DSHW-2010-035369 - 0901a068801a1198

Tooele Chemical Agent Disposal Facility
(TOCDF)
Request for a
CLASS 3 MODIFICATION
to the
TOCDF RCRA Permit
Request Number
Request Title
EPA ID Number
T0CDF-ATT10-03-1111
TOCDF RCRA Final Closure Plan
Revision
UT 5210090002
For the
STATE OF UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY (DEQ)
Division of Solid and Hazardous Waste (DSHW)
195 NORTH 1950 WEST
P O BOX 144880
SALT LAKE CITYrUT 84f14-4880
TOCDF Class 3 Modification
TOCDF RCRA Final Closure Plan Revision
T0CDF-ATT10-03-1111
June 29 2010
TABLE OF CONTENTS
Section Page No
1 GENERAL DISCUSSION 2
1 1 Background 2
1 2 Graphical Depiction of the TOCDF TSDF 3
1 3 Regulatory Basis and Modification Classification 4
2 DESCRIPTION OF CHANGE AND JUSTIFICATION 5
3 IMPACT TO TOCDF 6
4 PUBLIC NOTICE DRAFT 7
5 PERMIT CHANGE PAGES 8
Page 1
I UL-Uh L,iass ci Moaiiicauon
rOCDF RCRA Final Closure Plan Revision
TOCDF ATT10 03 1111
June 29 2010
1 GENERAL DISCUSSION
11 Background
Located on the property of the Deseret Chemical Depot (DCD) m Utah's rural Tooele County,
the Tooele Chemical Disposal Facility (TOCDF) is a permitted Resource Conservation and
Recovery Act (RCRA) Hazardous Waste Treatment Storage and Disposal Facility (TSDF)
possessing the United States Environmental Protection Agency and State of Utah Identification
Number UT5210090002 The majonty of TOCDF operations take place at its main location
corresponding to the TOCDF "Limited Area", which is defined as the aiea within the double
fence surrounding the Munitions Demilitanzation Building (MDB) However, there exist
permitted Hazardous Waste Management Units (HWMUs) in locations that are remote from the
TOCDF main facility These somewhat "remote" HWMUs are fijlly incorporated within the
TOCDF TSDF RCRA Penmt For the purposes of this modification, the remote HWMUs are
grouped into 1) the CAMDS "portion", and 2) tiie Area 10 "portion"
90-day hazaidous waste accumulation sites that have been established in support of managing
newly-genejrated wastes are exempt from the "Closui e" requirements and are thus not considered
withm the TOCDF Closure Plan
:Page 2
luour oiass j ivioaiiicauon
TOCDF RCRA Final Closure Plan Revision
TOCDF-AmO 03 1111
June 29 2010
1 GENERAL DISCUSSION (continued)
1 2 Graphical Depiction of the TOCDF TSDF
X
1631 (Autoclave)
3S1
I (DVSSR)
(652 ipVSsJ.
1633 I
1635 I
Area 10 Active Portion
NOT withm scope
of this modification
^AMDS Active Portion
^7 <J7
cJ7c27 (ECV) 57 (TMA) (CHB) 37 (UPMC)
J
J
(ACS)
cS7
J
J
(SDS)
57 57
57
csr 57
57 57
cJ7 57
dJ 57
cJ7 57
c37 57
cJ7 57
57 57 cir •IT
57 57
57 57
(OCs/
ALs)
57 575757
57 57 57
57 57 57 57
I
(UP A)
XXX
(MDMs)
(BDSs)
57 X! ]X
(PMDb)
X _
(Cutter) QD
57 57575757
O
(DFS)
57
(MPF)
57 57 O
(Lie 1)
57 ^5;r
(Lie 2)
MDB/P.4S
TOCDF Mam Active Portion
I
5-2
57
PUB
jr
J
J
5T
OVERALL SrOPE OF TOrOF TSD RCR A PERlVflT
Autliouzing
Closuie Plan
Active
Portion HWMU Type Total
HWMUs
PCRA PeimK
Atiaclanent 10
TOCDF Mam
Subpart I Container Storage Aiea 8
PCRA PeimK
Atiaclanent 10
TOCDF Mam Subpart J Tank System 9 Tanks
PCRA PeimK
Atiaclanent 10
TOCDF Mam Subpart J Tank System 68 Sumps
PCRA PeimK
Atiaclanent 10
TOCDF Mam
Subpart 0 Incineiatoi System 4 PCRA PeimK
Atiaclanent 10
TOCDF Mam
Subpart X Miscellaneous Unit 8 PCRA PeimK
Atiaclanent 10
Area 10*
Subpart I Container Stoiage Aiea 5
PCRA PeimK
Atiaclanent 10
Area 10* Subpart J Tank System 0
PCRA PeimK
Atiaclanent 10
Area 10* Subpart O Incinerator System 0
PCRA PeimK
Atiaclanent 10
Area 10*
Subpart X Miscellaneous Unit 4
•"r . - . -V 1
-RGgAiEeriSt'
Attaehraerit 25^
ri'4:' •"r . - . -V 1
-RGgAiEeriSt'
Attaehraerit 25^
ttS^i|i^.J,?£ank System . f 1 Tanl^
•"r . - . -V 1
-RGgAiEeriSt'
Attaehraerit 25^
ttS^i|i^.J,?£ank System 32 SutnpS
•"r . - . -V 1
-RGgAiEeriSt'
Attaehraerit 25^ ^SB^^f?'(ij^ii0ratSf?SystMn 3
•"r . - . -V 1
-RGgAiEeriSt'
Attaehraerit 25^
jiibpart.X T^iscellaneous tJmt 7
* Although not currently permitted, several HWMUs are at vanous stages of
becoming permitted at Area 10 via a separate modification Four (4) tank systems,
one (1) incinerator system, and one (1) miscellaneous unit are proposed in addition
to the numbers shown here
V
RCRA Closure of
these HWMUs ar-^
witiiin [he scope of
Aitaclimeni 10 as
proposed m this
modification
RCRA Closure of
these HWMUs are
NOT within the
scope of this
modification
Page 3
iu»jur <^icibb o jvjuuriioduuri
TOCDF RCRA Final Closure Plan Revision
TOCDF ATT10 03 1111
June 29 2010
1 GENERAL DISCUSSION (continued)
1 3 Regulatory Basis and Modification Classification
This permittee-requested modification to the TOCDF RCRA Permit is submitted as a Class 3
modification based pnmanly on the "Other Modifications" language of 40 CFR 270 42(d)(1),
incorporated by R315-3-4 3
"In the case of modifications not explicitly listed in appendix I of this section, the
permittee may submit a Class 3 modification request to the Agency, or he or she
may request a determination by the [Executive Secretary] that the modification
should be reviewed and approved as a Class 1 or Class 2 modification
40 CFR 270 42(d)(2)(iii) states that "Class 3 modifications substantially alter the facility or its
opeiation" Smce this modification substantially alters activities that will be perfonned dunng
the closure of TOCDF, as well as completely refomiatting the Closure Plan, it has been
conservatively classified at the highest level This ensures the maximum opportunity for public
participation
Page 4
TOCDF Class 3 Modification
TOCDF RCRA Final Closure Plan Revision
TOCDF-ATT10-03-1111
June 29 2010
2 DESCRIPTION OF CHANGE AND JUSTIFICATION
The current TOCDF Closure Plan, which exists as Attachment 10 of the TOCDF RCRA Permit,
IS laid out in a manner that generally follows the regulatory requirements point-by point and in
order
The revised TOCDF Closure Plan, while still contaimng all of the essential elements of a written
closure plan, is laid out in a manner that is more m keeping with the sequence of closure events
as they will occur and the decision-making process that forms the basis for the physical work
requirements
The entire proposed revised TOCDF Closure Plan is presented at the end of this modification
request The Plan is drafted as a self-contained document that is self-justifying
Consistency - Attachments 10 and 25
The proposed revised TOCDF Closure Plan layout is consistent with the layout of the recently-
approved CAMDS Closure Plan, which exists as Attachment 25 of the TOCDF RCRA Permit
CAMDS closure activities under the authorization of Attachment 25 are currently being
implemented Consistency between TOCDF Closure Plan and the CAMDS Closure Plan will
enable the most effective use of site implementation procedures that have been developed at
CAMDS and can be adapted for use at TOCDF
Waste Analysis Plan - Impacts
The two Waste Analysis Plan waste streams 2 2 2 29 "Closure-Generated SDS" and 2 2 2 30
"Closure Generated Waste", were revised in anticipation of TOCDF entering "closure" These
two waste streams were originally added to the WAP in order to accommodate certain CAMDS
waste streams since CAMDS has already entered closure
Waste stream 2 2 2 29 was revised to consider wastes that do not enter a tank system but are
managed entirely within containers
Waste stream 2 2 2 30 was revised to enable the conservative management of any wastes
generated at closure as liquid-agent exposed wastes or matenals
Page 5
I uour uiass i ivioQiiicauon
TOCDF RCRA Final Closure Plan Revision
TOCDF ATT10 03 1111
June 29 2010
3 IMPACT TO TOCDF
The pnmary goal of this modification is to replace the existing RCRA Closure Plan with a
newly-prepared RCRA Closure Plan that more accurately reflects the facility's physical
configuration and revised closure strategy The current RCRA Closure Plan and the proposed
RCRA Closure Plan share the same end-goal of final closure pnmanly through removal and
disposal of the overall facility (i e , clean-closure) Smce both plans are written to achieve the
same end-goal, the impact of the new proposed plan versus the existing plan is negligible
Environmental Impacts
There are no adverse impacts to the environment resulting fi"om this modification The final
closure end-state of the proposed closure plan remains the same The overall permitted facility
equipment, buildings and stmctuies will have been disposed as hazardous debns in a offsite
pennitted Subtitle C landfill, witl) specified exceptions
TOCDF Personnel Impacts
There are no adverse impacts to the facility personnel resulting from this modification The
overall workforce lequirements remain essentially the same
Physical TOCDF Impacts
Fheie aie no adveise impacts to the physical end-state of die facility resulting troni this
modification Although the work activities necessaiy to achieve the final end-state differ, the
end-state does not
Page 6
4 PUBLIC NOTICE DRAFT
CMA
U I «*MT CHCiUCAl
•iKTEIIUll ktCUCY
PUBLIC NOTICE
JLEGRG Tooele Chemical Agent Disposal Facility (TOCDF)
Ecs<£i>>oi««o«Mints Located at the U S Army's Deseret Chemical Depot (DCD), Stockton Utah
Class 3 Penmit Modification Request
"TOCDF RCRA Final Closure Plan Revision"
What is the
permit
modification
about?
When is the
Public
Meeting?
The Tooele Chemical Agent Disposal Facility (TOCDF) is a Resource Conservation and
Recovery Act (RCRA) permitted treatment and storage facility (TSDF) The overall mission
of the TOCDF is to destroy the portion of the U S Army's chemical weapons stockpile that
resides at the Deseret Chemical Depot (DCD) in addition to eliminating the inventory of
secondary wastes generated in pursuit of that mission
TOCDF has completed destruction of the majority of the DCD chemical weapons stockpile,
and IS actively eliminating (e g , treating, shipping) its inventory of secondary waste In
anticipation of completion of permitted-treatment and storage operations, TOCDF is
preparing to begin formal regulatory RCRA final closure activities Accordingly, TOCDF is
revising the TOCDF RCRA Closure Plan that currently exists in the RCRA Permit as
Attachment 10 This revision of the Closure Plan reflects the current physical configuration
and closure strategy of the TOCDF facility which has been greatly modified since the
preparation of the original Closure Plan prepared prior to permitted-operations in 1996
This Permit modification request is identified by the designation T0CDF-ATT10-03-1111
A public information meeting on this permit modification request will be held at 6 00 p m on
Wednesday, July 28, 2010 at the Tooele Chemical Stockpile Outreach Office, 54 South
Mam Street Tooele, UT 84074 The telephone number for the Outreach Office is (435)
882-3773
Where can I
find a copy of
this permit
modification
request?
Who can I talk
to about this?
How long is
the comment
period?
A copy of this permit modification request is available for review by the general public during
regular business hours at
-•Tooele Chemical Stockpile Outreach Office, 54 South Mam St, Tooele, UT 84074
->^Tooele City Library Reference Desk, 128 W Vine Street, Tooele, UT 84074
->Utah Division of Solid and Hazardous Waste (DSHW, Department of Environmental
Quality), 195 North 1950 West, Salt Lake City, UT 84114
The TOCDF point of contact is Mr Trace Salmon at [phone] The Permittees' (U S
Army Chemical Matenals Agency/EG&G Defense Matenals) compliance history during the
life of the permit being modified is available from the State of Utah [contact Mr Tom Ball of
the Utah Division of Solid and Hazardous Waste at [phone], or via email at
tball@utah gov] ~-
The public comment penod for this permit modification request lasts a minimum of 60 days
and begins Thursday, July 1, 2010 and will end Monday August 30, 2010 Written
comments regarding this permit modification request can be submitted to Mr Scott
Anderson, Director, Division of Solid and Hazardous Waste, Utah Department of
Environmental Quality, P O Box 144880, Salt Lake City, UT 84114-4880, and must be
received no later than 5 GO p m , Monday, August 30, 2010
Ttiis public notice satisfies requirements of the Resource Conservation and Recovery Act and the Utah Hazardous Waste Management Rules
(Utah Administrative Code R315)
Page 7
5 PERMIT CHANGE PAGES
Change Pages in Permit Body
Module II, General Facility Conditions
Pages 5 and 6
Change Pages m Permit Attachments
Attachment 2, Waste Analysis Plan
Pages 28, 29, 47 and 48
Attachment 10, TOCDF Closure Plan
Pages 1 through 42 (all)
Changes to Permit Drawings
None
Page 8
TOCDF
General Facility Conditions
February 2010
IIII c The Permittee shall submit a biennial report covering the TOCDF and CAMDS activities
to the Executive Secretary in accordance with R315-8-5 6 and R315-3-3 1(1)(9)
n 11 d The Permittee shall submit additional reports to the Executive Secretary m accordance
with R315-8-5 8
III 2 All reports, notifications, applications, or other matenals required to be submitted to the
Regional Administrator shall be submitted to the State and Tnbal Assistance Office,
Assistant Regional Administrator to the EPA Regional address shown m Condition
IAA3
II13 All reports, notifications, applications, or other matenals required to be submitted to the
Executive Secretary shall be submitted to the address shown m Condition 1AA 2
IIJ CLOSURE
II J 1 The Permittee shall meet the general closure performance standard as specified m R315-8-
7 during closure of all TOCDF and CAMDS hazardous waste management units
Compliance with R315-8-7 shall require closure of each hazardous waste management
unit m accordance with Condition IIJ , Attachment 10 (TOCDF Closure Plan) and
Attachment 25 (CAMDS Closure Plan)
II J 2 All secondary waste generated dunng the processing of Agents GB, VX, and Mustard
shall be processed by the Permittee pnor to the completion of closure of TOCDF
II J 3 Reserved
II J 4 Reserved
IIJ 5 The Permittee shall decontaminate or dispose of all equipment as specified m Attachment
10 (TOCDF Closure Plan) and Attachment 25 (CAMDS Closure Plan)
j II J 6 The Permittee shall provide certification statements that alleaeh TOCDF and TOCDF-
Operated hazardous waste management unitb and the overall TOCDF facilityhas have
been closed m accordance with the applicable specifications m Attachment 10 (TOCDF
I Closure Plan) and^ Attachment 25 (CAMDS Closure Plan) as required by R315-8-7
IIJ 7 The Permittee shall notify the Executive Secretary at least 45 calendar days pnor to the
closure date of any hazardous waste management unit is expected to begin
III 8 In the event that any hazardous waste management unit cannot be clean closed by
removing hazardous waste, hazardous waste constituents, contaminated subsoil, and any
contaminated groundwater as specified in Attachments 10 and 25 (Closure Plans), the
Permittee shall submit the modified closure and post-closure plan for that hazardous waste
management unit to the Executive Secretary, as a permit modification request, m
accordance with R315-3-4, within 30 calendar days of the date that the Executive
Secretary notifies the Permittee in writing that the unit shall be closed as a landfill, in
accordance with R315-8-7
Module 11 - Page 5
TOCDF
Geneial Facility Conditions
February 2010
II J 9 Within 90 calendar days of the Perrmttee's receipt of the wntten approval from the
Executive Secretary, in accordance with R315-3-4, of the modified closure plan and the
post-closure plan required by Condition IIJ 8 , the Permittee shall close the hazardous
waste management umt in accordance with the approved plans
HK CLOSUBE PLAN - COMPLIANCE SCHEDULE
II K 1 The Permittee shall close the TOCDF facility m accordance with schedules appearing m
submit Q permit modification request tliot updates Attachment 10 (TOCDF Closure Plan)
and Attachment 25 (CAMDS Closure Planum the seeond quarter of oalendar-year 2010
IIL EQUIVALENT MATERIALS/INFORMATION
n L 1 For certain equipment, matenals, or minor mformation specified in this Permit and
documents listed or descnbed in Attachment 3 (Samplmg, Analytical, and QAJQC
Procedures) and Attachment 23 (CAMDS LMQCP) that do not affect the analytical
methods m the documents listed oi descnbed jn Attacliment 3 (Sampling, Analytical, and
QAJQC Procedures)or descnbed in Attachment 23 (CAMDS LMQCP) the Peraiittee is
allowed to use the equivalent or supenor equipment, matenals, or minor mfonnation Use
of such equivalent or supenor items shall not be considered a modification of the Pennit,
but the Permittee shall place in the Operatmg Record (pnor to the institution of such
revision) the revision, accompanied by a narrative explanation, and the date the revision
became effective The Executive Secretary may judge the soimdness of the revision
dunng inspections ol the TOCDF and CAMDS and take appropriate action The loimat
of tables fonns, and figuies is not subject to the requuements of ihis Penmt lud mav he
rcMsed at the Pennittee's discietion
11 M FINANCIAL ASSURANCE FOR FACILITY CLOSURE
11 M 1 The Permittee is exempt from the closure financial assurance requirements, in accordance
with R315-8-8 [40 CFR Section 264 140(c) incorporated by reference]
UN LIABILITY REQUIREMENTS
11 N i The Peimittee is exempt from the liability coverage for sudden and accid'=i'jta! occurience
requirements, m accordance with R315-8-8 [40 CFR Section 264 140(c) mcoiporated by
reference]
Module 11 - Page 6
TOCDF
Waste Analysis Plan
May 2010
2 2 2 29 Closure-Generated Spent Decontamination Solution (Excludmg SAF Lab and CAMDS
Monitonng Waste")
2 2 2 29 1 Spent decontamination solutions generated from closure activities may be managed at an
ofF-site Subtitle C TSDF or treated in one of the TOCDF LICs in accordance with Section
22 14
2 2 2 29 2 Each taakbatch of spent decontamination solutions shall be sampled and analyzed for
chemical agent concentiation, conosivity (pH), HRA metals, BTU ignitabihty, total
halogens, total organics and specific gravity A batch shall be defmed as containenzed
spent decontamination solutions that will be isolated from any additional waste being
added to the tank or container pnor to off-site shipment SDS that is potentially VX
contaminated shall additionally be analyzed for the VX-related constituent EA 2192 pnor
to off-site shipment
2 2 2 29 3 Spent decontamination solutions having chemical agent concentrations less than 20 ppb
for GB 01 VX and 200 ppb for mustard may be managed ai an oft-site Subtitle C TSDF
If chemical agent is detected at or above 20 ppb for GB or VX and 200 ppb lor mustaid
additional decontamination solution shall be added to the collection tanks or containers,
the contents lecirculated (i e mixed) and another sample analyzed for agent concentration
2 2 2 29 4 In addition to the above lequirements, the following restrictions shall apply to off-site
shipments of SDS
• J 29 4 I Cdiliactual lestuttions shall be imposed on the traii3p'"r(ers nirl ofl-sit;. .ncio^geinti'f
facilities to ensure thai the spent decontamination solutions arc direclly tei in'o an
iiicineiator irom the tanker tnick lo pievent comiomghng vwth other <^/')s!c streams
managed at the tacihty As an alternative to direct tanker feed, a aedicated tank ai ihe oil-
site incinerator for the spent decontamination solution may be used to prevent
commingling at the off-site management facility
2 2 29 4 2 Contiactual restrictions shall be imposed on the transporters and off-site management
facilities to ensure that the spent decontamination solution pH is not lowered m each
tanker or dedicated tank
2 2 2 29 4 3 The off-site tieatment facihties to which SDS may be shipped are limited lo.hazarctous
waste incineration facilities
2 2 2 29 4 4 The off-site transporters and management facihties shall be trained m chemical agent
exposure and spill response before shipment of SDS
2 2 2 30 Closure-Generated Waste
22 2 30 I Waste matenals exposed to liquid or aerosol chemical agent, or matenals suspected or
conservatively-presumed to have been liquid or aerosol exposed will be chemicallv-
decontaminated per the decontamination steps outlined m the-Attacliment 10 (TOCDF
Closure Plan) and Attachment 25 (CAiVlDS Closure plan)
Attachment 2 - Page 28
TOCDF
Waste Analysis Plan
May 2010
I 2 2 2 302 The resulting decontamination final nnsate will be analyzed for chemical agents If the
agents are detected at or above 20 ug/1 (ppb) GBA/X/GA or 200 ug/1 (ppb) for
mustard/Lewisite, repeat the decontamination procedures and reanalyze the nnsate
2 2 2 30 3 The spent decontamination solution/nnsate may be processed by either
2 2 2 30 3 1 Treating m the TOCDF LIC 1 /LIC2 pnmary or secondary chamber per 2 2 1 4 and
analyzed for the following paiameters, agent, conosivitiy, peicent organics, specific
gravity and HRA metals oi
2 2 2 30 3 2 Spent decontamination solutions may be sent off-site to a Subtitle C TSDF if the agent
concentration is below 20ug/l (ppb) GAJGBfWX and 200 ug/1 (ppb) mustard/lewisite The
waste Will additionally be analyzed for TCLP metals, total organics, corrosivity
Additionally BTU content, HRA Metals and flashpoint if incinerated
2 2 i 30 4 Once decontaimnated, the waste will be characteiized for olhei RCR_\ parameteis to
ensure pioper waste management
2 3 PARAMETER TEST METHODS R315-8-2 4 140 CFR 264 13(b)(2)l.
2 3 1 Table 2-3 provides a listing of the analytical methods that shall be used to detect and
quantify the selected parameters fhis information is piesented m a relational loiniat m
Tables 2-0 and 2-1 (the WAP Summary Tables)
3 2 The CAL and SAF shall perlonn the analyses related to chemical agent lisfed in tables 2-
0 and 2 1
2 3 3 The CAL and SAF shall be Utah-certified to perfoirn analyses for the paiamelers that
require Utah certification
2 3 4 Off-site analyses shall be perfonned by a Utah-certified laboiatory foi the parameteis
listed m Table 2-3
2 3 5 The off-site laboratories selected shall be certified by the State oi Utah foi the methods
referenced m this waste analysis plan When new promulgated methods aie approved by
EPA, the Perrmttee shall notify the off-site laboratones of the required change and request
a time frame of when the change will occur A laboratory will have six months to subirat
documentation to the Pennittee of the change or a time frame when the change will be
completed The laboratory must use the most recently approved method withm one year
of promulgation If that is not possible, a written request for extension must be provided
to the Executive Secretary for approval Only SW-846 promulgated methods shall be used
unless an alternate method is approved by the Executive Secretary
2 4 SAMPLING METHODS R315-50-6 140 CFR 264 13(b)(3)l.
2 4 1 The sampling methods to be used for each waste stream are found in Tables 2-0 and 2-1
(the WAP Summary Tables)
2 5 FREQUENCY OF ANALYSES R315-8>2 4 [40 CFR 264 13(b)f4)|.
Attachment 2- Page 29
Waste AnaH
:DF
Ian
-010
Taljie 2-1
TOCDF WASTE AIVAL\ SIS PLAN SUMMARY
2 2 2 WASTES REOUIRING OFF-SITE TREATMENT/DISPOSAl,
WASTE STREAM
GENERATIOIN
SOURCE ANALYTICAL PARAMETER'-
PREPARATION and
fSJSALVTIC/^O.
METHODS
FREQUENCY OF ANALYSIS'
(establish profile)
SAMPLING
METHOD
2 2 226 MSB and Monitonng Solid
Waste
MSB
CAMDS
CheiTiiCal Agent Concentration
See section 2 2 2 25
TE LOP 572 01
TE LOF-409 412 413 416
Each containei One sample of the
decontamination solution collected at the
bottom of the accumulation container taken
toi analysis
Coliwasa
2 22 27 Sump 110 Sump 110 Ageiu Concentration
TCLP Metals
TCLP Oi games'
Conosivttv/pH
TE LOP 572
nil and 3010 01 3015 and
6010 or 6020 and 7470
131 land 5030 and 8260 and
3510 ot 3520 and 8270
TE LOP 574 (9040)
Each tanker One sample toi analysis Coliwasa
2 2 2 28 Autoclave Treated Waste Area 10 (Igloo
1631)
Subpart X
Autoclave
Agent TE LOP 524
(Pnmary)
TE-LOP 522
(Contiixnation)
Each Batch Treated NRT
(Pnmary)
DAAMS
(Confirmation)
2 2 29 Closure<jeneratod Spent Decon
Solutions
Site Closure
Acnvities
Agent Concentration
Conosivity (pH)
TE-LOP 572 or
TE LOP-409 412 413 416
90408 01 TE LOP 574 (9040)
Each CAMDS tankTMF 1 and TMF-2 after
mixmg a minimum of one-hour PRIOR TO
transfer to CAMDS tanks T13D orT13-E
tank
Tap
HRA Metals (totals)
igiutability
TC Oiganic";'
30I0A 7470A 60I0B
lOlO/ IO2OA01 1020 01 1010
8260B 8270COI
1311 and 5030 and 8260 and
3510 01 3520 and 82V0
Each tank pnor to offsite shipment after
mixing a rmrumum of one hour or one sample
from each container
Tap or Coliwasa
Sperinc Giavity
BTU
27101- 01 TE LOP 374
ASTM D240 87
OR ASTM D 5865
ToiLil Halogens
9056 01 m 0/300 1
Attachnit'n 2 Page 4""
Waste Anal
DF
an
JIO
Table 2-;t
TOCDF WASTE ANALYSIS PLAN SUMlMARY
2 2 2 WASTES REQUIRING OFF-SITE TREATMENT/DISPOSAL
WASTE STREAM
GENERATION
SOURCE ANALYTICAL PARAMETERS
PREPARATION and
ANALYTICAL
METHODS'
FREQUENCY" OF ANALYSIS'
(establish profile)
SAMPLING
METHOD
2 2P30 Closure-Generated Waste
(Liuuid ui Auiosol Agent Exposed, as
deliimd by the i^oin-b|«mdinn Closuic
PIJII methodology)
Site Closure
Activities
Agent Concentration
RCRA Charactenzation paramelei ^
TE LOP 572 or
TE LOP409 4(2 413 416
As generated
Footnotes
1 The annotated methods identified are to be used When new piomulgated methoas aie appiovcd by EPA, the Permittee siiall notify the laboratory of i.he required change and request a
time frame of when the change will occui The laboratoiy will have bix months to bubinit documentation to the Permittee of the change or a time frame when the change will be
completed The laboratory must use the most promulgated method withm one year of piomulgation If that is not possible a wntten request for extension must be provided to the
Executive Secretary for approval
2 A batch is defined as all the drums (or containers) of waste generated from the same event af the same location
3 TCLP organicb are defined as those compounds descnbed bv 40 CFR 261 24 by the waste codes DO 18 D019,D02I D022 D023, D024, D025, D026 D027, D028, D029, D030 D032
D033, D034, D035, D036 D037 D038 D039, D040 DO^i and D042
4 ' Dioxins (PCDDs) and Furans (PCDFs) aie additionally analyzed toi only it waste is Toxicity Chaiacteiistic foi oigames
5 The Permittee^hall sample the organic analytical paiameteis using the samplmg and analytica! methods and frequencv ot analysis in accordance with section 2 10
6 TCLP metals are defined as those descnbed m 40 CFR 2o 1 24 as waste codes D004 D')05 DOOb, D007, D008 D009 DO 10 and DOI 1
7 HRA metals are defined as the following Aisenic, Barium Chiomium Cadmium Lead Meicu'-y Silver Selenium Aluminum Antimony, Beryllium Boron, Cobalt, Copper
Manganese Nickel Thallium Tin Vanadium and Zmc
Attachmepi Paoe 48
TOCDF
Closure Plan
June 2010
ATTACHMENT 10
TOCDF CLOSURE PLAN
10 1 CLOSURE PLAN OVERVIEW 2
10 1 1 Closure Status 3
10 1 2 Closure Plau Document Structure 3
10 1 3 Key Definitious 4
10 1 4 Supporting Documents 5
10 1 5 Compreliensive List of TOCDF and TOCDF-Operated Facibty HWMUs 7
10 1 6 Inspections, Calibiations and Waste Feed Interlock Function Tests 9
10 1 7 Preparedness and Pi evention, Contingency Plan 10
10 1 8 Closure Monitonng 10
10 2 CLOSURE PERFORMANCE STANDARD 10
10 2 1 General Standards 10
10 2 2 Technical Staiidaids li
"10 2 2 1 Coiitainei Stoiagp Areas, - 40 CFR 264 178 (amended by Rl! 5 8 9 9) J i
10 2 2 2 Tank Sybtems - 40 CFR 264 197 11
10 2 2 3 Incmeiatois-40 CFR 264 351 (amendedbyR315-8-15 8) 12
10 2 2 4 Miscellaneous Units - 40 CFR 264 601 12
10 2 3 Closure Sampling and Analysis (Closure Verification) 12
10 2 4 Final Closure Performance Standard Values 13
10 3 MAXIMUM WASTE INVENTORY ESTIMATE 13
10 4 FACILITY CLOSURE METHODOLOGY 17
10 4 1 Decoulamination and Equipment Removal Sequence 18
10 4 2 Equipment and Facilities Decontamination 23
10 4 3 Schedule foi Closuie, Time Allowed for Closure, and Extension of Closure 27
10 4 4 Scope of Ancillary Equipment 31
10 5 CLOSURE WASTE MANAGEMENT 35
10 5 1 Waste* G'eueiated Dui lug Closure 35
10 2 E^'a)ua^lOJ^ and Delernnnation of Agent Exposure Status "^7
10 5 3 Decontamination & Decommissioning of Equipment, Buildings and Structures 38
10 5 4 Special Handling of Waste During Site-Wide Demolition Phase 39
10 6 GROUND-WATER MONITORING AND RUN-ON & RUN-OFF CONTROL 41
10 7 CLOSURE PLAN COST ESTIMATE 41
10 8 POST CLOSURE 41
10 9 CERTIFICATION OF CLOSURE 41
10 10 CORRECTIVE ACTION FOR SWMUS 42
Attachment 10 Page i
TOCDF
Closuie Plan
June 2010
TOCDF CLOSURE PLAN
10 1 CLOSURE PLAN OVERVIEW
This plan has been prepared for the closure of the Tooele Chemical Agent Disposal
Facihty (TOCDF) m accordance with Title 40 of the Code of Federal Regulations, Part
264 and Utah Administrative Code (UAC) R315-8-7
Owned by the U S Chemical Matenals Agency (CMA), TOCDF is a hazardous waste
treatment and storage facility co-operated by the CMA and EG&G Defense Matenals,
Inc , (a division of URS) In addition to being co-operators, CMA and EG&G are co-
permittees of TOCDF
Although located entirely withm the boundanes of the Deseret Chemical Depot (DCD),
TOCDF operates as an autonomous permitted facility under the authonty of its own
RCRA Permit The DCD operates under a separate RCRA Permit even though the DCD
and the TOCDF facilities share the same EPA I D Number of UT5210090002
Consequently, this closure plan only addresses operations directly associated with
TOCDF In order to complete closure of the entiie UT'52] 0090002 installation, DCD
closure operations will be addressed withm a DCD Closure Plan entirely separate from
this TOCDF Closure Plan and the CAMDS Closure Plan
This plan describes general closure requirements for the TOCDF Facility, which includes
multiple individual hazardous waste management units (HWMUs) included m this
permit, but does NOT include those HWMUs subject to the provisions of Attachment 25
(CAMDS Closure Plan)
EPAID Number
UT5210090002
EPAID Number
UT5210090002
TSDF
RCRA Permits
Closure Plans
Scope of This
Attachment
TSD Fat-ihty
TOCDF
Attachment 10
(TOCDF Main Facihty
& TOCDF-controlled
facilities within Area 10)
TSD Facility
DCD
Attacloment 25
(CAMDS)
Attacliment 5
(DCD)
This closure plan was prepared for the TOCDF-controlled facilities (except the CAMDS
active portion) and wiH result m conditions protective of human health and the
environment dunng and after closure The ultijnate goal of this plan is to present the
processes that will enable the TOCDF Facihty to be closed in a manner that minimizes
the need for further maintenance, and minimizes, controls, or eliminates post closure
escape of hazardous wastes or their constituents into the environment
Attachment 10 - Page 2
TOCDF
Closure Plan
June 2010
10 1 1 Closuie Status
Since the beginning of chemical agent permitted-treatment operations in 1996, vanous
pemntted HWMUs have been removed and RCRA-closed as 1) certain "treatment
campaigns" were completed and the equipment became obsolete, or 2) the equipment
was no longei useful for its onginally-intended purpose
HWMUs that have heretofore attained and been granted formal "closure" status no longer
appeal in the RCRA Pennit as pemiitted-HWMUs (e g , Subpart X Rocket Shear
Maclune, the Subpart O Dunnage hicineiator, etc ) Howevei, obsolete HWMUs that
have NOT been gianted fonnal closure status AND that still appeal m the Permit will, foi
the purposes of this closure plan, be considered active HWMUs regardless of whether
they are still in-place oi if they have been partially or fully disassembled Hence, all
cuiTently-operatmg or previously-operated pennitted HWMUs are considered "active"
Only those previously-opeiated HWMUs that have been granted formal closure-status by
the Utah Department of Enviiomnental Quality (DEQ) Division of Solid and Hazardous
Waste (DSHW) wil! be consideied "RCRA-closed"
10 1 2 Closuie Plan Document Stmctute
Contents of the temainder of Attaclmienf 10, TOCDF Closure Plan include
10 2 Closuie Performance Standanl provides the perfonnance standards lor the
closure of hazardous waste management units This section also provides details tor the
detenninaiion of whethei closuie perfonnance standaids have been met tor closed RCRA
peiiViiiU'd 'iPiis
10 J Miniiiiuii! iVusie In\enron. lists tlie iiLnMiivjin ni- eiH,.. iot u us ^ ,|.' rc i d •,
time at (he facility
10 4 Facilny Closuie Methodology descnbes (he overall appioach lor closure
including the overall closure sequence, a description of the decontamination methods to
be utilized, and the overall schedule to complete closure activities
lO ^ Clo'iLae Wash Management descnbes the methods ivhich vvd! De utiiizcd in,
,na(]3ging ihe hazaidous wastes generated dunng closure
10 6 Ground Water Monitonng and Run-on and Run-off Control descnbes the run-on
and nin-off control that will be employed dunng closure
10 7 Closui e Plan Cost Estimate documents that financial assurance is not applicable
to TOCDF
10 8 Poit Closure describes the requirements foi post-closure care of the facihty
10 9 Certification of Closure states that closure will be certified according to the
approved Closure Plan by an independent, qualified, registered professional engineer
10 10 Corrective Action for Solid Waste Management Units descnbes the activities that
may need to be taken to comply with 40 CFR 264 101
Attachment ) 0 - Page 3
TOCDF
Closuie Plan
June 2010
10 1 3 Key Definitions
The following terms are used frequently throughout this closure plan 40 CFR 260 10 is
incorporated by Utah Administrative Code (UAC) R315-l-l(b) and 40 CFR 268 2 is
incorporated by UAC R315-13-1
10 13 1 Active Portion means that portion of a facility where tieatment, storage or disposal
operations aie being or have been conducted and which is not a closed portion
(§260 10)
10 13 2 Ancillaiy Equipment means any device that is used to distnbute, meter, or control the
flow of hazardous waste from its point of generation to a storage oi Ueatment tank(s),
between hazardous waste storage and treatment tanks to a point of disposal onsite, or to a
point of shipment for disposal off-site (§260 10) For the purposes of this closure plan,
secondary containment systems and Subpart CC air emissions control devices/closed-
vent systems are included within this definition regaidless of the fact that they do not
directly contact the hazardous waste being managed by the H^^TVIU
10 13 3 Clean Closure means achieving the geneial and technical closuie performance standards
by lemoving hazardous waste from the facility or HWMU and then decontaminating (i e
contaminants Irom permitted-operations) the facility or HWMU such that no post-closure
care is required The TOCDF facility, including all of its HWMUs will be "clean-closed'
in accordance with this plan
10 13 4 (1 losed Portion means that portion of a facility which has closed in accoidance with the
3ppioved facility closure plan or a specific partial closuie plan and nil ippl cable clnsuir
lequiiements (ii260 10)
10 13 5 Debi is means solid material exceeding a 60 mm particle size that is intended foi disposal
and that is
1) a manufactured object, or
2) plant or animal matter, or
3) a natural geologic matenal (§268 2)
10 ! 3 6 Decontamination means the act of removing sorae or all liazaidous waste residues or
contaminants "contained nf equipment, buildings oi stiijctuies by ase of one or moje or
the following technologies physical extraction, chemical exiraction, thermal extiaction,
biological destruction, thermal destruction, chemical destruction
10 13 7 Facility means all contiguous land, and structures, other appurtenances, and
improvements on the land, used for treating, storing or disposing of hazardous waste
The TOCDF "facility" includes multiple treatment and storage operational umts (i e ,
HWMUs), some of which are detached (i e , Area 10 igloos) (§260 10) ''Approved
hazardous waste management facihty " or ''approved facility " means a hazardous waste
TSDF which has received an EPA permit m accordance with federal requirements, has
been approved under Section 19-6-108 of the Utah Code and R315-3, or has been
permitted or approved under and other EPA authorized hazardous waste state program
[R315-l-l(f)(l)]
10 13 8 Final Closure means the closure of all HWMUs at the facility in accordance with all
applicable closure requirements so that hazardous waste management activities under
Attachment 10 - Page 4
TOCDF
Closuie Plan
June 2010
parts 40 CFR 264 and 265 aie no longei conducted, unless subject to the [90-day
accumulation] piovisions of §262 34 (§260 10)
10 13 9 Generator means any person, by site, whose act oi process produces hazardous
waste 01 whose act first causes a hazardous waste to become subject to regulation
(§260 10) Since manufactured equipment, buildings and structures are "manufactured"
and not teclinically "produced", their point-of-generation as "hazardous debns" is vaguer
than foi hazardous waste For the purposes of tlus closure plan, equipment, buildings and
stmctuies undergoing closure will be generally defined as "first becoming subject to
hazaidous waste geneiatoi regulation" as newly geneiated waste at tliat point m time thai
demolition of that part of the building commences hilact portions of the building or
structure undergoing closuie will not be consideied newly-generated waste Equipment
that is lemoved during pre-demolition activities will be subject to hazardous waste
geneiator lequirements of 40 CFR 262 32 when the equipment is removed from the
building that it was contained m Once "generated", the "hazardous debns ' becomes
subject to all the pre-transport requirements (e g , packaging, labeling, marking,
placarding, accumulation time, etc ) of 40 CFR 262 The basis of charactenzmg the
iiewly-geneialed F999 hazaidous debus will geneially be 40 CFR 262 1 \ {J){2) (i e
"geneiatoi knowledge' gained fioin acdvities conducted puisuant to this closuie plan)
10 I 3 10 Hazaidous Debns means debris that
1) coiuams a hazardous waste listed in subpart D of pail 261 [including UAC R315-2-10
(F999) and R315 2-11 (P999)], oi
2) that exhibns a [charactensttc of igniiibility, toirosivity, reactivity or toxicity] (§268 2)
i'j 1 ' 1 rnft'a! CL/^uic means the closure nf a f'-ingle] HWM" u iccotdin„e with the .applicable
closuie iequiremen(s of 40 CFR 264 and 265 or an approved pardal closure pho at i
l icih'y that contains other acuve HWMUi (§260 10)
'0 I 3 12 Tieatment means any method, technique, oi piocess designed to change the chemical or
biological charactei or composition ot any hazardous waste so as to
1) neutialize such waste, oi
2) lecovei eneigy oi matenal lesouices fioin (he waste, or
3) to rendei such waste
a) non hazaidous, or
b) less hazardous or
c) safei to tiansport, oi
d) safei to stoie, oi
e) safei to dispose of, or
0 amenable for lecovery, oi
g) amenable for storage, oi
h) 1 educed m volume (§260 10)
10 1 4 Supporting Documents
In addition to the content piovided herein, the following separate documents will be
generated and will support closuie operations at TOCDF
• Closuie Venfication Sampling and Analysis Plan (CVSAP) This document
provides the required number, type, and location of samples to be collected
in support of post-demolition closure verification, the methods and
procedures for sample collection, and the analyses to be performed on the
Attachment 10 - Page 5
TOCDF
Closuie Plan
June 2010
collected samples With this document will be a Quality Assurance Project
Plan (QAPP) that details the quality assurance requirements for the sampling
activities and analytical procedures outlined in the CVSAP The CVSAP and
QAPP will be submitted to the Executive Secretary for review Executive
Secretary approval of these documents shall be received prior to
commencement of final closure venfication sampling In some cases, the
media sample may be collected pnor to the demolition phase if it is
determined that demolition activities will make the sample more difficult to.
collect (e g , collecting soil samples by bonng through a concrete slab pnor
to slab removal) In each case, the soil sample will be collected and managed
appropriately to ensure its validity
Spill Site Cleanup Plans Cleanup Plans and the resulting Cleanup Reports
are required for each of the TOCDF Related Spill Sites identified in Module
VII, Table VII1 Post-cleanup sampling requirements for these spill sites
will be addressed in the CVSAP as required
Attachment 10 - Page 6
TOCDF
Closure Plan
June 2010
10 1 5 Comprehensive List of TOCDF and TOCDF-Operated Facilitv HWMUs
Table 10-1 lists all HWMUs that aie subject to tins closure plan
Table 10-1
TOCDF and TOCDF-Operated Facility HWMUs
40 CFR 264 HWMU Unique
Identification
Ancillary
Equipment
Definition
Location of Primary
Element
(MDB unless noted)
Vent Cat of
Pnmary
Element
Subpart I
Container Stoiage
Aieas
CHB 10 44 5 CHB D
Subpart I
Container Stoiage
Aieas
UFA 10 4 4 4 UFA C
Subpart I
Container Stoiage
Aieas
ECV 10444 ECV AJB
Subpart I
Container Stoiage
Aieas
TMA 1044 4 TMA A
Subpart I
Container Stoiage
Aieas
TMA Airlock 10 44 4 TMA Airlock C
Subpart I
Container Stoiage
Aieas
TMA Decon 10444 TMA Decon A/B Subpart I
Container Stoiage
Aieas
UPMC 1044 4 UPMC A
Subpart I
Container Stoiage
Aieas S-2 1044 5 S-2 D
Subpart I
Container Stoiage
Aieas
Igloo 1632 104 4 Aiea 10 Igloo 1632 See Note 2
Subpart I
Container Stoiage
Aieas
Igloo 1633 10 4 4 5 Area 10 Igloo 1633 D
Subpart I
Container Stoiage
Aieas
Igloo 1634 104 4 5 Area 10 Igloo 1634 D
Subpart I
Container Stoiage
Aieas
Igloo 1635 104 4 5 Area 10 Igloo 1635 D
Subpart I
Container Stoiage
Aieas
Igloo 1636 104 4 5 Area 10 Igloo 1636 D
Subp.li f J
Tank Svt-ieins
Conventional
ACS-TANK-101 1044 1 Toxic Cubicle A
Subp.li f J
Tank Svt-ieins
Conventional
ACS-TANK 102 104 4 1 Toxic Cubicle A
Subp.li f J
Tank Svt-ieins
Conventional
SDS TANK 101 1044 1
SDS Room A
Subp.li f J
Tank Svt-ieins
Conventional
SDS-TANK-102 1044 1 SDS Room A
Subp.li f J
Tank Svt-ieins
Conventional
SDS-TANK 103 10 4 4 1
SDS Room A
Subp.li f J
Tank Svt-ieins
Conventional
BRA-TANK-101 10 4 4 1 Subp.li f J
Tank Svt-ieins
Conventional
BRA-TANK-102 10 4 4 1 Outdoors D
Subp.li f J
Tank Svt-ieins
Conventional
BRA-TANK 201 1044 1 Outdoors D
Subp.li f J
Tank Svt-ieins
Conventional BRA-TANK-202 1044 1
Outdoors D
Subp.li f J
Tank Svt-ieins
Conventional
Subp.li f J
Tank Svt-ieins
Conventional
Subp.li f J
Tank Svt-ieins
Conventional
Subp.li f J
Tank Svt-ieins
Conventional
Subp.li f J
Tank Svt-ieins
Conventional
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 134 104 4 2 111 "A" Airlock A Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 135 104 4 2 TMA "A' Area A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 154 10442 TMA "A' Area A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 153 104 4 2 TMA 'WB" Area A/B
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 164 1044 2 Lower Buffer Storage Area A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment Sump 190 10442 Lower Buffer Storage Area A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 179 10442 Lower Munitions Corridor A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 184 104 4 2 Lower Munitions Corridor A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 125 1044 2 123 "A" Airlock A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 106 10442 ECR-B A
Subpart J
Tank Sybiem^
ICU Sumps With
Secondary
Containment
Sump 107 10442 ECR-A A
Sump 108 104 4 2
ECV B Sump 109 104 4 2 ECV B
Sump 110 1044 2
ECV B
Sump 112 104 4 2 Upper Munitions Corridor A
Sump 113 10442
Upper Munitions Corridor A
Sump 114 1044 2
Upper Munitions Corridor A
Sump 115 1044 2
Upper Munitions Corridor A
Attachment 10 - Page 7
TOCDF
Closure Plan
June 2010
Table 10-1
TOCDF and TOCDF-Operated Facihty HWMUs
40 CFR 264 HWMU Unique
Identification
Ancillary
Equipment
Definition
Location of Primary
Element
(MDB unless noted)
Vent Cat of
Primary
Element
Sump 116 10442
Sump 117 10442
Sump 118 10442
Sump 169 10442
Sump 174 10442
Sump 189 10442
Sump 145 1044 2
Sump 146 10442
Sump 147 10442
Sump 148 10442 Munitions Processing Bay A
Sump 149 10442
Sump 168 10442
Sump 175 1044 2
Sump 124 1044 2 255 A All lock B
Sump 126 1044 2 265 A Airlock B
Subpart J Sump 130 1044 3 Monitoring Room 457 C
J ank Systems Sump 131 1044 3 Observation Corridor 451 C
Sump 132 10443 DFS "C" Airlock c ICU Sumps Without Sump 133 1044 3 Obser\'ation Corndoi 454 c Secondaiy Sump 144 1044 3 HC2 Secondaiv c Coiitamirieni Sump 150 1044 3 SDS Room A
Sump 151 1044 3 Toxic Cubicle A
S'imp 1 10 4 4 J L IC 1 Se(.i>hdar\ '~
Suinp 157 10 1-1 3 LIC2 Pninai ' A
Sump 160 1044 3 111 'B" Aidork ' B
Sump 161 1044 3 DFS "B" Airlock B
Sump 167 1044 3 Observation Con idoi c
Sump 180 1044 3 -Lie "A/B" Airlock A/B
Sump 187 1044 3 MPF "A/B" Airlock A/B
Sump 188 1044 3 LTCl Pnmary A
Sump 193 1044 3 Observation Corridoi 359 C
Sump 197 104 4 3 Laboratory' c
Sump 173 10 44 3 Observation Coindoi c
Sump 182 10443 123 'B" An lock B
Sump 101 1044 3
Sump 102 10443 Unpack Area C Sump 103 10443 Unpack Area C
Sump 104 10443
Sump 136 1044 3 Observation Corridor C
Sump 137 1044 3 Observation Corridor C
Sump 138 10443 Observation Corridor C
Sump 139 1044 3 ObservaUon Corridor C
Sump 140 10443 Observation Corridor c
Sump 141 104 4 3 Observation Corridor c
Sump 142 10443 Observation Corridor c
Sump 123 10443 255 B Airlock B
Sump 127 10443 265 B Airlock B
Sump 192 10443 Observation Corridor c
BST Sump 103 10443 Outdoors D
Attachment 10 Page 8
TOCDF
Closure Plan
June 2010
Table 10-1
40 CFR 264 HWMU Unique
Identification
Ancillary
Eqmpment
Definition
Location of Primary
Element
(MDB unless noted)
Vent Cat of
Primary
Element
BCS Sump 107 1044 3 PUB Bulk Chemical Storage D
SubpaitO
Incinei ators
LIC 1 10446 LIC 1 Pnmary and Secondary A
SubpaitO
Incinei ators
LIC 2 1044 6 LIC 2 Pnmary and Secondary A SubpaitO
Incinei ators MPF 104 4 6 MPF Primary and Secondary A SubpaitO
Incinei ators DFS 1044 6 DFS Room and Outdoors A
SubpaitO
Incinei ators
'•}{:. 'j^'ATL!C!_ ..^.^ '^•igloo. 1 (535.;s..'. «„ .
Subpart X
Miscelkneous Units
PMD-101 1044 7 ECR-A A
Subpart X
Miscelkneous Units
PMD-102 104 4 7 ECR-B _j A
Subpart X
Miscelkneous Units
MDM-101 104 4 7
Munitions Processing Bay A
Subpart X
Miscelkneous Units
MDM-102 10447
Munitions Processing Bay A
Subpart X
Miscelkneous Units
MDM-103 1044 7 Munitions Processing Bay A
Subpart X
Miscelkneous Units
BDS-101 10447
Munitions Processing Bay A
Subpart X
Miscelkneous Units
BDS 102 10447
Munitions Processing Bay A
Subpart X
Miscelkneous Units Projo Cuttei 1044 7 ECR-A A
Subpart X
Miscelkneous Units
DVS 101 104 4 7
Area 10 Igloo 1632 C
Subpart X
Miscelkneous Units
DVS-102 104 4 7 Area 10 Igloo 1632 C
Subpart X
Miscelkneous Units
DVSSR 1044 7
Area 10 Igloo 1632 C
Subpart X
Miscelkneous Units
Autoclave 1044 7 Area 10 Igloo 1631 See Note 2
Subpart X
Miscelkneous Units
Subpart X
Miscelkneous Units
Notes
These new HWMUs are undeigomg public comment for addition to this Pennit
Ahliodgb not meeting die technical definition of MDB ventilaUon - Tregor;, C ufti
opv-ifiie"? iiiidcr negatr'e pre.'-sure engmeeniig controls and wdl be managed -n-. a tnti
L aiea toi the puiposes ol this closure plan
tisH\Vi\al
10 I 6 Inspections, Calibrations and Waste Feed Interlock Function Tests
10 16 1 Inspections and Automatic Waste Feed Cut-off (AWFCO) testing may be suspended for
HWMUs and support systems identified in Attachment 5 of the TOCDF RCRA Permit
when an item is removed from service for closure and aftei all visible hazardous waste
has been leinoved (if piesent) from die item undergoing closure The Executi^;:,
Secietaiy be notified when any inspection requirement or AWFCtJ tes* bsted in
Attacliment 5 is suspended tor closure hi addition, logbooks will no longer be lequired
to be maintained or kept at locations identified in Attachment 5 once the item is removed
from service for closure A notation will be made m the associated inspection form or
logbook that the item is undergoing closure when it is removed from service for closure
10 16 2 Calibrations and Waste Feed Interlock Function Tests may be suspended for equipment
and systems identified in Attachment 6 of the TOCDF RCRA Permit when an item is
removed from service for closure and after all visible hazardous waste has been removed
(if present) from the item undergoing closure The Executive Secretary will be notified
when any calibration requirement or Waste Feed Interlock Function Test identified in
Attachment 6 is suspended for closure
Attachment 10 - Page 9
TOCDF
Closure Plan
June 2010
10 1 7 Preparedness and Prevention, Contingency Plan
10 17 1 Emergency equipment and systems identified in Attachment 8 and Attachment 9 of the
TOCDF RCRA Permit may be removed or decommissioned in place as facility closure
progresses Emergency equipment and systems will be maintained by the Pennittee
during closure until it is determined that the eqmpment and systems no longer serve their
intended purpose The Executive Secretary will be notified when any emergency
equipment or systems are to be removed or decommissioned as the result of facility
closuie
10 17 2 Periodic changes to Attachment 8 oi Attachment 9 of the TOCDF RCRA Pennit resulting
fiom closure activities will be identified m quarterly updates that will be submitted to the
Executive Secretary as Class 1 permit modification notices to keep the Attachments
current with routine changes to facility
10 1 8 Closure Monitoring
As closuie of die TOCDF piogresses, agent monitonng requnements will change A key
objective for the closure of the TOCDF is to perlorm unventilated agent monitoring to
demonstrate that the < 1 0 VSL criterion has been met When this cnteiion has been
satisfied, agent monitoring will be terminated and demolition will commence as
descnbed in 10 4 1 of this plan Temporary changes may be made to the monitoring
requirements of Attachment 22 of the TOCDF RCICA, Pennit by following the normal
') OCDF procedures which provide proper approvah and documentation This will alloiv
loi adding to, reducing the number of oi changing the contlguialion of ^gent monitois on
1 i'=!nporpry b.isi'? 1 he Pennittee shall notify the F^en'iive Sf .letciry oinli • of nny
leduced moniloiing ajjplicabJe to Aflaclunent 22 pnoi lo uvplemevirituni
! 0 ? CLOSURE PERFORMANCE STANDARD
140 CFR 264 111, 270 14(b)(13), and UAC R315-8-7I
The closure performance standards may be divided into two parts thegenercd standaids
applicable to all TSDFs, and the technical standards for specific types of HWMUs This
Closuie Plan defines the processes that will be followed to close the TOCDF and
TOCDF-Operated Facilities such that all oFthe closure peifom;anve standaids are met
tO?l Geneial Standards
The general performance standards of 40 CFR 264 111 that are applicable to the overall
TOCDF facility are as follows
The owner or operator must close a permitted hazardous waste facility in a manner that
• Minimizes the need for further maintenance, and
• Controls, nunirmzes, or eliminates, to the extent necessary to protect human
health and the environment, the post-closure escape of hazardous waste,
hazardous constituents, leachate, contaminated runoff, or hazardous waste
decomposition products to the surface or groundwater or to the atmosphere
These general standards will be venfied at TOCDF by performing site-wide post-closure
samplmg and analysis descnbed m 10 2 3
Attachment 10 - Page 10
TOCDF
Closure Plan
June 2010
10 2 2 Teclinical Standaids
Thetechmcal perfonnance standaids of 40 CFR 264 111, winch constitutes the HWMU-
specific standards are as follows
The owner or operator must close a pemnitted hazardous waste facility m a manner that
• Complies with the closure requu-ements of 40 CFR 264, including the
lequirements of 264 178 (containers), 264 197 (tank systems), 264 351
(incineiatois), and 264 601 though 264 603 (miscellaneous umts)
10 2 2 1 Containei Stoiage Ai-eas - 40 CFR 264 178 (amended by R315-8-9 9)
At closuie, all hazardous waste and hazardous waste residues must be removed from
the containment system Remaining containers, liners, bases and soil containing or
contaminated with hazardous waste or hazaidow; waite residues must be
decontaminated or removed At closure the solid waste removed [shall be presumed
and managed as hazaidous waste] "
This technical standaid will be met at TOCDF b> 1) lemovmg all HW containeis and poiitiNe
secondaiy containment devices (e g , secondary contaimnenl pallets, ONCs), and 2) deconlaminatmg the
fi\ed secondaiy containment (i e , (loois and sumps) to the extent necessary for disposal as F999
hazardous debns m a Subtitle C Hazaidous Waste Landfill Secondai7 containment pallets and ONCs
Will be decontaminated by (nple-iinsing in accoidance with RCILAL All hazardous waste or hazardous
waste lesidues leinoved dunng decontamination activities will be chaiactenzed and managed as newly-
geneiaied hazaidous vvasfe The ancillary equipment (e g fixed secondciy containment m addition to
ibf Subpdil CC (.I'.'Sed ^-enl and contiol device) will then be demolished in their entiretv md disposed ns
ne.vb, jieneiaied F''^9''J liazaioous debns No ort illai >• e']L ipmeiu -will ieuuim po^i I i^v-f
Tlij'- fcv ln^iccl stindaid wdl I.K- vej ilied <ii 10(. DP h\ p;\ loiinms site wide no-' '.-h 'f
sampling and analysis descnbed m 10 2 3 m addition to venfication ol disposal of the MicdKi'v
equipment
10 2 2 2 Tank Systems - 40 CFR 264 197
Ai chsure of a tank system, the ownei or operator must remove or decontaminate all
wa^'fe residues contaminated containment system components (liners, eic )
c'jiv'aiiiinaied s'oiis, and siiuctwes and equipioent coi'liiniuiated w-nh '^vi'^'e •'"•// "I'j-^'ige
theiP a\ ha^fi'(toils Mci^^te If n')i all 'Contaminated soi/s can be p'acuconi; •env.- e. IC"
decontannnated then the owner or operatoi must perform post-closiiie care
Tins technical sfandaid will be met at TOCDF by decontaminating the vessel and ALL ancillary
equipment to the extent necessary for disposal as F999 hazardous debris m a Subtitle C Hazardous
Waste Landfill All hazardous waste oi hazardous waste residues removed during decontamination
activities will be charactei ized and managed as newly-generated hazardous waste The vessel and all
ancillaiy equipment will then be demolished in their entirety and disposed as newly-generated F999
hazaidous debns Neithei the vessel nor any ancillary equipment will remain post-closure
This technical standard will be verified at TOCDF by performing site-wide post-closure
sampling and analysis described in 10 2 3 m addition to verification of disposal of the vessel and its
ancillary equipment Thus, successful removal of contaminated soils (a requirement for achieving clean-
closure) will be venfied as well
Attachment 10 Page 11
TOCDF
Closuie Plan
June 2010
10 2 2 3 Incinerators - 40 CFR 264 351 (amended by R315-8-15 8)
"At closure, the owner or operator shall i emove all hazardous waste and hazardous
waste residues, including, but not limited to, ash, scrubber waters, and scrubber sludges,
from the incinerator site At closure the residue removed [shall be presumed and
managed as hazardous waste] "
This technical standard will be met at TOCDF by decontaminating the incinerator and ALL
ancillary equipment (including the PAS) to the extent necessary for disposal as F999 hazardous debns in
a Subtitle C Hazardous Waste Landfill All hazaidous waste or hazardous waste residues lemoved
during decontamination activities will be charactenzed and managed as newly-generated hazardous
waste The mcmeiator and all ancillary equipment will then be demolished m their entuety and disposed
as newly-generated F999 hazardous debns Neither the incinerator nor any ancillary equipment will
remain post-closure
This technical standard will be venfied at TOCDF by performing site-wide post-closure
sampling and analysis described m 10 2 3 in addition to verification of disposal of the incinerator and its
ancillary equipment
10 2 2 4 Miscellaneous Units - 40 CFR 264 601
A miscellaneous unit must be closed in a manner thai will ensure pi otection of human
health and the environment
This teclmical standard will be met at TOCDF by decontaminating the miscellaneous unit and
ALL ancillary equipment to the extent necessai^y for disposal as F999 hazardous debii': m a Subtitle C
Hazaid ai? Wa'^te Landfill AH hazaidous waste oi hazaidous waste lesidues lemoved during
deconiamiiuition activities will be chaiacterized and managed as newly generated hazardous vvasle The
miscellaneous unit and all ancillary equipment will then be demolished m then entuety 'iiid disposed ^^
iiewly-generated F999 hazardous debris Neither the miscellaneous unit nor any ancillary equipment will
remain post-closure
This technical standard will be verified at TOCDF by performing site-wide post-closuie
sampling and analysis descnbed in 10 2 3 in addition to verification of disposal of the miscellaneous unit
and its ancillary equipment
1C 2 3 Closure Sampling and Analysis (Closuie Venfication)
In Older to reach the final post-closuie configuration of the TOCDF facility, the building
that houses the vast majority of the HWMUs (the MDB) will be removed in accordance
with the Facility Closure Methodology descnbed m section 10 4 of this Plan With the
exception of those specific buildings or structures that will remain under the non-RCRA
use of a future tenant, outlying building superstructures that housed any HWMU ancillary
equipment (e g , the PAS, and the MDB HVAC System), and all portions of concrete,
asphalt and soil identified in Module VII as contaminated from spills will be removed
Once demolition and disposal of demolition debris is complete, the final post-closure
configuration of the TOCDF will have been achieved and the soils underlying the
removed HWMUs, HWTVIU ancillary equipment and spill sites will be sampled for
hazardous constituents The buildings that will remain under non-RCRA use by future
tenants, which housed pennitted HWMUs, but were not themselves ancillary to those
units (i e, did not provide secondary containment) will be venfied decontaminated and
Attachment 10- Page 12
1024
TOCDF
Closuie Plan
June 2010
letumed to custody of DCD Area 10 igloos subject to the DCD RCRA Pennit will be
subject to the final closure piovisions of the DCD Pennit, separate from TOCDF closure
Final Closure Perfonnance Standard Values
A final closure performance standard value is an analytical value for a chemical of
potential concern (COPC) that indicates a level of contanunation that is allowed to
leinam m place at final closure after demolition and disposal is complete The values,
which aie protective of human health and the environment, are presented m Table 10-2
which contains closuie peifomiance standaid values for seveial COPCs that have been
identified foi one or mote HWMUs at TOCDF, including chenucal warfare agents
(CWA) and agent degradation products (ADP)
TABLE 10-2
FINAL CLOSURE RISK PERFORMANCE STANDARD VALUES
Chemicals of
Potential Concern
An borne Exposure
Limits (VSL)
(mg/m')
CHPPM HBESLs'
Ung/kg)
Chemical Waifnie
Ageirts
(CWA)
GB IxlO' 32 Chemical Waifnie
Ageirts
(CWA)
HD 3x10 ' 0 2"
Chemical Waifnie
Ageirts
(CWA) VX IxlO' 1 r
Agent Degradation
Products
(ADP)
bA2192 N/A 1 F
Notes
if. The healtl ba-,ed soiecnuig levels developed by U S '^imy Ceiite" tor llt ilth Promotion f^nd '^'reientire Medi' ire
fUSACHPPM, 1999 (CHPPM)] thai tollow the USEPA Region IX iisk assessment metho'f is proposed tor chermca!
agent contaminants, to be leferred as the Health Based Environmental Screening Level (HBESl)
b The CHPPM HBESL is 0 3 mg/kg for Mustaid The final closuie performance standard for Mustard is equivalent to
the Field Dunking Watei Standard
c The agent degiadation product EA2192 will be considered additive to the HBESL for VX, i e the combined value of
VX and E.A2192 m a collected sample will not exceed I 1 mg/kg
Note Otliei agent degiadation products are not included based on the compounds ha"mg no HBESLs developed
due lo tlieii ielatively low toxicity
10 3 [MAXIMUM WASTE INVENTORY ESTIMATE
140 CFR 264 112(b)f3). 270 14fb)f 13). and UAC R315-8-7I
The inventory of hazardous wastes will be managed in accordance with the requirements
of the Utah Hazardous Waste Management Regulations (the Rules) for storage facilities
and other HWMUs undergoing closure At the time a HWMU is closed, there will be no
residual inventory of hazardous waste present However, 40 CFR 264 112(b)(3) requires
that a closure plan provide an "estimate of the maximum inventory of hazardous wastes
ever on-site over the active life of the facility" As such, Tables 10-3, 10-4 and 10-5
provide the maximum permitted-storage capacity of hazardous waste in Subpart J Tanks,
Subpart J Intermittent Collection Unit (ICU) Tanks and Subpart I Container Storage
Areas at TOCDF Table 10-5 provides the total aggregate storage capacity at the TOCDF
Facihty subject to this closure plan (i e , CAMDS excluded) All volumes are reported m
US liquid gallons (231 in^)
Attachment 10- Page 13
TOCDF
Closure Plan
June 2010
This maximum inventory estimate is prepared using the conservative strategy of
summing the maximum permitted capacity of all umts regardless of whether they were
ever operated m that manner This is particularly conservative considenng that, unlike
the permitted tanks, the sumps are explicitly limited to a storage duration of 24-hours
maximum As a result of this extreme conservatism, the volume of ancillary piping is not
considered in the total In addition, throughout the operating history of TOCDF, newly-
generated hazardous wastes were accumulated onsite in multiple container storage areas
and tanks However, the volume of hazardous wastes that temporarily resided in these
90-day areas are not included this estimate
TABLE 10-3
SUBPART J PERMITTED STORAGE TANKS
Tank Description Location Capacity
(Gallons)
Agent Storage System (ACS) Tanks 1712
ACS-TANK-101 MDB First Floor Toxic Cubicle 582
ACS-TANK-102 MDB First Floor Toxic Cubicle 1130
Spent Decon System (SDS) Tanks 6600
SDS-TANK-101
MDB First Floor SDS Room
2200
SDS-TANK-102 MDB First Floor SDS Room 2200
SDS-TANK-103
MDB First Floor SDS Room
2200
Brine Surge Tanks (BSTs) 171,600
BRA-TANK-101
Outdoors, West of
Brine Reduction Area (BRA)
42,900
BRA-TANK-102 Outdoors, West of
Brine Reduction Area (BRA)
^ 42,900
BRA-TANK-201
Outdoors, West of
Brine Reduction Area (BRA) 42,900
BRA-TANK-202
Outdoors, West of
Brine Reduction Area (BRA)
42,900
Total .storage Capacity of Subpart J Permitted Conventional Stoi age Tanks ' I79,'.>12
TABLE 10-4
SUBPART J PERMITTED ICU TANKS' (SUMPS)
General Specific Sump Capacity
Location Location ID^ (Gallons)
MDB Monitoring Room 457 130 89
First Observation Comdor 131 89
Floor DFS "C" Airlock 132 89
Observation Corridor 133 89
111 "A" Airlock 134 89
TMA "A" Area 135 89 TMA "A" Area 154 89
LIC2 Secondary 144 89
SDS Room 150 85
Toxic Cubicle 151 512
TMA "A/B" Area 153 89
LICl Secondary 156 89
LIC2 Pnmary 157 89
111 "B" Airlock 160 89
DFS "B" Airlock 161 89
Lower Buffer Storage Area 164 89 Lower Buffer Storage Area 190 89
Lower Munitions Comdor 179 89 Lower Munitions Comdor 184 89
Attachment 10- Page 14
TOCDF
Closuie Plan
lime 2010
TABLE 10-4
SUBPART J PERMITTED ICU TANKS' (SUMPS)
General
Location
Specific
Location
Sump
ID^
Capacity
(GaUons)
LIC "A/B" Airlock 180 89
MPF "A/B" Airlock 187 89
LICl Pnmary 188 89
Observation Comdor 193 89
Laboratory 197 89
MDB 123 "A" Airlock 125 89
Fnsf Obsen,'atiou Comdoi 173 89
Floor
Platfomi 123 "B" Airlock 182 89
101 89
Unpack Area 102 89 Unpack Area 103 89
104 89
ECR-B 106 89
ECR-A 107 59
108 89
ECV 109 89
110 89
112 89
113 89
114 89
115 89
MOB
Second
Flooi
1 'pi r-i MiiMitioi.s Coind ! iir Jf_ _ _
9. II
MOB
Second
Flooi
169 89" MOB
Second
Flooi 174 89
MOB
Second
Flooi 189 89
Observation Comdor 136 89
Observation Comdoi 137 89
ObservaUon Comdoi 138 89
Observation Comdor 139 89
Obsei vation Comdoi 140 89
Obseivatioh Comdoi 141 39
Observation Comdor 142 89
145 89
146 69
147 69
Munitions Processing Bay 148 89
149 59
168 69
175 89
Observation Comdor 167 89
MDB
Second
Floor
Platform
255 B Airlock 123 89 MDB
Second
Floor
Platform
255 A Airlock 124 89 MDB
Second
Floor
Platform
265 A Airlock 126 89
MDB
Second
Floor
Platform 265 B Airlock 127 89
MDB
Second
Floor
Platform Observation Comdor 192 89
Total Stoiage Capacity of Subpart J Permitted ICU Sumps 6173
Attachment 10 - Page 15
General
Location
TABLE 10-4
SUBPART J PERMITTED ICU TANKS' (SUMPS)
Specific
Location
Sump
ID^
Capacity
(Gallons)
TOCDF
Closure Plan
June 2010
Notes
1 ICU sumps are permitted as Subpart J Tank systems because they may be used as
pnmary containment of hazardous waste for a permit-imposed maximum penod of
24-hours Sumps that serve ONLY as secondary containment for nearby tanks or
containers are not mcluded in this list
2 Sumps are identified by their corresponding sump pump number [e g , sump 130
corresponds to the sump's pump equipment piece number (EPN) SDS-PUMP-130]
Attachment 10 - Page 16
TOCDF
Closure Plan
June 2010
TABLE 10-5
SUBPART I CONTAINER PERMITTED STORAGE AREAS
Container Storage HWMU Maximum Inventory
(Gallons)
Container Handling Building (CHB) 36,555
S-2 Warehouse 38,720
Area 10 Igloo 1632 14,520
Area 10 Igloo 1633 14,520
Area 10 Igloo 1634 14,520
Area 10 Igloo 1635 14,520
Area 10 Igloo 1636 14,520
Unpack Area (UPA) 3424
Explosive Containment Room Vestibule (ECV) 833
Upper MunUions Comdor (UPMC) 4366
Toxic Maintenance Area (TMA) Container Storage Area 2200
TMA Airlock 381
TMA Decon Aiiea 381
Total Storage Capacity of Subpart I Container Permitted Storage Aiens 144,940
TABLE 10-5
Aggregate Total Storage Capacity, All Permitted HW Storage Units
HW Storage Unit Type Maximum Inventory
Subpart I Tank Systems 179,9)2 Gallons
Subpart) ICU Sunips
Subpait 1 Container Storage Areas
6,173 Gallons
144 940 Gallons
fot il Capacity, A)! Permititil Storage, 1999 & P999 MJ,025 Gallons
(44,249 ft')
10 4 FACILITY CLOSURE METHODOLOGY
140 CFR 264 112(b)(n & (2)
This section summarizes the processes which will be used to close HWMUs al TOCDF
This section is broken up into four subsections The firs! subsection (10 4 1) provides flit
sequence of events for decontamination and equipment removal The second subsectioi-i
(10 4 2) provides the methods to decontaminate the HWMUs The thjrd siiDsechon
(10 4 3) provides the overall closure schedule The fourth and final subsecnon (10 4 4)
provides a specific definition of what equipment pieces associated with a HWMU are
considered "ancillary equipment" and thus constitute a part of the HWMU subject to
closure
Since disassembly of a HWMU pursuant to closure does not constitute modification of
the HWMU with the intent to commence storage, treatment, or disposal of hazardous
waste withm the HWMU, Facility Construction Certifications (FCCs) will not be
required Hence, Permit Condition I S will not apply when modifying the configuration
of any HWMU pursuant to closure
It should be noted that the safety regulations for chemical agents descnbed m Department
of the Army Pamphlet 385-61 and all local TOCDF procedures that outline specific
methods/codes for dress or operatmg procedures will be followed dunng closure
Attachment 10 - Page 17
TOCDF
Closuie Plan
June 2010
10 4 1 Decontamination and Equipment Removal Sequence
The sequence for proceeding tlirough decontannnation and equipment removal is a senes
of steps that will be perfonned at each area/unit withm the TOCDF to ensure they have
been decontannnated to a level protective of workeis and the environment The sequence
begins with the management, control, and monitoring of hazardous exposures, proceeds
tluough decontamination, and any appiopnale equipment and matenal removal
hifomiation fiom the Contanunation History report was used m developing this
sequence
The sequence of events foi each area is as follows
1 Establish Engineering Controls/Monitoring - For areas normally under
ventilation engineeiing contiols (e g , categoiy A, A/B, B and C), engineeiing
contiols will be verified established and functioning befoie initiating HWMU
disassembly activities withm a pieviously agent-contaminated area (liquid oi
vapoi) Foi TOCDF opeiations, the controls will address agent vapor
management through ventilation contiol as well as \voikspace momtormg ioi
agent vapor
2 Preliminary Survey - Aftei ventilation engineering controls are venfied
established, workeis will entei the designated area to peitorm a pielimmaiy
survey, which will seive to veiify existing conditions vvithm the aiea (e g
general arrangenient of installed eqtupmcnt pieseiue o( occluded sfiaccs
woikspace hazards lequiiing miugatioti befoie wo'k tAecution) The steps
associated with the pei(oim?iKe ol an o.oiuded sp ice --^u •-•ty uc des„iibfd in
section 10 4 11
i Preparation for Work Execution - The leadiness of the area for intended work
IS evaluated in this step Energized systems in the woik aiea that could affect the
safety of the workers will be isolated and the integrity of secondary containment
systems and spent decontamination solution (SDS) collection systems will be
verified before gross decontamination activities are undertaken Supporting
utilities such as fiie suppiession system watei, pldPt an piocess vatei y^ili he
isolated to aieas as needed The irapacl of these system isolations will bf
evaluated in ordei to maintain the safety of peisoimel giiti the facility
4 Decontamination and Equipment Disposition - The appioach to work m each
area will differ depending upon existing conditions, installed equipment, and
contamination histoiy The decision to decontaminate, and to what degree, will
be evaluated throughout the closure process Agent-contaminated equipment,
buildings and stmctuies will be decontaminated and monitored such that
engineering controls for ventilation oi air pollutant emissions control (i e ,
Subpart CC boundaries) aie no longer lequired to ensuie worker exposure/release
levels do not exceed 1 0 WPL Woik activities in a selected area will include the
following as appropnate and generated waste will be managed m accordance
with 10 5, Closure Waste Management
a Elimination of fluids
b Removal of components and equipment deemed too complex for
thorough disassembly and revealing of occluded spaces
Attachment 10 Page 18
TOCDF
Closure Plan
June 20 iO
c Exposure (revealing) of occluded spaces
d Surface decontamination for chemical agent and other hazardous waste
constituents
e In situ thermal decontamination of specific components and structures in
accordance with a specific formal m situ thermal destruction plan
prepared m accordance with site procedures
f Removal of components and equipment that pose a personnel tripping
hazard or area congestion hazard
g Removal of floor coalings for underl> mg concrete sampling as described
m section 10 4 12
h Identification and evaluation of embedded dram lines
1 Removal of sump protective liners
J Removal of umversal wastes
Post Disposition Survey - At the conclusion of decontamination and equipment
removal activities m each work area, a post-work survey will be performed to
•.'enfy that work objectives have been achieved Phis sur/ey will confirm the
following conditions to verify that a safe conftgutation has been achieved
a Occluded spaces (as descnbed in 10 4 1 1) that have nol otherwise been
adequately treated (e g , thennally) have been exposed or eliminated,
b Explosives and PCBs have been removed to levels below industrial
clean-up standards and
c Non-agent waste materials (e g lead based punt nsbeslos nitLrciiiy
uni.'ersai vastes) h-.ive beeri removed orlelt ui pl.~'i i. lu' e u^sn
identified fi^r propet diopcs.-i liirmg 'lemold'oo
Perform Final Ventilated Monitoring lent - Aieas normally under venttkition
engineering controls will be subject to a final Ventilated Monitoring 1 est (VM 1)
The VMT requires 24 continuous hours of NRT monitonng with the forced
ventilation system ninning If any results are > 1 0 VSL, evaluation of areas will
be performed with point-source ACAMS to identify hot spots Contaminated
aieas will be decontaminated and the procedure will be repeated until results are
1 0 VSL Achieving satisfactory ventilated monitortng results pro /ide-
fissi'rance thai clecontaimmnon and equipmeni removal fctu'ities ha^e been
completed, and if the area is subject to an unventilated inoiutonng lest, ihen ^'nai
test IS ready lo proceed The VMT does nol apply to ventilation category areas L>
and E and outdoors
Perform Final Unventilated Monitonng Test (UMT) - Areas normally under
ventilation engineenng controls and which have thus been determined via nsk
assessment, will be a final Unventilated Monitonng Test (UNIT) Final
verification (prior to demolition) includes the performance of an UMT for areas
identified via risk assessment, the goal of which is to measure an agent off-gas
rate This off-gas rate will be determined by holding the unventilated area test
volume for a pre-determmed penod of time to allow for agent, if present on
building and equipment surfaces, to off-gas into the test volume airspace After
the test volume's hold time has expired, the agent concentration m the test
volume airspace will be measured via air monitonng using 1 0 VSL as a test-
specific cnterion UMT success cntena will be the determination of an agent
off-gas rate for an area such that workers will not be exposed to a work
Attachment 10 - Page 19
TOCDF
Closuie Plan
June 2010
enviionment at or above 1 0 WPL post-UMT (e g, dming demolition) If the
measuied off-gas late does not meet this cntenon, evaluation of areas will be
perfonned with point-source ACAMS to identify hot spots Contaminated
surfaces will be further decontannnated and the UMT process will be repeated
until the UMT success cnterion is met
hi areas subject to the UMT, a successfiil UMT in addition to the performance of
actn'ities described in 10 4 1 steps 1 tluough 7 constitute evidence of
1) successfiil decontannnation of building, equipment and structures
such that the buildings, equipment and stmctuies can be safely
demolished, tiansported and disposed at a Subtitle C Hazardous Waste
facility as F999 Hazaidous Debns ot Hazaidous Waste, and
2) the non-applicability of the P999 hazaidous waste code to the
demolition debris via the contained-in policy
Final Isolation - For aieas subject to the UMT, upon successful completion of
the final UMT, monitonng will be lemoved For aieas subject to the VMT only,
upon successful completion of the VMT, moniloiing will be lemoved Access io
the buildings/aieas will be lestiicted until such time that demohtion of the
building begins
Demolition ~ Aftei the MDB and all othei buildings housing HWMUs are
decontaminated and venfied to meet the minimum "action level criteria foi
disposal" (< 1 0 VSL generated off-gas idles detennined thiough a successful
UMT 01 completed decontamination foi aieas not subject to the UMT), the
buildings and then contents will be demolished, with the exception of those
specifically lequested by DCD lo jemaiii foi futuic non RCRA use Dcnrilifi"n
\vdl include the ienu>\'al of the MDB cniiciefe slaos and die remo^'al of I'ly
ancillary undergiound piping With the ex.cept.on of tlio^e specincally-iecjuested
by DCD to remain foi futuie non-RCRA use buildings and stmcttires not
associated with HWMUs will be removed to the flooi slab, which will lemdin
Al the conclusion of the demolition step
a All HWMUs will have been removed from the TOCDF site including the
DCD Aiea 10 treatment units,
ti With the exception of buildnigs (hat will leinau^ under non-RCRA use by
fuluie tenants, all buildings that housed HWMUs, will have been
removed iiom the TOCDF site, including the MDB floor slabs,
c Buildings that will remain undei non-RCRA use by future tenants by
specific request that housed HWMUs and their ancillary equipment will
have been decontaimnated of TOCDF-related operations potential
contaminants,
d Module VII Spill Sites will have had all contaminants removed,
including contaminated soil and pavement,
e With the exception of specific non-HWMU buildings and their support
utilities buildings and stmctuies (e g , sewage treatment, security, and
electncal/water stmctuies) that will remain in non-RCRA use by other
tenants, all buildings will have been removed down to the grade slabs,
which will remam m-place,
Attachment 10 Page 20
TOCDF
Closure Plan
June 2010
f Paved roads, parking lots and other concrete surfaces will remain in
place for use by other tenants
10 Conduct Final Closure Venfication Sampling - A combination of random and
judgmental samples will be collected for the purpose of closure venfication As
stated in Section 10 1 4, a separate Closure Venfication Sampling and Analysis
Plan (CVSAP) and Quality Assurance Program Plan (QAPP) will be submitted to
the Executive Secretary for approval
10 4 11 Occluded Space Survey
An Occluded Space is defined as a confined or restricted access volume within a system,
stmcture, or component that was exposed, or potentially exposed, to liquid agent and has
the potential to contain any quantity of agent or agent-exposed or contaminated liquid
The location and position of such spaces may prevent or limit contact with
decontamination solutions
Piioi to peifomnng air monitoring per 10 4 1, all potential sources of res'duil liquid
agent (occluded spaces) must be identified and decontaminated Revealing (exposingi
the occluded space to enable effective penetration of decontamination solution is ihe
pnmary method of ensunng agent decontamination of an occluded space In lieu of
chemical decontamination, thermal decontamination may be used in certain
circumstances provided the rigors of the m situ thermal destmction technology are met
as descnbed m 10 4 2 2 9
General examples ol a potential occluded space include
» riooi anchor bolts, or anchor bolt holes, in an ngent ope.iati>;n ai-"ci, v^^het^er < r
not theie vvas a known agent spill m the area
e Anchor bolts, or anchor bolt holes m walls for which there was known liquid
agent contact with the wall
• An agent pipe that has been blinded, capped or otherwise sealed, mespective of
v/hether or not it has been previously decontaminated
9 Flat, parallel surfaces in close proximity to each other that limit effective
penetration of decontamination fluids
« Pipe and tank supports
9 .'\ieas sealed with any type of caulking, grout or rubber seols and gaskets
• The space under a floor mat, support plate, or other movable object which
covers a potentially contaminated surface
• Equipment which harbors space inaccessible to decontamination solutions
Examples are
o Internal check valves or complex geometry valves with the potential to
trap liquid agent behind double seal o-rings, within packing etc
o Shaft seals, bearings, etc
o Internal blind or occluded cavities of pumps
o Tools, closed tool boxes, etc
Following decontamination/decommissioning activities but before unventilated
moniformg begins, a final survey will be performed to validate that all occluded spaces
have been addressed and also to ensure that no other occluded spaces have been missed
m the assessment and work process
Attachment 10 - Page 21
TOCDF
Closure Plan
June 2010
104 1 2 Liquid Agent-Exposed Flooi s
In aieas where coated conciete floors have been exposed to liquid agent, the approach
will be to perfonn statistical chip sampling in combination with judgmental samples (i e
locations where stains/suspect areas based on observations, process knowledge and
professional judgment) Ageiit-contammation withm the underlying concrete indicates
failure of the floor coating to perfomi as an impermeable barrier In order to access the
undeilying concrete, the floor coating will be lemoved m these aieas wheie samples are
lo be collected If the conciete clnp sample indicates agent conlaimnation above the
waste control limit (WCL), 20 ppb foi GAJGBfVX and 200 ppb for Mustard/Lewisite,
further sampling will be perfonned to assess the lateial extent of concrete contaimnalion
Once the extent of conciete contanunation has been determined, the agent-contaminated
concrete within the defined area will be decontaminated by application of one of the
fallowing technologies
1) Physical Extiaction to meet the applicable perfonnance standard (e g , removal
of at least 0 6 centinieteis of the surface layer and achievement of a clean debns suiface)
The lenioved contaminated layei matenal will be lenioved, tieated and disposed ac
hazardous waste m accoidance with the Waste Analysis Plan oi the geneiatoi
lequiiements of 40 CFR 262 11 Successfully decontanimated concrete (uncontammated
undei lying conciete) sampling below the WCL will be peifoimed to verify concrete
decontamination
2) Theimal Destmction m accoidance with a fonnal ad hoc in situ thermal
destmction plan prepared in accoidance with site pioceduies Successfully
decontaminated concrete sampling below the WCL mW be peiloimed (o venfy concrete
deconfammaiion
10'^j 3 Eaiiy Partial Closuie-Individual HWMUs
Ihis section pertains to the partial closuie of an individual HWlN'IU or any part thereol
that IS perfonned anytime aftei the HWMU has fulfilled its puipose, but pnor to TOCDF
enteiing the site-wide demolition phase
fOCDF may, when the opportunity aiises, peifoira partial closuie of individual
HWMUs, wholly oi m-part, piovided that the individual HWTS-IU and/or its ancillaiy
equipment can be 1) disassembled, deconiammaied, fieated and disposed MI a manner that
IS consistent with the Waste /Analysis Plan (WAP) oi the geneiatoi lequiiements of 40
CFR 262 11 or, 2) thennally-deconlaminated m accoidance with a fonnal ad hoc in snu
thermal destmction plan prepared in accoidance with site procedures
Because early partial closure diiectly impacts the planned sequence and duration of
closuie activities as described in tins Closuie Plan, the Permittee shall notify the
Executive Secretaiy of the intent to peifonn, eithei whole or m-part, early partial closure
pnor to commencement of disassembly
HWMU components undergoing early partial closure can be decontaminated, treated and
disposed in a Subtifle C HW landfill within the scope of an existing specified waste
stream appeanng in the WAP (e g, thermally treated as waste stream 2 2 16 "non-
combustible bulk solid waste" or decontaminated and disposed as waste stream 2 2 2 30
"closure generated waste") HWMU components themially decontaminated pursuant to
early partial closure m accordance with a formal in situ thermal destmction plan shall be
Attachment 10 - Page 22
TOCDF
Closure Plan
June 2010
1) left m-place for removal dunng demolition, or 2) removed, declared F999 hazardous
debns, and disposed in a Subtitle C hazardous waste landfill
Because closure of the HWMU must ultimately be certified by an independent registered
professional engineer at the conclusion of final closure activities, all records pertainmg to
the disassembly, decontamination, treatment and disposal of the HWMU, including each
piece of ancillary equipment, shall be retamed for fiiture retneval
Metal components may be recycled by reclamation in lieu of being disposed in a landfill
as hazardous debns/waste provided the requirements of 10 5 4 5 are met
10 4 2 Equipment and Facilities Decontannnation
The decision to decontaminate, and to what degree, will be evaluated throughout the
closure process Agent-contaminated equipment, areas, and facilities will be
decontaminated and headspace-monitored to < 1 0 VSL such that engineering controls
for ventilation or secondary containment (i e, protective containment boundaries) are no
longer required
Within each of the buildings/stmctures, selected rooms and equipment will require
decontannnation to reduce residual agent levels pnor to disassembly and removal m
accordance with the closure sequence (Section 10 5 1) The decontamination methods
will be compatible with the individual systems and will not cause imminent failure or
breach of the system's primary containment
Decontamination of non agent-contannnated areas addresses hazardous waste and
hazardous material residue other than agent For areas/systems that are also
contaminated with agent, the non-hazardous waste/material may be completely or
partially removed with the same decontamination technique(s) used for agent
Many support buildings at TOCDF were never used for or exposed to chemical agents,
hazardous materials, or hazardous wastes These areas include the CON, modular office
"T" buildings, some stationary "S" buildings, the Entry Control Facility, etc Gross
decontamination of these facilities will be limited to collection and removal of loose
debns, as necessary No ftirther decontamination is anticipated prior to bulk demolition
Non-agent contariimation existing outside facility buildings is assumed to be minimal and
to require limited decontamination effort, if any Decontannnation of non agent-
contarmnated areas will be conducted to support removal of the protective containment
boundaries and allow demolition of the equipment and stractures, and to support the
various disposal options for the generated waste streams Additionally, coatings,
insulation, and building matenals will be evaluated for presence of lead-based paint,
asbestos-containing matenal, and other regulated matenals Stripping and segregation of
these regulated materials, if necessary to ensure proper debns disposal, will take place
prior to building demolition Regulated matenals and associated demolition debns will
be shipped offsite for disposal m accordance with applicable regulations
1042 1 General Decontamination Approach
Even though equipment, buildings and stmctures will not technically have been declared
as hazardous debns at the time of decontamination (not formal "treatment"), they will
Attachment 10- Page 23
TOCDF
Closure Plan
June 2010
ultimately be declared hazardous debns upon demolition, charactenzed based on
generator knowledge, and disposed as hazardous debns Therefore, decontamination of
equipment, buildings and stmctuies will be conservatively based on methods listed in 40
CFR 268 45, Table 1 Altemative Treatment Standards for Hazardous Debns
Decontamination will proceed in a specific sequence/order, based on conditions at each
area, to allow the most effective, easiest and safest decontannnation and/or disassembly
Equipment and matenal may be disassembled and themially decontaimnated in the MPF
or Autoclave permitted umts in accordance with the WAP Alternatively, surfaces that
have been m contact with liquid agent may first be decontaimnated using mechanical
means, such as wiping the suiface to lemove particulates, giease, and other surface
debris, or by scarifying to remove surface coatings that may have been contaminated with
agent Following mechanical decontamination, equipment and suifaces may be
chermcally decontaminated with a neutralization solution or may be size reduced,
packaged as appropriate, and sent to permitted storage awaiting further treatment If
chemical decontamination occurs, decontamination solution will be used m such a
manner as to prevent the spread of contamination Newly generated lesidual
decontamination solution will be managed m accoidance with WAP
Aftei chemical decontamination is complete, decontaminated surfaces will be an diied
and equipment and areas will be tented and an monitored to delermme if the
"unventilated monitoring cnterion" ot <1 0 VSL for chemical agent has been achieved
Equipment that meets the agent screening cnterion of <1 0 VSI may be packaged
appropriately and shipped offsite m accordance with its planned disposition or may be
left in place foi futuie removal dunng sue-wide demolition Equipment and aiea^ laihny
'lie 'iLtum le\e) .ritejion for disposal of >I o VSI .i-ili be e.';-ihi,-)iul I'"- defeirnnie
vheihei additional chemical mcciianical oi iii siii, theuiiiU Jti uiiioimii:.iH/n is viahk- lo
a'-tiiCve ihe cr ieuon, oi v/hethei (oinial HV'' 'le'uinciu ^ .in .itii HvVMU M^'.. ,
10 4 2 2 Decontamination Fechniques
This section describes the various methods that will be employed for decontamination
The methods may be employed, either singularly oi in combination, to decontaminate the
equipment, building or stmcture Any wastes nev/ly-geneiated from decontammation
fictivities (e g , nnsate, DPE, etc ) will b° managed in accordance wjth ihe Waste
Analysis Plan (WAP)
1042 21 Water/Steam Flushing
Water and/or steam fiushing has both chemical and mechanical decontamination
properties This techmque involves flooding a surface with water (typically hot) oi
steam The water or steam removes the contaminants and the resulting wastewatei is
, collected for treatment or disposal This teclinique may be used with detergents or other
chemicals that enhance the effectiveness of the technique The flushing action may also
erode and remove loose debris from the exposed surface area Steam cleaning may be
used to physically extract contamination from building and equipment surfaces This
technique combines the solvent action of water with the kinetic energy effect of blasting
and elevated temperature Effectiveness of steam cleaning as a decontamination method
for agent is further increased by localized hydrolysis of the residual agent The steam
may be applied using hand-held wands or automated systems, and the condensate is
collected in room sumps for treatment and/or disposal
Attachment 10 - Page 24
TOCDF
Closure Plan
June 2010
104 222 Chemical Decontannnation Solutions
Sodium hydioxide (NaOH, caustic) and bleach solution (calciiun hypochlorite, sodium
hypochloiite) are lecognized as effective decontannnation solutions for the chemical
destmction of agent contamination The chenucal decontaimnation technique involves
the application of caustic, bleach, or other similar solutions to the contaminated surface
The suiface may be scmbbed with the solutions and/oi allowed lo stand for a period of
time, and then flushed thoroughly with water These solutions may also be used m
coinbiiialion with deteigents and suifactanls
10 4 2 23 Delei gents and Suifactanls
Most commeicial detei gents aie fonnulations of a deteigent (sodium laurel sulfate,
sodium oleate, alkyl aryl sulphonate) tliat also acts as a wetting agent or surfactant, a
phosphotous 01 caibonate salt (NaiP04, Na2C0i), a thickening agent (carboxyl methyl
cellulose), and othei fillers Unlike the decontamination solutions descnbed above that
effectively deslioy the agent contamination, deteigents aie used in decontamination to
physically lemove suiface conlaininants (e g , agent) and captuie thern in the resukmg
spent solution Suifactanls woik by loweiing liquid sui face tension and providing better
conlact between the suiface and the liquid Deteigents aie effective, mild, all-purpose
cleaners for all facility suifaces and equipment They can be used to increase the effect
of water, steam, and solvents, and then effectiveness is mcieased by mechanical
agitation Deteigents may not be effective on metal corrosion and long standing
contamination A commercial all puipose cleaner/suifaLtant (Whistle(Ri) has been used
successful',/ lo deconlammate items dm.ing T OCDF plant opeiatioMs
10 4 2 2 foaiH De(>)iiLaniinalioii
Foam such as that pioduced by deteigents and wetting agents, can be used as a earner
mechanism foi chemical dexontaminadon agents They can be applied in different depths
and surface orientations The foam decontammation method can effectively
decontaminate metallic walls and parts of complex components Surfactants in the
foaming agent can eiiliance the effect by increasing contact with the surface The
pj nn-)yy mode of action of the derontaminant is based on oxidizing propeities oj
hydiogen peio ide A surfac lanl and aii acceleiam mciease the late ot peiO/^ide a^ti ^'tv
and allow llic decontammant lo be applied as stable loam
104 2 2 5 Physical / Mechanical Scmbbing
Physical/mechanical scmbbing with bmshes or othei devices was found to be extiemely
beneficial and most likely necessary, in the decontamination of other demilitanzation
sites Combining scrubbing of suifaces with the appiopriate decontamination solution
mcieases the efficiency of the decontamination solution in removing and destroying
lesidual agent by enhancing contact between the solution and the agents
10 4 2 2 6 CO, Blasting
CO2 blasting (also known as dry ice blasting) is a decontamination technique used to
physically remove contaminated surfaces The method utilizes compressed air to
accelerate frozen carbon dioxide (CO2) pellets, at supersonic speeds, towards a surface
Attachment 10 Page 25
TOCDF
Closuie Plan
June 2010
The impact of the CO2 pellets creates mim-explosions on the surface and results m the
lifting/removal of the topmost layer of a substrate CO2 blasting is a non-abrasive,
nonflammable and nonconductive cleaning method which is environmentally-friendly
and contains no secondary contanunants such as solvents or grit media The method
allows most items to be cleaned m place and can be used without damaging active
electncal or mechanical parts or creating fire hazards Additionally, CO2 blasting can be
used to remove production residues, release agents, contaminants, paints, oils and
biofilms from surfaces
1042 2 7 Mechanical Surface Removal
Mechanical surface lemoval, such as gnnding, scraping, 01 scanfymg, is a
decontamination option to physically remove contaminated surfaces These techniques
may be used to decontaminate areas intended for reuse or to achieve a prerequisite
condition to support removal of protective containment boundanes Surface removal
may also be used to reduce the volume of hazardous waste by removing only the
contaminated fraction and allowing disposal of the uncontammated substrate as non-
hazardous waste or leaving the uncontammated substiate in place Giindmg with
grinding wheels or suifacing discs lemoves thm layeis of suiface contamination from
concrete where contamination is limited to the coating or sealant fimsh Scaiifieis
physically abrade both coated and uncoated concrete and steel surfaces The scarification
process removes the top layers of contannnated surfaces down to the depth of sound,
uncontammated surfaces Scabblmg is a scanfication piocess used to remove conciete
surfaces Needle scaling is a scarification process for both conciete and steel surface
removal 1 he lemoved surface material is then collected by vacuum system for treatment
Tiid/oi disposal
10 4 i 2 8 Surface Coating (Encapsulation)
Coatings may be used on contaminated surfaces to fix 01 stabilize the contamination in
place The intent is to decrease or eliminate the exposure hazaid, and redute the potential
spread of contamination Although no removal of contamination occurs, the stabilized
contaminants can be left in place and removed with the substrate for further treatment 01
disposal This may be used to achieve a condition that allows removal of the protective
containment boundaries if the substiate can be safely lemoved latei vithout those
boundanes m place
1042 2 9 In-Situ Thennal Destmctibn
Chemical warfare agents GB, VX and Mustard are susceptible to molecular destmction at
elevated temperatures At TOCDF, thermal destmction in subpart O incinerators is the
prescnbed method for permitted-treatment of liquid chemical agents, as descnbed in
Module V and VI of this permit The residence time necessary to destioy agent at the
elevated temperature is generally an inverse function of the temperature Hence, the
1000+ °F temperatures in the incinerators results in a very rapid destmction of agent
(e g , seconds) In contrast, lower temperatures used during in situ thermal destmction
results m a relatively long residence time (e g ,minutes or hours)
Although more complex to perfonn than surface decontamination, the in situ thermal
destmction of chemical agent contaminants on equipment greatly reduces the need to
disassemble complex equipment in order to reveal agent-harboring crevices This is due
Attachment 10 - Page 26
TOCDF
Closure Plan
June 2010
lo the ability of heat to effectively penetiate by conduction into crevices and dnve the
local tempeiatuie up
Based on the "Alternative Treatment Standard for Hazardous Debris" B 3, in situ thermal
destmction, when utilized for hazardous debns, is subject to venfication of localized
terrqperatiue and residence tune Only with venfied localized temperature and venfied
lesidence tune can in situ thennal destmction be i eliably effective Hence, the use of this
teclmology as a means to decontaminate potentially agent-bearing crevices, occluded
spaces, complex equipment oi concrete requues
1) the peifomiance of a "ueatability study" as defined in 40 CFR 260 10 wheiem
optimal piocess conditions oi imnimum effective piocess conditions (i e , minimum
lestdence time as a function of local temperature, oi nnnimum local temperature as a
fimcUon of residence tune) are detennined in ordei to achieve the desired agent
destmction effectiveness, and
2) a iigoious situatioiial-specific engineering application combined with objective
data collection dw ing actual thermal treatment (e g , conservative thermocouple
placement conservative thennal dosimeter, or the use of spiked samples) in order to
veiify that the optima! oi minimum effective piocess conditions were met oi exceeded
10 4 2 210 Natuial Altenualion/Volatilization
Analogous to the ''Altemative Tieatment Standard foi Hazardous Debris" A 3 b
"Thennal Desoiplion", Natuial Attenuation repiesents the extraction of volatile
hazaidous contaminants (e g , agent) from the debus suifaces and subsequent capture o*
the contaminants liom the exhaust gas (e g the caibon adsoiption HVAC filtration
system I Natural Attenuaiion oc^uts at ambient teniperaluies within the normjl HVAC
diirloN',' Naluial utenua'ioii is the iCoult ol mass tiansfei oy evap()ration ageni fiOiU
debus iUifaces lo the "^uuoundmg an, and is not netcssaiily effective kr matenals uch
as baie conciete, wood oi materials possessing occluded spaces Hence, natural
attenuation as a means of decontamination will only be effective for non-porous metallic
01 painted surfaces and only upon venfication by headspace monitonng to <] 0 VSL
10 4 3 Schedule foi Closure, Tune Allowed for Closuie, and Extension of Closure
1-40 CFR 270 I4('b)(l3). 264 112(b)(6). 264 112(b)(2). 264 113(a) and (b)l
Tlip andciiiaied fOCDF faciliiy closuie schedule is piesented m Figure 10 1
Decommissioning withm the MDB, whiclr houses the vast majority of HvVMUs, will
pioceed m an aiea-by-aiea mamiei based primarily on ventilation category Hence, a
specific sequence of HWMU decommissioning is not provided since a given HWMU's
ancillary equipment is oftentimes spread throughout multiple areas of the MDB
Howevei, the general decommissioning sequence of the HWMUs' primary elements is
piovided in Figuie 10-2
The closure of TOCDF will occur in four distinct phases
Phase 0, Pre Closure Planning and Early Opportunity Work
This phase occuis prior to the completion of munitions processing and official
commencement of closuie operations Along with administrative planning and
preparations, other activities to take advantage of time and resource availability
and to piepare the plant for closure after the end of munitions processing will be
Attachment 10 - Page 27
TOCDF
Closure Plan
June 2010
planned and executed Early Partial Closure, in accordance with conditions
descnbed in 10 4 1 3, will occur dunng this phase
Phase I, Decommissioning and Decontamination
Dunng this phase, eqmpment, bmldings and stmctures are decontannnated,
dismantled, verified decontaminated and charactenzed as necessary to prepare
the facility for demolition and disposal, or turnover to other tenants as
determined m the end state document Foi agent contaminated facilities, this
includes successfully completing Unventilated Momtormg Testing (UMT) and
final isolation of utilities and systems for demolition The objective of the D&D
phase is to decontaminate the facility to a level that is protective of the
demolition crew, the HW transportei, the disposal facility workers and the
environment, and meets the regulatory requirements for disposal
Phase 2, Demolition and Facilities Disposition
During this phase a demolition subcontractor will demolish, package, offer for
transport and offer for disposal of equipment, buildings and stmctures in ordei lo
achieve the physical end-state of the facihty in accoidance with legulatory plans
and permits
Phase 3, Administrative Closeout
During this phase, the RCRA clean-closed end-state of the facility will be
verified through implementation of the CVSAP In addition, completion of
facility closure will be certified by an independent registered Professional
Fngineer Accordingly, the TOCDF RCRA TSDF Pennit will be leimmaled
Various non-RCRA busmess-i elated activities dunng thr- phase IPL hide
Final disposition ot both Real and Personal Piopeny
« Purchase Ordei and SubcontuiLt Closeou and all claims settled
• All lecords are in an /^nny-compliani foi mat and delivered to then final
destination
• Final close out of Prime Conti act
Attachment 10-Page 28
Figuie 10-1 TOCDF Closuie Plamung Schedule
1 OCDF
Closure Plan
June 2010
TOCDF
RCRA HWMU Closures
Within This Scope
_^ I
-I't^i HI
Attachment 10 Page 29
TOCDF
Closure Plan
June 2010
Figure 10-2 General Sequence of HWMU Decomrmssiomng
f HWMUs
General Area Container
Storage Tank Sump Incinerator Miscellaneous
Umt
MDB and Vicinity, September 2011 - September 2013
1 DFS Primary Room 132,161 DFS
2 ECR A 107 PMD-101,
Projo Cutter
3 ECRB 106 PMD-102
4 Munitions Processing
Bay
145,146, 147, 148,
149, 168, 175
MDM-101,
MDM-102,
MDM-103,
BDS-101,
BDS-102
5 Toxic Cubicle ACS-TANK-101,
ACS-TANK-102 151
6 Lower Buffer Storage 164,190
7 LIC 1 156, 180, 188 LIC 1
8 LIC 2 144,157 LIC 2
9 Explosive Containment
Vestibule ECV 108, 109, 110
10 Upper Munitions
Comdor UPMC
112, 113, 114, 115,
116, 117, 118, 169,
174,189
11 Lower Munitions
Corridor 179, 184
12 255 Airlocks 123,124
13 265 Airlocks 126,127
14 Toxic Maintenance
Area 135,154
15 Toxic Maintenance
Area Airlock
TMA
Airlock,
Decon
153
16 123 Airlocks 125,182
17 111 Airlocks 134,160
18 Spent Decon System
Room
SDS-TANK-101,
SDS-TANK-102,
SDS-TANK-103,
150
19 Metal Parts Furnace 187 MPF
20 Pollution Abatement
System Building Major Ancillary Equipment of MPF, LIC 1, LIC 2, and DFS Incinerators
21 Unpack Area 101, 102, 103, 104
22
Category C
Observation Corridors,
Laboratory, and
Monitoring Room
167,131, 133, 193,
173, 192, 136, 137,
138, 139, 140, 141,
142,130, 197
23 HVAC Structure Major Ancillary Equipment (Subpart CC) of ACS-101 ACS-102 and Cat A Sumps
24 Container Handling
Building CHB
25 S-2 Warehouse S-2
26
1
Bnne Surge Tank Farm
BRA-TANK-101,
BRA-TANK-102,
BRA-TANK-201,
BRA-TANK-202
Attachment 10- Page 30
TOCDF
Closure Plan
June 2010
HWMUs
1 General Area Container
Storage Tank Sump Incinerator Miscellaneous
Unit
Area 10 D VS/D VSSR, December 2012 - April 2013
1 Igloo
1632
DVS-101,
DVS-102,
DVSSR
Area 10 Autoclave, November 2013 - April 2014
1 Igloo
1633 Autoclave
1044 Scope of Ancillary Equipment
This section descnbes the minimum extent of what is considered "ancillary
equipment" for the purposes of this closure plan Hence, a HWMU will be defined
as the pnmaiy HWMU element (e g , wetted tank vessel, incinerator combustion
chambeis) in addition to all of its ancillarv equipment
10 4 4 Conventional fank Systems
Efluipment Constituting Subpart J Tan
Table 10-7
i. Systems (Brme Surge Tanks, ACS Tanks, SDS Tanks)
Portion Sub-Portion Boundaries/Extent
Pi unary
Containment Vessel Entire vessel including nozzles, lids manhole covers vent
pipe, conservation vent
Seconddi y
Containment
Flo(;i and
walls/btiPi'-/dikcs
Entire floor and wall'berin within the credueii le.iuired i
secondary containment volume caiciihii r Seconddi y
Containment Sump system
(BSTs Only)
Entire sump internal surface Seconddi y
Containment Sump system
(BSTs Only) All piping, fittings, flanges, valves, filters and pumps fiom
pump suction to vessel connection
Hazardcus Wasr?
C(m\eyante
Supply (Inflow)
All piping, fittings, flanges, valves, filters and pumps from
vessel connection io boundary with conterminous
downstream HWMU
Hazardcus Wasr?
C(m\eyante Discharge (Outflow)
Ail piping, fittings, flanges, ral/es, filteis and pumps / om
vessel connection to boundary with conterminous
downstream HV/MU or unload station
Hazardcus Wasr?
C(m\eyante
Recirculation All piping, fittings, flanges, valves, filters and pumps fiom
vessel discharge connection to vessel input connection
Subpart CC Air
Pollutant
Emissions System
(ACS Tanks Only)
Closed vent MDB HVAC ductmg/row MDB exit to connection to each
of nine carbon adsorption filter housings
Subpart CC Air
Pollutant
Emissions System
(ACS Tanks Only)
Emissions control
device
HVAC carbon adsorption filter housings from incoming
ducting connections to discharge ducting connections
10 4 4 2 Sump Systems With Secondary Containment
Table 10-8
Equiptnent Constituting Subpart J ICU Tank Systems Possessing a Steel Lmer
Portion Sub-Portion Boundaries/Extent
Primary
Containment Sump liner Entire steel liner
Attachment 10 Page 31
TOCDF
Closure Plan
June 2010
Secondary
Containment Conciete vault Entile concrete vault internal suiface
Hazardous Waste
Conveyance
Supply (Inflow) Floor surfaces that chaimel liquid toward the pnmary
containment Hazardous Waste
Conveyance Discharge (Outflow)
All pipmg, fittings, flanges, valves, filters and pumps from
sump pump suction to boundary with conterminous
downstream HWMU (e g , SDS Tank System)
Subpart CC An
Pollutant
Emissions System
(P999 Sumps
Only)
Closed vent MDB HVAC ducting/rom MDB exit to connection to each
of nine caibon adsoiption filtei housings
Subpart CC An
Pollutant
Emissions System
(P999 Sumps
Only)
Enussions contiol
device
HVAC caibon adsoqDtion filtei housings from incoming
ducting connections to discharge ducting connections
10 4 4 3 Sump Systems Without Secondary Containment
Table 10-9
Equipment Constituting Subpart J ICU Tank Systems with No Liner
Portion Sub-Portion Boundaries/Extent
Piimaiy
Containment Conciete vduU Eiitiie conciete vault intemal surface
Hazardous Waste
Convevance Dischaige (Outtlow)
All piping, fittings, flanges, valves, filters and pumps fnmi
sump pump suction to boundary with conterminous
downsfieam HWMU (e g ,SDS fank System)
Subpart CC Au
Pollutant
Emissions Sv<-lein
(P999 Sumps
Only)
(."losed vent MDB HVAC dueling funv MDB exit to conneLtun 'o e ich
ot nine caibon adsonplion filtei housings
Subpart CC Au
Pollutant
Emissions Sv<-lein
(P999 Sumps
Only)
Emissions conlioi
device
HVAC caibon adsoiption fillet huusiugs iium incoiiiaiig
ducting connections to dischaige ducting connections
10444 Container Stoiage Areas with Fixed Secondai7 Containment
Table 10-10
Ecfuipmeut Constituting Subpait I Container Storage Areas)
Poition Sub-Poition Boundaries/Extent
Piimaiy
Containment Containers All coniameis will have been lemoved liom tlie storage
unit prioi to closure
Secondary
Containment
Floor and
walls/benns/dikes
Entire flooi and wall/berm within the credited required
secondary contaiimient volume calculation
Subpart CC Air
Pollutant
Emissions System
Closed vent MDB HVAC ducting/rom MDB exit to connection to each
of nine carbon adsorption filter housings
Subpart CC Air
Pollutant
Emissions System Emissions control
device
HVAC carbon adsorption filter housings from incoming
ducting connections to discharge ducting connections
Attachment 10 - Page 32
TOCDF
Closure Plan
June 2010
10445 Container Storage Areas Without Fixed Secondary Containment
Table 10-11
Equipment Constituting Subpart I Container Storage Areas without Fixed Secondary
Containment)
Portion Sub-Portion Boundaries/Extent
Primary
Containment Containers All containers will have been removed from the storage
umt pnor to closure
Secondary
Containment
Containment
Pallets/Devices
AH secondary containment pallets and devices (e g ,
ONCs) will have been removed from the storage unit pi lor
to closure
10 4 4 6 Incinerator Systems
Table 10-12
Equipment Constituting Subpart O Incineiator
Portion Sub-Portion Boundaries/Extent
Combustion
Chambers
Pnmary Chamber
(LICs Only) Entire pnrnary chamber vessel from
combustion fan inlet to secondary chamber inlet
Combustion
Chambers
Pnmary Chamber (MPF Only) Entire pnmary chamber fiimace from
combustion chamber blowers to secondary chamber inlet
Combustion
Chambers
Pnmary Chamber
(DFS Only) Entire kiln to connection with secondary
chamber (includes BL AD) Combustion
Chambers
"secondary Chamber
(LICs On>v) Entire secv>ndary chaivber ves:.s.l ho n Hue
gas inlet lo flue gas outlet
Combustion
Chambers
"secondary Chamber (MPF Onh) Entire seconci-^i)' ^tianber fir -i priiprry'
chamber to PAS gas tram
Combustion
Chambers
"secondary Chamber
{DFS Only) Entire secondary chamber
Hazardous V/aste
Conveyance
Supply (Inflow)
(LICs Only) All piping, fittings flanges, valves filters and
pumps fiom ACS tanks to pnmary injection nozzles
Hazardous V/aste
Conveyance
Supply (Inflow) (MPF Only) Immediate feed conveyor Hazardous V/aste
Conveyance
Supply (Inflow)
(DFS Only) Feed chutes from slide gaies to kiln
Hazardous V/aste
Conveyance
Discharge (Outflow) (MPF Only) Immediate discharge conveyor
Hazardous V/aste
Conveyance
Discharge (Outflow) {DFS Only) Entiie heated discharge conveyor
Pollution
Abatement
System
PAS Flue Gas Tram
(LICs Only) Entire gas train from LIC secondaiy cJiamber
to common stack (includes quench tower, ventun scrubber,
scmbber, demisters and induction fans)
Pollution
Abatement
System
PAS Flue Gas Tram
(MPF Only) Entire gas tram from secondary chamber
exhaust to common stack (includes quench tower, ventun
scrubber, scmbber, demisters and induction fans) Pollution
Abatement
System
PAS Flue Gas Tram
(DFS Only) Entire gas train from secondary chamber
exhaust to common stack (cyclone, quench tower, ventun
scmbber, scmbber, denusters and induction fans)
Pollution
Abatement
System
PAS Liquid Tram
All piping, fittings, flanges, valves, filters and pumps
comprising the quench brine system and scmbber brine
system, including brine piping to the BST inlets and PAS
condensate lines to PAS-TANK-103
Attachment 10 - Page 33
TOCDF
Closure Plan
June 2010
10446 Miscellaneous Units
Table 10-13
Equipment Constituting Subpart X Miscellaneous Units
Portion Sub-Portion Boundaries/Extent
PMD
PMD Machine Entire machine (not including electrical and
hydiaulic support systems)
PMD Supply (Munition) Immediate conveyor PMD
Dischaige (Munition) Immediate conveyoi
PMD
Discharge (Eneigetics) None
MDM
MDM Machine Entire machine(not including electrical and
hydiaulic support systems)
MDM
Supply (Munition) Pick and Place Machine
MDM
Discharge (Munition) Pick and Place Machine
MDM Dischaige (Buistei Well) BWIC Assembly MDM
Dischaige (Agent)
All piping fittings, flanges, valves, filters and
pumps fiom agent pump suction to boundaiy
with conlenninous downstream HWMU
(ACS Tank System)
BDS
BDS Machine
Entire machine (not including electrical and
hydiaulic support systems) including the Heel
Transfer System and all its associated piping,
fittings, flanges valves, filters and pumps
BDS Supply (Bulk Cotilamei) Immediate conveyoi BDS Dischaige (Bulk Contamei) Immediate conveyoi BDS
Dischai ge (Agent)
.All piping fittings, llaiiges, "alves tU'CK ijul
pumps from agent pump suction to boundaiy
with conteiminous downstream HWMU
(ACS Tank System))
Piojo Cuttei Entiie Assembly Entne Projo Cuttei Machine
DVS
Muln-Corapartment Euclosui e
Entire stmcture including spent decon
collection and transfei system up to but not
including the ie< eivmg <90-day
accumulation tank DVS
Subpait CC An Pollutant
Emissions System
Entile duclwoik system fiom enclosuie
compartments, tlirough carbon filter system
and dischaige of the ID fans
DVSSR
Mult!-Compartment Enclosure
Entne stmcture including spent decon
collection and transfei system up to but not
including the leceiving <90-day accumulation
tank DVSSR
Subpart CC An Pollutant
Emissions System
Entire ductwoik system from enclosure
compartments, thiough carbon filter system
and discharge of the ID fans
Autoclave Pressure/Vacuum Vessel Entire vessel (not including electncal and
hydraulic support systems) Autoclave
Condensate Collection System
From condenser discharges up to but not
including the receiving <90-day accumulation
tank
Attachment 10 - Page 34
TOCDF
Closure Plan
June 2010
Subpart CC Air Pollutant
Emissions System
Entire ductwork system from vessel, through
ejector, condensers, carbon filter system and
discharge of the ID fans
10 5 CLOSURE WASTE MANAGEMENT
This section descnbes the methods which will be utilized during closure for
1) removing, transporting, treating, stonng or disposing of the hazardous waste
inventory,
2) detemunmg the agent-exposure status of newly-generated wastes and debris,
and
3) detemunmg the agent-exposure status of equipment, buildings and stmctures
that will be subject to general demolition
10 5 1 Wastes Generated During Closure
Hazardous waste and hazardous debris generated dunng closure decommissioning,
dismantling and decontamination activities that is not intended to be left in place for
demolition will be managed and disposed of as prescribed for that applicable waste
stream in accordance with R315-5-1 11 [40 CFR 262 11] for newly-generated waste
or the WAP Any remaining inventory of hazardous waste in the permitted storage
will be also be removed and managed in accordance with the WAP Equipment,
stmctures and building materials that are left in place for demolition will not be
declared as F999 hazardous waste/debris until demolition of the applicable building
area oi stiuctuie begins and the material has been containenzed for transportation
Table 10-14 summarizes the most common types of wastes that will be generated
while performing decommissioning, dismantling and decontamination activities, but
is not intended to be all inclusive Waste and debns generated dunng closure
decontamination and decommissioning, pnor to demohtion, will be imtially divided
into three major categories liquid agent-exposed, vapor agent-exposed and non
agent-exposed The methodology for the evaluation and determination of agent
exposure status is presented in Section 10 5 2
Although equipment, buildings and stmctures will not have been declared hazardous
debns prior to demolition provided the building and stmcture are intact, the status of
the equipment, buildings and stmctures will be determined using the same
methodology presented m Section 10 5 2
Newly-generated wastes and debns will be categorized based on their agent-
exposure status as determined in Section 10 5 2 and will be m accordance with
Section 10 5 3
Attachment 10 - Page 35
TOCDF
Closure Plan
June 2010
TABLE 10-14
TYPES OF WASTE GENERATED DURING CLOSURE DECONTAMINATION AND
DECOMMISSIONING (PRIOR TO DEMOLITION)
Spent decontaminant/nnsate
Residue sludges
Housekeeping waste
Spent hydraulic fluid
Electncal sensors not intended for reuse
Concrete chips and residue resulting from scabblmg, scarificafion, conng
Tools, contannnated or no longer useful (debns)
DPE suits (debns)
TAP gear not reusable (debns)
Paint and coating residue removed puisuant to concrete sampling
Conveyors, hydraulic components, cranes removed from building, contaminated or not intended for reuse
(debns)
HWMU piping, valves, fittings removed from building (debris)
Non-FIWMU piping, valves, fittings removed from building, contaminated or not intended for reuse
(debris)
Concrete chunks removed from building (debris)
Attachment 10 - Page 36
TOCDF
Closure Plan
June 2010
10 5 2 Evaluation and Determination of Agent-Exposure Status
Equipment and areas exposed to chemical agent will not automatically be considered
agent-contarmnated The decision making process to detenrune whether equipment
or waste (i e , "matenal") is agent-contaimnated is based on generator knowledge of
the process, operational history, contaimnation and exposure history, agent
monitoring and/or sampling and analysis results Wastes generated outside the
buildings that house HV.'TVIUs (e g miscellaneous support buildings) are unlikely to
be agent contaminated, however, these wastes will undergo the process descnbed m
this section The following steps will be used m the contamination assessment
1 Step 1, Determination of Liquid Agent or Agent Aerosol Exposut e - The
first step in the contamination assessment will be to determine whether the
material has historically been exposed to liquid agent or agent aerosol Any
material exposed to liquid agent or agent aerosol will be assumed to be
liquid agent exposed and will be managed in accordance with Section
10 5 3 1 Aieas that are known lo have been exposed to liquid agent or
agent aierosol include the TOX, TMA A LlC-1 Pnmary Room LIC-2
Pnmary Room, MPB, UMC UPA, ECR A, ECR -B and the ECV
Otheiwise, materials will be evaluated in Step 2
2 Step 2, Determination of Agent Vapor Exposure - In step two, materials
that have not been exposed to liquid agent or agent aerosol will be assessed
loi historical exposure to agent vapor Materials with adequate historical
monitoring records that have been historically e^fposed lo agent Viipors Its--
Jiari i 0 V SL A ,(| Le as..umed i" be cura-ntlv igenl-u'k or'ai-vnalc'' •!.''
-•ih be managed if accoidance 'villi Seriion 10 ^ ^ rvlaieci ils :. ax'-ei' e
igcm vapois^ 1 0 VSL will be evahiaiecl iii Step .1 '\ ^ualuair-'^
evaluation as descnbed m Step 4 will be required for maienals thai lack
adequate historical monitonng data
3 Step 3, Determination of Agent Vapor Exposure > I 0 VSL - In step tluee.
a determination of whether the material has been exposed lo agent vapors >
I 0 VSL must be made If the material has been exposed lo agent vapors >
I 0 VSL, and reliable and thorough historical roorntonng records are
•1 'ailable, theu the mate> ial will be considered vapor-agent -e-Mposed at.d v/ii|
1)L oianaged m accoidance vilh 10 5 3 2 11^ hov/ev^r the inatenal has bee^i
exposed to agent vapors ^ 1 0 IDLH and liquid agent or agent aerosol was
piesent, the item will be considered liquid agent-exposed and will be
managed in accordance with 10 5 3 1 Otherwise, the material will be
evaluated m Step 4 In the absence of reliable and thorough monitonng
records, occluded spaces with agent exposures > 1 0 IDLH will be presumed
liquid agent-contaminated, removed and treated as a newly-generated P999
hazardous debns/waste
4 Step 4, Conduct Qualitative Evaluation - In step four, materials for which
histoncal momtormg records do not exist will undergo a qualitative
evaluation The qualitative evaluation will be used to determine the
possibility of existing agent contamination on surfaces The assessment
considers the following
• Utilization of the equipment, unit, and/or area (i e , type of process,
operation, or nsk)
Attachment 10 Page 37
TOCDF
Closuie Plan
June 2010
e Histoncal documentation foi sirmlai opeiations
• Concentration of agent and duration of exposure
9 Confidence in the monitonng data and in past management practices
• Matenal of composition (porosity, density, etc)
9 Temperatuie of the environment
• Location of equipment oi item considenng the souice of the agent
vapoi and the an flow duection
Matenals detemnned to be potentially liquid agent-exposed through the
qualitative evaluation will be managed as liquid agent-exposed, otherwise,
they will be managed as agent-micontaminated All wastes will be managed
in accordance with then agent exposure detennmation, as specified in
Section 10 5 3
10 5 3 Decontamination & Decommissioning of Equipment, Buildings and Stiucmres
The strategy for decontamination and decommissioning of equipment, buildings and
stmctures is based pnmanly upon their agent-exposure status
10 5 3 1 Management of Aeiosol and Liquid Agent-Exposed Surfaces
One of the initial steps m the management of liquid agent-exposed ecpnpment
i^i'ildiiigs and sT'ictuie"; is to mndutt an occluded spare suivcv ! he occluded ^pacc
suivey \vill be osed ii oidei to identify ..-onfined aieas v;ithiii eouipmem, buildii'L,
suifaces and stiucluies thai weie exposed, or potentially exposed to liquid or
aeiosol agent and that have (or have had) the potential to contain liquid agent The
suivey will consider operational knowledge as well as information gathered through
site walkoveis aiid/oi facility drawing reviews If the survey reveals that occluded
spaces exist, steps such as equipment disassembly may be taken to reveal these
spaces foi decontamination
Upou completion of die occluded space suivey, a detennmation will tie made
\vhei.hei to ') decontaminaie liquid oi aeiosol agent-exposed items oi 2) declaim
Ihem as P999 hazaidous waste/debits and tieat Ihem m a pennitted tieatment Unit
These liquid or aerosol agent-exposed materials shall not remain in-place for general
demolition unless they are effectively decontaminated and demonstrated to meet the
< 1 0 VSL screening cntena
Materials that will remain m-place for geneial demolition may have been
decontaminated in the past (e g , duimg agent opeiations) or may be decontaminated
dunng closui e Dui mg demolition, the i esuhing newly-genei ated demolition debi is
shall have been air monitored (prior to commencement of demolition) as descnbed
in 10 4 1 m order to be disposed at a permitted TSDF as F999 hazardous
waste/debns
Areas withm the MDB that are known to have been exposed to liquid agent or agent
aerosol include the TOX, TMA-A, LIC-1 Primary Room, LIC-2 Pnmary Room,
MPB, UMC, ECR-A, ECR-B and the ECV At a minimum, these areas will be
Attachment 10 - Page 38
TOCDF
Closure Plan
June 2010
pressure washed oi sprayed with the appropnate decontamination solution identified
in 10 4 2 in order to decontanunate any residual liquid or aerosol agent
contanunation resulting from agent destmction operations
Concrete Considerafion - Liquid agent-exposed concrete that underlies an applied
coating (e g , Epoloid) is subject to augmented direct sampling and analysis to venfy
that the coating successfiilly performed its fimction as an impervious layer Only
with this verification of the coating (to include cracks) will surface decontamination
be deemed effective Otherwise, the agent-contaminated concrete shall be subject to
additional decontaimnation techmques as descnbed m section 10 4 12
10 5 3 2 Management of Vapor Agent-Exposed Surfaces
If It IS detenmned that vapor agent-exposed materials will likely be difficult to
decontaminate to the < 1 0 VSL cnterion, the materials may 1) be assumed to be
agent-contaminated, removed declared P999 hazardous waste/debns, treated in a
permitted treatment unit and disposed, or 2) undergo decontamination in accordance
with 10 4 2 along with additional air monitonng Additionally, vapor agent-exposed
matenals destined for thermal treatment as P999 hazardous waste/debns must meet
waste acceptance cntena of the treating TSDF Matenals that are assumed to be
vapor agent-exposed which will be remo\ed for treatment at TOCDF will be
declared as P999 hazardous waste and will be treated in a permitted treatment unit or
placed in TOCDF permitted storage until permit'ed-treatmenl is possible
FUiildiiigs, stiLicture" and equipment 'hat wereot;!/ exposed to vnpot agent wh'ch
can be demonstrated to meet the unventilated momtormg SL eenmg criteria ol ^ I ('
VSL do not lequire additional decontamination prior to demoluion and duiposal
10 5 3 3 Management of Non Agent-Exposed Surfaces
Prior lo final disposition of non agent-exposed equipment, buildings, and stmctures
(i e , not subject to P999 and F999 waste codes), a determination of whether the
material contains any other listed or charactenstic RCRA hazardous waste must be
made Those materials that do not contain any listed or charactenstic hazardous
waste may be removed and shipped offsite for reuse or recycling, ma / be ••smoveri
and shipped to a solid waste landfill (i e , Subtitle D Landfill), or may be leh m
place for fiiture demolition This will not include any TOCDF facilities where agent
was stored or treated, or housed any FIWMUs
10 5 4 Special Handling of Waste During Site-Wide Demolition Phase
1054 1 Demolition Waste Strategy
During in-process demolition and preparation-for-shipment activities (e g , size
reduction), the resultant debris shall be segregated to remove large and odd shaped
solid matenals such as steel stmcture and sheeting, equipment, rebar, concrete,
asphalt and the like ("hard materials") leaving materials such as wood, insulation
and the like in a separate pile ("soft matenals") Hard and soft materials will be
recombmed dunng container-loading as necessary to minimize void spaces within
the loaded container Should size reduction of the hard materials be unnecessary,
Attachment 10 Page 39
TOCDF
Closuie Plan
June 2010
they may be loaded for shipment diiectly without segiegation Relocation of debris
matenals within the site shall be permissible piovided dust control and wind-driven
material rmtigation measures are employed, as descnbed m 10 6 5 2
All newly-geneiated F999 hazaidous demolition waste will be containenzed and
accumulated onsite m accordance with the "geneiator" lequirements of 40 CFR
262 34 until such lime within 90 days that the containers aie transported to a
Subtitle C Hazaidous Waste Landfill
10 5 4 2 Dusl Suppiession and Mitigation of Wmd-dnven Matenals
Dust abatement dunng demolition and size-ieduction activities will be accomplished
thiough the use of water sprays sparingly applied so as to avoid mn-off out of the
HWMU-buildmg footpnnt Any lesulting mn-off of dust suppression water from
the debits pile to suiToundmg soil shall be lecoided Judgmental closure venfication
samples will be subsequently c ollected m aieas wheie dust suppiession watei nm-off
may have accumulated in oidei lo venfy lhat the activiiy dm not contaminate the
soil
The "soft materials" shall be dampened with water as necessary dunng the woik day
and off-shifl to pievent Ihem from becoming wmd-diiven insofar as practicable
Efforts shall be made dunng m process segiegation to shake soft matenals fiom
iiard matenals such thai haid matenals can undeigo size ledudion without
dampening
)''. ^ 1 Builf.lint; C':.'rmponeui and r'tiuiiameni 1 empoiJiv Liydowii
1 aige building components and equipmeni in need ol size leduction (icr til lulc loll
0) f Gontameis) may be placed upon
1) concrete slabs that aie themselves destined foi disposal undei TOCDF closuie,
and
2) conciete slabs, dsphah. 01 soil piovided the location is recoided and
"iibseq it^:\ addilicnal judgmenlal ' losiiii: venfication sampling is peifo'in"^!
.'.udei lo ••/piify ihai the acn-'ity dui not roniammale the soil
10 5 4 4 Timely Containei ization of Demolition Waste
Once demolition has commenced, placement of the lesulting debris into appioved
DOT containers (e g , roll-offs, end-dumps) shall be accomplished in as timely a
maimer as demolition and size reduction activities allow All soft materials
susceptible to becoming wmd-dnven in spite of dampening will be containenzed
pnor to the end-of-shift each day
10,5 4 5 Recycling/Reclamation of Metal Components in Lieu of Disposal
Attachment 10 Page 40
TOCDF
Closure Plan
June 2010
Metal equipment and building pieces that are recyclable by reclamation (i e ,
lecovery of the metal content) are exempted from RCRA Subtitle C hazardous waste
regulation per 40 CFR 261 6(a)(3)(ii) In order for the scrap metal to be recycled by
reclamation in lieu of disposed as hazardous debns, all of the following conditions
shall be met
10 5 4 5 1 The scrap metal shall have met the requirements of this closure plan for disposal
10 5 4 5 2 The perantlee shall evaluate the potential foi any agent hazaids to demolition,
transportation, and recycler personnel
10 5 4 5 3 The permittee shall be able to demonstiate a known market for the scrap metal
10 5 4 5 4 The pennittee shall possess a contract with a legitimate lecycler for leceipt of the
scrap metal including piovisions for assurance of reclamation
10 6 GROUND-WAFER MONITORING AND RUiN-ON & RUN-OFF CONTROL
There aie no disposal units associated with the TOCDF RCRA permit No giound-
watei contamination is expected as a lesult of the TOCDF operations Hence,
although ground-water monitoring may be pei formed by DCD as a result of DCD
operations, this closure plan does not address ground-water monitonng or any othei
long-temi monitoring associated with the DCD Permit and pieviously identified
SWMUs
Dunne the closuie penod, piecipitalion run-on and uin-olf contiol will continue to
be accomplished tluough the mamJtenance of sue grading and conianmient
structuies During the demolition phase, mn-off of demohtion peisonnel-applied
dust-suppression watei and precipitation out of HWMU buildings and stmctures will
be managed as descnbed in 10 5 4
10 7 CLOSURE PLAN COST ESTIMATE
A closuie cost estimate is not requited loi this RCP>A Pemut State and fedeial
govemjuents aie exempt {nrn the financial lequuemenis of •^0 CFR 264 Subpan H
m accoidance with 40 CFR 264 140(r)
10 8 POST CLOSURE
The closute plan is designed to accomplish a safe, risk-based clean-closure of the
site Furthei post-closure actions at the site are not anticipated Any post-closure
care resulting from activities not conducted pursuant to the TOCDF TSDF Permit
will be addressed under the DCD Enviromnental Restoration Program
10 9 CERTIFICATION OF CLOSURE
140 CFR 264 115 and UAC R315-8-71
Attachment 10 Page 41
TOCDF
Closure Plan
June 2010
Within 60 calendar days of completion of TOCDF final closiu-e, the Permittee shall
submit to the Executive Secretary, by registered mail, a certification that the TOCDF
facility has been closed in accordance with the specifications in this closure plan
The certification shall be signed by the Permittee and by an independent registered
professional engineer Documentation supporting the mdependent registered
professional engineer's certification shall be furnished to the Execufive Secretary
upon request
10 10 CORRECTIVE ACTION FOR SWMUS
140 CFR 264 1011
Other then the DCD solid waste management units (SWMUs) associated with
CAMDS, discussed in the CAMDS Closure Plan Attachment 25, no SWMUs have
been identified at the TOCDF site All SWMUs within the DCD boundanes and
conective actions associated with them are incorporated in the DCD RCRA TSDF
Permit Ten (10) specific spill sites associated with TOCDF operations have been
identified and are listed in Module VII These spill sites will be verified clean-
closed in accordance with this closure plan so that no post-closure conective action
will be necessary
Attachment 10 - Page 42
REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
us ARMY CHEMICAL MATERIALS AGENCY
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UTAH 84071
JUN 3 0 2010
•^^'^ 3 0 20/0
Tooele Chemical Agent Disposal Facility PM0483-10
SUBJECT Class 3 Modification to the TOCDF Resource Conservation and Recovery Act
(RCRA) Permit, TOCDF-ATT 10-03-1 111, TOCDF RCRA Final Closure Plan Revision, EPA
ID UT 5210090002
Mr Scott Anderson, Director
Utah Department of Environmental Quahty
Division of Solid and Hazardous Waste
P O Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
Dear Mr Anderson
JUN 3 0 2010
UlAH DIVblOlM ur
SOLID & HAZARDOUS WASTF
In accordance with the TOCDF RCRA Permit requirement IIK 1, this letter is submitted to
the State of Utah Division of Solid and Hazardous Waste as the Class 3 Modification to the
TOCDF RCRA Permit, TOCDF-ATT 10-03-1 111, TOCDF RCRA Final Closure Plan Revision
If you have any questions regarding this issue, please contact Ms Sheila R Vance at (435)
833-7577 or Mr Trace Salmon at [phone]
Sincerely,
Xd^phR Majestic
G&G Defense Materials, Inc
•CERTIFICATION STATEMENT
Thaddeus
TOCDF S Project Manager
•CERTIFICATION STATEMENT
Enclosure
I CERTIFY UNDER PENALTY OF LAW THAT THIS DOCUMENT AND ALL ATTACHMENTS WERE PREPARED UNDER MY DIRECTION OR SUPERVISION IN
ACCORDANCE WITH A SYSTEM DESIGNED TO ASSURE THAT QUALIFIED PERSONNEL PROPERLY GATHER AND EVALUATE THE INFORMATION SUBMITTED
BASED ON MY INQUIRY OF THE PERSON OR PERSONS WHO MANAGE THE SYSTEM OR THOSE PERSONS DIRECTLY RESPONSIBLE FOR GATHERING THE
INFORMATION THE INFORMATION SUBMITTED IS TO THE BEST OF MY KNOWLEDGE AND BELIEF TRUE ACCURATE AND COMPLETE I AM AWARE THAT
THERE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION INCLUDING THE POSSIBILITY OF FINE AND IMPRISONMENT FOR KNOWING
VIOLATIONS