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.

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.

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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