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OCR for page 14
Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munition Disposal System: Letter Report TOCDF CLOSURE STATUS AND ISSUES Facility Description To dispose of chemical agents, TOCDF uses an incineration process comprising five interconnected systems: System for unloading and unpacking system for munitions from the adjacent Area 10 storage of the Deseret Chemical Depot (DCD); Separate disassembly systems for rockets, bulk containers, mines, and projectiles; Furnace and incinerator systems that include a deactivation furnace system for energetic materials, a metal parts furnace, and two liquid incinerators for agent; Various safety systems that include areas for explosive containment, a cascaded ventilation system that moves plant air from less contaminated to more contaminated areas, airborne agent monitoring, fire protection, and door access monitoring; and Various support systems, including pollution abatement systems, and controls for electric, fuel gas, instrumentation, compressed air, hydraulics, and cooling. The pollution abatement system has recently been upgraded by the addition of a postcombustion mercury abatement system to capture various degrees of mercury contamination in mustard agent ton containers and projectiles. Current Operations TOCDF began agent disposal operations in August 1996 and completed disposal of GB nerve agent and munitions in March 2002. Disposal operations for VX nerve agent began in March 2003 and were completed in June 2005. The mustard agent campaign began in July 2006 and is projected for completion in the third quarter of 2011. This date will meet the treaty obligation date of April 29, 2012. Closure Planning Status Closure planning for TOCDF is in early stages. A project management approach is envisioned, with experienced senior management personnel presently assigned to closure planning and implementation as their chief responsibilities. Moreover, experienced technical personnel familiar with the facility will be engaged during closure planning and implementation. Subject matter experts and proven procedures are also expected to be used as much as possible during closure. Closure planning will employ best practices and approaches based on lessons learned from JACADS and other closures. Detailed plans and procedures have yet to be developed, but a general framework and time line have been established. The committee anticipates that these plans and
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Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munition Disposal System: Letter Report procedures for closure would include an appropriate emphasis on safety, which were not discussed fully in the closure documents and presentations obtained while this letter report was being prepared. Approval of the basic closure plan is expected to be requested from the UDEQ in June 2010. The target date for planning completion is January 2011, and the expanded plans will include development of new documentation for unit-by-unit closure and the closure implementation schedule. TOCDF closure planners are maintaining good relations and cooperation with the UDEQ. Closure operations, including those for the munitions demilitarization building, are projected to begin in September 2011, but some advance work was being carried out as this report was being prepared (as discussed below). The metal parts furnace and liquid incinerators will be closed later in the schedule (mid-2013) to allow for their availability to process closure waste process. Present planning for TOCDF closure is based on a strategy of decontamination by moving progressively from the most contaminated to the least contaminated areas and structures. In general, this will involve removal of any residual agent and explosive material residues, followed by removal of agent-exposed equipment and subsequent decontamination of occluded spaces and exposed surfaces. Scabbling will be used if in-progress sampling shows it is needed.3 When an area and structure have been completely decontaminated, the strategy for decontaminating the cascaded ventilation systems is to use a final washdown, certify that occluded spaces have been appropriately decontaminated, and, finally, use ventilated and unventilated testing to measure internal ambient air agent concentrations in a controlled manner. Certain closure tasks, such as decontamination and removal of equipment, will be performed under partial-closure plans when possible without disrupting disposal operations. Already a number of such tasks have been completed. Early closure activities are projected to continue through August 2011. A large quantity of stored legacy secondary waste, secondary waste being generated during continuing munitions disposal operations, and waste from TOCDF closure operations is projected to be either processed on-site and/or shipped off-site. Treatment, if necessary, and shipment of such wastes will take place during continuing disposal operations as scheduling opportunities present themselves or, alternatively, during closure operations. Secondary waste from all sources is projected to be disposed of by the third quarter of 2014. The time line for TOCDF closure indicated above takes into consideration uncertainties concerning the UDEQ determinations on allowable standards for secondary waste treatment and off-site disposal. Site deconstruction is projected to continue until June 2014, with final administrative closure of TOCDF in February 2016. Notwithstanding the planning described above, and based largely on committee members’ collective experience and observations in obtaining permit changes, the committee believes that the current schedule is optimistic. Moreover, certain members of the public are known to take great issue with some of the activities surrounding the chemical demilitarization program. Generally speaking, the more contentious the issues, the longer the permitting processes are likely to take. 3 Scabbling is the removal of a surface layer of material (such as concrete) to a specified depth.
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Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munition Disposal System: Letter Report Current Permit Status The currently approved version of the TOCDF RCRA permit includes a basic closure plan (Army, June 2009). The Army is presently pursuing a permit modification for both CAMDS and TOCDF that combines active operations of both facilities, including closure, under the TOCDF permit.4 Utah officials have indicated that they will soon be ready to act on permit modification approvals, following RCRA public involvement and administrative actions.5 TOCDF has held initial discussions with the UDEQ regarding closure, focusing on specific issues. A RCRA permit modification to establish details for the regulatory-required closure plan is planned for submittal by June 2010. TOCDF closure plans within the existing (prepermit modification) permits indicate that the closure performance standard will be based on an industrial future use scenario. The TOCDF closure plans also indicate that the incinerators and other units will be decontaminated as needed and dismantled. Some structures for TOCDF (primarily those used for nonagent operations) may remain following closure. Presently, TOCDF plans to remove all materials, including scrap metal and demolition wastes (e.g., concrete) from structures. Current requirements call for all of these materials to be disposed of in a hazardous waste landfill as designated F999 wastes. Some wastes, such as demilitarization protective ensemble suits, may retain the combined P999/F999 waste code (discussed later under Utah Regulatory Requirements) following decontamination. Waste analysis to meet waste control limits (WCLs) and other criteria have been required for both chemical agent and for agent degradation products prior to the off-site transport of various wastes generated during disposal operations (such as decontaminated munitions casings). However, analytical methods for these analytes in certain closure wastes (such as concrete and carbon) are still under development and will require regulatory approval. End Use and End Use Status The site is envisaged at present to be closed to meet an industrial end use specification and will become part of the Tooele Army Depot following closure. Complete closure of the TOCDF site and remediation to levels of residual contamination for industrial use is envisioned. 4 Information here has been taken from a question-and-answer session between Ted Ryba, Site Project Manager, TOCDF Field Office, and the committee, on October 22, 2009. 5 Information in the final sentence of this paragraph and from the next three paragraphs is from a question-and-answer session between Dennis Downs, Director, Utah Department of Solid and Hazardous Waste, and the committee, on October 22, 2009.