Rapid Response System
RCRA Part X Research and Demonstration Permit
Comments prepared by Clearwater Revival Company
on behalf of Non-Stockpile Chemical Weapons Citizens Coalition
The Rapid Response System is a mobile system for demilitarization of Chemical Agent Indentification Sets (CAIS). The mobile system consists of three semi-trailers housing a analytical laboratory, power generator, and the glove box trailer. In the glove box trailer, workers unpack recovered CAIS items, verify the chemical contents, and oxidize the chemical warfare agent with a strong base in a hand mixer. The glove box trailer is equipped with air pollution control equipment and air quality monitoring devices.
Condition II.A.3 - "The Permittee is not authorized and therefore shall not treat hazardous wastes that are not currently stored, as of the effective date of this permit, on-site at the Deseret Chemical Depot."
According to Attachment 1 (p. 1), the hazardous wastes currently stored within the Deseret Chemical Depot include:
Condition III.D.3.a - All hazardous wastes generated as a result of operations by the Rapid Response System shall be sent offsite for treatment by a permitted hazardous waste incinerator.
Condition II.A.3 should limit the Rapid Response System to treatment of recovered Chemical Agent Identification Sets (CAIS) that are currently stored at the Deseret Chemical Depot. The current condition permit condition is overly broad and could be interpreted to include the other wastes identified in the permit.
- Obsolete M55 rockets containing chemical agent, propellants and explosives, declared as waste by the Army. The rockets are stored in 27 earth-covered igloos.
- Wastes associated with chemical ammunition maintenance or disposal activities, including spent carbon filters, scrap metal, spent decontamination solutions, spent solutions from air monitoring activities, incinerator ash, etc.
- Waste generated from RCRA and Comprehensive Environmental Response, Compensation, and Liability Act corrective actions both on and off Deseret Chemical Depot, including recovered CAIS.
The Rapid Response System process description (Attachment 2, p. 24), indicates that "..some CAIS items may repacked ... for ultimate return to Edgewood Research Development and Engineering Center for study" by the generator. Condition III.D.3.a would however prevent this.
Condition III.E.1 - The Construction of the Rapid Response System shall be built with the drawing submitted in the Engineering/Design Documentation of the Rapid Response System Part B Permit Application.
Condition III.D.3a is also not consistent with the generator's current waste management practices which include the recycling of decontaminated PIGs and other waste chemical agent containers. Condition III.D.3a, therefore prohibits the waste generator from pursuing an environmentally responsible and economic waste disposal alternative for wastes generated by the Rapid Response System.
Condition III.D.3a requires use of a disposal technology that has not been demonstrated to be the "best available technology." Currently, RCRA land disposal restrictions for most CAIS components are concentration based. Incineration has only been demonstrated to be the best available technology for treatment of phosgene and cyanogen chloride wastes.
Condition III.D.3a also discourages the generator from investigating treatment technologies to further reduce the volume or toxicity of hazardous wastes generated by the Rapid Response System.
The Rapid Response System drawings do not currently show a backup unit for the carbon air filter exhaust fan that is specifically required by Condition III.I.15, and required to meet Condition III.I.9.
Condition III.H SYSTEM TEST PLAN - "The only permitted treatment operations in the Rapid Response System are the four processes listed in Table 4-2 of Attachment 4 (Red, Charcoal, Charcoal "L", and Blue)."
Condition III.I.9 requires that the carbon filter system be operated continuously (the one exception is the shut down to replace spent carbon filters) until the closure of the Rapid Response System is completed per Condition II.J.
This condition of the permit is not consistent with Condition III.I.5 - "Contaminated dunnage shall be treated in accordance with Attachment 1."
Condition III.I.5 - All dunnage from each CAIS shipping container shall be processed prior to introducing a new shipping container can be introduced into glovebox. (sic)
Contaminated dunnage is not proposed to be treated by any of the four processes listed in Table 4-2. As described in Attachment 1, and in more detail in Attachment 2, contaminated dunnage is to be treated using chemical reagent or a five percent solution of sodium hypochlorite.
Treatment of dunnage may occur in a 30 gallon drum using several gallons of chemical reagent or 5 percent sodium hypochlorite solution. The 30-gallon drum, unlike the 1-gallon Rapid Response System Reactor, is not equipped with a thermometer or pressure transducer.
The proposed treatment of contaminated dunnage called for stirring the contents of the 30-gallon "solids" drum, a procedure that appears impractical given the ergonomic limits of the glove box.
Mitgative Design and Operating Standards [R315-3-2-2a(6)] described in Attachment 2 (p. 31) indicated that "treatment processes will be conducted inside the confinement of the glovebox." The glove box has been defined as consisting of three parts, the air lock station, the unpacking station, and neutralization station. The proposed treatment of dunnage, in the solids drum, will actually occur outside the "confinement of the glovebox."
Wording needs to be clarified.
Condition III.I.8 - CAIS items shall be treated by intermittent agitation in the reactor vessel with the appropriate decontamination solution for a minimum of 15 minutes per batch before the waste material is transferred to the thirty (30) gallon waste drum.
Condition III.I.8 is the only condition establishing a treatment effectiveness standard for the Rapid Response System. This standard is a 15 minute batch reaction time.
Condition III.I.12 - If any chemical agent or CAIS chemical is detected in the exhaust stack from the activated carbon filter system, no additional chemical agent or other waste shall be placed into the Rapid Response System until the carbon air filter system are available the carbon air filter system is operational and available in accordance with III.I.10. (sic)
The Army permit application proposed a treatment goal of less than 50 part-per-million (ppm) agent. The treatment goal is based on the lowest limit of detection that is currently achievable for the chemical warfare agent analysis. A lower treatment level may be appropriate if sample analysis techniques improve.
One of the four process, Charcoal, did not achieve the treatment goal of 50 parts-per-million during a 15 minute batch reaction. The report "Dichlorodimethylhydantonin Treatment of Chemical Agents on Charcoal," US Army, June 1997, indicates concentration of sulfur mustard (HD) and nitrogen sulfur mustard (HN-1) above 50 ppm remained on the charcoal beyond the 15 minute reaction time. The treatment goal was achieved within 24 hours.
Addition of the partially treated charcoal to the liquid waste drum relies on dilution to meet the 50 part-per-million treatment level. RCRA prohibits dilution as a form of treatment.
The proposed waste analysis plan would not collect a sample of the solid layer in the liquid waste drum. This solid layer could contain partially treated charcoal.
Condition III.I.8 should also prohibit the reactor from being emptied into the liquid waste drum when the temperature in the reactor is above 120 degrees Fahrenheit (Attachment 2, p. 16).
Condition III.I.8 should be modified to identify the 50 part-per-million treatment level. An appropriate reaction time should be identified for the Charcoal Process to ensure complete treatment. The Waste Analysis Plan should be modified to include a sample of the solids layer in the "liquid" waste drum. The permit condition should require the 50 ppm treatment level be achieved for both the liquid and solid phases before the 30 gallon liquid waste drum is removed from the Rapid Response System trailer.
The wording of Condition III.I.12 needs to be clarified.
Condition III.I.13 - If chemical agent breaks through a carbon filter element, the element is determined to require replacement.
The detection of chemical agent or CAIS chemicals represents an action limit. The detection limit concentrations for chemical agents and CAIS chemicals should therefore be explicitly stated in the permit conditions.
MINICAM alarms are to be set at 70 percent of the chemical agent's Time Weighted Average (TWA) exposure limit. While the MINICAM's lowest levels of detection are not discussed in the permit conditions or supporting documents, these detection limits are lower than the alarm level.
Condition III.I.13 - Carbon Filter Replacement
Condition III.I.13 should be clarified to define chemical warfare agent break through as a positive detection of agent. This is consistent with Condition III.I.12 which requires carbon filter replacement when "any chemical agent or CAIS chemical is detected in the exhaust stack."
The permit conditions, and waste analysis plan (Attachment 4) do not address the treatment and disposal of spent carbon filters. These spent carbon filters may contain chemical warfare agent in excess of the 50 part-per-million treatment goal.
Condition III.I.13 - MINICAM Alarm Confirmation
Attachment 4 should discuss how profile sampling of the carbon filters is to be performed. Currently all sampling is to be performed under the environmental controls of the glovebox. The carbon filters are, however, to large to fit in the "controlled environmental" of the glove box.
MINICAM alarms are to be confirmed per the Environmental Monitoring Plan (Attachment 8), Table 8-2. For cyanogen chloride (CK), phosgene (CG), chloropicrin (PS), and chloroform, colormetric tubes are to be used to confirm MINICAM alarms. As shown in the following table, the colormetric tube's range of detection is above the concentration of chemical agent that would have set off the MINICAM alarm for cyanogen chloride, chloropicrin, and chloroform.
The Environmental Monitoring Plan states that any alarm that can not be confirmed will be considered a false alarm. The current design of the confirmation sampling program would identify potential carbon breakthrough, and unsafe work conditions as a false alarm.
|Colormetric Tube Range
- TWA converted from (mg/m3) to (ppmv) at 25 oF and 1.0 atmosphere.
- Alarm set at 70 percent of TWA.
- Chloroform monitoring of CAIS storage vault.
- Alarm set point at detection limit.