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7 Disposal of Carbon from Chemical Agent Disposal Facilities
Pages 52-60

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From page 52...
... It had approvals. a regulatory permit allowing shipment of all of its The central theme of this report is that the used exposed carbon as a listed secondary waste to a qualiactivated carbon from chemical agent disposal facili- fied treatment, storage, and disposal facility (TSDF)
From page 53...
... levels of mustard agent HD were placed in 95-gallon Fortunately, no explosive event happened at JACADS, but polyethylene drums and shipped by truck to the Veolia the possibility is real and must be considered. A prudent Environmental Services Facility in Port Arthur, Texas, course now would be for the Chemical Materials Agency to where the used carbon was incinerated without open immediately pursue alternative disposal options for treating spent activated carbon resulting from current operations as ing the drums.
From page 54...
... These filter trays are placed in waste incineration of used unexposed carbon from Banks 3 through 6 of containers that are fed to the MPF. Since the carbon the HVAC filter units to Calgon Carbon Corporation would not be completely oxidized at the end of normal for reactivation.
From page 55...
... Recommendation 7-4.  Although carbon can be successfully treated in the metal parts furnace, on-site Recommendation 7-5b.  The Chemical Materials disposal treatment of exposed carbon in the metal parts Agency should review the planned sampling and furnace should be limited to small quantities of exposed analysis procedures for carbon that will be treated in the carbon -- from, for example, agent collection system fil- autoclave. This would ensure that they are appropriate ter units and M-40 protective mask canisters -- because for achieving the postautoclave processing condition the time required to completely oxidize all of the of the carbon and that they can reliably measure agent exposed carbon generated at a chemical agent disposal concentrations at levels required by the permit for offfacility would seriously extend the disposal operations site shipment to a hazardous waste disposal facility.
From page 56...
... container, the number of containers per shipment, SOURCE: Adapted from Michael McNaughton, Southwest Research and the total number of shipments in a given time. Institute "Analytical procedures for GB/VX carbon," Presentation to the committee, July 23, 2008; Brian O'Donnell, Chief, Secondary Waste, These values are set to limit general population risk to Closure Compliance and Assessments, CMA, "Transportation risk assess1 acute exposure guideline level (AEGL)
From page 57...
... A protocol and a procedure would have to be Finding 7-7.  The Chemical Materials Agency car- established to determine how much decontamination bon management strategy includes treatment of all solution should be added and how to ensure adequate of the agent collection system filter unit carbon and wetting of carbon surfaces to achieve decontaminacarbon from the M-40 protective mask canisters on- tion to levels safe for shipment. While experimental site because treatment of the small quantities involved data indicate that a pH of 7 completely hydrolyzes GB will not disrupt or delay overall facility operations or in solution, decontamination solution having a pH of closure.
From page 58...
... caustic solution with a pH at or above 10 will guarantee that the GB concentration is below the waste control Finding 7-9.  Reactivation of unexposed carbon from limit. Such a method could eliminate the need to mea- chemical agent disposal facilities has been demonsure agent contamination on carbon before shipping it strated by the experience at the Newport Chemical off-site.
From page 59...
... Anniston Chemical Agent Disposal Facility appear to be below the waste control limits of 20 parts per billion. General Recommendation 1.  All unexposed carbon However, the remaining concentration of GB appears (as determined by generator knowledge)
From page 60...
... decontaminated carbon and decontamination since the chemical agent disposal facilities expect to solution can then be shipped off-site. The method operate without changing out the heating, ventilation, of applying the decontamination solution must be and air conditioning filter units before closure.


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