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Disposal of Activated Carbon from Chemical Agent Disposal Facilities
chapters are presented at the end of this Summary and in Chapter 7.
Only three types of filter units are expected to ever be exposed to agents under normal operating conditions: (1) those that filter the heating, ventilation, and air conditioning (HVAC) air from the munitions demilitarization building (MDB), (2) the filters installed on the vent line from the agent collection system storage tanks, and (3) the canisters for the M-40 protective masks used by workers. The carbon from the initial banks of MDB HVAC air filters accounts for by far the largest share of exposed carbon. All of the other filter units installed to protect personnel or the environment will never have been exposed to agent unless some upset had occurred (e.g., release of agent to the atmosphere outside the MDB).
The MDB, which is where the munitions or containers are opened and treated, has a cascading HVAC system that is designed to move ventilation air from clean, uncontaminated areas to areas having increasing levels of agent contamination. The HVAC system then discharges the air through banks of activated carbon filters. Each bank of the filter units, which are arranged in series, contains 48 metal trays each holding approximately 50 lb of carbon. An important feature of the system design is that operational procedures normally allow only the carbon in Banks 1 and 2 of the multibank adsorber units filtering the plant HVAC air to ever be exposed to agent. The carbon from Banks 3-6 of the HVAC filter units and the carbon from the pollution abatement system (PAS) filtration system (PFS) on each of the incinerators make up the bulk of the unexposed carbon. Estimates of the amounts of carbon that must be disposed of from the indicated sources at each site are tabulated in Tables S-1 and S-2. The ratio of unexposed to exposed carbon is approximately 4 to 1.
TABLE S-1 Summary of Sources and Estimated Inventories (in Pounds) of Carbon Exposed to Agent at CMA Incineration Sites During Operations and Closurea
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, as of September 29, 2008.
The disposal of the exposed and unexposed carbon is regulated under the Resource Conservation and Recovery Act (RCRA) by the respective state regulatory agencies. Each facility has been issued a RCRA permit under the applicable state regulations. These permits establish waste characterization requirements, pertinent sampling/analysis methodologies, waste disposal methods, operating parameters, and closure requirements for each facility. The state-issued RCRA permits for all of the disposal facilities specify waste control limits (WCLs) or, for Oregon, permit compliance concentrations (PCCs) in parts per billion (ppb) of chemical agent below which a waste may be shipped off-site for disposal.
The permits for the chemical agent disposal facilities at Anniston, Alabama, Pine Bluff, Arkansas, and Tooele, Utah (ANCDF, PBCDF, and TOCDF) set the WCL as 20 ppb for nerve agents GB and VX and 200 ppb for mustard agent, while the facility at Umatilla, Oregon (UMCDF) sets PCCs, which serve a similar purpose, at 13 ppb for VX, 16 ppb for GB, and 152 ppb for mustard.2 The primary analytical methodology for characterizing a waste at most of the chemical agent disposal facilities is set forth in EPA Publication SW-846; it includes the toxic chemical leaching procedure (TCLP), which is required to determine if a waste meets the toxicity characteristic definition.3
The existing requirements to transport activated carbon off-site for disposal are stated in each facility’s RCRA permit (Table S-3). Any changes require applying for a modification to the permit—the approval process takes approximately 1 year. Planned applica-
Brian O’Donnell, Chief, Secondary Waste, Closure Compliance, and Assessments, CMA, “Transportation risk assessment,” Presentation to the committee, July 24, 2008.
40 C.F.R. 261.24(a). A waste is considered hazardous for toxicity if the extract from the procedure contains a listed contaminant above a specified concentration, with mercury listed at 0.2 mg/L (Table 1).