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C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 229 CASE 2 PROCEED WITH BASELINE TECHNOLOGY AFTER DELAY FOR ALTERNATIVE TECHNOLOGY REVIEW
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 230
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 231
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 232
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 233 SFIL-CME-M (50q) 29 July 1992 INFORMATION PAPER SUBJECT: Chemical Agent Monitoring Limits 1. Purpose: To provide information to the National Research Council's Committee on Alternative Technology Committee relative to air monitors detection limits for lethal Chemical agents. 2. Facts. a. Agent monitoring standards are targeted to achieve a reliable of agent concentrations limits in air. The airborne agent standards are based on analyses and extrapolations of agent toxicological data. This applies to General Population Levels (GPL), Time Weighted Average (TWA) exposures of unprotected workers (long term) and High Level Exposure (HLE) of unprotected workers (short term). The latter is equivalent to the immediately-dangerous-to-life-and-health (IDLH) concentration. The Allowable Stack Concentration (ASC) is based on an achievable level of agent in incinerator exhausts from a well-designed and well-operated incinerator. Worst case air modelling of ASC emission from the plant exhaust stacks results in air concentrations well below the GPL at all detail installation boundaries. The ASC is the only one of the four critical standards which is not based on toxicological analyses. A fifth plant air control standard, described as the maximum allowable concentration of agent in air to which workers in protective clothing (the demilitarization protective ensemble or DPE) can be exposed, is based simply on the test limits of the DPE. b. Minimum detection limits (MDL) for GB, VX and HD using the Automatic Chemical Agent Monitoring System (ACAMS) and the Depot Area Air Monitoring System (DAAMS) are derived from precision and accuracy studies and are updated monthly based on responses from quality control challenges. Statistical analyses of instrument responses to a range of challenges are used to produce a regression curve with 95% confidence bounds. The MDL is defined as the lowest true agent concentration that, 50% of the time, results in 97.5% confidence that the agent will be detected. Current operational data from JACADS and CAMDS produced the following MDL for the ACAMS and the DAAMS for each of the three lethal chemical agents. MINIMUM DETECTION LIMITS FOR ACAMS (mg/m3 ) Agent ASC TWA HLE GB 0.000030 0.000010 0.020 VX 0.000039 0.0000013 0.0026 HD 0.006 0. 0006 0. 0006
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 234 SFIL-CME-M (50q) SUBJECT: Chemical Agent Monitoring Limits MINIMUM DETECTION LIMITS FOR DAAMS (mg/m3 ) Aent ASC TWA HLE GB 0.000009 0.000003 0.006 VX 0.00012 0.00004 0.0008 HD 0.003 0.0003 0.0003
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 235 1 June 1992 INFORMATION PAPER SUBJECT: Disposal of Wastes from the JACADS Facility 1. Purpose: To respond to four questions raised by the National Research Council's Alternative Technology Committee. 2. Responses to the NRC Committee's questions were prepared by the operating contractor for the Army's Program Manager for Chemical Demilitarization. Questions and responses are as follows: a. Question. What are the costs, permits, etc. related to waste shipments from Johnston Island? Response. JACADS hazardous wastes are classified into two categories-process wastes and non-process wastes. Process wastes are generated as a direct result of the incineration processes. wastes are generated from general maintenance of the facility. Process wastes (hazardous or non-hazardous) are normally shipped to (Chem-Waste Management Inc. 's Kettleman Hills Facility to California. In the case where the Brine Reduction Area (BRA) cannot be operated, then brines may be sent to them-Waste Management's Corpus Christi, Texas, deep well injection disposal facility. Non-process wastes are shipped to the defense Reutilization and Marketing Office (DRMO) facility in Hawaii. JACADS wastes are accepted by these Treatment, Storage, and Disposal Facilities (TSDFs) after the wastes have been Characterized (''profiled'') by JACADS Environmental personnel and verified by the TSDF laboratory personnel. profiling involves sampling, analyses, and data reporting of the wastes to be disposed. Waste permits are called profiles. Every waste is profiled before it gets accepted for disposal by the TSDFs. The cummulative cost of JACADS process wastes disposed through the Chem-Waste contract through April, 1992 is approximately $1,015,000. The cost for JACADS non-process waste disposed through January, 1992 is approximately $124,000. The total cost for JACADS wastes from the start to now is approximately $1,139,000. This total reflects only the cost of disposal at the TSDFs. It does not include the water shipment transportation incurred by Matson Navigation Company. b. Question. What are the transportation criteria and any restrictions placed upon these shipments? Response. Title 49 of the Code of Federal Regulations (Department of Transportation) are followed for shipment of the wastes through water and over
C LETTER FROM CHARLES BARONIAN, DATED AUGUST 7, 1992 236 SAIL-PMM SUBJECT: Disposal of Wastes from the JACADS Facility land. The only restrictions pertain to weight limitations and section of incompatible wastes in sea nets or conexes. c. Question. What are the rules for shipment and landfill disposition of 3X material? Response. Before any 3X materials are shipped off-island, the U.S. Army Safety Department Headquarters must approve release. specific existing procedures or to-be-generated procedures followed for all 3X items to be disposed. All 3X materials approved for disposal are sent to Chem-Waste at Kettleman Hills. d. Question. What are landfill costs currently being Response. costs differ for each type of JACADS waste. This is dependent on what type of pre-treatment is necessary before actual landfilling or deep-well injecting of the particular JACADS waste. Listed below are current examples of process and non-process wastes and their disposal costs. Process Wastes DFS Ash and Metal Residue $367/ton BRA Salts $130/drum 3X DPE Suits $50/drum Brines $.60/gallon Non-Process Wastes Corrosives (Acids/Caustics) $2/pound Contaminated oil $1/pound Glycols $l/pound Paint, solids $.50/pound Detailed breakdown of the costs are provided for each type of waste in the contracts with (hem-Waste and with DRMO-Hawaii. ACTION OFFICER: JOSEPH S. STANG OFFICER: DONALD L. PUGH
