Disposal of Legacy Nerve Agent GA and Lewisite Stocks at Deseret Chemical Depot Letter Report (2009) / Chapter Skim
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Letter Report
Letter Report
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Specifically, the Committee on Disposal of Legacy Nerve Agent GA and Lewisite Stocks at Deseret Chemical Depot reviewed information provided to it on the 50 percent design of the Area Ten Liquid Incinerator (ATLIC) facility.
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The committee believes the principal challenges to be addressed for the Area Ten Liquid Incinerator facility arise largely from the arsenic content in the lewisitethat is, from capture of the arsenic species and management of the resulting arsenic waste streams. Since GA is chemically similar to GB and contains no extraordinary amounts of regulated metals, its incineration is expected to be straightforward and to present no issues that have not been successfully resolved during GB disposal operations at the Tooele Chemical Agent Disposal Facility.
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identify all secondary waste streams generated at the Area Ten Liquid Incinerator facility; (2) adopt a comprehensive waste analysis plan that establishes appropriate sampling and analysis methods and waste control limits for each secondary -3
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Beaudet, Chair Committee on Disposal of Legacy Nerve Agent GA and Lewisite Stocks at Deseret Chemical Depot Attachments A Statement of Task B Pertinent Properties of GA and Lewisite C Process Flow Diagrams for GA and Lewisite Processing; Schematic Diagram of ATLIC Pollution Abatement System D Abbreviations and Acronyms E Committee on Disposal of Legacy Nerve Agent GA and Lewisite Stocks at Deseret Chemical Depot F Acknowledgement of Reviewers -4
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The remaining mustard agent containing high levels of mercury will be destroyed following installation and systemization of the pollution abatement system carbon filter system at the TOCDF, which were under way when this report was being prepared. This letter report examines the 50 percent process design provided by the Army and its contractor for the small destruction facility called the Area Ten Liquid Incinerator (ATLIC)
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Section 112 of the Clean Air Act required the EPA to establish emissions standards for hazardous air pollutants. These National Emission Standards for Hazardous Pollutants are commonly referred to as MACT standards because the EPA used the MACT concept to determine the levels of emission control.
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Construction cannot begin until receipt of the approval order for installation of the ATLIC facility. An approval order will be issued if the UDAQ determines that the degree of pollution control for emissions, including fugitive emissions and fugitive dust, is at least the best available control technology and that the facility complies with all applicable requirements for other air quality conditions, including the National Emission Standards for Hazardous Air Pollutants.
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Except for the acetic acid solution, which will be sent to the primary chamber, and the nitric acid, which will be recovered by diffusion dialysis, spent decontamination liquids and rinse water will be injected into the burner flame in the secondary chamber. Exhaust gas from the secondary chamber of the liquid incinerator is fed to a pollution abatement system (PAS)
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All agent and decontamination fluids removed from the TCs are pumped to the appropriate ATLIC feed tank or directly to the incinerator. The standard approach for accessing all of the TCsthat is, the 4 GA TCs, the 10 lewisite TCs, and the 10 transparency TCs that might contain lewisite residuesincludes the following key steps: All accessible liquid is transferred either to the primary chamber feed tank (lewisite and acetic acid rinse)
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The direct transfer of ton container liquid contents and decontamination fluid and rinse water to the Area Ten Liquid Incinerator primary chamber may not ensure that the flow and composition of the liquid to the primary chamber injector nozzle is uniform to thereby provide optimum incineration conditions. However, the Army is addressing this problem by providing a high fuel:feed ratio and by designing the injector to accommodate a range of fluid properties.
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But the application of this technology to nitric acid that contains both mercury and high concentrations of arsenic, as well as other contaminants from the lewisite ton containers, is untested. Alternatively, it might be possible to send the waste nitric acid that will be contaminated with arsenic, mercury, and other metals off-site for disposal to an appropriate treatment, storage, and disposal facility under conditions established in the state-approved Resource Conservation and Recovery Act permit, including any waste control limit for agent.
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Recommendation 4. Prior to systemization, the integrated Area Ten Liquid Incinerator and pollution abatement system should be assembled, tested, and debugged off-site with the same auxiliary fuel to be used in Area Ten.
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These changes will impact the details of the combustion patterns, but, given the reported increased total residence time, the Army expects that the destruction efficiencies will meet the RCRA requirements. 11 Trial burns with agent and spent decontamination solution liquid surrogates will be conducted to 10 Jim Clark, URS, "GA/lewisite–Area Ten Liquid Incinerator (ATLIC)
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The committee believes that the temperatures and times in the primary and secondary combustion chambers of the Area Ten Liquid Incinerator will ensure destruction efficiencies that meet regulatory requirements for the organic content of the GA and lewisite ton containers. The process for permitting a new incinerator under RCRA and MACT regulations requires trial burns to determine the range of operating conditions that will achieve the desired DRE.
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Extrapolation of experimental measurements and thermodynamic analysis suggest that HgCl2 is likely to be the dominant form of mercury at the exit of the secondary combustion chamber of the Area Ten Liquid Incinerator. Pollution Abatement System Based on the chemical composition of GA and lewisite, the anticipated products of combustion that will require treatment by postcombustion pollution abatement processes will be compounds containing arsenic (As)
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After quenching, the arsenic removed by the Area Ten Liquid Incinerator pollution abatement system is expected to be predominantly in the form of arsenic oxides. Any remaining AsCl3 will be removed in the quench towers because it is water soluble.
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At the 50 percent stage, the design status of the various components of the Area Ten Liquid Incinerator pollution abatement system ranges from design concepts to actual hardware that is ready for installation. While the design as a whole is 50 percent complete, the committee did not have access to detailed specifications for several of the more conceptual components and thus could not conduct an in-depth assessment of their operation.
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The committee believes the Area Ten Liquid Incinerator pollution abatement system, as designed, will meet EPA's Maximum Achievable Control Technology emissions limits for arsenic and mercury because it includes redundant operations for their removal. Recommendation 6.
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The unique waste streams of the ATLIC PAS containing arsenic are the following: Spent liquor from the common sump of the quench tower, packed-bed scrubbers, and the venturi scrubber; Particulate matter from the hopper that receives material dislodged from the baghouse filters; Spent SIC filters and HEPA filters used in the final stage of the PAS; Waste from the nitric acid diffusion dialysis process; and Rinsate from the TCs and spent decontamination solution. There may also be some slag from the secondary chamber of the ATLIC.
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Available information on the management of secondary waste streams from the Area Ten Liquid Incinerator facility seems to indicate a reasonable approach is being taken, but a more complete review must await the development of further information such as the waste analysis plan required by RCRA regulations. RISK ASSESSMENTS The ATLIC facility project team has established a system safety engineering management plan (SSEMP)
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Finding 15. A review of the hazard tracking log provided to the committee for the 50 percent design of the Area Ten Liquid Incinerator facility indicates that the risk assessment and safety analysis techniques are being properly applied.
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Proposed Installation and Operation of a Small-Scale Incineration Unit for the Destruction of Chemical Agents Tabun and Lewisite at the Deseret Chemical Depot in Utah. Edgewood, Md.: Chemical Materials Agency.
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