based on the transportation risk assessment and the validated analytical methods.

  • Adding caustic solution to the drums. If the addition of caustic (NaOH) decontamination solution to a drum of exposed carbon completely wets the carbon, the caustic will hydrolyze the agents remaining on the exposed carbon to below the waste control limit (WCL) or permit compliance concentration (PCC). The drum containing the decontaminated carbon and decontamination solution can then be shipped off-site. The method of applying the decontamination solution must be negotiated and approved by the facility’s regulatory authority. Analysis for agent on the carbon should not be necessary with this arrangement.

General Finding 5. Environmental Protection Agency Method 3571 appears to have provided an improved method detection limit for extractive analysis of VX on the Bank 1 carbon sample from the Anniston Chemical Agent Disposal Facility, but it must still be validated. Neither Environmental Protection Agency Method 3571 for HD nor modified Method 3571 for GB, which appears to minimize re-formation of GB during extraction and analysis, had been validated at the time this report was being prepared.


General Recommendation 5. Both the original Environmental Protection Agency Method 3571 and the modified Method 3571 must be validated for use on carbon exposed to all three agents (GB, VX, and mustard) since the chemical agent disposal facilities expect to operate without changing out the heating, ventilation, and air conditioning filter units before closure.

REFERENCES

NRC (National Research Council). 2001. Standing Operating Procedures for Developing Acute Exposure Guideline Levels for Hazardous Chemicals. Washington, D.C.: National Academy Press.

NRC. 2007. Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements. Washington, D.C.: The National Academies Press.

NRC. 2008. Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants. Washington, D.C.: The National Academies Press.



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