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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 CAMDS CLOSURE STATUS AND ISSUES Description CAMDS was constructed to develop and test equipment and technologies for dismantling and treating the stockpile of chemical agents and munitions stored on Johnston Island and at eight storage sites in the continental United States. The CAMDS facility was originally constructed between 1974 and 1978 and began munitions processing on September 10, 1979. CAMDS was a pilot plant for various processes later constructed as fixed units at either baseline incineration or chemical hydrolysis-based chemical agent disposal facilities. Some of the processes developed and tested at the facility are listed in Table 2. A total of 98,051 munitions and 363,524 pounds of chemical agents, including GB, VX, and mustard agent, were destroyed at the facility ending in March 2005.6 Many of the process units and much of the equipment at CAMDS have been dismantled. CAMDS closure is complicated by a number of factors, including the following: (1) the age of the various units, resulting in incomplete knowledge of the operating history; (2) its use as a pilot plant, resulting in use for a wide variety of chemical demilitarization operations; and (3) its configuration as multiple interconnected buildings having a common ventilation system and common utility services that require careful attention to the order of shutting down parts of the system. TABLE 2 Examples of Equipment Developed at CAMDS Process type Equipment Bulk neutralization Area detection system Instrumented ton container Incineration Liquid incinerator Deactivation furnace system Metal parts furnace Hydrolysis (Assembled Chemical Weapons Alternative [ACWA] program) Projectile washout system Thermal destruction (ACWA program) Metal parts treater SOURCE: Elizabeth Lowes, Deputy General Manager, Closure Integration, EG&G, “CAMDS and TOCDF closure approach/status,” Presentation to the committee, October 21, 2009. 6 Elizabeth Lowes, Deputy General Manager, Closure Integration, EG&G, “CAMDS and TOCDF closure approach/status,” Presentation to the committee, October 21, 2009.
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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 Closure Operations Current operations are limited to closure activities and the on-site laboratory, the last mentioned of which continues to provide analytical support for the DCD, including capabilities not found elsewhere at DCD. Closure activities are focused on 61 hazardous waste management units, including the following: 14 Subpart I units (chemical storage areas) 43 Subpart J units (tank systems) 1 Subpart O unit (incinerator) 3 Subpart X units (miscellaneous) Closure activities will involve the facility ventilation system as well, including the carbon filter units; the destruction of a number of buildings from which the bulk of the processing units have already been removed and that will also require asbestos abatement measures; and outside chemical and agent transfer lines. Closure Planning Status The current operator of the CAMDS facility, the EG&G Division of URS Corporation, only recently assumed control of the facility, and final closure planning is not complete. However, many of the processing units were dismantled and removed by an earlier contractor. The current contractor has prepared partial closure plans for the material treatment facility and chemical test facility, and acceptance is being negotiated with the UDEQ. Current efforts are directed toward the material treatment facility to refine and test closure procedures. They will be followed by deconstruction of the remaining buildings, from the most contaminated to the least contaminated. For each building, decommissioning work packages will be prepared that recognize the unique processes and contamination history of the building and utilize a 10-step approach for each building as follows: Establishment of engineering controls and monitoring, Preliminary survey, Preparation for work execution, Decontamination and equipment disposition, Post-disposition survey, Ventilated vapor screening level (VSL) monitoring,7 Unventilated VSL monitoring, Final isolation, Demolition, and 7 The VSL concentrations are equivalent to the short-term limit (STL) value, which is a concentration typically expressed in milligrams of specific agent per cubic meter of air. STLs are similar to short-term exposure limits (STELs) but without the 15-minute exposure time component. The VSL and short-term limit values for agents of interest are as follows: GB, 0.0001 mg/m3; VX, 0.00001 mg/m3; mustard agent, 0.003 mg/m3 (NRC, 2007).
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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 Closure verification sampling. CAMDS closure involves some unique complications. Because different process units were originally constructed over time, their closure involves dismantling numerous buildings with potentially different challenges. The buildings are also tied together with common utilities, including ventilation and sump drains, which could also complicate the decontamination procedures. The analytical laboratory at CAMDS is not a hazardous waste management unit identified within the permit covering CAMDS, so no specific permit actions are required to remove it from the applicable RCRA permit. However, it is anticipated that the heating, ventilation, and air conditioning filters for the laboratory will need to be worked out in the future. Finally, current closure planning does not address issues that will limit reuse of the property, such as the presence of subsurface fuel oil contamination. This contamination, unrelated to the destruction of agent, is designated Solid Waste Management Unit (SWMU) 13. This and other SWMUs on DCD are separate from the closure of CAMDS. Current Permit Status A pending permit modification for both CAMDS and TOCDF provides for combining the active operations of both facilities, including closure, under the TOCDF permit.8 Utah officials have indicated that they will soon be ready to act on permit modification approvals, following RCRA public involvement and administrative actions. The resulting permit will contain basic closure plans for CAMDS, which will eventually need to be expanded into unit-by-unit detailed closure plans and approved by the state prior to execution.9 CAMDS has already started work on these more detailed closure plans, which were not, however, made available to the committee in time for this report. In the interim, CAMDS has proceeded with preclosure decommissioning activities (e.g., decontamination, removal of equipment) with the knowledge and oversight of the UDEQ.10 End Use and End Use Status Like TOCDF, the CAMDS site will become part of the Tooele Army Depot upon closure. Closure will involve decontamination and disposal of all agent-contaminated facilities and all buildings and facilities not needed by the depot. Closure of the CAMDS site will not resolve outstanding contamination issues, if any, associated with the analytical laboratory. In addition, subsurface fuel oil contamination from SWMU 13, 8 Information from a question-and-answer session between Ted Ryba, Site Project Manager, TOCDF Field Office, and the committee, on October 22, 2009. 9 Information from a question and-answer session between Dennis Downs, Director, Utah Department of Solid and Hazardous Waste, and the committee, on October 22, 2009. 10 Information from a question-and-answer session between Jerold Lynn, Site Project Manager, CAMDS, and the committee, October 22, 2009.
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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 below the CAMDS site, is being addressed under a general permit corrective action program for DCD and thus is not an issue for TOCDF or CAMDS closure. ENVIRONMENTAL REGULATORY ISSUES APPLICABLE TO CAMDS AND TOCDF In closing CAMDS and TOCDF, the Army must comply with regulations established by the UDEQ under its delegated authority for a number of different environmental regulatory programs, including the Clean Air Act, the Clean Water Act and hazardous waste management regulations established under RCRA. The most challenging of these for CAMDS and TOCDF are the facility closure regulations under RCRA (40 CFR Part 264, Subpart G). RCRA Regulatory Background Utah has adopted EPA’s RCRA closure regulations established under 40 CFR Part 264, Subpart G (Utah R315-8-7). These require facilities to comply with a closure performance standard. The performance standard for closing a facility is typically translated into risk-based quantitative criteria (such as concentrations) for specific constituents in waste materials. These criteria depend on the future use of the site. Criteria for unrestricted (residential) use are generally more protective than those for industrial use. The RCRA closure regulations also require facilities to submit detailed closure plans when applying for the permit. The plan then becomes part of the permit when it is issued. It may dictate a simple closure that applies to the entire unit or facility or may propose a series of partial closures for specific units that will eventually lead to final closure for the entire facility. Further, the closure plan includes waste inventory estimates, identification of the closure performance standard, and a schedule for closure, among other information. Closure plans may be revised as needed as closure operations proceed, but such revision would require a formal permit modification. Utah Regulatory Requirements and Practices Utah has imposed regulations and practices with respect to chemical agents, many of which can be considered more restrictive than the usual RCRA requirements. These unique regulations and practices have evolved over the years and are currently applicable to closure. Specific Utah regulations and practices are identified below. Utah Regulatory Requirements P999 and F999 Waste Codes. Utah has listed “Nerve, Military, and Chemical Agents” as acute hazardous waste under hazardous waste code P999 and “Residues from Demilitarization, Treatment and Testing of Nerve Military and Chemical Agents” as
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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 listed hazardous waste under hazardous waste code F999.11 Throughout the demilitarization campaign at CAMDS and TOCDF, restrictions were placed on management of acutely hazardous waste P999, and wastes resulting from treatment of the P999 wastes were designated F999. Residues from treatment, storage, or disposal of F999 wastes retain the hazardous waste designation and the code F999. Thus, wastes produced during closure, even those that result from treatment of F999 wastes, are required to be managed as F999 hazardous wastes, even if they are known to contain no detectable agent or other hazardous constituents.12 Cleanup Action and Risk-Based Closure Standards. Utah has established specific requirements for closure of industrial sites: “Cleanup Action and Risk-Based Closure Standards” (UDEQ, 2001). Closure performance standards are developed in accordance with RCRA regulations. Risk-based closure performance standards are determined case by case for nearly all facility closures. Utah Regulatory Practices Agent Vapors. Utah includes materials contaminated as a result of actual or potential contact with agent vapors as F999 waste. The result is that significant additional volumes of various types of materials would become regulated as hazardous waste once generated during closure. Off-site Restrictions. Utah places restrictions on the off-site transportation of potentially agent-contaminated materials for further treatment and/or disposal. In Utah, wastes must be tested against the WCLs and may be transported off-site only if these levels are met. The WCLs were initially developed as drinking water standards for soldiers in the field (HQDA, 2005; HQDA, 2008). Even if the WCL is met, these wastes are still controlled as hazardous waste under the Utah F999 waste code. Waste Characterization. Since the early days of the chemical demilitarization program, the Army, being concerned primarily with worker exposure to agent vapor hazards, has relied on the vapor screening of materials and wastes that have been exposed to chemical agents (HQDA, 2008). In contrast, RCRA has historically used direct chemical analysis of wastes for constituents of concern (EPA, 2009). Utah has been reluctant to accept vapor screening as a means of characterizing wastes that may have been exposed to liquid or vapor chemical agent. In those limited cases where it has accepted vapor screening, Utah has required the Army to apply more stringent criteria than the Army itself has established. For example, whereas the Army’s screening level for protection of workers is 1.0 VSL, Utah requires the Army to apply a more stringent standard, 0.5 VSL, as added protection. Further, some waste streams, in particular those that may absorb chemical agent, must be decontaminated before vapor screening. 11 Acute hazardous wastes are established under the RCRA program at 40 CFR 261.33(e) (Utah R315-2-9). F999 is added by the UDEQ to the listing of hazardous wastes from nonspecific sources found in 40 CFR 261.31 (Utah R315-2-11). 12 While RCRA and the Utah regulations provide means of demonstrating that F999 wastes are not hazardous (that is, of “delisting”), the demonstration required is often arduous and prohibitively expensive.
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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 Waste Activated Carbon and P999. Waste carbon that is actually or potentially contaminated with chemical agent is designated P999 under Utah regulations. Under present Utah restrictions, P999 wastes may not be sent off-site for treatment and disposal. For example, much of the activated carbon (the final four of six banks) of the heating, ventilation, and air conditioning system has not, based on generator knowledge, been exposed to agent. It will also be necessary to evaluate in detail the disposal of carbon from the TOCDF pollution abatement system filter system, which is likely to contain mercury or mercury compounds from the processing of mustard agent munitions having mercury contamination. Dual Waste Code for Some Materials. Some waste materials, primarily permeable solids, can be difficult to sample and analyze for chemical agents. Others, such as demilitarization protective ensemble suits that become waste after use, can be difficult to sample. In these cases, Utah has required decontamination of the materials and application of a dual P999/F999 waste code prior to off-site transport for disposal. The standards and practices that Utah uses to address demilitarization disposal operations were developed before chemical agent began to be destroyed at CAMDS and TOCDF. Now, however, there will not be any significant amount of agent present during closure. Furthermore, decontamination procedures will further reduce any agent residues that may be contaminating waste materials. Thus, the risks to human health and the environment from agent and its degradation products during closure operations will be reduced. This should provide the basis for considering less restrictive practices than the present UDEQ requirements, based on an evaluation of the risks of managing the closure wastes. PUBLIC PARTICIPATION Community involvement at the Utah demilitarization facilities is conducted primarily through the Citizens Advisory Commission (CAC), appointed by the Governor of Utah. The committee expects the CAC to provide opportunities for public participation in closure planning. Thus far, although the CAC is aware that closure planning is under way, it is still engaged in the oversight of demilitarization operations. Although the committee found the community was concerned that the end of demilitarization operations might lead to layoffs or have other economic consequences, it did not find any community concerns that the closure of TOCDF and CAMDS would affect the environment. The CAC, as well as other community bodies, such as the Restoration Advisory Board for the entire DCD, are concerned about munitions response, corrective action, and related disposal activities, but those issues are beyond the scope of the task for this committee. The Army and community have not yet developed a plan for community involvement during closure other than the requisite state forums under RCRA. While closure oversight is likely to be less intense than discussions of demilitarization, the CAC or a similar body can serve a valuable role during closure. The committee urges the Army
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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 to discuss with the CAC ways to continue constructive public involvement between the end of demilitarization and formal closure. REFERENCES EPA (U.S. Environmental Protection Agency). 2005. RCRA Hazardous Waste Identification Training Module, 40 CFR 261, September, Washington, D.C.: Environmental Protection Agency. EPA. 2009. SW-846 Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. Available online at http://www.epa.gov/waste/hazard/testmethods/sw846/online/index.htm. Last accessed November 23, 2009. HQDA (Headquarters Department of the Army). 2005. TB Med 577 Sanitary Control and Surveillance of Field Water Supplies. Available online at http://chppm-www.apgea.army.mil/documents/TBMEDS/TBMed577-15Dec2005.pdf. Last accessed November 19, 2009. HQDA. 2008. DA-PAM 385-61 Toxic Chemical Agent Safety Standards. Washington, D.C.: Department of the Army. NRC (National Research Council). 2007. Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements. Washington, D.C.: The National Academies Press. NRC. 2009. Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities. Washington, D.C.: The National Academies Press. TOCDF (Tooele Chemical Agent Disposal Facility). 2009. Closure Plan Attachment 10. Stockton, Utah: Tooele Chemical Agent Disposal Facility. UDEQ (Utah Department of Environmental Equality). 2001. Title V Operating Permit. Available online at http://www.airquality.utah.gov/Permits/DOCS/11339pmt.20060502.pdf. Last accessed November 19, 2009. UDEQ. 2001. R315-101: Cleanup Action and Risk-Based Closure Standards. Available online at http://www.hazardouswaste.utah.gov/Rules/Adobe/HazardousWasteRules/R315-101.pdf. Last accessed December 17, 2009.