDF will also use sulfur-impregnated carbon when these facilities are processing mustard agent-containing munitions and ton containers. Table 2-2 estimates total quantities of used carbon expected to be generated during disposal operations and site closure for each of the incineration-based chemical agent disposal facilities currently operating and for the neutralization (hydrolysis)-based Newport 2 The DAAMS monitors consist of adsorption tubes that confirm the ACAMS monitors since they sample any agent in the airstream on a continuous basis but are analyzed only periodically (several times daily). Measurements to date beyond Bank 2 have been non-detect for agent.
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-2 Schematic representation of airflow through the six filter banks that make up each MDB HVAC filter unit. Carbon filters each contain 48 filter trays arrayed in six columns and eight rows, with each tray oriented in horizontal position. The 85 indicates 85 percent efficiency for the particulate prefilter; H indicates HEPA filter; F indicates filter; and C indicates carbon filter. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. Chemical Agent Disposal Facility (NECDF), which recently completed destruction of the stockpile of bulk VX nerve agent stored in ton containers at the site. Table 2-2 also indicates the quantities of carbon that the Army currently anticipates for off-site and on-site treatment. Table 2-3 estimates the quantities of carbon anticipated to be exposed to agent and the operations that produce them at each of the Chemical Materials Agency (CMA) incineration facilities. Table 2-4 pro FIGURE 2-3 A filter tray. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANDCF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. vides complementary estimates of the quantities of carbon that can be considered unexposed to agent and the operations where this carbon was used. These estimates include used carbon from both operations and closure and are based on data provided by the Army showing which carbon it expects will be treated on-site in the MPF (exposed) and which can be slated for off-site shipment (unexposed.) It is important to note that the numbers in Tables 2-3 and 2-4 represent calculated estimates as of September 2008 and are subject to changes based on operational factors, design modifications, and ongoing developments and negotiations concerning permitting and regulatory requirements for on-site analysis and treatment and off-site shipment and disposal. There is also some variation in how the data from which these tables were generated was compiled at each site (e.g., dry weight or actual weight, frame and hardware weight included or not). However, the main point made by Tables 2-3 and 2-4 is that the anticipated total amount of exposed carbon (~508,400 lb) is about one-fourth the anticipated total amount of unexposed carbon (~2,107,800 lb), or only about one-fifth the total used carbon (~2,616,200 lb) expected from operations and closure at the four incineration sites. Also evident from Table 2-3: The overwhelming majority of exposed carbon comes from the MDB HVAC system, which is also the source of about half the unexposed carbon, as shown in Table 2-4. The PFS
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-4 Airflow path through a filter tray. SOURCE: Susan Ankrom, SAIC Task Manager, ANCDF, “Published values for agent loading capacity of MDB and PFS carbon,” Presentation to the committee, June 6, 2008. carbon, including the sulfur-impregnated carbon that will be used to capture mercury emissions from the processing of mustard agent munitions, constitutes FIGURE 2-5 PFS filter unit. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. the bulk of the remaining carbon that can be considered unexposed to agent, as discussed later. It is also worthwhile noting that RCRA regulations at 40 CFR 261.10(a)(2)(ii) allow generators of solid waste to use the “knowledge of their waste” to determine whether the RCRA regulations apply to it.3 The data provided from the neutralization-based NECDF indicate that the used carbon generated during the now-completed disposal operations and ongoing facility closure comes primarily from MDB HVAC and process filters (270,000 lb) but also from other sources (nearly 11,000 lb). At the time this report was being prepared, 200,000 lb of this carbon had been shipped to Calgon Carbon Corporation, a carbon supplier, for reactivation and has never been returned to the NECDF inventory. The Army has released it for sale on the open market. There is no requirement for NECDF to sample and analyze the used exposed carbon, which is managed as a listed hazardous waste under the Indi- 3 What is commonly termed “generator knowledge” as applicable to used carbon from chemical agent disposal facilities is discussed further in Chapter 3 and later chapters.
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-6 Schematic of the PAS/PFS flow configuration including the PFS filter unit. The carbon filter units refer to two zones of the PFS unit, which are actually in series and not in parallel as shown. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. FIGURE 2-7 Schematic representation of the combustion gas flow path through the PFS. The carbon filters, denoted by “C,” are actually horizontal beds with gas flow from the first bed through the second bed and then out through the HEPA filter, denoted by “H.” “F” is a generic denotation for various types of filters. The efficiency of the particulate prefilter is 85 percent. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008.
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-8 An M-40 protective mask with the filter C-2 canister attached. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. ana Department of Environmental Management 1001 waste code and is to be disposed of accordingly, at an approved treatment, storage, and disposal facility (TSDF). MANAGEMENT OF USED CARBON Two considerations dictate how used carbon is handled on-site: Is the carbon contaminated with agent? How much agent is present on the carbon? The current practice when a filter tray containing exposed carbon is removed from operation is to first bag the tray in two plastic bags and then place the double-bagged tray in a 95-gallon polyethylene drum (see Figure 2-9), which is stored for future disposal. This practice avoids unnecessarily exposing personnel to agent as would be the case if the carbon were to be removed from the filter trays prior to packaging for storage and disposal. While this approach minimizes any chance of exposure to agent during packaging, it makes it difficult to characterize the amount of agent that might be present on the used carbon. Recall from Table 2-1 that each MDB HVAC filter unit typically consists of six banks and each bank consists of 48 filter trays. Each filter tray is specified to contain 48.3 lb of carbon. Only the used activated carbon from the PFS is handled in bulk form; i.e., the used carbon is not contained in filter trays. The used carbon from PFS filters is emptied as a loose solid into plastic bags, and the bags are placed in polyethylene drums for storage and disposal. The PFS filter beds are arranged in two horizontal zones in series in the process vent gas stream with ACAMS monitoring between the zones. In some facilities, combustion gas flowing to Zone 1 is not monitored for agent because it is expected to be free of agent during normal plant operation based on tests performed when the facility was licensed for operation. While the PFS carbon is not expected to be exposed to agent, each disposal facility has installed a DAAMS monitor downstream of Zone 1. The sampling tubes in this monitor are regularly removed and analyzed in the laboratory. Finding 2-1. At some chemical agent disposal facilities, no depot area air monitoring system monitor has been installed in front of Zone 1 of the pollution abatement system filtration system. Recommendation 2-1. If the activated carbon in a pollution abatement system filtration system unit at a chemical agent disposal facility is ever to be changed out, consideration should be given to installing a depot area air monitoring system (DAAMS) upstream of Zone 1 (the first carbon bed) of the pollution abatement system filtration system if none exists now. The addition of this DAAMS unit would document the absence of agent in the gas stream flowing to the carbon in Zone 1, even though no agent is expected to be released as a result of incineration and subsequent scrubbing of the incineration flue gases. While current management philosophy dictates handling the used carbon as contaminated material, most of the used carbon will be unexposed even at the end of agent disposal operations, barring an airborne release on-site. Furthermore, standard operating procedures may preclude the exposure of filters in air streams that contain agent. Four key factors that reduce the agent loading on the MDB HVAC filter are these: Keeping agent vapor levels low in Level A (the most contaminated) process areas by periodic decontamination with caustic to clean up spills and leaks. Providing ACAMS and DAAMS monitoring between zones. A vestibule is provided to change
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities TABLE 2-1 Uses of Activated Carbon Filters at Chemical Agent Disposal Facilities Use Typical Configuration Expected Agent Exposure Level ACS filter 1 filter tray per ACS High. Filters are exposed to vent gases flowing from headspace of the agent collection tanks, which feed agent to the LIC. Banks 1 and 2 of each filter unit of the MDB HVAC system filtersa Each filter unit bank contains 48 horizontal filter trays typically arranged in 6 columns and 8 rows. Bank 1 is the first bank that MDB air encounters and Bank 2 is the second bank. Semicontinuous monitoring (ACAMS/DAAMS) is used after Banks 1 and 2. High. Filters in Banks 1 and 2 are exposed to any agent vapors in air from the processing rooms. Filters in Banks 1 and 2 are changed if agent breakthrough above the short-term limit is detected between Banks 2 and 3. A filter housing vestibule is installed for removal of Bank 1 and 2 filter trays in a controlled environment.b Banks 3, 4, 5, and 6 of each unit of the MDB HVAC system filters Each filter unit bank contains 48 horizontal filter trays typically arranged in 6 columns and 8 rows. Air from Bank 2 flows through Banks 3 to 6 before flowing to the plant stack. Semicontinuous monitoring (ACAMS/DAAMS) is used after Banks 3, 4, and 5. None. ACAMS monitoring between Banks 2 and 3 provides data that demonstrate the lack of exposure.b PAS/PFS filters 3 filter units; 2 banks of bulk carbon/unit None. By design, agent is destroyed by incineration in the DFS, LIC, and MPF. Agent would only be present in offgas during upset operations. DFS cyclone enclosure filter 1 filter unit; 2 filter banks; 12 trays/bank None. Agent could be present in ash during upset operations. At TOCDF the cyclone ash collection system enclosure has no filter and is vented to the MDB HVAC system filters. Laboratory hood exhaust filter 1 filter unit; 2 banks/unit; 48 filter trays/bank None. Normally not expected based on laboratory procedures. M-40 mask canisters 1 canister/mask None unless a mask used in area where agent vapors are present. Control room ventilation air supply filter 1 filter unit; 2 banks/unit; 48 filter trays/bank None. No agent expected in ambient air. Laboratory ventilation air supply filter 1 unit; 2 banks/unit; 48 filter trays/bank None. No agent expected in ambient air. Personnel and maintenance building ventilation air filters 1 filter unit; 1 bank/unit; 36 filter trays/bank None. No agent expected in ambient air. Site maintenance facility; mechanical maintenance facility; electrical maintenance facility, protection facility ventilation air supply filters 2 filter units each; 5 filter trays/unit None. No agent expected in ambient air. a Typically, there are 9 MDB HVAC filter units each consisting of 6 banks of filters arranged in series with respect to airflow. b At UMCDF, the policy is to change the filters in Banks 1, 2, and 3 if agent breakthrough above the short-term limit is detected between Banks 3 and 4. However, in this report, the committee has formulated its findings and recommendations and supporting text on the expectation that MDB HVAC Bank 3 filter at UMCDF will not experience agent exposure above the short-term limit. This expectation is based on the monitored experience to date concerning Banks 1 and 2 carbon at all sites. SOURCE: Adapted from Timothy Garrett, Site Project Manager, ANCDF, “Carbon management by site,” Presentation to the committee, July 23, 2008. out the filter trays in Banks 1 and 2 when agent breakthrough is detected at the outlet of Bank 1 filters. Figure 2-10 shows a vestibule on the side of an MDB HVAC unit. Thus, used activated carbon from Bank 3 and higher is never exposed to chemical agent during normal operation.4 The low volatility of VX and distilled mustard agent, HD, which results in low carbon filter loading. The nerve agent GB, which is more volatile, presents the potential for high carbon filter loading. The degradation of agent on activated carbon at varying rates in the presence of moisture in the filtered gas stream (see Chapter 4). Current evaluations of the long-term behavior of agents on activated carbon indicate that chemical agents are hydrolyzed by the water adsorbed on the carbon. (See Table 2-5 for information on properties of 4 See footnote b in Table 2-1.
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities TABLE 2-2 Estimated Carbon Waste Inventories (in Pounds) for CMA Chemical Agent Disposal Facilities as of September 29, 2008a Site Existing Inventory Changeout Prior to Closure Total Generated at Closure Off-site Shipment On-site Treatment in MPF ANCDF 18,000 209,700 573,700 642,700 158,700 UMCDF 148,100 60,400 304,000 598,200b 54,400 TOCDF 367,700 40,000 325,000 537,400 195,300 PBCDF 33,100 48,500 302,400 295,100c 96,900 NECDF 235,000 0 35,000 270,000 0 aWeights may include carbon, carbon tray materials, and packaging. Quantities have been rounded. bInformation updated as of March 17, 2009. Includes 140,000 lb additional PFS carbon since September 29, 2008, estimate. cInformation updated as of March 18, 2009. SOURCE: Adapted from information provided to the committee by Timothy Garrett, Site Project Manager, ANCDF, as of September 29, 2008. agents.) Chapter 4 provides a detailed discussion of the chemical reactions of agent on activated carbon. At chemical agent disposal facilities using incineration to destroy agent, the ACS filters and personnel protective equipment canister carbon are expected to be disposed of on-site in the MPF. CMA plans to dispose of all other used carbon by bagging and drumming it and eventually shipping it to a qualified TSDF. As noted previously, the bulk carbon from the PFS will be bagged and drummed as loose material. All other used carbon will be contained in metal filter trays similar to those used in the MDB HVAC (see Figures 2-3 and 2-4). TABLE 2-3 Summary of Sources and Estimated Inventories (in Pounds) of Carbon Exposed to Agent at CMA Incineration Sites During Operations and Closurea Site ACS Laboratory MDB HVAC M-40 Mask Canistersb Other ANCDF 3,600 <100 153,800 1,400 UMCDF 4,800 <100 47,500 2,100 TOCDF 200 15,300c 159,000 3,100 20,800d PBCDF 1,200 <100 95,600 <100 Total 9,800 15,300 455,900 6,600 20,800 aWeights may include carbon, carbon tray materials, and packaging. Information is as of September 29, 2008. Estimates of exposed carbon made on basis of anticipated on-site treatment. Quantities have been rounded. bCarbon from M-40 mask canisters, while normally not exposed to agent, is generally expected to be treated as exposed at most sites in view of the relatively small amounts involved. cThis carbon amount is the result of the significantly larger amounts and greater variety of materials tested over the longer duration of TOCDF operations compared to other sites. dThis carbon amount is the result of a ton container sampling operation unique to the site. SOURCE: Adapted from information provided to the committee by Timothy Garrett, Site Project Manager, ANCDF, September 29, 2008. The ACS filter trays and gas mask canisters, including the metal canister frames and canister bodies, are double bagged, placed in 95-gallon polyethylene drums, and sent to storage. Subsequently, when operating schedules permit, they are removed from the drums, placed in waste incineration containers, and treated in the MPF. In the MPF, the spent carbon and container are treated to an agent-free condition for several hours as they pass through each zone. The MPF process meets TABLE 2-4 Summary of Sources and Estimated Inventories (in Pounds) of Unexposed Carbon Used at CMA Incineration Sites During Operations and Closurea Site PFS Carbon (Regular) Laboratory MDB HVAC PFS Sulfur-Impregnated Carbon Control Room Other ANCDF 115,500 15,400 414,700 69,300 15,400 12,400 UMCDF 270,000b 10,600 95,000 200,000b 5,300 17,300 TOCDF 0c 6,300 318,000 240,000d 5,000d 2,500d PBCDF 80,800e 15,900 127,500 48,500f 8,000 14,400 Total 466,300 48,200 955,200 557,800 33,700 46,600 a Weights may include carbon, carbon tray materials, and packaging. Information is as of September 29, 2008, unless otherwise noted. Estimates of unexposed carbon made on basis of anticipated off-site treatment. Quantities have been rounded. b Information updated as of March 17, 2009. c PFS was only recently added at TOCDF for the processing of mercury-contaminated mustard agent and therefore only sulfur-impregnated carbon is to be used. d Information updated as of March 19, 2009. e Information updated as of March 18, 2009. Of this amount, 48,500 lb has already been shipped off-site. f Information updated as of March 18, 2008. SOURCE: Adapted from information provided to the committee by Timothy Garrett, Site Project Manager, ANCDF, September 29, 2008.
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities FIGURE 2-9 A 95-gallon drum for storage of used carbon filter trays. SOURCE: Robie Jackson, Waste Management Manager, ANCDF, and Tracy Smith, Trial Burn Manager, ANCDF, “The use of carbon at ANCDF,” Presentation to the committee, June 5, 2008. the temperature and time criteria,1000°F for at least 15 minutes, to allow the treated residual materials leaving the MPF to be safely released to a commercial disposal facility. However, any carbon must be kept in the MPF until it has finished smoldering. Treating all the carbon filter units in the MPF would seriously delay the schedule for completion of facility operations and closure. FIGURE 2-10 Vestibule on the side of an MDB HVAC unit. SOURCE: Photograph taken at ANCDF and provided courtesy of ANCDF. For the used carbon that is to be shipped to a qualified TSDF, a permitted protocol is needed. At the time this report was being written, CMA was working on such a protocol that uses sampling, extractive analysis, and transportation risk assessment (TRA) guidelines to establish the conditions under which the carbon can be safely transported to an off-site qualified TSDF with-out prior on-site treatment (see Chapter 4 for further discussion on an analysis protocol). The waste control limits for off-site shipment at operating sites other than UMCDF are 20 parts per billion (ppb) for GB and VX and 200 ppb for mustard agent; for UMCDF, the state has set permit compliance concentrations that serve a similar purpose: at 13 ppb for VX, 16 ppb for GB, and 152 ppb for HD (see Chapter 3). The CMA TRA approach requires the chemical agent disposal facility TABLE 2-5 Pertinent Physical Properties of the Chemical Agents and Mercury Property Nerve Agent Blister Agent GB VX HD Elemental Mercury Vapor pressure (torr) 2.48 at 25°C 0.410 at 0°C 8.78 × 10−4 at 25°C 4.22 × 10−5 at 0°C 0.106 at 25°C 1.2 × 10−6 at 20°C Volatility (mg/m3) 18,700 at 25°C 3,370 at 0°C 12.6 at 25°C 0.662 at 0°C 75 at 0°C 906 at 25°C 0.884 Boiling point (°C) 150 292 218 357 Freezing point (°C) −56 <−51 14.45 −38.87 Solubility (g/100 g water) Miscible 5% at 21.5°C 0.092 at 22°C Insoluble SOURCE: Lide (1985) and U.S. Army (2005).
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Disposal of Activated Carbon from Chemical Agent Disposal Facilities to estimate the maximum amount of agent that might be present in each carbon container. This amount will then be compared to the maximum amount determined for safe shipment by a “bounding” TRA prepared for the anticipated size and method of shipment (see Chapter 7). Finding 2-2. Carbon is used at many locations in a chemical agent disposal facility. However, it will be exposed to agent-contaminated air or process vent streams in only two locations during normal operation: the agent collection system vent filters and Banks 1 and 2 of the heating, ventilation, and air conditioning filter units. Recommendation 2-2. A recognized means for characterizing hazardous waste for regulatory purposes is known as “generator knowledge” (as described in Chapter 3). It should be the basis for determining which used carbon can be considered unexposed to agent and thereby minimizing the use of sampling and analysis for final disposition of the carbon. REFERENCES Lide, D.R. 1985. Handbook of Chemistry and Physics, 66th edition. Boca Raton, Fla.: CRC Press. NRC (National Research Council). 1999. Carbon Filtration for Reducing Emissions from Chemical Agent Incineration. Washington, D.C.: National Academy Press. U.S. Army. 2005. Potential Military Chemical/Biological Agents and Compounds. FM3-11.9/MCRP3-37.1 B/NTRP3-11.32/AFTTP (I) 3-2.55, January. Fort Monroe, Va.: U.S. Army Training and Doctrine Command.