December 17, 1999
Comments
System Test Plan
Rapid Response System
Deseret Chemical Depot, Utah
On behalf of the Non-stockpile Chemical Weapons Citizens Coalition,
Clearwater Revival Company (CRC) has completed an analysis of the
Rapid Response System (RRS), System Test Plan, to be performed by the
US Army Program Manager for Chemical Demilitarization. CRC's review
identified several changes to the proposed System Test Plan that would
result in a better test. These changes are included with CRC's
recommendations in the following paragraphs.
The scope of CRC's review included the following documents:
- Rapid Response System (RRS), System Test Plan, Version 1, June
1997
- Final Resource Conservation Recovery Act Part B Permit for Rapid
Response System, State of Utah Division of Solid and Hazardous Waste,
December 22, 1998
- Report of the Pre-operational Survey for the Rapid Response
System Operations, January 4-7, 1999
- Chemical Materiel Monitoring Implementation Plan for the Rapid
Response System, Revision 1, August 2, 1996
- Dichlorodimethylhydantoin Treatment of Chemical Agents on
Charcoal, June 1997
- Dichlorodimethylhydantoin Treatment of Sulfur Mustard (Blue
Process), June 1997
The RRS System Test Plan is comprised of 16 subtests. CRC reviewed
the purpose of each subtest's objectives, criteria, methods, data
collection and data analysis requirements. CRC's review indicated that a
number of subtests evaluated operator performance or the adequacy of
standard operating procedures rather than the performance of the RRS
technology itself. CRC categorized each of the subtests as either
evaluating logistics, operator performance, standard operating
procedures, or the performance of the technology, as shown in Table 1.
CRC's comments and recommendations principally address three of the
four subtests that evaluate the RRS technology's performance. A failure
to reach the requirements, goals and indicators for these three subtests
addressing the technology performance would likely lead to a decision to
develop a technology option to the RRS.
Recommendation: CRC recommends that a Raman Spectra be obtained
for each CAIS item before it is treated in the RRS or shipped untreated
as an industrial chemical to a permitted off-site Treatment, Storage, and
Disposal Facility (TSDF).
Rationale: The RCRA Part B Permit Requirement III.I.6 requires that
"All glass CAIS items that are not leaking, except those containing
solids (e.g. charcoal) shall be interrogated by the Raman
Spectrophotometer, even if the vials are etched with any identification
markings."
The Test Plan method is not consistent with RCRA Part B permit
requirements. The Test Plan (p. 4-18) calls for the Raman
Spectrophotometer to "... be used to identify the contents of questionable
or unknown CAIS containers and of all ampules." The Test Plan
indicates that manufacturers' markings would be used during the Test
Plan to identify other CAIS items.
The RCRA Part B Permit Waste Analysis Plan, however, makes
contradictory statements about CAIS item identification methods. First
a statement appears that: "All bottles and ampules containing liquid
material will be subjected to Raman spectrometry to aid in
identification." (RCRA Permit, Page 4-3). Later a statement appears that:
"The chemical agent CAIS components will not be sampled prior to
treatment because sufficient information is available from chemical
agent manufacture, manufacturing specifications, and previous studies
conducted to date." (RCRA Permit, Page 4-17).
Recommendation: Modify operating procedures to either remove all CAIS
items from the glovebox at completion of each operating day, or maintain
qualified laboratory and operations personnel on-site 24 hours per day to
confirm and respond to alarm conditions.
Rationale: The RRS is to be operated one shift per day. CAIS that have
been unpacked, but have not been processed at the end of a shift would
be left in the RRS glovebox between shifts. The RCRA Permit allows up
to 390 CAIS components to be stored in the glovebox at any time. The
maximum capacity of the RRS is approximately 24 CAIS Bottles or 72
CAIS ampules in an 8 hour shift.
The Preoperational Survey (No. 1999-P1-23) indicates that the glove box
can not be used for unattended storage of CAIS for any period of time.
Citing Army regulations for arms, ammunitions, and explosives the
Preoperational Survey notes that "When CAIS are to remain outside of
secure storage, operational personnel will be required to remain within the
facility in a position to observe the location of the CAIS to provide
constant surveillance."
The RCRA Part B permit requires that the RRS glovebox ventilation
system remain operational (except for carbon filter replacement) from the
time the first CAIS item is introduced into the glovebox until closure and
decontamination is started. Monitoring of the glove-box ventilation
system between shifts would be performed with MINICAMs. However,
between shifts, personnel would not be available to collect a
confirmation sample, to analyze the confirmation sample in the on-site
analytical laboratory, and to take appropriate response actions if the
alarm is confirmed.
Recommendation: Samples of spent carbon filters should be collected to
determine the chemical agent and volatile organic loading on activated
carbon.
Rationale: As previously indicated in CRC's comments on the Draft
RCRA Permit (June 25, 1998), the Waste Analysis Plan (Attachment 4)
does not address the sampling or disposal of spent carbon filters.
Sampling of spent carbon filters should be performed because the filters
may adsorb chemical warfare agents in excess of the 50 part-per-million
treatment goal which would prohibit off-site transportation.
The chemical analysis of spent carbon filters would also provide a
historical record of the air quality within the glovebox and characterize
the chemicals which may off-gas during the neutralization reaction.
Recommendation: Collect a series of eight hour composite air samples
from the glovebox, operations trailer and carbon filter exhaust to
evaluate volatile organic emissions from the process.
Rationale: A plan for monitoring volatile organics is mandated by the
RCRA Part B permit to demonstrate compliance with RCRA air emission
requirements.
The Preoperational Survey (No. 1999 - P1-99), requested a written
explanation on why air monitoring for vinyl chloride and other minor
components is not necessary to evaluate potential work-place exposures
to these compounds.
Recommendation: Collect a minimum of ten samples from the
neutralent of each RRS reaction process for chemical agent analysis and
RCRA waste characterization.
Rationale: The Test Plan (p. 4-23) indicates that "The results of
chemical analyses of nuetralents will also be collated, and averages and
ranges will be presented." Given the wide variability of waste composition
measured during previous bench scale tests by the Army, ten samples is
believed to be the minimum number to generate data that is statistically
significant.
Treatment residues from the four different RRS reaction processes (RED,
BLUE, CHARCOAL, and CHARCOAL-L) will be segregated into three
streams. The CHARCOAL and CHARCOAL-L process wastes will be
combined. A single sample from each 30 gallon drum will be collected
and analyzed to determine agent concentrations, and RCRA Waste
characterization.
Notes from CRC's visit to Deseret on November 24, 1997 indicated that
the Army anticipated six drums of liquid waste to be generated from the
1,000 plus CAIS items stored at the depot. Under these circumstances a
maximum of two samples per reaction process would be collected. This
limited number of samples would not produce data that would allow
averages and ranges to be determined with any level of statistical
confidence for the process wastes.
The RCRA permit, however, indicates as many as 30 liquid waste drums
would be produced by the RRS Test Plan. If this waste volume is
accurate, 30 samples of treatment residues, or 10 samples per waste
stream would be collected and analyzed.
Recommendation: Include additional parameters in waste
characterization to support the use of non-incineration disposal
technologies for neutralent wastes.
Rationale: The U.S. Army Program Manager for Chemical
Demilitarization indicated previously that a Class I modification to the
RRS RCRA Part B Permit would be requested from the State of Utah to
enable the use of non-incineration disposal technologies for neutralent
wastes. Alternative disposal technologies may require information about
waste parameters beyond what would be collected during the proposed
Test Plan to support transportation of the waste to an incinerator.
Recommendation: Develop criteria (requirements, goals, indicators) for this
subtest.
Rationale: Of the 16 subtests this is the only subtest that did not list criteria.
These criteria would provide a list of what this subtest was trying to measure
about the performance, failure, maintenance and repair history of the RRS components.
Recommendation: Correct errors and verify the accuracy of the finalRCRA Part B
permit before initiating Test Plan.
Rationale: The RCRA Part B Permit III.I.13 identifies the response to an
alarm as Attachment 8, Paragraph 8-7. This paragraph which begins on
Page 8-42, is incorrectly identified as Attachment 8, Paragraph 8-4.
CLOSING
If there are any questions on the above information please call me at
(510) 522 - 2165.
Sincerely,
Clearwater Revival Company
Patrick G. Lynch, P.E.
Civil/Chemical Engineer
RRS System Test Plan
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