DSHW-2024-007862

Tooele Chemical Agent Disposal Facil$mruD DELIVERED(rocDF)
,DEC f 32010
UTAH DIVISION OF
$0un & HAzARDous WASTE
Response to
DSHW COMMENTS CONCERNING MODIFICATION REQUEST
TOCDF-AI0-03-1092
Titted.,Install and operate Area 10 Liquid Incinerator'
DSHW Tracking Number: 2010.00067
lf REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY CHEMICALS MATER}AL AGENCY
TOOELE CHEMICAL AGENT D]SPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UT 84071
DEC 1 3 20t0
F{Aruffi [}ffiLNVffiFqEM
ffiHC $ S ?trItr
UTAH DIVI.$ION OF
SOLID & HAZART}OUS WASTE
Jo lo. 07wfr \
Tooele Chemical Agent Disposal Facility PM0902-10
Mr. Scott Anderson
Director, Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
P.O. Box 144880
195 North 1950 West
Salt Lake City, Utah 84114-4880
SUBJECT: Response to Division of Solid andHazardous Waste (DSHW) Comments
Conceming Tooele Chemical Agent Disposal Facility (TOCDF) Class 3 Permit Modification
Request Titled "Install and Operate Area 10 Liquid Incinerator", TOCDF-AI0-03-1092 DSHW
Tracking Number: 2010.00067, EPA ID: UT5210090002
Dear Mr. Anderson:
Please find enclosed the response to comments received from DSHW concerning Permit
Modification Request TOCDF-AI0-03-1092, which is titled "Install and Operate Area 10 Liquid
Incinerator". Also enclosed is a compact disk containing electronic files of the affected TOCDF
Resource Conservation Recovery Act (RCRA) Permit change pages incorporating DSHW
comments, where applicable, revised ATLIC performance test plans, revised drawings, and
enclosures which provide supporting information. A hard copy of the files included on the
compact disk is also provided.
Note the following:
o The ATLIC exhaust stack Near Real Time (NRT) agent monitor Automatic Waste
Feed Cut-Off (AWFCO) limit is revised from 0.5 and 0.4 Source Emission Limit
(SEL) for Agent GA and Lewisite, respectively to 0.2 SEL for each agent. The SEL
value for Lewisite remains at 0.03 milligrams per cubic meter (0.03 mg/m3).
o The ATLIC Surrogate Trial Burn (STB) Plan is revised to include the spiking of
the Spent Decon Solutions (SDS) with an organic compound (monochlorobenzene),
and add the collection of exhaust gas samples for semi-volatile organic compounds.
o Module IV and Attachment 2 are revised to increase the agent concentration limit
for SDS to be processed in the Secondary Combustion Chamber of the ATLIC from '
20 and 200 parts per billion for agent GA and Lewisite, respectively to 500 parts per
million (ppm) for each agent. The 500 ppm agent limit for spent decon feed to the
ATLIC Secondary Combustion Chamber is conservative and is proposed based on the
intended organic spiking rate to the Secondary Combustion Chamber (SCC) during
the ATLIC STB. TOCDF will spike monochlorobenzene to the ATLIC SCC during
r"'"
JJ
Printed "^ @
Recycred Paper
a
-2-
the STB at a rate that will result in a Spent Decon organic content of approximately
8,000 ppm (0.8 weight percent). The selected organic spike is more difficult to
incinerate than Agent GA or Lewisite.
o The SDS feed rate specified in the test plans is increased to account for the need
to spike the SDS with Phosphoric Acid to replicate during the STB the particulate
loading that will be experienced during the process of Agent GA.
o The ATLIC Agent Monitoring Plan is revised to use a Depot Area Air Monitoring
System as the confirmation method for Lewisite NRT monitor alarms rather than
second NRT monitor that is configured with a different analytical column.
.
o The ATLIC AWFCO system test frequency is revised from once every 30 days
and proposed to as once every 14 days when the ATLIC is feeding hazardous waste
for a period longer than 14 days. The basis for this proposal is provided in the
response to DSHW comment # 4.
o Module VI is revised to require TOCDF to conduct a Lewisite Mini-Burn which
will allow for the continued processing of Lewisite upon completion of the Lewisite
CPT. Data from this test will provide assurance that the ATLIC post-CPT Lewisite
processing complies with the TOCDF RCRA hazardous waste incinerator
performance standards
TOCDF intends to submit a revised Laboratory Quality Control Plan (LQCP) and revised
Laboratory Operating Procedures applicable to Agent GA and Lewisite analyses and monitoring
under separate cover. TOCDF is aware of the desire of the DSHW to include the revised LQCP
in the documents that will be evaluated during the second public comment period. A revised
LQCP is being prepared and will be submitted to the DSHW shortly after January l,20ll.
TOCDF respectfully requests a meeting to begin discussing any issues DSHW may have
with the enclosed comment responses on or before December 22,2010, so that we may begin to
work on those issues that appear to be the most concerning as soon as possible.
The points of coniact in this matter are Ms. Sheila R. Vance at [phone] or Mr. Trace
Salmon at [phone].
Sincerely,
G-k,try#
i&e
tCI
Gary ilV. McCloSkey
EG&S Defense Materi4ls,Inc.
*CERTIFICATION STATEMENT
Thaddeus A. Ryb a, lr.
TOCDF Site Project Manager
*C ERTIFICATION STATEMENT
Enclosure
* I cERTtFy uNDER pENALTy oF LAw ru,lt rgrs ootuMENT AND ALL ATTACHMENTS wERE pREPARED UNDER My DtREcrroN oR supERvIsIoN tN
ACCORDANCE WITII 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 DIRDCTLY RESPONSIBLE FOR GATHERING THE
INFORJ|'IATION. THE INFORMATION SUBMITTED lS. TO THE BEST OF MY KNOWLEDGE AND BELIEF; TRUE, ACCURATE AND COMPLETE. I AM AWAR.E TttAT
TEENE ARE SIGNIFICANT PENALTIES FOR SUBMITTING FALSE INFORMATION, INCLUDING THE FOSSIBILITY OT FINE AND IMPRISONMENT FOR KNOWING
vlot-ATloNs.
HAND DELIVHHED
,0 l0 ,0 3il1
, DEC f'3 ACIl0
TOCDF Response to UTAH DlVlSloN 0F
DSHw ATLIC for GA and Lewisite Modification Cosrgl-H.qttzARDous wAsTE
Main Body of Permit Modification (General)
1. Please explain the management of spent nitric acid being shipped off-site for disposal
versus the rinse water treated in the incinerator.
Spent nitric acid is generated from rinsing out lewisite (L) Ton Container (TCs). After an
L TC has been drained of its agent fill, it is filled more than halfway with a three (3) molar
solution of nitric acid through the fill and drain valves. The lines are then detached from
the TC valves, and the TC is rotated for at least one hour. The acid is added to the TC to
both destroy any agent remaining in the TC and to dissolve the un-drainable solid heel that
was identified during the GA and L sampling effort.
After the TC is rotated for the required period of time (i.e., approximately one hour), the
drain line is attached to the TC and the spent nitric acid is transferred to NSF-Tank-8514
or LCS-Tank-8516 that are located in the Area 10 Liquid Incinerator (ATLIC) Igloo Toxic
Area.
A sample of the spent nitric acid is taken at the tank, which is screened for agent
concentration. If the L concentration in the spent nitric acid is greater than the Worker
Concentration Limit (WCL), an eight (8) molar solution of nitric acid is added to the tank
to destroy the agent. When the agent concentration in the spent acid is less than the WCL,
the spent acid is transferred to 90-day Pollution Abatement System (PAS)-Tank-8569,
which is located in the Environmental Enclosure, the same enclosure that houses the
ATLIC PAS. Note the tank's designation is assigned based on it physical location, it is not
associated with the ATLIC PAS.
The samples collected from PAS-Tank-8569 are analyzed for pH, total dissolved and total
suspended solids, and metals. The parameters of analysis are selected to support the
planned method of disposal of this waste stream, which is deep well injection.
Deep well injection is selected as the method of disposal because the spent nitric acid
waste stream will have high concentrations of both arsenic and mercury. The mercury
concentrations associated with this waste stream most likely will exceed the Land Disposal
Restriction (LDR) limits for high mercury (HMERC) wastes. There are no metal
concentration limits for wastes that are disposed of by deep well injection. The pH of this
waste stream is maintained intentionally low to minimize suspended solids.
2. Please explain the mechanism to pump liquids out of the glove boxes.
Liquids are added to and rernoved from TCs that are placed in the glove boxes through the
use of two multifunction 4-way and 5-way valves. A 4-way valve in each glove box, with
three lines coming into it and one line going out of it, is set to direct decontaminating
Page 1 of 107
solution (decon), process water, or nitrogen to the TC (the single line coming out of the 4-
way valve is attached to the higher of the two vertically-positioned TC f -inch valves).
A 5-way valve in each glove box, with one line coming into it and four lines going out of
it, is set to transfer GA to the ATLIC Primary Combustion Chamber (PCC), spent decon
to the Spent Decon Tank, lewisite to the Agent Holding Tank, or spent nitric acid to the
Spent Nitric Acid Holding Tanks. Liquids are transferred from the TCs in a line dedicated
to the specific liquid using a pump that is also dedicated to that type of liquid. See
drawing EG-22-D-8812.
3. Please provide narrative explaining the mechanism for injecting the carbon into the
exhaust gas stream.
The Pulverized Activated Carbon (PAC) system is a fully-automated system capable of
injecting carbon into the inlet of a baghouse. When the PAC system is in automatic
operation mode, carbon is injected into it, with the assistance of a blower, and.metered
constantly by adjusting the speed of a screw feeder, based on weight loss and the desired
injection weight. Carbon is hansferred from a bulk bag when the level in the screw feeder
hopper is below a low weight setpoint. A rotary valve feeds the screw feeder hopper.
Rotary valve operation stops when the screw feeder high weight setpoint is reached or
when the level probe is maintained for a set amount of time. The cycle continues until the
system is stopped.
A tapered bulk bag of PAC is placed (tapered end down) into a hopper using a hoist. The
tapered neck of the bag is positioned in the tapered bottom of the hopper. A bulk-bag
massager can be automatically pulsed to maintain the free flow of carbon from the bag. A
rotary valve directs this flow of carbon to a second smaller hopper that is used to measure
the feed rate of the carbon to the ATLIC PAS. Carbon in the second, smaller hopper is
metered into the process by adjusting the speed of a screw feeder. The screw feeder
transfers the carbon to a funnel. The verticallytapered exit of the funnel is joined to a
horizontally-oriented pipe through which air flows. The flowing air draws the carbon from
the funnel by venturi effect. The end of the pipe adjoins the ATLIC PAS. The PAC is' introduced into the PAS upstream of the Baghouse.
4.The AWFCO system associated with the ATLIC will need
every seven days.
to be manually tested
TOCDF initially proposed a 30-day test frequency for the ATLIC AWFCO System, which
is the longest frequency allowed by the regulations. Rather than this frequency TOCDF
request the DSHW to consider the following which is provided to justify a l4-day
AWFCO Systern testing frequency.
Groups of Operating Parameter Limits (OPLs) are specified for each component in a
Pollution Abatement System (PAS) train based on the equipment type. The ATLIC PAS
train includes multiple wet scrubbers, a venturi scrubber with a dedicated sump, a carbon
injection system, a baghouse, and a fixed bed carbon filter. The number of PAS train
components incorporated into the ATLIC PAS design res'ult in a larger AWFCO System
than that associated with any of the TOCDF incinerators.
Page 2 of 107
o
Because the limited amount of waste to be processed by the ATLIC and the resulting short
duration of ATLIC hazardous waste operations, the ATLIC AWFCO Systern will be tested
manually. The short operational period of the ATLIC does not justify the development of
automated AWFCO System testing software. Each test of the ATLIC AWFCO System is
therefore estimated to take about 8 hours. When including the time to organize and
coordinate the testing, each AWFCO test will take l2-hour, or one shift, during which
waste feed to the ATLIC will be suspended.
TOCDF is proposing an ATLIC AWFCO System test frequency of every 14 days, or
before hazardous waste feed is initiated for times when the ATLIC is idle (i.e., not
processing waste) for longer than 14 days.
The ATLIC will be idle for extended periods of time. The ATLIC is idled (i.e., no
hazardous waste processing) after completion of the Surrogate Trial Bum (STB) up until
the STB Preliminary Data is approved by the Executive Secretary. The GA Campaign is
expected to take 10 days.
The ATLIC is then idled from the end of the GA Campaign to the start of the shakedown
period associated with the Lewisite Comprehensive Performance Test (CPT), a period of
53 day per the current schedule. During this time the Lewisite Operation Readiness
Review (ORR) will be conducted.
The AWFCO system must be tested prior to the initiation of hazardous waste and after any
changes are made to the system. Considering the changes to the system needed to
accommodate "half feed rate" and AWFCO System operational status changes during time
when stack sampling is being conducted (i.e., during the performance testing when stack
sampling is being conducted), the proposed testing frequency would result in testing of the
system 6 times.
Considering the number of tests, the time required to conduct each test, and the estimaied
total ATLIC hazardous waste operating time (i.e., the time the ATLICis actually buming
hazardous waste, the proposed frequency of 14-day or prior to the beginning of hazardous
waste feed for idle period lasting longer than l4-days, the percentage of time required to
test the ATLIC AWFCO System would be similar to that for a "long term" hazardous
waste incineration system that was required to perform the testing every seven days ( 14
percent for the ATLIC as compared to once every seven day, or ll7 * 100: 14 percent).
Table 1 shows the estimated number of ATLIC hazardous waste operational hours. Table
2 shows the number of AWFCO test events based on the proposed frequency and
compares the percentage of time required to perform the testing for various tests
frequencies as compared to the total hours of ATLIC hazardous waste operations.
Page 3 of 107
Tahle 1. Tutal ATLIfl Hazariluns lYarte Feerl Opsratiun Tirne
ffA f,;unpaign
TC Seriel Nurrher Pounils ofAeent Prrocessiilg Ef,te ltrours ofPrucessing
GA TC D.2523 1325 1J0 lbs.ftu.9.5
GA TC D-3J248 1488 150 lb s./hr.11.0
GA TC D.29813 653 150 lb s.lhr.J.J
GA TC D.51365 636 150 lb s./tu.5.5
Each TC generate s 460 gallons
SDS (Approxitnate
3,83J lbs. of SDS
Each TC genere ates
345 gallons of SDS
( approximately 2,876lbs. of SD$
Each TC genere ates
345 gallons of SDS
( approximately 2,876lbs. of SD$
Totel hnur:s ofPncessing Agent l,s$,isite >1369
Totel ltrours ofPrueessilg SDS @ 450 Ih SDS/IIr ]639
TranrperEncy TC Prucocessing
Totel Hours ofPrucessng SDS @ 450 Ih SDS/Hr F | 63.9
Total llours Agent & SDS Prucessing ts 332.,2
Euiuelent Days ofprucessing @24llourslDey >14
Estiileteil llour oftlarardnus lUaste Operation tu I
Sr4port Surrrogate Trial Eurn enil Shakedrri'nl f fC
Perioil F
Total AlfrIC llnxerfuus lUastc Oueratins tlours ts I 4PB
Total llnurs ofPrucessing Asent GA ]
Totrl llnuns ofPmcessng SI]S @ 450 Ih SI]S/Hr >
TC Serial Nrunber
D-79705. & D-79711 150 th s./tn.
D-49?21. D-79697- & D-79701
150 lb s./tu.
150 lb s./tr.
150 lbs.flu.
Page 4 of 107
Table 2. Percentage of AWFCO System Testing Time Based on Total ATLIC Hazardous Waste Feed Operation Time
Event Estimated Date Purpose
S-Jul-11 AWFCO Test Test beforehazardous waste feed
Start Surrogate Shakedown 6-Jul-l I
Start Surrogate Trial Burn 13-Jul-11 AWFCOs Waived
for stack testingEnd Surrogate Trial Burn 18-Jul-l I
l2-Aug- l 1 AWFCO Test
Revise Waste Feed Rate to ll2 STB Demo'ed Rate, PCC
and SCC Low-Temp Limit and Exhaust Gas Max-Flow
Rate Limit to STB Demo'ed Rate and test AWFCOs to
ensure Jumper for STB is removed
Start GA Operations 13-Aue-l I
End GA Operations 23-Aue-11
l4-Oct-l I AWFCO Test
Revise Waste Feed Rate to LCPT Rate, Test all
AWFCOs nrior to resumins hazardous waste feed
Start Lewisite Shakedown l5-Oct-l I
27 -Oct-ll AWFCO Test Everv 14-dav AWFCO test
Start Lewisite CPT 28-Oct-11 AWFCOs Waived
for stack testing
End Lewisite CPT 3l -Oct-l I
l-Nov-l I AWFCO Test
Revise Waste Feed Rate to ll2 LCPT Mini-Burn
Demo'ed Rate, PCC and SCC Low-Temp Limit and
Exhaust Gas Max-Flow Rate Limit to STB Demo'ed
Rate and test AWFCO to ensure Jumper for LCPT is
removed
Start Post Test Lewisite Ooerations 2-Nov-I
End Lewisite Ooerations 3-Nov-I
4-Nov-I AWFCO Test Everv l4-dav AWFCO test
Start Transparency TC Processing 5-Nov-1
End Transparency TC Processing 9-Nov-I
ATLIC Hazardous Waste Operational Duratio 9-Nov-I
5-Jul-1
Days Spanning ATLIC Hazardous Waste
Operator t3i
No. AWFCO Tests @, everv 7-dav interval 20
No. AWFCO Tests @ everv 14-dav interval l0
No. AWFCO Tests @ l4-day interval or before
Haz. Waste Feed if idle longer than l4-days 6
Hours to perform AWFCO Tests @
everv 7-dav interval*23s 47"h
Percentage of AWFCO Testing
{ Time @ 498 Hqgrs ATLIC
Hazardous Waste Operations
Hours to perform AWFCO Tests @
every l4-dav interval*n7 240h
Hours to AWFCO Tests @ l4-day interval or
before Haz. Waste Feed il
idle loneer than l4-davs*
72 140
*AWFCO Testing will take approximately 8 hour l2-hr shift
There was no description of the secondary containment systems with calculations of
their capacities. The only mention made of this issue was that there was insufficient
capacity requiring installation of a "major spill collection tank" (see page 11 of the
Class 3 Modification request). It is unclear how this would fulfiIl the secondary
containment requirements as it is not one of those specified in 40 CFR S264.193(d).
It appears that it would serve the purpose of removiiig the leaked or spitted material
collected in a secondary containment system as described in 40 CFR $264.196. The
purpose of the secondary containment system is to hold the spilled or leaked material
until it can be collected and managed. Tank 8534 would not serve this purpose, as it
would not be collecting this material until after the leak was detected, hoses
connected, and the material was pumped to the tank. It is also confusing since
Page 5 of 107
6.
516.4.9.4 of Attachment 16 makes it appear that there is sufficient secondary
containment in the bermed area.
The ATLIC TOX secondary containment calculations demonstrating that the design is in
compliance with the applicable regulatory requirements can be found in Enclosure A.
Drawings EC,-22-G-8216,F,C'-22-G-8217, EG-22-G-8227, aind EG-22-C,-8228 show
various sumps. Please show on a floor plan where these sumps are located. Also,
please describe which secondary containment system each are associated.
A diagram showing the locations of the various sumps located in the ATLIC facility, and a
table listing the area that each sump supports, can be found in Enclosure A.
Table I Page 4 - The acetic acid was not discussed in the surrogate trial burn plan,
(Section 1.3.1) but NaOH was for GA. Please explain
The reference to acetic acid in Table 1 is an elror, a remnant from an early draft version of
the permit modification request when TOCDF was considering an acetic acid rinse for the
lewisite TCs. Bench scale testing using acetic acid to remove lewisite from metal coupons
showed that it did not dissolve the lewisite, but instead created slime that coated the metal
coupon. Acetic acid will neither be used in the processing of the lewisite TCs nor fed to
the ATLIC,.
Page 5 & 6 - Sampling in accordance with an approved sampling plan (2.2.1.3.3) must
be performed for both liquid and sludge materials. Please provide a sampling plan
for further sampling/characterization verification.
The TOCDF requests that DSHW reconsider the need for additional sampling and analysis
of the agent in the GA and lewisite TCs based on the following paragraphs from
Attachment 2 of the TOCDF RCRA Permit, which specify how the analysis of chemical
agent occurred during past TOCDF Agent Campaigns.
7.
8.
2.2.r.3.2.
2.2. 1 .3.3.
The Permittee shall analyze the chemical agent prior to each agent
campaign from bulk containers. Agent samples shall be collected from a
representative number of bulk containers agreed upon with the DSHW.
The containers shall be sampled and analyzed following an approved
sampling and analysis plan.
At the beginning of each munition or bulk container campaign, agent
samples shall be collected using a Sampling scheme that is approved by
the Executive Secret ary. The samples shall be analyzed as specified in
Table 2-0.
These conditions were added to the TOCDF RCRA Permit partway through the first
TOCDF agent campaign, which was for Agent GB; during the early stages of that
campaign, it became evident that there was insufficient existing analytical information
about the agents to establish incinerator metal feed rates through a single demonstration,
Page 6 of 107
which ideally occurs during the Agent Trial Bum (ATB). Two additional performance
tests were required during the Agent GB Campaign to increase incinerator metal feed rates
as metal analytical data for Agent GB became available. The above quoted paragraphs
were added to Attachment 2 of the TOCDF RCRA Permit to prevent having to perform
multiple metal feed rate demonstrations throughout an agent campaign.
Paragraph 2.2.1.3.2 discusses how "a representative number of bulk containers agreed
upon by DSHW" will be sampled. This is an important discussion point for an agent
stockpile comprised of thousands of TCs. For the GA and lewisite stockpiles, TOCDF
sampled every TC since there are only four GA and ten lewisite TCs.
Paragraph 2.2.1.3.3 specifies the parameters of analysis that, for the VX and Mustard
Campaigns, were Health Risk Assessment (HRA) metals and organic content, which
included agent purity. The metals analysis was performed on both liquid and solid phases
of the TCs if solids were present. For the GA TCs, a liquid sample was collected from
each TC and analyzed for organic content with the constituent of concern being the
monochlorobenzene; this compound is more difficult to incinerate than Agent GA. Each
sample was also analyzed for HRA metals using the same methods approved by DSHW
for agent metals analyses conducted at TOCDF.
Liquid and solid samples were collected from each lewisite TC. The liquid samples were
analyzed for organic content and the Ll concentration was quantified. TheLZ and L3
concentrations were estimated because calibration standards for these compounds are
unavailable. Both liquid and solid samples were analyzed for HRA metals.
The sampling/analysis efforts for the GA and L TCs resulted in generation of the same
data that would have been collected from an Executive-Secretary-approved
sampling/analysis plan. Al1TCs were sampled, samples of both solid and liquid fractions
were collected, and the parameters of analysis for the GA and L TCs were the same as
those in past approved plans (i.e., organics to include agent purity and HRA metals).
The GA and L TC sampling/analysis efforts provided TOCDF sufficient data to design and
develop the Surrogate Trial Burn (STB) and Lewisite Comprehensive Performance Test
(CPT) Plans to ensure that worst case demonstrations are made during the testing and to
avoid the past problems that were experienced during the TOCDF Agent GB Campaign.
Therefore, the existing GA and L TC analytical data fulfill the intent of the requirement
found in the above-referenced paragraphs from Attachment 2 of the TOCDF RCRA
Permit,
Additionally, the permit modification request made clear the proposal not to perform any
additional organic analyses of the GA and lewisite agent, or any additional metal analyses
of the Agent GA. Therefore, the public was provided with an opportunity to comment on
this proposal during the permitting process.
Note TOCDF is evaluating the possibility of collecting a GA sample for metals analysis. If
collected this sample(s) would be used to verify the results.presented in the GA and L Ton
Page 7 of 107
Container Sample Analysis Report which was submitted as Attachment 3 to the initial
ATLIC permit modifi cation requests.
9. Page 6 - Please provide justification why GA agent should be directly fed to the LIC
instead of a tank (see comment above concerning additional samplinglanalytical).
The Agent GA was proposed to be fed from the TCs directly to the LIC to minimize the
amount of equipment that would require decontamination during the agent campaign
change over from GA to lewisite. The transfer of GA to Agent Holding Tank LCS-Tank-
851l, and from this tank to the ATLIC Primary Combustion Chamber (PCC), would incur
having to decontaminate the agent transfer line between the glove box and the holding
tank, the holding tank, and the transfer line from the holding tank to the ATLIC PCC
before the Lewisite Campaign could begin. The spent decon solutions that were generated
from this decontamination process would also have to be heated in the ATLIC Secondary
Combustion Chamber (SCC) before the Lewisite Campaign could begin.
Furthermore, TOCDF plans to transfer the lewisite from the TC to the agent holding tank
before feeding it to the ATLIC to allow blending the lewisite from different TCs to create
an agent waste feed that has more consistent metal concentrations (i.e., the contents of the
Lewisite TCs with high metals concentrations will be mixed with the contents of TCs with
lower metals concentrations to create a feed with average metals concentrations). The
individual metals analytical results for the GA TCs show a much narrower range among
TCs; therefore, mixing the GA to create a more consistent waste feed in regards to metal
content is not required.
10. Page 6 - Please explain the mechanism for mixing the agent tank.
A recirculation line is incorporated into the design of the permitted lewisite, spent decon,
and spent nitric acid hazardous waste storage and treatment tanks. The drawings that were
submitted with the permit modification request show these lines. The liquid wastes are
drawn from the bottom of the tank and reenter the tank at approximately the vertical
midpoint. An eductor is located inside the tank on the end of the line. The eductor is
submerged in the liquid, and the flow of liquid through the eductor causes the surrounding
liquid to be pulled into and through the eductor, which multiplies the mixing efficiency.
11. Page 7 - All transparency tons will need to be treated the same and be processed
through an approved decontamination procedure of nitric acid rinses (3x) followed
by water rinse and it must be verified that all LlrLz and L3 are less than the waste
control limit. Spent decon must be analyzed for agent, metals, and organic content.
The agent content must be less than 20 ppb for GA and 200 ppb for Lewisite and the
demonstrated organic content. Metals must have been demonstrated in the SCC
prior to feeding to that chamber.
The TOCDF concurs with the request to process all Transparency TCs in a similar manner.
The original version of this permit modification request proposed to acid rinse only those
Transparency TCs for which there were head space monitoring results showing the
presence of lewisite. All other Transparency TCs would only undergo a water rinse.
o
Page 8 of 107
The TOCDF has revised the proposed Module VII Permit Conditions associated with
Transparency TC treatment to require each Transparency TC to undergo an acid rinse
followed by three water rinses. A single acid rinse is determined to be sufEcient for
Transparency TCs. The interior of each TC was inspected with a borescope. No solid
heels were found in any of the TCs. Additionally, afterbeing rinsed out, each TC will be
cut in half and monitored for agent before being transferred off-site as F999 hazardous
waste.
Concerning the need to analyze lewisite and lewisite-derived wastes for Ll, L2, and
. Analytical calibration standards are not available forL2 and L3. The presence of these
isomers of lewisite (Ll) can be determined, but they cannot be quantified because of
the lack of applicable calibration standards.
o The presence of L2 and L3 will be noted on the analytical reporting sheet and will be
reported in a similar manner as are the Tentatively Identified Compounds (TICs).
o All agent-derived wastes are required to be managed as F999 listed hazardous wastes.
The application of this waste code ensures that these wastes will be managed as listed
hazardous wastes.
Conceming the need to spike the ATLIC Secondary Combustion Chamber (SCC) waste
feed during the Surrogate Trial Bum (STB) with organics and metals:
o The TOCDF concurs with the need to spike STB SCC waste feed with an organic
compound. The STB Plan has been revised accordingly.
o The TOCDF does not concur with the need to spike the SCC waste feed with metals
since the metals spiked into the Primary Combustion Chamber (PCC) will travel
through the SCC. The SCC does not remove metals from the exhaust gas. The metal
feed rates demonshated during the STB, as derived from the metal spikes added to the
PCC, will be regulated as the total metal fed to the PCC and SCC during ATLIC
operations.
Note that spent decon generated from the actual rinsing of lewisite TCs will be fed during
the Lewisite Comprehensive Performance Test (CPT).
12.Page 8 - The temperature of scrubber solution will need to be monitored as a waste
feed cutoff (< 185" F). Waste collected in sumps must be analyzed for waste
characterization. Each PAS system needs temperature cutoffs. Where is the sump
sludge anticipated to be managed/treated?
As required by the current TOCDF RCRA Permit, each incinerators Automatic Waste
Feed Cutoff (AWFCO) system includes an AWFCO for High Quench Towdr Exhaust Gas
Temperature. This AWFCO was specified in the RCRA Permit'before the promulgation
of the Hazardous Waste Combustor Maximum Achievable Control Technology (HWC
MACT) regulations. These regulations specify the Operating Parameters (OPs) that are
Page 9 of 107
associated with the control of each emission standard, and the sample emission standards
are listed as Performance Standards in the RCRA Permit.
The HWC MACT regulations do not require that a High Quench Tower Exhaust Gas
Temperature Operating Parameter Limit be established to ensure compliance with the
ernission standards because this OP has no influence on the rernoval or control of
ernissions from incinerators, and is therefore not an indicator of compliant incinerator
operations in regards to the emission (i.e., performance) standards.
A High Quench Tower Exhaust Gas temperature alarm is included in the ATLIC control
system as a "Stop Feed" (i.e., an unregulated OP); it is included to protect equipment
rather than to confrol emissions. The ATLIC control system will stop: feed to the PCC
and SCC, the combustion air blowers, and the flow of fuel gas when the Quench Tower
Exhaust Gas temperature exceeds 250 "F to ensure equipment downstream of the quench
tower is not damaged.
This OP was not included as an AWFCO because the temperature of the quench tower
exhaust is not specified in the HWC MACT regulation as a surrogate measure of
compliance with any of the emission standards. Rather, it is used as a Stop Feed for best
managernent practice to protect equipment.
Therefore, TOCDF does not concur with including this OP as an AWFCO.
Concerning accumulated liquids in sumps; TOCDF concurs with the need to characteize
liquids accumulating in sumps. Liquids that accumulate in sumps that are connected to
SDS-Tank-8523 will be analyzed prior to being fed to the Secondary Combustion
Chamber (SCC) of eh ATLIC. The liquids that accumulate in the sumps that are not
directly connected to the SDS-Tank will be characteized prior to treatment. Sumps not
connected to the SDS-Tank are managed as 90-day accumulation tanks and because they
are not a permitted Hazardous Waste Management Unit (HWMU), and are not ancillary
equipment to a HWMU, these sumps are managed under the "Generator Rules". These
rules do not require a written waste analysis plan for wastes managed in tanks that are not
permitted HWMUs.
Concerning sump sludge management; TOCDF doe not expect to manage sump sludge
due to the shortness of the ATLIC operations.
L3. Page 8 describes the exhaust gas from the secondary combustion chamber entering
the quench tower at the bottom and flowing counter-current to the cooling water.
Drawing EG-22-D-821L, sheet I of 4, shows it entering the top. It also doesn't show it
exiting the quench tower and entering the first tower of the packed bed scrubber.
Please explain.
A review of the drawing shows the description on page 8 of the permit modification
request to be incorrect. The flow of exhaust gas is from the top to bottom of the Quench
Tower. Water is sprayed into the exhaust gas as it travels down the length of the tower.
Page 10 of 107
A review of the drawing also shows baffles in the Recirculation Tank (Tank 8912) which
direct the flow of exhaust gas exiting the quench tower to the first packed bed scrubber and
from the first packed bed scrubber to the second, and so forth. The baffles cause exhaust
gases flowing through the PAS to contact the packed bed scrubbers in series, and prevent
the parallel flow of exhaust gas through the three packed bed scrubbers.
14. Page 11 indicates that tanks 8514 and 85L6 are connected so that, ifnecessary, the
content of one tank can be transferred to the other. Drawings EG-22-D-8215 and
EC,-22-D-8216 show a connection to transfer from tank 8516 to 8514 but no piping is
indicated to transfer from tank 8514 to tank 8516. Please explain.
Revision (Rev) 5 of EG-22-D-8216 shows the capability to transfer wastes from tank 8516
to tank 8514, and from tank 8514 to tank 8516. A revised drawing package, to include this
drawing, is provided with submission.
15. Please provide utilities drawing EG-22-D-8221referenced on the drawings for
inclusion in the modification packet.
The referenced drawing is provided in this submittal
16. Please provide a description of all of the interlock functions in either a drawing,
table, matrix, or logic diagram. (It may be the matrix (ATLIC A&I MATRIX.XLS"
referenced in Note 4 of drawingBC,-22-D-8210.)
The ATLIC Alarm and Interlock (A&I) Matrix is provided as Enclosure B
17. Please explain how each of the follow issues will be handled for the carbon injection
system:
a. Ilandling the micronized carbon introduces problems associated with
housekeeping and poteltial respiratory problems in the event of a failure in a
filter element. This problem would be compounded because the carbon dust
would be contaminated with substances of potential concern (SOPCs). In
addition, finely divided activated carbon dust presents a fire and explosion
hazardl.
The ATLIC PAS Baghouse is equipped with 36 individual GORE-TEX filter
elements configured in six rows with each row containing six elements. A loss of
one of the filter elements inside the Baghouse will not result in contaminated
activated carbon escaping the PAS. The PAS is a sealed system that is operated
under negative pressure by the Induced Draft fan. However, it will result in a
higher exhaust gas particulate loading downstream of the Baghouse. Prior to the
exhaust gas release to the ambient air, these particulates will be removed by the
Fixed Bed Carbon Filter (FBCF), which is downstream from the Baghouse. The
FBCF design includes a High-Efficiency Particulate Air (HEPA) Filter at the back
end, which will capture any Pulverized Activated Carbon (PAC) in the exhaust gas
stream resulting from a loss of a Baghouse filter elernent. The pressure
measurement across the FBCF will increase as the HEPA filter becomes loaded,
Page l1 of107
which will eventually cause a Stop Feed with an associated alarm indicating that
there is a process problem.
Fires and explosions are prevented by the carbon being contained in the Bag during
handling, and the high exhaust gas ternperature limit imposed on exhaust gases
entering the baghouse by the MACT regulations.
The process requires that a layer of uniform thickness be built up on the bag
filter to provide uniform treatment for all of the gas. If the thickness varies,
gas will pass preferentially through the thinner sections. It was not clear how
uniform thickness would be achieved.
The filter elements used in the ATLIC PAS Baghouse are made of GOR-TEX and
do not require a filter cake to be deposited on their outer surfaces to efficiently
remove particulate to meet the particulate emission standard. Any filter cake
deposited on the bag would only minimally add to their particulate removal
efficiency.
More carbon consumption is required in the dry sorbent-injection design than
the fixed-bed design. Thin layers on bag filters would have to be replaced
frequently, during which breakthroughs would have to be avoided while
acceptable flow and pressure were maintained. How will this be
accomplished?
The ATLIC Baghouse includes six rows of six filter elements each. A reverse jet
of air is used to blow the filter cake off the elements to maintain a differential
pressure across the Baghouse. A single row of elements is cleaned at a time, and
the cleaning of individual rows of elements is controlled by a timer. At steady-
state operations, there would always be 30 elements with a layer of filter cake on
their outer surface and six elements without. However, as previously stated,
TOCDF has selected the most efficient filter elements available for this application.
"For dusts having a spherical shape, the reverse air jet also cleans out most of the
residual dust cake in the filter media. After each pulse there will be very large
penetrations of dust through the media until the cake reforms. The most effective
solution to this problem is to provide GORE-TEX@ which is a laminated media.
This laminated mernbrane provides what can be termed a very efficient artificial
cake that is not affected by the cleaning jet."r
18. The rinse water contaminants must be demonstrated during the surrogate trial burn
for feed of organics into the SCC.
See response to DSHW comment #11.
19. Page 13 - Table 4lists the waste streams treated and generated by the ATLIC
operations. There is no mention of the baghouse dust or the PAS blowdown. Please
update.
I Principles of Pulse Jet Fabric Filter and Cartridge Filter Performance, Dustex Corporation
Page 12 of 107
b.
c.
TOCDF concurs that these waste steams were not included in the Table 4 of the permit
modification request. However the table in the permit modification request is not included
for review during the Second Public Comment Period.
The PAS blow-down (i.e., spent scrubber brines) and baghouse dust (i.e., Spent Pulverized
Activated Carbon [PAC]) are included in Sections2.2.2.29 and2.2.2.31 of Attachment2,
respectively.
20. No written assessment, reviewed and certified by a qualified PE, attesting that the
tank systems have sufficient structural integrity and are acceptable for storing or
treating the waste as outlined in 40 CFR 5264.192 could be located. Please provide.
The above referenced certification was provided to the DSHW with the submission of the
Temporary Authorization Request to begin early construction of the ATLIC. A copy of
the Professional Engineer (PE) certification is provided as Enclosure C.
2l.Page L3 - Please add narrative concerning additional waste codes such as benzene,
dioxins, UTS, etc. that may apply.
A narrative discussing Land Disposal Restriction Universal Treatment Standards (UTS)
was not included for ATLIC waste streams because unlike the TOCDF Metal Parts
Furnace (MPF) which is a batch operation incinerator, the ATLIC is a Liquid Incinerator
(LIC). Wastes are metered into a LIC which results in a much more narow (i.e., steady-
state) operational envelope as compared to a batch incinerator. LIC combustion chambers
do not experience the momentary low oxygen concentration that are typical of batch feed
incinerators. Further the waste feed to a LIC is atomized as it enters the combustion
chamber which allows the oxygen present in the chamber to fully contact the waste
droplets.
TOCDF included UTS for MPF TC ash because this waste stream was generated inside a
punched TC. The low oxygen environment created by the configuration of the waste feed
to the MPF during Mustard TC processing (i.e., a large solid heel which was treated inside
a "punched" TC) created the potential for compounds for which UTS were specified to be
present in the ash generated inside the TCs. TOCDF therefore specified an analysis for
these compounds in the TOCDF RCRA Permit Waste Analysis Plan.
22.Page 13 - The ATLIC carbon will have decon solution added to it. What is the decon
solution and when is it added (type of container, etc.)? Please be specific.
TOCDF revised Attachment 2 to specify Spent ATLIC HVAC activated carbon to be
treated in the Autoclave. See Attachment2, Section 2.2.2.36. Note TOCDF is however
investigating other methods of Spent HVAC carbon treatment.
23. Table 4 - There were no listings of PAS brines and disposal method/codes in the
table. Please update.
Page 13 of 107
See response to DSHW comment # 19.
24.Page 14 - Spent decon from closure is listed, yet a closure plan was not submitted for
this unit. Please revise.
This permit modification request proposed to add a permit condition in Module II that
would require TOCDF to submit an ATLIC Closure Plan by a specific date. The proposed
Permit Condition reads:
II.K.2. The Permittee shall submit a permit modification requeit that updates Attachment
10 (Closure Plan) for ATLIC associated hazardous waste manasement units no
later than the frrst third quarter ofcalendar year 201 l.
The TOCDF has also submitted a Class 3 Permit Modification Request to revise the
RCRA Permit Closure Plan (see modification request TOCDF-ATT10-03-1111). The
ATLIC closure should be addressed in Closure Plan after it is modified through Permit
Modification Request TOCDF-ATTI0-03-111 1. Changes to the TOCDF RCRA Permit
Closure Plan caused by this modification request will not be incorporated into the TOCDF
'--- permit until some time in second quarter 2011.
Zl.Page 18 - Please explain why DAAMS tubes aren't being used for the stack. Some
narrative indicates they will be used.
The revised Agent Monitoring Plan included rvith this submittal specifies the use of
DAAMS as the confirmation method for lewisite Near-Real Time (NRT) alarms.
26.Page20 & 2l - The Surrogate Trial Burn Plan should address the high metals
loading in the Lewisite and not just address the GA components.
The TOCDF discussed this issue with DSHW prior to the development of the ATLIC
Class 3 Permit Modification Request. It was determined that two separate trial burns
would be submitted. A Surrogate Trial Burn (STB) would be conducted to demonstrate
successful treatment of GA and lewisite organic constituents by dernonstrating the ability
of the ATLIC to burn surrogate organic compounds that are more difficult to incinerate
than either agent. Further, GA contains monochlorobenzene, which is one of the
surrogates selected for use during the STB.
The TOCDF decided to conduct a Lewisite Comprehensive Performance Test (CPT)
because of the inability to spike the surrogate with a-suffrcient amount of arsenic to allow
for the desired feed rate of lewisite.' The solubility of arsenic compounds in the required
surrogates (monochlorobenzene being one of them) is limited. The selected arsenic-
'containing compound that will be used during the STB is soluble in the surrogate to a
concentration that results in an overall arsenic feed concentration of 100 parts per million
(ppm). To feed more arsenic to the ATLIC PCC would require either that the arsenic be
spiked as an arsenic oxide, which is a solid, or that the arsenic-containing compound be
fed as an additional separate feed to the PCC at the same time the surrogate is fed (as
accomplished during the TOCDF Liquid Incinerator (LIC) Mustard Agent Trial Burn).
Page 14 of 107
If arsenic oxides were used as a metal spike, they would need to be suspended in the liquid
surrogate. To support lewisite processing, the oxides would need to be suspended in the
liquid surrogate such that the arsenic content of the blend is 35 weight percent (the same
arsenic weight percent as lewisite). At this high a weight percent, the suspended arsenic
oxides would have a high probability of falling out of solution in the feed line and feed
tank before they reached the ATLIC PCC feednozzle tip. This would result in a
questionable and unverifiable arsenic feed rate demonstration.
To feed a separate arsenic-containing solution to the ATLIC at the same time as the
surrogate would require TOCDF to cut back on the surrogate feed rate since there is a limit
as to how much heat content can be fed to the PCC. The spiking solution that was used to
deliver the arsenic spike to the LIC PCC during the Mustard ATB was primarily ethylene
glycol. The energy fed to the ATLIC PCC as spiking solution would limit the amount of
surrogate that could be fed since all incinerators have heat input limits.
Therefore, it was determined that the best waste feed to demonstrate the effectiveness of
the ATLIC to control high and low-volatile metals emissions was lewisite.
27.Page 20 - All transparency tons must go through an approved decontamination
process.
See response to DSHW comment #11.
28. Page 23 - The 507o feed rate after the trial burn may not be feasible for both agent or
spent decon. If successful, may need to start at 20o/o feed rate.
The proposed series of Module VI permit conditions associated with the ATLIC post-trial-
burn waste feed rate are more restrictive then those proposed in the past for TOCDF
incinerators. The sequence of conditions also ensures compliance with the TOCDF RCRA
Permit Performance Standards as required by the 40 CFR 270.62(c), which reads:
For the purposes of allowing operation of a new hazardous waste incinerator
following completion of the trial burn and prior to final modification of the permit
conditions to reflect the trial burn results, the Director may establish permit
conditions, including but not limited to allowable waste feeds and operating
conditions sufficient to meet the requirernents of 9264.345 of this chapter, in the
permit to a new hazardous waste incinerator. These permit conditions will be
effective for the minimum time required to complete sample analysis, data
computation and submission of the trial bum results by the applicant, and
modification of the facility permit by the Director.
And 40 CFR 63.1206 (bXsXi)(C)( 2 ), which reads:
You may petition the Administrator to obtain written approval to burn hazardous
waste in the interim prior to submitting a Notification of Compliance for purposes
other than testing.or pretesting. You must specify operating requirements,
including limits on operating parameters that you determine will ensure compliance
with the emission standards of this subpart based on available information. The
Page 15 of 107
Administrator will review, modiff as necessary, and approve if warranted the
interim operating requirements.
The series of conditions proposed by TOCDF that would be applicable to the ATLIC post-
trial-burn feed rate ensure compliance with the emission standards as follows:
Waste feed is suspended pending availability, review, and submission of trial burn
exhaust gas sample results and a determination as to whether results show compliance
with the RCRA Permit Performance Standards for Destruction and Removal Efficiency
(DRE); volatile, semi-volatile, and low-volatile metal emissions; chlorine and
hydrogen chloride emissions; particulate emissions; and dioxin emissions.
Agent GA and associated spent decon feed do not resume until the Executive Secretary
approves the STB preliminary results (preliminary data results provide the information
to make the determinations discussed in the previous bullet).
The GA feed rate to the ATLIC Primary Combustion Chamber (PCC) is limited to half
the PCC Principle Organic Hazardous Constituent (POHC) feed rate demonstrated
during the STB and the spent decon feed rate to the Secondary Combustion Chamber
(SCC) is limited to half the SCC organic feed rate demonstrated during the STB.
These wastes are fed to the ATLIC at the limited rates while the operations of the
ATLIC are maintained within the operational envelope used during the STB which is
the same operating envelope that resulted in performance-standard-compliant
incinerator operations, as demonstrated by preliminary data results, at twice the waste
feed rates, for metal, and chlorine feed rates.
The post Lewisite Comprehensive Performance Test (CPT) waste feed of lewisite and
spent decon is limited to half the feed rates specified in the approved Lewisite CPT
Plan. TOCDF is required to perform a Lewisite Mini-Bum during which the lewisite
and spent decon feed rates are also limited to 50o/o and 100% of the approved CPT Plan
approved rates, respectively. Post test ATLIC lewisite operations are therefore assured
to be in compliance with the performance standards based on exhaust gas sample
results obtained during the required mini-burn and result obtained during the STB.
Lewisite and associated spent decon feed are proposed to resume after completion of the
Lewisite CPT at rates demonstrated during the Lewisite Mini-Burn because:
Compliance with the DRE standard for lewisite is ensured by results of the STB during
which more difficult to incinerate organics were fed to the ATLIC than during the
Lewisite CPT (provided the Executive Secretary approved the STB results).
Compliance with the chlorine and hydrogen chloride emission standard is ensured by
the results of the STB during which the feed rate of chlorine was higher than during the
Lewisite CPT (provided the Executive Secretary approved the STB results).
Compliance with the metal emission standards are ensured by results of the Lewisite
Mini-Bum and by limiting the feed rate of Lewisite to the mini-bum feed rate, which
is limited to half the design feed rate of the ATLIC.
Note that TOCDF's past experience with preliminary data submissions associated with
trial burns and demonstration tests have proven to be consistently accurate.
Page 16 of 107
In addition, the DSHW maintains the authority to require TOCDF to suspend waste feed
and penalize TOCDF if DSHW review of the preliminary data determines that the
emission standards were exceeded during the time between the submission of the data and
the completion of the DSHW review.
29.Page 23 - When is the mini-burn planned?
The performance of a mini-burn is not required by regulation. Mini-bums are performed
at the discretion of the owner, and are conducted to ensure a successful trial burn.
The ATLIC is designed to treat the worst-case chemical agent, which is lewisite. To allow
treatment of Agent GA, the STB will be conducted using metal spiking concentrations.
The STB metal spiking rates are so low, relative to the capabilities of the ATLIC PAS, that
TOCDF is confident that the STB results will show compliance with the TOCDF
Performance Standards necessary for a successful STB. The resulting STB metals feed
rates will be substantially lower than those expefienced during lewisite processing.
TOCDF desires to continue the processing of lewisite after completion of the CPT and is
therefore proposing to include a condition that if approved would required TOCDF to
perform a Lewisite Mini-Bum. The feed rates of lewisite and spent decon during the
Mini-Burn would be limited to 50Yo and 100% of the rates in the approved CPT Plan,
respectively. These feed rates will produce a sufficient metals feed rates to allow the
performance of the ATLIC PAS to be evaluated. Post Lewisite CPT ATLIC operations
are assured to be in compliance with the performance standard based on the results of the
Mini-Bum and by limiting the feed rate to rates demonstrated during the Mini-Bum, which
for Lewisite are half the design feed rate and for spent decon 100% of the design feed rate.
Note the post-CPT feed rate of spent decon is proposed to be 100% design rate (i.e., the
rate specified in the approved CPT plan) because the spent decon is primarily water and
spent decon is used to cool the SCC.
The Lewisite Mini-Burn will occur shortly after the beginning of Lewisite operation
because there is a proposed permit condition that limits the number and mass of Lewisite
that can be used during the Lewisite CPT shakedown period.
30.Page24 -a. The permit requires that the Executive Secretary approve the sampling and
analysis plan prior to implementation. This was not performed. Sampling
prior to approval was at TOCDF's own risk.
See response to DSHW comment #8.
b. The High Quench Tower Exhaust Gas Temperature will still be required for
the hazardous waste permit even though MACT may also require the sample
OPL.
See response to DSHW Comment #12
Page 17 of 107
c. The testing will be performed weekly as specified by the regulations. Since this
is a new incinerator system, which will only be operating for about six months,
this requirement is not unduly restrictive.
See response to DSHW Comment #4
d. A closure plan for this unit has not been provided.
See response to DSHW Comment #24
e. The Source hmission Limit for GA 0.0003 mdm3 x0.2:0.00006 mg/m3 10.2
SEL). For Lewisite, the GPL'/WPL/STEI/VSL value of 0.003 mg/m3 x 0.4:
0.0012 g/m3 should be used for the SEL. The stack limit is based on earliest
detection. of.an upset condition.
TOCDF has revised the ATLIC exhaust stack agent NRT monitor alarm setpoint to be
0.2 SEL for agents GA and L, with the L SEL value remaining at 0.03 mglm3. These
setpoint will be evaluated during systemization to determine if the frequency of false
positives alarms caused by use of a0.2 SEL alarm (i.e., AWFCO) setpoint is too great
to allow efficient ATLIC operations. TOCDF will submit a Temporary Authorization
Request with supporting documentation to revise the setpoints if a revision to the
ATLIC exhaust stack agent NRT monitor alarm setpoints is required. The following is
provide in support of the 0.03 mg/m3 SEL value for L and the use of the 0.5 and 0.4
SEL exhaust stack NRT monitor alarm setpoint for GA and L should the 0.2 SEL
setpoint prove unworkable
o Module I of the TOCDF RCRA Permit includes reporting requirements for when
incinerator agent exhaust gas emission concentrations are confirmed to exceed I
SEL. The TOCDF is aware that MINICAMS exhibit a negative bias when
monitoring for lewisite, and studies show that a MINICAMS result of 0.4 SEL is
actually equal to 1.0 SEL. Compliance with the following condition would be
difficult to demonstrate were NRT monitors to also be used as a confirmation
method for ATLIC lewisite operations, particularly if the AWFCO setpoint were
established at0.4 SEL with a SEL equal to 0.03 mg/m3.
Any release to the atmosphere from the combined stack for the two Liquid
Incinerators, the Deactivation Furnace, and the Metal Parts Furnaceg
ATLIC stack if the confirmed stack emission level, as defined in
Attachmentg 22 and22A (Agent Monitoring Plan 4g!3!MeSeen!
Monitorins Plail. iesoectivelv), exceeds the maximum e$enrable*taek
identified for each individual
agent in Table 1 of this Permit. The Permittee shall orally report, as
specified in Condition I.U.l., to the Executive Secretary.
o
o
I.,[f.1.c.
Since the initial submission of the ATLIC Class 3 Permit Modification Request,
TOCDF has developed a DAAMS method that will be used to confirm and
quantiff lewisite exhaust gas concentrations. Therefore, the confirmation and basis
of the lewisite emission concentration will be performed through DAAMS analysis
Page 18 of107
and not by the MINICAMS result. Use of a DAAMS to confirm and quantifu
lewisite exhaust gas onissions provide assurance that the requirement of Permit
Condition I.U.1.c can be complied with when using an ATLIC exhaust stack
MINICAMS AWFCO setpoint of 0.4 SEL with the SEL equal to 0.03 mglm3.
The SEL values, which are applicable to agent incinerator exhaust gas emissions
for all of the chemical agents is set higher than the GPLAMPL/STELNSL values
because of the presence of interferents in the exhaust gas that are absent in ambient
air. An AWFCO setpoint that borders the detection limits of the agent monitors
will result in numerous false positive alarms and intemrptions in waste feed. The
potential exist that the false positive alarms could be so frequent that they would
have an impact on the Lewisite Comprehensive Performance Test (CPT) results.
The MINICAMS will be used to monitor for lewisite in the ATLIC exhaust gas.
These monitors detect lewisite using a halogen-specific detector that responds to
the chlorine in the lewisite. Halogenated compounds are present in the process
water used by the TOCDF incinerator PAS because the chlorinated well water is
used for process water.
The basis for the selection of the ATLIC agent exhaust gas concentration AWFCO
setpoints proposed by TOCDF was to minimize false positive alarms. The effect of
ATLIC exhaust gas matrix interferents on the ability of the monitors to accurately
detect agent at concentrations near the monitor's detection limit will not be known
until completion of the 28-day Baseline Studies, during which time the monitors
will be arralyzingthe actual ATLIC exhaust gas matrix.
The TOCDF implemented agent exhaust gas AWFCO setpoints at0.2 SEL for the
TOCDF Common Stack during the GB, VX, and Mustard Campaigns. There were
numerous false positive alarms at the beginning of the GB Campaign that were
investigated and eventually attributed to the mercaptan that is added to natural gas
to give it an odor. The low AWFCO setpoint of 0.2 SEL also contributed.
Throughout the agent campaigns, beginning inl996 to date, the TOCDF Common
Stack agent exhaust gas concentration AWFCO setpoint has been 0.2 SEL.
Throughout this same time period, there was one Common Stack agent exhaust gas
concentration AWFCO alarm that was confirmed as caused by the presence of
agent and 800 false positive alarms. Through 14 year of agent campaign
experience with TOCDF incinerator exhaust gas matrix effects, the monitoring
staff has minimized the occurrence of false positive Common Stack agent alarms.
The ATLIC will process agents GA and lewisite for less than approximately 200
hours. The operational time of the ATLIC is not sufficient to develop NRT agent
monitoring (by ACAMS and MINICAMS) methods that would be reliable at the
detection limits of the instruments.
Dispersion modeling results do not support an exhaust gas AWFCO setpoint for
GA or lewisite that is lower than proposed. For worst-case atmospheric conditions
(i.e., most stable conditions), the minimum ATLIC exhaust gas agent concentration
required to produce a ground level agent concentration equal to I STEL is 370 SEL
Page l9 of 107
(this for lewisite with the SEL equal to 0.03 mdm3). For Agent GA, the minimum
ATLIC exhaust gas agent concentrations required to produce a ground level GA
concentration of I STEL is 1,200 SEL. This information is provided in Enclosure
D.
Therefore, the proposed ATLIC agent exhaust gas concentration AWFCO values
of 0.5 SEL for GA and 0.4 SEL for lewisite, with a lewisite SEL equal to 0.03
m7lm3,provides protection to site workers and will provide a sufficient margin to
alert the operator to take corrective actions before there is a risk ofexposure at
ground level.
Comparisons of arsenic mass emission rates based on the SEL and environmental
regulations do not support the imposition of a more restrictive lewisite SEL value
or an AWFCO setpoint that is less than 0.4 SEL. The table below compares the
mass emission rate of arsenic from the ATLIC based on a SEL value of 0.03 mylm3
to the arsenic mass emission rate based on the HWC MACT Low-Volatile Metal
(LVM) New Source Emission standard of 23 micrograms per dry standard cubic
meter corrected to 7 percent oxygen. Arsenic is included in the LVM grouping.
Arsenic (As) Emission Rates Comparison @ the SEL and RCRA Permit Performance Standard
Exhaust Gas Flow Rate (scfin 834 834 Exhaust Gas Flow Rate (scfm)
Exhaust Gas Temperature ("F)230 3.5 Exhaust Gas Moisture Content (%)
Pressure (psia 12.2 6.6 Exhaust Gas 02 Conc (%)
ATLIC Stack Exhaust Gas Flow Rate
(acfin)905 782.5 Exhaust Gas Flow Rate (dscfin@ 7oh Oz
ATLIC Stack Exhaust Gas Flow Ratr
(acrn/min 25.6 22.2
Exhaust Gas Flow Rate
(dscm/min @7% Oz)
Lewisite SEL mg/m3 0.03 23
As Emission Standard
(ug/dscm@ 7% C,2)
Lewisite Emission Rate @ SEL (mg/hr)46.12
Lewisite As weight Fraction (%)36.14
As Emission Rate @ SEL (rng/hr)16.7 30.6 As Emission Rate @, STD (mg/hr)
The above table shows that the mass ernission rate of arsenic allowed by the HWC
MACT LVM New Source Emission Standard is almost twice the rate that would
result if the ATLIC lewisite exhaust gas ernission concentration were maintained
just below the I SEL, with the lewisite SEL value taken at 0.03 ^d^t.
It is reasonable to compare differences in Arsenic mass emission rates rather than
Lewisite emission rates because inorganic Arsenic is a Group A carcinogen.
There is only anecdotal evidence for the potential carcinogenicity of
Lewisite. However, the data are not definitive and do not support
classifying Lewisite as a suspected carcinogen. The chronic exposure risk
Page20 of 107
relative to ATLIC Lewisite processing is the inorganic Arsenic oxides
generated from the combustion of the Lewisite and the environmental
exposure and remediation concern related to the arsenic component of its
degradation products rather than the Lewisite that may survive the
incineration process.
http ://www.nap. edu/openbook.php?record_i d:9 644 &p age:27 5
The ATLIC and associated PAS train incorporate three separate units that control
organic emissions: 1) the Secondary Combustion Chamber,2) the Pulverized
Activated Carbon (PAC) Injection System, and 3) the Fixed Bed Activated Carbon
Filter System. Most commercial hazardous waste incinerators are equipped with
Secondary Combustion Chambers, or Afterbumers. Some are equipped with either
a PAC Injection Systern or Fixed Bed Carbon Filter Systern. The TOCDF is
unaware of any commercial hazardous waste incinerators that are equipped with
both activated carbon systems.
The DSHW proposed SEL value for Lewisite is 0.003 mdm3. A 0.03 mg/m3 SEL
value for Lewisite is supported by the Center for Disease Control (CDC). This
value was published by the CDC on March 8, 1988. A copy of the publication is
provided in Enclosure E. The publication includes the justification for the
selection of the lewisite SEL value.
31. I.U.4.b - The acronym "ATLIC" should be added after "TOCDF."
The TOCDF concurs with this comment; the condition is revised as proposed.
32. I.U.S.a.ii - The acronym "ATLIC" should be added with 66TOCDF" and '(I)CD."
The TOCDF concurs with this comment; the condition is revised as proposed.
33. I.U.6 - The acronym "ATLIC" should be added after "TOCDF" on the first line.
The TOCDF concurs with this comment; the condition is revised as proposed.
34.11.8.4 - This condition needs to readr "...until the TOCDF and ATLIC a;re,.."
The TOCDF concurs with this comment; the condition is revised as proposed.
35.II.F.2 - Same comment as above.
The TOCDF concurs with this comment; the condition is revised as proposed.
36. II.G.2 - This condition needs to read, "...at the TOCDF and ATLIC..."
The TOCDF concurs with this comment; the condition is revised as proposed.
37. II.I.1.c - The acronym "ATLIC" needs to be added after "TOCDF."
Page 2l of 107
The TOCDF concurs with this comment; the condition is revised as proposed.
Module II
38. Page 4 - Please change 1.0 SEL to 0.2 SEL (the HVAC is at 1.0 VSL).
The TOCDF does not concur with the proposed revision that would change the value of
the ATLIC NRT monitor stack alarm point at which worker are required to mask from 1.0
SEL to 0.2 SEL; this would cause the ATLIC Control Room to mask the site and workers
at other Area 10 locations. The proposed permit condition is similar to an existing permit
condition applicable to TOCDF Common Stack agent alarms.
Additionally, TOCDF has revised the ATLIC stack exhaust gas agent concentration
AWFCO setpoints to 0.2 SEL as recorlmended by DSHW. With this change, the
management of incinerator exhaust stack agent alarms for both the ATLIC and TOCDF in
regard to actions taken to protect worker are identical. Each has the same initial alarm
setpoint (i.e., 0.2 SEL) and the same masking criteria (i.e., workers mask if exhaust gas
agent concentration reported by both staggered NRT monitors equals or exceeds 1.0 SEL).
39. Page 4 - There is a typo, it should read Attachment 22A instead of Attachment22.
Please change ACAMS references to NRT. (ACAMS or MINICAMS)
Corrections were made on Pages 3 and 4 of Module II to add the phrase'NRT monitors
(ACAMS or MINICAMS)" and to note that the ATLIC agent monitoring requirements are
in Attachment22A.
40.11.J.2.t - A closure plan must be provided for the secondary waste that could be
processed in the Autoclave (provided the autoclave has demonstrated that agent
waste stream prior to closure).
See response to DSHW comment #24
41. II.J.5 - Please add ATLIC and Autoclave Closure Plan to closure plan attachments.
See response to DSHW comment#24.
42.11.J.6: Please verify that the DVS and DVSSR are included in the closure plan if
referenced here.
Condition II.J.6 reads:
The Permittee shall provide certification statements that each TOCDF and Area 10
hazardous waste management unit has been closed in accordance with the applicable
specifications in Attachment 10 (Closure Plan), as required by R3l5-8-7.
The reference to Area 10 hazardous waste management units include the Autoclave; ATLIC; Drum
Ventilation Syglem (DVS); and Drum Ventilation System Sorting Room (DVSSR); and Igloos
1632,1633,1634,1635, and 1636 (all of which are located in Area 10 and managed by TOCDF).
Page22 of 107
To differentiate between TOCDF- and DCD-managed Area 10 Hazardous Waste Management
Units (HWMUs), the proposed condition is revised to read:
The Permittee shall provide certi{ication staternents that each TOCDF and TOCDF
manased Area 10 hazardous waste management unit has been closed in accordance with
the applicable specifications in Attachment 10 (Closure Plan), as required by R315-8-7.
Additionally, Class 3 Permit Modification Request TOCDF-ATT10-03-1111, which was
submitted in June 2010 to comply with existing Permit Condition II.K.1, revised the
TOCDF Closure Plan (Attachment 10 of the TOCDF RCRA Permit). A1l TOCDF-
managed Area 10 HWMUs are addressed in the revised Closure Plan except the ATLIC.
The TOCDF proposes to incorporate ATLIC closure requirements during the Second
Public Comment Period associated with TOCDF-ATTI0-03-I1I I.
Also see response to DSHW commerrt#Z4.
43,II.K.I - Please add Autoclave, DVSSR/DVS, CAMDS Attachment and ATLIC.
Permit Condition II.K.I was proposed to be revised to read:
The Permittee shall submit a permit modification request that updates Attachment
10 (Closure Plan) for TOCDF associated hazardous waste manaeement units in the
second quarter ofcalendar year 2010.
In addition, TOCDF proposed a new Condition 11.K.2., which reads:
The Permittee shall submit a permit modification request that updates Attachment
10 (Closure Plan) for ATLIC associated hazardous waste manaqement units no
latsr than the f,rst third quarter of calendar year 2011
Also see response to DSHW comment#24.
Module IV
44,Table on page 2 - ttre LCS tanks are allowed to contain Lewisite miscellaneous liquid
and decon solution during closure. Please add the word Lewisite to text.
The proposed change has been incorporated into the revised Module IV that is included
with this response.
45. Page 2 - Please separate out NSF-TANK-8514 and LCS-TANK-8516.
The proposed change has been incorporated into the revised Module IV that i, i*frrara
with this response.
46.1Y.8.2 - A subparagraph should be added to this permit condition for the SDS sumps
in the ATLIC facility. Adding them to this paragraph adds an additional waste code
to ALL of the sumps in the MDB as well as the ATLIC.
Page 23 of 107
A subparagraph to Condition IV.B.2 has been incorporated into the revised Module IV that
is included with this response.
41.lY.G.l - The only hazardous waste allowed in LCS-TANK-8511 is liquid Lewisite
chemical agent and Lewisite spent decontamination solutions (l8o/o NaOH Solutions)
from closure activities.
Condition IV.G.I was revised to include (i.e., match) the wastes that are specified in the
table starting on page 2 of Module [V. See response to DSHW comment #44.
48. IV.G.3. - The word 6feet' should be deleted prior to 667.5 inches.'
The correction has been incorporated into the revised Module IV, which is included with
this response.
49.1Y.H.2. - The word "each'prior to *NSF-TANK-8514'needs to be deleted as well as
the word "feett' after "67.5.)'
The correction has been incorporated into the revised Module IV, which is included with
this response.
50. A paragraph similar to IV.I.4 should be added in IV.H for tanks NSF-TAI\K-8514
and NSF-TANK-8516 since the waste from these tanks is being shipped off-site for
deep well injection.
The TOCDF concurs; Condition IV.H.4 was added to address this comment.
51. IV.J.I- This condition should require that tank LCS-TANK-8534 be empty at all
times, not just when chemical agent is being processed or stored. This tank is the
secondary containment for the area and secondary containment should never have
anything in it untdss there is a spill or release of some kind.
The TOCDF concurs; Condition IVJ.l was revised to read:
The Permittee shall maintain LCS-TANK-8534 free of waste when liquid wastes are
nresent in the ATLIC Processins Bav or Toxic Area. This tank shall be used in the
event of a major spill as a result of a tank. ancillary equipment. or ton container failure.
52.1Y.L.2.- The reference to Condition IV.M.I should be IV.L.l.
The correction has been incorporated into the revised Module IV, which is included with
this response.
53. IV.l - Please specify the concentration of the decon nitric acid solutions.
Condition IV.H.3 was revised to specify the concentration of the nitric acid solution that
will be added to NSF-TANK-8514 and LCS-TANK-8516 at 50 %.
Page 24 of 107
54. IV. - TOCDF specifies two decon solutions, NaOII and sodium hypochlorite. Please
provide narrative describing the decon used for each agent.
The only decontamination solution that will be added to LCS-TANK-8523 is sodium
hydroxide. Sodium hydroxide will be used to treat spent decontamination and GA TC
rinse solutions that accumulate in LCS-TANK-5823 to agent concentrations below the
Waste Control Limit of 20 ppb. It will also be used to treat solutions that are generated
during lewisite processing and accumulated in LCS-TANK-8523 to lewisite
concentrations less than 200 ppb.
Condition [V.I.l was revised accordingly.
55. IV.J.6 - Please specify the primary combustion chamber for all treatment. Please
also specify which hazardous waste management unit is referenced.
The intent of the proposed condition was to not specify how wastes that are stored in the
major spill tank will be treated because the'major spiil.tank, as a contingency, may store
any liquid waste generated at the ATLIC. If a major.spill of agent occurs, the spilled agent
will be fed to the ATLIC Primary Combustion Chamber (PCC). If a major spill of spent
nitric acid occurs, it will be captured in the major spill tank and transferred to an off-site
Subtitle C Treatment Storage and Disposal Facility (TSDF). Spent nitric acid cannot be
fed to the LIC because buming the acid would generate excessive nitrogen oxides.
Condition IV.J.6 was revised to read:
Waste stored in LCS-TANK-8534 shall be treated in the combustion chamber or
Hazardous Waste Manaeernent Unit soecified for the waste stream beine stored in
Conditions IV.G.I IV.H.l. IV.L15 or IV.K.I. A,qenfGA Specifically, chemical
agents shall be treated in the Prim
Spent Nitric Acid Solutions shall be transferred to an off-site Subtitle C TSDF.
Spent Decontamination Solutions shall be treated in the Secondarv Chamber
of the ATLIC LIC.
56. IV.O - Please add ATLIC to the closure section.
Condition IV.Q.2 was revised to read:
-IV.MQ.2. The Permittee shall close the TOCDF and ATLIC Tank Systems in
accordance with Attachment 10 (Closure Plan):
Module V
57.Y.4.g.2 - Please provide details for the proposed NRT monitoring configuration
which TOCDF has determined will be the best configuration and will best determine
if there has been a release. Are the MINICAMS and DAAMS able to detect Lewisite
in an incinerator stack environment?
Page25 of 107
Condition V.A.1.g.2 was proposed to account for the possibility of using either a second
NRT or a DAAMS as a confirmation method for ATLIC Agent Exhaust Gas Automatic
Waste Feed Cutoff (AWFCO) alarms. A "single-cycle" DAAMS method for lewisite was
not available at the time the ATLIC permit modification request was submitted.
Since that time a DAAMS method has been developed and tested that is suitable for use as
a confirmation method for lewisite exhaust gas MINICAMS AWFCO alarms. Proposed
Condition Y.A.2.9.2 should be revised to read:
V.A.1.e.2. When processine Lewisite the Permittee shall rnaintain and operate €ithtr
DAAMS tubes and staggered MINICAMS monitors on the ATLIC Stack
L!}
it
tih,".
/nl lt
,rE ! .'
.." J -q'
J' ,r'.
L/
as specified in Attachments 19 flnstrumentation and Waste Feed Cut-
offTables) and 22 (Aqent Monitorinq Pl$n).ffi
with Ci$similor anolytieal eo
Note the MINICAMS and "single-cycle" DAAMS methods that have been developed for
'lewisite are capable of detecting this agent in the ATLIC exhaust stack. The methods were
developed based on a lewisite Source Emission Limit of 0.03 mg/m3 and a MINICAMS
sample/analysis cycle of seven minutes.
58. VA.l.H.ii - Please explain why the API-3000EM was specified. Is this type of
monitor exclusive to TOCDF and ATLIC operations?
The API-300EM CO CEMS was specified because it has internal components that are
different from the other CEMS. Major and minor repairs and the recertification
requirement associated with them are different for this model of CEMS.
The model's high range span limit of 5,000 ppm is preferable over a CO CEMS having a
lower range because of the requirement in the Hazardous Waste Combustor Maximum
Achievable Control Technology (HWC MACT) to use a default value of 10,000 ppm in. the hourly rolling average exhaust gas CO concentration calculation for each minute that
an operator's CO CEMS reports a maximum span value.
,_
59. V.A.2.a - Please be advised that the DRE performance standards will be the same as
was performed at TOCDF - a DRE of 99.999.9Yo for both surrogate and agent trial
burns in the [,ICs.
The TOCDF concurs with increhsing tire ATLIC Destruction and Removal Efficiency
(DRE) Performance Standard for99.99 percent to 99.9999 percent for the selected
surrogates. Section ll.4.l of Appendix A (Quality Assurance Project Plan) to the ATLIC
Surrogate Trial Burn (STB) Plan shows that a "six-9s" DRE is mathematically possible.
The revised Module V, which is included with this qubmission, incorporates the proposed
change in the DRE requirement which will be demonstrated during the ATLIC STB.
Page 26 of 107
60. V.A.4.a.i - The GA action level will be 0.2 SEL. Note 5 is not consistent with the
narrative that appears in operations. The SEL for Lewisite should be 0.003 mdm3.
See response to DSHW comment #30.e. The alarm setpoint for the ATLIC stack NRT
agent monitors was revised from 0.5 and 0.4 SEL for GA and lewisite, respectively,to 0.2
SEL for each agent.
Note 5 was revised as follows because DAAMS will be used as a confirmation method for
Lewisite.
s' GA D.AAMS beqome historical when Lgwisite is the only asent being processed
by the ATLIC.
witheifferq* an*ytieet eet m*@
61. V.A.4b - Please explain if only MINICAMS was used for Lewisite.
See response to DSHW Comment #57.
62.Y.A.4.g- The Lewisite monitoring level should be 0.003 mg/m3 and the action
leveUalarm level should be 0.0012 mglm3.
See response to DSHW comment #30.e, and #60. No change was made to this condition.
63. V.E.3.c - See comment above.
The TOCDF concurs with the need to test the ATLIC AWFCO System more frequently
than every 30 days and proposes a 14 day testing frequency. Additionally because the
ATLIC system will experience periods of extended idle where it will remain at operating
temperature, without processing waste while performance test results are being reviewed
and approved, TOCDF requests that testing of the AWFCO system be required either
every 14 days or prior to resuming waste feed for idle periods lasting longer than 14 days.
See revised condition below and responses to DSHW comment #4.
V.E.3.c. 'The Permittee shall perform a waste feed cut-off function test no
less than once every 39 fourteen (14) days. No waste shall be fed
to the ATLIC during the function test. If the ATLIC is not
operational (i.e.. Shut down) or idlinq for loneer than 14 davs. the
Permittee shall derforfir the function test when the ATLIC becomes
operational. or priorio waste feed.'
:hhu#deu# A:,cgpy of each function test shall be olaced in the
64. V.E.l.a - Spent decon may be burned in the primary chamber if it is below the
demonstrated concentrations.
Page 27 of 107
There is no intent to feed spent decon to the Primary Combustion Chamber of the ATLIC.
Upon completion of each agent campaign, a solvent will be used to flush the agent feed
lines. The solvent that is selected will conform to the requirements specified in Permit
Conditions V.E. 1.b through V.E. 1.h.
65. V.E.l.a.ii - Please provide characterization of the anticipated composition of the
miscellaneous agent contaminated waste stream.
The miscellaneous agent-contaminated waste stream refers to the solvent that will contain
chemical agent as it will be used to flush the agent line upon completion of each agent
campaign.
66. V.E.l.d - Please specify the anticipated chlorine feed rate.
The maximum chlorine feed rate to the ATLIC will be demonstrated during the Surrogate
Trial Burn and is 192 pounds per hour, or 2,304 pound per 12 hours.
67. Please provide documentation that the viscosity of the waste to be pump is
compatible with equipment.
A report documenting the capabilities of the PCC waste feed lance nozzleis provided in
Enclosure F.
68. V.E.l.g - The sampling plan for verification of waste must be approved and
performed.
The TOCDF does not concur with the need to perform additional analysis of the chemical
agents. See response to DSHW comment # 8.
69. V.E.l.h - Please delete 'oeach."
The correction to Condition V.E.l.h has been incorporated into the revised Module V
provided with this submission.
70.Y.e.2.b - Please replace short term condition at half (or 20%) feed rate instead of
TBD.
Historically, Module V has not included short-term incineration conditions, which are
included in Module VI. Module V is titled Long Term Incineration, which begins after the
performance test results (as presented in the submitted test reports) are reviewed by
DSHW. The term To Be Determined (TBD) was used throughout Module V for this
reason (i.e., the operating parameter limits are determined from performance test results,
and the tests have not yet been performed).
Therefore, no change was made to the condition.
71. V.E.3.b - If the system is automatic, the word manual should not be necessary.
o
Page 28 of 107
This condition required the operator to manually stop feed if there were a failure of the
AWFCO system. This condition is verbatim from the conditions in Module V that are
specified for each TOCDF incinerator.
Therefore, no change was made to the condition.
72.Y.8.3.c - Please be advised that waste feed cut-offs will be every seven days instead of
every 30 days.
See response to DSHW comments tA and#63.
73. Table Y.4 - The values are too high based on the processing feed rates of the agent.
The values in Table V.4 for High and Low-Volatile metals are based on the metal feed rate
associated with L since L is in excess of 30 weight percent arsenic. The value for the
Semi-Volatile Metal feed rate is based on the planned lead feed rate during the ATLIC
STB ([325 lb surrogateftr] * [001b lead/106 lbs surrogate] * l2hr: 0.39 lb semi-vol
metalll2-hr) Enclosure G provides a spread sheet that calculates metals, chlorine, and ash
feed rates associated with L feed. The Semi-Volatile metal feed rate associated with STB
is provided above.
Module VI
74. Module VI proposes to feed GA at 50oh of the demonstrated trial burn feed rate
during the post-trial burn after the Executive Secretary has approved the
preliminary results. However, for Lewisite, it proposes a 507o feed rate after the
preliminary results are submitted and a75Yo rate after the Executive Secretary
approves the preliminary results. Why the differenee? It also proposes to increase to
l00oh of the trial burn feed rates without any regulatory approval (iust submittal of
the NOC and trial burn reports). Approval of the trial burn reports will need to be
done before full operations can commence.
The precedent set by permit conditions applicable to past post-trial-bum feed-rate
limitations applicable to the TOCDF incinerators that were established through permit
modifications was to: l) feed at 50 % of the trial-burn-demonstrated rate immediately
after completion the trial burn; 2) feed at75 Yo of the demonstrated rate after approval of
preliminary data (as defined in the RCRA Permit ) by the Executive Secretary; and 3) feed
at 100 %o of the demonstrated rate upon submission of the NOC and trial burn reports, and
review by the Executive Secretary of the trial burn report Executive Summary.
The feed rate increases discussed above were applicable to TOCDF incinerators during the
final agent campaign, after multiple trial burns had been performed on each TOCDF
incinerator.
Because the ATLIC is a new incinerator, TOCDF proposed to suspend feeding of
hazardous waste (i.e., agent) following completion of the ATLIC Surrogate Trial Burn
(STB) until the Executive Secretary had approved the preliminary data. A review of the
data by the Executive Secretary prior to proceeding with GA processing is deemed prudent
Page 29 of 107
because. the STB would have been the first time a performance test was conducted on the
ATLIC.
The TOCDF also proposed to require the performance of a Lewisite Mini-Burn at a
reduced lewisite feed rate to allow for the processing of lewisite after completion of the
Lewisite CPT because the ATLIC is a new incinerator with no prior performance test
result dataavailable to document the ability of the incinerator to comply with the metal
emission standard associated with lewisite processing because of its high arsenic and
mercury content. Note metals feed rates are allowed under the HWC MACT regulations
to be extrapolated up based upon a review of trial burn data conducted by EPA which
found a linear relationship between metal feed rates and metal emission concentrations.
75.V1.4.2.a.i - The Executive Secretary must approve the Lewisite and GA monitoring
for all areas, including the staclg prior to approval of the mod (the LQCP, CDRL 24
and Table l2-2wrllbe updated in this modification).
The TOCDF concurs with the need for the Executive Secretary to approve the Laboratory
Quality Control Plan (LQCP) prior to ATLIC hazardous waste operations. A revised plan
will be submitted.
76,Y1.A.2.a.i.b - GA will be 0.2 SEL for process upsets.
See responses to DSHW comment # 30.e, last paragraph
77.Yl.A.z.b.ii - Please delete "agent operation.'
The condition is revised to read:
VI.A.2.b.ii. The Shakedown Period associated with ATLIC Surrosate Trial Bum shall not
exceed 720 hours ofa*ent hazardous waste operations.
78. VI.A.2.b.iii - Characterization of the feed will need to be sampled and analyzed form
the tank prior to feeding the waste during shakedown.
See response to DSHW comment # 8.
79. VI.A.3.a.i - Please be advised that the DRE will need to be 99.9999Yo for surrogates
and agents as required for all other TOCDF agents and surrogates. The Lewisite
monitoring level will be 0.003 mdm3.
See response to DSHW comments #30.e and #59.
80. Vl.A.4.a.iii.a.1 and,2- If any monitor fails, then waste feed stops immediately.
Condition Vl.A.4.a.iii.a and associated sub-conditions have been revised to read as follows:
VI.A.4.a.iii.a
Page 30 of 107
ffiThe Permittee shall provide continuous monitorins in
tn..{fI,fC tt
monitorins shall consist of two staseered MRT monitors for each
asent (ACAMS fo for
tubes for each aeent beins processed per Condition Vl.A.4.a.xvii.a. If
an interruption in monitorine occurs. feed to the ATLIC shall be
discontinued.
VLA, l,a,iii,a,l When preeessing agent Grt the merdterkrg sholl eensist ef twe steggerC A€rlJt{S
andDA"AA{S*ube*
VI,A,l,a,iiio,2 WhenBreeessing'ewisitethemerdteringshdl€onsistefeitlftreftwestegEerC
is
@
Vl'rt,4.a.iii,a'3 If ene ef ttre rCwdant agent merfters fails er malfirnetierq tho Pernfttee shell
r€elaee er r€eair the rnonitff w
i.:..
These conditions were originally proposed because there was not a "single-cycle"
DAAMS method available for lewisite MINICAMS when the permit modification request
was submitted. The TOCDF wanted to provide assurance to the public that a method to
confirm ATLIC stack lewisite MINICAMS alarms would be provided by one of two
methods, either a second, collocated MINICAMS or a collocated DAAMS. A "single-
cycle" DAAMS confirmation method for lewisite has since been developed, and it will be
used during lewisite processing.
81. VI.A.4.a.ix.d - Since only one CEMS is online, waste feed must be immediately
stopped.
The drawings that were submitted with the initial permit modification request did not
depict that the ATLIC PAS is equipped with two carbon monoxide and two oxygen
CEMS. The management of these CEMS will be the same as the CEMS application at
TOCDF.
82. Vl.A.4.a.x.viiia - Please specify the location of agent monitors in the PAS.
The ATLIC agent NRT monitors and DAAMS that are used to detect agent in the ATLIC
exhaust gas are located in the horizontal run of exhaust duct that is downstream of the
fixed bed carbon system and the ATLIC PAS Induced Draft (ID) fan (see drawingBg-22-
D-8211, sheet 3 of 4, Rev. 7).
83. Vl.A.4.axviii - DAAMS tubes will be required.
Page 31 of 107
The TOCDF intends to use DAAMS to confirm MINICAMS lewisite alarms in the ATLIC
exhaust stack since development of a lewisite "single-cycle" DAAMS method. The above
referenced condition is revised to read:
I Vl.A.4.a.xviii. DAAMS tubes on the TOCDF coilrmon stack and ATLIC PAS stack{if
usetlshall be analyzed at a frequency of one tube per four hours of
sampling with a corresponding QP sample for each agent.
84. VI.E. - Please delete "other applicable codesD and list all allowable codes.
This comment is assumed to refer to proposed condition VI.E.1.a.iv. The wording of this
condition was taken from existing Permit Condition VI.B.1.a.iv, which is applicable to the
TOCDF LIC and has been in the permit for many years. Additionally, TOCDF has revised
the ATLIC Surrogate Trial Bum (STB) Plan to include organic spiking in the secondary
chamber of the ATLIC (see below)
,l r,,,;,0
ii\
I VI.E.I.a.iv. Decontamination solution with the F999 waste code, and otheryp-pligatlE'
waste codes, may be fed to the secondary chamber of the ATLIC during
the shakedown period only if the operating conditions specified in
Condition VI.E.I.b. are satisfied and the Automatic Waste Feed Cut-Off
(AWFCO) set-points specified in the trial burn plans are in effect with the
exception of those AWFCO set-points specified in Condition VI.E.l.a.ix.
vI B l a iv
ff:,""":ffi::lfi lt?st"1il3ff"3.ilxilffi:l:,* llE:fli,l"f,i:"
shakedown period only if the operating conditions specified in Condition
VI.B.I.b. are satisfied and the waste feed cut-off limits specified in the
trial burn plans are in effect.
Module VII
85. VII.A.1.g - Please reword. The narrative is confusing.
Revisions to Module VII were not proposed in the ATLIC permit modification request.
// The TOCDF assumes that the correct reference is proposed condition VIII.A.I.h. The(\. condition is revised to read:
VIII.A.I .h.Two ATLIC Gloveboxes located in DCD Area 10 Igloo 1639 fer*e+reining€f
iaers
Module VIII
86. VIII.D.8.c - Must be less than 0.5 VSL. Please provide narrative for the decon
procedure
Condition VIII.D.8.c and VIII.D.8.k have been revised to read:
The Permittee shall maintain the pressure within the affected Glovebox
below - 0.25 inches of water column as measured relative to the ATLIC
Page 32 of 107
O
VIII.D.8.c.
Process Bay pressure until the agent concentration within the affected
Glovebox is determined to be less than + 0.5 and 0.4 Vapor Screening
Limitg (VSL) for Asent GA and Lewisite. resoectivelv.
VIII.D.8.k. The Permittee ma], remove emptied and rinsed ton containers from the
Glou"bo* irrtu.ior' rn*itorirre
results are less than 0* 0.5 and 05 0.4 VSL for asents GA and L.
respectively.
.'.,
These values conform to the action levels specified in Attachment22a of the permit
modification request.
87. VIII.D.8.d. - Please be advised that GA will need to be pumped to a tank before
processing
See response to DSHW comment # 9.
88. VIII.D.8.f - There will need to be a triple rinse with NaOH followed by a triple rinse
with water.
The TOCDF does not concur with the need to perform three NaOH decon solution rinses
on GA TCs. The RCRA regulations allow generators to declare used containers "empty''
if the container previously held an acutely toxichazardous waste and was triple rinsed with
an appropriate solvent. Empty containers do not have waste codes associated with thern
and are not regulated by RCRA regulations.
The TOCDF is not rinsing the GA or lewisite TCs in an attempt to change their status to
non-regulated containers. The emptied and rinsed TCs will be managed as F999
hazardous waste. Once drained and rinsed, the TCs will be returned to permitted storage,
and the glove boxes will be removed. A pipe cutter will be installed in the ATLIC
Processing Bay where the glove boxes used to be. The pipe cutter will be used to cut each
of the TCs in half. Then, these halves will be monitored for agent prior to being disposed
of at a Subtitle c TSDF.
The TOCDF has determined that the lewisite TCs will receive at least two nitric acid
rinses. Proposed Permit Condition VIII.D.S.g is revised to read:
VIII.D.8,g.The Permittee shall ensure Lewisite and solid heel residues have been
completely removed from the in-process ton container by performin g a
minimum of ene.lwo ton container rinse using a Nitric Acid based
solution, followed by a minimum of three rinses using process water.
89. VIII.D.f.i - How will solids be determined? Please explain why nitric acid is used as
decon instead of NaOH. Please specify the advantages for solids removal for agent
and metals heels.
During the GA and lewisite TC sampling and analysis program, the interior of the TCs
were sampled for non-liquid matrices (solids or sludge) by attempting to collect a sample
from scraping the inner wall of each TC. No samples were collected from the GA TCs,
/7rtt
k'
Page 33 of 107
but were from the lewisite TCs. Solubility studies were conducted on the lewisite sludge
samples using deionized water, acetic acid, and nitric acid. Nitric acid was selected as a
rinsate for lewisite TCs because it both dissolved the sludge to some extent and destroyed
the lewisite, whereas use of the deionized waste dissolved only the sludge and resulted in a
rinsate with a high concentration of lewisite. This information is included in the Final
Report for Ton Container Sample Analysis, which was provided as Attachment 3 to the
ATLIC Class 3 Permit Modification Request.
90. VIII.D.8.g.1.i states that the nitric acid rinse will go to either tank 8414 or tank 8416
(probably meant 8514 and 8516). However, the drawings only show it going to tank
8516.
The referenced permit condition is revised to read:
VIII.D.8.g.1.i. Spent Nitric Acid to eitherNitric Acid Holding Tank (NSF-TANK-8514
or LCS-TANK-8!16), and
Drawing EG-22-D-8216 Rev.5 is revised to show the nitric acid rinse going to either tank.
91. V[I.D.8.b. - The word "measure' on the last line should be *measured.'
The proposed condition is revised as recofilmended.
:
92. VIII.D.8 - The order should be drained, decontaminated, rinsed, and monitored
The condition is revised to read:
VIII.D.8.a.The Permittee may use the ATLIC Gloveboxes to drain, rins'e
decontaminate, rinse. and monitor Agent GA, Lewisite, and
"Transparen cy" ton containers.
93. VIII.D.8.c - It should be less than 0.5 VSL.
See response to DSHW comment # 86.
94. VIII.D.8.d - Agent from GA ton containers will need to be transferred to a tank prior
to processing in the LIC primary.
See response to DSHW comment # 9.
95. V[I.D.8.f - Please change one rinse to three rinses with NaOH, followed by the water
rinses.
See response to DSHW comment # 88.
96. VIII.D.8.h.1 & 2 - All transparency tons will go through the decontamination
sequence, not just ones that have been head-spaced. Also, three nitric acid rinses will
be required instead of one.
Page 34 of 107
The TOCDF concurs with performing the same rinse process on all Transparency TCs.
However, TOCDF does not concur with the need to rinse Transparency TCs with three
nitric acid rinses.
Each Transparency TC was assayed with a borescope during the TC sampling and analysis
program. The TCs were found to be emptybased on these results (i.e., they did contain
solid heels). Photographs taken with the aid of the borescope are included as Enclosure H.
Proposed conditions VIII.D.8.h. I & 2 are revised to read:
VIII.D.8.h.l .Performing a minimum of one ton container rinse using a Nitric Acid
based solution followed by a minimum of three rinses using process water.
Tld+-eq*emqrt is appli€able te Tran^pareey Ten eentalrtrs fer wldeh
detcete4
Additionally, rinsed and empty Transparency TCs will be managed as F999 hazardous
waste. They will be cut in half monitored for lewisite, and disposed of at an off-site
Subtitle C TSDF (i.e., in the same manner as the rinsed and emptied GA and lewisite TCs).
See response to DSHW comment # 88.
97. VIII.D.8.g.1.i. -Tank number 8414 should be 8514 and 8416 should be 8516.
The proposed condition is revised as recoilrmended.
98. VIII.D.8.h.3.i. - See comment
"Oor".
The proposed condition is revised as recommended.
99. VIII.D.8.i. - This permit condition should be worded as follows, (In the event of a spill
from tanks Lcs-taNK-8s 1 1, NSF-TANK-8s 14, LCS-TANK-8s I 6, SDS-TANK-8523,
a ton container, or associated transfer systems specified above, the Permittee may use
tank LCS-TANK-8534 as an alternate storage tank as allowed by Condition IV.J.2."
Proposed condition VIII.D.8.i is revised to read:
b
the event of a spill frorn tanks LCS-TANK-8511. NSF-TANK-8514.
LCS-TANK-8516. SDS-TAI[IG8523. a ton container. or associated
transfer svstems specified pbove. the Permittee mav use tank LCS-
VIII.D.8.i.
Page 35 of 107
4t,
/i.rl IF
Irl
TAIYK-8534 as an alternate storase tank as allowed bv Condition
fv.J.2.
100. VIII.D.8j. - The word gcontainer" at the end of the second line should be
ttcontainers.'
The proposed condition is revised as recommended.
101. VlI.D.8.k - A minimum of two complete monitoring cycles needs to be specified.
The TOCDF concurs with the need to collect a representative sample for analysis. We
also concur with the need to ensure that all the sample gas that flows through the Pre-
Concenkator-Tube (PCT) is sample gas and not ambient air thatmay have entered the
sample line while the monitor was offline.
There are no conditions in the TOCDF RCRA Permit or associated attachments that
specify a required number of NRT agent monitor sampling/analysis cycles. The
requirement to perform multiple NRT monitor sample/analysis cycles is typically specified
in the procedure specific to the operation. The requirement to perform multiple NRT
cycles, or at least to time the collection of the sample so that the sample collected represent
the intended sample, will be included in the glove box procedure, which is the process
currently specified for the DVS operations.
102. VI[.E.18.c. - This condition should read, *...before removing the treated ton
container in accordance with VIII.D.8.k."
The proposed condition is revised to read:
VIII.E.18.c.Upen eemptetierefthe draining and rinsing; the Ug-Permittee shall
monitor the interior of the Glovebox before removing the treated ton
container in accordance with VIII.D.8.k.
103. VI[.E.8.h - The acceptable range must be specified. Please include language to
monitor a minimum of two complete cycles.
The TOCDF assumes this comment refers to the agent monitoring results required to allow
removal of a TC from a glove box. The limits are specified in Conditions VIII.D.8.o. and
VIII.D.8.k as less than 0.5 and 0.4 VSL for GA and lewisite TCs, respectively. See
response to DSHW comment # 86.
See response to DSHW comment # l0l regarding the need to perform two NRT cycles to
monitor the interior of a glove box prior to removal of TCs.
ji'
104. VI[.E.18.b - Please specify the acceptable range.
The proposed conditions appearing before VIII.E. 18.b specify a minimum value of less
than 0.25 inches of water column. The condition is revised to refer to those conditions and
reads:
Page 36 of 107
Ol VIII.E.18.b.
105. VIII.E.18.c - Please
done.
The Permittee shall monitor the pressure differential between the interior
of the Glovebox and the ATLIC Processing Bay throughout ton container
draining and rinsing operations in accordance with Conditions
VIII.D.8.b and VIII.D.8.c.
specify where the monitoring specified in Condition VIII.D.8.k is
The glove box pressure is monitored using a differential pressure hansmitter that provides
a local reading and sends a reading to the ATLIC Control Room (see drawingBG-22-H-
8202, sheet l, Rev. 7).
106. The modification request proposes to not include an operating parameter limit for
high quench tower exhaust gas temperature. The justification is that establishing a
limit for the maximum quench tower exhaust gas temperature would be redundant to
the high temperature limits on the baghouse and carbon filter. A maximum quench
tower exit temperature is necessary to ensure proper operation of the packed bed
scrubber. It should also be included as an equipment protection parameter.
Maximum Quench Tower Exhaust Gas Temperature is included as a non-regulated Stop
Feed for equipment protection, but not as a regulated AWFCO. See response to DSHW
comment # 12.
Module X
107. X.A.3.b&c - Please include the sumps.
The TOCDF does not concur with the need to add sump references to Conditions X.A.3.b.
and X.A.3.c. Section X.G of Module X is applicable to sumps and therefore applicable to
the sump located at the ATLIC.
The ATLIC sump system is designed similar to TOCDF's. There are sumps that are
ancillary equipment to the spent decon holding tank. The same type of engineering
controls applicable to TOCDF sumps will be used to control emissions from the ATLIC
sumps (i.e., a cascading air ventilation system that is operated at less than atmospheric
pressure and vents to a carbon filter system).
The TOCDF recommends the following revision to address Subpart BB and CC
requirer4enJs applicable to ATLIC permitted storage tanks and sumps.
x.G.12.The Permittee shall control air emissions from hazardous waste tanks used
as primary containment devices in accordance with R315-8-22 [40 CFR
264.10841for the tanks identified in Table2 and Table 2-A.
108. X.A.3.c - GA will need to be placed into tanks before processing for sampling
requirements.
See response to DSHW comment #9.
Page 37 of 107
109. X.J.3 - Please provide a detailed description of the HVAC monitoring system.
There are three ATLIC Heating, Ventilation, and Air Conditioning (HVAC) carbon filter
units; two are online at arry time. Each filter unit is configured with a bank of pre-filters,
followed by a bank of High-Efficiency Air Filters, then by three beds of activated carbon,
followed by a bank of HEPA filters.
The NRT monitors (ACAMS for GA and MINICAMS for lewisite) are used to monitor for
agent breakthrough after the first carbon bed (i.e., mid-bed between carbon beds I and2).
A single NRT specific to each agent "spools" between the first mid-bed of the two online
filter units. The DAAMS are used to continuously collect a sample after the first and
second carbon beds of each online filter unit. The DAAMS are analyzed daily to generate
a historical record.
110. X.J.3 - The narrative should specify throughout closure, not just when online. Are
the two tMC systems identical? Please clarify.
Proposed conditions X.J.3.a through X.J.3.c are similar to the existing Module X
conditions that are applicable to the TOCDF HVAC carbon filter system. (See existing
Permit Conditions X.J.l.a through X.J.l.c.) Therefore, no change was made to the
proposed conditions.
Each HVAC carbon filter unit is identical. See response to DSHW comment #109 and
drawing Ec-22-H-8202,which was submitted as part of the ATLIC permit modification.
111. X.K.7 - It should be 0.5 VSL.
The need to replace an activated carbon filter bed within an HVAC carbon filter unit is
based on the results from the mid-bed NRT monitor. A review of the ATLIC Agent
Monitoring Plan (Attachment22/t) shows that NRTs are used to monitor ATLIC HVAC
carbon filter units only after the first carbon mid-bed. Therefore, the basis for carbon bed
replacement and the required beds needed for change should be the status of Bed 1. Bed 1,
being the impacted carbon bed (i.e., the compliance point), leaves two carbon beds
downstream to ensure. agent is not emitted to the environment. Considering that,
Condition V.K.7 is revised to read:
The Carbon Adsorption Filtration system for ATLIC shall have the first
M carbon filter beds replaced when any agent is derteeted
confirmed between the first and second midbeds at a
concentrationgreaterthanorequa1to1.0V@daysfromthe
time the midbed agent concentration reaches 1.0 VSL, the Permittee shall
begin operations to replace the carbon in the affected unit.
As revised above, Condition X.K.7 includes carbon replacement requirements equivalent
to those applicable to the carbon filter unit that supports Autoclave operations (See
Condition X.K.5). The two separate filter systems should have similar carbon replacement
requirements considering that each carbon filter consists of three carbon filter beds.
Page 38 of 107
Tables
ll?a. Table 1- Please specify 0.003 for Lewisite.
See response to DSHW comment #30.e.
112. Table 4a,page9 - Please explain why there is the potential for agent in the SDS,
SDS-PUMP-8527 P999 but not in the other sump systems.
The Spent Decontamination System (SDS)-PUMP-8527 is located in the ATLIC Primary
Combustion Chamber (PCC) Room. The P999 waste code was listed in association with
this sump for a contingency should there be a release of neat agent in the ATLIC PCC
Room from the fgent piping that leads to the waste feed lance.
The P999 waste code is not applicable to the other sumps listed in Table 4a because these
sumps are located in the airlocks that are used by personnel entering and exiting the areas
of potential agent contamination. These sumps will receive spent decon on a routine basis.
The agents contacted by the decon bei:ome F999 waste by definition of the'State of Utah
waste codes specific to chemical agents (P999) and residues from the treatment of
chernical agents (F999).
Appendix B
1L3. Please define transparency ton containers specifically. The'transparency ton
containers must go through an approved decontamination procedure and then be
agent monitored. Please revise the description.
The following definition was included in Appendix B aS part of the ATLIC permit
modification request:
x. "Transparency Ton Container" shall mean a toh container than has been
determined to be empty of liquids and solid and whose headspace has been
sampled for Lewisite.
The Transparency TCs were initially included on the list of the declared chemical
stockpile because there was no proof that they did not contain recoverable liquid chemical
agent, The 10 TCs to be rinsed at the ATLIC have been verified free of recoverable liquid
agent through borescope assay; they are no longer included on the Chemical Weapons
C,gnJention delfared chemical stockpile inventory of the United States.
These TCs were also head-spaced monitored for lewisite and industrial chemicals. The
results of the aqsay and head-space sampling can be found in the "Final Ton Container
Sample Analydis Report," which was included as Attachment 3 of the ATLIC permit
modification request.
Attachment I - Main Body Permit Mod (Facility Description)
114. 1.1.3.6, Table 1-1 - Please change the quantity of Lewisite to 20 ton containers and
include a footnote indicating that ten are transparency ton containers. Please make
Page 39 of 107
new table for the GA and L for the ATLIC since only L and GA will be processed at
the ATLIC (or add another footnote). Footnote 5 does not include the leakers. This
should be clarified.
The Transparency TCs are not part of the Deseret Chernical Depot Stockpile. They were
removed from the stockpile based on results of the assay and sampling documented in the
final Ton Container Sample Analysis Report that was submitted as Attachment 3 of the
ATLIC permit modification request. See responses to DSHW comment # ll3.
Rather than create a new table for the ATLIC, TOCDF proposes to identify which items
and agents will be destroyed at the TOCDF and which items will be desfroyed at the
ATLIC by identiffing the applicable treatment facilitybeneath each item. Tablesl-l and
l-2 are revised accordingly.
Regarding Footnote 5, which is associated with Table l-1, TOCDF is unaware of any VX-
or GB-containing leaking munitions that remain. Leaking VX and GB munitions were
deshoyed at the end of the respective agent campaigns.
115. Table 1-2 - The "*tt footnote is not accurate for the leakers.
The TOCDF concurs; the reference is deleted.
116. 1.1.4.3.2 - Please specify "Lewisite'transparency ton containers.
The Transparency TCs were assayed and found free of any recoverable liquid agent. The
interior of each TC was also monitored by MINICAMS that were configured to detect
lewisite. One TC had positive results for the presence of lewisite. It is not accurate to
describe all Transparency TCs as lewisite Transparency TCs, particularly since they have
been determined through borescope assay to be empty. Pictures from the borescope assay
are included in Enclosure H.
ll7. 1.1.5.2.1.12 - Please add baghouse residues.
The description associated with the above reference was intended to describe the Baghouse
residues. The description is revised to read:
1.1.5.2.1.12 Bashouse residues
118. 1.1.4.5. - This section should also discuss the ATLIC PAS.
The following paragraphs are added to Attachment 1 to address the ATLIC PAS:
1.1.4.5.2. ATLIC exhaust eases are treated in a unioue PAS that is both
wet and dry. Exhaust gases first pas throuqh a Ouench Tower.
which causes them to cool and become saturated with water.
The sases next pass throush a series of Packed-Bed Scrubbers
that have chilled scrubber solution flowine throueh them. The
Page 40 of 107
chilled scrubber solution causes the water in the exhaust sas to
condense. The eases iater pass throuqh an electric re-heater
which ensures the qases are at a temperature hieher than the
dew point. The remainder of the ATLIC PAS downstream of
the eas re-heater is a drv PAS and equipped accordinelv with a
Pulverized Activated Carbon (PAC) Iniection Svstem. and a
Baehouse.
1.1.4.5.2.1. Spent scrubber brines which are collected in tanks and
baehouse residues which are collected in containers are
transported off-site for treatment and disposal.
119. 1.2.6.1- The wind rose on drawing TE-16-C-3 is for all of DCD and this paragraph
should be edited to reflect this.
The following revision is made to paragraphs 1.2.6.1 and 1.2.6.2.t-
1.2.6,1
1.2.6.2
The wind rose for the TOCDF and ATLIC is included on Drawing
TE-16-C-3 (restricted access - protected record). The wind rose plot
is desiened from data collected at the DCD weather station located
in Building 5108, and it reflects 1997-_year3-end data from Weather
Station 9. The prevailing winds at the TOCDF area follow the
orientation of the mountain ranges flanking either side of the
facility. Wirtds are prevalent from the south through southeast in
the summer and from the north through northwest in the winter.
The wind rose reference above is applicable to all facilities
within the DCD boundarv since mountains flank the entire
boundarv of DCD.
120. 1.2.14.2 -All fire suppression and detection equipment for the ATLIC will need to be
installed by EG&G and its contractors. None of it will be covered in the DCD permit.
This paragraph should have information similar to paragraphl.2.l4.l.
The paragraph is revised to read:
1.2.14.2 The ATLIC Fire D.etection and Prevention Svstem is described
in Attachment 9. Section 9.1.4.9.
l2l, 1.4.5.1 - Please change "munition" to ttmunition or bulk container."
The requested correction is included in the revised attachment included in this submission.
Attachment 2 - Main Body Permit Mod (Waste Analysis Plan)
Page 41 of 107
":r!
i,iL .,,,
{'rii,o'\.*.
122. 2.2.1.3,2 & 3.3 - This narrative still holds for GA and Lewisite. Additional sampling
under an approved sampling plan is still required. Limiting this requirement to
TOCDF agent campaigns is not appropriate. Please delete 6'TOCDF' from the
narrative.
See response to DSHW comment # 8.
Additionally the analysis data for the GA, lewisite, and Transparency TCs were included
in the permit modification so that the public would have an opportunity to comment on the
data validity. The proposal presented in the revised Attachment 2 use these data for the
charactertzation of these waste steams.
123. 2.2.1.7.4 -Please be advised that additional sampling will be required for
completeness.
This information is included in the Ton Container Sample Analysis Final Report, which
was included as Attachment 3 to the ATLIC permit modification request.
The TOCDF position is that the data included in the report provide a complete
characterization of the waste to be processed by the ATLIC for the following reasons:
o Both agents were characterized for organic content and metals. These
characteizations provide sufficient information to the operator to ensure compliance
with the TOCDF RCRA Permit incinerator Performance Standards specified in
Module VI.
The analytical results show that GA contains monochlorobenzene (MCB) and further
quantify the GA MCB concentration. The TOCDF used this information to identiff
the need to perform a Surrogate Trial Bum (STB) prior to processing GA. The
information was also used to select the surrogates MCB and perchloroethylene (PCE).
Considering that MCB is a Class I Principle Organic Hazardous Constituent (POHC)
and that the ATLIC Destruction and Removal Efficiency (DRE) demonstration will be
based on this POHC and PCE (a Class 2 POHC), the organic data associated with the
GA analysis are sufficiently complete to allow the operator to comply with the existing
and proposed permit conditions prohibiting the incineration of organic compounds that
are more difficult to destroy than what was demonstrated during a Surrogate Trial Burn
(see below). Note that the GA organic compounds that were identified as "I-Inknown"
in the analysis cannot be more difficult to incinerate than Class 1 POHCs, which are,
according to the EPA, the most difficult to destroy.
o
lc l;
'#
..,.i
V.B.1.c._The Permittee shall not incinerate anyhazardous waste in the LICs that
contains R315-50-10 organic hazardous constituents, which are more
difficult to destroy than the material demonstrated in the surrogate trial
burn.
_The Permittee shall not incinerate any hazardous waste in the ATLIC that
contains R315-50-10 organic hazardous constituents, which are more
V.E.1.c.
Page 42 of 107
difficult to destroy than the material demonstrated in the surrogate trial
burn.
The analytical results quantiff the metal content of Agent GA. These results were
used to select the metal spikes and their associated feed rates during the ATLIC STB,
which is being performed to support GA processing. The ATLIC PAS is designed to
control metal emissions during lewisite processing, which involves metals at
concentrations measured in weight percents; these metals are 1,000 orders of
magnitude greater than the metal concentrations found in GA.
The lewisite organic analytical results sufficiently characterize this waste stream to
allow the TOCDF to ensure compliance with the TOCDF RCRA Permit Incinerator
Performance Standards considering the selected Class I and2 POHCs that will form
the bdsis of the DRE demonstration made during the ATLIC STB. The lewisite
(whether it be Ll, L2, or L3) is not more difficult to destroy than the selected STB
POHCS.
The lewisite metals analytical results Sufficiently characterized this waste steam to
allow the TOCDF to design the ATLIC PAS and to develop the lewisite RTC
processing procedure, which requires mixing the contents of selected lewisite TCs in
the Agent Storage Tank prior to feeding to create a waste feed with a consistent
mercury concenhation. Note that metal results will be obtained throughout operations
as the permit modification request proposes to quantiff the mbtal content of each tank
of lewisite prior to processing its contents.
The sampling plan that required an attempt to collect samples from the interior of the
GA and lewisite TCs, and the associated result of the samples collected, provided
sufficient information to the operator to develop and plan a process for rernoving the
solid found in the lewisite TCs. The presence of solids and their high mercury
concentration formed the basis for TOCDF to devise a nitric acid rinse processing step,
to permit and install hazardous waste storage tanks for this waste stream, and to
calculate that the spent nitric acid waste stream mercury concentration will be too great
to process this waste steam in the ATLIC.
Finally, the borescope assay performed on the Transparency TCs provided sufficient
charaeterization for TOCDF to determine that theses TCs do not require as rigorous a
rinse process as the lewisite TCs because the Transparency TCs contain minimal
solids. The assay results were used to remove these TCs from the Chemical Stockpile
list of the United States because they demonstrated that the Transparency TCs did not
coritain any recoverable agent
2.2.1,21- Please reword to reflect the comments specified above regarding additional
sampling. Please provide a sampling plan for approval for both liquid and sludge
material.
See response to DSHW comments # 8, and 123.
Page 43 of 107
125. 2.2.1.21.2 - Please delete the sentence *A detailed report of the...' since this was
never approved by the Executive Secretary. See comment above describing an
additional sampling plan.
See response to DSHW comment # 8,123, and 124.
126. 2.2.1.23.1- A minimum of one hour rotation is needed for treatment instead of a
6predetermined time.t' Please revise the narrative. Also, the ton containers need to
be filled/extracted three times with NaOH.
Rather than include a compliance requirement in an attachment that may be difficult to
find, TOCDF proposes to revise conditions in Module VIII to require a minimum one-hour
rotation of TCs between each rinse. The condition is revised and shown here. The same
revision is made to the similar conditions appearing in Module VIII that pertain to lewisite
and Transparency TCs.
VIII.D.8.f. The Permittee shall ensure Agent GA and solid heel residues have been
completely removed from the in-process ton container by performing a minimum
of one ton container rinse using a sodium hydroxide based decontamination
solution followed by a minimum of three rinses using process water._fuggg!
rinse the ton container with added rinsate shall be ro\ated for a minimum of
Regarding the comment reference to three NaOIi rinses, ."" r".porrre to DSHW comment
# 89.
127. 2.2.1.23.3 - Besides GA and HHRA metals, VOCs and SVOCs need to be added to
the sampling plan. These parameters must be demonstrated during the trial burn in
the SCC or the solutions must be processed in the PCC. The sludge sampling and
analysis must be addressed in another section.
Because the analysis of the spent decon will be performed on site to minimize delays in
processing, TOCDF proposes to perform an analysis for percent organics, similar to the
organic screen analysis that is currently applicable to waste analysis performed on spent
decon treated at the TOCDF.
Paragraph 2.2.1.23.3 is revised to read:
2.2.1.23.3 Prior to processing, the tank's contents are analyzed for agent content to
ensure the Agent GA concentration is less than 20 parts per billion (ppb),
which is the Waste Control Limif (WCL) for Agent GA, pefgggt-qgsanig
content. and for HHRA metals. Note: if the Agent GA concentration is
equal to or greater than 20 ppb NaOH based Decon Solution is added to
the tank and the contents are sampled and analyzed again for agent.
The same revision is made to paragraph2.2.l.25.3, which is applicable to spent decon
generated during lewisite TC processing.
Page 44 of 107
The TOCDF concurs with the need to spike the ATLIC Secondary Combustion Chamber
(SCC) with an organic during the Surrogate Trial Burn (STB). The ATLIC STB Plan is
revised to speciff spiking the SCC with monochlorobenzene. This level of organic spiking
will establish the organic feet rate to the SCC. The percent organic analysis will ensure
compliance with the limit established during the testing.
128. 2.2.1.24.1- A minimum of one hour rotation is needed for treatment instead of a
*predetermined time." Please revise the narrative accordingly. Also, the ton
containers need to be filled/extracted three times with 3M nitr_ic.apid.
See responses to DSHW comment # 126.
129. 2.2.1.24.2 - There are other waste codes which need to be characterized for shipment
off-site.
The TOCDF acknowledges that other waste codes may apply. The sampling of this waste
',"stream for off-site treatment and disposal does not occur until the waste in the tank located
in the ATLIC Toxic Area is transferred to the 90-day accumulation tank located in the
ATLIC PAS area.
130. 2.2.1.25 - Besides GA and IIHRA metals, VOCs and SVOCs will need to be sampled.
See response to DSHW comment # 127.
131. 2,2.2.14 - Please Explain why TOCDF was added to the SDS tank sludges. Does the
ATLIC need its own section with the same information except for GAIL instead of
GB/VX and mirstard?
The ATLIC SDS Tank Sludge waste steam was not identified because the speffdE'eor...
generated at the ATLIC will be diluted with the TC water rinses. Sludge is,'nqt expected,to
accumulate in the tank used to store ATLIC spent decon.
132. 2.2.2.29.1- The statement concerning organics should be clarified or deleted. The
next paragraph indicates that they will be sampled and analyzed.
The paragraph is revised to read as follows:
, = -'2.2.2.29.1 Spent S'Ciubber Brines are senerated from the operation of the ATLIC
Pollution Abatement System (PAS). Purged scrubber brines are
u." fq99.. D002. OOO+. OOOZ. OOOA. D009. *d D010J*"...{".rt
ie
eedrtpound$ arenot e*peet€d te be prc
senrbffiif€*
133. 2.2.2.29.2 - Brines will need to be tested weekly, not quarterly.
Page 45 of 107
1"i
''.. j
The TOCDF does not concur with the sampling frequencyproposed for ATLIC Spent
Scrubber Brine for the following reason:
A weekly sampliflg and analysis frequency was agreed upon for Spent Scrubber Brine
generated by TOCDF Metal Parts Furnace (MPF) operations during the Mustard
Campaign because TOCDF collected and analyzed less than2i solid heel samples
from mustard TCs. To compensate for the infrequent sampling of the mustard TC
solid heels that were fed to the MPF, TOCDF sampled andanalyzed the MPF scrubber
brines on a weekly basis.
The ATLIC waste feeds have been thoroughly characterized. Samples were collected
and analyzed from each TC to be processed. Additionally lewisite and spent decon
that are fed to the ATLIC will be characteized prior to being fed. Samples will be .
collected from the "batch managed" Hazardous Waste Storage/Feed Tanks.
Because TOCDF has charact eized,and will continue to characteri ze,thewaste feeds
to the ATLIC, the proposed Scrubber Brine sampling and analysis frequency of either
at each agent campaign char-rge or once per month (equivalent to the brine sampling
frequency for characteizationof brines generated by the TOCDF incinerators) is
sufficient.
134. 2.2.2.31.1- Organic compounds may be present and will need to be analyzed for in
each waste stream.
Proposed paragraph 2.2.2.31.2 specifies organics as an analytical parameter for Spent
Pulverized Activated Carbon (PAC). To remove confusion, paragraph 2.2.2.31.1is
revised to read:
2.2.2.31 .l The ATLIC PAS includes equipuient to inject PAC into the exhaust gas
stream. The PAC is injected after the Exhaust Gas Re-Heater. The PAC
adsorbs Mercury and (if any) residual organic vapors from the exhaust
gas. Spent PAC is generated from operation of a baghouse filter system
which removes the PAC from the exhaust gas. Spent PAC is discharged
from the hopper located below the baghouse into a storage container. The
federal and state waste codes applicable to this waste steam are F999,
D004, D007, D008, D009, and D010. @
135. 2.2.2.32.1 & 2 - Not all compounds wiII be captured by the PAC. The baghouse
residue must be sampled and ana.lyzed.
The requirement to sample and analyze the Baghouse residues is found in Section 2.2.31.
Also see response to DSHW comment # 136.
136. 2.2.32 - The baghouse filters residue must be sampled during each agent
demonstration test and weekly during shakedown and post trial burn test.
Page 46 of 107
o Section 2.2.31discusses the sampling and analysis required for Baghouse residues. The
TOCDF proposed to apply the same waste codes to the fabric fi1ter media (i.e., the
Baghouse filter residues) that are determined applicable to the Baghouse residues. The
Baghouse residue matrix will be comprised of metals, ash, and Pulverized Activated
Carbon (PAC). These same residues will be contained in fabric filter media that was used
to remove the residues from the exhaust gas.
Note that the Surrogate Trial Bum (STB) and Lewisite Comprehensive Performance Test
(CPT) Plans are revised to require the collection and analysis of Baghouse residues during
the testing.
137. 2.2.2.34.2 - Please provide the carbon method and validation for Executive Secretary
approval.
A method to analyze spent ATLIC activated carbon waste streams is currently under
development. When available, the procedure will be provided to DSHW for review, and a
method validation study will be preformed, which DSHW representatives may observe.
138. 2.2.2.35.1 - Please add to the end of the statement 6'...if no conlirmed alarm on the
stack has occurred.'
The paragraph is revised to read:
Ol The ATLIC Heating Ventilation and Air Conditioning (I{VAC) System
consists of three filter units, with any two on-line at all times that agent is
in the facility. Within each filter is a bank of pre-filters followed by a ," '
bank of HEPA filters, followed by three banks of activated carbon filters,
followed finally by a second bank of HEPA filter. These filter elements
will be replaced on an as-need basis. The applicable waste code is P999
for the pre- and HEPA filter located in from of the earbon beds and F999
for the HEPA filfer l6cated behindJhe lastcarbon bed-@
conlirmed asent alarm on the stack occurs. ''
-
139. 2.2.2.35.2 - All P999, P9991F999 carbon should be autoclaved.
Section 2.2.2.35 discusses the waste characterization for ATLIC Heating, Ventilation, and. . ,Air Conditioning (HVAC) System Pre- and High-Efficiency Particulate (HEPA) Air
Filters that are used in the HVAC carbon filter units. Section 2.2.2.36 discusses the waste
charactertzation ai2plicable to the activated carbon that, when spent, willbe removed from
the HV.AC filter units.
Regarding the comment that the HVAC carbon should be treated on sjte using the
Autoclave Subpart X Treatmbnt Unit, TOCDF concurs with the suggested treatment of
spent activated carbon found to be"contaminated with agent above the Waste Control Limit
(WCL) using the on-site Autoclave Subpart X Treatment Unit; Section 2.2.2.36 has been
revised accordingly.
Paragraph 2.2.2.36.2 is revised to read:
22.2.35.1
Page 47 of 107
I/)
'.{-
r^-..'\ -
t'
2.2.2.36.2 Agent contaminated carbon is treated on-site in the Autoclave Subpart X
Treatment Unit
140. 2.2.2.35.2 -The reference to Module YIII does not explain how this waste stream will
be managed. It only explains what the DVS/DVSSR is for and how it is used.
Management of this waste stream needs to be spelled out more clearly.
Paragraph 2.2.2.35.2 is revised to read:
2.2.2.35.2 Discarded pre- and HEPA filters located before the carbon beds have a
high potential of being contaminated with agent and are therefore
managed on-site per the requirernents found in Module VIII which are
associated Autoclave and Drum Ventilation System/Drum Ventilation and
Sorting Systern Room (DVS/DVSSR) secondary waste management,
Filters found to be contaminated with chemical asent above 1.0 VSL
are treated in the onsite Autoclave Subpart X Treatment Unit.
l4l. 2.2.2.36.2 - Is there a decontamination plan for deconning carbon filters for Lewisite
and GA? \ilhy isn't the carbon autoclaved? What type of management control will
be specified for direct feeding and witnessing the burning this waste stream? What is
the determination for other compounds (metals and organics) for shipping this off-
site? Is the carbon sampled for the other compounds prior to deconning?
See response to DSHW comment # t39
142. 2.2.2.37.1.- The word "conduced'in the first line should be changed to "conducted."
143.
The suggested revision is in Attachment2, included with this submission.
2.2.2,37.2.,2.2.2.38.2. and2.2,2,39.2. -See comment regarding on-site waste
processing in the MPF orautoclave.
Each of the above-referenced pafagraphs are structured the same in that they specify waste
management practices discussed in Module VIII, meaning that drums containing these
waste streams will be evaluated in the Drum Ventilation System (DVS) to determine
whether the headspace of the drum has an agent concentration greater than 1.0 Vapor
Screening Limit (VSL). Drums with headspace monitoring results greater than the VSL
will be treated in the A.utoclave; drums with headspace monitoring results equal to or less
than the VSL will be shipped off site'to a Subtitle C TSDF.
144. 2.2.38.1 - What determines successful deconning? Please specify < 0.5 VSL for a
minimum of two complete cycles.
Page 48 of 107
ol
There is not sufficient volume in a sealed drum to perform two agent monitoring cycles.
Therefore, these wastes will be evaluated for agent contamination byperforming
headspace monitoring while they are in the drum. A representative headspace result is
assured based on techniques presented to DSHW as a result of a previous DSHW comment
conceming two-cycle headspace monitoring for waste currently being processed through
the Drum Ventilation System (DVS).
145. 2.22.40.3 - is the TOCDF planning to use the MPF to process GA and L secondary
waste, or is the strainer waste destined for the autoclave? Please specify.
Paragraph 2.2.40.3 is revised to read:
2.2.2.40.3 SpentAgentFeedSystemstrainerSwillbetreatedon-@sg
Autoclave Subpart X Treatment Unit during the Secondary Waste
146. 2,2,2.41.2 - These also need to be sampled and analyzed for organics to verify they
are below the regulatory and feed rate concentration. How will this waste stream be
managed, on-site or off-site?
This waste stream will be land disposed at an off-site Subtitle C TSDF. Paragraph
2.2.2.4t.2 is revised to read:
2.2.2.41 .2 Representative samples of the discarded strainers are arralyzed for agent
fand TCLP metals, including the analytes specified in Table 24a a;w!
L TCLP orsanics. Samples from each of these two waste streams are
collected once during each agent campaign.
147. 2.2.2.42.2 - Please spell out Lewisite and specify '6...and Lewisite transparency ton
containers.tt
Paragraph2.2.2.42.2 is revised to read:
2.2.2.42.2 Three (3) M nitric acid is used to rinse out the Lewisite Ton Containers
after they are drained oftheir agent fill and to etch the interior of
Transparencv Ton Containers. The acid's strength is diminished after
use. Based on bench scale testing the concentration of Lg14jg[g in the
weakened acid is greater then the WCL. The addition of 3 M or greater
strength nitric acid drives the Lglqilg concentration to below the WCL.
The waste -eodes anticipated to be applicable to this waste steam are F999,
D004, D007, D008, D009, and D010.
148. 2.2,2.42.3.- The word "metals" prior to 6'TCLP metals" should be deleted. Will this
waste be disposed on-site or off-site? What mechanism will be used?
The suggested revision is incorporated into the revised Attachment 2 included with this
submission.
Page 49 of 107
The Spent Nitric Acid Tank strainer will be disposed of off site (i.e., at a Subtitle C TSDF)
provided the agent screen results demonstrate that the lewisite concentration is below the
WCL.
149. 2.2.2.43.1- The decontamination procedure using 18% NaOH (GA) and 3M nitric
acid must be performed a minimum of three times prior to rinsing with water.
See response to DSWH comment # 88.
150. 2.2.2.44.3 - Please change TCLP to totals (total metals and total organics) since the
disposal is direct feed incineration.
The suggested revision is incorporated into the revised Attachment 2 included with this
submission.
151. Table 2-0 and Table 2-1 - information will need to be updated once all comments
have been negotiated. All LOPs will need to be validated and approved by the
Executive Secretary.
The TOCDF concurs with the need to revise the above-referenced tables once the GA and
lewisite Laboratory Operating Procedures (LOPs) are developed, and validated and
approved by the Executive Secretary. The TOCDF intends to submit the LOPs as they
become available through Class I Permit Modification Requests (with approval) as has
been done in the past during agent campaign changeovers when new procedures were
required b ecause of pro cessing different agents.
152. Table 2-A-2c and2-A-Zd - These should indicate draft or preliminary data (please
add a footnote indicating additional sampling is required). The solids and liquid
table should be called a different number or they should be next to each other in the
plan.
The TOCDF does not concur with the need to perform additional organic analysis of
Agents GA and lewisite since the analytical results provided with the ATLIC permit
modification request provided sufficient characterization based on the planned
performance test demonstrations. The TOCDF proposed to sample and analyze the
lewisite transferred to the agent tank for metals to ensure compliance with the metal feed
rates. The results of the Surrogate Trial Burn and compliance with the AWFCO setpoint
ensure compliance with the Destruction and Removal Efficiency (DRE) performance
standard while processing lewisite, which is less difficult to destroy than the selected
surrogates.
Attachment 3 - Main Body Permit Mod (Sampling, Analytical & QC Procedures)
153. Please submit changes to the CDRL 24 for inclusion into this Class 3 Permit
modification for GA and Lewisite.
A revised CDRL 24 wtll be provided shortly after this submlsslon.
Page 50 of 107
Attachment 4 - Main Body Permit Mod (Security Procedures)
154. 4.1.1.- Please change to read, "Security at all EG&G operated facilities at the DCD
shall meet the criteria..."
155.
157.
The paragraph is revised as suggested.
4.1.2 - Please change to read, o'...in effect at all EG&G operated facilities at the DCD,
the DCD installation provides..."
The paragraph is revised as suggested.
4.1.2. - In the second line after "Chemical Surety Restricted Area" the term oo(i.e.,
Area LO)'o is all that is needed. These changes make the wording in these paragraphs
more general for all EG&G operated facilities and remove the need to constantly
alter these paragraphs every time a new unit is added to the permit somewhere else
on the DCD property.
The paragraph is revised as suggested.
4.1.3. - This paragraph can be deleted, it is not needed.
The paragraph is revised as suggested.
158. 4.3.1. - This paragraph should read, "Continuous surveillance is accomplished by
security patrols. Overall administration of security personnel is performed by the
Chief, DCD Security office."
The paragraph is revised as suggested.
159. 4.5.1. - This paragraph should read, "Visitor access within the separate, fenced,
perimeters is controlled by 24-hour guarded gates. Visitors are accompanied at all
times during their visit to the facitity and are subject to security checks."
The paragraph is revised as suggested.
160. 4.5.2. - This paragraph should be changed to readr "...routinely work in the EG&G
operated facilities, picture identity badges.. . "
The paragraph is revised as suggested.
161. 4.5.5. - This paragraph should be changed to read, "Pedestrian access is controlled
by a..."
The paragraph is revised as suggested.
Page 51 of 107
162. 4.5.6. - This paragraph should be changed to read, "Vehicle access is controlled by a
continuously guarded gate at each area. When a vehicle requires entry, all
occupants...t'
The paragraph is revised as suggested.
163. 4.5.7. - This paragraph should be changed to readr "...during their time within the
facilities."
The paragraph is revised as suggested.
Attachment 5 - Main Body Permit Mod (Inspection Plan)
164. Table 5-1 - Under the heading, "Storage/Treatment Units" the cells in the
"Frequency Inspection Method" column for ACS tanks need to be merged with
ATLIC tanks. The cells in the same column for SDS tanks also need to be merged.
Please list the individual PAS units, (e.g. carbon injection, baghouse, etc.) in the
ancillary equipment section.
Table 5-1 was revised to merge the cells as suggested. However, individual PAS process
units were not added to this table because it was intended to provide a summary overview
of the inspection requirements. Additionally, the PAS of the TOCDF and ATLIC
incineration systems are different, which would require two separate listings. Note that the
individual PAS process units are identified in the inspection tables that are specific to the
incineration PAS requiring inspection (see Tables 5-15 and 5-33).
165. Table 5-2 - Agent monitors are every four hours instead of daily (Table 5-34 is
correct). The UPS and Security do not have a frequency specified.
The table was revised to specify that agent monitoring challenges occur every 4 hours or
daily, and a reference to Table 5-24 is added. The UPS inspection is specified as monthly.
Regarding Security, the ATLIC is within the boundary of U.S. Army Deseret Chemical
Depot (DCD) Area 10. The ATLIC uses the security fence, warning signs, and lighting
that are provided for Area 10 to prevent entry by unauthorized personnel. There is not a
fence that surrounds the ATLIC itself.
166. Table 5-32 - The fixed roof and closure devices of the TOX tankS shoirld be checked
weekly.
Table 5-37 specifies an annual inspection of ATllC:regulated hazardous waste storage
and treatment tanks fixed roofs and closure devices. The frequency requirements are the
same as those specified for the same tank features associated with the permitted hazardous
waste storage tanks in the TOCDF TOX.
The TOCDF does not concur with the need to increase the frequency of this inspection by
52 times considering that the integrity of the fixed roofs of the ATLIC tanks will be
inspected prior to use, the tanks will be in service for months rather than years (as is the
Page 52 of 107
O
case for the TOCDF tanks), and the ATLIC is operated under the engineering controls
provided by the ATLIC cascading HVAC ventilation system, which vents to multiple
carbon filter units.
167. 5,4.3.1. - There are sumps in the ATLIC that need to be included in the narrative.
The inspection log sheet found in Attachment 5 "Inspection Log Sheets" onpageD-2l
lists the sumps that are regulated because any liquids that accumulate in them maybe
pumped to a permittedhazardous waste storage tank. The four sumps identified on the
inspection log sheet are ancillary equipment to the permitted Spent Decontamination
System Tank located in the ATLIC Toxic Area, and they are inspected daily for
accumulated liquids.
Paragraph 5.5.3 is revised to read:
5.5.3 Storage/Treatment units and their associated secondary containment systems located
outside the MDB and inside the ATLIC TOX Area undergo a dail! physical visual
inspection. ATLIC sumps are insoected dailv for accumulated liouids.
Note, there are seven other sumps located in the ATLIC (for a combined total of 11
sumps) that would bd used to collected wastes released from tanks that are operated as 90-
day accumulation tanks. These seven sumps cannot be drained to a permitted storage tank,
but must be drained using a portable sump pump or vacuum truck. These sumps are not
ancillary equipment to any permitted hazardous waste storage tank and, therefore, are not
referenced in the TOCDF RCRA Permit.
168. 5.9.2. - The acronym *ATLIC' is misspelled at the end of the fifth line.
The correction to paragraph 5.9.2 is made.
169. Tables 5-31 & 5-35 - Please replace ttobserve" with "document." Please add "ton
container or waste.t'
Rather than replacing the word
inspection criteria was revised
waste" was added.
"observe" with the word "document," the wording of the
to read "Observe and record". To Table 5-3 1 the term "or
170. Table 5-32 - The frequency of the Waste Feed Cut-Off test needs to be every seven
days, not 30 days.
See response to DSHW comment # 4 and#63.
171. Table 5-33 - The baghouse section should include bag inspection for rips and tears.
This suggested inspection criterion was not added to Table 5-33. The function of the
fabric filters within the Baghouse is continually evaluated by the instrumentation that
measures the differential pressure (dP) across the Baghouse. There is a regulated AWFCO
Page 53 of 107
that occurs when the dP across the Baghouse is too low. A lower than expected dP across
the Baghouse indicates loss of fabric filter integrity (e.g., a tom filter element, loss of a
filter element).
Additionally inspection of the bags would require either that the baghouse be bypassed
during the inspection or that the incinerator be shutdown.
172. Table 5-34-35 - Please change the word "observe" to document."
See response to DSHW comment # 169.
173. Page D-28, and M-13, Items 2a,2b, and 2d - The second "ATLIC PCC" should be*ATLIC SCC."
The suggested correction is included in the revised attachment provided with this
submission.
174, PageD-2g - "TOCDF PAS'should read "ATLIC PAS."
All references to PAS are correct to read ATLIC PAS
175. PageD-32 - The first paragraph should be number 1. Footnote 2 should be 0.2 VSL
for GA for early control. It is unclear exactly how the HVAC will be monitored.
Please provide specific details on rotation, challenging, switching units, etc.
The TOCDF does not concur with the use of a 0.2 VSL alarm point for the Filter Unit
Vestibules. The proposed alarm point of 0.5 VSL is still set at half the VSL, which is a
conservative alarm setting considering that the VSL is equal to the STEL, but the VSL is
not a time weighted value - it is based on a single NRT sample/analysis cycle.
A 0.5 VSL is also selected to ensure that the alarm value is not impacted by interferents
that may be present.
See response to DSHW comment # l}g for a discussion on the monitoring associated with
the ATLIC HVAC system.
176. PageD-32, note 2 - It looks like the last two columns should be using notes 3 and 4,
not 2 and 3. The agent monitoring plan should be22a, or just specify the values. Is
spooling performed (vestibules)? How is it documented? What does the heading(DAAMS only station" mean for documentation? It could be indicating an alarm if
the reviewer didn't know it was a DAAMS-only station.
The footnote references are corected as suggested, and a reference to Attachment 22ais
added. Note 2 on page D-32 says that the filter unit vestibules are monitored with
DAAMS that are used at specific locations. (i.e., spooling is not applicable to DAAMS).
The heading "DAAMS Only Station" refers to the sampling locations in each filter unit
that are monitored by DAAMS only when the filter is online; these locations are the
vestibule, after the second carbon bed, and after the third (i.e., the final) carbon bed.
Page 54 of 107
If an entry to a filter unit is required, the filter unit is taken offline. Additionally, if an
entry to the filter is required, the NRT is spooled from the current post-bed monitoring
location to monitor the vestibule prior to the entry.
177. PageD-27 - Please add room for printing the inspector's name and signature.
The referenced form included in Attachment 5 - Inspection Logs is revised as
recommended.
178. Inspection Logs - All the headers will need to be redone on the newly added
inspection log sheets so that they are correctly formatted like the rest of the headers
in the document.
The reference to "headers" is assumed to refer to the header on the page that shows the
attachment name, attachment number, and date of revision. The attachment in question
has historically been formatted to have different dates in the header based on when a
particular form was added to the attachment. The TOCDF concurs that the final permit
issued by DSHW will require headers on the newly incorporated inspection forms that are
formatted similar to those that were in the attachment prior to the revision. However, this
change in formatting cannot be completed until the data of issuance is known. Therefore,
no change was made to the document included in this submission to address this comment.
179. Page D-33, item lc - The word ttnot" between the words $are" and ttleakingt' should
be deleted.
The referenced form included in Attachment 5 - Inspection Logs is revised as
recommended.
180. Page M-12, note l. - Please explain why the DSHW letter and date is included?
Please insert the required information.
The DSHW letter reference is deleted. The requirernent specified in the letter is shown on
the form in bolded text as follows:
If the inspection cannot be performed due to residues in the sump, the residues must
be removed to complete the inspection
181. Pages Q-6, Q-7, Q-8 - Please change to monthly.
The referenced pages are the inspection forms for the semi-annual and annual inspections
applicable to the ATLIC fire protection systerns, the annual inspection applicable to the
ATLIC Emergency Power Systems, and the annual inspection applicable to the ATLIC
Toxic Areahazardous waste storage and treatment tanks.
The TOCDF does not concur with the need to increase the inspection frequency associated
with the referenced systems. The inspection frequency currently specified for these
ATLIC support systems andhazardous waste storage tanks is identical to that specified for
Page 55 of 107
the corresponding TOCDF support systems andhazwdous waste storage tanks. The
components of ATLIC systems must comply with the same design specifications as the
corresponding TOCDF system in regards to reliability. The TOCDF is unaware of
reliability issues with the selected components that comprise the ATLIC systems that
would merit a l2-fold increase in the inspection frequency.
The TOCDF is unaware of any data that show a need to increase the inspection frequency
of the components of the above referenced systerns. If DSHW has access to such
information, please provide it to TOCDF, and we will make the necessary adjustments to
the inspection frequencies.
No changes were made to the referenced inspection log sheets and inspection frequencies
as a result of this comment.
Attachment 6 - Main Body Permit Mod (Instrument Calibration Plan & Incinerator Waste
Feed Interlock Function Test
182. 6.5.2.1 - Please provide the documents for approval. When are they anticipated to be
available?
The procedure will be available before the beginning of systernization.
Paragraph 6.5.2.1provides reference numbers for the on-site operational procedures used
to test incinerator AWFCO systerns. The exiting procedure, which is applicable to the four
TOCDF incinerators, is not a TOCDF RCRA-controlled procedure. These procedures are
available for review whenever a DSHW representative is on site. DSHW representatives
can observe the performance of AWFCO system testing whenever they choose. The
TOCDF typically demonstrates the AWFCO system testing for DSHW before beginning
an agent campaign.
183. 6.5.7.1., 6.5.8.1, and 6.5.10.3 - It should be tested weekly instead of monthly.
The above referenced paragraphs are revised to read:
6.5 .7.1 The frequency at which the testing of the waste feed interlock
system of the ATLIC incinerator occurs is at least once every !l3e
days (unless the incinerator is idle and does not process waste for
lonser than 14 davs or shut down) or at the beginning of each
agent campaign, which ever is shorter@
the shert drratien ef the ineinerater's hazardeus waste eperatiens; 2)
ine
the manual methed; and 5) the need te dsnenstrate the preper
ip
Page 56 of 107
\,3r,
r*$
x
6.5.8.1 The frequency of testing of the overtop protection systan of each
.. ATLIC tank is at least once every lzpe days ffi
The frequency at which the"funotion test occurs which is specified
as once every 14 days or +gZdays, as indicated in Section 6.5.1.
''--,'t'i'184. Table 6-E -. The carbon injection feed and airhow must have information specified.
The baghouse and carbon filter delta pressure frequency should be weekly. It needs
to specify back-up monitors on the HVAC. DAAMS line challenges on the HVAC
will be weekly.
Values for instrumentation associated with the carbon injection system have been added to
Table 6-E.
Regarding the proposed accelerated calibration schedule for Pressure Differential
Indicating Transmitters (PDITs); this same type of instrument is used to measure regulated
operating parameters on the TOCDF incinerators. The calibration for these instruments
has been 360 days throughout the operational life of TOCDF. The instruments have
proven sufficiently reliable to support a 360-day calibration frequency; otherwise, TOCDF
would have accelerated the frequency of calibration based on past necessary adjustment
trends.
The TOCDF is unaware of reliability issues with the PDITs selected for the ATLIC
application tl;art are so extreme as to require an increase of 52 times in the calibration
frequency. If DSHW has data that show a need to increase the calibration frequency of
PDIT instrument, please provide it, and TOCDF will make the necessary adjustments to
the calibration frequency.
References to the HVAC backup agent monitors are also now included in Table 6-E.
Regarding the DSHW proposal to increase the sample line challenge for ATLIC HVAC
DAAMS from every 60 days to every 7 days; TOCDF is aware of issues regarding lewisite
transmission down sample lines. Therefore, TOCDF has conducted Precision and
Accuracy (P&A) studies on the MINICAMS that are configured to monitor for lewisite,
which require the use of 1, 2-ethanedithiol (EDT) to transmit the lewisite down the sample
line to the monitor. These results will be provided to DSHW prior to final permit issuance.
The.TOCDF has not yet conducted P&A studies for lewisite DAAMS, which do not use
EDT in the sampling line for lewisite transmission. These studies, in combination with the
sample line challenges that will occur when the systems are installed in the ATLIC
HVAC, will provide data that can be used to determine whether a more frequent sample
line challenge is necessary. Note that the instrumentation will be installed and operated
approximately nine months before it is needed for lewisite monitoring, so sufficient data
will be available in enough time to allow for changes in the sample line challenge
frequency prior to lewisite operations if it is determined, from the data, to be necessary.
6.5. 10.3
o
t
,
Page 57 of 107
186.
Attachment 7 - Main Body Permit Mod (Training Plan)
185. Table 7-1 -Will the CAMDS lab and monitoring personnel perform duties for, the
ATLIC? Is the TOCDF CAL lab not performing analytical duties for the ATLIC?
Please specify, for the ATLIC personnel, the location of generic personnel (e.g. junior
chemist).
The ATLIC laboratory personnel (e.g., Junior Chunist) will be performing their duties at
the CAMDS Site Analytical Facility (SAF); other positions will perform duties at the
ATLIC site.
All duties for the ATLIC will be performed by ATLIC personnel, designated in Table 7-1
by a CD (which stands for CAMDS DCD) before job title (e.g., CD Instrument
Technician). The CAMDS Site Analytical Facility (SAF) will handle ATLIC analytical
duties.
Please add "CDt'to the acronym list on page23.
Completed
187. Table 7-2 - Needs the words *TOCDF Personnel" in a row above the General
Manager job title.
Completed
188. Table 7-2 -The words (ATLIC personnel" are used in Table 7-1 and "GA"/Lewisite
personnel" are used in Table 7-2. Please be consistent in terminology.
Completed using "ATLIC personnel"
189. Table 7-2 - Why are the Senior Lab Support Tech, Control Center Operator, and
Electrical Tech the only personnel required.to have Toxic Area Training?
Added X in TAT column for GA/Lewisite Mechanical Technician job title as a person in
that position could perform entries. Two other job titles require TAT: Conhol Center
Operator and Controls/I&C/Electrical Technician, and they are marked in the appropriate
TAT column. The rest of the job titles are not positions that perform entries and,
therefore, do not require TAT. (The Senior Lab Support Tech position is being eliminated
and has been deleted from the table.)
Attachment 8 - Main Body Permit Mod (Preparedness and Prevention Plan)
190. 8.1.2.1- Please include ATLIC information.
Section 8.1.2 discusses aisle space that is maintained in permitted container storage
locations to allow for the inspection of containers. There are no permitted container
storage locations at the ATLIC facility. Therefore, no reference to the ATLIC is made in
this section of Attachment 8.
191. 8.2.1.4.1- Please include narrative to indicate that it will be characterizedlanalyzed
and monitored for agent.
Page 58 of 107
The paragraph is revised to read:
8.2.1.4.1 Waste at the ATLIC such as residue from the Pollution Abatement Systern
(PAS) particulate removal device. and exoended PAS carbon filters and
HEPA filters used in the PAS will be @
sampled
and analvzed for aeent content per the requirernents in the Attachment 2
(Waste Analysis Plan)rreret. Ooerators handling waste will wearthe
appropriate level of PPE. Al[ waste is pl.aced in containers that meet or
exceeds the requirernents stated in R315-8-9.3 and R315-7-16.3.
192. 8.2.4.1.9.2 - Please provide the differences and similarities of the FCS and PDARS.
The Process Data and Recording System used at the TOCDF is a data loggtng system that
records data that can be retrieved through a series of"canned" or custom reports. The data
can be reviewed to investigate problems with incineration operation or to demonstrate
compliance with regulated operating parameters. The TOCDF PDARS is solely a system
that records data provided by the process controllers that control the automated steps in the
demilitarization process (e.g., the incinerator AWFCO System).
The ATLIC Facility Control System (FSC) is a distributed control system similar to that
used at the TOCDF, but comprised of more up-to-date hardware. The FSC will generate
' " 'data, througiibut its operation, that will also be recorded by a data acquisition system
independent of the TOCDF PDARS. Data from the ATLIC systern will be able to be
retrieved in a similar manner as it is from the TOCDF PDARS.
193. Add sectio n 8.2.4.2.2. Please indicate.that the ATLIC incinerator has an automatic
waste feed cutoff system as specified in Attachment 19, Table D-8-2.
Paragraph 8.2.4.2.2.L 1 is revised to read:
8.2.4.2.2.1.1 All incinerators. includine the ATLIC. have automatic waste feed' : cutoffs)rsterns as specified in Attachment 19 (Instrumentation and' Waste Feed Cut-OffTables).
194. Please replace the bection heading 8.2.4.2.2.1.2 with section heading 8,2.4.2,2,1.
See response to DSHW comment # 193 above.
195. 8,2:6,3- "Should be t'each area's". How is the sump leak detected and reported to
the CON-OP?
The suggested correction is made. Sumps that are ancillary equipment to the permitted
hazardous waste storage and treatment tanks (i.e., sumps whose content can be pumped
directly to the tank because piping is provided to link the sump to the tank) are equipped
. with interstitial leak detection probes. These sumps are of a similar design to those located
Page 59 of 107
at the TOCDF. The status of the leak detection probes is observable from the Control
Consoles located in the Control Room.
196. 8.2.7.2 - Please add Attachments s22 and22a.n
The suggested correction is made to paragrap h8.2.7.2
lg7. 8.2.7.3- Please change all references in this paragraph from GB to Gseries if
applicable.
Paragraph 8.2.7.3 is revised to read:
8.2.7,3 In addition to the agent monitoring equipment, detector paper may
be used as a confirmatory test for identifyrng G series, VX, and H
series agents in suspect liquids. This paper does not detect vapors
or extremely small droplets of GBG series. VX, or mustard agents
and may change color in the presence of other chemicals.
. ,{.'198. 8.3.6.2 - GA should be transferred to a tank and not direct fed to determine
chiracterization of the feed prior to feeding to the LIC. Also, the sludge remaining
after a liquid transfer must be sampled and analyzed.
See response to DSHW comment # 9.
Attachment 9 - Main Body Permit Mod (Contingency Plan)
199. 9.1.4.9.- The Iast sentence does not end properly. It appears text is missing.
Paragraph 9.1.4.9 is revised to read:
9.1.4.9 The ATLIC Fire Detection and Protection consists of a Fire Alarm
Control Panel (FACP) located in the Area 10 Control Point facility
ATLIC CCEE. The FACP reports to the TOCDF CON and the
DCD Fire Department. The fire detection. internal alarm and
central reportine systems are configrured in accordance with NFPA.
Drawins EG-22-K-8201. Sheet 1. brovides a complete description" and list of ancillarv equipment to the Fire Protection Svstem.
200. Table 9-1-1- Please include SAF lab.
The SAF equipment that is supported by emergency power is included in the revised table.
Additionally, the table was revised to list that, generally, ATLIC ACAMS, MINICAMS,
and DAAMS are provided with emergency power.
201. 9.2.2.10.1. - This paragraph states that the TOCDF is the primary medical care
facility for agent related events at the DCD. Is this correct?
Page 60 of lA7
202.
203.
204.
It is correct that the TOCDF Clinic is the primary medical facility for the entire depot
(DCD included).
9.4.2.7.1- Please discuss Ll,Lz and L3 and reformation to back to Ll.
The referenced paragraph discusses the physical, chemical, and toxic properties of lewisite.
A paper titled "Processing of Lewisite Munitions in the Explosive Destruction System," by
Tricia Weiss, Chemical Materials Agency; John Didlake, Sandia National Laboratories;
Tim Shepodd, PhD, Sandia National Laboratories and Robert Bradshaw, PhD, Sandia
National Laboratories, dated March 2,2005 explains:
Lewisite has a complex chemistry, presenting several challenges in developing a
destruction process suitable for application to the EDS. The first challenge is with
the characterization of Lewisite. Lewisite is actually a complex mixture of several
compounds, all of which occur as trans-, cis- and gern- isomers. In munitions-grade
Lewisite, the trans-Ll isomer typically predominates. The three homologues (L1,
L2, and L3) form because Lewisite is produced by the catalyzed reaction of arsenic
trichloride and acetylene. The Ll forms initially, but it will react with some of the
acetylene to form L2, which will in turn react tq form.L3. In munitions grade
Lewisite, Ll is the vesicant agent, but L2 aiid L3 are also toxic. Munitions-grade
Lewisite is characterizedby specification as a minimum of 87%o Lewisite content' by weight, and a maximum of 4% arsenic trichloride content by weight.
No distinction between Ll,Lz, and L3 were made in paragraph9.4.2.7.l because each
isomer is equally toxic, and all are contained in the lewisite mixture. The hazards and
precautions associated with lewisite management are the same regardless of the chemical
structure of the lewisite molecule. Therefore, no change was made to paragraph9.4.2.7.l.
9.4.2.7.2.1. - The word "signs" is misspelled at the beginning of the fourth line.
The suggested correction is made to paragraph9.4,2.7.2.l
9,5.3,7.1.- This paragraph t:ilks about decon solutions for GB and VX. Is this
correct or should this be GA and Lewisite? References to GB, VX and Mustard
should be deleted from the ATLIC paragraph. Please specify which decontamination
solutions will be in the two storage tanks.
The pdragraph is revised to read:
. 9.5.3.7.1 The ATLIC would also be suoported by the TOCDF Emergency Response
teams should a laree spill occur. ATLIC has additional spill response and
decontamination equipment and resources located in the immediate
vicinity. There aretnretanks is one tank at the ATLIC for storaee of the
decontamination solution (187o NaOH solution) ffi.
Truck mounteddeqontamination units with decontaminants fer€B*QC
andawtar&agenti;are available at Area l0 to supDort ATLIC. These are
maintained by'Deieret Chemical Depot Ammunition Storage Division for
ATLIC and munition storagq missions.
Page 6l of 107
205.Figures - There is no figure showing the eyewash locations, fire extinguishers and
evacuation routes for the ATLIC. Please provide in hard copy and electronic
version.
A figure showing the exits applicable to the ATLIC has been included in the revised
Attachment 9. Figure 9-7-35 shows the evacuation routes for DCD, to include Area 10.
The TOCDF Conhol Room will direct the evacuation route from the ATLIC within Area
10 based on wind direction as reported from the DCD Emergency Operations Center
(EOC). Fire extinguisher locations are not shown on the drawing because none are
planned. Rather, the ATLIC is equipped with a Fire Protection System that includes
sprinklers to extinguish fires.
206. Table 9-5-1- Please add SAF and DCD Operations (Area 10) to emergency
.l .;..opeTations. Why is the radio network deleted for TOCDF daily operations?
The SAF and CAMDS do not have radio systems; communication is by telephone only.
The DCD is referenced in the footnote to Table 9-5-1. The section that was crossed out
was deleted because information in the deleted section was applicable to daily operations
and not emergency situations.
207, 9.5.3.7.1 - Please explain how the two additional tanks for spent decon will be ready.
Which decon will be used for each agent?
The decontamination solution in the tank could be used to address spills within the
ATLIC. Note that the decontamination solution for Agent GB is 18 % NaOH. This same
decontamination solution can be used for lewisite; however, the resulting reaction liberates
acetylene. The NaOH can be used to decontaminate lewisite only if the lewisite is present
at low concentrations. As an example, the addition of 18 % NaOH is planned to lower the
concentration of lewisite in the TC rinse water that will accumulate in the ATLIC Spent
Decontamination System Tank to below the WCL. The NaOH can be used for this
application because there is insufficient lewisite in the rinse water to cause an acetylene
concentration of concem. The TOCDF is currently investigating different types of
decontamination solutions that could be used for lewisite.
Attachment 10 - Main Body Permit Mod (Closure Plan)
208. Table I-1-1 - The Closure Plan needs to be updated.
See Responses to DSHW comment#24.
Attachment 11 - Main Body Permit Mod (General Facility Drawings)
209. Pages 14 & 15 - Please update drawing per narrative.
A revised set of drawing and revised Attachment 11 are provided with this submission.
Attachment14 - Main Body Permit Mod (Demil Miscellaneous Treatment Units)o
Page 62 of 107
Several paragraphs have the word *value'in place of the word ('yalve."
The word "value" is replaced with the word "valve" where applicable.
14.10.4.1. - An tts' needs to be added to the word ttroller" at the beginning of the
fouth line. How is the ton container rhanually moved? Please provide narrative for
the conveyor and movement from storage igloo.
The transfer table is equipped with a motor that moves a TC into the glove box. The TC
contacts a bearing-like roller in the glove box, which reduces friction to the point that the
TC can move out of the glove box by manually pushing it. With the aid of a motorized
wheel that contacts the bottom of the in-place TC, the same rollers are used to rotate the
TCs while it is in the glove box. Paragraph 14.10.4.1is revised to read:
14.10.4.1. There are no conveyors associated with the ATLIC gloveboxes.
Ton containers are moved into and out of the eloveboxes by beine
placed on a cart referred to as a "transfer table". The ton container
is manually.moved from the transfer table and placed upon multi-
directional rollers that are used to move a ton container (alons
its axis) in and out of ud*i? the elovebox. The same rollers are
used to rotate the ton container around its axis rellers.are+sod
during the rinse orocessing step to rotate the ton container to vAi€h
allows for its entire interior surface to be contacted with the
differerrt rinse solutions.
'/.,4.10.6.'/.,. - An '(s" needs to be added to the word "containertt near the end of the
sixth line. The "a'prior to the words 6'storage tankst' on the eighth line should be
deleted.
The referenced paragraph is revised as suggested.
14.10.7.1- Explain how spilled wastes will be removed from the glove box.
The paragraph is revised to read:
14.10.7.1. There are no strmp pumps associated with the elove-box hazardous
.waste manaeement units. Solutions accumulating within a slove-
box. as a result of a spill and associated decontamination. can be
transferred to a container bv openins a drain line located in the
bottom of the slove-box.
14.10.8.1. - An 6's" needs to be added to the word "container" at the beginning of the
second line. Please change the word ttthere" to "they" on the second line. Please add
an 65s" to the word t'material" on the last line.
The paragraph is revised to incorporate the suggested cha4ges.
14.10.11.1. - Please replace the word "then" in the fifth line with the word "they."
Page 63 of 107
The paragraph is revised to incorporate the suggested change.
216. 14.10.12.1- The word 66the" between the words "from" and "each" on the first line
should be deleted. The narrative is confusing. If each glove box is ducted to the
HVAC, why is the phrase "ultimately vents" specified?
The paragraph is revised to incorporate the suggested change. The word "ultimately''is
deleted.
217. 14 10.15. General Operating conditions. How do we know that insoluble
solids/sludges are actually being rinsed during the GA TC rinsing process? Are there
any other verification processes? Same question for Lewisite ton containers.
The GA TCs were assayed for solid heels during the GA/L Ton Container Sampling
Program. The results were provided as Attachment 3 of the Class 3 Permit Modification
Request for the ATLIC.
The lewisite TCs were also assayed and found to contain a small sludge layer that adhered
to the inside bottom of the TC. Samples of the sludge layer were obtained.
The rinsing process is intended to remove any non-liquid matrices. If sludge residue
remains after the rinse process, these solids would be removed at the end of the process
when the TCs (GA, L, and Transparency) are cut open. Once cut, the pieces will be tented
and monitored for the agent of interest. Cutting the TCs also provides access to their
interiors. The TOCDF plans to rernove the TC valves, plugs, and eduction tubes at this
time. [n addition, solid residues that do not adhere to the interior of the TC, including
discarded sampling equipment, will also be removed and containerized after the TCs have
been cut in half.
218. 14.1015.2 - GA should be pumped to a tank prior to processing as discussed
previously.
The TOCDF does not concur with the need to transfer the GA from the TC to an
intermediate storage tank before it is processed in the PCC of the ATLIC. See response to
DSHW comment # 9.
219. 14.10.15.6. - Delete the "s'o from the word o'fills" in the third line. The SDS will need
to be sampled, analyzed and verified so it can be processed in the SCC. If not, it must
be processed in the PCC.
The proposed changes to Attachment 2 of the TOCDF Permit require the sampling and
analysis of the spent decon prior to feeding it to the SCC of the ATLIC. Additionally, an
organic screen has been added to the analyical parameters for spent decon, and the
Surrogate Trial Burn Plan has been revised to require spiking the wastes fed to the SCC
with an organic compound during the testing.
Page 64 of 107
220.14.10.15.9. - Please delete the')" after the acronym "TSDF" in the fourth line. See
comment on,SDS in Section 14.10.15.6. Organics will need to be analyzed and be
below the limits verified in the SCC during the surrogate trial burn.
The paragraph is revised to incorporate the suggested change. See response to DSHW
comment # 219 concerning spent decon feed to the ATLIC SCC.
221, 14.10.15.10 & 11 - All transparency tons must go through an approved
decontamination process and then may be head-spaced.
The TOCDF initially proposbd to only rinse with nitric acid solution those Transparency
TCs that headspace monitoring found to be contaminated with lewisite. The TOCDF has
revised Module VIII and Attachment 14 to require all Transparency TCs to be rinsed out
using one nitric acid solution rinse followed by three water rinses. One acid rinse is
determined to be sufficient for Transparency TCs based on the borescope assay conducted
on each Transparency TC during the GA/L Sampling/Analysis effort. The borescope
results showed that there were no solid heels or residues inside the Transparency TCs.
Pictures obtained by the borescope assay are provided as Enclosure H. Paragraphs
14.10.15.10 and 14.10.15.11 are revised to read:
14.10.15.10. , All Transparencv TCs underso ,one Nitric Acid rinse followed bv
three water rinses. Each rinse consists of fillins bv more than
half wav (approximatelv 110 eallons) the emptied TC with the
- ...*,-i"'-l--i rlnse ioiutirih and rotatine the TC for a minimum of one hour.
i)dia-r(
14.10.15.11. Tran'Bareney T€s th* re at Breugr samnle eelteeti ine
ReServed.
222. 14.10.15.11. - Please delete the word "are' prior to the word "undergo" at the end of
the second sentence.
Paragraph 14.10:15.11 is deleted. See response to DSHW cotnnent22l.
223. 14.10.15.12. - Please change the word "transfer" to "transferred" in the last line.
The par?graph is revised to incorporate the suggested change.
224.14.10.19 - The heading should be "Agent Monitoring Procedures". Additional waste
characterization will be required.
The section heading is revised as suggested.
225. 14.10.19.1. - Please delete the 66s" from ttTCs."
Page 65 of 107
226.
227.
228.
The paragraph is revised as suggested.
14.10,19.2- Please provide specific details of the treatment by rinsing with three
rinses of decon followed by three rinses of water.
The details of the rinse process for GA, lewisite, and Transfer TCs is specified in the
proposed permit conditions found in Module VIII.
14.10.19.34 - The section number should be 14.10.19.3. < 4.0 YSL should be < 0.4
VSL. Also, please add a minimum of two complete monitoring cycles.
The paragraph is revised to read:
14.10.19.34. TCs are removed from the elove-box based on results obtained from the
monitorins of the interior of the elove-box. For GA TCs. slove-box
monitoring results of < 02 0.5 VSL allow for the TC to be removed from
the elove-box. For Lewisite TCs. glove-box monitoring results of < 4+ 0.4
VSL allow for the TC to be removed from the glove-box. These
monitorins criteria for removine TCs from a slove-box are based on
monitorine results obtained from two sample/analvsis cvcles of the
Near Real TimeMonitor or one complete cvcle preceded bv a purse cvcle
to ensure the samole line is filled with the intended sample.
14.10.20.1- Please add an *s'to the word "container' at the beginning of the last
Iine and after the word "ton'in the first line of the first bullet. See previous
comments on transparency tons and decontamination procedures. Previous
headspace monitoring is not applicable, they must first go through an approved
decon procedure prior to agent monitoring. Additional waste analysis is required for
waste characterization. Waste codes specified may not be the only ones. Analysis
will determine the correct codes.
The suggested revision is made. Additionally, TOCDF concurs with the need to treat all
Transparency TCs in the same manner, regardless of the previous headspace monitoring
results. The third bullet in paragraph 14.10.20.1 is revised to read:
1 ,l..i i; *,*l'i' 'i. .i' i ,,1i: , ,".'"'*..'i Up to ten ernpty ion containers. which are referred to as "Transparency Ton
a Containers". These TCs undergo one Nitric Acid Solution rinse followed bv
three water rinses. havebeen detefmined
te saffrple' Transpareney T
I ewisite based en
.
229. 14.10.23.1,1-The narrative is confusing. Please separate out the section for the
ATLIC and the igloos.
Page 66 of rc7
The parugraph is revised to read:
14.10.23.1.1.
A.+er apprevat ef eartial eto
. The slove-boxes will be
closed as individual Ilazardous lYaste Manaeement Units
(HWMU) bv disposal as hazardous waste debris/waste
230. 14.10.24.2.1. - The last line should be reworded as follows; "...transfer lines are
detached and removed from the ton container yalves.tt
The paragraph is revised to read:
14.10.24.2.1. The gJove-box provides secondary containment for the ton container
beins treated. The sealed desiqn of the qlove-box controls both air
ernissions and contains any release that may occur when the transfer
lines ffi are detached and removed from the
ton container valvestre+meried.
231. Attachment 14 general cornment - A table of sensors with critical sensors designated
should be added to this attachment for the glove boxes.
The ATLIC TC draining and rinsing is a manual process that is managed by local
. operators; it is not managed remotely. Therefore, no sensors are associated with the glove
boxes (see P&ID drawings EG-22-D-8212 and -8213).
Attachment 16 - Main Body Permit Mod (Tank Systems)
232. 16.1.2.2. - The term 66SDS tanks" in the next to last line should be "SDS tank"
because there is only one.
The suggested correction is included in the revised attachment provided with this
submission
233. 16.1.2.5- Please provide the tank number. Please also provide lab validation that the
acid matrix for determining agent concentration is less the WCL.
The referenced tank number (PAS-Tank-8569) has been added to paragraph 16.1.2.5. The
analytical procedures (i.e., LOPs) will be provided to DSHW as a Class 1 Permit
Moclification (with approval) prior to the start of hazardous waste operations. The TOCDF
is aware that the procedures require validation and approval by DSHW prior to the
beginning of ATLIC hazardous waste operations.
- n4. rc.2.3- The word 3'tank" should be added between the words "waste" and "that" onIt the fifth line.
Page 67 of 107
The suggested correction is included in the revised attachment provided with this
submission
235. 16.3.1. - The acronym "ATLIC" is misspelled the second time it appears in this
paragraph.
The suggested correction is included in the revised attachment provided with this
submission.
236. 16.3.6.1- GA will be fed to the tank also (see previous comments).
The TOCDF does not concur with the need to transfer the Agurt GA from the TCs to an
intermediate storage container before feeding it to the ATLIC Primary Combustion
Chamber (PCC). See response to DSHW comment # 9.
237. 16.3.6.2 - Please delete the term "empty' and replace with different terminology.
Empty may be confusing and misused.
The paragraph is revised to read:
16.3.6.2. The amount of Lewisite drained from each ton container is not
quanffied. Lewjsite ton containers are drained to the maximum
extent possible
the compressed air used to Bressurize the ton.contain€r durine
drainineblows throuqh the ton container drain valve and the cycline
of the diaohragm oumo that is used to drain the aeent increases.
which notes that there are no liquids rernaininq. in the ton contain€r
to oump.
238. 16.2.3 - Which tanks are carbon steel?
The only tank that is made of carbon steel is the tank that will hold the lewisite, which is
LCS-Tank-8511. Table 1 of the ATLIC Permit Modification Request specifies the
material of construction of each of the tanks located at the ATLIC.
239. 16.3.6.1- From previous eomments, GA is to be pumped to a tank and not directly
fed.
See response to DSHW comments # 236 and # 9.
240. 16.3.6.2 - Please provide narrative discussing the sludge left in the ton container and
how it will be managed.
This attachment is applicable to the permitted hazardous waste storage tanks. The sludge
in the lewisite TCs is dissolved to the extent possible by the multiple acid rinses. The
amount of sludge left after the acid rinses will not be completely known until the TCs are
cut in half. Note that the lewisite TC sludge samples were difficult to obtain because
minimal amount of sludge in the TCs.
Page 68 of 107
O z4t.
242.
16.3.6.6 - Please describe how often the strainers will need to be emptied and how the
waste will be managed.
The strainers are emptied based on differential pressure (dP) measured across the filter.
The strainer dP is shown on the control screens in the Control Room, and an alarm
provides notice to the operator that a strainer needs to be emptied.
Residues collected in the strainer are transferred to a waste container; the container is
sampled and analyzed per requirement specified in Attachment 2 of the TOCDF RCRA
Permit.
Sections 16.3.6.7 and 16.4.9.3 indicate that tank 8534 can be filled, as well as emptied,
with circulation pumps associated with the other tanks in the Toxic Area. Please
explain how this would be done. X'rom the drawings, it appears that tank 8534 could
only be fitled with the sump pumps since the tees on the recirculation lines are prior
to the pumps.
The descriptions in Sections 16.3.6 and 16.4.9 are revised based on a review of Drawings
EG-22-D-8216, Rev. 5 and EG-22-D-8217,Fiev 3. The following changes are made to
Section 16.3.6.
16.3.6.6. . Major Spill Tank LCS-Tank-8534 is also included as gart of the Lewisite
Collection Tank S]rstem. This tank does not have any Bumps associated with it.
ie
.
LCS-Tank-8534 can be filled with liquid that accumulates in the Toxic Area
Room Sumn 107 usins SDS-Pumo-E530. or bv connectins a flex hose between
the output of LCS-Pump-8522 (which services the bermed area that supoorts
the spent nitric acid tanks) and valve 1"-V-8636. Each tank's pipine svstem is
equioned with a t-connection that a flexible hose can be attached. To transfer the
contents of LCS-Tank-8534. a flexible hose is attached to the Major Spill Tank t-
connegtion and to the t-connection that the spill tank's contents are to be
transferred. The "dEstination" tank's circulation gump is then used to transfer the
waste to the desired tank.
It,3,6'7. MaiffS is
is
The following changes are made to Section 16.4.9.
16.4.9. ATLIC Tank System Secondary Containment
16.4.9.1. The ATLIC permitted hazardous waste storaee and treatment tanks are located in
the Toxic Area. The secondarv containment for these tank systefns is provided by
the imoermeable base of the Toxic Area and the six inch curb that run the length of
the area's outer oerimeter. The impermeable base is created bv coatins the
concrete floor and berm with an epoxy coatins. There is second berm that runs
Page 69 of 107
the lenqth of the Toxic Area. This 'lensth wise" berm seoaratOs the
secondarv containment area into two areas. The ourpose of the berm is to
isolate snill from the Spent Nitric Acid Storaqe Tanl$ which prevents the
cominsline of soill residues from the these tanl$ and the Soent Decon Tanlc
16.4.9.2. In addition there arettte is one sumps located in urithh the bermed Toxic Area.
The*umtx-are This sump is of identical desisn as the lntermittent Collection
Units located at the TOCDF. LCS-Pump-8522 is nrovided to transfer liouids
that accumulate within the bermed area supoortinq the Snent Nitric Acid
Tanks to the Maior Soill Tank or to the intact Snent Nitric Acid Tank should
one of the acid tanks reouire senice.
16.4.9.3. Further the Major Spill Tank that is located in the Toxic Area is maintained empty
as a contineency should one of the tanls within the Toxic Area fail. The
reouirernent to hold this tank in reserve to address potantial major soill essentiallv
creates an additional 1.020 eallons of secondary contaiffnent caBacity. This tank is
constructed of stainless steal which is compatible with all the wastes and materials
that are stored in the tanks located within the ATLIC Toxic Area. Liquids are
transferred to the Maior Snill tank throush the use of SDS-Pump-8530 bv
first lettins the spiUed liquids accumulate in the secondarv containment area.
or bv flex hose connections and the use of LCS-Pumo-8522 mreu*+ne{s€€f
ing
ffi
16.4.9.4. There are five permitted hazardous waste storage and treatment tanks. and one
tuok thut i,
"*etopt
fro* th" h-u.dor, *u itri"
Acid that will be used to rinse out Lewisite TCs (i.e.. product). within the Toxic
Area bermed area. One of the five oermitted tanks is maintained empty to address
major spills. Eaih tank is of identical design except for the materials of
construction (the Lewisite Collection Tankbeing made of carbon steel. the others
made of stainless steel). The permitted storaee capacity of each tank is 1.020
gErllons. The volume sf the overall secondary containment created by the bermed
Toxic Area is *$8'6 2.555 qallons. The volume of the secondary containment
area that supnorts the Snent Nitric Acid Storase Tanks is 958 gallons. A spill
sreater than 958 eallons would overflow the berm and flow into the Toxic
Area secondarv containment area. The total volume available to address spills
in the Toxic Area. includine that provided by the Major Spill Tank is 2o906 3.575
gallons.
243. 16,3.7.1- Please reword based on previous commi:nts.
Paragraph 16.3.7.1describes the waste streams that are accumulated in SDS-Tank-8523.
A review of this paragraph did not show a need for it to be revised since the Transparency
TC are not included as part of the l;ewisite TC inventory.
244. 16.3.7.5.- (LDS-FILT-8510" is actually *SDS-FILi-gtrO." Please indicate in the
narrative that the SDS tank will be sampled and analyzed to verify it can be fed to
the SCC or PCC.
Page 70 of 107
A review of Drawing EG-22-D-8217 shows that the pump tag is LDS-FILT-8510. To
address the sampling and analysis requirements of the DSHW comment, the paragraph is
revised to read:
16.3.7.5. A diaphragmpump (LDS-Pump-8506) is used to transfer sperit
decontamination solution and rinSe water from the ton containers to SDS-
Tank-8523. The decontamination solution and rirse waterBasses throueh
a duBlex strainer (LDS-FILT:8510) before it reaches the tank. There is a
diaphragm pumB available for mixingthe contents of the tank SDS-
Pumo-8524. After beinq samnled and analvzed per Attachment 2 of
this permit the Ths tank's contents are fed to the Secondary Combustion
Chamber of the ATLIC usine variable frequency drive eouipped soent
decon feed pumps SDF-Pumg-8330 or 8340. The waste feed passes
throueh a basket strainer located nrior to the pumos.
245. 16.3.8.1. - The word "duringt' should be added between the words 5'generated" and
"the' near the end of the second line.
The suggested correction is included in the revised attachment provided with this
submission.
246. 16.3.8.3. - (NSF-Pump-85L5" is actually "NSF-Pump-8548."
A review of drawing EG-22-D-8216 shows the reference to be correct as currently
described in paragraph 16.3.8.3.
247. 16.3.8.4. - "NSF-Pump-8565 is actually "NSF-Pump-8577.'
The suggested correction is included in the revised attachment provided with this
submission
248, 16,4,9,2. - Please delete the word ttin" from the first line next to "within." Please add
the sump IDs to the narrative.
The suggested correction is included in the revised attachment provided with this
submission
249. 16.5.2 - Please change the narrative to "will submit for approval" since the FCC has
not been approved.
The paragraph is revised to read:
The fabrication date of the three ATLI C hazardous waste tank
systems is aftbrJanuary 12. 1998 and each tank is required to
undergo a Facility Construction Certification. The certification wiII
be submitted for,approval imnoreved by the Division of Solid
and Hazardous Waste. Therefore the requirerrrents of 40 CFR
264.191 are not applicable.
16.5.2.
Page 7l of 107
250.16.7.2. - The sumps have level indicating transmitters. This information should be
included in a narrative.
Paragraph 16.7.2.2 is revised to read:
16.7.2.2. Each sump is equipped with a level indicator. sumn pump. and a leak detection
system located between the concrete vault and the metal liner. A leaking metal
liner would cause the leak detection system for the associated sump to alarm as
observed on a Control Room Advisor Screen.
251. Table 16-4 - Please verify the specifications are exactly the same (e.g., shell thickness
etc.) for the carbon steel tank and the stainless steel tank. Additional information
will need to be provided for the GA agent tank.
The specifications for the carbon steel and stainless steel tanks have been verified to be the
same. Regarding a tank for Agent GA; the GA is to be hansferred from the TCs directly
to the ATLIC Primary Combustion Chamber.
252. Tables 16-41 16-5, & 16-6 - The vapor pressufe include an"L." What does that
indicate?
The "L" is a typographical error and is deleted in the revised attachment provided with this
submission
AttachmentlT - Main Body Permit Mod (Equipment Lists)
253. Table 17.7 - Valve rt'-Y-8576 is listed as being blind flanged in the table but it
appears that on the drawing valve %u -Y-8577 is the valve that actually has the blind
fl ange. See drawin g &C,-22-D-8214, Rev. 2.
Table 17.1 was updated to reflect changes.
254. Table 17.l - The table should indicate that valve %"-Y-8770 is blind flanged. This
should also be shown on drawingBG-22-D-8212, Rev.2. Valve y4u-Y-8766 should
also be shown on the same drawing with a blind flange.
Valves y4"-Y-8770 and 8766 are used to inspect the double wall pipe for leak detection
and are not blinded. The table has been updated to indicate theses valves are used for leak
detection.
255. Table 17.1- The table lists PI-8671. but this instrument does not appear on drawing
EG-22-D-8223, Rev. 3. Instrument PI-8678 does appear on the drawing but is not
listed in the table. This appears to be a typo.
Table 17.1 has been updated'to show PI-8671. Due to space issues the design has been
updated and now there is only one agent feed pump. EG-22-D-8223, Revision 6 has been
updated to show changes along with Table 17.1.
Page 72 of 107
256.Table 17.l - Valve y2"-Y-8432 is capped. This needs to be indicated in the
Equipment Type column of the table.
Table 17.1 was updated to reflect changes.
Attachmentlg - Main Body Permit Mod (Instrumentation and Waste Feed Cut-Off Tables)
257. Table D-8-1 of Attachment 19 references a "common stack." The ATLIC has only
one exhaust stack. Please delete *common stack" and replace with 6'exhaust stack."
Table D-8-1 was updated to reflect changes.
258, Table D-8-1 - Lewisite only uses MINICAMS, not ACAMS. GA uses ACAMS and
DAAMS. Please update.
Table D-8-1 was updated to reflect changes.
259. Table D-8-2 - There should also be a low baghouse inlet temperature interlock. The
baghouse differential pressure of 0.1" seems very low for a limit. Please justify this
number.
40 CFR 63.1209 (What are the monitoring requirements) reads;
(l) Maximum inlet temperature to dry particulate matter air pollution control
device. You must establish a limit on the maximum inlet temperature to the
primary dry metals emissions control device (e.g., electrostatic precipitator,
baghouse) on an hourly rolling average basis as the average of the test run
averages.
There is no requirement for a low inlet temperature interlock.
(m) Particulate matter. You must comply with the particulate matter emission
standard by establishing and complying with the following operating parameter
limits. You must base the limits on operations during the comprehensive
performance test, unless the limits are based on manufacturer specifications.
The baghouse differential pressure limits are based on manufactures specifications.
260. Table D-8-2 - The GA stack alarm should be 0.2 SEL. Please update footnote d also.
Table D-8-1 was updated to reflect changes.
Attachment20 - Main Body Permit Mod (CEMS Plan)
261. Table 6.4-l - Please change GA/L Furnace to GA/L Incinerator.
The plan was updated to reflect the correct language.
Page 73 of 107
262.Table 6.5-1 - C0 should be CO. If the unit is down for any reason, no waste feed may
commence and any feed must stop. Please provide values for TBD.
This table was updated to change the CO (zero) to a CO and also to include a back up CO
and Oz monitors to allow feed if one unit is offline. Values are not available for the
upstream and downstream locations. These values will be updated once the units have
been installed.
263. 6.6,3 - Is the COIOz unit one unit or separate units? Why are their tag numbers
different? Per 40 CFR, TOCDF must perform the RATA and DSHW must be
notified 14 days in advance. Please include narrative.
The CO/Oz units are one unit, but provide two separate streams of data. Different tag
numbers are needed because they represent the storage locations of the separate data
streams. Section 6.11.2 requires TOCDF to provide a45-day notice of testing.
264. EG033 - CEMS QAPP - Why was the section after 1.4 deleted? Please incorporate
CDRL 006 and TE-LOP 540 and provide the correct revision number. Gas audits
need to be changed in the Tables in EG 033.
Section 1.5 has been updated to remove obsolete and non-applicable language. Section 1.3
references CDRL-06 and TE-LOP-540 already. Current revisions are not included in the
reference to avoid unnecessary updates to multiple documents when one procedure is
changed.
The TOCDF does not agree that the gas audit tables need to be changed. All ATLIC
CEMS operate on the same range as the current TOCDF CEMS.
265. Table 3-1 - Please provide narrative that a function test for the new AIT numbers
will be done to ensure that the units are properly working.
The TOCDF does not agree that a narrative needs to be provided detailing function
testing. This is part of the normal process of installinEany instruments at TOCDF in
compliance with the engineering change process, which includes a function test. If any
part of the unit were not working properly, this would also show up in the initial RATA
testing.
Attachmentzz - Main Body Permit Mod (Agent Monitoring Plan)
266. Page 48 - The MED 904K should be an ACAMS, not MINICAMS. Why aren't
DAAMS tubes specified? Please change the alarm level for GA to 0.2 Z.
The MED 904K is a MINICAMS detector. The DAAMS Tag# 731 will be added to the
plan for this station
The TOCDF does not agree to the 0.2 Z alarmlevel and proposes a 0.5 Z alarm level.
Page 74 of 107
267. Footnote 26 -Details on the confirmation procedure will need to be provided. Please
explain which columns will be used for each monitor.
Footnote 26has been overcome by events and will be removed from the plan. The details
concerning which columns are to be used are controlled by EG-080
268. 3.2.1- Please explain why the total hydrocarbon monitor was deleted.
The HWC MACT regulations require operators to demonstrate compliance with the
hydrocarbon standard only during the DRE portion of performance testing. After this
testing, compliance with the DRE perfornance standard is dernonstrated by maintaining
the incinerator Operating Parameter Limits (OPLs) for maximum waste feed rate,
minimum combustion chamber temperature, maximum exhaust gas flow rate, and
maximum exhaust gas carbon monoxide concentration within the limits established by the
performance test. See 40 CFR 63.1206(bX6) and 40 CFR 63.1209(a)(7).
Attachment22A- Main Body Permit Mod (ATLIC Agent Monitoring Plan)
Lewisite General:
269. Draft vapor validation studies show that Lewisite DAAMS HPLC/MS method at the
objective of25oh accuracy at95Yo confidenceonlyhadaccuracy30to3lpercent.
Please provide a final vapor validation study of the environments the Lewisite will be
in contact with at the facility. Please modify this section to reflect air
action/confirmation of DAAMS at 0.2 AEL (WPL/GPL/VSL/SEL?).
Additional vapor validation studies are not planned. A mass-spectrometry-based DAAMS
method, of which the DAAMS lewisite confirmation method is an example, has an
objective accuracy of * 35 o/oper programmatic U.S. Army Chemical Materials Agency
CMA LMQAP requirements. Therefore, the DAAMS HPLC/MS method in the draft
vapor validation studies met CMA programmatic requirements. Moreover, in their April
10, 2003 letter to the Program Manager for Chemical Demilitarization Environmental and
Monitoring Office, the CDC stated that the lewisite DAAMS method certified under the t'
vapor validation study was acceptable as a quantitative Class 1 method (see Enclosure I).
Note that the systemization of the monitors includes 28-day initial baseline studies. The
NRT monitors will be operational approximately three months before the beginning of
toxic operations. Additionally, the monitoring systems must past the initial baseline study
before they can be used.
The Agent Monitoring Plan and AWFCO tables included in Attachment 19 and the ATLIC
performance test plans have been revised to show an NRT alarm point (i.e., an AWFCO
setpoint) for ATLIC exhaust gas agent concentrations at 0.2 SEL for GA and L, with an L
SEL equal to 0.03 mdm3.
270. Please specify the temperature and humidity calculated for emissions from the stack.
The draft vapor validation studies show low accuracy for NRTs when operating at
high temperature and humidity.
Page 75 of 107
t'ii
\ ,,t,'F.--- r&'
,b.
i['.-,1
I t
t
t
i
!
fr,
1
\
A review of the ATLIC Mass and Energy Balances (MEBs) from the trial burn plans (and
included with this permit application) show the exhaust gas temperature at the exhaust
stack NRT monitoring location to be 230 'F with a moisture content of 4.5 percent by
volume. This compares to a typical TOCDF exhaust gas temperature and moisture content
of approximately 270 oF and 50 percent by volume, respectively. The initial 28-day
baseline study will confirm the reliability and repeatability of the NRT monitoring
systems. Baselines will be performed and approved before operations commence.
211. Alarm confirmation for NRTs will be at0.4 VSL/SEL/ECL but the action level will' rieed to be set at0.2 VSL/SEL/ECL.
See Attachmertt22A, paragraph 32.3, for action levels. The lewisite action for the stack
has been revised to 0.2 SEL, with the SEL value for lewisite equal to 0.03 milligrams per
cubic meter (mglm3).
272. Page 9 - The GPL definition will need to indicate a24-hour GPL instead of 72-hour
TWA for Lewisite.
, 1.,
The CMA programmatic LMQAP Section 7.3 (Table 7.1, attached) lists the lewisite GPL
as a7}-hotr TWA.
273. Page 9 - Baseline Definition: Please clarify cwithin limits." Please explain why the
GPL AEL is for a"7}-hour TWA.'
The initial Baseline definition was revised to read:
Baseline (Initial): Before each individual agent campaign the monitoring system
is operated in the configuration in which it will be used during the campaign. This
is known as baseline operations. The purpose for the baseline is to provide
I evidence that the whole system will perform within required tolerances and
requirements, and to document the configuration of the system at the time of the
baseline. Once a system is baselined
baSed on the precision and accuracy study. at the start of the initial baseline study.
",, Regarding the origin of the 72-fu GPL, the original time weighting period for all the'\ i chernical agent GPLs was set at 72 hours in 1988 (Federal Register, Vol. 53, No. 50,
- pp8504-850S.) The lewisite AELs were not included in the CDC 2004 revisions of
chemical agent AELs. Therefore, the lewisite GPL remains a 72-hour TWA.
274. Page 10 - The SEL for Lewisite will need to be reevaluated for DCD because the
Army previously had no intention of incinerating this agent and the SEL is site
specific.
The original TOCDF RCRA Permit allowed for the incineration of lewisite and GA at the
TOCDF and specified feed rates for these wastes to the TOCDF Liquid Incinerators (LICs)
in Module V.
Page 76 of 107
The CDC has evaluated the lewisite SEL value and found that it protects human health.
Additionally, TOCDF requested that the SEL be evaluated using anair dispersion model.
The associated report is included in Attachment D.
The TOCDF was informed at a meeting with DSHW that the CDC had communicated
their finding and support of a 0.03 mglm3 SEL value for lewisite.
275. Page 10 - Please use the same definition of RDTE solutions as is specified in the
TOCDF Monitoring plan, Attachment 22.
The definition of RDTE solutions is revised to read:
RDTE Dilute Solutions: RDTE Dilute Solutions are defined by the agent
concentration and by the quantity in a single container. They are as follows:
Agent Maximum Total Quantity Maximum Concentration
G-agents
Lewisite
RDTE Dilute Solutions:
Agent
G-agents
Lewisite
20.0 mg
50.0 mg
Maximum Total Quantity
20 mg
50 mg
2.0 mg/ml
5.0 mg/ml
agent concentration and by the quantity in
Maximum Concentration
2.0 mg/ml
5.0 mg/ml
276. RDTE Dilute Solutions are defined by the
a single container. They are as follows:
No response required.
277. Section 22A.1- Please reword filter monitoring. It is confusing and most of the
information could be placed in other locations.
This is an introduction that highlights ATLIC monitoring and is intended to provide an
overview. This section was changed to note that DAAMS would be used to confirm
lewisite NRT alarms.
278. 2242.1.1 - Please discuss suspending of monitoring in another location. The last
sentence is confusing. Only GA and L will be used with this monitoring plan.
The second paragraph in this section is revised to reference the correct paragraphs and the
last sentence ofthe paragraph is deleted. The paragraph now reads:
This plan reflects the monitoring for each processing area when it is being used for
agent work. When agent work in a given area is suspended, the monitoring for that
area may be suspended as stated in Paragraphs 22A.9, 22A.17 .3 , 22A17 .5, 22A.20
or 224.21.
hit.I1
l.\",
Irl,!
i. 'i-rn"
i
I'irI
Page 77 of 107
279.
280.
Section 22A.2.2 - Since TOCDF is going to be processing GA and L in the ATLIC,
and it operates both the CAL and SAF laboratories, please justify why TOCDF is not
responsible for the perimeter monitoring since it operates the laboratory which
analyzes the tubes.
The DCD performs and is responsible for the actual monitoring of the perimeter. In
addition, the DCD is responsible for the maintenance and operation of the perimeter
monitoring equipment, and for collecting and retrieving the samples. The Chernical
Assessment Laboratory (CAL) and SAF are responsible for the analysis of the tubes
provided to them by DCD. The DCD has been responsible for the perimeter monitors
since the inception of demilitarization operations.
Section 22A.2.4.2 - Will the co-located Lewisite DAAMS stations be used for
confirmation of the MINCAMS alarms? DAAMS sample lines at CAMDS were
eliminated as sample line failures were high. WiIl sample lines be use at these ATLIC
stations? If yes, then does the vapor validation study support long sample line
lengths? Please explain how the DAAMS only stations are being set up.
Currently, method development is ongoing for lewisite DAAMS confirmation of
MINICAMS alarms. Lewisite DAAMS sample line testing is being conducted.
Configuration of DAAMS stations will be according to drawings, the Configuration
Control Plan, and procedures.
281. 22A.8.3.'1, - What is considered the "processingbay?" The glove boxes? The igloo?
The ATLIC Processing Bay is an area inside the igloo where the glove boxes are located.
282. 22A.9.1- ACAMS and MINICAMS will need to monitor the IIVAC stack when
processing that agent.
Paragraph 9.1.1 describes the filter monitoring. Table I of Attachment22A shows that the
HVAC filter stack will be monitored using NRTs for GA and lewisite during their
respective campaigns.
283. 22A.9.1.2 - Why isn't the same setup of ACAMS/MINICAMS rotating through three
beds with DAAMS confirmation on each mid-bed used for both GA and L?
The duration of the ATLIC processing is shorter, and the amount of agent less, compared
to the TOCDF agent campaigns. At the TOCDF, TCs and munitions are opened to access
the agent cavity, which allows the agent to volatilize into the air within the Munitions
Demilitarization Building (MDB), thereby increasing the agent loading of the MDB
HVAC carbon. At the ATLIC, TCs are processed by draining agent through the TC
valves. This method of draining the GA and lewisite greatly reduces the loading of the
ATLIC HVAC carbon.
The NRT will cycle between the first and second mid-beds with DAAMS between the first
and second, and second and third, which are analyzed daily. Having the DAAMS
analyzed daily between the mid-beds as described provides an early indication of agent
i
:
Page 78 of 107
.O
breakthrough. Note there is DAAMS dedicated to second and to the third carbon filter
bank.
284. 22A.9.1.2 - This section states that ATLIC filter mid-bed (between banks I & 2)
locations shall be monitored continuously with DAAMS for any agents being
processed, and that an NRT will eycle through the three different filter banks. Please
justify why each filter bank should not have its own NRT for the mid-beds.
See response to DSHW comment #283 above.
285. 22A.9.1.2 - The station table appendix has two MINICAMS stations with different
columns for L with one station for confirmation. Please explain the location of the
backup stations that will be needed when the stations are challenged so continuous
monitoring is achieved.
The revision to Attachment22A included with this submission specifies DAAMS as the
confirmation method for Lewisite NRT mid-bed alarms.
286. 22A.g.1.2- Please specify that any alarm will be confirmed for L if the other station
is being challenged.
This comment has been overcome by events. TOCDF no longer intends to use a second
NRT as a confirmation method for Lewisite alarrir. Rather a Lewisite DAAMS NRT
confirmation method has been developed. Attachment2zA has been revised to specify
this.
287. 22A.9.1.2 - Please explain the TOCDF proposal of monitoring with DAAMS for L when a
reliable method for confirmation has not been provided.
A DAAMS confirmation rnethod for Lewisite NRT alarm has been developed and will be
provided to DSHW for approval. The revision to Attachment22A included with this
submission specifies DAAMS as the confirmation method for Lewisite NRT mid-bed
alarms.
Note CAMDS has been using DAAMS for Lewisite historical monitoring in their filter
banks formany years with the approval of DSHW.
288. 224.9.1.2 - There is only one GA NRT listed for the mid-beds of all three banks.
Where is the backup station at this location?
See response to DSHW comment #283.
289. 22A.9.1.3-22A.9.2 - Since there is an option to analyze ATLIC wastes at the SAF or
CAL, the more stringent requirement for the SAF laboratory will need to be
provided.
Page 79 of 107
,,1,, ,t
,'
'ltl
.t\
Paragraphs 22A.9.13 and22A.9.l.4 are deleted and marked reserved since Attachment
22Ais specific to the monitoring requirements for the ATLIC. Agent GA and Lewisite
monitoring and carbon change out requirements for the SAF filters are specified in
Attachment 29 and 30 of the TOCDF RCRA Permit, respectively.
290. 22A.9.1.4 - This section is in conflict with the change-out requirements of Module X.
Attachmentzzl should state a criterion of one VSL for change out and Module X
has one VSL change out criteria for carbon. Also, as there are only three carbon
banks in this HVAC, the change out should begrn after break through in Bank One.
Please justify why change out should occur only after break through of the second
carbon bank.
See response to DSHW comment # 289 above.
291. 22A3.1- Both lilter stacks will need to meet the requirement of monitoring in Section
9. The CAMDS monitoring Plan, Attachment 30, requires different monitoring
requirements. Please use those for the processing of GA and L (see Section 30.3).
The DSHW comment references paragraph 22A.3.1which discusses responsibilities.
Paragraph 22A9.1references filter stack monitoring. The DSHW references to "both filter
stack" is assumed to mean the ATLIC HVAC filter stack and the SAF filter stack. The
ATLIC HVAC filter stack is equipped with NRT monitors (for the agents being processed
in the plan0. The SAF filter stack requirements are specified in Attachment29 and 30 of
the TOCDF RCRA Permit and are not addressed in Attachment22A.
Attachment 30 requires NRT monitors on the plant filter stack for the agents being
processed. The current monitoring configuration specified in Attachment22Ameets that
requirement since the ATLIC filter stack is equipped with NRT monitors.
Attachment 30 specifies the monitoring requirements for the SAF. GA and Lewisite NRT
are not currently required (see Attachment 30, Section 30.3, third paragraph).
Also see response to DSHW comment # 293.
22A.9.1.3 - This section states that the SAF Laboratory lilter shall be monitored with
DAAMS for any agents in use. Does this mean any agents in use at the ATLIC or in
the SAF lab?
292.
..,
nrr .e'.j"'rj
r-l'i'
itu.i'
\. \,\r,:'
;'"\"-;o.,,i The SAF filter stack monitoring requirements for GA and Lewisite are specified rn
Attachment29 and 30 of the TOCDF RCRA Permit.
293. 22A.9.1.3 - Since TOCDF will be doing further neat agent sampling of GA and L,
please indicate where these samples will be analyzed? Lewisite has been monitored
at the SAF filter stack with DAAMS only because of the past history with Lewisite at
the CAMDS facility. A new campaign will require NRT monitoring at the SAF filter
stack for both GA and L.
Page 80 of 107
Currently the TOCDF is not planning to install NRTs agent monitors on the SAF filter
stack. Additionally there are no permit requirements to monitor the SAF stack for GA and
L whether or not non-dilute levels of neat agent samples are brought into the lab.
The need to analyzeneat GA or Lewisite samples at the SAF is not anticipated. Field
dilutions will be performed on agent samples that are collected to comply with treaty
requirements, and methods are currently being developed to perform field dilutions on
agent samples that are require a metals analysis.
Should it be necessary for the SAF to perform neat agent sample analyses the installation
ofNRT monitors on the SAF filter stack may not be necessary considering the limited
number of neat agent samples requiring analysis. Worst case there would be two Agent
GA samples needing analysis for Treaty compliance, two Agent GA samples two meet
additional analysis requests from the DSHW, five Lewisite samples requiring metals
analysis to comply with proposed conditions included in this permit modification, and no
more than four Lewisite samples requiring analysis for Treaty compliance. This totals 13
neat agent samples requiring analysis for the entire ATLIC scope of operations. The CAL
filter stack is equipped with NRT monitors for the agent being processed at the TOCDF.
The CAL analyzed over 6,000 neat agent mustard samples.
Note considering the limited scope of potential SAF neat agent operations, if necessary
rather than adding NRT monitors to the SAF filter stack TOCDF will adhere to the CMA
Monitoring Concept Plan (MCP) requirement to conduct Freon testing of the filter banks.
, , !,-'
Freon testing is conducted annually on the SAF carbon filter system.
294. 22AJ0.1- Please specify the limits in the SOP and provide a copy.
These will be controlled in EG-080 and by procedures which is available for onsite review
by DSHW representatives.
295. 22A.12.1.1- The TOCDF LQCP will need to be updated to include the requirements
specified for the ATLIC. Changes per comments will be incorporated.
A revised LQCP is currently under review and will be submitted in time to support the
planned ATLIC operational schedule.
296, 224.12.2.3 - Paragraph22{.1,5.3 does not exist. Please add that the Executive
Secretary will also be notified.
The referenced paragraph is revised from 15.3 to 16.3. Regarding notification of the
Executive Secretary: this section describes what actions ar'e taken if the Limiting
Conditions of Operation (LCOs) are not met. There is no requirement to notify the
Executive Secretary of operations suspension at the TOCDF when LCOs are not met.
TOCDF does not concur with the need to notify the Executive Secretary whenever ATLICtrr'
operations are suspended because LCOs are not met.
Page 8l of 107
\.rig..
:.. 'ir'"
$ ;$ i gi,o*c
v ?'lJ', riu
.;ft oli;'
;,(i:,
:. 1.ri'ri.t
297. 22412.2.4 - Please explain the mechanism for when two NRTs are monitoring for
confirmation and one goes off line.
This comment is overcome by lvents since the revised Attachment 22A submitted with
this response to comments specifies the use of DAAMS as a confirmation method for
Lewisite NRT alarms.
298. 22A'.12,2.4 - TOCDF has requested the use of dual Lewisite monitors without
DAAMS tubes. TOCDF'will need to add a pafagraph designating the second NRT as
the primary monitor in the event that the primary NRT is down. Please specify that
agent would be conlirmed if there was an alarm.
This comment is overcome by events since the revised Attachment 22A submitted with
this response to comments specifies the use of DAAMS as a confirmation method for
Lewisite NRT alarms.
299. 22A.13.2 - Please include the CAL laboratory also.
The CAL is currently controlled in Attachmeri22. The CAL is not referenced because the
status of the CAL does not have any impact on ATLIC operations and therefore CAL
status is not a Limiting Condition of Operations. AttachmentZZAwas written to address
the GA and L monitoring requirements needed to support ATLIC operations.
300. 22413.2 - References to 224.31 are incorrect.
The reference was corrected to 22A.32
301. 22A'.13.3 - Please add the CAL and correct the wrong reference in paragraph
22A.12.2. Please delete "for all furnace."
The phrase oofor all furnaces" is deleted. Also, see response to DSHW comment #299.
302. 22A.13.4 - Where are the dual MINICAMS confirmation set-ups located? Should
additional information be added to this paragraph for MINICAMS with DAAMS
confirmation tubes?
This comment is overcome by events since the revised Attachment 22A submitted with
this response to comments specifies the use of DAAMS as a confirmation method for
. Lewisite NRT alarms.
303. 224.14.1- Which NRTs are not connected to the Facility Control Center?
The only NRTs not connected to the FCC are short-term portable units.
304. 224.14.1. - The text states that all stack ACAMS and MINICAMS will be challenged
in accordance with TE-LOP-524. Does TOCDF plan to use an ADC on the ATLIC?
Also, new procedures will need to be addressed in LOP 524 for the addition of the L
Page 82 of 107
confirmation NRTs. Please add narrative that each station will have an NRT and a
DAAMS log book.
The LOP 524 is being updated to add ATLIC requirements. Dilution Air Flow Controllers
will be used on selected DAAMS stations as identified in the procedure. 'Documentation
requirements are located in section 22A.ll. Note that the revised Attachment22A
submitted with these comment responses specifies the use of DAAMS as the lewisite NRT
confirmation method.
22A15.1- This section states that the "actual" monitoring locations are found in
Appendix A. Please clarify the drawing location (it must specify the exact locations
of monitors).
Appendix A does identiff the location and the drawing number of the monitoring
locations. The location of the ATLIC stack monitors can also be found on the drawings
provided with the permit application (see drawingEg-22-D-8211, sheet 3 of 4, Rev. 7).
22A.16.2.1- The reference to Paragraph2LA.li.3 is incorrect. Please revise.
The reference has been changedto 22A.13.3
22A.16.3 - Please add that temporary changes to monitoring at the stack and the
HVAC are not allowed without permission from the Executive Secretary.
As identified in paragraph22A.16.3.l, the Executive Secretary is notified prior to any
reduction in monitoring. This is the same statement as that used in Attachment22.
22A.17.1.1- WPL monitoring during these short agent campaigns should be
conducted on a daily basis; not just on just the first five days of processing in
category C areas.
The first five days is a requirement from the CMA programmatic MCP. The WPL
monitoring will be conducted on a daily basis in the processing bay, filter area, and
DAAMS-only stations as stated in Appendix A.
22A.17.1.1- Please clarify the last sentence. Will these be L2-hour tubes or 24-hour
tubes?
The WPL monitoring for the first five days of processing is a requirement from the CMA
programmatic MCP. A11 Category C areatubes will be analyzed for the first five days of
processing. The tubes will be collected and analyzed per approved methods.
22A.17.3.1- The last sentence should indicate "the incinerator." Please add the
alarm level of 0.2 SEL for GA and 0.4 SEL for L.
The sentence is corrected. The alarm levels and action levels are identified in other
sections and do not need to be added here. Note that the alarm setpoint for the incinerator
Page 83 of 1 07
exhaust stack was revised to 0.2 SEL for both GA.and lewisite, with the SEL equal to the
values established by the (CDC).
311. 224.17.2.3 - Please revise the narrative to include the STEL (used for worker
protection and is a limit a worker cannot exceed more than once in a work shift).
The STEL is defined on page 10 of Attachment22A.
312. 22A.17,3.1- Please justify why the SEL alarm level is not set at0,2 for both Lewisite
and GA for early warning of process upset conditions.
See response to DSWH comment # 30.e.
313. 22A.17.4- The Lewisite level for the stack needs to be 0.003 mgnf (see Attachment
9, page 37).
As discussed with DSHW, TOCDF has revised Attachment 22Ato speciff an ATLIC
exhaust gas agent concentration AWFCO setpoint from 0.4 SEL to 0.2 SEL. The lewisite
SEL remains 0.i3 mdm'.
314. 22A.17.4 - How was the IDLH for Lewisite determined? Please provide any
supporting documentation.
The US Army issued a recommended IDLH for lewisite in August 2009 (see Enclosure J).
The CDC has reviewed the documentation provided and agrees with the IDLH. The IDLH
documentation package is currently going through final review at NIOSH.
315. 22A.17.5.2 - Will the facility be decontaminated before agent monitoring is
discontinued? Please include closure plan informatien.
This is a monitoring plan; a closure plan will be developed separately. Also, see response
to DSHW comments #24 and# 40.
316. 22A.18.2 - Please explain how low volume sampling is attached to the Lewisite
MINICAMS.
If a method is developed utilizing an LVS, an operation will be developed and added to the
procedure, which will need approval before use.
317. 224.18.4.1- Sample lines should be challenged on the stack every four hours and on
the other locations weekly since these campaigns are so short.
Evaluations will be made as testing, systemization, and baselines are performed. If it is
determined that sample lines need more frequent challenging, this will be implernented.
318. 22A.18.5.2 - Are the stations related to the control room that it is an'oS" mode?
Explain how that.is documented if an alarm occurs. Since the DAAMS tubes are
Page 84 of 107
used as the primary monitor of the original location, they are not used as
conlirmation tubes.
As described in the referenced section, the FCC receives a notification when a monitor is
switched to the spool mode. The only stations that are designated as spool stations are the
glove box stations. This NRT is a process monitor without DAAMS. The other spolled
monitor is in the processing bay. This monitor may spool to Vestibule 101 in case of
emergency.
319. 22A.18.6.1- Please provide a detailed narrative as to why V-G pads will be used for
GA.
As described in this section, V-G pads provide a cleaner, namower chromatographic peak
by converting tabun (GA) to the more volatile species fluoro-tabun.
320. 22A.18.6.2 - Silver fluoride pads on the stack should be replaced every four hours.
Unlike the TOCDF stack, the ATLIC stack is dry, and therefore, pads may not need to be
replaced every four hours. The TOCDF incinerator exhaust is approximately 50 Yo
moisture by volume; the ATLIC exhaust gas is about 4 % moisture by volume. The silver
fluoride pad change out frequency willbe evaluated during systernization and the initial
baseline study. If it is determined that a change-out frequency must be specified, it will
be included in the Monitoring Configuration Control Plan.
321. 2i2A.19.1.3 - Why is the CON referenced instead of the Facility Control Center?
What happens when the Lewisite MINICAMS are not staggered and no DAAMS
tubes are available?
The reference to the CON is changed to FCC. Also, the revised Attachment 22A specifies
the use of DAAMS for lewisite NRT alarm confirmation rather than the use of a
differently-confi gured NRT monitors.
322. 22419.13 - Any stack alarm will be confirmed if the lewisite monitors are not
staggered as there will not be DAAMS tubes available for confirmation. Please
explain in detail how a Lewisite alarm will be confirmed. Please include narrative if
the back-up is on-line.
This comment is overcome by events since the revised Attachment22A submitted with
this response to comments specifies the use of DAAMS as a confirmation method for
Lewisite NRT monitor alarms.
323. 224'.21.1- Please use 0.4 VSL and 0.2 WPL for Lewisite.
The TOCDF does not concur with these limit criteria for suspending location specific
agent monitoring. Section 21.1 of the Attachment 22A presents requirements that are
identical to those specified in the DSHW approved Agent Monitoring Plan for TOCDF
(Attachment 22).
Page 85 of 107
It also should be noted that a < I VSL threshold has been adopted as a criteria for closure
activities. When the agent concentration is determined to be less than 1 VSL, as measured
under non-ventilated monitoring conditions, both monitoring and decontamination
activities for the location being evaluated are suspended.
The suspension of monitoring that Section22A2l.l refers to is during the transition to
different agent campaigns when the facility is still operational and not during the time
when closure activities are being conducted. TOCDF is aware that if monitoring in
specific ATLIC locations is suspended prior to the time when non-ventilated monitoring
can be conducted that monitoring for these locations may need to be reestablished and
non-ventilated monitoring conducted to meet closure requirements.
324, 22A.22.1- Appendix A does not have a footnote indicating which monitors are not
connected to the Facility Control System.
A11 monitors identified in the plan are connected to the FCC. If any monitors are added
that are not connected, then a footnote will be added atthat time. Also, see response to
DSHW comment # 303.
325. 22A.22.1- This section references Section 22*.10.1for any potential exceptions to
manually recorded logbooks, but Section22A.l0.l does not discuss logbooks. Please
clarify and add narrative.
The reference was changed to 22A.1 1.1
326. 22A.23.I, - Please provide the SOPs and method validation for approval. The lowest
calibration standard must be at or below the alarm level, not the reporting level.
Procedures and methods will be provided to DSHW for Executive Secretary approval prior
to the beginning of agent operations. TOCDF understands that the DAAMS method
reporting level cannot exceed the NRT monitor alarm level for the method to be valid.
327. 22A,28.1- Is the alarm level verified at the Control Center like TOCDF does?
Accuracy between the NRT and the FCC will be verified by work orders. The verification
is part of systernization and is performed via a function test.
328. 22L.l8.31What DAAMS method uses only three minutes sample time? Please
provide exact locations of the GPL perimeter monitors.
The DSHW comment is assumed to be in reference to paragraph22A.l8.3.1, which
discusses the range of DAAMS-method sampling periods. There is a GB method that has
a 3-minute sample time.
The location of the perimeter monitors is identified in the DCD RCRA Permit since it is
the responsibility of DCD to establish and maintain the perimeter monitoring system.
Page 86 of 107
329.22A.32.1- The alarm level for GA will be 0.2 SEL and for L will be 0.4 SEL. A QP
must be sampled with each DAAMS set (every four hours). Please delete references
to furnaces.
The revised AttachmentzzA submitted with this comment response specifies a 0.2 SEL
alarm level for ATLIC exhaust stack NRT monitors forboth Agent GA and lewisite. The
utility of this alarm setpoint willbe evaluated based on data generated during method
development, certification, and validation. If there are excessive false or positive alarms
during systemization, TOCDF will request a Ternporary Authorization to revise the alarm
setpoints.
As identified in section 22A.19.2.1, a QP is run with each set of DAAMS.
The fumaces/incinerators reference is corrected.
330. 22A.32.2 - Please provide details on what is meant by "checked by monitoring." If
both MINICAMS alarm, it is confirmed asent. Monitoring personnel do not have
the option to say otherwise without DAAMS confirmation tubes.
"Checked" means that the Monitoring personnel will verify whether the monitor is in
alarm. Note that the revised Attachment22A, submitted with this response to comments,
specifies the use of DAAMS as a confirmation method for lewisite NRT monitor alarms.
331. 22A32.3 - Please justify why the action level for Lewisite is not set at 0.2 VSL for the
Category C and D areas. Lewisite is a carcinogen.
Lewisite has not been identified as a carcinogen. From the CDC: "There is only anecdotal
evidence for the potential carcinogenicity of Lewisite. However, the data are not definitive
and do not support classifying Lewisite as a suspected carcinogen."
(http://www.atsdr.cdc. gov/mhmi/mmg 1 63.html)
TOCDF does not concur with the setting the alarm setpoint for Lewisite VSL NRT at 0.2
VSL. Based on a discussions held with DSHW TOCDF agreed to reduce the alarm level
for GA and Lewisite NRTs monitoring the ATLIC exhaust stack to 0.2 SEL. The GA and
Lewisite VSL NRT monitor alarm level remain at 0.5 and 0.4 VSL, respectively.
332. Page 28, Monitoring Level - Instead of putting both levels (ECLNSL) which is
confusing, just put in the table the actual level of monitoring VSL.
The monitoring level for these stations may change between ECL and VSL. The purpose
of these is to monitor equipment/waste/personnel contamination levels. No change was
made to the table.
333. Page29, DAAMS mode - the DAAMS tube will be analyzed weekly at the WPL with
a corresponding QP. Please provide information for the primary DAAMS station,
such as two QPs will be sampled and analyzed with each set of tubes (a QP for the A
tube and a QP for the B tube).
Page 87 of 107
TOCDF does not concur with the need to analyze VSL and WPL DAAMS on a weekly
basis. Specific areas have different requirements as stated in the attachment. Specific
sampling requirements will be indicated in the site LQCP. TOCDF has an established
process for selecting which QPs will be analyzed. The LIMS program randomly selects
the tubes tobe analyzsed to meet the CMA programmatic requirement of analyzing a
DAAMS tube for each DAAMS method daily rotating stations with a tube from each
station analyzed at least once every 28 days. This procedure will be implanted during
systemization, and throughout the time period that the monitoring systems are operation
prior to actual agent operations and throughout the 28-day initial baseline.
Note TOCDF does not collect a QP with DAAMS tube set, rhther one QP is collected from
each base-lined station whether the station collects A, B, C, and D tubes or only A and B
tubes.
334. Table 1-
a. Please change aII alarms for GA on the stack to 0.2 SEL.
See response to DSHW comment # 30.e.
b. Please explain why DAAMS tubes are not utilized in the stack as confirmation.
The revised Attachment 22A submitted with this comment response specifies the use
of DAAMS as the confirmation method for lewisite stack NRT alarms.
c. Please explain use of TENT09DLIFL historical monitoring.
DAAMS historical monitoring is conducted to ensure that continuous monitoring of
the ATLIC exhaust stack occurs, in the event the lewisite NRT monitors fail. Based on
lewisite DAAMS methods already in use for CAMDS monitoring, successful
development of a DAAMS SEL historical method was known to be feasible.
d. Please explain TEN 721K & TEN 721L. Based on "table explanation" there
wouldn't be a need for the ECL, just the 0.5 VSL (three alarms levels were listed
but only two monitoring levels).
Alarm levels will be based on safety monitoring as this area is an A area. The
VSL/ECL nomenclature coffesponds to the .515140 alarm level as follows:
The VSL alarm level is 0.5 VSL
The ECL alarm level may be set at 5 or 40 ECL based on the expected agent
concentration in the area being monitored
e. Please specify which Lewisite monitors 709 A goes with on the other MINICAMS
(e.g.709 A has column DB-l and confirms with 7098L having column DB-624).
See response to DSHW comment # 334.b above.
o
o
Page 88 of 107
f. Note 4 indicate these monitors can monitor three other locations. Please specify
which ones. IIow does the confirmation DAAMS tubes work? When monitoring
three locations, do the primary locations of the DAAMS confirmation tubes and
the other two locations assume any alarm is a confirmed agent as previously
mentioned in the narrative?
The reference to DAAMS was deleted from the note. Note that four is only for the
glove-box locations indicated in the table. Monitoring in the glove box consists of the
glove box and two small airlocks (one included in the design of each glove box). The
DAAMS confirmation at these locations is required since agent is assumed to be
present if the NRT monitor alarms. Additionally, the monitoring will rotate between
the glove boxes and glove-box airlocks as needed.
g. Please explain why TEN 729 AL is historical when 729 BL is conlirmation to AL
yet AL has DAAMS tubes. This section is confusing. Please add footnotes for
clarification. Please also show validation of DAAMS historical for Lewisite.
This comment is overcome by events since the revised Attachment 22A submitted with
this response to comments specifies the use of DAAMS as a confirmation method for
Lewisite NRT alarms.
h. What problems are associated with Lewisite DAAMS tubes? Please explain why
the tubes can be used for historical purposes but not confirmation.
The mass of lewisite collected over the time period of a single cycle MINICAMS
alarm (5 to 15 minutes) is very small compared to the mass of agent collected over a
historical sampling period (4 to 12 hours). In order to achieve the sensitivity required
to detect the very small masses of lewisite associated with MINICAMS alarm
confirmation, new methods employing very sensitive detectors had to be developed.
Please explain why laundry monitoring for Lewisite is a DAAMS tube instead of
MINICAMS.
TEN 733K and TEN 733L are deleted from revised Attachment22A submitted with
this response to comments. The cotton goods being monitored are product and not
hazardous waste. Therefore these monitors should not be included in a hazardous
waste permit.
The narrative in the HVAC monitoring indicates that the NRT would be rotating
through the mid-beds, yet the table for filter monitoring does not indicate process
only monitoring at mid-bed one.
The narrative in the HVAC monitoring section indicates that the NRT will rotate
through the mid-bed 1 for all three filter banks. This is reflected in Table I by the
ACAMS/MINICAMS tag number, which is the same for mid-bed I on filters 101, 102,
and 103.
Page 89 of 107
A MINICAMS for Lewisite Backup confirmation appears to be missing. Since
two MINICAMS with dissimilar columns are needed for one "NRT setr" then the
second set must be the same way. A confirmation column type is missing. Please
specify column type, such as DB-1/DB-24, for each MINICAMS.
See response to DSHW comment # 334.b.
Please clarify stack monitoring in this section. DAAMS are listed for Lewisite.
Please label all Lewisite NRTs with column configuration.
See response to DSHW comment #334.b.
DAAMS stations for Lewisite are listed for many stations but this is not reflected
in the text. Also, TOCDF currently does not have a method for Lewisite analysis.
Several areas have historical lewisite DAAMS monitoring, as indicated in the narrative
(e.g., section22Al8.3.l). The TOCDF has developed and certified several lewisite
DAAMS methods. These methods will be validated when the monitoring equipment is
installed in the ATLIC facility and initial baseline studies are conducted. Also see
response to DHSW comment # 334.b.
Attachment l-Surrogate Trial burn plan for ATLIC
335. ES-l - Destruction of other potential organic compounds will need to be
demonstrated during the trial burn or spent decon will need to burned in the
primary combustion chamber. Please revise the language.
The Executive Summary was revised to indicate that chlorobenzene will be fed to the
Secondary Combustion Chamber (SCC) as part of the ATLIC Surrogate Trial Bum (STB).
336. Pagel- All SOPs for Lewisite and GA monitoring and waste analysis
characterization will need to be approved by the Executive Secretary prior to GA or
Lewisite processing. This includes the validation studies for each matrix.
The second bullet on Page 2 of the plan was modified to address this comment.
337. Page 4- Additional sampling of the GA and Lewisite (liquid and solid) must be
performed. The Executive Secretary has yet to approve a sampling plan for GA or
Lewisite ton containers or the transparency ton containers. At what concentration is
the NaOH added to the GA ton containers for rinsing? How many times are the GA
ton containers rinsed with NaOH? What is the concentration of nitric acid added to.
the Lewisite ton eontainers? How many rinses are performed with the nitric acid?
Data provided with the ATLIC STB were valid and the possible metals analyses of an
Agent GA verification sample is being investigated. The lewisite feed tanks will be
sampled and analyzed for metals.
The GA TCs will be rinsed with 18 % NaOH, and Section 1.3.1 was revised to include
additional information.
k.
l.
m.
a.
b.
Page 90 of 107
c. One treatment with NaOH followed by three water rinses.
d. The nitic acid is 3 Molar (M).
e. Two treatments with nitric acid followed by three water rinses.
338. Page 4 - The spent decon tank will also need to be analyzed for organic compounds
since the compounds are not processed through the PCC.
The spent decon fed to the SCC during the STB will be a phosphoric acid solution, and no
organic compounds will be added to it; therefore, the STB spent decon will not be
analyzed for organic compounds. The phosphoric acid solution will be analyzed for the
phosphate concentration and the metals concentration. Chlorobetuene will be added
through a separate feed connection to the SCC feednozzle. The vendor-supplied analyses
of the chlorobenzene will be used to characterize the feed, and it will not be analyzed.
339. Page 4 - GA should be placed in a tank prior to sampling or sampling will be
required prior to bringing the ATLIC on line. Sludge samples may be taken from
the ton container in the glove box. All ten ton containers of Lewisite will need to be
sampled, drained and processed in the ATLIC. The sludge will need to be sampled,
drained and then the ton container decontaminated in accordance with an approved
decontamination plan and then sent to a Subtitle C TSDF. The ten Lewisite
transparency tons containers will need to be sampled, drained and then
decontaminated in accordance with an approved decontamination plan.
O See response to DSHW comments # 8 ,9 andl 1.
340. A sampling plan and decontamination plan for the ton containers wiII need to be
submitted and approved by the Executive Secretary prior to introducing hazardous
waste.
See responses to DSHW comments # 8 and I l.
341. Page 6 - Since mercury is being added to the surrogate mixfure, why not use a higher
concentration to mimic the Lewisite?
The Lewisite Comprehensive Performance Test (LCPT) will demonstrate the metals
treatment for lewisite.
342. Pages 6-7, Sectionl.4.l - During the surrogate trial burn, the worst case for the
metals (representing Lewisite) will need to be demonstrated. The chlorobenzene will
need to demonstrate the GA.
The LCPT will demonstrate the metals for lewisite processing because the arsenic
concentration in the lewisite is so high; metals spiking would require a compound like
lewisite. Therefore, it was determined that the best way to demonstrate the arsenic
concentration was to conduct the LCPT.
The ATLIC STB will demonstrate the worst case for organic compounds incineration by
establishing a DRE for Class 1 compounds. The STB will use chlorobenzene in the
Page 91 of 107
surogate mixture feed material, and it will be fed by itself to the SCC. Chlorobenzene
was chosen because it is a Class I compound in the EPA ranking system. The
demonstration of a DRE for a Class I compound allows other Class 1 compounds, and any
compounds ranked lower, to be incinerated without demonstrating a DRE for every
compound; therefore, the dernonstration of a DRE for chlorobenzefie establishes the worst
case forboth Agent GA and lewisite processing.
343. Page7, Section 1.4.2 - Please describe the cyanide and how it will be treated when
processing GA.
The ATLIC STB will not use Agent GA; therefore, there is no possibility of hydrogen
cyanide emissions during the ATLIC STB. In any case, the Agent GA does not contain
hydrogen cyanide; therefore, there are no special precautions for treating the cyanide. The
cyano functional group on the Agent GA molecule will be combusted with the rest of the
Agent GA.
344. Page7, Section 1.5 - DRE will be 99.99990/0 instead of 99.99o/o, as was previously
performed for the other agents and surrogate of the TOCDF systems.
The references to the DRE were changed to 99.9999 %o tlvoqgh out the plan.
345. Please evaluate the spent decon summary for LIC GA and Lewisite decon and what
needs to be specified for the trial burn.
The spent decon was re-evaluated, the proposed surrogate spent decon was redefined, and
Section L.4.2 was revised.
346. Table 1-1 through 1-3 - Please indicate that this is preliminary data that was used to
design the incinerator and propose parameters for the surrogate test. Additional
characterization is required prior to processing the agent. Only about 40 weight
percent of the GA agent is accounted for. The weight percent was not provided for
the Lewisite, only the arsenic. Why was the data reported in so many different units?
Why is the spent decon characterization for the HD applicable for the Lewisite and
GA?
a. The data provided will not change from the last sampling event. The ATLIC STB
established a DRE for Class 1 compounds by demonstrating chlorobenzene; therefore,
it does not matter what the organii compounds are since they are all approved for
incineration based on the DRE demonstration of the Class 1 compound. Also see
response to DSHW comment # 8.
b. The tables were revised to point out that more than 40 Yo of the material was accounted
for.
c. The tables show the lewisite results as area percent.
d. The units were reported based on the analyses results.
e. The spent decon description was revised, and Table 1-3 was removed.
Page 92 of 107
347.Since the process for draining the GA and Lewisite ton containers was not provided
in detail, how much heel Qiquid/solid) would be left in the containers? The spent
decon characterization has yet to be evaluated for these agents.
Additional information was added to the plan for draining the TCs. The GA TCs do not
contain solids and the TCs will be drained to a 0.5 inch of the bottom of the TC. This
corresponds to less thanT lb of Agent GA, or less than 0.5 %oheel. The treatment with
NaOH will add about 110 gallons of 18 % NaOH, and that will be combined with 2,400 lb
of water as the rinse for a total of 3,200 lb of rinse. The resulting concentration of organic
compounds in the rinses would not be able to exceed 0.25 %.
348. Section 1.7 - The surrogate will need to be worst case for both agents, not just GA.
The spent decon organics must be demonstrated during the surrogate trial burn in
the SCC and then be at or below those Hmits during operations (for example, < 0.5
wto/o organics).
This section was revised to discuss the worst-case selection, and the addition of
chlorobenzene to the SCC to demonstrate feeding organic compounds to the SCC.
349. Page 11 - Why is the "worst case" metals only for agent GA? Why isn't it evaluated
for Lewisite metals also?
The LCPT will demonstrate the metals feed for the lewisite. The only way tq spike with
arsenic at a level for processing is to feed lewisite, which is the purpose of the LCPT.
350. Page 12 - The narrative indicates potential for HAPs in the spent decon, but goes on
to indicate that the surrogate chlorobenzene fed to the PCC will cover the SCC.
Please justify.
The section was modified to discuss the addition of chlorobenzerLe to the SCC.
351. Page 14 of the ATLIC Surrogate Trial Burn Plan references drawings EC,-22-F-8201
and E,C,-22-F -8202. Please provide these drawings.
These drawings are provided with this submission.
352. Section 2.3 - Please provide the residence time. Has an SOP been developed for the
transfer and clean-out of the ton containers? Please provide.
The residence time was calculated based on the information from the Mass & Energy
calculations. The total residence time for the ATLIC is 3.36 seconds as shown in
Appendix C of the plan provided. Sections 2.1 and 2.2 were modified to include a
statement on the calculated residence times of the PCC and SCC.
The SOPs for the cleanout and transfer of the ton containers have not been finalized
point.
atthis #I
Page 93 of 107
353. Page 17 - Please verify on the daily inspections the negative pressure on the glove
boxes.
The differential pressures in the glove boxes are monitored by PDIT-831 1 and PDIT-8319,
which are recorded by the control system. There are high- and low-pressure alarms
associated with these monitors. The second paragraph of Section 2.5 was revised to
include this information.
354. Page 17 - The glove boxes are locations where sludge samples could be taken in a
controlled environment. Also,liquid agent (GA) may be obtained here if TOCDF
wants to direct feed instead of sampling the tank. A sample of Lewisite from the tank
will need to be analyzed prior to feeding. Verifying the mixing of the tank is part of
the design.
There is no need to sample the TCs further. The DRE will be demonstrated by a Class I
compound during the ATLIC STB and distinguishing the compounds that are present in
the TCs is not relevant based on the demonstrated DRE. Also see response to DSHW
comment#8andl23.
355. Section 2.5.1- GA should be transferred to a tank prior to processing. Samples of
the sludge from each ton containers should be analyzed for agent, metals, and
organics. A minimum amount of time should be specified, such as 60 minutes. The
NaOH rinse will need to be performed three times followed by water.
The GA TCs were examined for sludge during the last sampling event, and no solids or
sludges could be obtained. This indicates that was not any sludge in the GA TCs, or so
little sludge that it would be removed by the TC rinse. The discussion was modified to
include the rotation times that were specified in the modifications to Module VIII of the
permit. The modified Module VIII states the Agent GA TCs will be rinsed with 18 %
NaOH once for a minimum of 60 minutes, followed by three water rinses for a minimum
of 60 minutes for each rinse. For further discussion, see the response to the next comment.
356. Page L8 - Please specify the concentration of the NaOH solutions. The container will
need to be rotated for a minimum of 30 minutes. Why isn't the container filled three
times with NaOH ("the appropriate solvento') and once with water as the final
verification? Same comments for Lewisite with the nitric acid.
The Agent GA TCs will be heated with l8 % NaOH and will be rotated for a minimum of
60 minutes. The Agent GA will be drained from the TC until a 0.5 inch of agent remains
in the TC, which corresponds to about 7 lb of agent. The 110 gallons of 18 % NaOH gives
amolarration of l20ll. Thehalf life of Agent GA at apH of ll at72 oF is 1.5 minutes.
Therefore, the one rinse with NaOH for 60 minutes will be adequate to hydrolyze any
remaining Agent GA. The TCs will then be triple rinsed with water to remove the NaOH
from the TC.
The lewisite TCs will be rinsed twice with 3 M nitric acid and rotated for a minimum of 60
minutes with each rinse. Following the acid rinses, the TCs will be rinsed three times with
water and rotated for a minimum of 60 minutes with each rinse. The lewisite will be
Page 94 of 107
drained to less than 0.5 inch, which corresponds to about 12 lb of agent. The 2 hours of
reaction time would allow adequate time for the lewisite to hydrolyze to 2-chlorovinyl
arsonous acid [ClC2HzAs(OH)z or CVAA], which would be soluble in water, based on the
reported solubility of the lewisite hydrolysis products. The water rinses will rernove the
acid from the TCs to stop the reaction between the metal TC and the acid.
357. Page L8 - Please provide details on what procedure is followed if the ton containers
are cut in half and solids are found.
The solids will be removed and heated as hazardous waste and transferred to a Subtitle C
TSDF.
358. Section 2.5.2 - Please provide the chemistry for processing the Lewisite. Ll plus an
acidic medium goes to HCI plus chlorovinylarsenous oxide (solid). What are the
potential side reactions through the entire incinerator and PAS? What type of
reactions could happen during the nitric acid rinses in the TOX tank? Where will
the solids that form be tested? What percent of the liquid from the rinsing will be
drained into the TOX tank and into the Spent Decon Tanks? What type of strainer
will be located on the transfer line to the SCC if solids are present? More details
need to be provided on the transfer from the ton container to the nitric acid TOX
tank and also to the spent decon tank. Where is the ton container stored before the
cutting process? How will the solids be treated (there is potential for Lewisite
byproducts, metals, and other organic which may be as toxic as Lewisite 1)? How
much IICI is produced in this process? How will the cutting process be performed
and what will be done if solids are found?
a. The lewisite will be incinerated to carbon dioxide, water, hydrogen chloride, and
arsenic oxide (As2O3). After the lewisite has been transferred from the TCs, the heel in
the lewisite TCs will be treated with 3 M nitric acid to remove the lewisite. The
lewisite will hydrolyze in the 3M nitric acid to form CVAA.
The hydrolysis of the lewisite quickly goes to 2-chlorovinyl arsonous acid, but the
continuation to Lewisite oxide proceeds slowly. During testing to simulate the rinsing
of the TCs, no solids were detected, indicating the reaction did not proceed to the oxide
over the time frame of the testing.
There would not be any side reactions in the incineration process because the lewisite
will be oxidized to carbon dioxide, hydrogen chloride, water, and arsenic oxide. There
are no side reactions in the PAS because the lewisite will not leave the incinerator.
Any lewisite in the presence of water will hydrolyzeto CVAA.
The lewisite in the acid solutions will continue to be converted to the CVAA until the
concentration has decreased to below the WCL.
e. The preliminary testing did not indicate that solids would form. If solids form in the
lewisite Agent Holding Tank (LCS-TANK-8511), they would be collected in the filters
on the pump that drains the tank.
b.
c.
d.
Page 95 of 107
h.
During the processing of lewisite TCs, there willbe a minimum of two nitric acid
rinses with approximately 110 gallons of liquid for each rinse, followed by three water
rinses. The two nitric acid rinses will be transferred to the Nitric Waste Collection
Tank (LCS-TANK-8516), and the three water rinses will be transferred to the Spent
Decontamination Systern Holding Tank (SDS-TANK-8523).
g. The transfer line going from the SDS-TANK-8523 to the SCC has a duplex basket
strainer to collect solids prior to entering the feed nozzle to the SCC.
Spent nitric acid is generated from rinsing lewisite TCs. After an L TC has been
drained of its agent fill, it is filled with approximately 110 gallons of 3.0 M nikic acid
solution through the fill and drain valves; this fills the TC more than half fuIl. The
lines are then detached from the TC valves, and the TC is rotated for a minimum of 60
minutes. The acid is added to the TC to deshoy any agent rernaining in the TC.
After the TC is rotated for a minimum of 60 minutes, a drain line is attached to the TC
and the spent nitric acid is transferred to NSF-TANK-8514 or LCS-TANK-8516
which are located in the ATLIC Igloo Toxic Area.
A sample of the spent nitric acid is taken at LCS-TANK-8516, which is analyzed for
lewisite concentration. If the lewisite concentration in the spent nitric acid is greater
than the WCL, 8.0 M nitric acid is added to the tank to destroy the agent. When the
Lewisite concentration in the spent acid is less than the WCL, the spent acid is
transferred to the 90-day tank PAS-TANK-8569, which is located in the
Environmental Enclosure. This enclosure also houses the ATLIC PAS.
The samples collected from PAS-TANK-8569 are analyzed for pH, total dissolved and
total suspended solids, and metals. The parameters of analysis are selected to support
the planned method of disposal of this waste stream, which is deep well injection.
Deep well injection is selected as the method of disposal because the spent nitric acid
waste stream will have high concentrations of both arsenic and mercury. The mercury
concentrations associated with this waste stream most likely will exceed the Land
Disposal Restriction (LDR) limits for High Mercury (HMERC) wastes. There are no
metal concentration limits for wastes that are disposed of by deep well injection. This
waste stream is acidic to minimize suspended solids.
The TCs will be stored in a permitted hazardous waste storage igloo until they are
ready to complete the cleanout process.
j. After opening the TCs, solid debris will be characteized and shipped off site to a
Subtitle C TSDF. (See response to DSHW comment # 218 and 358)
k. The processing of the solids remaining in the TCs is not anticipated to generate any
HCI.
l. A special cutter that is similar to a pipe cutter will be used to cut the TCs. See
previous response (i) for the handling of solid waste.
Page 96 of 107
359.Section 2.5,3 - ALL transparency ton containers will need to be treated as if they
were full ton containers after draining and proceed through the decontamination
process and final disposition.
The transparency TCs will be treated with one 3 M nitric acid rinse followed by three
water rinses. The last water rinse will be analyzed for lewisite. Section 2.5.3 was revised
to include this information.
360. Page 19 - All transparency ton containers will need to be rinsed three rinses with
NaOH (or nitric acid) and three times with water and then head-space monitored.
The transparency TCs will be treated with one acid rinse followed by three water rinses.
The nitric acid rinse will be placed in LCS-TANK-8516, while the water rinses will be
placed in SDS-TANK-8523 and processed in the SQC. The last water rinse will be
analyzed for lewisite. Section 2.5.3 was modified to include this information.
361.Section 2.6.1- The surrogate will need to be pumped to a tank as the GA will be
processed and sampled in the tank. Please explain why the acetic acid is used to
purge the nozzle. IIow often is the purge performed?
a. GA will be drained from the TCs directly to the PCC. .
b. Acetic acid is no longer used to purge thenozzle, however Dowanal will be used to
purge the agent nozzle between campaigns or if the fumace temperature needs to be
lowered for any reason.
c. The agent line willbe purged with compressed air every time there is a Stop Feed.
362. Sections 2,6.1 & 2.6.2 - IIow is the strainer material managed?
As identified it the Waste Analysis Plan (WAP), the strainers for the PCC will be handled
as secondary waste. The final disposition has not been established fully as of yet, but will
be labeled with waste codes P999, D004, D007, D008, ,W, and 19,21.
J
The strainers for the SCC will be handled separately because they are not expected to be
agent contaminated. These strainers will be samplqd for agent and TCLP metals. Waste
codes associated with this waste stream will Qe P9.p, D004, D007, and D008.
363. Page 20 - Please verify that the strainers of the ATLIC have waste analysis associated' with them.
See the previous comment.
364. Page2l - Are there any mercury monitors on this unit? If so, where?
No, there are no mercury monitors on the ATLIC.
A I a *';'1,;/'
!:,t 't ' '"
,o/
L.
.i'' , /'"
ft; C \\I1,_.1J
112
Page 97 of 107
365.Page 2l - In the last paragraph, o'until" should be "unit."
Corrected.
366. Page22 - In accordance with264.347, all AWFCO testing will be weekly.
See response to DSHW comments #4 and#63.
367. Section 2.7 - Attrchment 22A, Appendix A indicates a different monitoring btrategy
than specified in this section. Please clarify.
Agent monitoring is not part of the STB. The difference in monitoring strategy has just
recently changed, and the language in this plan will change to reflect using DAAMS as
confirmation monitoring for lewisite.
368. In the fifth paragraph, "until" should be "unit."
Corrected.
369. What type of carbon is in the HVAC? What type of carbon is provided in the carbon
injection? What is the difference between the HVAC mentioned in Section 2.7 and
the carbon filter system mentioned in Section2.10.7 besides the difference in design?
Is the carbon filter system describedlrn2.10.7 just prior to the exhaust stack used for
something else? The carbon injection system/baghouse was supposed to be used for
mercury removal. What type of carbon is included here? Why will only one carbon
bed be operating?
The HVAC carbon is the same type of carbon used in the TOCDF HVAC units.
The Baghouse Carbon Injection Systern uses a qowdered-Uro-inu@ carbon to aid in
*"r"*y and metal removal. - -"/
The systern described in Section 2.7 is the system that removes agent from the rooms
and filters the air through carbon to remove organic compounds and then discharges
the filtered air to the environment, while the system described in Section 2.10.7
removes mercury from the exhaust gas from the combustion process. The Carbon
Filter System (2.10.7) uses a sulfur-impregnated carbon designed to remove mercury,
which is the same type as used in the TOCDF PFS.
The system described in2.l0.l is designed for mercury removal from the exhaust gas
from the combustion process.
The Baghouse system is also designed for mercury removal.
The Baghouse Carbon Injection System uses a powdered-brominated carbon to aid in
mercury and metal removal.
a.
b.
c.
d.
e.
f.
Page 98 of 107
g. The system is designed to operate with one carbon filter unit at a time, and the second
unit is a back-up unit if needed. The carbon beds described in Sectiot2.10.7 contain
enough carbon to remove the total mercurypresent in the Agent GA and the lewisite.
370. Page28 - All GA and Lewisite monitors at the stack will be challenged at the distal
end every four hours. Please specify this in the plan.
Agent monitoring at the stack is not part of the STB. As described in the plan, the
monitors will be operated as described in the Agent Monitoring Plan (AMP), which is
Attachment 22ato the TOCDF Permit. The AMP requires the ACAMS to be challenged
every 4 hours.
371. Page 31 - Please verify the baghouse residue is sampled in the WAP.
As described in the WAP, a composite of the baghouse residue will be sampled for each
container transferred off site.
372. Page32 - Why is only one activated carbon bed used for removal of mercury? Are
there mercury monitors after this carbon bed?
The amount of carbon in one bed is estimated at882lb, and the carbon can have a
3 Yomercury loading, which would be about 26 lb of mercury. The total amount of
mercury in the Agent GA and lewisite totals 5.02 lb of mercury. Therefore, one
bed of carbon can hold five times the amount of mercury in the two agents. Also,
the carbon injected before the Baghouse will also remove some of the mercury.
The conclusion is that one carbon bed is more than adequate to handle the mercury
in the Agent GA and lewisite.
There are no mercury monitors in the ATLIC.
373. Page32 - Please provide a drawing of the sample point locations for the sampling
trains and where the agent monitors will be located.
Drawing EG-22-D-8211, Rev. 7,page3 of 4, was provided in Attachment 4 to the Permit
Modification Request, and it shows the sampling ports for the ATLIC.
374. Section 2.10.8 -Are the agent monitors in the LIC duct instead of the stack? Please
clarify.
The agent monitoring ports are located in a duct between the Induced Draft fan and the
stack as described in the plan. Please see DrawingBG-22-D-8211, page 3 of 4.
375. Section 2.11, - Please explain why the discharge stack (exhaust stack) is made of
fiberglass reinforced plastic instead of steel. Are the carbon filter unit and the
HVAC made out of the same material?
Originally, the furnace was designed as a portable unit, and weight was a factor; therefore,
the designers chose the fiberglass stack.
,. ;J,'
ji. ,.t
"..."'t I rf ,[]'^{" ' :
i,#'1 Wr
$ ... ,i ..'.-."
l'ri t +f. { ,[. -,*.:" :\'---" .:i,,r,-.irti.' l,' '
a.
b.
Page 99 of 107
37 6.
The outside of both the Carbon Filter Units and the HVAC units are made from Type 316
stainless steel.
Table 2-2 -There needs to be additional MINICAMS for Lewisite confirmation.
The DAAMS will be used for lewisite confirmation, and the plan will be updated to
describe this. The number of MNICAMS will be controlled by the Agent Monitoring
Plan, which is Attachment2Zato the TOCDF Permit.
377. Section 2.12.10 - Please provide the chemical reaction of brine with the Lewisite by-
products.
Lewisite and any organic reaction products should combust in the incinerator, which just
leaves arsenic oxide and hydrogen chloride. These compounds will be collected in the
scrubber liquor where the pH is controlled between 7.5 and 9.5. The hydrogen chloride
will be neutralizedto form sodium chloride, and the arsenic oxide would dissolve to form
-.soaiirm aisGirat*
,''''' *---^-"jSzb--SmUOnTrDnn will be gg.ggggo/o as specified in the permit and was performed
previously for the TOCDF LIC.
The references to the DRE were changedto 99.9999 %othroughout the plan.
379. Feed rates for metals will be specified since MACT CEMS for mercury or arsenic are
not being utilized.
The metals feed rates are listed in Table 5-3.
380. Page 43 - Since the TOCDF DRE requirement of 99.9999Yo is being required, please
make the appropriate changes throughout the plan.
The references to the DRE were changed to 99.99 99 Yo tl'rolghout the plan.
381. Page 43 - A semi-volatiles (SVOC) sampling train is required during the surrogate
trial burn. Please revise through-out the plan.
The STB plan was revised to include a Method 0010 sampling train for SVOCs.
382. Section 3.1 - A semi-volatiles sampling train is required. Please review sampling
ports in Attachm ent 4, EC,-22-D-8211.
See response to DSHW comment # 382.
383. Table 3-1 - For the surrogate trial burn, please replace MINICAMS with the SVOC
train.
The STB plan was revised to include a Method 0010 sampling train for SVOCs.
Page 100 of 107
384.Page 44 -Lewisite monitoring would not be necessary during the surrogate trial
burn. Please add the SVOC sampling train.
The STB plan was revised to include a Method 0010 sampling train for SVOCs.
Page 45 - Is there layering of the spiking solution or is the mixture completely
homogenous? Please provide details on how the ton container is mixed. How will
sludge be determined, sampled and managed? Please specify the exact location of the
surrogate organic and metals feed valve.
The spiking conhactor has developed a homogenous solution for the surrogate material,
which will be transferred to a ton container. These are the same chemicals used for the
LIC surrogate trial burn which had no issues with sludge. The metal feed will be injected
into the system just prior to the agent nozzle. The exact location will be determined once
the piping is installed.
385.
386. Section 3.2 - Please specify the time the surrogate mixture will be mixed. If
simulating GA, then feed the surrogate from the ton container into the tank. Please
specify a time frame, such as 30 minutes after sampling starts and 30 minutes prior to
final sampling.
387.
The spiking contractor will mix the chlorobenzene and tetrachloroethene, and ship the
mixture to TOCDF. The metals spiking solution will be a separate solution that will be
injected into the feed lines just before the waste feednozzle. These two waste streams will
be both sampled and analyzed separately. Both of the waste feed samples will be taken
during the first and last hour of each run and analyzed separately.
Page 46-During the surrogate trial burn, a cyanide train will be required. Please
include cyanide analysis in every waste stream.
Agent GA will not be used during the ATLIC STB; therefore, there is no need to add a
cyanide frain to the sampling.
388. Section 3.3 - TOCDF is mixing version numbers in the narrative (e.g. 8260C and
8260 B). Please verify the correct version number and be consistent.
The method numbering was standardized in the plans.
389.Section 4.0 - Please clarify the narrative. The exhaust samples will be collected for
four hours with2Soh of sampling time spent in each of the four sampling ports. It
should indicate how the trains will be sampling at what times during the four-hour
run.
Sections 3.2 and 4.0 were revised to clarify the collection of the isokinetic exhaust gas
samples.
Page 101 of 107
390. Page 49 - Spent decon will need to be demonstrated with 57o organic IIAPs if that is
the cut-off for processing in the SCC.
Section 5.1.2 was revised to describe the use of the diluted phosphoric acid and
chlorobenzene as a simulated spent decon. The chlorobenzene will be added to the SCC
during the STB at a feed rate that will represent about a I %o organic compound feed rate.
391. Page 50 - Please explain why mineral spirits were used as the matrix for spiking and
provide an MSDS of the type pla lned for use in the trial burn. Table 5-1 does not
specify the metals as indicated in the narrative on page 49.
Mineral spirits and the metals have been removed from the surrogate mixture. The
arsenic, lead, and mercury will be spiked into the feed line using a separate feed stream.
Table 5-1 was modified to only include the chlorobenzene and tehachloroethene. The
metals feed rates are shown in Table 5-3.
392. Section 5.1.1 - Why isn't the surrogate mixture worst case also for the Lewisite?
The surrogate mixture is not the worst case for lewisite because lewisite has higher arsenic
and mercury concentrations, and Lewisite processing will be demonstrated in the LCPT.
393. Section 5.1.2 - Spent decon needs to be representative of what will be fed during the
agent campaigns. If TOCDF is only going to feed a specified concentration of
organics and metals, then that would need to be demonstrated.
Section 5.1.2 was modified to reflect the revised simulated spent decon.
394. Table 5-1 - The surrogate mixture does not include the metals.
The metals concentrations are shown in Table 5-3.
395. Section 5.2 - The permit specifies a DRE is 99.9999oh and previous surrogate trial
burns at TOCDF had the same specification.
The references to the DRE were changedto 99.9999 Yothrolghout the plan.
396. Page 51 - The Permit requires 99.99990/0 DRE for the LIC.
The references to the DRE were changed to 99.9999 %otfuottghout the plan.
397.Page 51 - This is the same spent decon issue that was previously discussed. The
HAPs and metals should also be discussed.
Section 5.3.1 was revised.
398. Page 54 - Please add TDS to the spent decon requirements.
Page IAZ of 1 07
A diluted phosphoric acid solution will be fed as the simulated spent decon during the STB
to simulate the phosphorus feed when feeding Agent GA and to increase the particulate
load to the ATLIC. Chlorobenzene will also be fed to the SCC as part of the STB. The
chlorobenzene and phosphoric acid will be pure streams and will not require a TDS
analysis.
399. Page 54 - Based on ash rate, TOCDF is planning to process GA at 200 pounds/hour
after approval.
Section 5.8 was revised.
400. Page 57 & QAPP - 499.9999% DRE is required rather than the proposed DRE of
99.99Vo.
The references to the DRE were changedto 99.9999 %throryhout the plan.
401. Page 6L - The AWFCO system will need to be demonstrated prior to each agent
campaign.
Section 6.4 was revised.
402. Page 63 & QAPP - Please add semi-volatiles throughout.
O The STB plan was revised to include a Method 0010 sampling train for SVOCs.
403. Page 65 & QAPP - See previous comments on DRA.
The references to the DRE were changed to 99.9999 Yotlrou,ghout the plan.
Quality Assurance Project Plan (QAPP)
404. Figure A-4-l - The ACAMSiDAAMS on the chart for the Surrogate Trial Burn is not
needed.
Figure A-4- 1 was revised.
405. Please add the semi-volatile train throughout document.
The STB plan was revised to include a Method 0010 sampling train for SVOCs.
406. Section 6.3.7 - Method 29 does not specify not to cool for mercury, but references
Method Five that does require cooling. Unless there is a reason not to cool the metals
samples, please cool in accordance with Method Five.
Methods 5,26A, and 29 do not address cooling the samples after they have been
I
recovered, and the only requirement is to ship the samples in an upright position to \ t L 1
minimize leakage. Also, 40 CFR 136, Table II, the preservation steps for aqueous \ v
samples requires metals samples to be acidified to below pH2, but there is no requirement
Page 103 of107
for cooling the samples that include mercury. Therefore, the samples recovered from the
Method 5,26A, and29 will not be cooled.
407. Section 6.4 - Additional process samples (baghouse residue, condensate, process
water) will need to be sampled and analyzed.
The process samples listed in Section 6.4 were revised. An evaluation of the process
samples resulted in the following process samples to be collected: surrogate feed mixture,
scrubber liquor, venturi scrubber liquor, Baghouse residue, process water, and spent decon.
408. Table A-6-2 - The surrogate solution will need to be sampled at the start of the run
and in the last 30 minutes of the run. Therefore, there are two samples per run.
Also, organic compounds in VOC/SVOC should be analyzed in the surrogate
mixture. The brine sample should be collected in the last 60 minutes of the run (add
footnote). The spent decon should also be analyzed for TDS.
Table A-6-2 was revised to add the second surrogate feed mixture sample. The surrogate
feed mixture will be from commercial chemicals, and the certificate of analyses will be
used to provide the other compounds present. The mixture will be aralyzed to determine
the feed rates of the POHCs to the incinerator. The diluted phosphoric acid stream will not
be analyzed for TDS.
409. Section 6.4.1- Does the spent decon need to be screened for agent during the
surrogate trial burn?
Section 6.4.1 was revised because the spent decon will not be screened for agent during
the STB.
410. Table A-7-l - Because of the mercury, metals samples will need to be cooled after
collection for Method 29.
Methods 5,26A, and29 do not address cooling the samples after they have been recovered
and the only requirement is to ship the samples in an upright position to minimize leakage.
Also, in 40 CFR 136, Table II, the preservation steps for aqueous samples requires metals
samples to be acidified to below pH 2, but there is no requirement for cooling the samples
that include mercury. Therefore, the samples recovered from the Method 5,26A, and29
will not be cooled. Table A-7-l was revised, and the requirement for cooling the process
samples for metals was removed.
4ll. Section 8.2 - Please add a sensitivity check on balance requirements.
One of the bullets already states that the operation of the balance will be checked before
weighing any samples.
412. Section 9 - Please add the semi-volatiles train. Also, please indicate that two samples
of spent decon will need to be collected instead of just one.
Page 104 of 107
The STB plan was revised to include a Method 0010 sampling train for SVOCs. The
diluted phosphoric acid stream will be sampled from each tank that is made up for use in
the STB. It is anticipated that two tanks of acid will be used, and each tank will be
sampled.
413. Table A-9-1 - Please provide a link for Method 3885. Please update the table with
TDS and other organic lists.
Table A-9-1 was revised to show SW-846, Method 3585, instead of Method 3885.
Additional Samples and analyses were added to the table to reflect the additional process
samples added for analyses.
414. Table A-9-2 - Please add the semi-volatile train and sample.
The STB plan was revised to include a Method 0010 sampling train for SVOCs.
415. Section 9.1.1 - Please replace the word ttappropriate" with the word "certified."
This section was revised to add o'certified" to the standards.
416. Section 9.1.2 - Please add TDS as another inorganic parameter.
The TDS analysis was added for the process water stream.
417. Section 9.1.3 - Please indicate that TICs will also be reported.
The Tentatively Identified Compounds (TICs) will be reported for the VOC and SVOC
analyses of the process samples.
418. Section 9.1.4 - Please provide Method 3551A.
The reference to Method 3551A was a typo, and it was changed to Method 30514.
4lg, Section g.2.1-For the LCS and MSiMSD, please add tetrachloroethene (PCE).
Tetrachloroethene will be added to the LCS and MS/MSD sample analyses of the process
samples and the Method 0031 samples.
420. Table A-9-5 - Please describe why the other compounds will not be analyzed.
Chlorobenzene (BP 131'C) is on the borderline of VOCs/SVOCs and should be
analyzed on both trains. VOCs are usually considered < 100 oC.
The compounds that did not have an oo*" next to them are retained by the Tenax resin, and
they do not make it to the Anasorb-747 tube; they are not recoverable from the Anasorb-
741 resin.
Chlorobenzene is listed as a target analyte in Method 5041A (VOCs), and it is not listed as
a target analye in Method 8270D (SVOCs). It has been analyzed in the Method 0031
Page 105 of 107
421.
422.
423.
424.
samples in the past with no problems; therefore, it would be best to analyze it with the
VOCs.
Section 13.2 - Please include the MS/IVISD analysis for all the process streams.
The MS/I\4SD samples will be added for the process water, one of the scrubber liquors,
and the Baghouse residue samples.
Annex A, page A-13 - Please add PCE to the MS/MSD and LCS.
Tetrachloroethene will be added to the LCS and MS/MSD sample analyses of the process
samples.
Annex C - Are the URS resumes current? Are Eugene Youngerman and Margaret
Jepson still working on this project? Please review and update if necessary.
The resumes for each of the subcontractors were reviewed, and Annex C was modified to
delete those ernployees no longer working on the project; in addition, new ernployees were
added.
Update table D-l - The Lewisite feed rate will be based on the Lewisite trial burn,
not the surrogate trial burn. Also, the set point for agent monitors is 0.2 SEL for GA
and 0.4 SEL for Lewisite.
Table D-l has been updated to reflect any changes in the operating parameters setpoints.
Appendix B
425. Page B-1 - Please clarify the narrative to indicate that the ATLIC shakedown may
426.
begin after the surrogate and agent trial burn test p!4s have heen approved by the
Executive Secretary. See previous comments regarding spent decon concentrations.
Page B-l was revised to include the approval by the Executive Secretary and the new
description of the spent decon feed.
Page B-3 - The statement that the tons are empty is not accurate. Please revise.
Page B-3 was revised to state: "The Transparency TCs were sampled and no liquid or
solid samples could be collected from the TCs, indicating that they do not contain any
liquids or solids; however, they may have once contained Lewisite."
Page B-4 - The extension of an additional 720 hours will need to be approved by the
Executive Secretary.
Page B-4 was modified to read: "An extension of 720 additional hours of operating time
may be requested, if necessary, as allowed by the governing regulations and TOCDF
RCRA Permit, but the additional 720 hours will need to be approved by the Executive
Secretary before any operation beyond the original 720 hours of shakedown."
427.
Page 106 of 107
428.Additional sampling during the shakedown could also include the ton containers
themselves by following a sampling and analysis plan approved by the Executive
Secretary.
All TCs have been sampled and the data provided.
Attachment 3- Draft report on Ton container samples
429, The note should specify that before hazardous waste operations begin, the SOPs and
LOPs will be submitted to the Executive Secretary for approval.
The report that was included in Attachment 3 of the initial permit modification request
present results obtained from a sampling and analysis effort that has occurred. The report
is what it is and no change is made to the report. TOCDF is aware that ATLIC LOPs that
are applicable to the monitoring, extraction, and analysis of Agents GA and L require the
approval by the Executive Secretary. These LOPs will be submitted as they become
available.
430. General: When monitoring for L, the CMA LMQAP (Table L3-3 or L3-4) requires
two NRT challenge events be applied per station and divided evenly over the
workday. Please address.
A review of the CMA LMQAP shows the requirement to perform two challenges per day
on Lewisite NRT monitors to be in Table 12-1 titled Summary of QC Challenge
Requirements. This requirement is included in the revised LOP-524,now titled NRT
Operations. The revised LOP will be provided to DSWH when the review is complete.
431. Please provide language for the Level A suit for Lewisite.
The report that was included in Attachment 3 of the initial permit modification request
present results obtained from a sampling and analysis effort that has occurred. The report
is what it is and no change is made to the report. The type of suit that will be used at the
ATLIC for Level A entries is the Responder@ CSMrM Suit which is made by DuPont.
Page 107 of 1 07
E,NCLOSIJRE AA
Secondary
Containment
Calcu\ations
Toxic Area Room
Room Containment Dimensions
474 inches * 208 inches* 6 inches =591,552 in3
Convert in3 to gallon multiply by .00432
Toxic Area Room Containment Capacity = 2,555 gallons
The Largest Vessel in this area is capable of holding 1,000 gallons.
Nitric Acid Containment Area lnside the Toxic Area Room
Containment Dimensions
474 inches * 78 inches* 6 inches =221,832in3
Convert in3 to gallon multiply by .00432
Nitric Acid Berm Area Capacity = 958 gallons
The Largest Vessel in this area is capable of holding 1,000 gallons.
Note: lf all 1000 gallons of the Nitric Acid were to leak from the tank the extra
42 gallons would over flow the 6 inch berm between the Nitric and SDS tanks
and be contained in the Toxic Sump area. See Drawing EG-22-S-8213 sheet
1 for dimensions.
tro
tItl
r
,Gtr
.I+,ooot-o
lh
otr
(u
l-FCLE=a
cf
)Nro@IYzFIaoa-YcoFo)
.EEoItrooooCoo-ao-coaoacoF
cf
)Nroo!
}<zFIaoa.YcoFo)
.EpoIEoooocoo-ao-cog.oacoF
CONlo@IYzFIaoa-YcGFo)
.sE6:Ecoooocoo-ao.Co9.oacoF
coNlooI
:<zFIaoalzEoFo)
.EE6Ttroooocoo-
U)o-coaoacoF
aoEcoooaEGoroooacootraoc(Ucoo-EAE
o
G'
r
)
oa
c
oo
tr
A-
'o
@=
so
FC
)
a$Ecoooac(UoEooU)cGoC(t
,
T)cocoo-EAE
o
(o
a
oa
C
oo
tr
.A
c
'6
aE
So
FC
)
pcoCoo-Eat
s
o
oaoa
C
GO
tr
.9
.

E'6
@=
-c
O
FO aoEcoooacooEol-oaEooc.9
,
rO00
roOI
\zzFIao()
ldcoF(,
)
.EEo-6co()o.CoaoaCoF
U'
lzcGFo(,
)ooac=o1)3omU)
(Lo-coaoU)coF
o.Yc(I
,Fc=o:o3od)aTLo-CoaoocGF
1'CGcoo-Eat
o
(o
A
oa
c
oo
E
@-
'6
a=
So
F-
O aGEcoooacGoEooac(UoC.9
,
:foGo-Ef,aoNOIaINNIotUcI
)c=GEIf
,o-Coo$o.Coocr
)>.t
s
'ooIIO=Fo)
-C.sao-EfaoGoFooGoo-cF
tr
-oo'
E
oo
.a
E
JT
,
tr
ao
ao
ao
ao
oz
oz
oz
ao
ao
ao
oz
tr
.,
.
9
-
g
E8
J6
o
ao
U,o
ao
ao
oz
oz
oz
oz
ao
oz
oz
oCLFCLE=a
(L:)aEoE
ILfatoE
o-
faEOx
o-
faEOE
xO&coz
EOxcoz
EoECoz
x()Ecoz
xoEcoz
EOxCoz
M()xCoz
F-o
II+,CL
.I
l-ooootro
II*,c,ooJ
o-Efalt
'
-oEoox.ooo'=oF
(ooEoox.mlzoo-EtU

-a
@oEooE.
-YootU

-a
o-E:lU)oEoot()J
Eoox.o-oEG.CoboEcoooAo
-
e5
JA
o-Efaooa(L
o-E:,U)
(ooaIL
o-EfoEootrcooooGCoo
Gooo)Gt-oU)c3oE=od)a(L
GocI
)
.sroooJc=oIf
,=ooa(L
.YofFoLCGFoECf
ctzCLE=a
+to.E:l
cr
)
N+to.Efa
CO
:t
LoEfU)
*oE=U)
LO
:f
Lo-Ef,a
(o
:f
Lo-EfU)
lt
-+o-Efa
@+to-E=l
U)
O)
:f
to-Efo
o:f
to-Efa
:t
Lo-Ea
zoIF=uoILzo-=fao-JF
a
o
ENCLOSTJRE Ab
ATLIC Sump
Locations
o
Mw REPLY TO
ATTEI{TIOII OF:
DEPARTMENT OF THE ARMY
US ARMY CHEUICAL IIATERIALS AGENCY
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UTA}I T4O7I
APR 0 6 20t0
i-I AND DELIVHRED
APR 0 I 2010
UTAH DIVI$ION OT
$OLID & HAZARDOUS I/VASTE
6mora6-lD
PM022l-10Tooele Chemical Agent Disposal Facility
SUBJECT: Temporary Authorization (TA) Request to Place Area l0 Liquid Incinerator
(ATLIC) Facility Hazardous Waste Management Units (HWMUs)
Mr. Dennis Downs, Director
Utatr Deparfrnent of Environmental Quality
Division of Sotid and Hazardous Waste
P.O. Box 144880
288 North 1460 West
salt Lake city, utah 841144880
Dear Mr. Downs:
The Tooele Chemical Agent Disposal Facility (TOCDF) is requesting a TA to begin placing
the permitted HWMUs associated with the ATLIC facility, to include the incinerator and
associated Pollution Abatement System (PAS).
A Class 3 Permit Modification Request (PMR) to construct and operate the ATLIC was
submitted to the Utah Division of Solid and Hazardous Waste (DSHUD on January 7,2010.
Class 3 permit modification requests undergo two public comment periods that are separated by
sufficient time to allow DSHW to incorporate necessary changes to the initial permit request,
based on their review and input from the pubic. This TA is being submitted after the expiration
date of the first Public Comment Period.
$270.a2(e)(2XiiXA), Activities to be Conducted Under the TA
Activities to be conducted under the TA are the placement of the regulated ATLIC HWMUs
proposed in PMR TOCDF-AI0-03-1092 titled "Install and Operate Area l0 Incinerator".
If the TA is granted, TOCDF will install five tank HWMUs and ancillary equipment, two
Subpart X HWMUs (i.e., drain and rinse glove-boxes) and ancillary equipment, and one LIC
with associated PAS equipped as discussed in the PMR.
$270.a2@)QXiiXB), Necessity of the Temporary Authorization
40 CFR 270.42(c) does not contain a post-comment-period condition in order to begin
constrirction activities associated with Class 3 modifications requests to correspond with
5270,42(b)(8) for Class 2 modification requests. However TOCDF has conservatively taken the
-t_a
PM022l-10
position that construction activities associated with Class 3 modification requests may not
proceed until the Class 3 modification request is approved. Consequently, in order to begin
construction activities prior to this Class 3 modification approval, temporary authorization to do
so is requested from the DSHW.
To prevent a disruption of ongoing waste management activities, TOCDF desires to proceed
with the construction and installation of the HWMUs referenced in the previous section prior to
receiving approval of Resource Conservation and Recovery Act (RCRA) Permit modification
request.
The Lewisite (L) agent that will be treated by the ATLIC is not amenable to treatment in the
existing TOCDF incinerator because of the high concentration of arsenic in the agent.
Construction of the facility is expected to take approximately 8 months.
A Class 3 PMR will undergo two public comment periods. Although the duration of the
comment periods is defined in both the federal and state regulations, the time period between
the end of the first and beginning of the second public comment period is open-ended and varies
based on extent of changes to the initial permit request deemed necessary by DSHW and
negotiated wilh the modification requestor and public commenter's. The ATLIC construction
contractor is unable to schedule construction without TA approval because the approval date of
the ATLIC PMR cannot be anticipated. There is not a regulatory defined time period for Class
3 PMR by which the administrator (i.e., the DSHW Executive Secretary) must make a
determination as is the case with Class 2 PMR. Approval of the TA will allow scheduling of
construction based on a fixed date and will allow completion of construction several months
earlier.
$270.a2@)(2Xii)(C)i Continued Compliance to 40 CFR 264 Standards
The HWMUs that are planned to be installed witl not be used to manage hazardous waste
during the duration of the TA. Hazardous waste management activities, to include the
processing of surrogate material in the ATLIC, will not begin until approval of the PMR is
received.
$270.42(e)(3XiiXC),' Objective of the Temporary Authorization
The objective of the TA is to prevent a disruption of waste management activities at the
Deseret Chemical Depot (DCD). Without TA approval the completion of the treatment of L
Ton Containers (TCs) at the ATLIC will lag behind the completion of the treatment of the last
remaining Mustard TCs at the TOCDF incinerators by as much as 350 days according to the
existing schedules.
The ATLIC is being constructed to destroy the four agent GA and ten L TCs that are part of
the DCD Stockpile. The ATLIC will also treat ten empty TCs referred to as Transparency TCs.
-3-
PM0221-10
The destruction of the entire DCD Stockpile of chemical agent and munitions will be completed
when these 24TCs (in total) are treated. These 24 TCs have remained in storage at DCD
pending the availability of an acceptable method of treatment, which is the ATLIC.
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,
Urus^/6t cr,-s
Elizabeth A. Lowes
EG&G Defense Materials, Inc,
* CERTIFICATION STATEM ENT
Enclosure
Thaddeus A. Ryba, Jr.
TOCDF Site Project Manager
* CBRTI FICATION STATEMENT
, I CERTIF'Y UNDER PENALTY OF LAW THATTHIS DOCUMENT AND ALL ATTACHMENTS WERE PREPARED UNDER MY D'RECTION OR SUPERVISION IN ACCORDANCE
WITH A SYSTEM DESICNED TO ASSURE THAT QUALIFIED PERSONNEL PROPERLY GATHER AND EVALUATE THE TNTORMATION SUBMTTTED, BASED ON MY INQUIRY OF
THE ?ERSON OR PERSONS WHO MANACE THBSYSTEMT OR THOSO PERSONS OIRECTLY RESPONSTOLE FOR CATHERING THE INFORMATION. THE INFORMATION
SUBMITTED IS. TO THE BEST OF MY KNOWLEDGE ANI' BELIEN TRUE, ACCURATE AND COMPLETE. I AM AWARE THAT THERE ARE SIGNITICANT PENALTIES FOR
suBMIrflNCF LSEtNFORMATTON,tNCLUDtNCTHEPOSS|DILITYOrHNEANDTMPRISONMEM'r'ORKNOWTNGVTOLATTONS.
AA MELLOR H,:;ffi ','.',:r"'i'
sui'ie 1
/ V'ENGlNttRlN0 offioe(801)768'0658
DESIGN CERTIFICATION
The design for the tanks identified in Table 1, was reviewed to determine if the tanks will
satisfy the requirements outlined in 40 CFR Section 264.192. The tanks will be located in
Area 10 of Deseret Chemical Depot. This certification satisfies the requirements of R315-8-10
(40 CFR Section 264.192).
The design for the tanks identified in Table 1 was reviewed and meets the requirements
outlined in 40 CFR Sestion 264.192.
Tank #-U"qese Descri
PAS-TANK.8569 Hazardous Waste Brine HDLPE (Poly Tank)
PAS.TANK.8551 Hazardous Waste Brine HDLPE (Polv Tank
PAS-TANK.8552 Hazardous Waste Brine HDLPE (Polv Tank
PAS-TANK.8553 Hazardous Waste Brine
LCS-TANK-8s11 fiI;diAo G-Wa;te," A(iA nt" Sto ii
LCS-TANK8534 Hazardous Waste, Agent, Spent Stainless Steel
Decontam i n ati gn S_o ! u,tig11 (gpj
SDS.TANK.B523 Hazardous Waste, Spent Stainless Steel
Decontamination Solution SDS
NSF-TANK-8514 Stainless Steel with Teflon Liner
SDS
LCS.TANK-8516 i Hazardous Waste, Spent
-i-Degsr lerilne-tiell $el tltr"-o n f s p s
i Stainless Steel with Teflon Liner
I
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision according to a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who managd the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete, I am aware that there are significant penalties for submitting false
information, including the possibility of fine and imprisonment for knowing violations.
l, the undersigned, do hereby certiff that based on the information obtained, the design
certification for the above referenced tanks addressed in this document is accurate and in
accordance with the requirements of 40 CFR Section 2A4192.
23 March 2010
IP-LPE P-qU-r"an$"
Carbon Steel
Hazardous Waste, Spent
Decontamination Solution
,
i
o
Tahle 1: ATLIC Tank ldentification
'ffw\h9[ .YffiiJ' nn
ffi
Engineer
No. 318691
ENCLOSIJRE D
ATLIC Dispersion
Modeling Results
Analysis of Worker and General Population Safety
Standards from Potential ATLIC Stack Emissions of
Chemical Agents GA and Lewisite and Pollutants Cyanide,
Mercury, and Arsenic at Deseret Chemical Depot
October 2010
Background
The EG&G has requested this study of potential chemical agent and pollutant emissions
from the stack at the proposed Area 10 Liquid lncinerator (ATLIC) at Deseret Chemical
Depot.
Hypothetical chemical agent emissions for GA and lewisite are considered during an
"upset" condition for the incinerator stack. The pollutants cyanide, mercury, and arsenic
are evaluated assuming constant emissions from the stack. The projected chemical agent
concentrations outside the stack are compared to current worker and general population
health standards; the pollutants cyanide, mercury, and arsenic concentrations are
compared to worker health standards. Two separate stack flow rates, a low flow and high
flow, are considered.
Approach
Computer models are used to simulate potential chemical agent and pollutant emissions
through the ATLIC incinerator. For modeling pu{poses, the stack effluent is presumed to
contain chemical agent at a concentration equal to the Source Emission Limit (SEL);
pollutant concentrations ire set equal to values previously measured (EGG). The model
simulates the amount of "plume rise" above the stack due to buoyancy and momentum,
the transport and diffrrsion of the effluent plume, and the maximum ground-level
chemical agent concentrations. For the chemical agents, the model- predicted
concentrations are compared to the established acute worker safety concentrations: the
Short-Term Exposure Limit (STEL) and the General Population Limit (GPL). For the
pollutants, the model-predicted concentrations are compared to acute worker safety
concentrations: STEL (cyanide), Time Weighted Average (mercury), and Threshold
Limit Value (arsenic).
This analysis employs the Army's D2 model, which is accredited through the Army
Safety Office and Department of Defense Explosives Safety Board (DA Pamphlet 385-
61). The model generally provides conservative (safe-sided) predictions of potential
agent concentrations (DPG, 2004). Worst-case daytime and nighttime meteorological
conditions - which maximize the potential agent/pollutant concentration - are assumed.
Chemical Agent and Pollutant Emission Ouantities
The chemical agent emission rate is assumed to equal the Source Emission Limit (SEL)
concentration. The emission duration for the "upset" condition is assumed to last
approximately two monitoring cycles, eg 15 minutes. The SEL concentrations for GA
and lewisite are listed in Table l.
Table l. Stack Emission Levels (-gl-')
Agent
GA
L
SEL
0.0003
0.03
For the model simulations, these concentations are converted to mass by multiplying the
SEL concentration and stack flow rate (Table 3).
The pollutants cyanide, mercury and arsenic are assumed to be emitted continuously.
Based on HWC MACT data, the assumed emission rates for the pollutants are listed in
Table 2.
Table 2. Pollutant Emission Rates (grams/second)
Pollutant Stack Low Flow Stack High Flow
Cyanide 2.918-3 4.638-3
Mercury 2.188-6 3.478-6
Arsenic 6.198-6 9.86E-6
Source Emrs slon P arameters
In terms of modeling agent concentrations at ground level from stack emissions, the
critical stack parameters are listed in Table 3.
Table 3. Incinerator Stack Data
Height (m)
Diameter (m)
Velocity (m/sec)
Temperature (C)
Exhaust Flow Rate (ft3/min)
Low Flow
12.
0.36
6.8
I 10.
889.
Hiqh Flow
-
12.
0.3 6
13.6
I 10.
r52l .
Plume downwash has been considered, and deemed not likely to occur. Downwash
results from a pressure differential of airflow around the stack, potentially dragging the
stack emissions toward the ground much quicker than expected from simple atmospheric
difhrsion. Downwash is considered not likely for these stacks, primarily due to the face
velocity of the stack emissions and the elevated temperature of the emissions.
The worker exposure is assumed to occur where the plume first reaches gtound-level,
which is the peak concentration at groundJevel. The GPL is applied at the nearest depot
fenceline location from the ATLIC, which is 7500 feet. In both cases, the maximum
model-predicted concentration is assumed for both the worker and general public.
It is worth emphasizing that a chemical agent emission is not expected. This study
simply evaluates the unlikelypossibility of agent in a stack at a concentration equal to the
SEL and the hazard to workers and the general population as determined by the STEL
and GPL concentrations.
Chemical Agent and Pollutant Toxicity Standards
The chemical agent toxicity standards are listed in Table 4.
Table 4. Chemical Agent Safety Standards (-g/^3)
Agent
GA
L
Pollutant
Cyanide
Mercury
Arsenic
STEL
0.0001
0.003
Acute Worker Standard
5.0 (NIOSH STEL)
0.025 (NIOSH TWA)
0.01 (osHA PEL)
GPL
0.000001
0.00002*
not been promulgated; value set equal to the GPL for mustard*the GPL for lewisite has
agent
The GPL is treated as a 12 hour averaging time.
The pollutant toxicity standards are listed in Table 5.
Table 5. Pollutant Worker Safety Standards (mg/m3)
Meteorolo gical Parameters
The important meteorological parameters needed to simulate this scenario are
aftnospheric stability and wind speed. Ahnospheric stability represents a measure of
turbulence, or the natural ability of the atmosphere to dissipate a chemical to lower
concentrations as the plume migrates from the source. Worst-case meteorological
conditions have been assumed, which produce the highest model-predicted groundJevel
concentration. These conditions are: Pasquill Stability Category D (neutal) for a
daytime emission and Pasquill Stability Category F (stable) for a nighttime emission.
High wind speeds will restrict the amount of "plume rise" and produce the highest
groundJevel concentration. As a result, for the nighttime emission, a wind speed of 3
m/sec is assumed, the maximum wind speed allowed for this stability category. Since
there is no theoretical limit of wind speed with Stability Category D, a statistical
approach is used. In this case, the 95th percentile is chosen to represent a high wind
speed, to minimize plume rise above the stack. From an analysis of on-site DCD
meteorological data, the 95th percentile wind speed is 9 m/sec. Windspeeds of 1 m/sec,
for both daytime and nighttime emissions, are simulated to ensure the model captures the
maximum groundJevel concentrations and dosages for the combination of low/trigh stack
flow and plume rise.
Model Results
The maximum expected chemical agent concentrations are listed in Table 6.
Due to the elevated emission, the peak concentration can occur at a significant distance
from the stack. These "touchdown" distances ranged from approximately 200 - 300
meters (daytime) to 900-1000 meters (nighttime). Differences in these distances result
from the natural diffusion of the chemical plume between daytime and nighttime
conditions.
The D2 model input/output for all simulations is listed as Appendix A.
Table 6. Chemical Agent Peak Concentration (rngirn3) within DCD and Peak
Dosage (mg-min/m3; at DCD Fenceline for 1 SEL Stack Release
Agent GA
Peak Concentration (mCm3)
DCD
Peak Dosage
Fence I ine
Dav
6.1 E-B
1. 1E-7
(mg-min/m3)
Niqht.
4.1E-7
1 .6E-7
Dav
Low Fl-ow A.IE-B
High Flow B.1E-B
Ni qht
4 .4E-B
3 .4E-B
Peak Concentration
DCD
Agent Lewisite
t* " (mg-min/m3)
Dav
Low Elow 6.lE-6
High Flow B. 1E-6
Low Elow
High El-ow
Low El-ow
High Fl-ow
Ni qht
5.2E-6
1 .6E-6
FenceI ine
Dav Niqht
6.J E-6 4.J E-5
1.1E-5 7 .1E-5
ln all cases, a stack emission of chemical agent GA or lewisite equal to the SEL
concentration produces a peak concentration at ground-level much lower than the STEL
or GPL, for daytime and nighttime emissions. The elevated stack concentrations of GA
and lewisite necessary to produce the STEL and GPL have been calculated. The results
are provided in Table 7, in terms of multiples of the SEL.
Table 7. Minimum Stack Emission Necessary to Produce Given Toxicity Threshold at
Ground-Level (in Multiples of SEL).
Agent GA
srEL (DCD)GPL (Fenceline)
Dav
-2,700.
!,200.
Ni qht
2,200 .
2,900.
Lewi s ite
Dav
-10,000.
6,500.
Ni qht
1,500.
940.
srEL (DCD)
Dav Niqht
490. 510.
370. 390.
GPL (Fenceline)
Dav Niqht
2,700. 300.
1,300. 180.
The maximum expected concentration levels at ground level for the pollutants cyanide,
mercury, and arsenic are listed in Table 8. The model results (Appendix A) treat these
emissions as one-hour events with constant meteorological conditions and determine the
maximum one-hour concentration. If all one-hour predicted concentrations are less than
the established toxicity threshold, the concentrations from continuous emissions with
variable meteorological conditions must also be less than the established toxicity
threshold.
Table 8. Pollutant Peak Concentration (mg/m') ut Ground-Level
Low EIow
High EIow
Low FIow
High Fl-ow
Low Flow
High Flow
Low Flow
High Flow
Low Flow
High FIow
Cyanide
Dav Niqht
t.4E-3 7.2E-3
t.l E-3 7.6E-3
Mercury
Dav
-1.1E-6
1.3E-6
Dav
3.0E-6
3.J E-6
Ni oht
-
9 .78-1
7 .2E- 6
Arsenic
Ni qht
2 .6E-6
3.5E-6
In all cases, the peak concentration is lower than the worker protection standard. The
increased emission rates for the pollutants cyanide, mercury, and arsenic necessary to
produce the worker safety standard have been calculated. The results are provided in
Table 9, in terms of multiples of the HWC MACT emission rates (see Table 2).
Table 9. Minimum Stack EmissionNecessary to Produce Worker Safety Standard at
Ground-Level (in Multiples of HWC MACT Pollutant Levels)
Cyanide
STEL
Dav Niqht
3,500. 4, 100.
2,900. 3,100.
Mercury
TVIA
Dav Niqht
22,000. 21,000.
79,000. 20,000.
Low Fl-ow
Hi gh El-ow
Arsenic
TLV
Dav Niqht
31300. 31800.
2,100. 2,800.
The results show that very large chemical agent emission quantities, relative to the SEL,
are required before the STEL and GPL can be exceeded for chernical agents GA and
lewisite. For example, a lewisite stack concenkation of - 390 SEL is necessary before
the STEL can be reached at ground level and a stack concentation of 180 SEL is
necessary before the GPL can be reached for worst-case meteorological conditions.
Larger stack concentrations for non-worst-case meteorological conditions would be
required to exceed the STEL or GPL.
Similarly, much largerpollutant emission rates than IIWC MACT standards must be
emiffed before worker safety is threatened away from the ATLIC facility. For example,
an emission quantity of arsenic at least 2,700 times greater than the HWC MACT
standard must be emitted before the Threshold Limit Value is reached.
Conclusions
Chemical agent emissions of GA or lewisite at the SEL concentration are not expected to
produce concentrations at ground level that exceed the STEL or GPL concentrations for
the ATLIC incinerator at Deseret Chemical Depot. The HWC MACT Emission Standard
rates for cyanide, mercury, and arsenic are far below that necessary to impact worker
safety. Extremely large stack concentrations of chemical agent or pollutants are
necessary before the STEL, STEl-equivalent, and GPL standards can be exceeded.
References
Implementation Guidance Poliqtfor New Airborne Exposure Limitsfor GB, GA, GD,
GF, VX, H, HD, and HT, Department of Army, Assistant Secretary for Installations &
Environment, 18 June 2004.
Personal Computer Programfor Chemical Hazard Prediction (D2PC), CRDEC TR-
8702t, t987.
Results of the Independent Verffication and Validation Analysis of D2-Puff Version 4.4,
U.S. Army Dugway Proving Ground, Meteorology Division, DPG WDTC-TR-04-122,
October 2004
Tortc Chemical Agent Safety Standards, Departrrent of Army Regulation 385-61,
12 October 2001.
Handbook on Atmospheric Dffision, U.S. Department of Energy, DoE/TIC-\1223,1982.
Guideline on Air Quality Models,EPA,40 CFR Ch I, 1999.
Hazardous Waste Combustor Maximum Achievable Control Technology (HWC MACT)
Emission Standard forNew Sources.
o
ENCLOSURE E
o Federal Register
March 1988
Lewisite SEL
O
Final Rgcommendations for Protecting Health and Safety Page I of 7
Sea rc h
Warning:
This site is being maintained for historical purposes, but has had no new
entries since October 1998. To find more recent articles, please visit the
following:
. M-MWR at http://www.cdc.gov/mmwr/mmwrsrch.htm. CDe lllleb Sea-r.ch at http:l lwww.cdc.gov/search.htm
Final Recommendations for Protecting the Health and Safety
against Potential Adverse Effects of Long-Term Exposure to
Low Doses of Agents: GA, BV, VX, Mustard Agent (H, HD, Y),
and Lewisite (L)
Department of Health and Human Services, Centers for Disease
Control Public Health Service, National Center for
Environmental Health
Publication date : 031 L5(19BB
WONDER Home Contact Us
Table of Contents
Agency
Aslian
Su_mmary
Su ppl em_en!.a fy I n form atio n
Recommendatlstrg
P9IN IP-E q ANIACI TORJH IS-LA-CUME NT;"
Tables
esn-tj'pJl!mi-ts--f p-r-p"llemlcal"arenls
Allgwa ble stack conceffiaHen_E_ h.r EhemiEAl
o-Agency
http : I / w ond e r. c dc . g ov/wo nde rlP rev Gui d/p 0 0 0 0027/p0 0 0 0A27 . a sp U2312008
Final Reoommendations for Protecting Health and Safety
'' Centers for Disease Control (CDC), Public Health Servlce, HHS.
Page 2 of7
Action
Notice of Final Recommendations
Effects of Long-term Exposure to
Lewisite ( L).
for Protecting Human Health
low doses of agents GA, GB,
and Safety Against
VX, Mustard Agent
Potential Adverse
(H, HD, T), and
Summary
Agents GA, GB, VX, Mustard Agent (H, HD, T), and Lewlslte (L) are now stored by the Department of
Defense (DOD). Public Law 91-145 (50 U.S.C. 1521) mandates that all unltary (self-contained) lethal
chemical munitions be destroyed by 1994. Public Law 91-121 and Public Law 91-441 (50 U.S.C.
1512) mandate that the Department of Health and Human Servlces revlew DOD plans for disposing of
these munitions and make recommendations to protect human health. Publlc comment was
requested on these recommendations; this notice summarizes comments received, responds to those
comments, and states the final recommendations.
Effective Date: March 15, 1988.
For Further Information Contact:
Linda W. Anderson, Chief, Special Programs Group, Center for Environmental Health and Injury,
Centers for Disease Control, Chamblee 27, Room 1208, MS F29, 1500 Clifton Road, NE, Atlanta,
Georgia 30333.
Supplementa ry Information
On December 22, 1987, the Department of Health and Human Services (HHS), Centers for Disease
Control (CDC) published "Recommendatlons for Protectlng the Health and Safety Agalnst Potential
Adverse Effects of Long- Term Exposure to Low Doses of Agents: GA, GB, VX, Mustard (H, HD, T),
and Lewisite (L)" in the Federal Register (52 FR 48458), seeking public comment. We received
comments from eight respondents.
One respondent indicated that the recommendations had been sent to several agencies within their
organization for review and that they had approved the statement as published. Two other
respondents objected to the use of "weak" to characterize the carcinogenicity of mustard agent. Both
polnted out that the term is not used by the Internatlonal Agency for Research on Cancer; one noted
further that the National Toxicology Program has not accepted "weak" as a standardized descriptive
term. The specific terms "strong" and "weak", as applied to carcinogens, were once used in
extrapolating animal data to human prediction. The way in which that was done is not now generally
accepted. We agree: the word "weak" has been deleted.
One respondent objected to the statement "Some evidence suggests that Lewisite might be a
carcinogen...." and referred to a recent comprehensive review of the published literature on Lewisite
as well as unpubllshed reports avallable ln the llbrary of the U.S. Army Chemical Research,
Development, and Engineering Center at Edgewood Arsenal. The respondents concluded, from their
review of the literature, that Lewisite was not carcinogenic. The documents do mention the same
evidence for carcinogenicity which was considered by the group. We agree that the evidence available
to us does not seem to be of the quality required to label a chemical as "suspected carcinogen" but
will stand by the original phrasing; "Some evidence suggests that Lewisite might also be a
carcinogen...." (emphasis added).
http : I I w onder. c d c . g ov/wonder/Prev Gui d/p0 0 00027/p 0 0 0 002 7 . asp U2312008
Final Recommendations for Protecting Health and Safety Page 3 of7
We were advised that the NIOSH recommended standard for occupational exposure to arsenic does
not dlstlnguish between organic and lnorganic arsenic and recommends a standard of 0.002 mg
(As)/m(3). The suggested control limit for Lewisite is equivalent to 0.001 mg/m(3), measured as
arsenic'and is thus lower than both the OSHA Permissible Exposure Level and NIOSH's more
protective recommendation. The same respondent objected to the comparison of cancer risk to risk of
death by injury in industries considered nominally safe on the grounds that such a comparison
supports the belief that injury rates are acceptable or irreducible. The obJection is valid and the
comparison has been removed.
Another respondent suggested that the recommendations would be strengthened by references. An
extensive bibliography is available on request. The respondent also recommended use of a pressure-
demand respirator when entering munition-storage igloos. This is in keeping with joint NIOSH-OSHA
respiratory selection policy guidelines. Entry into igloos is governed by storage regulations and is not
included in the Chemical Stockpile Disposal Program. HHS has no authority in matters concerning
storage of chemical weapons. We therefore cannot include thls recommendation under Pub. L. 91-
L2t,9L-44L, or 99-L45. We will forward the suggestlon to the Army Surgeon General's Office for
their conslderatlon.
An unpublished paper on the toxicology of VX was forwarded to us by an interested party. The paper
suggested that there was a high probability of serious non-lethal effects wlth exposure to VX. The
doses required to achieve these effects were not specified. Most of the paper was conjecture, based
on analogy with other organophosphates. Information available in the open literature describing
actual studies on VX was not used. These and other weaknesses in the paper rendered it not halpful
for our deliberations; we do not concur with the conclusions of that paper.
One respondent reminded us that a portion of the stockpile ls held in the Federal Republic of
Germany. This was noted.
A minor typographical error, "skin" mlsspelled "kin" was noted by several respondents. In addition to
this correction, changes have been made in the text to note the NIOSH recommendation, to convey
the sense of the epidemiologic evidence on carcinogenic potency without use of the term "weak," and
to delete reference to deaths by injury in industries considered nominally safe. The final text of the
recommendations follows.
Recommendations
Section t4L2 of Pub. L. 99-145 (50 U.S.C. 1521) mandates that the present stockpile of lethal
chemical agents be destroyed by September 30, 1994. Public Law 91-121 and Pub. L. 91-441 (50
U.S.C. 1521) mandate that the Department of Health and Human Services (HHS) review Department
of Defense (DOD) plans for transporting and/or disposing of lethal chemical agents and make
recommendations for protecting human health and safety; HHS has delegated this authority to the
Centers for Disease Control (CDC). In the absence of Federal regulatory standards, DOD has
developed safety and health standards for handling these agents. Therefore, CDC revlewed the data
and is making recommendations for protecting human health and safety during the transportation
and/or dlsposal of these lethal agents.
The national stockpile of lethal chemical agents includes six chemicals:
o GA (Tabun or ethyl N, N-dimethyl phosphoroamidocyanldate, CAS 77-81-6)
o GB (Sarin or isopropyl methylphosphonofluoridate, CAS 107-44-8)
o VX (O-ethyl-S-(2-diisopropylaminoethyl)-methyl phosphonothiolate, CAS 50782-69-9)r H, HD (Sulfur mustard or di-2-chloroethyl sulfide, CAS 505-60-2)
o T (Bis(2-chloroethylthioethyl)ether, CAS 63918-89-8)
o L (Lewisite or dichloro-2-chlorovinylarsine, ffS 541-25-3)
The DOD stores these agents in bulk containers and/or munitions at eight locations within the
continental United States. The remainder of the stockpile is stored outside the continenta! United
States on Johnston Atoll in the Pacific Ocean (Southwest of the Hawaiian Islands) and in the Federal
http : I I w ond e r. c d c . g ov/wonde r/P rev Guid/p 0 0 0 0027 I p0 0 0 0 0 2'l .asp U2312008
Final Reoommendations for Protecting Health and Safety
Republic of Germany.
None of the nerve agents are mutagenic. Results of recently completed studies on
reports of studies on VX indicate no teratogenic effect. The EEG changes reported
with GB were considered to be of questionable significance--given the difficulty of
http ://wonder.cdc.gov/wonder/PrevGuid/p0000027 / p0000027 .asp
Page 4 of 7
Previously, HHS has made recommendations for protecting human health from the adverse effects of
acute exposure to agents GB, VX, and mustard agent. Cltizens near depots where chemlcal weapons
are stored have expressed concerns about potential for delayed effects of acute exposure and about
the potential health effects of long-term exposure to low doses of agents. (Here "low dose" means an
airborne concentration of agent below the control limits.) To resolve these questions, CDC gathered
data on these agents and held an open meeting to discuss the potential delayed effects of acute
exposure and of adverse effects of long-term exposure to low doses of these agents. The meeting,
announced in the Federal Registerdated August 20, t987 (52 FR 3L449), was held September29-30,
L987, in Atlanta, Georgia. The CDC invited consultants and the publlc. Comments from individuals
rather than group comments or consensus were solicited.
Llke widely used insecticides, the nerve agents, GA, GB, and VX are organic compounds containing
phosphorus (organophosphorus compounds). They affect neryes, muscles, and glands by inhibiting
acetyl cholinesterase, an enzyme these tissues must have to function properly. Sulfur mustard (H.
HD, hereafter referred to simply as "mustard agent") and Lewisite (L) are vesicants--that is, they
cause chemical burns or bllsters of the skin and mucous membranes, such as the conjunctiva of the
eyes and the mucosa of airways. Lewisite is an organic compound containing arsenic. A sixth agent,
HT, is a mixture of mustard agent, agent T (Bis(2- chloroethylthioethyl)ether) and impurities. Very
little is known about the long-term toxicity of agent T, Agent T has a much lower volatility than the H
with which it is mixed. It is not expected to constitute an airborne hazard unless mustard agent is - 2
also present at concentrations much higher than permitted. Almost all (99.7o/o) of the vapor released /
by HT is mustard agent. HT control limits will therefore be identical with those for HD, with Jconcentrations measured as HD. :
During the public meeting on the potential effects of exposure to these agents, concerns that were
raised included: organophosphate-induced delayed neuropathy; electroencephalographic (EEG) or
other functional changes followlng exposure to organophosphates; the carcinogenicity, mutagenlclty,
and/or teratogenicity of organophosphates; the cumulatlve effects of organophosphates, decreasing
resistance to organophosphates pesticides; the carcinogenicity, mutagenicity, and teratogenicity of
mustard agent and Lewisite; delayed keratitis (injury to the cornea of the eye) following exposure to
mustard agent; the response time, sensitivity, and specificity of monitors; the amount of agent in
various parts of the storage and demilltarlzatlon facilities; the response tlmes and efficacy of
abatement procedures in the event of an upset in plant operations or a release from storage,
transportation, or incineration; use of historical monitoring in process control; and interactions of
agents with other chemicals in the environment.
Published and unpubtished repofts of all potential adverse effects including carcinogenicity,
mutagenicity, and teratogenicity for all agents were considered. Information on human
carcinogenicity following wartime exposure to vesicants supplemented experimental data for mustard
agent and Lewisite. Since the acute toxicity of GA and Lewisite had not been reviewed before, it was
considered along with the potential long-term health effects. Reports relating delayed keratitis to
mustard agent exposure were evaluated. The reports on delayed neuropathy and on EEG changes
associated with poisoning by GB were available. In addition, individuals contributed critical
information from their own experience and knowledge.
The ability of organophosphates to cause delayed neuropathy has been tested in domestic chickens, a
sensitlve lndlcator species. The chickens are given doses from 20 to more than 100 times the mean
lethal dose and, for the chlckens to demonstrate this effect, they must be protected from death by
pretreatment with atropine or with atropine and oxlme. GB caused neuropathy in chickens only at
doses several times greater than the mean lethal dose. Under similar conditions, VX did not induce
delayed neuropathy. Neuropathy is considered an unlikely outcome from either acute intoxication
with any of the nerve agents or from long-term exposure to them.
GB and initial
after intoxication
demonstrating such
| 12312008
Final Reoommendations for Protecting Health and Safety
changes and the absence of clinically significant effects even when EEG changes are present.
Page 5 of 7
HHS had not previously reviewed standards for GA. The available information indicates that about
twice as much GA as GB is needed to produce acute toxicity. Data for adverse reproductlve effects
are less complete for GA than for GB. The llmited amount of GA present in the stockpile (4 tons) and
the remoteness of the area where it will be destroyed (Tooele, Utah) provide further assurances that
human health will be protected at the same control concentrations previously set for GB.
Questions related to the nerve agents proved relatively easy to resolve. The information bases are
falrly complete, and there appears to be little risk either of adverse health effects from long-term
exposure to low doses or of delayed health effects from acute exposure. On the basis of the evidence
reviewed, HHS concludes that human health wlll be adequately protected from exposure to GA, GB,
and VX vapor at the concentrations shown in Table 1. Even long-term exposure to these
concentrations would not create any adverse health effects. At these concentrations, no detectable
reduction in resistance to organophosphorus pesticides would occur.
The control limits contained in Table 1 are substantially below concentrations at which adverse effects
have been observed for mustard agent and Lewisite. Delayed keratitis and chronic brohchitis are
effects that follow acute symptomatic intoxication with mustard agent and would therefore not be
expected at the limits proposed. Mustard agent ls not a teratogen, but lt ls a mutagen. Because HHS
accepts that mustard agent is a human carcinogen and because some evidence suggests that
Lewisite might also be a carcinogen, lower levels of exposure are of potential concern. Although the
data suggest that mustard agent is less potent than such other known human carcinogens as
tobacco, radon, and chromates, the data do not permit an estimate of the carcinogenic potency or
the exact degree of the carcinogenic risk with confidence. Quantitative risk assessments prepared by
the Oak Ridge National Laboratories and by a community study group at Edgewood, Maryland were
considered. On the basis of a review of the methodology, we conclude that the many uncertainties in
the method employed preclude its being used to define precisely the acceptable exposure limits to
mustard agent.
We conclude that the proposed work-place limits appear to provide adequate protection for workers
during the limited time of potential exposure prior to completion of the Chemical Stockpile
Demilitarization Program. Control of the stack emissions and the work-place air in accordance with
the limits for mustard agent given in Tables 1 and 2 will amply protect a general population 1,000
meters or more from a demllltarlzation site or transportation route.
Exposure to or contact with mustard agent by any route--respiratory, skln, or oral--should be limited
to the extent practicable. This can be done by using appropriate engineering controls, personnel
protective equipment, and work practices. Concentrations in the work-place environment and
surrounding air should be measured and verified by instruments that can reliably detect
concentrations at or below the control limits. Rail cars or other transport vehicles should be treated
as work places for this purpose. At this time, the most sensitive monitors can reliably measure 0.003
mg/m(3) of mustard agent and Lewisite in the work-place air. The cycle time for mustard agent is 8
minutes--that is, the test is automatlcally repeated every 8 mlnutes. The cycle time for Lewisite is 12
hours. This level of exposure would be adequate protection for public health. The Army has reported
the capability to monitor for mustard agent at concentrations as low as 0.0001 mg{m(3) using a 12-
hour sample time. This capability has been proven under usual ambient conditions at only one site, If
it will not delay disposal, it is recommended that such capacity be demonstrated at and used for all
sites where mustard agent will be transported or destroyed, The capacity to conduct such monitoring
at al! sites with mustard agent would represent a redundant safety factor.
Toxlcological information speclflc to Lewisite is sparse. More is known about arsenic-containing
compounds in general, but caution must be used ln extrapolation. The recommended control
concentration limit, 0.003 mg/m(3), (measured as Lewisite) in air is equivalent to 0.001 mg/m(3),
measured as arsenic and should be adequate to protect public health. The Occupational Safety and
Health Administration had promulgated a standard of 0.5 mg/m(3) (measured as arsenic) for organic
arsenic concentrations in work-place air. The National Institute for Occupational Safety and Health
(NIOSH) has recommended a standard of 0.002 mglm(3) for all forms of arsenic. The proposed
http : //wonde r. c dc . g ov/wo nde r/P rev Gui d/p0 0 0 00 27 I p0000027 . asp | 12312008
Final Rgeommendations for Protecting Health and Safety Page 6 of7
Lewisite control limits are lower than the existing OSHA occupatlonal standard for organlc arsenic by
a factor of approximately 500 and are lower than the NIOSH recommended standard by a factor of 2.
The Army should seek, through engineering design and operational controls, to minimize exposure to
Lewisite. The facts that Lewisite will be destroyed only at Tooele, Utah, a facility remote from
population centers, and that the maxlmum burning time for destructlon of the existing stockpile of
Lewisite is estimated to be less than 30 days provide additional assurance that human health will not
be endangered.
Certain monitoring crlteria are essential because any recommended exposure llmlt ls only as good as
the capabllity to measure and verify the exposure concentrations as they may occur. Specifically, the
Army has agreed to provide data to CDC that document accurate and reproducible monitoring for
agents at the recommended exposure limits and at each transportation or demilitarization facility
monitored.
In summary, the control limits speclfied in (Table 1) for all agents tisted are considered protective of
human health. The relatlvely short duratlon of the disposal program provides and addltional margin of
safety. Control llmits for stack emisslons are prlmarlly an englneerlng matter. These limits should (a)
be attainable by a well-deslgned, well-constructed, and well-operated incineration facillty; (b) glve an
early indication of upset conditions; and (c) be accurately measurable in a timely manner,
Limlts based on these criteria will restrict emissions to concentrations wetl below those that would
endanger health; they wlll usually prove more restrictlve than a set on health bases alone. CDC has
found that the allowable stack concentrations proposed by the Department of Army, (Tablg."_2) meet
the criteria above and are more restrictive than limits set on health bases alone; therefore, CDC
recommends no changes in the concentrations. The concentrations must be evaluated by air
dispersion modellng a worst-case-credlble events and condltlons specific to each site to ensure that
the control limits for the general population and work-place (Iah!el) would not be exceeded as a
consequence of releases at or below the allowable stack concentrations.
Dated: March 8, 1988,
Robert L. Foster, Acting Director
Office of Program Support, Centers for Disease Control
(FR Doc. 88-5573 Filed 3-14-88; 8:45am) Billing Code 4150-18-M
POINT OF CONTACT FOR THIS DOCUMENT:
To request a copy of this document or for questions concerning this document, please contact the
person or office listed below. If requesting a document, please specify the complete name of the
document as well as the address to which you would like it mailed. Note that if a name is listed with
the address below, you may wish to contact this person via CDC WONDER/PC e-mail.
NATIONAL CTR FOR ENVIRONMENTAL HEALTH
CDC (NCEH) Publications
4770 Bufford Hwy, NE MS:(F-29)
Chamblee, GA 30341
Agent General Population Workers
GA, GB
\r'(
H, HD, HT(2)
0.000003 (3x10-)
0.000003 (3x10- )
0.000L (lxL0-)
0.0001 (1xl0-)
0.00001 (1xL0- )
0.003 (3xL0- )
http : / I w ond er. c dc . go v/wo nd e r/P re v Gui d/p 0 0 00 0 27 / p00 0 002 7 . a sp v2312008
Fi.nal Rpcommendations for Protecting Health and Safety Page 7 of 7
0.003 (3xLO-)0.003 (lxtO- )
Averaging Time 72 Hours I llourE
1. Protection against elq)osure to agents in aerosol and liquid form muEt be
sufficient to prevenE, direct contact with
2 . DaE,a support,ing t,he ability to monitor f or
mg/m ( 3 ) at, all sites should be developed .
the skin and eyes.
mustard agent at 0.000L
HT is measured as HD.
Table 2
Table 2 -- ALL0WABLE STACK CONCENTRATIONS (MG/M(3) ) FoR CI{EMICAL AGENTS
Agent Maximum Allowable Stack Concentrat,ion
GA, GB
\irx
H, HD, HT(L)
L
( 1) HT j.s measured. as HD.
0.0003 (gxf 0- )
0.0003 (3xL0-)
0.03 (3xL0-)
0.03 (3x10-)
This
Hp.me- I Policies and Regulati-p-ns
aAFEE o HEALTX I EF r PEOPLE-
Centers for Disease Control and Prevention, 1600 Clifton Rd, Atlanta, GA 30333, U.S.A.
Tel: [phone] / Public lnquiries: [phone] / [phone]
q1/t \.
,N'
page last reviewed: Wednesday,
I Pisclaimer I e-Government I
August 29, 2OO7
EPIA I Contact Us
/-'-\- Departmgnt ofi .4 Health\tF 3::#:T,,
1/-((-"
http : I lwo nd e r. c dc . g ov/wo nd e r/P revcu i d/p0 0 00027/p0 0 0 0 02 7 . asp U2312008
o
ENCLOSURE F
Waste Nozzle
Atomrzatton Report
o
frrN sp r?yAnaryss
'#il
$ililMffit
and Research Services
Laboratory Test Report
Conf idential
By: Egemen Ergene
Research Eng ineer
Spray Analysis and Research Services
Sp raying Systems Co.@
Eg eme n . e rg e ne@sp ray. com
Ph: 630-51 7 -127 1
Test Number: 201 0T41
Drop Size Testing of
North American Nozle
Euntinental Research
and Engineering
Prepared For:
Date: April 1 6, 201 0
,N sprayAnaD/sis(rilllt g*,Smg:roa
Introduction
Background
Continental Research and Engineering needed spray droplet size testing of a proprietary air atomization
nozzle within several conditions. Spraying Systems Co., Spray Analysis and Research Services group
used Phase Doppler Interferome@ (PDI) technique to measure the drop size and velocity distributions
of the supplied nozzle. The drop size data will be arulyzed by Continental Research and Engineering to
define the most suitable testing condition parameters for their requirements.
Test Nozzle
Continental Research and Engineering supplied the test nozzle to be characteized in this study. The
nozzle operates with a liquid and a compressed air supply line. A representative image of the target
nozzle is provided in Figure 1.
Figure l. North American Nozzle
,-N sprayAnalysis
Wlflfllr and Research Services
'r r I '- A Seryice of SprayinsSyutaar Co.
Test Fluid
Liquid Supply andflow rate measurement
All testing was performed using a salt water solution as the original fluid is an environmentally health
hazard. Several solutions are prepared to match the density of the original fluid, GA (p:1.073 gl"til.
As a result, the water salinity was determined to be 100 g of salt/L of the mixture. The salt water
solution was supplied to the system by a high capacity tank which was pressurized with dry compressed
air. An air-driven agitator is installed inside the tank to prevent any precipitation of salt. Flow rate of salt
water solution is contolled by Micro Motion RFT9739D4SUA Elite Remote Flow Transmiffer as
shown in Figure 2.Elite series Flow meters have the accuracy of +0.10% within the flow rate range of
this experiment.
It's known that density is not the only parameter to match the sprayability of liquids. Therefore,
viscosity and surface tension of the solution are also evaluated. It's found that at this salt content, the
solution is losing its Newtonian viscosity character. Viscosity was determined to vary between 1.9 cP to
2.4 cP at the estimated shear rate range at room temperature. The actual fluid used by Continental
Research and Engineering, GA, has.a viscosity of 2.277 cP.
Surface tension decreased with the addition of salt. Pure water has a surface tension 72 mN/m and the
solution was determined to have a surface tension of 62 mN/m. Continental Research and Engineering
informed that the original working fluid has a surface tension of 32.5 mN/m at room temperature.
Therefore, the drop sizes with the original working fluid are estimated to be rblatively smaller than the
values determined by using the salt water solution.
Figure 2. Micro Motion Elite Remote Flow Transmitter
,-\ sprayAnaD^is
Y(lllli i**ffim:;ffie
Atomizing Nitrogen Supply andJlow rate measurement
The atomization inside the nozzle is assisted with dry compressed air. The atomization air was at room
temperature (68 F) for all tests. Moreover, it was steady and consistent throughout testing. The
compressed air flow rates were measured with a calibrated thermal mass meter manufactured by
Endress-Hauser. This meter measures the airlnitrogen temperature and pressure at the measurement
location to directly determine the mass flow rate. The high-accuracy (+l%) measurement range of this
meter was from 0.01 scfm to -400scfrn. This device is shown in Figure 3.
Test Setup
Two separate supply systems were used in these tests. The first was a compressed air setup which
provided a constant pressure air supply to the nozzle. The second supply was the pressurized salt water
tank. Figure 4 describes the compressed air and salt water solution supply tank connections.
Figure 3. Endress-Hauser Proline T-mass 65
,\N sprayAnatysis'*ilflfllilt and Research Services
'r I r '' A Servtce of SprayingSr4etaar Co.
Figure 4. Experimental Setup Schematic
In addition to the liquid delivery setups, PDI measurement system test setup was used for this project to
acquire drop size and velocity measurements across the major axis of the spray plume
Phase Doppler Interferometry (PDD
A tno-dimensional Artium Technologies PDI-200MD instrument was used to collect drop size and
velocity measurements, as shown in Figure 2. The solid state laser systems (green 532 nm and red 660
nm) used in the PDI-200MD are Class 38 lasers and provide about 50-60mW of power per beam. This
laser provides sufficient beam intensity power to offset spray density effects. It should be noted that the
PDI system was .operated in a l-D orientation for these measurements, this results in a purely axial
velocity component (speed at which particles are traveling downward in this case). PDI system setup is
shown in Figure 5.
h'essu.G G
,'N SprayAnatysis
Wflf;flfle and Research Servicest r I ! '" A Service of SprayfosSrlutaars Ca
The laser transmitter and receiver unit were mounted on rail assemblies with rotary plates; a 40" forward
scatter collection angle was used. For this particular test, the choice of lenses was 1000mm for the
transmitter and 1000mm for the receiver unit. This resulted in a size range with a size of about 4.2Wn -
480prm. This optical setup was used to ensure capturing a wide range of droplet sizes while maintaining
good measurement resolution. The particular range used for these given tests was determined by a
preliminary run where the Dys.5 and the overall droplet distribution could be examined. This appeared
adequate to collect the target droplet size range produced by the nozzles. For each test point, a total of
approximately 20,000 samples were used were acquired.
The measurement point is formed by the intersection of the 2 laser beams (gleen beams). Because the
PDI technique is a "poinf' sampling method, many measurement points were acquired for each
nozzle/operating pressure. Specifically, 20,000 samples were acquired at 0.5' intervals from the spray
centerline (directly below the nozzle) to outside the spray where no spray was present (5-7 point
measurement total (2.5-3.0" spray radius). All PDI measurements were acquired at a 12" spray distance.
The nozzle was traverse horizontally to measure from the spray center to the spray outer-edge. These
sets of data are averaged by using a Volume Flux-Area weighing method. Weighted averages are based
on the volume flux which passes through each point at which data was collected. These values are also
weighted based on the area of the spray that they are meant to represent. In practice this means that the
measurements at the outer spray plume locations cafiy a large consideration (weight) since they
represent a larger area of the total circular sprayplume region.
The volume-flux-weighted averaging method was conducted as follows. The drop size and velocity
measurements are collected in a 'coincidence' mode; this means that both the velocity and drop size
must be validated by the measurement system for a droplet to be counted. By measuring the drop size
Test Nozzle
Figure 5. PDI system setup
o
,"N sprayAnalysis
'*rtflflInil r**,Itrffim:;ffie
and velocity of each valid drop as it passes through the measurement volume, a calculation of a local
volume flux is obtained. By weighted averaging the drop sizes and velocities by the relative distribution
of local volume flux, regions where a higher volume of spray passes carry more weight. This will
account for regions that may have abnormally high or low drop size. ,
Additionally, the drop size and velocity results were area weighted. This method takes into account the
area that each measurement point is prescribed to represent. For example, when acquiring evenly spaced
measurements moving radially outward in a circular spray plume, the outer point represent much more
spray area than the center point. See Figure 6 for a graphical representation of this concept. Clearly, as
the circle radius (r) increases, the area increases by a2"d order degree.
Through the cornbination of volume flux and area weighted averages, very reliable and condensed
average drop size and velocity values are calculated from very diverse and complex spray characteristics
across each spray plume. Clearly there are very wide distributions of both drop size and velocity
throughout a spray plume, the weighted averaging method described here repiesents the most reliable
method determined by Spraying Systems Co. to present the atomization process.
Figure 6. Circul at area measurement point area weighting concept
,-N SprayAnalysis'*il llflfle and Research Services'r t tr '' A Servtce of SprayingSlatams Ca
Drop Size (Diameter) Definitions
The Dvo.t, Dvo.s, D:2, and Dvo.s diameters were used to evaluate the drop size. The drop size
terminology is as follows:
Dvo.sl Volume Median Diameter (also known as VMD or MVD). A means of expressing drop size in
terms of the volume of liquid sprayed. The VMD is a value where 50% of the total volume (or mass) of
liquid sprayed is made up of drops with diameters larger than the median value and 50% smaller than
the median value. This diameter is used to compare the change in drop size on average between test
conditions.
D:z: Sauter Mean Diameter (also known as SMD) is a means of expressing the fineness of a spray in
terms of the surface area produced by the spray. The Sauter Mean Diameter is the diameter of a drop
having the same volume to surface area ratio as the total volume of all the drops to the total surface area
of all the drops.
Dvo.r: is'a value where l0% of the total volume (or mass) of liquid sprayed is made up of drops with
diameters smaller or equal to this value.
Dvo.g: is a value where 90% ofthe total volume (or mass) of liquid sprayed is made up of drops with
diameters smaller or equal to this value.
Duax: is the value of the largest drop size.
,\N sprayAnalysis
' 4ffi I | f,
u
ru*, 5ffF,?H:;ffie.
Results and Discussion
Table I showi the results the weight-averaged drop size data and axial velocity. As seen from the table
below, axial velocity is dominantly controlled by the air supply as in most of the air-atomization
nozzles. Drop sizes get larger as the fluid flow rate increases and as the atomization air decreases.
Table 1. Volume Flux and Area Weighted Average Drop Size and Velocities
TC
Liquid Flow
Rate (lb/h r)
Air Pressure
(psi)
Air Flow Rate
(scfm)
DVO.1
(pm)
D32
(pm)
DVO.5
(pm)
DVO.9
(pm)
Dmax
(pm)
Ave rage Axia!
Velocity (m/s)
t 200 75 33.85 40.19 6L.94 55.04 111.05 183.53 28.35
2 300 75 34.01 45.38 70.95 73.63 130.30 ztt.2L 28.s0
3 325 75 34.05 48.29 75.L4 75.77 135.68 223.3L 29.07
4 325 50 24.85 49.93 77.43 81.49 153.19 248.56 22.22
Following graphs are showing the axial velocity and the drop size profiles across the spray radius. Series
names in the figures are showing the salt water solution and compressed air flow rates respectively in
the units given by Continental Research and Engineering. Some test conditions have less radial data as
the spray is slightly narower in those cases. Figure 7 shows the axial velocity profile. As would be
expected, the axial velocity magnitudes decrease as the measurement region is moved further
downstream from the exit orifice; also, the velocity is shown to peak at the spray centerline and the
profiles spread out within the measurement plane.
Axial Velocity
r/l
-a
E
h,
+..U
-9(u
-t!'=
70
60
50
40
30
20
L0
0
.{-2OA-75
{i300_75
-+325_75
0.s 1 1.5 2 2.5
Radial Distance frorn Center (inchl
i-
t__*____
I
I
I
I
i-*--_-*.-_'r__ - _-r-_ "_T_-_-_r'---r------r_'---l' i- ---r ____r'-_-_T_*-_--_'-__r___'_T-_ --r-_
Figure 7. Axial Velocity Profiles
As seen from Figure 8, the trend of drop size profiles are very similar in the given test conditions. Larger
drops are located at the inner radius. At the center of the nozzle, relatively larger drops are observed,
which is very common in external mixing nozzles.
,\N sprayAnatysis
Hlllfllt and Research Services'I I I '' A Seryice of SptayingSyreams Ca
D32
.-
E
=Y
o
J!
UIcoLo
120
100
80
60
40
20
0
-+.200J5
{i300_75
+325_75
+*-ll$ 50
0.5 1 1.5
Radial Distance from center linchl
Fisure 8. Sauter Mean Diameter (Dlz) Profiles
Figure 9 presents the volume mean diameter (VMD) data. The VMD profiles are very similar to D:z
profiles that were presented in the previous figure. One of the goals of Continental Research and
Engineering is to keep VMD value less than 100 microns throughout the spray. With 75 psi air pressure,
nozzle is capable of producing drops at the desired range. When the air line pressure is reduced to 50
psi, VMD value is slightly over 100 microns at centerline.
DvO.5
.-
E
=-,o,t{
a-vt
CLoL-cr
120
100
80
50
40
20
o
-{-2OO-75
-G-3OO_75
-,F325_75
-ri-325 50
I
t----.-------.-
l
1
J
i
oo.5 1 1.5 2 2.5
Radial Distance from center (inchl
Fizure 9. Volume Mean Diameter (Dvg.s) Profiles
l0
,\N sprayAnalysis'*{tflililr'r#,5trtrH:ffie
The other goal of Continental Research and Engineering is to
possible. Figure 10 shows the variation of Drvrax as a function
keep the maximum drop size as small as
of the radial distance.
Dmax
,-
E:,Y
o.!0
coLo
400
3s0
300
250
200
150
100
50
0
.r+-200_75
{-300_75
..f-325_75
-ii-325 50
0.5 1 1.5
Radial Distance from Center (inch)
Figure 10. Drraax Profiles
As seen from the figure above, at constant amount of salt water solution, feeding more air to the nozzle
helps to reduce the maximum drop size. This effect is not very noticeable at the outer radius. However,
significantly large drops are observed at the centerline.
Conclusion
The results presented here acquired with the Phase Doppler Interferometry (PDD provides quantitative
characteization of the nozzle supplied by Continental Research and Engineering Drop Size/Velocity
data of several test conditions with different amounts of salt water solution and compressed air are
compared.
These measurement results provide clear spray characterization results with the North American Nozzle.
Additional information can be drawn for the 'raw' data. However, this raw data requires proprietary
processing programs to access the information. Therefore, if there is any information not contain within
the delivered results that is of use to the Continental Research and Engineering, please contact Spraying
Systems Co. and the data will be accessed and provided.
Appendices
Continental Research and Engineering is planning to prepare a CFD study based on the drop size data.
For this purpose, axial velocity vs. drop size data is provided for some test conditions at centerline.
l1
,\N sprayAnatysis'+ilflffllr and Research Services
'r r r '" A Seruice of SproyingSysGams Co
Figure I 1. Velocity vs. Drop Size for 200-75 case at centerline
Figure 12. Velocity vs. Drop Size for 325_75 case at centerline
t2
/-\ spraynp2lysis
o":llllflr ru*,Iffim:ffie
100.0 :m,0
Umrtcr(fn)
Fizure 13. Velocity vs. Drop Size for 325_50 case at centerline
l3
ENCLOST]RE G
Table Y4
Metal Feed Rates
o.Y'ao!,(Eotr-CLCLooFe-*,
'=o
{r
,
(Ecnol-l-Jol-eOL
-
e-
R
cl
t
(v
)

=
r.
=

ll
o1
1
.
te
.CU'
_(
E
a=
ro
t
r-
N
l-
r
-o

-o
€(
0
(\

co
Fl
f
,
)
F
.F
r

CD
6s
?
oo
ra
--
ll
L.oE
Eo
r
ar
(E
*
ll
o
g
E'

iE
tr

E'
(!
o
tr
t
(u
=
il
omt
s
F-A
o
?
ot
E
-o
(
L
E=

=
tr
-
c
t
m
;(
LE
o.
g
AL
-JI-
-
F9o

o
E3
E
gL

F'
(E
-
c

tr
-.
1
5
(
/
,
-
gs
:
$a
:
=
ts

b
Or
E
=l
(
r

-r
E$
t
9
.g
;
.r
o
o
E
3g
O
(U
-
goz
tJ.
I(\
F.c
t-o+,
(EuEoolJ
.+,
troE'
)@oo+,GtE'ooII-(E
a-
,o=
Le-INF-o
I
oNc,
oC'
)
coci
(0
rOFF
(oco1(
)
F
@o)c\C\
l-e-o-o
(0qo
o*,otrooo
oa?
(0C'
)
@(\
I
F
o)nFo)
F
ct
)
I-(E*,o=oa-*JGo
t,o+.c
t
o-o
l-+,
(E6.iEoU'
t:o+om+oo
a-+,
(EoI=oJ
F-o
og
a-
l-oe-o
E=g
9&
fi
E
g
He
)
roO)qO
lr
)NC;
N(o$1-
-N
rooqo
oooqo
(0cf
)
l:
.qO
oooqo
(ooOqo
cf
)ooqo
rooqo
rooqo
roooC;
CAOOqo
oooqo
roOqo
(of:
.oqo
(o(oqo
C8?E5
8;

6
XCo\
/
cf
)
rO
cf
)
r
r
r
cf
)
-
N
r
F
N
r.
IF
lO
r
EAot
r
a.
0
o(
o
oo
N
N
N
r
r
N
N
r
r
r
N
r
N
r
E
o=E3
55
(,ol'
,
,
|
rOoN
-oo
(f
)oNo
o(om
oom
o00
oEO
(f
)oNO
oNJC)
No-oo-
o
aZ
Nooa
oc!
(,
)
oa
1r
)oN
oN
ooco
=(Uo
@q(oN
LO\Nr
NNq$f-
tta?
l-cf
)-
NFqO)
oqor
nNrF
(oO)q-rO
ti
f
r.
c
)
c"
j
(o
O)
FF:
.oN
$cf
)q\t
rO
\@ro
(oqoN
f:
.
oq
f-o!-
o)q@rr
N$qorO
Na?
rO(o
ilt-e-.c
lo+,(t
tE'oolro.t
sa'=oJ
pe
oq
)
(U
-
?
nsca
ttrco
ooo_
rNcf
)
@c?o
(oqo
qo)O)
(oqo
ar
rt
r
)qoV
qr
Na?O
@ro
cf
)o,
T.
(f
)nlo
@qo
sFo
lr
)qoV
ono
c!$r
rf
)+rt
E.EE
oEc
.9coa
EJ.E(U00
EJ:=Eoco
Cot-oco
E:l
.E]C(UO
EEot-
.CO
=o-ooO
l-oo-o-o(J
E(EoJ
oaoooC(!
e=lot-o
6.Y.9z
EJ.Eooa
oa
E.=EF
tr
EJE(UC$
oN
?-o
a-+,
(t
r=o(Eoo+,
(EtEooIJ
.e
r-
oE?-IEo?-'=-9l-
r-oh
I
G+,o=o-Jl-
ENCLOSTJRE H
Trunsparency
Bore Scope Images
1A
ra
*r
=
tr
4H8
t_
YO'

E,
Tr
O
ry
U
E=
o
B
or
)
6
OJeE
o
d
g
j
pE
e
-?
-.r
.
0
j
oo
6
zz
J
aoo)GEoo-ooaol-oml-gREN5o
C)CoF;
.
.
.
'
,
oCol-(Uo-aC(Ut-F
EE'=o-ot,L-G=oFE"
tr
-tooJCLol-
t,tr
IJ
Jo-(!oE'
l-o=o1-E'
)
tr
.YooJG=opo+,
!E'
)E
E'
tr
II
JE'
)5o-ot,L(E=oFED
tr
.YooJEo*,+,oo
!,trulo
.G
oE'
LIE=oFE'
)
tr
.YooJ(E=opU'
Ilt
soJ
LON$Noao(r
)
(UEoo-oC)ac)
t-om
al-oC'6
.l
-
,
CoOCoFoCooCol-(Uo-aC(Ut-FoOo
t,cII
JoGot,LG=oFE'
)
tr
.YooJEo+,+,oo
t,tr
IUo.:GoE'
L.G=oFE'
)
tr
.YooJCLoF
o
{r
,
?LooE6
o'
=
E
E
E
O{
o=
E
=t
g
o-
t
J
o
pE
g
=t
r
o
.9
.
9
c
l
JA
J
oo
o
zz
z
aoo)GEoo-ooaot-omt-

-+
ed
I-

I\
t-
(U

Cr
)
{r
,

!r
C\oo
OCoFoCol-Go-aC(Ut-F
t,tr
]UE"=-o-ot,L-G=oFE"
tr
a--tooCLoF
!,trUJo-:(Eo!,L-G=oFcD
tr
a-.YooJ-G=opU'
+,
!E"
a-tr
E'
tr
IJ
JcD:,o.o!,t-G=o]-C,
,
,
tr
.YooJEo+,
.Joo
E'
tr
IJ
Jo(!oE'
l-t!=oFE"
tr
.YooJ-(gBopogIL
oJ
at-oCE$
CL
O
ON
oc
e
r
5o
l-taoo
co
)
og
F
Pop3
(u
O
o-
a
?s
)
sb
Fm
oOo
T'
tr
IJ
Jo-:oot,LG=oFE'
tr
a-.YooJEo+,+,o6
E'
trUJo(Eo!,Lo=oFE'
)
tr
a---ooJCLoF
otr
!I
GEoC)
.=p=ct
!-Joll
g
l
;
iHt
s
r
,
EE
E
=
Eo
-

dx
z
E
t;
6E
r
-
g
=E

E
-e
r
)
6
*E
o
(it
t
r
J
9-
(
2
-
zi
t
oE.
0
.
3
oo
6
zz
J
ao(r
)
(UEoo-ooa0)
t-oml-

-+
oi
\
=\
,
.=
No(
o
Ec
o
oO
OCoFoCot-
(Uo-oCol-F
E'
tr
IJ
JE'
)
JEot,Lo=o]-E'
)
tr
a--tooCLoF
E'
tr
IJ
Jo-Go!,LG=oFE"
tr
a-.Yoo
.J
-G=opo{i,
s-E)
a-t
E'
tr
IJ
JE)=o.oE'
LG=oFcncl(ooJEo+,+,oo
E'
tr
IJ
Jo2Go!,L(E=oFE'
)
tr
.YooJ(E=opovIL
oJ
at-oCE\
r
cc
o
ONos
(-
\
'
-oo
l-taoo
co
)
OE
)-
Pop3
(U
O
o-
a
?s
)
sb
Fm
oOo
t,cUJo:Go!,LG=oFE,
,
tr
.YooJEo+,+,oo
!,tr
IJ
JoGo!,LG3oFc,
)
tr
.YooJCLoF
.A
ra=o\/E'orh
,oorh
,ooJoz
{r
,troir
E
o-
LOo-

too
E,

I-
'=

o-
Jcr

E'
tI

tr
rI
-l
ooa
-Q

P-
G-
-Gooo'
=
OLo.
9
taoo
zz
f-otr
l-
(U+,
troo.=p=E
.IJo-c
lGl-ooooutroz
ooCD
(UEoo-ooaot-omt-

/n
ox
-
Y
t-

,-
f
r-

\/
(U
0
)
EO
D
oo
OCoFoCol-Go-aC(Ut-F
t,trUJE'
)
JdoE'
Lo=oFE'
)c-tooCLol-
!,tr
IJ
Jo-:
(EoE'
LG3oFE'
)
tra-
.YooJ(U=optt
,+,s-E"E
t,trulE'
)3-Got,L(u=oFE'
)
tr
.YooJEo+,+,oo
E'
truJoGoT'
l-G=oFE'
)
tr
.YooJ-G'=opovrLoJ
aI-oCEc
o
coooOP
1r

\'
Lroo
l-taoo
co
)
OE
F
Pop3
GC
)
o-
a
?s
)
sb
Fm
oOo
E'cII
Jo(Uo!,L.
(E=oFE"
tr
.YooJEo+,+,oo
E'
trUJoGoE'
L(E=oFE"
tr
.YooJCLoF
6I
U=60
L.
YO-

E,
Ih
,
E
8
tr
o
o
of
/
)
*
,
"o
u_
,

+,
gr
E
o
LdG
J
OI
PE
E
rI
F
l
-
.f
.
0
i
JAoo
a
zz
J
U)o(,
)
(UEoo-ooaol-omt-

fn
e6
.=

0D
(U
l
r
)
E\
f
,
oo
OCoFoCot-$o-aC(Ut-F
t,trUIE'
)
JEoT'
L(E=oFE'
)
tra-
.YooCLoF
E'
trUJo2(uo!,LG=oFEDc
a-.YooJG=opUt
*,e-cDE
!,tr
IJ
JE'
)=o.o!,LG=oFE'
)c.YooJEo+J+Jom
!,tr
IJ
Jo2(Eo!,LG3oFcn
tr
.YooJG=opCI
'EoJ
@LOco
LO\toaoo)
(UEoo-oC)aol-om
aI-oC'6
{r
,
CoOCoFoCoOCoI-(Uo-aCN1-FoOo
t,cLl
Jo:Go!,f-G=oFcn
tr
.YooJEo+,
{r
,oE
E'c]UoGoE'
l-G'=oFE'
)c.YooJo.oF
aE=gE'o
{r
,
oo*r
,ooJI
ooJ=oJ
+,
troooLo-pI
oa{r
,
trG'o
IItF'E.9
)aoz
rh
,
troooLo-p=ct
TIJoz
a:
o(r
)
(UEoo-ooaot-oml-

-+
OA
-
Y
.=

co
G(
o
E\
T
oo
C)CoFocq)
l-(Uo-
U)CGt-F
]
t,tr
lI
JE'
)=o.ot,Lo=oFcr
)c.Yo-9CLoF
E'
trUJo(EoE'
L(u=oFE'
)
tr
.YooJ(E=opo+,
.CE"E
!,tr
IJ
JE'
)=o-oEl-(U3oFE'
)
tr
.YooJEo+,
-,o@
t,trUJo.:(Eo!,f-G=oFE'
)
tr
.YooJG=op(t
,
gt+
-oJ
$oco
(o\roaoo)
(UEoo-oOaoI-om
a1-oC'6{-
,CoOCoFoCoOCoI-$o-aC$I-FoOo
t,cII
Jo(uoE'
LG=oFED
tr
.YooJEo+,
+r
,oo
!,tr
IJ
Jo.:(UoE'
L(E3ol-E'
)
tr
--ooJCLo]-
14
,aI=o\/tto*,oo{r
,ooJoz
t-otr
!-
TE+,
troo.Ep=cr
a-Jo
.c
T
GLo8
{r
,
o?
lV
---
-
o
6|
u
,
E
zo
L
LOo-

10
,oEi
Jcr

!,
tr

rr
-
I
JOoa
-Q
E
GL
jt
t
r
ooo'
=
OLoj

.9
E,
A
oo
zz
aoo)
(UEoo-oC)aol-omt-

/n
ei
d
.=
N
GC
o
EL
O
oo
OCoFoCol-(uo-aCGt-F
E'
tr
IJ
JE'
)
JEo!,LG=oFE"
tr
-vooCLoF
E'
trUJoGoE'
f-(E=oFE'
)
tr
.YooJG=opo{J?-E'
tr
!,oLJyCLG'ooE)G.E--G=opo+,?-C'
)Eoz
!,trUIE"=o-oE'
L(E=oFE'
)gtaooJEo+,+,oo
!,clt
Jo.:(Eo!,LG=ol-E'
)c.YooJG=opoEoJ
aI-oCEc
o
c(
o
Ol
-
?8
-oo
l-taoo
c(
,
)
OE
F
Pop3
(U
(
)
o-
a
?o
sb
Fm
oOo
E'cUJo-:Got,
l-G3oFE'E.YooJEo+,*,oo
E'
tr
IJ
JoEoE'
l-(E=oFE'
)
tr
.YooJCLoF
oc
.I
(EEoo.=pIJcr
IIJ-g
.c
T
Gl
+
,
6t
r
aoEu

E
E
o-

E
^
-
E
E
3
JE
r
r
r
oA
=
sI
E
E
gt
s
oo
o
1F
1
r
r
!
r
xt
r
o
u.
g
o
ta
J
oo
o
zz
z
aoo)
(UEoo-ooarot-oml-
NOi
n
-\
,
t-

,^
\
.-

\/
($
r
Eo
o
oo
C)CoFoCot-
(Uo-aCGt-F
T'
trutE'=o.oE'
LG=oFE"c.YooCLoF
o.c
I
(E
II
(E(Uocr
)
c,Eoz
t,tr
IJ
Jo(EoT'
t-(!=ol-E,
,
tra-
.YooJo=opo*,
.CE'
)
tr
t,tr
IJ
IE"=-o-o!,Lt!=oFE'
)c.YooJEo+,
*r
,oo
E'gIJ
Jo2Go!,l-G=ol-E,
,
tr
.YooJ(u3opog*-oJ
a1-oCEF
-
co
oc
o
?E
-oo
Faoo
C
C'
)
og
F
Pop3
(U
(
)
o-
a
?s
)
sb
Fm
oC)o
t,trUJo:(EoE'
L(E=oFE)g.YooJEo+,+,oo
E'
truloGoE'
L-
t!;oFED
tr
.YooJCLoF
o
I
ENCLOSURE I
CDC Lewisite
DAAN{S Class I
Method Approval
t
DEPARTMENT OT HEATTH & HUMAN SERVICES Public Health Service
"":l"J;"T,ffii"Ti"?Ti.'
Atlanla GA 30341-3724
April 10,2003
Mr. WilliamJ'B. Pringle
Chieq Environmenul and Monitqing Office
Prograur Manager for Ctreutical Demilitarization
Environmenol and Monitsring Ofiice
ATTN: SFAE€D'MM (Edge$,ood ArGs)
Aberdeen Proving Groun{ MD 210t04005
Dcar Mr. Pringle
Thank you for yorn later dsted April l, 2003 rqarding rcsults of tlre lewisite vapm validatiou fon
thc MINICAIT{So-XSD and DaaMS as well as tbe report March 2003 rcort ,ao& ite Yopr
Validationlo t E MNICAIIS)ffD ord Drl"llvfri Metlpds. In consultntion with rhc Nadonal
Institute fo Occupational Safery and Heahh (NIOSH), wc have rcviened bch the resuhs and
r€porL
Thc resutts of the vapor validadon tests cstlblish and documented the performance of the L-XSD-
MIMCAI\{S0 to +i4fl%naccrracy criterion wSth 95% corlidence for &rch corrcentration. The
accuracy is less thsn the+l-25Vo acccptance criterion forNKf class I mcthods, Hovurver,
opqating conditions uring a +l-25% frr liquid eftallenge recovaies in colrjunction with an alarm
sctpoint of 4Wo of ths TWA monitoring level corupensate for tlre varian$. Under the specified
operating conditions, this is considqed a vslid modified-class I method fo monitoring lerrisite
'n apo. tluoughout the chenrical denrilitarization program.
The results of the vapor validation tcsts cstablish and documcnted rhe perfonmance of thc L
MSD'DAAIv|S to +/-35% accuracy crit€rioo with 95% confidence for each conccut:ation. This is
acceptrble as a quantitative clags I method for a mass-selective dctects udcr the sclestcd
conditions.
The use of liquid stlrdard chollenges above a constant vapor challenge helps defend the liquid
clralleuge approach bcing ured tbr properly functioning anatytical systenu.
We would like to thank you for your ruppct on the vapor validation tasks. We would like to oote
Mr. Nisholas Kurlick's ecrcellent assistance and coordination with CDC and MOSH statr
Please contact Mr. Jotrn Dccker of my staffat [phone] if you havo any questioos.
I Sincoely youm,
/",-rb
Paul Jo€, DO, MPH
Acting Branch Chief, Medical Officer
Chemical Dernilitarization Branch
Division of Emergency and Environrnental Health Serrrices
National Ccrrter for Envhonmental Heahh
I
ENfimSUmJ
.i :
DEPARTIUIENT OF THE ARTUIY
OFFICE OF THE SURGEOH GENERAL
SIOO LEESBURG PIKE : .
FALI.^S CHURCH VA 22441.3268
MCHB-TS-MEM 24 August 2009
MEMORANDUM FOR BG William T. Wolf, Director of Army Safety, 223 23'd Street, Room 980,
tulington, YA 22202
SUBJECT: New Immediately Dangerous to Life and Health (IDLH) Concentration kvel for
Lewisite
1. Per request of the Department of the Army Chemical Safety Council (DACASC) @nclosure,
reference a), an effective Lewisite IDLH concentration of 0.36 mg/m3 is recommended to replace
the 0.003 mdmt value that is currently cited in Departnent of the Army Pamphlet (DA Pam)
385-61, Toxic Chernical Agent Safety Standards. This health-based value is considered appropriate
for determining when air-purifring respirators and self-contained breathing appamtus are required
during Army operations such as demilitariTationoperation on-going at Pine BluffArsenal.
2. As noted in the DA Pam, the existing Lewisite IDLH value was not toxicologically derived and
was detection based due to perceived concems regarding carcinogenicity. The recommended value
of 0.36 mg/rn3 is'considered a straightfonrard, scientifically defensible, toxicologically based,
reasonably protective effective IDLH concentration level.
3. The enclosed memorandum documents the health and toxicological basis for deriving the
recommended IDLH value. The evaluation addresses potential of both carcinogenic and non
carcinogenic health effects. It was prepared by the US Army Center for Health Promotion and
Preventive Medicine in conjunction with external subject matter experts who have been involved in
a variety of past and on-going efforts pertaining to the development of health based exposure limits
for chemical warfare agents to include an IDLH for the blister agent sulfur mustard.
4. Inquiries reghrding this recomrnended Lewisite IDLH can be directed to Ms. Veronique
Hauschild, Directorate of Occupational and Environmental Medicine, USACHPPM, commercial
[phone], DSN 584-1010, or email: [e-mail].
FOR THE SURGEON GENERAL:
Encl TIMOTHY K. ADAMS
Brigadier General, USA
Functional Proponent for Preventive Medicine
MEMORANDUM FOR RECORD
4 August 2009
SUBJECT: New Immediately Dangerous to Life and Health (IDLID Concentration
Level for l-ewisite
l. References:
a. Email, To OTSG (COL Hewitson, COL Evenson and COL Rowe), from
Mr. Stephan Graham, USACHPPM, (as Chair ofthe Department of Army Chemical
Agent Safety Council (DACASC) Chemical Agent Technical Subgroup (CATS), Subject:
DACASC Request for Use of Air Purifring Respirator (APR) Against Lewisite,
24 June 2009.
b. Department of the Army Pamphlet (DA Pam) 385-61, Toxic Chemical Agent
Safety Standards, December 2008.
c. Army Regulation AR 40-5, Preventive Medicine,2007.
d. Acute Exposure Guideline Levels (AEGLs) for Lewisite 1 (CAS 541-25-3),
Lewisite 2 (CAS 40334-69-t) and Lewisite 3 (CAs 40334-70-l\, Technical Support
Documentn Interim l, July 2007. Available at http:llwww.epa.gov/opVaeeVoubs).
e. DHHS (US Department of Health and Human Services). 1988. Centers for
Disease Control and Prevention, Final Recommendations for Protecting the Health and
Safety Against Potential Adverse effects of Long-Term Exposure to Low Doses of
Agents GA, GB, VX, Mustard Agent (H, HD, T), ad Lewisite (L).Fed Reg 53:8504-8507
(15 March 1988).
f. Army Regulation AR 385-61, The Army Chemical Agent Safety Program, Table
Z.Z,page 11,12 October 2001.
g. DHHS.2004. Centers for Disease Control and Prevention Interim
Recommendations for Airborne Exposure Limits for Chemical Warfare Agents H and
HD (Sulfrrr Mustard). Fed Reg 69 (85): 24164-24168 (3 May 2004).
h. NRC/COT.2003,Nerve Agents (Appendix 1, pp 15-300), and Sulfur Mustard
(Appendix 2, pp 301-383), in Acute Exposure Guideline Levels for Selected Airbome
Chemicals, Vol.3, Committee on Toxicology Subcommittee on Acute Exposure
Guideline Levels, The National Academies Press, Washington, D.C. (Available at
www.nap.edU).
2. Purpose. Per request of the Department of the Army Chemical Agent Safety Council
(DACASC) (reference a), USACHPPM recommends that a Lewisite effective IDLH
concentration of 0.36 mg/m3 should be used to replace the 0.003 mg/# value that is
cnrrently cited in DA Pam 385-61 (reference b). This health-based value is considered
appropriate for determining when air-purifying respirators (APRs) and self contained
breathing apparatus (SCBA) are required during Army demilitarization operations such
currently on-going at Pine Bluff Arsenal.
3. Authority. The Army's Srugeon General is responsible for recommending health-
based exposure levels for military-unique chemicals (reference c). Personnel of the
Environmental Management Program (EMP) of USACHPPM's Directorate of
Occupational and Environmental Medicine have historically been involved with the
derivation of other chsmical agent health criteria such as the sulfur mustard IDLH. The
EMP continues to follow other efforts regarding toxicological derivation of chemical
agent criteria, and thus have coordinated this effort with extemal subject matter experts
from the Oak Ridge National Laboratory (ORNL) Environmental Sciences Division. The
ORNL has been supporting an effort to develop acute (shofi term) public health exposure
guidelines for Lewisite (reference d) and are thus very familiar with the current
toxicological data.
4. Background.
a. Per reference a, the DACASC requested the Surgeon General for guidance to help
address recent problems at Pine BluffArsenal where efforts to demilitarize empty agent
ton containers were being hampered by application of IDLH value (0.003 mg
Lewisite/mll that was cited in iOOA edition of DA Pam 385-61 (reference b). as noted in
the DA Pam, the existing Lewisite eflbctive IDLH value was not toxicologically derived
and was detection based due to perceived concerns regarding carcinogenicity.
b. The Centers for Disease Control (CDC) does have certain oversight to ensure
public safety at US Army stockpile sites and has formally established certain exposure
limits for chemical agents in the stockpile. Though Lewisite is not currently recognized
as a stockpile agent, in 1988 the CDC did pubtish continuous long term expoflre values
termed chemical agent airbome exposure limits (AELs) for the general population (GPL)
and unmasked agent workers (8-hr Time weighted average (TWA) for Lewisite
(reference e). However, the CDC value for Lewisite was 0.003mg/mr for both workers
and the general public. This value wasn't specifically 'derived' from the toxicological
data, and the CDC FR (reference e) included the statement that "The control limits...are
substantially below concentrations at which adverse effects have been observed
for...Lewisite." At that time (1988), no IDLH value for any CW agent, including
Lewisite or sulfir mustard, was developed by CDC.
c. Immediately Dangerous to Life and Health (IDLH) exposure conditions are defined
by NIOSH (www.cdc.gov/niosUngp/pgintrod.html) as "conditions that pose an
immediate threat to life or health, or conditions that impose an immediate threat of severe
exposure to contaminants, such as radioactive.materials, which are likely to have adverse
cumulative or delayed effects on health." NIOSH goes on to point out that "The purpose
of establishing an IDLH exposure concentration is to ensure that the worker can escape
from a given contaminated environment in the event of failure of the respiratory
protection equipment. "
d. Because the Army needed values to use as the maximum use conoentration (MUC)
for both HD and L to determine levels requiring supplied air protection, the Army made
the protective decision to publish "[DLH" values for Lewisite as well as HD that were
equal to the worker 8-hr TWA as established by CDC (the 1988 values provided in [tem
4.b above). The MUC values for HD and L were published as 0.003 mg/m3 HD or
Lewisite and are noted in Table2.2, AR 385-61, p. I l, 12 October 2001 (reference f)
where Footnote I gives an explanation for the 'blank entry' for IDLH for sulfi.r mustard
agents and Lewisite as follows: "Since IDLH values are used solely for the purpose of
establishing the concentrations at which SCBA or supplied-air respirators are required, it
is not necessary to formally establish IDLH values for H and L because workers will
already be required to wear these types of respiratory protection at concentrations much
lower than what is corisidered IDLH for H and L because of soncems over
carcinogenicity." [n short, and because the unmasked worker guidance was established at
such a protective (low) concentration (and thus requiring respiratory protection at air
concentrations >0.003 mg/m' , the authors of the October 2001 AR 385-61 assumed
respiratory protection would have already been donned prior to atlainment of a Lewisite
concentration with IDLH consequ€nces.
e. In 2004 (reference g) the CDC updated the 1988 chemical agent AELs but did not
address Lewisite because Lewisite was no longer in the stockpile. For the vesicant agent
sulfi.u mustard HD the CDC published a new value -the STEL (0.003 mg UU#; and a
new and toxicologically derived HD IDLH (0.7 mg HD/m').
f. tn the most recent DA Pam 385-61 (reference b), the 1988 Lewisite concentrations
remained and were 'oflat lined" as protective values for the unmasked 8-hour TWA
workerpopulation limit (WPL), the STEL and the IDLH. (NOTE: It is noted that there
is actually an error in the WPL entry for L and HL in the December 2008 edition of DA
Pam 38S-6t (reference b; Table 2-1-,p.7);the scientific notation to 0.003 mdm3 should
be "3 x l0-3" rather than the depicted "3 x 103').
g. Since the same concentration (0.003 mg Lewisite/m3; is now established as the
Lewisite WPL, STEL and IDLH by DA Pam 385-61 (reference b), any exceedance of the
WPL or STEL for this compound also simultaneously exceeds the IDLH. As a
consequence, APRs cannot be used when workplace air concentrations exceed 0.003 mg
L/m3, and air-supplied respirators must be donned to meet PPE requirements for work in
IDLH atmospheres. Data (reference^d) for Lewisite indicate that use of APRs at
concentrations above 0.003 mg L/mi would be sufficiently protective, and allow agent
workers to more efficiently perform the task of residual agent removal from materiel
currently accumulating in garrison storage.
5. Derivation of Recommended Lewisite IDLH Value.
a. General Approach. While there has not previously been a toxicologically derived
"IDLH" for Lewisite, there are recent scientifically developed and peer reviewed acute
human exposure guidelines for Lewisite which could be used as the basis for estimating
an effective IDLH value. Specifically, Acute Exposure Guideline Levels (AEGLs) for
Lewisite are now available to the public from the USEPA Office of Pollution Prevention
and Toxics (reference d). These values are calculated from available toxicological data
for one-time exposures and designed to be protective estimates for a heterogeneous
civilian population. There are three AEGL levels that reflect increasing severity of
effects in the general population (1, 2 and 3, with Level 3 being most severe). Specific
AEGL concentrations for each level are provided for five exposure durations: l0
minutes, 30 minutes, t hour, 4 hour, and 8 hours. A comparison of numerous hazardous
chemical CDCAIIOSH-developed IDLH values against published AEGL values
generally indicate that most IDLH values are within the range bounded by AEGL 2 to
AEGL 3 concentrations. Since there are AEGLs for a 30 minute exposure period, this
general boundary can also be applied to the Lewisite 30 minute interim AEGL 2 and3
values. As a consequence, a recommended effective IDLH for Lewisite would be located
between 0.23 mg/m3 (30 minute interim AEGL 2 for Lewisite) and 1.4 mg/m3 (30 minute
interim AEGL 3 for Lewisite).
b. Calculation. To establish a specific value, we considered several different
approaches. Since both HD and L are vesicants and since oritical effects for both
vesicants are direct and local effects to eye and ocular tissues, and given the more robust
data set and complete set of health criteria for HD (references g and h), we recommend
that a Lewisite effective IDLH could be develaped from a ratio derived from the sulfur
mustard AEGLs and IDLH values. HD values evaluated included the 30 minute AEGL?
= 0.20 mg HD/m3, the 30 minute AEGL 3 :2.7 mg HD/m3 (from reference h), and the
IDLH value = 0.7 mgHD/m3) (reference g). After evaluating the basis for the HD AEGL
2 and 3 and IDLH values, we determined that a reference ratio of the IDLIIi30 minute
AEGL 3 concentration derived from HD information could then be applied to the 30
minute interim AECL 3 for Lewisite to arrive at an estimated effective IDLH. It is noted
that the ratio approach was applied to the AEGL tier (AEGL 3) for which suffrcient
experimental Lewisite vapor exposure data are available rather than the tier (AEGL 2)
derived by exhapolation; results of the following assessment are thus based on the most
complete Lewisite toxicity data available. The calculations are shown below:
HD ratio IDLH|S0 minute AEGL3 : (0.7)l(2.7):) ratio of 0.26
Then to estimate IDLH for Lewisite:
>Derived ratio from above (0.26) x 30 minute
>(0.26) x ( 1.4 mglm3) : 0.364 mg/m3
> Rounded ta 2 significant digits, 0.36 mg/m3
Lewisite
Lewisite AEGL 3 (l .4 mglm3) -
is proposed as an effective IDLH for
o
c. Carcinogenicity. We also evaluated the carcinogenic potential for Lewisite for ttris
exposure level and scenario. Though in 1988 the CDC noted "...HHS accepts that
mustard agent is a carcinogen and because some evidence suggests that Lewisite might
{emphasis added} also be a carcinogen...," we have evaluated the most current data set
for Lewisite and based on following do not consider carcinogenicity to be a concern.
While some confounded WWII-era human data indicate cancer lesions have been
observed in humans exposed to Lewisite, these incidents were either associated wilh
acute severe dermal injury from direct liquid exposure to Lewisite, or exposure to high
airborne concentrations of Lewisite in combination with other warfare compounds such
as sulfur mustard that together induced acute upper respiratory tract damage. No
evidence supports carcinogenicity of Lewisite at low-level exposures. Many
investigators consider the potential carcinogenicity of Lewisite to be a function of the
elemental arsenic breakdown component of agent Lewisite. More recent toxicological
assessments (reference d) included extensive searches ofthe open literature (including
reports by the World Health Organization and Intemational Agency for Research on
Cancer), and examination of lab animal data for potential Lewisite carcinogenicity.
Consequurtly, we consider there to be no conclusive evidence that organo-arsenical
compounds are oarcinogenic.
6. We consider the recommended Lewisite effective IDLH value of 0.36 mglm3 to be
scientifically defensible, toxicologically based, and reasonably protective. Though
personnel in an IDLH concentration would be required to wear self-contained breathing
apparatus for protection, personnel working in Lewisite atrnospheres at concentrations up
to 50 times the Lewisite WPL or STEL but below the IDLH can also use air puri$ing
full-facepiece respirators w'ith appropriate chemical/particulate cartridges. Using full-
facepiece respirators provides protection against the effects of relatively mild ocular and
nasal initation expected at this concentration (reference d). These initation effects would
be direct and local and not a consequence of systemic absorption, which provides
additional evidence for the degree of protection afforded by the effective IDLH
estimation presented here. Further, all data exarnined indicate that carcinogenesis would
not be a conc,ern following 30-minute exposure to a conceutation of 0.36 mg
Lewisite/m3. As such, the Environmental Medicine Program is recommending that this
calculated effective IDLH value of 0.36 mg Lewisite/mr be used to replace the 0.003
mglm3 value cunently cited in DA Pam 385-61 (reference b), which is unnecessarily low
and is cunently hampering the ability to safely and effectively conduct necessary
operations at Pine Bluff. If this recommended elfective IDLH criteria would be useful in
other applications it may be appropriate to consider requesting review by an extemal
agency such as the Department of Health and Human Services (DHHS).
7. Points of Contact. Inquiries regarding this MFR can be directed to Ms. Veronique
Hauschild, or Dr. Coleen Baird, Environmental Medicine Program, Directorate of
Occupational and Environmental Medicine, US Army Center for Health Promotion and
Preventive Medicine; commercial [phone], DSN 584-1010, or email:
[e-mail] or [e-mail]4n.y,Inil.
7F>
a.(-
o
TOCDF
Standard Permit Conditions
May 2005
MODULE I
STANDARD PERMIT CONDITIONS
I.A. EFFECT OF PERMIT
I.A.1. The Permittee is allowed to store or treat hazardous waste in containers, treat and store
hazardous waste in tanks, treat and store hazardous waste in miscellaneous (Subpart X)
units, and ffeathazardous waste in incinerators at the TOCDF and ATLIC in accordance
with the conditions of this Permit and in accordance with R315-5
I.A.2. Any treatment, storage, or disposal of hazardous waste not authorized in this Permit is
prohibited except as allowed by R3 1 5-5-3.34 or Condition I.F. 1 . The Permittee is
authorized to comply with the conditions of other permits issued by the Utah Department
of Environmental Quality or elements thereof and by the USEPA, so long as those
conditions are not inconsistent with this Permit. When conditions of various permits are
inconsistent, the Permittee must either comply with the more stringent conditions or
... - request and obtain modification of appropriate permits to avoid non-compliance.
I.A.3. Compliance with this Permit during its term constitutes compliance, for purposes of
enforcement, with the Utah Hazardous Waste Management Rules, except for those
requirements not included in this Permit which become effectiveby statute. Specifically,
compliance with this Permit druing its term constitutes compliance, for purposes of
enforcement, with R3i5-8 only for those manggeme,nt practices specifically authorized by
this Permit. The Permittee is also required to comply with R3 1 5-1, 2, 3, 4, 5, 6, 9, 12, 13,
14,16,50, and 101 as applicable.
I.A.4. Issuance of this Permit does not convey prop"rty rights of any sort or any exclusive
privilege nor does it authorize any rnjury to persons 0r property, any invasion of private
rights, or any infringement of State or local law or regulations..
I.B. ENFORCEABILITY
I.8.1. Violations duly documented through the enforcement process pursuant to Utah Code
Annotated 19-6-1 12, rnay result in penalties.
LC. OTHERAUTHORITY
I.C.l . The Board expressly reserves any right of entry provided by law and any authority to order
or perform emergency or other response activities as authorized by law.
I.D. PERMIT ACTIONS
I.D.1. This Permit may be modified, revoked and reissued, or terminated for cause, as specified
in R315-3-4.
1.D.2. The filing of a request for a permit modification, revocation and re-issuance, or
termination, or the notification of planned changes or anticipated noncompliance on the
part of the Permittee does not stay the applicability or enforceability of any permit
condition.
Modulel-Pagel
I.D.3.
r.D.4.
I.E.
I.E.1.
I.F.
I.F.1 .
I.F,2.
I.G.
I.G.1 .
I.H.
I.H.1 .
TOCDF
Standard Permit Conditions
May 2005
The Executive Secretary may modit/ this Permit when the standards or regulations on
which the Permit was based have been changed by statute, amended standards or
regulations, or by judicial decision after the effective date of this Permit.
Except as provided by specific language in this Permit, the Permittee shall not modifu or
change the design or operation of the TOCDF or ATLIC or anyhazardous waste
management practice referenced in this Permit until the Permit is modified in accordance
with R315-3-4 and R315-4-1.5.
SEVERABILITY
The provisions of this Permit are severable and if any provision of this Permit, or the
application of any provision of this Permit to any circumstance, is held invalid, the
application of such provision to other circumstances and the remainder of this Permit shall
not be affected thereby. Invalidation ofany State or federal statutory or regulatory
provision which forms the basis for any condition of this Permit does not affect the
validity ofany other State or federal statutory or regulatory basis for said condition.
DUTIES TO COMPLY
The Permittee shall comply with all conditions of this Permit, except to the extent and for
the duration such noncompliance is authorized by an emergency permit issued in
accordance with R3 1 5 -3 -6 .2 or a temporary authorization issued in accordance with R3 I 5 -
3-4.3. Any permit noncompliance, other than noncompliance authorized by an ernergency
permit or temporary authorization, constitutes a violation of the Utah Solid and Hazardous
Waste Act and is grounds for enforcement action, permit termination, revocation and re-
issuance or modification of the permit or denial of a permit renewal application.
Compliance with the terms of this Permit does not constitute a defense to any order issued
or any action brought under Sections 3007, 3008, 3013, or 7003 of RCRA (42 U.S.C.
Sections 6927,6928,6934 and 6973), Section 106(a), 104, or 107 ofthe Comprehensive
Environmental Response, Compensation, and Liability Act of 1980 (42 U.S.C. 9606(a),
commonly known as CERCLA) as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), or any other State or federal law providing for
protection of human health or the environment from any imminent and substantial
endangerment.
DUTY TO REAPPLY
If the Permittee wishes to continue an activity allowed by this Permit after the expiration
date of this Permit, the Permittee shall apply for a new permit a minimum of 180 calendar
days prior to the expiration date of this Permit, in accordance with R315-3-3.1(b) and
R31s-3-2.1(e).
PERMIT EXPIRATION
This Permit shall be effective for ten years from the effective date of this Permit.
Module I -PageZ
I.I.
I.I.1 .
TOCDF
Standard Permit Conditions
May 2005
CONTINUATION OF E)(PIRING PERMII
This Permit and all conditions herein shall continue in force until the effective date of a
new pennit, if the Permittee has submitted a timely and complete application (in
accordance with R315-3), and through no fault of the Permittee, the Executive Secretary
has neither issued nor denied a new permit under R3l5-3-5 on or before the expiration
date of this Permit.
REVIEW OF PERMIT
In accordance with the Utah Solid and Hazardous Waste Act, UAC 19-6-108(13), this
Permit shall be reviewed five years after the effective date and modified as necessary.
NEED TO HALT OR REDUCE ACTTVTTY NOT A DEF'ENSE
It shall not be a defense for the Permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this Permit.
DUTY TO MITIGATE
In the event of noncompliance with the Permit, the Permittee shall take all reasonable
steps to minimize releases to the environmentresulting from the noncompliance; and shall
carry out such measures as are reasonable to prevent significant adverse impacts on human
health or the environment.
PROPER OPERATION AND MAINTENANCE
The Permittee shall, at all times, properly operate and maintain all facilities and systems of
treatment and control (and related appurtenances) which are installed or used by the
Permittee to achieve compliance with the conditions of this Permit. Proper operation and
maintenance includes following parts pf Permittee-approved Standard Operating
Procedures (SOPs) which affect the management of h6zardous waste, effective
performance, adequate fundlng, adequate operator staffing and training, and adequate
laboratory and process controls, including ippropriate quality assurance procedures. This
provision requires the operation of back-up or auxiliary equipment or similar systems only
when necessary to achieve compliance with the conditions of this Permit.
The Permittee shall follow the procedures for SOP revision whenever it is necessary to
change an SOP.
The TOCDF Environmental Office shall provide copies of all temporary changes that
address deviations from this P6rmit, upon request.
Prior to July 1, 2005, and each July 1 thereafter, the Permittee shall submit a report to the
Executive Secretary of the occasions during the previous calendar year when each
incinerator operated outside of the operating ranges in Module V. Each report shall
include the amount of time that an incinerator processed waste, idled, and tumed off the
bumers (e.g., maintenance shutdowns, etc.). The report should, at a minimum, contain the
I.J.
I.J.1 .
I.K.
I.K.1 .
I.L.
I.L.1 .
I.M.
I.M.1 .
I.M.2.
I.M.3.
I.M.4.
Modulel-Page3
I.N.
I.N.1 .
I.O.
I.O.1
I.O.1.a.
I.O.1.b.
I.O.1 .c.
I.O.1 .d.
r.o.2
I.P.
I.P.1 .
TOCDF
Standard Permit Conditions
May 2005
information provided in the "Tooele Chemical Agent Disposal Facility (TOCDF)
IncineratorUpset Conditions Estimate for 1998, PDARS Review Based" (EG&G, 1999).
DUTY TO PROVIDE INFORMATION
The Permittee shall fumish tothe Board and the Executive Secretary, within a reasonable
time, any relevant information which the Board or the Executive Secretary may request to
determine whether cause exists for modifoing, revoking and reissuing, or terminating this
Permit, or to determine compliance with this Permit. The Permittee shall also fumish to
the Board and the Executive Secretary, upon request, copies ofrecords required to be kept
by this Permit.
INSPECTION AI\D ENTRY
Ptrrsuant to the Utah Solid and Hazardous Waste Act, UAC 19-6-109, the Permittee shall
allow the Board, the Executive Secretary, or their authorized officer, employee, or
representative, upon the presentation of credentials as may be required by law to:
Enter at reasonable times upon the Permittees' premises where a regulated facility, unit, or
activity is located or conducted or where records are kept as reqrfired by conditions of this
Permit;
Have access to and copy, at reasonable times, any records that are kept as required by
conditions of this Permit;
Inspect at reasonable times any portion of the Facility, equipment (including monitoring
and control equipment), practices, or operations regulated or required under this Permit;
and
Sample or monitor for the purposes of assuring permit compliance or as otherwise
authorized by the Utah Solid and Hazardous Waste Act or RCRA, any substances or
parameters at any location.
The Executive Secretary, or an appointed representative, shall be allowed to make record
of inspections by photographic, electronic, video tape, or any other reasonable medium.
MONITORING AND RECORDS
The Permittee shall retain records of all monitoring information, including all calibration
and maintenance records and all original strip chart recordings (or equivalent recordings)
for continuous monitoring instrumentation, copies of all reports required by this Permit,
the certification required by R315-8-5.3. (40 CFR Section 264.73(b)(9) incorporated by
reference), and records of all data used to complete the application for this Permit for a
period of at least three years from the date of the sample, measurement, report,
certification, or recording unless a longer retention period for certain information is
required by other conditions of this Permit. The Permittee shall retain, at the Facility, all
monitoring records from all surface water sampling, seep sampling, soil sampling,
sediment sampling, groundwater monitoring wells, and associated groundwater surface
elevations until three years past the end ofthe corrective action instituted to address
Modulel-Page4
Or
TOCDF
Standard Permit Conditions
May 2005
releases of hazardous waste or hazardous waste constituents from any solid waste
management unit created as a result of operations at the TOCDF a4dd[Jq. These
periods may be extended by request of the Executive Secretary at any time by written
notification to the Permittee and the retention times are automatically extended during the
course of any unresolved enforcement action regarding the TOCDF- aogl r![IJg, to three
years beyond the conclusion of the enforcement action.
Pursuant to R315-3-3.1fi), records of monitoring information shall specifu:
The date(s), exact place(s), and time(s) of sampling or measurements;
The name(s), title(s), and affiliation(s) of the individual(s) who performed the sampling or
measurernents;
The dates analyses were performed;
The individual(s) who performed the analyses; ..
The analytical techniques or methods used; and
The results of such analyses, including the Quality ControVQuality Assurance sunmary.
rqr.:. q;
Samples and measurements taken for the purpose of monitoring shall be representative of
the monitored activity. The methods used"shall be those approved procedures found in
Module X; Attachments2,3,20, and22; or equivalent methods approved in accordance
with Condition LP.4.
The Permittee may substitute analytical methods which are equivalent or superior to those
specifically approved for use in this Permit by modiffing the Permit in accordance with
" R315-3-4.3. The modification request shall provide information, in terms of sensitivity,
'accuracy, and precision (i.e., reproducibility), demonstrating the proposed method(s)
requested to be substituted.
REPORTING PLAIINED CHANGES
Prior to any planned physical alteration or addition, the Permittee shall give notice to the
Executive Secretary of any planned physical alterations or additions to the permitted
Hazardous Waste Management Units (permitted units).
The Permittee shall give advance notice to the Executive Secretary of any planned changes
in the permitted units or activities which may result in noncompliance with requirements
of this Permit. Advance notice shall not constitute a defense for any noncompliance.
CERTIFICATION OF CONSTRUCTION OR MODIFICATION
The Permittee may not commence storage, treatment, or disposal of hazardous waste in
any newly permitted unit or in a modified portion of an existing permitted unit until the
Modulel-Page5
r.P.2.
r,P.2,a.
I.P.2.b.
T,P,2,C.
I.P.2.d.
I.P,2.e.
r.P.2.f.
I.P.3.
r.P.4.
I.Q.
I.Q.1.
r.R.
I.R.1 .
I. S.
I.S.1.
I. S.2.
I.S.3.
I.S.4.
I.T.
r.T.1 .
t
I.IJ.
I.IJ.I .
I.IJ.1 .a.
I.IJ.1 .b.
I.IJ.l .b.i.
TOCDF
Standard Permit Conditions
May 2005
Permittee has submitted to the Executive Secretary by certified mail, express mail, or hand
delivery a letter signed by the Permittee and a registered professional engineer certiffing
that the permitted unit at the TOCDF anf!:\'IL!Q haves been constructed or modified in
compliance with this Permit; and
The Executive Secretary has reviewed and inspected the modified or newly constructed
permitted unit and has notified the Pem.rittee in writing that the permitted unit was found
in compliance with the conditions of this Permit; or
I[ within 15 calendar days of the date of submission of the letter in Permit Condition
I.S.1., the Permittee has not received notice from the Executive Secretary of the inte,lrt to
inspect, prior inspection is waived and the Permittee may commence treatment, storage, or
disposal of hazardous waste in the permitted unit certified in accordance with Condition
r.s.1.
Construction certification shall be performed for all the permitted units listed in Table2
and the IIVAC System.
TRANSF'ER OF'PERMIT
This Permit may be transferred to a new owner or operator only if it is modified or
revoked and reissudd pwsuant to R315-3-4. Prior to transferring ownership or operation
of the'IOCDF during its operating life, the Permittee shall notifu the new owner or
operator, in writing, of the requirernents of R315-3, R315-8, and this Permit.
TWENTY-FOTIR HOI]R REPORTING
In accordance with R315-3-3.1(l)(6), the Permittee shall orally report to the Executive
Secretary any noncompliance with this Permit which may endanger human health or the
environment. Any such information shall be reported as soon as possible, but not later
than24 hours from the time the Permittee becomes qware of the noncompliance. Potential
endangerment to human health and the environment shall include, but not be limited to:
Noncompliance with Condition tI.A. 1.
Any release to the environment of a P999 hazardous waste as listed in R315-2-11(e)(1) or
an F999 hazardous waste as listed in R315-2-10(e)(1) which results in the following:
Confirmed agent concentrations at the DCD Facility boundary due to a release from the
TOCDF or ATUC exceeding the General Population Limits as specified in Table 1 for
each agent; or
Confirmed agent coricentrations exceeding the Work Place Limits specified in Table 1 and
Attachment 22 (Agent Monitoring Plan) at any agent monitor within Category C, D, and E
areas as specified in Attachment 9 (Contingency Plan).
Any release to the atmosphere from the combined stack for the two Liquid Incinerators,
the Deactivation Furnace, and the Metal Parts Fumace. or ATLIC stack if the confirmed
stack emission level, as defined in Attachmentg22 g,nd22A (Agent Monitoring Plan gg!
I.I-J. 1 .c.
Modulel-Page6
I.LJ.1 .d.
I.IJ.1 .e.
I.IJ.1 .f.
r.u.2.
I.u.3.
I.u.4.
I.U.4.a
I.U.4.b,
I.IJ.4.c.
I.LJ.4.c.i.
I.U.4.c.ii.
I.U.4.c.iii.
I.U.4.c.i.v.
I.I.J.4.c.v.
I.tf .4.c.vi.
i, ,,
TOCDF
Standard Permit Conditions
May 2005
ATLIC Asent Monijoring Plan. resnectivelv), exceeds the maximum allerrable*taelr
identified for each individual agent in Table I
of this Permit. The Pennittee shall orally report, as specified in Condition I.U.l., to the
Executive Secretary.
Any release to the atmosphere from the TOCDF or ATLIC HVAC stack if the confrmed
ernission level exceeds the level specified in Table I for each individual agent.
Any indication that a release to the atmosphere from the combined stack for the two
Liquid Incinerators, the Deactivation Fumace, and the Metal Parts Fumace, the ATLIC
stzick. the ATLIC HVAC stack. or from the TOCDF HVAC system stack, where the stack
emisSion level cannot be verified to be an agent monitor anomalywithnz4 hours ofthe
time in which the agent monitor indicated the stack emission level exceeded the levels
identified for each individual agent in Table 1 of this Permit.
Any exceedance of the metals feed rates specified in Module V.
The Permittee shall orally report to the Executive Secretary unintentional spills of P999 in
any quantity. Any such information shall be reported in accordance with the procedures
of R315-9, as soon as possible, but not later than 24 hours after the spill occurrence.
Lr accordance with R315-9-1, the Permittee shall orally report to the Executive Secretary
any TOCDF or ATLIL spill of any hazardous waste or material which, when spilled
becomes a hazardous waste, other than a hazardous waste listed in R315-2-11(e). Any
such information shall be reported as soon as possible, but not later than 24 hours after the
spill occurrence.
The oral report shall include, but shall not be limited to, the following:
Information concerning the release of any hazardous waste which may endanger public
drinking water supplies, and
Any information of a release or discharge of hazardous waste, or of a fire or explosion at
the TOCDF 3i!!p!Q, which could threaten the environment or human health.
The description of the occwrence and its cause including:
Name, title, and telephone number of individual reporting;
Name, address, and telephone number of the owner or operator;
Date, time, and type of incident;
Location and cause of incident;
Name and quantity of materials involved;
The q(tent of.injuries, if any;
Module I -Page7
I.LJ.4.c.vii.
I.IJ.4.c.viii.
I.LJ.4.c.ix.
r.LJ.s.
I.u.5.a.
I.IJ.5.a.i..
LU.5.a.ii.
I.U.5.a.iii.
I.U.5.a.iv.
I.U.5.a.v.
I.U.6.
I.V.
I.V.1 .
I.'W'.
I.W.l.
TOCDF
Standard Permit Conditions
May 2005
An assessmcnt of actual orpotential hazardto the environment and human health, where
this is appfi"batle;
Description of any emergency action taken to minimize tfueat to human health and the
environment;
Any other information necessary to fully evaluate the situation and to develop an
appropriate course of action.
Within fifteen cale,ndar days of the time the Permittee is required to provide oral
notification, as specified in Conditions I.U.1. through I.U.4., the Permittee shall provide to
the Executive Secretary a written submission explaining the incident.
In accordance with R315-9-4, the written submission shall include, but shall not be limited
to the following:
Name, address, and telephone number of the individual reporting;
A description (include cause, location, extent of injuries, if any, and an assessment of
actual orpotential hazardto the environment and human health outside the TOCDF, !!g
ATLIC, the DCD, or combination of affectedfacilities beth) of the incident;
The period(s) in which the incident occurred (including exact dates and times);
Whether the results of the incident remain a threat to human health and the environment
(whether the noncompliance has been corrected; whether the release has been adequately
cleaned up); and
If the noncompliance, release, or both have not been corrected, the anticipated time the
cleanup or noncompliance is expected to continue. The submission shall also identify the
steps taken or planned to reduce, eliminate, and prevent recrurence of the noncompliance
or release; and the steps taken or planned to adequately clean up the release.
The Permittee shall report all events occurring as a result of operations at the TOCDF q
1slg, classified as Chemical Events by either the TOCDF or DCD, to the Executive
Secretary as soon as possible.
OTHER NONCOMPLIANCE
The Permittee shall report all other instances of noncompliance not otherwise required to
be reported in this Permit in accordance with Condition I.U., at the time monitoring
reports are submitted in accordance with Condition I.AA.1. The reports shall contain the
information listed in Condition I.U. Reporting shall not constitute a defense for any
noncompliance.
OTHER INFORMATION
Whenever the Permittee becomes aware that it failed to submit any relevant facts in the
permit application or submitted incorrect information in the permit application or in any
Modulel-Page8
standard .".,nt, C"L:;3:
May 2005
report submitted to the Executive Secretary, the Permittee shall promptly submit such facts
or colrected information.
I.X. SIGNATORY REOUIREMENT
LX.1. All applications, reports, or other information requested by or submitted to the Executive
Secretary shall be signed and certified in accordance with R3l5-3-2.2 and R315-3-3.1(k).
I.Y. CONFIDENTIAL INFORMATION
I.Y.1. In accordance with Utah Code Annotated 63-2-308 et seq, and Utah Code Annotated 19-
1-306 and implementing regulations, the Permittee may claim confidential any
information required to be submitted pursuant to this Permit.
1.2. CONF'LICTS
l.Z.l. All conditions within the modules of this Permit supersede conflicting statements,
requirements, or procedures found within the attachments to this Permit.
1.2.2. If a conflict exists between conditions within the modules of this Permit, the most
appropriate condition, as determined by the Executive Secretary, shall be met.
I.2.3. Upon discovery of a conflict, a modification to the perinit shall be initiated by the
Permittee to meet the Executive Secretary's determination.
I.AA. REPORTS. NOTIFICATIONS. AND ST]BMISSIONS
I.AA.1. On or before Septernber 1 of each year, the Permittee shall submit to the Executive
Secretary a report which summarizes the QA/QC reliability problems experienced during
the previous 12 months (July 1 through June 30) with Carbon Monoxide (CO), Oxygen
(O2), and agent stack gas monitors and TOCDF ambient air agent monitors, including
Depot Area Air Monitoring Systems. This summary report shall include, but not be
limited to, the following:
I.AA. 1 .a. Identity of the monitor experiencing the problem including serial number and location;
I.AA.1.b. Identification of the tlpe of problem (e.g., borderline or deficient recoveries, description of
the problem);
I.AA.1.c. Frequency of the problem; and
LAA.1.d. Corrective action implemented to correct the problem.
l.AA.2. All reports, notifications, or other submissions which are required by this Permit to be sent
or given to the Executive Secretary shall be sent by certified mail, express mail, or hand
delivered to:
Executive Secretary
Utah Solid and Hazardous Waste Control Board
Modulel-Page9
Standard P"rrit C"ffi;3:
May 2005
288 North 1460 West
P.O. Box 144880
salt Lake city, Utah 84114-4880
(801)-s38-6170
The Utah Department of Environmental Quality 24-Horx Answering Service telephone
number is: [phone].
LAA.3. All reports, notifications, or other submissions which are required by this Permit to be sent
or given to the Regional Administrator shall be sent by certified mail, express mail, or
hand delivered to the EPA, Region VIII, State and Tribal Assistance Office, Assistant
Regional Administrator at:
U.S. Environmental Protection Agency
State and Tribal Assistance Office
999 18th Street
Suite 500
Denver, Colorado 80202-2455
Twenty-four hour number: (303!293- 1 78 8
I.BB. DOCT]MENTS TO BE MAINTAINED AT THE FACILMY SITE
The Permittee shall maintain at the Facility, until closure is completed and certified by an
independent, registered professional engineer, the following documents and amendments,
revisions, and modifications to these documents:
I.BB.l. Attachment 2 (Waste Analysis Plan), as required by R315-8-2.4 and this Permit.
I.BB.2. Attachment 5 (Inspection Plan), as required by R315-8-2.6 and this Permit.
I.BB.3. Attachment 7 (Training Plan), documents, and records, as required by R315-8-2.7 and this
Permit.
I.BB.4. Attachment 9 (Contingency Plan), as required by R315-8-4 and this Permit.
I.BB.5. Operating Record, as required by R315-8-5.3 and this Permit.
I.88.6. Attachment l0 (Closure Plan), as required by R315-8-7 and this Permit.
I.BB.7. Independent tank system assessment, installation, and repair certifications; as required by
R315-8-10 and this Permit.
I.BB.8. Plans and Operating Records as required by R315-8-18 and R315-8-22 ard this Permit.
Module I - Page l0
o
o
o
II.A.
I II.A.t.
TOCDF
General Facility Conditions
June 2007
MODULE II
GENERAL FACILITY CONDITIONS
DESIGN AI\D OPERATION OF FACILITY
The Permittee shall design, construct, maintain, and operate the TOCDF igLA:[LIg to
minimize the possibility of a fire, explosion, or any unplanned sudden or non-sudden
release of hazardous waste or hazardous waste constituents to air, soil, groundwater, or
surface water.
The Permittee shall construct all hazardous waste management units in accordance with
the approved designs and specifications, except for minor changes deemed necessary by
the Permittee to facilitate proper construction of the hazardous waste management units.
Minor deviations from the approved designs or specifications necessary to accommodate
proper construction and the substitution or the use of equivalent or superior materials or
equipment shall be noted on the as-built drawings and the rationale for those deviations
shall be provided in narrative form. After completion of construction of each hazardous
waste management unit, the Permittee shall submit final as-built drawings and the
narrative report to the Executive Secretary as part ofthe construction certification
document specified in Condition LS. of Module I.
The Permittee is only authorized and therefore shall only receive hazardous waste from
facilities possessing the State/EPA I.D. Number UT5210090002, which includes the
Deseret Chemical Depot (DCD) and the Chemical Agent Munitions Disposal Systern
(CAMDS).
WASTE ANALYSIS PLAN
The Permittee shall follow the procedures of Attachment 2 (Waste Analysis Plan) and
Subpart BB and CC requirements (Module X).
Reserved.
All analyses, with the exception of analyses for the parameters for which the EPA has not
promulgated methods, conducted pursuant to this Permit, shall be performed by a
laboratory with a current Utah Department of Health, State Health Laboratory
certification. As an altemative, the Permittee may conduct analysis pursuant to this Permit
using methods promulgated by EPA if the Permittee is certified for the EPA-promulgated' methods. If the Permittee has not been certified for the method to be used, the Permittee
may conduct the analysis provided that the promulgated method QA/QC requirements are
satisfied, an application for State Health Laboratory certification has been filed, the
Executive Secretary has been provided the MDL studies 14 days prior to the Permittee
using the promulgated method and the Executive Secretary approves the Permittee to use
the promulgated method.
II.A.2.
II.B.
II.B.1.
II.C.
[.c.1.
II.C.2.
II.C.3.
Module II - Page I
II.D.
II.D.1 .
II.E.
II.E.1 .
il.E.2.
II.E.3.
TOCDF
General Facility Conditions
June 2007
SECTruTY PROCEDI'RES
The Permittee shall comply with Attachment 4 (Security Procedures).
INSPECTION PLAI\
The Permittee shall follow Attachments 5 (Inspection Plan) and 6 (Instrument Calibration
Plan & Incinerator Waste Feed Interlock Function Test).
Reserved.
The Permittee shall remedy any deterioration or malfunction discovered by an inspection
as required by R315-8-2.6(c). Lrspection reports shall be recorded as required by R3 I 5-8-
2.6(d).
The Permittee shall maintain a copy of Attachment 5 (Inspection Plan) at the Facility until
the TOCDF and ATLIC are is.certified as clean closed.
The Permittee shall make only the following revisions to Attachment 5 (Inspection Plan)
without first obtaining a permit modification, in accordance with R315-3-4. The
procedures designated under Condition II.L. shall be followed to implement these
revisions:
The Permittee may change orientations of inspection related items on inspection tables.
TRAINING PLAN
The Permittee shall ensure that all personnel who handle hazardous waste are trained in
hazardous waste management, safety procedures and emergency procedures, as applicable
to their job description in accordance with Attachment 7 (Training Plan). Documentation
of training shall be maintained as specified in Attachment 7.
The Permittee shall maintain a copy of Attachment 7 (Training Plan) at the Facilityuntil
the TOCDF and ATLIC are is.certified as clean closed.
PREPAREDNESS AI\D PREVENTION
The Permittee shall follow Attachment 8 @reparedness and Prevention Plan).
The Permittee shall perform preventative maintenance and repair of the equipment
identified in Module VIII, at a minimum, in accordance with maintenance procedures
maintained at the facility. The Permittee shall maintain records of these preventative
maintenance and repair activities on this equipment and schedules, reflecting minimum
and planned frequency for the performance of these preventative maintenance activities in
the Operating Record at the TOCDF and ATLIC in accordance with Condition I.P.
II.E.4.
II.E.5.
II.E.5.a.
II.F.
II.F.1.
II.F.2.
II.G.
II.G.1 .
II.G.2.
Module II - Page 2
II.H.1 .
II.H.2.
TT,H.Z,A,
II.H.2.b.
II.H.3.a.
II.H.3.a.i.
II.H.3.a.ii.
II.H.3.a.iii.
II.H.3.a.iv.
II.H.3.b.
II.H.4.
TOCDF
General Facility Conditions
June 2007
CONTINGENCY PLAI\
The Permittee shall follow the procedures outlined in Attachment 9 (Contingency Plan).
If agent is detected in the DCD Facility perimeter monitors above the General Population
Exposure limits in Table 1, or agent is detected in e.tther the TOCDF Common Staclq er
TOCDF MDB HVAC Stac and is confirmed, the
Permittee shall implement Attachment 9 (Contingency Plan).
For TOCDF Common Stack confirmed ACAMS alarms, the Permittee shall cease agent
movement at the TOCDF, with the exception of container storage operations and storage
and treatrnent gperations in tanks.
For TOCDF MDB IIVAC Stack ACAMS alarms, the Permittee shall cease all process
operations at the TOCDF in accordance with Module X.
II.H.2.c. For ATLIC Stack confirmed NRT.monitor (ACAMS or MINICAMS) alarms. the
Permittee shall cease age,nt movement at the ATLIC. with the exception of storage of in-
process ton containers in the Glove.Box Suboart X heatment units and storaee and
treatment ooerations in tanks.
tr.H.2.c. For ATLIC HVAC Stack NRT monitor (ACAMS or MINICAMS) alarms. the Permittee
shall cease all orocess operations at the ATLIC in accordance with Module X.
II.H.3.
under either Condition Il.H.z. or shutdown as a result of a major explosion, as defined in
Attachment 9 (Contingency Plan), unless the following has occurred:
The Permittee has submitted a request to resume operations to the Executive Secretary
accompanied by the following information:
Detailed description of the accidenVincident;
The cause of the accident as determined by the results of investigation of the accident;
The corrective action(s) taken; and
A copy of the notification received by the Permittee from the Chemical Materials Agency
(CMA) that operations are authorized to resume.
The Executive Secretary has provided the Permittee a written approval to resume process
operations.
In the event of an off-site civilian chemical emergency, the Permittee shall comply with
the procedures outlined in the Chemical Stockpile Emergency Preparedness Progtam
(csEPP).
Module II - Page 3
II.H.5.
II.H.6.
TOCDF
General Facility Conditions
June 2007
Future modifications of Table 9-2-l or Table 9-2-2 of Attachment 9 (Contingency Plan)
shall be submitted in accordance with R315-3-4.
For TOCDF Common Stack ACAMS alarms at or above 1.0 SEL, the Control Room shall
initiate the TOCDF site audible agent alarm (warbler tone), which notifies TOCDF site
personnel to immediately mask and await further instructions. Both online Common
Stabk staggered ACAMS must be in alarm at or above 1.0 SEL to require implementation
of this site masking contingency. The control room has the option to mask site personnel
at anytime for worker protection.
II.H.7
which notifies Area 10 personnel to immediately mask and await further instructions. /Ft,
Both on-line ATLIC LIC Stack staesered ACAMS must be in alarm at or above 1.0 SEL ,fl
to r"q.rf"l*pt"-*tution of thi. riii -urkios *ntirrs*c]r. Th"
"ont
ot roorn t rs tt "
- '' -r'
option to mask Area l0 personnel at anytime for worker protection.
For TOCDF MDB HVAC Stack ACAMS alarms at or above l.0 VSL, the Control Room
shall initiate the TOCDF site audible agent alarm (warbler tone), which notifies TOCDF
site personnel to immediately mask and await further instructions.
II.H.8.
rfor ATTIQ-HVAC Stack NRT monitors (ACAMS or MINICAMS) alarms at or above
1.0 VSL. tlie ATLIC Control Room shall initiate the ATLIC site audible asent alarm
(warbler torie). which notifies Area 10 personnel to immediately mask and await further
-
instructions.
-
For TOCDF Category C Area ACAMS alarms above the alarm set point as specified in
Attachment 22,the Control Room shall initiate theTOCDF MDB site audible alarm
(repetitive beeping tone), which notifies personnel within the TOCDF MDB to mask and
evacuate. The Control Room shall also activate the TOCDF MDB agent waming lights
and notiff site personnel to remain clear of the TOCDF MDB.
' ' r'. *h(
-*$d\t'{"
II.H.8.a.For ATLIC Cat ACAM above th
Attachment 22A. the ATt shall initiate the ATLIC site audible alarm
(repetitive beepine tone). which notifies nersonEel"withi${heATLIC to mask and
ft(f the ATLI I Room-shall also activ
ATLIC aqent w
of the ATLIC.
*' t. .-" u-
I ''.-; Lr 1
II.H.9 For TOCDF Category D Area ACAMS alarms above the alarm set point as specified in
Attachment 22, the TOCDF Control Room shall initiate the TOCDF site audible agent
alarm (warbler tone), which notifies TOCDF site personnel to immediately mask and
await further instructions.
II.H.9.a. For ATLIC Cateeory D Area ACAMS alarms above the alarm set point as specified in
Attach-errt 22A- the ATLICE)troIRosq shall initiate the ATLIC site audible agerrt\)
-r/
Module II - Page 4
II.I
II.I.1 .
II.I.1 .a.
II.I.1 .b.
II.I.1 .c.
II.I.1 .d.
TT.T.2.
II.I.3.
II.J.
II.J.1 .
TOCDF
General Facility ::l3lffi;
alarm (warbler tone). which notifies ATLIC site personnel to immediately mask and await
*@
REC ORDKEEPING AI\D REPORTING
In addition to the recordkeeping and rep6rting requirements specified elsewhere in this
Permit, the Permittee shall comply with the following:
The Permittee shall maintain a written Operatrng Record at the Facility, in accordance
with R315-8-5.3 [40 CFR Section 264.73(a) incorporated by reference] for all records
identified in R3l5-8-5.3. [40 CFR Section 264.73b)G) through (bX14) incorporated by
reference].
The Permittee shall, by March 3l of each year, submit to the Executive Secretary a
certificationpursuanttoR3l5-8-5.3 [40CFRSection264.73b)e)incorporatedby
reference], signed in accordance with R3l5-3-2.2, that the Permittee has a program in
place to reduce the volume and toxicity of hazardous waste generated to the degree
determined by the Permittee to be economically practicable; and the proposed method of
treatment, storage, or disposal is that most practicable method currently available to the
Permittee which minimizes the present and future threat to human health and the
envlrorunent.
The Permittee shall submit a biennial report covering the TOCDF and ATLIC activities
to the Executiye Secretary in accordance with R315-8-5.6 and R315-3-3.10X9).
The Permittee shall submit additional reports to the Executive Secretary in accordance
with R315-8-5.8.
All reports, notifications, applications, or other materials required to be submitted to the
Regional Administrator shall be submitted to the State and Tribal Assistance Office,
Assistant Regional Administrator to the EPA Regional address shown in Condition
I.AA.3.
All reports, notifications, applications, or other materials required to be submitted to the
Executive Secretary shall be submitted to the address shown in Condition I.AA.2.
CLOST]RE
The Permittee shall meet the general closure performance standard as specified in R315-8-
7 during closule of all TOCDF and TOCDF manased Area 10 -hazardous waste
management irnits. Compliance with R315-8-7 shall require closure of each hazardous
waste management unit in accordance with Condition II.J. and Attachment 10 (Closure
Plan).
All secondary waste generated during the processing of Agents GB, VX, and Mustard at
the TOCDF shall be processed by the Permittee prior to the completion of closure of the
TOCDF.
TTJ.2.
Module II - Page 5
TOCDF
General Facility Conditions
June 2007
II.J.3.
II.J.4.
f[.J.5.
II.J.6.
TI.J,7 .
II,J.8.
II.J.9.
II.K.
II.K.1 .
II.J.2.a. The ATLIC may be closed before all secondary waste generated during the processing
Ae€,nt GA and Lewisite at the ATLIC have been processed provided the P€flnittee
orocesses these wastes during the Autoclave Secondary Waste Camoaign associatd with
DCD and CAMDS secondary wastes contaminated with similaraeents.
Reserved.
Reserved.
The Permittee shall decontaminate or dispose of all TOCDf. effrciandeutocfave
DVS. and DVSSR equipment as specified in Attachment 10 (ClosurlPfan).
The Permittee shall provide certification statements that each TOCDF and TOCDF
manased Area 10 hazardous waste management unit has been closed in accordance with
the applicable specifications in Attachment 10 (Closure Plan), as required by R315-8-7.
The Permittee shall notiff the Executive Secretary at least 45 calendar days prior to the
closure date of any hazardous waste managemen! glit is expected to begin.
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 Attachment 10 (Closure Plan), 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, in
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 R3l5-8-7 (e.g., Post Closure Plan).
Within 90 calendar days of the Permittee's receipt of the written approval from the
Executive Secretary, in accordance with R315-3-4, of the modified closure plan and the
post-closure plan required by Condition II.J.8., the Perrnittee shall close the hazardous
waste management unit in accordance with the approved plans.
CL9SI'RE PLAN - COMPLIANCE SCHEDULE
The Permittee shall submit a permit modification request that updates Attachment 10
(Closure Plan) for TOCDF associated hazardous waste manaeement units in the second
quarter ofcalendar year 2010.
tr.K.2. The Permittee shall submit a oermit modification reouest that updates Attachment 10
(Closure Plan) for ATLIC associated hazardous waste manaeqnent units no later than the
first third quarter of cal€Nrdar year 2011.
EOUTVALENT MATERIALS/INT'ORMATION
For certain equipment, materials, or minor information specified in this Permit and
documents listed in Attachment 3 (Sampling, Analytical, and QA/QC Procedures) that do
not affect the analytical methods in the documents listed in Attachment 3 (Sampling,
Analytical, and QA/QC Procedures), the Permittee is allowed to use the equivalent or
II.L.
II.L.1 .
Module II - Page 6
TOCDF
General Facility ::#,ffi;
superior equipment, materials, or minor information. Use of such equivalent or superior
items shall not be considered a modification of the Permit, but the Permittee shall place in
the Operating Record (prior 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 soundness of the revision during inspections of the TOCDF and
take appropriate action. The format of tables, forms, and figures, is not subject to the
requirements of this Permit and may be revised at the Permittee's discretion.
TINANCIAL ASSURANCE F'OR X'ACILITY CLOST]RE
The Permittee is exempt from the closure financial assurance requirements, in accordance
with R3 1 5-8-8 [40 CFR Section 264.1 40(c) incorporated by reference].
LIABILITY REOI]IREMENTS
The Permittee is exempt from the liability coverage for sudden and accidental occurrence
requirements, in accordance with R315-8-8 [40 CFR Section 264.140(c) incorporated by
reference].
Module II - Page 7
7
h-
o-(-
o
A
TOCDFt Tank Systems
March 2007
MODULE IV. TAIIK SYSTEMS
TV.A. APPLICABILITY
fV,A.l. The requirements of this Module pertain to the storage and treatment of hazardous waste
in the Agent Collection System (ACS), Spent Decontamination System (SDs)lbothet
TOCDF and ATLIC), aa*Brine Reduction Area (BRA) and Lewisite Collect
OCS) tank systems identified in Condition IV.B.I. The Permittee shall comply with
R315-8-10 and the conditions of this Permit for all tank systems.
TV.B. WASTE IDENTIFICATION AI\D TANK USAGE
IV.B.I. The Permittee may only store at the listed maximum capacity, and treat by detoxification
(T29) in accordance with Attachment 2 (Waste Analysis Plan), if applicable, the
hazardous wastes listed for the following tank systems:
TOCDF HAZARDOUS WASTE STORAGE AND TREATMENT TAI\K SYSTEMS
Tank Number Maximum
Storage
Capacity
Gallons
Nominal Tank
Dimensions I
Allowable
Waste Codes
Permitted Management
Activity'
ACS-TANK-I01 500 (agent)
582 (other
permitted'
liquids,
Note 2)
3'-6" diameter,
9'-9" high
F999, P999,
D002, D003,
D004, D006,
D007, D008,
D009, D010,
D01 1, D028,
D034, D039
Storage of agent,
miscellaneous agent
contaminated liquids,
decontamination solutions
for maintenance or agent
change-over, and non-
hazardous agent
simulants
ACS-TANK-102 1,130 4'-6" diameter,
1 1r-9rr high
F999, P999,
D002, D003,
D004, D006,
D007, D008,
D009, D010,
D011, D028,
D034, D039
Storage of agent,
miscellaneous agent
contaminated liquids,
decontamination solutions
for maintenance or agent
change-over, and non-
hazardous agent
simulants
SDS-TANK-I01
SDS-TANK-IO2
SDS-TANK-103
2,200 per
tank
6r-0rr diameter
1 1'-6" high
F999,P999,
D002, D003,
D004, D006,
D007, D008,
D009, D010,
D011,D018,
D019, D022,
D028, D034,
D039, D040,
D043
Storage and treatment of
spent decontamination
solutions, miscellaneous
agent contaminated
liquids from a spill, and
liquid wastes from Area
10 Glovebox Operations
Module IV - Page 1
TOCDF
Tank Systems
March 2007
BRA-TA}[K-IO1
BRA.TA}IK.IO2
BRA.TANIK-2OI
BRA.TANK-202
42,900 per
tank
20'-0" diameter
20'-0" high
F999, D002,
D004
through
DOl I
Storage and treatment
spent scrubber brines and
Pollution Abatement
System (PAS) liquids
ATLIC
IIAZARDOUS WASTE STORAGE AI\D TREATMENT TAI\K SYSTEMS
Tank Number Maximum
Storage
Capacitv
Gallons
Nominal Tank
I)imensions I
Allowable
Waste Codes
Permitted Manasement
Activitv
LCS-TANIK-8s1I 1.020 5'- 3" diameler
6'-8" high
P999. F999.
D002. D004.
D007. D009.
D0t0
77***
Storage of Lewisite (.L)
Agent. miscetlaneous
Lewisite aeqnt
qo
decontamination solutions
during closure
NSF.TANIK-8s14 1.020 5'- 3" diameter
6'-8" high
P999. F999.
D002. D004.
D007. D008
D009. D0l0
$torage of Spent Nitric
gqrrerated from L TCs
rinse-out. 3 M or greater
Nitric Acid is added to
treat agent concentrations
to less than the WCL
LCS-TAh[K-8516 1.020 5r_ 3il
diameter
6t-8tt high
P999. F999.
D002. D004.
D007. D008
D009. D010
Storaee of Spent Nitric
eenerated from L TCs
rinse-out. 3 M or
sreater Nitric Acid is
added to treat asent
concentrations to less
than the \ilCL
SDS.TAI\IK-8523 1.020 5'- 3" diameter
6'-8" high
F999. D002.
D004. D007.
D008. D021.
Storage for,sLent NaOH
solution used to
decontaminate the interior
D009. D0l0 of emptied GA Ton
Containers. process
equipment. water used to
rinse out both GA and L
TCs. NaOH
decontamination solution
is added to treat for agent
concentrations greater
than the WCL
Module IV - Page 2
rv.B.2.
fV.B.2.a. Sumps listed in Table 4a mav ndditionallv receive wastes with code D021,
TOCDF
Tank Systems
March 2007
The sumps listed in Tablq 4 rnd4a, used to collect decontamination solutions, agent and
miscellaneous liquid spills are subject to the requirements of this Module. These sumps,
also called Intermittent Collection Units (ICUs) by the Permittee, may be used to treat
agent and agent contaminated hazardous wastes with decontamination solution before they
are pumped to the permitted SDS tank system. Only wastes with the codes F999, D002,
D003, D004, D006, D007, D008, D009, D010, D0l l, D018, D019, D0+1. D022, D028,
D034, D039, D040, D043 and P999 are allowed in the SDS sumps. The maximum
capacity of the SDS sumps as shown in Tableg 4 and 4a shall not be exceeded, except as
allowed by Condition IV.B.S or Attachment 16 (Tank Systems). Wastes shall not remain
in these sumps for more than24 hours, except as allowed by Conditions IV.B.6. and
tv.B.7.
Off-site generated hazardous wastes shall not be placed in any of the permitted tanks or
sumps.
Laboratory wastes shall not be placed in any of the permitted tanks and sumps.
Notwithstanding the requirements specified elsewhere in this Permit, the Permittee may
exceed the capacity of the sumps identified in Table 4 that are not listed in this Condition
if, during a toxic area entry, the sump pump ceases to work and the subsequent
decontamination of entrants causes the sump capacity to be exceeded and the
decontamination is necessary to ensure a safe exit from the room or in the event of a
failure of any of the SDS or ACS tanks. If this occurs, the Permittee shall record in the
Operating Record the circumstances that caused the overfill and shall remove the waste as
soon as it can be safely accomplished in accordance with Condition IV.B.2. This
exclusion does not apply to the following sumps: SDS-PUMP-101, 102, 103, 104, 130,
131, 133, 136,137,138, 139, 140,141,742,144,156,167,173,192,193, BRA-PUMP-
704,204,103.
Notwithstanding the requirements specified elsewhere in this Permit, the Permittee may
store waste in the sumps listed in Table 4 for greater than24 hours if a toxic area entry
necessary to support waste removal cannot be initiated or completed for any of the
following reasons:
fv.B.3.
rv.B.4.
IV.B.5.
LCS-TANK-8534 1.020 5'- 3" diameter
6'-8" high
P999. F999.
D002. D004.
D007. D008.
D009. D0l0
D021
Contingency storage for
major spills from tanks
and/or ancillary
equipment located in the
TOX to include LCS-
TANIK-85I I. SDS-
TANK-8523. and NSF-
TANK-85 14
NOTES: 1. See Attachment 16 for design information for the ACS, SDS. LCS. NFS and BRA
tank systems.
2. Miscellaneous agent contaminated liquids are defined in Attachment 2 (Waste
Analysis Plan), Section 2.2.1.1 5.
IV.B.6.
Module IV - Page 3
fV.B.6.a.
fv.B.6.b.
fV.B.6.c.
fv.B.6.d.
IV.B.6.e.
fv.B.6.f.
IV.B,6,g.
rv.B.6.h.
rv.B.7.
fV.C.
rv.c.1.
IY,C.2,
IV.C.3.
rv.c.4.
IV.C.5.
fv.c.6.
IV.C.7.
TOCDF
Tank Systerns' March2007
Agent concentrations exceed the authorized level for the PPE to be worn.
A breach or tear occurs in a DPE suit.
A loss of communications occurs between the parties involved in an entry.
The room temperature is too high to allow an entry.
Any of the participants in an entry suffer from an illness or heat stress.
A loss of Life Support System (LSS) air occurs.
A loss of either utility power or the Heating, Ventilation, and Air Conditioning (HVAC)
system occurs.
Explosive components are present, endanger worker safety, and cannot be removed so as
to allow removal of waste from the sump within 24 hours.
Forthose instances where waste is not removed from the sumps within 24 hours as
allowed by Condition IV.8.6., the Permittee shall record in the Operating Record the
circumstances that prevented removal within 24 hours and shall remove the waste as soon
as it can be safely accomplished.
GENERAL OPERATING REOI]IREMENTS
The Permittee shall not place incompatible waste or material in a tank system if the waste
or material could cause the tank, its ancillary equipment, or the secondary containment
sump to rupture, leak, corrode, or otherwise fail.
The Permittee shall not place hazardous wastes in a tank or its ancillary equipment that
has previously held an incompatible material until the tank or ancillary equipment has
been properly decontaminated. The Permittee shall not place a different chemical agent in
the ACS tanks until all sludge is removed and the tank has been properly decontaminated.
The Permittee shall not place a different agent in the sump systems until the campaign
changeover requirements for sumps specified in Attachment 5 (Inspection Plan) have been
satisfied.
Any permitted tank system used to store or treat ahazardous waste at the TOCDF h\efliC stratl be managed in accordance with Module X. '<'
The design and operating descriptions of the permitted tank systems are provided in
Attachment 16 (Tank Systems). Operation of the permitted tank and sump systems shall
comply with Attachment 16 (Tank Systems).
Waste shall not be added to any of the tanks described in Condition IV.B.1. unless the
associated tank's level control instrumentation identified in Attachment 6 (Calibration
Plan) is operational in accordance with the manufacturers' specifications and the level
devices are fully calibrated.
If treatment is conducted in a tank system, sufficient freeboard shall remain so the
permitted tank capacity shall not be exceeded when decontamination solutiorrs are added.,\
Any permitted tank used to store or treat ahazardous waste at ,1r" 1g6pt,g}Turc shall
=7-be equipped with a level control device that prevents the tank system from dxceeding the
permitted capacity.
Module IV - Page 4
IV.C.8.
fv.D.
IV.D.1.
fv.D.2.
fv.D.3.
IV.D.4.
IV.D.5.
I rv.E.
IV.E.1.
N.8.2.
TOCDF
'ffi:.:il'iffi;
The Permittee may transfer liquids accumulated in PAS-SUMP-I10 to the Brine Surge
Tanls @STs) provided that prior to transfer, the Permittee has analyzed the liquids in
accordance with Attachment 2 (Waste Analysis Plan).
spEcrFrc oPERATTNG CoNprrroNs - TocDF AGENT STORAGE TAr\KS
The only hazardous wastes or other materials allowed in ACS-TANK-IOI and ACS-
TANK-102 are liquid hazardous waste chemical agents, miscellaneous agent contaminated
liquid wastes, non-hazardous chemical agent simulants, and decontamination solutions
used to decontaminate the system after agent campaigns and prior to maintenance
activities that will be treated in the Liquid Incinerator (LIC) primary combustion
chambers.
The only chemical agents that can be placed in the ACS, ACS-TANK-101, and ACS-
TANK-I02 are GB, VX and Mustard (fV HD/HT) and their naturally occurring break-
down products.
The miscellaneous agent contaminated wastes allowed in the ACS, ACS-TANK-101, and
ACS-TANK-II2 are identified in Attachment 2 (Waste Analysis Plan), Section2.2.l.l5.
The maximum storage capacity of the Agent Holding Tank, ACS-TANK-101, shall be
582 gallons, except for agent. No more than 500 gallons of agent shall be stored in this
tank. The maximum tank level, measured from the tangent of the bottom dome, shall not
exceed seven feet six inches for non-agent wastes and six feet three inches for agent.
The maximum storage capacity of Agent Holding Tank, ACS-TANK-102, shall be 1,130
gallons. The maximum tank level, measured from the tangent of the bottom dome, shall
not exceed eight feet nine inches.
SPECIFIC OPERATING CONDITIONS -TOCDF SPENT
DECONTAMINATION STORAGE TANKS
The only hazardous waste or materials that shall be placed in SDS-TANK-I01, SDS-
TANK-102, and SDS-TANK-l03 are sodium hypochlorite decontamination solutions,
sodium hydroxide solutions, agent breakdown products resulting from decontamination,
the miscellaneous liquid wastes identified in Attachment 2 (Waste Analysis Plan) Section
2.2.1.15, spent bleach from PPE/personnel decontamination in the Munitions
Demilitarization Building (MDB) using bleach bottles, wash-down of equipment or
personnel with soap and water, major spills in accordance with Condition fV.E.4, run-off
from fire suppression efforts as described in Attachment 9 (Contingency Plan), and
cleaning solutions used to decontaminate the system after agent campaigns and prior to
maintenance activities.
The maximum storage capacity of SDS-TANK- 1 0 1, SDS-TANK- I 02, and SDS-TANK-
103 shall not exceed 2,200 gallons in each tank. The maximum tank level, measured from
the tangent of the bottom dome, shall not exceed nine feet five inches.
,o
Module IV - Page 5
fv.E.3.
fv.E.4.
fv.E.5
rv.E.6.
IV.E.7.
IV.E.8.
I rv.F.
IV.F.1 .
rv.F.2.
fv.F.3.
TOCDF
'il|:il:iffi;
The only treatment allowed in the SDS Tanks shall be the addition oiapproved
decontamination solutions (sodium hypochlorite or sodium hydroxide decontamination
solutions) when the chemical agents GB and VX are detected at or above 20 parts per
billion (ppb), and the mustard compounds II/IID/HT are detected at or above 200 ppb.
The Permittee shall maintain a minimum of one SDS Tank (SDS-TANK-101, SDS-
TANK-102, or SDS-TANK-103) free of waste when chemical agent (P999) is being
processed or stored inside the MDB to be used in the event of a spill as a result of a tank
failure, munition over-pack failure, or munition/bulk item failure.
The Permittee may accumulate waste, identified in Condition ry.B.1., in all three SDS
Tanls when no chemical munitions and bulk items are inside the MDB and no chemical
agents are stored in ACS-TANK-l0l and ACS-TANK-102, such as during agent
campaign changeovers or extended plant shutdowns.
In the event of a spill described in IV.E.4., munitions that have passed the Explosive
Containment Vestibule (ECV) may continue to be processed. The Permittee shall not
process any other munitions until the circumstances which resulted in the spill have been
rectified, the spill has been cleaned up, and a minimum of one SDS tank is free of waste,
as specified in Condition IV.E.4.
The Permittee shall manage waste accumulated in each SDS tank as an operating batch. A
batch of waste shall be the volume of liquid accumulated in the tank when filling of the
tank has been stopped and the Permittee has determined that no additional waste will be
added to the tank before it is to be emptied. Prior to emptying the tank, the Permittee shall
sample and analyze each batch of waste in accordance with the Attachment 2 (Waste
Analysis Plan) and Module X.
Each batch of liquid waste accumulated in the SDS tanks shall be incinerated in the
secondary chambers of the TOCDF LICs. Only liquid wastes having an agent
conce,ntration at or below 20 ppb for GB, 20 ppb for VX, and 200 ppb for II/IIT/HD shall
be incinerated in the secondary charnber of the LICs.
SPECTFIC OPERATING CONDITIONS - TOCDF BRINE SI]RGE TAI\KS
(BSTs)
The only hazardous wastes that shall be placed in BSTs, BRA-TANK-101, BRA-TANK-
102, BRA-TANK-201, and BRA-TANK-202, are spent scrubber brines from the
incinerator Pollution Abatement Systerns (PASs), liquid wastes from Sump 110,
decontamination solutions, liquids collected in the BST secondary containment system,
and decontamination or cleaning solutions used to decontaminate the system after agent
campaigns and prior to maintenance activities.
Reserved
No ignitable or reactive waste may be stored in the BSTs.
Module IV - Page 6
o",
fv.F.4.
TV.F.5.
fv.F.6.
fv.F.7.
TV.F.8.
TOCDF
'ffi1:iliffi;
The maximum storage capacity of the BSTs, BRA-TANK-l0l, BRA-TANK-102, BRA-
TANK-201 and BRA-TANK-202, shallbe 42,900 gallons per tank. The maximum level
of liquid in the tank, measured from the bottom of the tank, shall not exceed 18 feet three
inches.
The only treatment allowed in the BSTs shall be the addition of approved decontamination
solutions when the chemical agents GB and VX are detected in the brine above 20 ppb,
and the mustard compounds IIII{D/HT are detected in the brine above 200 ppb.
Contaminated liquids shall not be pumped from the BSTs until concentration levels are at
or below 20 ppb for agents GB and VX, and 200 ppb for mustard compounds H/HD/HT.
The Permittee shall manage waste accumulated in the BSTs in batches. A batch of waste
shall be the volume of liquid accumulated in the tank when filling of the tank has been
stopped and the Permittee has determined that no additional waste will be added to the
tank before it is to be emptied. At such time, the Permittee shall sample and analyze the
waste contained in that tank in accordance with the Attachment 2 (Waste Analysis Plan).
Waste in the BST System shall be transferred off site to an approved facility for heatment
and disposal.
ry.G. SPECIFIC OPERATING CONDITIONS - ATLIC LEWISITE AGENT IIOLDING
TAI\tK
IV.G.I. The only hazardous wastes or other materials allowed in LCS-TANK-8511 are Lewisite
chemical asent. miscellaneous Lewisite aeent contaminated liquids. and
decontamination solutions used to decontaminate the system bfter asent camoaigns and
orior to maintenance activities or closure.
IV.G.2. The only chemical agent that can be placed in LCS-TANK-8SI1 is Lewisite and
associated break-down produqts.
tV.G.3. ' The maximum storage capaclty of the LCS-TANK-8SI1 shall be 1.020 gallons. The
maximum tank level. measured frorh the tangent of the bottom dome. shall not exceed
67.5 inches
tV.H. SPECIFIC OPERATING CONDITIONS - ATLIC NITRIC ACID HOLDING
TANK
lV.H.l. The onlv hazardous wastes or other materials allowed in NSF-TANK-8514 and LCS-
TANK-8516 are liquid hazardous waste generated from the rinsing of L Ton Containers.
IV.H.2. The maximum storage caoacity of NSF-TANK-8514 and LCS-TANK-8516 shall be 1.020
gallons. The maximum tank level. measured from the tansent of the bottom dome. shall
not exceed 67.5 inches
Module IV - Page7
TOCDF
Tank Systerns
March 2007
IV.H.3. The onlytreatment allowed inNSF-TAII[K-8514 and LCS-TANK-8516 shall be the
addition of
selutienslorNitric Acid Solution (50 wtTo) whe,n L is detected at concentrations equal to
or greater than 200 parts per billion (opb).
fV.H.4. The Permittee shall manase waste accumulated in NSF-TAI\K-E514 and LCS-
TAI\K-8516 as an oneratine batch. A batch of waste shall be the volume of liquid
accumulated in the tankwhen fillins of the tank has been stopoed and the Permittee
has determined that no additional waste will be added to the tank before it is to be
emntied. Prior to emptvins the tank the Permittee shall samole and anahze each
batch of waste in accordance with the Attachment 2 (lVaste Analvsis Plan) and
ModuleX.
ryJ. SPECIFIC OPERATING CONDITIONS _ ATLIC SPENT DECONTAMINATION
HOLDING TAI\K
lV.I.l. The only hazardous waste or materials that shall be placed in L€SDS-TANK-8523 are
sodium hydroxidp decontamination solutions and ae€,nt breakdown products resultine
from the rhsins out and decontamination of Aeent GA Ton Contain€rs. rinse water
A and L Ton Contain
IV.I.2. The maximum storaee capacity of LGSDS-TAI.[K-8523 shall be 1.020 gallons. The
maximum tank level. measured from the tangent of the bottom dome. shall not exceed
67.5 inches
IV.I.3. The only treatnent allowed in LGSDS-TANK-8523 shall be the addition of approved \ir
ium hvdroxide decontaminatio
orLi 0 oarts Der million
IV.I.4. The Permittee shall manaee waste accumulated in LCS-TANK-8523 as an op€ratine
batch. A batch of waste shall be the volume of liquid accumulated in the tank wh€n fillins
of the tank has been stopped and the Permittee has determined that no additional waste
will be added to the tank before it is to be emotied. Prior to emptyine the tank. the
Permittee shall sample and anallze each batch of waste in accordance with the Attachment .
2 (Waste Anal]rsis Plan) and Module X.
Each batch of li mulated in SDS-TAI\K-8523 shall be incinerated in
IC. Onlv liquid wastes havins an asent GA or Lthe secondafv i
concentrati hall be incinerated in the secondarv chamber
of the AT
IV.J. SPECIFIC OPERATING CONDITIONS - ATLIC MAJOR SPILL COLLECTION
ht or belo
TAI\K
Module IV - Page 8
TOCDF
Tank Systems
March 2007
fu.J.1. The Permittee shall maintain LCS-TANK-8534 free of waste when liquid wastes are
present in the ATLIC Processins Bav or Toxic Area. This tank shall be used in the
event of a major soill as a result of a tank. ancillary eouipment. or ton container failure.
lV.J.2. ln the event of a major soill LCS-TANK-8534 may be used to store any one of the
followine waste that are processed or eenerated at the ATLIC: Agents GA or Lewisite.
Spent Decontamination Solutions and ton container rinse water. or Spent Nitric Acid.
Onl], one type of waste may be stored in LCS-TANK-8534 at a time.
IV.J.3. The maximum storage capacity of LCS-TANK-8534 shall be 1.020 eallons. The
maximum tank level. measured from the tansent of the bottom dome. shall not exceed
67.5 inches
IV.J.4. The Permittee may complete the processing of any ton containers that are currently in the
Glove Box Miscellaneous Treatment Units. but shall discontinue,receipt of additional ton
containers until the circumstances which reSulted in the spill have been rectified. the spill
has been cleaned up. and LCS-TANK-8534 is empty. to include the lower oortion of the
tank that is domed.
IV.J.6. Waste stored in LCS-TANK-8534 shall be treated in the combustion chamber or
Hazardous Waste Management Unit specified for the waste stream being stored in
Conditions IV.G. 1 IV.H. I . IV.I.15 or IV.K. I . Aeen#GA Specifically, chemical agents
shall be treated in the Primary Combustion Chamber of the ATLIC LIC. Snent Nitric
Acid Solutions shall be transferred to an off-site Subtitle C TSDF. Soent
Decontamination Solutions shall be treated in the Secondarv Chamber of the ATLIC
LIC. ( ioO i {l,1, Q.,- '' r, t
IV.GK.SI]MPS DESIGNATED AS 24-HOI]R INTERMITTENT COLLECTION T]NITS
(ICUs)
Except as allowed by Conditions IV.B.6. and IV.B.7., hazardous wastes may be stored in
the sumps (ICUs) identified in Table 4 for a period not to exceed 24 hours. Except as
allowed by Conditions IV.B.6. and IV.8.7., sumps shall be pumped at least once every 24
hour period if liquids are detected.
Compliance with Condition IV.GL.1. shall be documented in the Operating Record by
recording the time and the duration between activation and deactivation of each sump's
low level indicator instrument.
OPERATING PROCEDTIRBS FOR BRINE TANKS SECONDARY
CONTAINMENT ST]MP
IV.GK.1.
IV.GK.2.
lv.+IL.
Prior to orocessins waste stored in LCS-TANK-8534 the Permittee shall comolv with the
Module IV - Page 9
^/
| [v.HL.1.
I rv.il.1.a.
I rv.++r.1 .b.
I rv.rn.l .c.
I tv.HL.2.
I
I IV.I+1.3.
1y.fM.
IV.[VI.1 .
I IV.[\rI.2.
TOCDF
'il:.:iliffi;
Except for the presence of liquid in the sumps allowed by Attachment 5 (Inspection Plan),
if the Permittee detects liquids in the BST System sump (identified by the associated
pump number, BRA-PUMP-l03 orBCS-PUMP-l07 in Table 4), within 24 hours, the
Permittee shall manage the liquids using one of the three following methods:
The accumulated liquids can be transferred to a BST where the liquids shall be managed
as a hazardous waste;
The accumulated liquids can be transferred off site where these accumulated liquids will
be managed as a hazardous waste (spent scrubber brines) as specified in Section 2.2.2.13
of Attachment 2 (Waste Analysis Plan); or
If it can be demonstrated, in accordance with R315-2-3, that the material removed from
the sump is precipitation, which does not contain listed hazardous wastes, the material
may be managed as a non-hazardous waste. For the purposes of demonstrating that the
material does not contain a listed waste, or is not derived from a listed waste, the analytical
results obtained shall indicate that there is no detectable chlorine, the pH is neutral, the
concentrations for TC metals and TC organics (identified by footnote 3 in Table 2-l in
Attachment 2) are below the corresponding detection limits, and the specific gravity is
equal to I t 5%. If these criteria are met, the material may be managed as a non-
hazardous waste.
Snow and ice shall not be allowed to accumulate or remain within the Brine Tank
Secondary Containment System. Snow, ice, and liquid shall be removed within 24 hours
of the end of the precipitation event. Snow and ice shall be managed as specified in
Condition IV.{L.1.
Sludges or solids collected in the BST System sump shall be analyzed for TCLP metals
and TCLP organics. If the material from a representative sample is found to contain
TCLP metals or TCLP organics above the toxicity characteristic regulatory level, the
material shall be managed as a hazardous waste. If the metals or organics are all below the
toxicity characteristic regulatory level, the material may be managed as a non-hazardous
waste,
INSPECTION SCIIEDT]LES AI\D PROCEDT]RES
The Permittee shall inspect the tank and sump systems in accordance with the inspection
schedule provided in Attachment 5 (Inspection Plan).
If any SDS or BRA tank has been out of service for 360 or more days, it shall be
recertified by an independent, qualified registered professional engineer that the tank
system is capable of storing liquid hazardous waste for the intended life of the system.
The Permittee shall have this certification performed before the tank is put back into
service. The certification report shall then be submitted to the Executive Secretary within
15 days after returning the tank system to service.
RESPONSE TO LEAKS OR SPILLSI rv.4!.
Module IV - Page l0
O
! fv.4g.1.
I rv.il$.1.a.
I rv.N.1.b.
I rv.N.1.c.
I rv.N.1.d.
I IV.4g.2.
I IV.49.3.
rv.Ko.
IV.KQ.1.
IV.tP.
IV.LP.1 .
TOCDF
'ilI,:iliffi;
In the event of a leak or a spill from a tank systern, from a secondary containment sump
system, or if a system becomes unfit for continued use, the Permittee shall remove the
system from service immediately and initiate the following activities:
Stop the flow of hazardous waste into the system and inspect the system to determine the
cause ofthe release.
Contain any visible release to the environment. The Permittee shall immediately conduct
a visual inspection of all releases to the environment and based on that inspection: (1)
prevent further migration of the leak or spill to soils or surface water and (2) remove and
properly dispose of any visible contamination of the soil or surface water.
Remove waste and accumulated precipitation from the systern within 24 hours of the
detection of the leak to prevent further release and allow inspection and repair of the
system. If the Permittee finds that it will be impossible to remove the waste within this
time period, the Permittee shall notiff the Executive Secretary as soon as possible but not
to exceed 24 hours of that determination.
For a release caused by a spill that has not permanently damaged the integrity of the
system, the Permittee shall remove the released waste and make the necessary repairs to
fully restore the tank or sump system before it is put back into service.
If the Permittee replaces a component of the tank system to eliminate a leak, the
replacement component shall satisfu the requirements for new tank systems or components
in R3 1 5 -8- 1 0 [40 CFR Sections 264.192 afi 264.193 incorporated by reference].
After all major tank or sump system repairs, the Permittee shall obtain a certification by an
independent, qualified registered professional engineer that the repaired system is capable
of handling hazardous wastes without release for the intended life of the system before
retuming the system to service. Examples of major repairs are: installation of an internal
liner, repair of a ruptured tank, or repair or replacement of a secondary containment vault.
CALIBRATION REOUIREMENTS
The Permittee shall maintain, calibrate, and operate all process monitoring, control, and
recording equipment as specified in Attachment 6 (Calibration Plan), whenever hazardous
wastes are present in a permitted tank system.
RECORD KEEPING AI\D REPORTING
Except as allowed in Condition [y.L.2' the Permittee shall orally report to the Executive
Secretary within 24 hours of detection when a leak or spill occurs from a tank system or
secondary containment syston.
Releases from a tank system that are contained within a secondary containment system
need not be reported unless they occur from an unexplained source. All pertinent
information about a release shall be recorded in the facility Operating Record.
| [v.L9.2.
Module IV - Page 11
| [v.L9.3.
IV.LP .3.a.
[v.LP.3.b.
I rv.rp.3.c.
I rv.rp.3.d.
I rv.rp.3.e.
| [v.L9.4.
I IV.Lg.5.
[V.LP.5.a.
IV.LP.5.b.
IV.LP.5.c.
I w.rg.s.d.
I rv.rp.5.e.
I rv.rp.s.f.
TOCDF
'ilL:iliffi;
Within 30 calendar days of detecting a release to the environment from a tank system or a
secondary containment system, except for P999 and F999 wastes which require a written
report 4s specified by Condition I.U., the Permittee shall report the following information
to the Executive Secretary:.
Likely route of migration of the release;
Characteristics of the surrounding soil (including soil composition, geology, hydro
geology, and climate) including proximity of down gradient drinking water, surface water,
and populated areas;
Results of any monitoring or sampling conducted in connection with the release. If the
Permittee finds it will be impossible to meet the written report time period, the Permittee
shall provide the Executive Secretarywith a schedule of when the results will be available.
This schedule shall be provided in writing before the required submittal period expires;
Description of response actions taken or planned to minimize the spill impact on the
environment;
Describe the repairs, design changes, or operating procedures to the tank system to
minimize the potential for additional spills or leaks.
The Permittee shall keep on file at the facility the written certification statements by those
persons that certifr the design, installation, and integrity of the tank systems until such
time that those tank systems are certified closed.
In the event that a tank exceeds the maximum allowable capacity designated for that
system, the Permittee shall notiff the Executive Secretary in writing within seven days of
discovery and document the following information in the facility Operating Record:
The date and time of occurrence;
The tank system involved and its contents at the time of the occurrence;
Any other available tank storage volume within the system. If no additional storage
capacity was available within the storage system, indicate if the associated collection and
treatment activities were automatically stopped;
A description of whether the tank system automatically switched from the High-High level
tank to a tank with the available storage capacity and if the tank intake valves were
automatically closed;
Any associated incinerator automatic waste feed cutoff interlocks. IdentiSr the interlocks
and whether the interlocks were successfully activated; and
A description of the operating control procedures that allowed the tank system to exceed
the maximum allowable storage capacity (e.g., why the operator was not successful in
managing the waste within the high level volume working capacity).
Module IV - Page 12
O I rv.Lg.6.
| rv.fg.Z. The Permittee shall document and record the results of each BST waste analysis and any
subsequent treatment.
I rv.nee. cr,osrrRE
I rv.UQ.t. Partial Closure
I W.Uq. t .u. At the conclusion of each agent campaigl, the TOX shall be thoroughly decontam:inated;
all decontamination films shall be removed using an appropriate rinse; all clouded
observation windows that compromise the ability to view operations shall be cleaned or
replaced; and maintenance and repair shall be performed. The Permittee will submit in
writing to the Executive Secretary, a request for partial closure of the room and tank
systems, since the agent is being changed. Upon approval for partial closure by the
Executive Secretary, the next campaign will commence, when authorized, and when it is
appropriate to do so.
lrv.uo.z.ThePermitteeshal1closethe@TankSystemsinaccordancewith
Attachment 10 (Closure Plan).
TOCDI.
Tank Systons
March 2007
The Permittee shall document and record the results of each SDS tank waste analysis and
any subsequent treatment.
Module IV - Page 13
o
o
o
i
TOCDF
Long-Term Incineration' 'i: March 2009
MODULE V LONC,-TERM INCINERATION
,iV.A. GENERAL CONDITIONS FOR INCINERATORS AIID f,'T]RNACES
.". V.A.I. CONSTRUCTION AND MAINTENANCE
V.A.1.a. The Permittee shall maintain each incinerator and furnace in accordance with the design
plans and specifications. Design plans and specifications shall be provided to
representatives ofthe Executive Secretary upon request.
V.A.l.b. Modification to the design plans and specifications for an incinerator or a furnace shall be
allowed only in accordancewith Condition tr.A.2.
V.A.l.c. ' The Permittee shall install and test all process monitoring and control instrumentation for
each incinerator and furnace in accordance with the design drawings in Attachment 11,
and in accordance with the performance specifications and maintenance procedures
Il. contained in Tables 6-A-1 (LIC 1) and 6-A-2 (LlC 2); Table 6-8 (MPF);an*Table 6-C
| (DFSLand fable 6-f (efLIC) in Attachment 6 (Instrument Calibration Plan and
Incinerator Waste Feed Interlock Function Test).
V.A.l.d. Reserved.
V.A.lre. The Permiuee shall maintain each incinerator or furnace such that when operated, in' accordance with the operatiiig requiremerts specified in this Permit, each incinerator or
fumace shall meet the applicable performance standards specified in Section Y.A.2.
V.A.l.f. The Permittee shall maintain and operate a minimum of one monitor for each oxygen (O2)
and carbon monoxide (CO) continuous emission monitor specified in Attachment 19
(Instrumentation and Waste Feed Cut-off Tables). If either the CO or 02 monitors fail,
" and no certified backup CEMS is on line, for continuous monitoring then feed to the
incineratoi or furnace shall be stopped.
V.A.1.f.i. For the MPF and DFS only, a back up 02 and CO monitor shall be on line in case the
primary monitor fails or malfunctions during waste feed. The Permittee shall use the
backup monitor until the waste has exited the furnacri or furnace system. The monitor that
failed or malfunctioned shall be replaced or repaired prior to resuming feed to the furnace
- or furnace system.
V.A.l.g. The Permittee shall maintain and operate Depot Area Air Monitoring System (DAAMS)
tubes and Automatic Continuous Air Monitoring System (ACAMS) monitor on each. incinerator or fumace exhaust duct and DAAMS tubes and staggered ACAMS monitors
on the corlmon stack as specified in Attachments 19 (Instrumentation and Waste Feed
Cut-off Tables) and 22 (Agent Monitoring Plan).
V.A.1 .9.1 . When processing Agent GA the Permittee shall maintain and operate DAAMS tubes and
staggered ACAMS monitors on the ATLIC Stack aS soeci.fibd in Attachments 19
(loit***tutio, urrd Wust" F""d Cut offT .
\* _.-i* :*&,
ModuleV-Pagel
TOCDF
Long-Terrn Incineration
March 2009
V.A.l.g.2. When processing Lewisite the Permittee shall maintain and operate ei{her DAAMS tubes
MINICAI{S monitors on the ATLI ed in Attachments
19 tion and Waste Feed Cut-off Tables) atid 22 A bnt Monitorin
Plan
v.A.1.h.
*itbthe4rs#se*
Major maintenance changes shall require recalibration of the Continuous Emission
Monitoring Systems (CEMS) in accordance with the most stringent requirements of 40
CFR Part 266, Appendix IX, 40CFR Part 60, Appendix B, Performance Specification
Tests and Attachment 20 (CEMS Monitoring Plans), Section 8.a.7. A certified monitor
may receive minor maintenance and repairs and still remain certified in accordance with
V.A.l.h.i and 40 CFR 266, Appendix D(.
The following table categorizes the CEMS repairs and maintenance, and the re-
certification step, if required, prior to placing the instrument on line for monitoring:
?
"tA "
v.A.l .h.i.
Maintenance operation Rep a irs/lVl a int en a n c e
Included
Operational Validation
Steps Required
Modification of Critical
Components
oChanges to probe
construction material
oChanges of detection
method
oAddition or deletion of
sample conditioning
components
oRelative Accur acy Test
Audit (RATA).
c7 -Day Calibration Drift
Test.
oResponse Time Test.
oCalibration Error Test.
Note: This is a full
CEMS re-certification.
Major oDetector change or repair.
oCircuit card change or
repair.
oPower supply change or
repair.
o7 -Day Calibration Drift
Test.
oResponse Time Test.
oCalibration Error Test.
Minor
(M aintenanc e/Rep airs)
oAll other maintenance and
repair activities not
addressed above. These
include, but are not limited
to:
.Analyzer adjustment or
optimization.
oCell replacement.
oPump r epatr I rep lacement.
oFilter replacement.
o Sample conditioner repair
gr replacement.
oProbe replacement.
oRe-calibration of
instrument.
oCalibration Error Test.
oResponse Time Test
Note: Re-certification in
accordance with 40 CFR
266, Appendix IX is not
required for monitors
receiving Minor
maintenance or repairs.
The monitor shall remain
certified.
ModuleY -Page}
. TOCDF
Long-Term Incineration. March 2009
oTubins replacement.
I V.e. t .U.ii. The fotlowing table categori zes the API-300EM CO analyzt repairs and maintenance,
and the recertification step, if required, prior to placing the instrument on line for
monitoring: ".
Maintenance Operation RepairslVlaintenance
Included
Steps Required to Re-
Certify for Operations
Modification of Critical
Components i:.
o Replacement or update
software
o Replacement of software chip
r Replacement of CPU
Full CEMS analyzer
recertification including :
o Relative Accuracy Test
Audit (RATA)
o 7.Day Calibration Drift
o Response Time Test
o Calibration Error Test
Major o Change out of detector
o S ynchronous/I) emodulation
board replacement
o Source
. GCF wheel
o GDF wheel motor
o Calibration Error Test,
Calibration
o Calibration Error Test,
Calibration, Dark Calibration
o Calibration
o 7 Day Calibration Drift
M inor (MaintenanceRep airs)o Front panel filter
o Any electronic board other
than Synchronous/
Demodulation
o Calibration
o Calibration
V.A.l.i. For the monitors specified in V.A.l.f., the replacement monitors, shall be certified in
accordance with Condition V.A.4.f.
I V.e.t j. Replacement ACAMSA4IMCAMS shall be available for the monitors specified in
V.A.1.g. These monitors shall be certified in accordance with Attachment 3 (Sampling,
Analyical, and QA/QC Procedures).
V.A.1.k. Replacernent of the oxygen (O) and carbon monoxide (CO) monitors specified in
V.A.l.f. shall be in accordance with the following:
V.A.l.k.i. The replacement monitor shall be calibrated in accordance with R3l5-50-16 [40 CFR Part
266 , Appendix lX, 2 .l .6 .2 . for Response Time, and 2 .I .6 .3 for Calibration Errorl
immediately aft er installation.
V.A.1.k.ii. The replacement monitor shall be calibrated when installed and checked thereafter for' Calibration Drift.
ModuleV-Page3
V.A.1.k.iv.
v.A.1 .1.
v.A.1.1.i.
Y.4.2.
Y.4.2.a.
TOCDF
Long-Term Incineration
March 2009
The replacement monitoring system shall be calibrated and on-line before the calibration
of the first monitor has expired. If this carurot be accomplished, feed to the incinerator or
fumace shall be discontinued.
Both monitors for one location may not be replaced within one 24-hour period without
approval from the Executive Secretary.
A report speciffing the following information shall be submitted to the Executive
Secretary within 14 calendar days of replacement of any oxygen (Or) and carbon
monoxide (CO) monitor specified in Condition V.A.1.f.
The calibration data, both raw data and Process Data Acquisition and Recording System
(PDARS), in accordance with R315-50-16 [40 CFR Part266, Appendix IX];
Serial numbers, t5pes, and ranges of both failed and replacement monitors;
Date and time the monitor failed;
Maintenance to be performed; and
The identity of the incinerator or fumace.
Replacement monitor information in Condition V.At.t. shall also be included in the
annual report specified in Condition I.AA.
PERFORMANCE STANDARDS
The incinerators and furnaces must achieve a Destruction and Removal Efficiency (DRE)
listed in the following table for the chemical agent trial bum principal organic hazardous
constituents (POHCs), the chemical agents GB, VX, and Mustard (H/IID/HT), and
propellant, explosives, and pyrotechnics @EP). The DRE shall be calculated by the
method specified in R315-14-7.
Incinerator / Furnace (POHC)Minimum POHC DRE
Each TOCDF LIC (GB, VX, Mustard')99.9999%
MPF (GB,VX, Mustardr)gg.9ggg%
DFS (GB, VX)'99.990
DFS (PEP)3 99.9904
ATLIC
(Monochlorobenzene & Tetrachloroethylene)a 99.99990/o (each)
'Distilled Mustard (HD) has highest concentration of POHC in Mustard series
HDIHIHT.
'A PFS DRE for Mustard not required.
3A,' one time demonstration during any agent campaign.
oThe DRE for the identiGtbompounds serve as a surrosate measure of the DRE
for An.r,t, urc th. trro un.nt th. ATLIC *ill pror"rr.
The particilaterfatter emission from the TOCDF common stack shall be controlled by
limiting the concentration of particulate in the exhaust gas from the Pollution Abatement
Svstem of each incinerator to less than 29.8 millierams per drv standard cubic meter,
v.A.2.b.
ModuleV-Page4
o
TOCDF
Long-Temr Incineration
March 2009
colTected to 7%o oxygen in accordance with the formula given below@
mi
P.:P,,X l4l(21 -Y)
P, : measured concentration of particulate matter ppm (dry volume)
Y: measured 02 in the stack gas
V.A.2.b.i. The particulate matter ernission from the ATLIC stack shall be controlled by limiting the
concentration of particulate in the exhaust gas to less than 3.7 milligrams per dry standard
cubic meter. corrected to 7olo oxygen in accordance with the formula given above.
Y.A.2.c. The hydrogen chloride emission from the TOCDF common stack shall be controlled by
limiting the concentration of hydrogen chloride in the exhaust gas from the Pollution
Abatement System of each incinerator to less thar32 parts per million by volume, on a
drybasis corrected toTo/o oxygen.
V.A.2.c.i..The hvdrosen chloride emission from the ATLIC stack shall be controlled bv limitins the
concentration of hydroqen chloride in the exhaust gas to less than 21 parts per million by
volume. on a dry basis corrected to 7olo oxyeen.
v.A.2.d.
V.A.2.e.
v.A.2.f.
v.A.3.
V.A.3.a.
Toxic metals emissions shall be controlled by limiting the agent and agent contaminated
waste feed rates to each incinerator and furnace. . ,"t//.cto,ot,l
The Permittee shall control emissions of product2of incomplete combustion from each
TOCDF incineratorg and furnaceg and the ATLIC such that the carbon monoxide (CO)
level in each exhaust duct, corrected to 7o/o oxygen in accordance with the formula given
below, shall not exceed 100 parts per million (ppm), dry volume, over a one-hour rolling
average.
CO. : CO,, x (21 - 7)l(21 - O,,)
Where:
CO.: corrected CO ppm (dryvolume)
CO. : measured CO ppm (dry volume)
O, : measuredoh Oz (dry volume)
Compliance with the operating conditions specified in Conditions V.B.2., V.C.2., ard
V.D.2.. and V.E.2 shall be regarded as compliance with the required performance
standards identified in Conditions V.A.2.a. through V.A.2.e. However, if it is determined
that during the effective period of this Permit that compliance with the operating
conditions in V.B.2., Y.C.2., erV.D.2.. oi V.E.2. is not sufficient to ensure compliance
with the performance standards specified in Conditions V.A.2.a. through V.A.2.e., the
Permit may be modified, revokel, or reissued, pursuant to R315-3-4
INSPECTION REOUIREMENTS
The Permittee shall inspect each incinerator and furnace in accordance with the inspection
requirements of Attachments 5 (Inspection Plan) and 6 (Instrument Calibration Plan and
Incinerator Waste Feed Interlock Function Test).
ModuleV-Page5
v.A.3.b.
V.A.3.c.
V.A.3.c.1
V.A.3,c.2
V.A.3.c.3
V.A.3.c.4
v.A.4.
V.A.4.a.
V.A.4.a.i..
TOCDF
Long-Term Incineration
March 2009
The inspection data for the incinerators and furnaces shall be recorded. The records shall
be placed in the Operating Record for each incinerator and furnace in accordance with
Condition II.I.
The following requirements apply when non-routine maintenance or repairs are performed
on the Quench Tower, Venturi Scrubber, Scrubber Tower, or Demister. Ancillary
equipment is excluded from these requirements.
The Permittee shall notifr the Executive Secretary prior to the non-routine work.
All work shall be performed in accordance with TOCDF work order procedure (PRP-MG-
015), which requires all work to be done in accordance with applicable specifications.
Qualrty inspection and verification shall be conducted in accordance with TOCDF qualrty
procedure (PRP-QA-006) and the affected component shall not be put in service until all
inspections are complete
All work order documentation and manufacturing specifications shall be maintained in
TOCDF Document Control for archiving during the life of the facility.
MONITORING REOUIREMENTS
The Permittee shall maintain, calibrdte, and operate process monitoring, control, and
recording equipment as specified in Attachments3 (Sampling, Analytical, and QA/QC
Procedures), 6 (Instrument Calibration Plan and Incinerator Waste Feed Interlock
Function Test), 19 (Instrumentation and Waste Feed Cut-off Tables), 20 (Continuous
Emission Monitoring System Plans), and 22 (Agent Monitoring Plan); Condition V.A.1.f.
and V.A.1.g.; and Conditions V.EE.6 through V.EE.10 while incinerating hazardous
waste.
The Resource Conservation and Recovery Act (RGRA) rhonitors shall monitor as
described in Conditions V.A.l.f. and V.A.1.g. The following table lists the alarm levels
for the common stack, ducts and HVAC stack. Any alarm at or above these levels at the
conrmon stack or ducts (when monitoring in accordance with Attachment 22)will cause a
waste feed cut-off. If the HVAC stack ACAMS alarm at or above 0.5 VSL for any agent
being monitored, a staged shutdown in accordance with Module X (Air Emission
Standards for Equipment Leaks, Tanks, Containers, and the HVAC) shall be performed.
MONITORING
STATION
MONITORING
LEVEL DAAMS Confirmation
Common Stack3
70 I AG ,7O I BG, 70I CG 0.2 SEL'70I DG,7OI EG
Common Stackr
706AV, 706BV, 706CV
0.2 SEL'706DV ,7068V
Common Stack
7A7 AH,7O7BH,7O7CH 0.2 SELI 7O7DH,7O7EH
DFS Duct
7O2AH,7O2BH 0.2 SELI Yes
MPF DuctJ
703C,703D
0.2 sEL' (Ce)
0.5 sEL'(VX)Yes
ModuleV-Page6
TOCDF
Long-Terrn Incineration
March 2009
MONITORING
STATION
MONITORING
LEVEL DAAMS Confirmation
MPF Duct
7O3AH, 7O3BH 0.2 SEL'Yes
LIC I Duct
7O4AH, BH 0.2 SEL'Yes
LIC 2 Duct
Duct 705AH, BH 0.2 SELI Yes
HVAC Stack
60I CH, 60I DH
0.5 VSL2 Yes
HVAC Stack
601AV, 601BV for VX
601 EG. 601FG for GB
0.5 VSL2 H i s tori callc o n fi im ati ona
ATLIC PAS Stack
GA monitors
L monitors
GA: 0.52 SELI
L - oif! sEL'
Yes5
ATLIC HVAC Stack
GA monitors
L monitors
GA: 0.5 VSL2
L: 0.4 VSL2
Yes5
Notes:
' SEL1mgm3l: cB=0.0003, VX=0.0003, HD: 0.03. GA:0.0003. Lewisite : 0.032 vsllmg/m3;: GB= 0.000 l, vx=0.00001, HD:0.003. GA=0.000 l. Lewisite : 0.003.
3
a' When processing secondary waste the DAAMS tubes become confirmation tubes. When
mustard is the only agent inside the facility boundaries, the tubes are historical.
5' GA DAAMS become historical when Lewisite is lhqonly aeent bcins proeessed bv the ATLIC.
U menitering is p€rformed
V.A.4.a.ii. A CEMS monitor may be taken off-line for calibration and minor maintenance as' - specified in Condition V.A.l.h.
Data from the CEMS shall be recorded in the operating record and PDARS.
V.A.4.a.iv. Data from the 02 and CO CEMS and staggered, common stack ACAMS monitors shall be
used for reporting requirements.
V.A.4.a.v. All RCRA monitors shall be connected to the waste feed cut-off.
V.A.4"b. Monitoring of oxygeri (O2), carbon monoxide (CO),.and agent shall be provided at all
times during waste feed to a fumace or incinerator. If an intemrption in monitoring (CO,
02 or agent) occurs, feed to that furnace shall be discontinued exce,pt as allowed in
Attachment 19 (lnstrumentation and Waste Feed Cut-off Tables). If the duct is not
monitored by an ACAMSA4IMCAMS, then the DAAMS tubes shall be analyzed for that
time period the ACAMSA{INICAMS was offJine. Monitoring shall resume in
accordance with Attachment 22 (AgentMonitoring Plan).
\:__
V.A.4.c. Hazardous wastes shall not be fed to an individual incinerator or furnace if any one of the
monitoring instruments listed in Attachment 19 (Instrumentation and Waste Feed Cut-off
Tables) pertaining to that incinerator or fumace fails to operate properly.
ModuleV-Page7
v.A.4.d.
V.A.4.e.
v.A.4.f.
v.A.4.f.i..
V.A.4.f.i.a
v.A.4.f.ii.
v.A.4.f.iii.
V.A.4.f.iv.
V.A.4.f.v.
V.A.4.f.vi.
TOCDF
Long-Term Incineration
March 2009
Upon receipt of a written request from the Executive Secretary, the Permittee shall
perform sampling and analysis of the waste and exhaust emissions to veriffthat the
operating requirements established in the Permit achieve the performance standards
delineated under Condition V.A.2.
All monitoring, recording, maintenance, calibration, and test data shall be recorded and
the records shall be placed in the operating record for each furnace in accordance with
Condition II.I.
The oxygen (Oz) and carbon monoxide (CO) monitors specified in Condition V.A.1.f.
shall be certified in accordance with R3l5-50-16 [40 CFR Part266, Appendix D( and
40CFR Part 60, Appendix B, using the most stringent requirements.
Certification or recertification must be accepted by the Executive Secretary.
Interim approval of certification or recertification test results may be granted by the
Executive Secretary, based upon a review of preliminary data and observations made
during the certification testing, to allow operation of the monitor for compliance prior to
submission of the final certification or recertification report.
A certified monitor may only receive minor modifications and still remain certified.
Condition V.A.1.h.i classifies CEMS repairs and maintenance as major changes or minor
changes.
Written approval from the Executive Secretary shall be required for downgrading a major
change to a minor change.
Each monitor shall be recertified annually, in accordance with R315-50-16 [40 CFR266,
Appendix IXI and 40CFR Part 60, Appendix B using the most stringent requirements.
This recertification shall be initiated within or before the calendar quarter of the
certification anniversary date. The current certification shall remain in effect until a
determination is made on the recertification.
The certification date shall be the first day of certification testing.
ModuleV-Page8
V.A.4.g.
v.A.5.
V.A.5.a.
v.A.6.
V.A.6.a.
v.A.6.b.
v.B.
v.B.1.
V.B .I .a.
TOCDF
Long-Term Incineration
March 2009
Pursuant to Attachment 22 (Agerfi Monitoring Plan), the Permittee shall monitor and , A {!
control emissions of chemical agsnts from each incinerator, fumace, and the TOCDF € lt r t-
common stack. The emission level measured by each monitoring system shall not exceed
the following concentrations:
Chemical Agent Concentration (mg/m3)
GB H/IID/HT VX
TOCDF Incinerator and
Common StackMaximum
StaelrEmission:
0.0003 0.03 0.0003
GA Lewisite
ATLIC PAS Stack
Maximum Emission:
0.0003
CLOSURE
At closure, the Permittee shall follow the procedures in Attachment 10 (Closure Plan).
RECORDKEEPING
The Permittee shall record and maintain, in the operating record for each incinerator and
fumace, all monitoring and inspection data compiled under the requirements of this
Permit, in accordance with Condition ILI.
The Permittee shall record in the operating record the date, time, and duration of all
automatic waste feed cut-offs, including the triggering parameters, reason for the deviation
that resulted in a waste feed cut-off, and corrective measures taken to prevent recuffence
of the incident. The Permittee shall also record all incidents of the automatic waste feed
cut-off function failures, including the corrective measures taken to alleviate the condition
that caused the failure.
TOCDF LIOUID INCINERATORS &ICs)
All numeric values included in any of the Conditions under V.B., which are marked with
an asterisk (*), (except numeric values for agent GB, which have previously been
approved) are tentative and may be modified by permit modification after the results of
each trial burn have been evaluated by the Executive Secretary in accordance with R3l5-
8-15.5(c). The Executive Secretary reserves the right to replace the values, which are
marked with an asterisk as necessary to be protective of human health and the
environment.
LIMITATION ON WASTE FEED
Except during the short-term periods specified in Module VI for shakedown, trial burn,
and post-trial burn, the Permittee shall incinerate only the following hazardous wastes in
each LIC, in compliance with the operating requirements specified in Condition Y.8.2.
ModuleV-Page9
V.E}.1.a.i..
V.B.1.a.ii.
v.B.1.b.
V.B.1.c.
v.B.1 .d.
V.B.l .e.
TOCDF
Long-Terrn Incineration
March 2009
Only one chemical agent, or waste containing one chemical agent, shall be fed to the
primary combustion chamber of the LIC at any given time.
The spent decontamination solution or the miscellaneous agent contaminated wastes may
be bumed either in the primary combustion chamber or secondary combustion chamber
but not at the same time. If these wastes are bumed in the secondary combustion chamber,
then only agent may be fed to the primary combustion chamber at the same time.
The Permittee shall not incinerate any chemical agent, or any waste containing the
chemical agent, for which treatment has not been successfully demonstrated through a trial
burn in accordance with Module VI or by other means approved by the Executive
Secretary.
The Permittee shall not incinerate any hazardous waste in the LICs that contains R3l5-50-
10 organic hazardous constituents, which are more difficult to destroy than the material
demonstrated in the surrogate trial burn.
The feed rate of chlorine to each LIC shall not exceed 6,425* pounds, over a twelve-hour
rolling average.
Non-hazardous waste simufant test materials may be fed to either the primary or secondary
combustion chambers to v'drify operating performance at the start of an agent or munition
campaign, following maintenance, or after an approved furnace system modification.
Only liquid, pumpable, waste with a maximum viscosity of 10 centipoise at 25o C shall be
incinerated in the LIC.
DESCRIPTION OF
HAZARDOUS WASTES
LIC 1 & LIC2
COMBUSTION CHAMBER
MAXIMT]MFEED
RATE lbs/hour
Chemical Agents (P999, D002, D003, D004, D006, D007, D008, D009, D010, D011,
D028, D034, and D039 )
Mustard G/HD/IIT)Primary 1,208*
Miscellaneous Agent Contaminated Liquid Wastes (P999, F999, D001, D002, D003,
D004, D006, D007, D008, D009, D010, D011, D018, D022,D028, D034, D039, D040,
D043, F002, and F005) as identified in Attachment 2 (Waste Analysis Plan), Section
2.2.t.15
GB Primary 833
VX Primary 5 80*
Mustard (H/IID/HT)Primary 1 ,208 *
Spent Decontamination Solutions (F999, D001, D002, D003, D004, D006, D007,
D008, D009, D010, D011, D018, D019, D022, D028, D034, D039, D040, D043) as
identified in Attachment 2 (Waste Analysis Plan), Section 2.2.1.4.
GB Primary/Secondary 1,790
VX Primary/Secondary 1,790*
Mustard @/HD/HT)Primary/Secondary 1,809*
v.B.1.f.
Module V - Page l0
V.8.1.g.
v.B.1.h.
v.8.1.i.
v.8.2.
V.B.2.a.
v.8.2.b.
V.B.2.c.
v.B.2.d.
V.B.2.e.
v.8.2.f.
V.8.2.s.
V.B.2.g.i.
V.B.2.g.t.a.
TOCDF
Long-Term Incineration
March 2009
The Permittee shall conduct sufficient analysis of all waste treated in the LICs to veriff
that the waste feed is within the physical and chemical composition limits specified, in
accordance with the waste analysis requirements in Attachment 2 (Waste Analysis Plan)
and Attachment 3 (Sampling, Analytical, and QA/QC Procedures).
Metals feed rates to each LIC shall not exceed the values specified in Table V.l located at
the end of this Module.
Mustard from 1) ton containers that are sampled in Area 10 with liquid sample analyical
results having mercury concentrations equal to one ppm or greater, or 2) 4.2-inch HD
Mortars shall not be processed in the LICs until a permit modification is approved by the
Executive Secretary for operation of pollution abatsment system equipment designed to
control emissions of mercury from the LICs.
OPERATING CONDITIONS
All operating conditions shall be monitored in accordance with the Monitoring
Requirements in V.A.4. The Permittee shall monitor emissions of chemical agent from
each incinerator duct (LIC #1, LIC#2), and the common stack, as specified in Condition
V.A.4. The waste feed(s) to the corresponding incinerator(s) shall be automatically cut off
if any of the monitored operating conditions deviate from the values specified in Tables D-
5-2AandD-5-28 in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
Primary combustion chamber exhaust gas temperature shall be maintained at or above
2,544*" F, over a one-hour rolling average, but shall not reach or exceed 2,850*o F.
Secondary combustion chamber exhaust gas temperature shall be maintained at or above
1,822*" F, over a one-hour rolling average, but shall not reach or exceed 2,200*" F.
Carbon monoxide in the exhaust blower exit gas, shall be corrected to 7%o oxygen in
accordance with the formula specified in Condition Y.A.Z.e' and shall be maintained
below 100* ppm, dry volume, over a one-hour rolling average.
LIC exhaust gas flow rate or unit production rate (as measured by the V-Cone) shall not
exceed 8,400* standard cubic feet per minute, over a one-hour rolling average.
If the exterior shell temperature of the slag removal system reaches or exceeds 500*o F, all
waste feed to the LIC system shall be stopped. Shell integrity shall be verified, and
recorded in the operating record, before wastes are re-introduced into the fumace system.
Atomizing air pressure for the waste bumer nozzles, for both chemical agent and
decontamination solution shall be maintained at or above the following set points:
Primary Combustion Chamber, All Feed Rates (1-100%) - 60* psig.
The Permittee may disable the Automatic Waste Feed Cut-Off associated with Condition
V.B.2.g.i. when the waste burner nozzle forthe primary chamber is removed and agent
feed to the LIC is isolated.
Secondary Combustion Chamber, All Feed Rates (l-100%) - 60* psig.V.B.2.g.ii.
ModuleV-Pagell
Long-Term rr.,H;il:
March 2009
V.B.2.h. Reserved.
V.8.2.i. The Permittee shall control fugitive emissions from the combustion zone of the LIC by the
sealed system design of the LIC combustion chambers.
V.B.2j. Quench tower exhaust gas temperature shall not exceed 225*" F.
V,8.2.k. Exhaust gas pressure drop across the venturi scrubber shall be maintained above 32*
inches of water column over a one-hour rolling average.
V.B.2.1. Brine feed rate to the venturi scrubber shall be maintained above 105* gallons per minute
over a one-hour rolling average and delivery pressure shall be maintained above 40* psig.
V.B.2.m. Clean liquor feed rate to the scrubber tower shall be maintained above 425* gallons per
minute, over a one-hour rolling average and delivery pressure shall be maintained above
35* psig.
V.B.2.n. Quench Brine shall be maintained above a pH of 7.5*over a one-hour rolling average.
V.8.2.o. Scrubber liquid effluent shall not reach or exceed 1.15TBD* specific gravity units, over a
twelve hour rolling average.
V.8.2.p. Oxygen concentration in the.exhaust blower exit gas, shall be maintained above 3o/o*,bttt
shall not reach or exceed 15olo* oxygen on a dry volume basis.
V.B.2.q. The maximum agent feed rate to the LIC primary combustion chamber shall not exceed
1,208* pounds over a one-hour rolling average.
V.B.2.r. The maximum spent decontamination solution feed rate to the LIC secondary combustion
chamber shall not reach or exceed 1,809* pounds per a one-hour rolling average.
V.B.2.s. During cold start-ups of LICI orLlC2, the primary chamber waste feed nozzle shall not
be installed and the waste feed control valve shall not be opened until the secondary
combustion chamber is at 1,550*o F or higher as measured by thermocouples 13-TIC-103
(for LICI) or 13-TIC-781 (for LICZ}
V.B.2.t. The Permittee may only direct exhaust gas to the PAS Carbon Filtration System (PFS)
when hazardous waste is not being treated in the primary and secondary chambers.
V.B.3. WASTE FEED CUT-OFF REOUIREMENTS
V.B.3.a. The Permittee shall maintain and operate the systems specified in Attachment 19
(Instrumentation and Waste Feed Cut-off Tables) to automatically cut off the hazardous
waste feed to the LIC when the monitored operating conditions deviate from the set-points
specified.
V.B.3.b. In the event of a malfunction of the LIC automatic waste feed cut-off systems listed in
Attachment 19 (Instrumentation and Waste Feed Cut-off Tables) the Permittee shall
immediately, manually, cut off the waste feed to the LIC and correct the malfunction prior
ModuleV-Page12
V.8.3.c.
v.c.
v.c.1.
V.C.1.a.
V.C.1 .a.i.
TOCDF
Long-Term Incineration
March 2009
to resuming waste feed. The Permittee shall record in the Operating Record any waste
feed cut-off system malfunctions, the time of the malfi,rnction, the time of resuming waste
feed, the apparent cause of the malfunctions, and specific steps taken to repair the
malfunction and avoid similar future malfunctions.
The Permittee shall perform a waste feed cut-off function test no less than once every 14
days. No waste shall be fed to the LIC during the function test. If the LIC is not
operational (i.e., shut down), the Permittee shall perform the function test when the LIC
becomes operational, prior to waste feed. Idling shall not be considered as "shut down."
A copy of each function test shall be placed in the Operating Record.
METAL PARTS FI]RNACE (MPF)
All numeric values included in any of the Conditions under V.C., which are marked with
an asterisk (*) (except numeric values for agent GB, which have previously been
approved) are tentative and may be modified by permit modification after the results of
each trial bum have been evaluated by the Executive Secretary in accordance with R315-
8-15.5(c). The Executive Secretary reserves the right to replace the values which are
marked with an asterisk as necessary to be protective of human health and the
erlironment.
LIMITATION ON WASTE FEED
During processing, the MPF dischaqge airlock (DAL) shall be monitored for the agents
being processed in the MPF. During munitions processing, the MPF DAL shall monitor
for agent either by high temperature or low temperature monitoring protocols according to
Y .C.2.r. and Attachment 22. For secondary wastes, the MPF DAL shall be monitored
using low temperature monitoring ac.cording to V.B.4 and Attachment22. Except during
the short-term periods specified in Module VI for shakedown, trial bum, and post-trial
bum, the Permittee shall incinerate only the following hazardous wastes in the MPF, in
compliance with the operating requirements specified in Condition V.C.2.
Chemical Asent Munitions
Waste Codes: P999,F999, D003, D004, D005, D006, D007, D008, D009,D010, DOl l, D028, D034, D039
Maximum Charge Weight (lbs)2: 630*
Mustard (H,HD,HT) Feed Rate (lbs/hr*)3: 3711*
Item Type Zone la
(min)
Zone 2a
(min)
Zone 3a
(min)
DAL4
(min)
Items/tray4
(#l
Cycle Time
(min)3
Mustard B aseline/B aseline P arent/Child
Ton Containers
(Mustard lbs. per Tray)
L2 is <220*
85*l0x I 00x I 00*I 00*
Mustard Baseline/Baseline Parent/Child
Ton Containers
Mustard lbs. per tray
L4 is 5490*
f'.
105*10*120*120*I 120*
Mustard Baseline/Baseline Parenychild
Ton Containers
t"'?f,l':;i;lrraY)123*l5*I 43*143*I l43x
Module V - Page 13
Mustard I 55mm Projectiles
Full Tray (48 Proios)s 66*20*86*86*48 g6*
4.2" HT Mortarso
(Mustard lbs. Per Tray < 83.5*)TBD*TBD*TBD*TBD*48-96 TBD*
NOTES:I Based on the maximum zone time plus a nominal 5 minute tray transfer time.2 Maximum mustard ([VHD/HT) chmge weight successfully demonstrated during MPF HD Ton Container Agent Trial Burn
for condition using ton containers.3 Cycle time is set by the longest zone time for all zones and does not include tray transfer time.a Values based on Discharge Air Lock (DAL) Low Temperature Monitoring (LTM) results obtained during agent trial bum,
or as determined through compliance with Condition V.C.l.a.i.c. The zone times presented represent the zone timer set
point and do not include the zone transfer time, which is a constant attribute of the MPF feed syste,m.5 The maximum zone time does not include the 5 minute zone hansfer time (86 + 5 =91 minutes), which is a constant of the
MPF system
6. The 4.2" HT mortars processing times and operating conditions will be developed during each ramp-up phase. The final
operating conditions will be incorporated into this table once the Executive Secretary has approved the final conditions.
Low Temperature Monitoring is required for all mortar trays during the ramp-up.
TOCDF
Long-Terrn Incineration
March 2009
V.C.l.a.i.a. Mustard ton containers that are sampled in Area 10 with liquid sample analytical results
having mercury concentrations of less than one part per million (ppm(mglkg)) may be
processed in the MPF before installation of Pollution Abatement System equipment
designed to control emissions of mercury from the MPF.
V.C.1.a.i.b. Mustard ton containers that are sampled in Area l0 with liquid sample ana$ical results
having mercury concentrations equal to one ppm or gleater and 4.2-inch HD Mortars shall
not be processed in the MPF until a permit modification is approved by the Executive
Secretary for operation of pollution abatement system equipment designed to control
emissions of mercury from the MPF.
V.C.1.a.i.c. Reserved.
V.C.1.a.i.c.i. Reserved
V.C.1.a.i.c.ii. Reserved
V.C.1.a.i.c.iii. Reserved.
V.C.1.a.i.d. The 4.2" HT mortars Sampling/Analysis Plan and associated Ramp-up Phases must be
approved by the Executive Secretary prior to implementation.
V.C.1.a.i.d.i Each4.2" HT Mortars shall be drained to fifteen percent (0.87 lbs) or less before feeding
to the MPF.
V.C.1.a.i.d.2 The Permittee shall low temperature monitor all4.2" HT mortars during ramp-up (Phase I,
tr, m).
V.C.l.a.i.d.3 Tlte 4.2" HT burster wells will be processed with each tray of mortars or on a separate
tray. A function test is required for more than 96 burster wells on a tray for those burster
wells that are not fed with the mortars.
V.C.l.a.ii. AeentContaminatedSecondaryWaste
ModuleV-Page14
TOCDF
Long-Term Incineration
March 2009
Agent Contaminated Secondary Waste may be treated in the MPF. The MPF DAL shall
be monitored for agents contaminating the waste by the low temperature monitoring
protocol (600'F for GBA/X and 700'F for Mustard). The maximum charge weight of
secondary waste for each category is specified Table V.C.l below, based on a minimum
75-minute fumace charge interval:
Category Feed Rates
Table V.C.l
Secondary
Waste
Category
Waste Stream
Subcategory/
Component
Maximum Tray
Limit
(per charge)
Pounds per 12 hours, on
12 hour rolling average
basis
Net Weight of
WIC/Container3
Contents
Net Weight of WlC/Container3
Contents
2410 pounds
maximum
Combustible Bulk
Solid Waste
Ash Content 70* lbs.809* lbs.
Halogen Content 97*lbs.1,500* lbs.
BTU Content 3.5* Million BTUs
Agent-Contaminated Spill
Absorbents 45* lbs
DPE Suits, Polyethylene Bags, and
carbon filter cartridges (<25
cartridges)
Metal bearing secondary waste
shall not be within the MPF
primary combustion chamber
when halogenated wastes are
present, except for metals that are
integrated (embedded)6 into the
waste's design and protective
mask carbon canisters.
354*NA
Non-Embedded Metalsa
Group I
(High-Volatile Metals)
Mercury (D009)
0.03 l7*
Non-Embedded Metalsa
Group 2
Semi-volatile Metals
Lead (D008
Cadmium (D006)
Antimony
Thallium
Tin
Zinc
7 6.54*
Module V - Page l5
TOCDF
Long-Terrn Incineration
March 2009
Category Feed Rates
Table V.C.l
Secondary
Waste
Category
Waste Stream
Subcategory/
Component
Maximum Tray
Limit
(per charge)
Pounds per 12 hours, on
12 hour rolling average
basis
Non-Embedded Metalsa
Group 3
Low Volatile Metals
Arsenic (D004)
Chromium (D007)
Barium (D005)
Boron
Cobalt
Copper
Selenium (D010)
Silver (D0l I )
Beryllium
Aluminum
Manganese
Nickel
Vanadium
50.7 4*
Non-Combustible
Bulk Solid Waste
Aluminum 1000* lbs.
Glass/Ceramics 241 0* lbs.
Miscellaneous Metal 241 0* lbs.
Carbon Filter Cartridges-
Aluminum Housing onlv 25* each
Building I Concrete
Materials ffi
To Be Determ ned'*
To Be Determ ned'*
Sludge
ACS, AQS, SDS Agent-
Contaminated Sludges and
Aqueous Wastes
45* lbs.
Area l0 Ton
Container Sampling
Waste 5'7
Polypropylene /Spill Pads
Nitrile Gloves
Steel Plugs
Iron Clad Gloves
Polyethylene Bags
Polyethylene Syringes
Polyethylene Bottles
Flex Hoses
Metal Hand Tools
lbs
LSS Hosess'7 Rubber/Neoprene Hoses with
metal quick-connect 64 lbs
High Density
Polyethylene
GDPE)s'7
HDPE Drum Material 32 lbs
Airlock TrashT
Butyl Gloves
DPE Booties #1 (Silicone Rubber)
DPE Booties #2 (PYC/CPE)
Plastic Bags (Polyethylene)
Duct Tape Gvc/Polyethvlene)
90 lbs
Table Notes
Note 1: Unless successive tmys are tracked to ensu'e the l2-hour limit is not exceeded, each WIC shall not
exceed any one of the indicated limits. The indicated lirnits rnay be exceeded on a WIC as long as the
l2-hour are complied with by limiting feeds on subsequent trays. If each WIC is limited to the
indicated limits, the l2-hour limit will not be exceeded.
Note 2: Successful treatment ofthese materials rnust be approved by the Executive Secretary
Module V - Page 16
TOCDF
Long-Terrn Incineration
March 2009
Category Feed Rates
Table V.C.l
Secondary
Waste
Category
Waste Stream
Subcategory/
Component
Maximum Tray
Limit
(per charge)
Pounds per 12 hours, on
12 hour rolling average
basis
Note 3: Waste Incineration Containers (WICs) are defined as the assanbly of metal components that is used
to contain, feed, and convey individual charges of secondary wastes and their resulting treatment
residues through the MPF (i.e., Cut-away Ton Containers (CTCs), bum trays, rectangular open
topped baskets equipped with catch pan).
Note 4: Non-ernbedded metals are metals that may vaporize or become entrained in the combustion gas air
during theunal treatment.
Note 5: Based on a 75 minute charge interval.
Note 6: Metals are fixed/embedded/ inefi/integrated/entrained in the waste and will not vaporize at fumace
temperafures.
Note 7: Based on Zone I (75 minutes), Zrl,rc 2 (50 minutes) and Zone 3 (25 minutes).
V.C.1.a.iii. Secondary wastes may be treated in the MPF only if the following conditions are met:
V.C.1.a.iii.1 The waste is evaluated and assigned to one of the secondary waste categories listed in the
first column of the table; net weight of container, combustible bulk solid waste,
noncombustible bulk solid wastes or sludge. Wastes associated with Condition
V.C.l.a.ii., may not be fed until the Permittee has complied with the function testing
requirements specifi ed in Condition VLC. 3.a. i.b.
V.C.1.a.iii.2 The waste is arranged upon the burn tray in a configuration approved by the Executive
Secretary in accordance with Condition VI.C.3.a.i.b.
V.C. 1 .a.iii.3 A description of the waste and the categoization basis are documented in the operating
record verifying feed rates are not exceeded.
V.C.l.a.iii.4 The containment of the container (WIC, CTC or burn tray) may not be exceeded.
V.C.1.a.iv. Secondary wastes generated during different agent campaigns may be fed separately or on
the same tray provided the following conditions are met:
V.C.1.a.iv.1 The MPF discharge airlock is equipped to monitor all agents contaminating the wastes fed
to the MPF.
V.C.1.a.iv.2 The MPF exhaust duct is equipped to monitor the agents contaminating the wastes fed to
the MPF.
V.C.l.a.iv.3 The Common Stack is equipped to monitor the agents contaminating the wastes fed to the
MPF.
V.C.l.a.iv.4 An MPF Destruction and Removal Efficiency has been determined, or an alternate means
has been approved by the Executive Secretary for the agent contaminating the secondary
wastes to be treated in the MPF
V.C.1.a.v. All non-munition wastes that envelop an interior space (e.g. gauges, cans, escape air tanks,
overpacks, glassware, etc.) must be opened or punctured before being placed in the MPF.
ModuleV-PagelT
V.C.1 .a.vi..
V.C.1 .a.vi.1
V.C.1 .a.vii
V.C.1.a.viii
v.c.1 .b.
V.C.l.c.
v.c.1.d.
v.c.1.d.i
V.C.1.e.
v.c.1.f.
TOCDF
Long-Term Incineration
March 2009
The wastes identified in V.C.l.a.ii. shall not be inside the MPF at the same time the
wastes identified in V.C.l.a.i. are inside the MPF.
Wastes identified in V.C. I .a.i and V.C.1 .a.ii may only be in the furnace at the same time if
a Discharge Airlock Alarm caused one of the wastes to be retumed to the fumace for
additional processing. Operating parameter limits specified in V.C.2 which are specific to
waste identified in V.C. 1 .a.i and V.C.1 .a.ii do not apply for the waste retumed to the
furnace provided the MPF zone times and terrrperatures in Zone 3, which ensures
treatment of the waste, are equal to or greater than the zone temperatures established for
the waste returned to the furnace and in compliance with Section 22.32 of Attachment22.
During shakedown, ramp-up and function testing, this condition will not apply but will
follow individual test plans.
Waste identified in Table 2-5 of Attachment 2, Waste Analysis Plan, maybe processed
for agent that has been successfully demonstrated per condition VI.C.3.a.i.c.1. at the
specified operating conditions for munitions/ton containers without further function
testing.
The Permittee shall maintain records that differentiate and document between the
Shakedown hours attributed to the processing of waste to be demonstrated during the trial
bum/demonstration test and hours attributed to the processing of secondary waste per
Condition V.C. 1.a.viii.
The Permittee shall not incinerate any chemical agent, or any waste containing the
chemical agent, for which treatment has not been successfully demonstrated through a trial
burn in accordance with Module VI or by other means approved by the Executive
Secretary.
The Permittee shall not incinerate anyhazardous waste in the MPF that contains organic
hazardous constituents as described in R3t5-50-10, that are more difficult to destroy than
the material demonstrated in the surrogate trial burn.
While processing secondary waste, the feed rate of total halogens to the MPF shall not
exceed 1,500* total pounds over a twelve hour rolling average ard97* total pounds per
each fumace charge.
While processing mustard munitions or ton containers, the feed rate of total halogens to
the MPF shall not exceed 1500* total pounds, over a twelve hour rolling average and206
total pounds per each fumace charge.
The Permittee shall drain liquid from secondary waste. The separated liquid will be
categorized and treated as an agent-contaminated sludge per Table V.C.l.
The Permittee shall conduct sufficient analysis of the waste treated in the MPF to veriff
that the waste feed is within the physical and chemical composition limits specified, in
accordance with the waste requirements in Attachments 2 (Waste Analysis Plan) and 3
(Sampling, Analyical, and QA/QC Procedures).
ModuleV-PagelS
Long-Term rr.,;T*:il:
March 2009
V.C.1.g. While processing secondary waste, the feed rate of ash to the MPF shall not exceed 809*
total pounds over a twelve-hour rolling average and 70* total pounds per each fumace
charge.
V.C.1.g.i While processing mustard munitions or ton containers, the feed rate of ash to the MPF
shall not exceed 809* total pounds over a twelve hour rolling average and 147* total
pounds per each fumace charge.
V.C.l.h. The non-embedded metals feed rates to the MPF shall not exceed the values specified in
Table V.2.a at the end of this Module.
V,C.2. OPERATING CONDITIONS
Y.C.2.a. All operating conditions shall be monitored in accordance with the Monitoring
Requirements in V.A.4. The Permittee shall monitor emissions of chemical agent from
the MPF duct and the common stack as specified in Condition V.A.4.a. The waste feed(s)
to the incinerator shall be automatically cut off if any of the monitored emission levels
exceed the values specified in Table D-6-2 in Attachment 19 (Instrumentation and Waste
Feed Cut-off Tables).
V.C.2.b. Only one loaded tray containing the waste materials shall be fed into the MPF at any given
time. The minimum time intervals between each tray feed are specified in Conditions
V.C.1.a.i. and V.C.1.a.ii.
Y.C.Z.c. The hourly feed rate of the residual chemical agent contained in the MPF feed, shall not
exceed the limits specified in Condition V.C.1.a.i.
V.C.2.d. The number of munition units fed to the MPF per batch feed shall not exceed the limit
specified in Condition V.C.1.a.i.
Y.C.2.e. While processing mustard munitions and ton containers, the temperature of the primary
chambershallbemaintainedabove 1,171"F* inZore 1, 1,318"F*inZone2andl,32l"F*
inZone 3, and each zone shall not exceed 1,800*o F.
Y.C.2.e.i While processing secondary waste the temperature of the primary chamber shall be
maintained above 1,415oF* forZone 1, 1,439"F* forZone2 and1438'F* for Zone3 arrd
each zone temperature shall not exceed 1800"F.
V.C.z.f. While processing mustard munitions and ton containers, the MPF afterburner temperature
shall be maintained above 1,976*" F over a one-hoqr rolling average and shall not exceed
2,175*o F.
Y.C.z.t.i While processing secondary waste the MPF afterburner temperature shall be maintained at
. " or above 2000oF* over a one-hour rolling average and shall not exceed 2,175oF.
Y.C.2.g. Carbon monoxide concentration in the exhaust blower exit gas and correctedto 7 yo
oxygen in accordance with the formula specified in Condition V.A.2.e., shall be
maintained below 100 ppm, dry volume, over a one-hour rolling average.
Module V - Page l9
Long-Term ,r"rffi;3:
March 2009
V.C.2.h. While processing mustard munitions and ton containers, the MPF exhaust gas flow rate, or
unit production rate (as measured by the V-Cone), shall not exceed 8,960* standard cubic
feet per minute, over an one-hour rolling average.
V.c.2.h.i While processing secondary waste the MPF exhaust gas flow rate, or unit production rate
(as measured by the V-Cone), shall not exceed 7,710* standard cubic feet per minute, over
a one-hour rolling average.
Y.C.2.i. Oxygen concentration in the exhaust blower exit gas shall be maintained above 3* o/o
oxygen but shall not reach or exceed 15* yo oxygen on a dry volume basis.
Y.C.zj. The Permittee shall control fugitive emissions from the combustion zone of the MPF by
maintaining the pressure in the primary chamber below -0.10 in WC.
V.C.2.k. Quench tower exhaust gas temperature shall not exceed 225*" F.
V.C.2.1. Exhaust gas pressure drop across the venturi scrubber shall be maintained above 30*
inches of water column over a one-hour rolling average.
Y.C.2.m. Scrubber liquid feed rate to the venturi scrubber shall be maintained at or above 105*
gallons per minute, over a one-hour rolling average and above a minimum pressure of 70*
psig.
Y.C.2.n. Clean liquor liquid feed rate to the scrubber tower shall be maintained above 420* gallons
per minute over a one-hour rolling average.
Y.C.2.o. Clean liquor liquid delivery pressure to the scrubber tower shall be maintained above 35*
pounds per square inch gauge, over a one hour rolling average.
Y.C.2.p. Quench Brine pH shall be maintained above a pH of 7.6*, over a one-hour rolling average.
Y .C.Z.q. Scrubber liquid effluent shall not reach or exceed 1.15* specific gravity units, over a
twelve hour rolling average.
Y.C.Z.r. The MPF Discharge Airlock shall be cooled, (low temperature monitored) to less than
600" F when processing GB and VX wastes and 700'F when processing mustard wastes,
munitions and bulk containers. The items will be monitored via low-temperature
monitoring in accordance with Attachment 22 monitoing procedures if any of the
following upset alarms occur as specified in the table below for the munitions/bulk
containers in the furnace at the time of the upset. In accordance with V.C.1.a.ii.a, all
secondary waste trays will be "low-temperature monitored" regardless if the following
upset alarms occur.
Module V - Page20
TOCDF
Long-Terrn Incineration
March 2009
Tag Number Limit Descriptions
14-TIT-152
> 1,558r'oF
(Baseline TC)
TBD
(4.2 HT Mortars)
Furnace Temperature (Zone l)
14-TIT-141
> 1 ,464*oF
(Baseline TC)
TBD
(4.2 HT Mortars)
Furnace Temperature (Zone 2)
14-TIT-153
> 1 ,561 *oF
(Baseline TC)
TBD
(4.2 HT Mortars)
Furnace Temperature (Zone 3)
14-TIT-065 or
14-TrT-069
<1800'F
MPF Afterburner Temperature Low-Low
14-TIT-065 or
14-Trr-069
> 2175'F
MPF Aft erburner Temperature High-High
14-PDrT-786
> 1 .2 tn. w.c.Afterburner Exhaust Gas Velocity
Pressure High
14-AIT-384m
minute average.
Correct to 7o/o-O2,
dry volume
Blower Exhaust CO Concentration.
Average of 4 consecutive data points
excluding points of calibration.
Approximately 1- minute average.
24-AIT-669m
> 1000 ppm 1
minute average.
Correct to 7o/o-Oz,
dry volume
Blower Exhaust CO Concentration.
Average of 4 consecutive data points
excluding points of calibration. 1- minute
average.
14-ArT-082 < 3o/o Oz Blower Exhaust 02
14-ArT-082 Blower Exhaust 02
60 second delay
24-ArT-670 < 3o/o Oz Blower Exhaust Oz
24-AIT-670 Blower Exhaust 02
60 second delay
PAS 7O3AH/BH
Z 0.2 SEL for
Mustard.
Malfunctions not
included.
PAS Blower Exhaust Agent Detected
PAS 707 AH/BH/CH
> 0.2 sEL.
Malfunctions not
included.
Common Stack Exhaust Agent Detected
Module V - Page2l
Tag Number Limit Descriptions
14-TIT-010
> 2,395*oF
(Mustard Baseline
Ton Containers)
TBD
(4.2 HT Mortars)
Primary Chamber Exhaust Temperature.
V.C.2.s.v.
v.c.2.t.
v.c.3.
V.C .3.a.
v.c.3.b.
V.C.3.c.
TOCDF
Long-Terrn Incineration
March 2009
The following items shall be documented in the daily operating record:
The monitoring protocol, either high temperature or low temperature
The time the tray entered the discharge airlock
The time the switch is activated to monitor the DAL instead of filtered air
The agent monitoring readings in the discharge airlock for all agent types being
processed at the time of occurrence
The time the tray exited the discharge airlock into the cool-down area
The Permittee may only direct exhaust gas to the PFS when hazardous waste is not being
treated in the primary combustion chamber.
WASTE FEED CUT-OFF REQUIREMENTS
The Permittee shall construct and maintain the systems, specified in Attachment 19
(Instrumentation and Waste Feed Cut-off Tables) to automatically cut off the hazardous
waste feed to the MPF when the monitored operating conditions derriate from the set-point
specified.
In the event of a malfunction of the MPF automatic waste feed cut-off systems listed in
Attachment 19 (Instrumentation and Waste Feed Cut-off Tables) the Permittee shall
immediately, manually, cut off the waste feed to the MPF and correct the malfunction
prior to resuming waste feed. The Permittee shall record in the Operating Record any
waste feed cut-off system malfunctions, the time of the malfunction, the time of resuming
waste feed, the apparent cause of the malfunctions, and specific steps taken to repair the
malfunction and avoid similar future malfunctions.
The Permittee shall perform a waste feed cut-off function test no less than once every 14
days. No waste shall be fed to the MPF during the function test. If the MPF is not
operational (i.e., shut down), the Permittee shall perform the function test when the MPF
becomes operational, prior to waste feed. Idling shall not be considered as "shut down."
A copy of each function test shall be placed in the Operating Record.
DEACTIVATION FT]RNACE SYSTEM DFS)V.D.
Module V - Page22
Long-Term r""rffi;3:
March 2009
All numeric values included in any of the Conditions under V.D. which are marked with
an asterisk (*) (except numeric values for agent GB, which have previously been
approved) are tentative and may be modified after the results of each trial burn have been
evaluated by the Executive Secretary, in accordance with R315-8-15.5(c). The Executive
Secretary reserves the right to replace the values, which are marked with an asterisk as
necessary to be protective of human health and the environment.
V.D.l. LIMITATION ON WASTE FEED
V.D.l.a. Except during the short-term periods specified in Module VI for shakedown, trial burn,
and post-trial burn, the Permittee shall incinerate only the following hazardous wastes in
the DFS, in compliance with the operating requirements specified in Condition Y.D.2.;
Waste Codes: P999, D002
Agent Feed Rate (lbs/hr)l
D003, D004, D005, D006, D007, D008, D009, D010
Not Applicable for Mustard (HiHD/HT)
Propellant/Explosive Pyrotechnic (PEP) Feed Rate (lbs/hr)z: 479
Explosive Contaminated ECR Maintenance Residue Feed Rate (lbs/drop)3: 3.6
Item Type PEP
(lbs/item)
Maximum ltem
Processing Rate
(items/hr)
Equivalent PEP
Feed Rate
flbs/hr)
4.2" Mortar bursters and fusesa 0. 14 274 3 8.4
155-mm Mustard Projectiles bursters and
supplemental chargess 0.414 276 I 15
NOTES:rAn agent feed rate to the DFS is not applicable during the Mustard Campaign since mustard
is not drained {iom mustard containing munitions in the ECRs (i.e., drained munition casings
are not fed to the DFS during Mustard Campaign). P999 waste code is retained to account
for incidental mustard contamination that may be on bursters removed from leaking
munitions.
2 PEP f'eed rate demonstrated during DFS VX Agent Trial Bum.
3 ECR Maintenance Residues allowed to be processed are identified in Attachment 2,
Table2-2a of this permit. Whm processing explosive-contaminated ECR Maintenance Residues an
intemal kiln spacing of one flight between successive drops.
4 4.2'HD and HT mortars contain the same type and amount of explosives. If incidental mortar propellant
that was not removed during reconfiguration is present, the Executive Secretary will be notified. The
propellant will be fed separately.
s Types 104 and 110 l55mrn projectiles contain the same type and amount of explosives.
V.D.1.a.i. Energetics from only one munition type (i.e., 155mm projectile energetics or 4.2" mortar
energetics), or waste generated from one chemical agent campaign, shall be fed to the
DFS, at any given time.
V.D.1.a.ii.Explosive Contaminated ECR maintenance residues shall be fed at a rate not to exceed 3.6
pounds per two-minute period. Non-explosive contaminated ECR maintenance residues
generated during the mustard campaign shall be fed at a rate not to exceed 10 pounds per
two minute period and 100 pounds per hour.
The Permittee shall not incinerate any chemical agent, or any waste containing the
chemical agent, for which treatmert has not been successfully demonstrated through a trial
v.D.1.b.
Module V - Pagez3
V.D.1 .c.
v.D.1.d.
V.D.l.e.
v.D.1 .f.
Y.D.2.
V.D.2.a.
v.D.2.b.
V.D.2.c.
v.D.2.d.
V.D.2.e.
v.D.2.f.
Y.D.2.g.
v.D.2.h.
V.D,2,i,
TOCDF
Long-Term Incineration
March 2009
burn in accordance with Module VI or by other means approved by the Executive
Secretary.
The Permittee shall not incinerate arryhazardous waste in the DFS that contains organic
hazardous constituents as described in R3l5-50-10, that are more difficult to destroy than
the material demonstrated in the surrogate trial bum.
The feed rate of chlorine to the DFS shall not exceed 6.8* pounds per hour over twelve
hour rolling average.
The Permittee shall conduct sufficient analysis of the waste treated in the DFS to verifu
that the waste feed is within the physical and chemical composition limits specified, in
accordance with the waste analysis requirements in Attachments 2 (Waste Analysis Plan)
and 3 (Sampling, Analytical, and QA/QC Procedures).
The non-embedded metals feed rates to the DFS shall not exceed the values specified in
Table V.3 at the end of this Module.
OPERATING CONDITIONS
All operating conditions shall be monitored in accordance with the Monitoring
Requirements in V.A.4. The Permittee shall monitor emissions for chemical agent from
the DFS and the common stack, as specified in Condition V.A.4.a. The waste feed(s) to
the incinerator shall be automatically cut off if any of the monitored emission levels
exceed the values specified in Table D-7-2 in Attachment 19 (Instrumentation and Waste
Feed Cut-off Tables).
The hourly feed rate and maximum feed weight of the chemical agent contained in the
DFS feed, demonstrated during the agent trial burn, shall not exceed the limits provided in
Condition V.D.1.a. An agent feed rate to the DFS is not applicable during the Mustard
Campaign since Mustard is not drained from Mustard munitions in the ECRs. The P999
waste code is retained to account for incidental Mustard contamination that may be on
busters removed from leaking munitions.
The number of munition units fed to the DFS in one hour shall not exceed the limit
specified in Condition V.D.1.a.
The temperature of the unquenched DFS rotary kiln exhaust gas shall be maintained above
954*" F, over a one-hour rolling average.
The temperature of the quenched DFS rotary kiln exhaust gas shall not exceed 1,650+o F.
Reserved.
The tempepture of the heated discharge conveyor shall be maintained above 1,000*o F.
The rate of movement of the heated discharge conveyor shall be controlled to provide a
minimum solid retention time of 15* minutes inside the heated enclosure.
The rotational speed of the retort shall be maintained within the following parameters:
Module V - Page24
TOCDF
Long-Terrn Incineration
March 2009
O Y.D.2.i.i. The speed shall not reach or exceed two* revolutions per minute (rpm);
V.D.2.i.ii. Except when in oscillation mode, the speed shall not reach or drop below 0.33 rpm;
V.D.2.i.iii. Hazardous waste shall not be fed while the retort is in oscillation mode unless as provided
in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
V.D.2j. The DFS afterburner temperature shall be maintained above 2150*o F, over a one-hour
rolling average but shall not reach or exceed 2,350*o F.
V.D.2.k. Carbon monoxide concentration in the afterbumer exhaust gas, correctedtoTo oxygen in
accordance with the formula specified in Condition Y.A.2.e., shall not reach or exceed
100 ppm dry volume over a one-hour rolling average.
V.D.2.1. The DFS exhaust gas flow rate, or unit production rate (as measured by the V-Cone), shall
not exceed 13,210* standard cubic feet per minute, over a one-hour rolling average.
V.D.2.m. Oxygen concentration in the exhaust blower exit gas shall be maintained above 3ohbut
shall not reach or exceed l5%o oxygen on a dry volume basis.
V.D.2.n. The Permittee shall control fugitive emissions from the combustion zone of the DFS by
maintaining the pressure in the kiln below the pressure of the DFS furnace room.
V.D.2.o. Quench tower exhaust gas temperature shall not exceed 200*o F.
V.D.2.p. Exhaust gas pressure drop across the Venturi scrubber shall be maintained at or above 30*
inches of water column, over a one-hour rolling average.
V.D.2.q. Quench brine feed rate to the venturi scrubber shall be above 310* gallons per minute,
over a one-hour rolling average and above a minimum pressure of 75* psig.
Y.D.2.r. Clean liquor feed rate to the scrubber tower shall be maintained above 800* gallons per
minute, over a one-hour rolling average.
V.D.2.s. Clean liquor pressure to the scrubber tower shall be maintained above 35* pounds per
square inch gauge, over a one-hour rolling average.
y.D.2.t. The pH of the quench brine shall be maintained above 8.7*over a one-hour rolling
average.
V.D.2.t.1 The Permittee may revise the limit specified in Condition Y.D.2.t upon submission of the
DFS performance test results that supports the revised limit; provided the performance test
results also demonstrate that no change is required for the chlorine feed rate limit specified
in V.D.1.d, and Operating Parameter Limits specified in Conditions V.D.2.l and V.D.2.p
through V.D.2.s have not changed.
V.D.2.u. Scrubber liquid effluent specific gravity shall not reach or exceed l.l0* specific gravity
units, over a twelve-hour rolling average.
Module V - Page25
V.D.2.v.
V.D.2.w.
v.D.3.
V.D.3.a.
v.D.3.b.
V.D.3.c.
TOCDF
Long-Term Incineration
March 2009
The DFS cyclone discharge shall be enclosed within a building, which shall be ventilated
to the MDB ventilation system when the DFS is operational or when waste is present
withrn the cyclone discharge building. The DFS cyclone discharge building shall be
operated in accordance with the procedures specified in Attachment 8 @reparedness and
Prevention Plan).
The Permittee may demonstrate that the agent concentration of a sample of the residue
generated from the operation of the DFS Cyclone is below 20 ppb for GB, VX or below
200 ppb for Mustard GI/IIDiHT), through analytical testing according to the procedures in
Attachment 2 (Waste Analysis Plan). If these analytical results indicate that the agent
concentration of the cyclone residue is below these limits, then the residue may be
transported off site to an appropriate hazardous waste management facility for keatment,
disposal, orboth. If such a demonstration is not made, then the DFS cyclone residue shall
be placed into permitted storage.
WASTE FEED CUT.OFF REOT]IREMENTS
The Permittee shall construct and maintain the systems specified in Attachment 19
(Instrumentation and Waste Feed Cut-off Tables) to automatically cut off the hazardous
waste feed to the DFS when the monitored operating conditions deviate from the set point.
In case of a malfunction of the DFS automatic waste feed cut-off systems listed in
Attachment 19 (Instrumentation and Waste Feed Cut-off Tables), the Permittee shall
immediately manually cut off the waste feed to the DFS and correct the malfunction prior
to resuming waste feed. The Permittee shall record in the Operating Record any waste
feed cut-off system malfunctions, the time of the malfunction, the time of resuming waste
feed, the apparent cause of the malfunctions, and specific steps taken to repair the
malfunction and avoid similar future malfunctions.
The Permittee shall perform a waste feed cut-off function test no less than once every 14
days. No waste shall be fed to the DFS during the function test. If the DFS is not
operational (i.e., shut down), the Permittee shall perform the function test when the DFS
becomes operational, prior to waste feed. Idling shall not be considered as "shut down."
A copy of each function test shall be placed in the Operating Record.
o
V.E. AREA 10 LIOUD INCINERATOR (ATLIC)
All numeric values included in anv of the Conditions under V.E.. which are marked with
an asterisk (t) are tentative and maybe modified bypermit modification afterthe results
of each trial bum have been evaluated by the Executive Secretary in accordance with
R315-8-15.5(p). The Executive Secretary reserves the rieht to repl4ce the values. which
are marked with an asterisk as necessarv to be orotective of human health and the
environment.
V.E.l. LMITATION ON WASTE FEED
V.E.l.a. Exceot during the shortterm periods specified in Module VI for shakedown. trial burn.
and posttrial burn. the Permittee shall incinerate onllr the following hazardous wastes in
the ATLIC. in compliance with the ooeratine requirements specified in Condition V.E.2.
Module V - Page26
TOCDF
Long-Terrn Incinerati on
March 2009
DESCRIPTION OF
HAZARDOUS WASTES
ATLIC LIC COMBUSTION
CHAMBER
MA)(IMUMFEED
RATE lhs/hour
Chemical Aqents 0999. F999. D002. D003. D004. D007. D00E. D009. D019. D021.
and D027 )
GA Primary
L Primary 325* h'ilu
Spent Decontamination Solutions G999. D002. D004.D007. D008. D009. D019.
D021. an D027) as iderrtified in Attachment 2 (Waste Analysis Plan)
Decon Solution Secgndary 45e550*
S'{;lr"*-'u"tn
?%
0b"
,rr*'r.q { L'*-:
{.{*Y ,,/ 1 ..-. [ ,-, ,,.r'Jyt
fd';' fi-r iA" '*"
V.E.1.a.i. Only one chemical ae€nt. or waste containing one cherdcal asent. shall be fed to the
V.E.l.a.ii. The spent decontamination solution orthe miscellaneous aeqrt contaminated wastes may
be burned either in the primary combustion chamber or secondary combustion chamber
but not at the same time. If these wastes are bumed in the secondary combustion chamber.
then only age'nt may be fed to the orimary combustion chamber at the same time.
--
V.E.t.b. The Permittee shall not incinerate any cheurical aeent. or any waste containingthe
chemical agent. for which treatment has not been successfully dernonstrated throueh an
agent or surrogate trial bum in accordance with Module VI or by other means aooroved by
the Executive Secretary.
V.E.1.c. The Permittee shall not incinerate any hazardous waste in the ATLIC that cbntains R3l5-
50-10 organic hazardous constituents. which are more difficult to destroy than the material
demonstrated in the surrogate trial bum.
no6*V.E.l.d. The feed rate of chlorine to the ATLIC shall not exceed 2J04* pounds. over a twelve- /
hour rolling average.
r-'"iV.E.l.e.ulan
to veri nnance at th f an asent or
followins mainte,nance. or after an approved furnace systern modification.
V.E.l.f. Only liquid. oumpable. waste with a maximum viscosity of 2.26 centiooise at 20o C shall
be incinerated in the ATLIC.
V.E.1.g. The Permittee shall conduct sufficient analysis of all waste treated in the ATLIC to veri&
that the waste feed is within.the Bhysical and chernical comoosition limits soecified. in
accordance with the waste analysis requirements in Attachment 2 (Waste Analysis Plan)
and Attachment 3 (Sampling. Analytical. and OA/OC Procedures).
V.E.l.h. Metals feed rates to the ATLIC shall not exceed the values specified in Table V.4 located
at the end of this Module.
f i{
Module V - PageLl
TOCDF
Long-TerTn Incineration
March 2009
V.E.2. ATLIC OPERATING CONDITIONS
V.E.2.a. All operatine conditions shall be monitored in accordance with the Monitoring
Requirements in V.A.4. The Permittee shall monitor emissions of chemical agent from
ATLIC exhaust stack as sBecified in Condition V.A.4. The waste feed(s) to the ATLIC
shall be automatically cut offif any of the monitored operatine conditions deviate from the
values specified in Tables D-8-2 in Attachment 19 flnstrumentation and Waste Feed Cut-
offTpbles).
V.E.2.b. The maximum waste feed rate to the ATLIC primary combustion chamber shall not
V.E.2.c. The maximuin waste feed rate to the ATLIC secondary combustion chamber shall not
exceed TBD * pounds over a one-hour rolline avemge.
V.E.2.d. Primary combustion chanrbqr exhaust eas iernoerature shall be maintained at or above
TBD to F. over a one-hour rolling averaee.
V.E.2.e. Secondary combustion chamber exhaust eas ternp€rature shall be maintained at or ahove
IBD to F. over a one-hour rolline averaee.
V.E.2.e. Atomizine airpressur,e for the waste burner nozzles. for both chernical ag€,nt and
decontamination solution shall be maintained at or above the followine set points:
V.E.2.e.i. Primary Combustion Chamber. All Feed Rates (l-1007o) - TBD t psig.
V.E.2.e.ii. Secondary Combustion Chamber. All Feed Rates (1-100o/o) - TBD t psig.
V.E.2.h. The Permittee shall control fugrtive emissions from the combustion zone of the ATLIC by
the sealed system desiem of the ATLIC combustion chambers.
V.E.2.i. ATLIC exhaust eas flow rate orunit oroduction rate (as mBsured by,instrurn€xrt 919-FIT-
8932 conrcted by ambierrt pressure and temDerature) shpll qot exceed TBP * standard
cubic feet per minute. over a orle-hour rollins averaee.
V.E.2j. Scrubber liouid feed rate to each of the three scrubbertowers shall be maintained above
TBD * gallons per minute. over a one-hour rollins averaee and deliver.v oressure shall be
maintained above TBD * osig.
V.I.2.k. The pressure droo across each oack bed scrubber tower shall be maintained above TBD
, inches of water column over a one-hour rolline average
V.E.2.1. The averaee of the scrubber liquid pH as measured b], the three oH probes in the common
scrubber sump shall be maintained above a pH of TBD *over a one-hour rolling averaee.
V.E.2.m. Scrubber liquid effluent shall not reach or exceed TBD* sgecific grravityunits. over a
twelve hour rolling average.
Module V - Page29
TOCDF
Long-Terrn Incinerati on
March 2009
V.E.2.n. Ttie Venturi Scrubber liquidpH shall be maintained above a oH of TBD tover a one-hour
rolline av€rage.
V.E.2.o. Venturi Scrubber Sump liquid effluent shall not reach or exceed TBD* soecific eravity
units. over a twelve hour rollins averaee.
V.E.2.p. Exhaust eas pressure droo across the veNrturi scrubber shall be maintained above TBD t
inches of water column over a one-hour rolline average.
V.E.2.q. Scrubber solution feed rate to the venturi scrubber shall be maintained above TBD *
gallons per minute over a one-hour rolling average and delivery oressure shall be
maintained above TBD t psig.
V.E.2.r. The powdered activated carbon injection rate shall be maintaind above TBD pounds oer
,hour over an hour rolline av€raee.
V.E.2.s. The powdered activated carbon carrier fluid (compressed air) differential oressure shall be
maintained above TBD inches of water column over a one-hour rolline average.
V.E.2.t. The teuroerature of exhaust gas enterine the baghguse shall not.exceed TBD oF ov€r a
one-hour rolling averaee.
V.E.2.u. Oxyeen concentration in the exhaust blow€r exit gas. shall be maintained above 3%*
oxygen on a dry volume basis.
V.E.2.v. Carbon monoxide in the exhaust blower exit gas. shall be corrected to 7 % oxygen in
accordance with the formula specified in Condition V.A.2.e.. and shall be maintained
below 100* pom. dry volume. over a one-hour rolling average.
V.E.2.w. The differential pressure across the on-line fixed bed carbon filter shall be maintained
above TBD inches of water column over a one-hour rolline averaee.
V.E.3. WASTE FEED CUT-OFF REOUIREMENTS
V.E.3.a. The Permittee shall maintain and ooerate the systems specified in Attachment 19
(Instrumentation and Waste Feed Cut-offTables) to autornatically cut offthe hazardous
waste feed to the ATLIC wheir the monitored operating conditions dwiate from the set-
points specified.
V.E.3.b. ln the event of a malfunction of the ATLIC automatic waste feed cut-offsvstems listed in
Attachment 19 (lnstrumentation and Waste Feed Cut-offTables) the Permittee shall
immediately. manually. cut off the waste H to the ATLIC and correct the malfunction
prior to resuming waste feed. The Permittee shall record in the Ooeratins Record any
waste feed cut-offsystem malfunctions. the time of the malfunction. the time of resuming
waste feed. the apparent cause of the rnalfunctions. and specific steps taken to repair the
malfunction and avoid similar future malfunctions.
Module V - Pagezg
fourteen fl4
V.EF.
v.EE.1.
V.EF.2.
V.EF.3.
V.EF.4.
V.EF.5.
V.EF.6.
V.EF.7.
V.EF.8.
v.EE.9.
v.EF.10.
v.EF.l 1 .
TOCDF
Long-Terrn Incineration
March 2009
waste fi
No waste shall be fed to the ATLIC durin the test. If the
nal (i.e.. shut
I perform the function test when the ATLIC becomes tional. or orior to
waste feed. A cooy of each function test
shall be placed in the Operating Record.
COMMON STACK FOR LICs. MPF'. & DFS
The Permittee shall maintain ACAMS and DAAMS continuous exhaust gas monitoring
systems forchemical agent emissions on the common stack.
The exhaust gas monitoring systems specified in Condition V.EE.1., shall be calibrated,
inspected and operated in accordance with the applicable elements of Conditions V.A.3.,
V.A.4., and Attachments 3 (Sampling, Analytical, and QA/QC Procedures); 6 (Instrument
Calibration Plan and Incinerator Waste Feed Interlock Function Test); 20 (Continuous
Emission Monitoring Plan); and22 (Agent Monitoring Plan).
Reserved
Emissions from the common stack shall be monitored for chemical agent as specified in
Condition V.EE.2. The agent concentration shall not exceed the values specified in
Condition V.A.4.g.
The waste feeds to all incinerators and furnaces shall be automatically cut off when the
emission level in the common stack exceeds 0.2 SEL for any chemical agent.
ACAMS on the common stack shall be comprised of two primary monitors in staggered
mode of sampling for continuous monitoring for each agent. A back-up monitor shall be
stationed in the stack for contingency purposes, i.e., primary monitor malfunctions or
calibration.
Waste feed to all incinerators and furnaces shall be cut off when the ACAMS are not
staggered.
DAAMS Tubes on the common stack shall be analyzed at a frequency of one tube per four
hours of sampling with a corresponding QP sample. A method of DAAMS tube trackino
is discussed in Section 22.17.2.1of Attachment 22 (Agent Monitoring Plan).
Data from all ACAMS shall be reported on PDARS.
Data from aII DAAMS analyses shall be reported in the Operating Record.
ffim:|;F##ffir shall be orally reported to the Executive Secretary wittttn24
Table V.l
TOCDF LIC Metals Feed Limits
ModuleV-Page30
TOCDF
Long-Terrn Incineration
March 2009
Metals l1224 hour Total
(pounds)*
Barium (D005)0.24
Selenium (D010)
|
0.44
Silver (D0l I )a.24
Metal Volatility Group I 2-Hour Rolling Average3
(Total Pounds perl2 hours)
High Volatile Metals
(Mercury D009)
0.01 45*s
Semi-Volatile Metals (Lead (D008) and Cadmium (D006))19.44*6
Low-Volatile Metals (Arsenic (D004), Beryllium, Chromium (D007))7.1g6
Notes:
l. 24-hour Total is meas ured from 0000 hours to 2400 hours each calendar day.
2. Based on LIC agent GB Trial Burn, mini-burn, or the Metals Dernonstration Test.
3. Based on LIC VX ATB
4. Based on LIC HD ATB Plan
5. Based on the Maximurn Theoretical Emission Calculation (MTEC) at 6,000 scfin. Exhaust
characteristics taken from the LIC HD ATB Report for Method 0029. Average exhaust gas moisture
was 52.3o/o, average exhaust gas 02 was 8.8olo.
6. Based in LIC HD Agent Trial Bum Report Results.
Table Y.2 RBSERVED
Module V - Page 3l
TOCDF
Long-Terrn Incineration
March 2009
Table Y.2a
MPF Non-Embedded Metals Feed Rates For Secondary Waste
Metal Volatility
Group Metals Pounds per 12 hours, on L2
hour rolling average basis
Group 1
(High-Volatile
Metals)
Mercury (D009)0.03 17*
Group 2
(Semi-Volatile
Metals)
Lead (D008)Thallium
47 .5*Cadmium (D006)Tin
Antimony Ztnc
Group 3
(Low-Volatile
Metals)
Arsenic (D00a)Boron
20.8
Chromium (D007)Cobalt
Barium (D005)Copper
Selenium (D010)Manganese
Silver (D001 I )Nickel
Beryllium Vanadium
Aluminum
l. Values based on 75 minute Charge lnterval.
Module V - Page32
TOCDF
Long-Terrn Incinerati on
March 2009
Table V.3
DFS Non-embedded Metals Feed Limits
Metals Z4-hour To talr'z
(pounds)*
Barium (D005)6l
Selenium (D010)0.00019
Silver (D0l I )0.000062
Metal Volatility Group I 2-Hour Rolling Average3
(Total pounds per 12 hours)
High Volatile Metals
(Mercury D009)
0.0094
Semi-Volatile Metals (Lead (D008) and Cadmium (D006))72
Low-Volatile Metals (Arsenic (D004), Beryllium, Chromium (D007))5.1
Notes:
1. Non-ernbedded metals are metals that may vaporize or become entrained in the combustion gas air
during thermal treatment.
2. 24-how Total is measured from 0000 hours to 2400 hours each calendar day.
3. Based on the DFS VX ATB.
Table V.4
ATLIC Metals Feed Limits
Metal Volatility Group I 2-Hour Rolling Averagel
Ootal pounds Ber 12 hours)
High Volatile Metals
(Mercury D009)
0.702
Semi-Volatile Metals (Lead (D008) and Cadmium (D006))0s+10393
Low-Volatile Metals (.fusenic (D004). Beryllium. Chnomium (.D007))I 1562
Notes:
I Other metal feed rate reeulated through ash feed rate limit.
2 Based on the ATLIC LIC L ATB Plan.
3 Based on ATLIC STB Plan.
4,.,rf {,!i,?rrh.u*''^
$*#: f r-
ModuleV-Page33
>;
(,
TOCDF
Short-Term Incineration
October 2007
MODULE YI SIIORT.TERM INCINERATION
YI.A. GENERAL CONDITIONS T'OR INCINERATORS AND FT]RNACES
. VI.A.l. TRIAL BURN PLANS
. tr'VI.A.I.a. Trial Bum Plan Submittal
VI.A.I.a.i. The Permittee shall submit a trial bum plan for each agent and for each incinerator that
will process that agent. The Permittee shall perform a trial burn for each agent to be
processed, for each fuinace that will process that agent. The Permittee shall submit each
trial bum plan a minimum of 180 days prior to the start of the Shakedown Period for the
planned trial burn.
VI.A.I.a.ii. Each individual trial burn plan for each fumace and each remaining agent shall be
submitted bythe Permittee in accordance with R315-3-4.
VI.A.I.a.iii. These trial bum plans shall define operating conditions and waste feed rates that will be'
used to determine incinerator performance in accordance with R315-8-15.4.
VI.A.I.a.iv. The trial burn plan shall include ramp-up procedures to be implemented during
shakedown for the furnace.
VI.A.1.a.v. The trial burn plan shall include sampling and analytical methods in order to include
decontamination solution in the trial bum runs. Proposed feed rates shall be evaluated by
the Executive Secretary prior to use during Short-Term Incineration.
VI.A.1.a.vi. The Executive Secretary shall review and approve all munition lot numbers to be
processed during Short-Term Incineration. This reouirement is waived for GA. Lewisite
and "Transparency''Ton Containers because of their small number.
. 'VI:A.l.a.vii. During the mustard campaign, the DFS is exempt from the requirements of Conditions
VI.A.1.a.i. through VI.A.1.a.v., VI.A.3, and VI.D.
VT.A.2. SHAKEDOWN
VI.A.2.a. Shakedown Periods
Vl'rt,2,e,i, The Pandtteernay net start the ShatrCewn Pqied in the speeifrefuraee systqn until the
F*eoutiYe Seeretarynppreyes in8
ino
,\-1 (L
VI.A.2.a.i. The Permittee may not start the aeent processing in the sodclfic fumace system until the
Executive Secretarv aooroves the specific trial bum plan and monitoring documentation is
provided to the Executive Secretary that demonstrates the initial baseline has passed the
.rit"riu tirt"d ir, tt
"
tOCp (CDnt Z+. tubl" tZ-2ffi-c '[,, I
Module VI - Page I
TOCDF
Short-Term Incineration
October 2007
VI.A.2.a.i.a. TOCDF alarm setpoints for NRT monitors in category C areas will not exceed 0.5
STE[/VSL. For mustard aeent. the common stack and ducts alarm setooints will not
exceed 0.2 sEL.
VI.A.2.a.i.b. The alarm setpoints for NRT monitors in cateeory C areas will not exceed 0.5 and 0.4
STELA/SL for Aeent GA and Lewisite. respectively. The ATLIC Liquid Incinerator
(LIC) exhaust stack alarm setooints shall not exceed 0.2 5 SEL for GA and 0.2 4 SEL for
Lewisite.
VI.A.2.a.ii.The Shakedown Period shall begin with the introduction of each surrosate or agent inlq
the fumace and shall end with the start of each fumace chemical agent or surroeate trial
burn. There shall be a separate Shakedown Period for each furnace anrglgg@!.
Only non-age,nt contaminated waste or materials shall be processed during Shakedown
hours attributed to the Secondary Waste Demonstration Test and during the test runs
associated with the demonstration test (i.e., DPE suits/material and carbon canisters).
Secondary Waste identified in Table 2-5 of Attachment 2 (Waste Analysis Plan), may be
processed during the Shakedown periods for agent that have been successfully
demonstrated per Condition VI.C.3.a.i.c.1 at the specified feed rates without further
function testing.
The Permittee shall maintain records that differentiate and document between Shakedown
hours attributed to the processing of waste to be demonstrated during the trial bumi
demonstration test and hours attributed to the processing of Secondary Waste per
Condition VI.C.3.a.i.c. 1.
A Monitoring plan for the discharge airlock will be submitted and approved by the
Executive Secretary prior to commencing shakedown operations.
Duration of the Shakedown Periods
VI.A.2.a.iii
VI.A.2.a.iv
Each Shakedown Period associated with the TOCDF incinerators shall not exceed720
hours of agent operation. The Permittee may petition the Executive Secretary for one
extension of the Shakedown Period for up to 720 additional hours for each agent test in
accordance with R3 1 5-8- I 5.5(cX 1 ).
VI.A.2.b.ii. The Shakedown Period associated with ATLIC Surrogate Trial Bum shall not exceed 720
hours of arat hazardous waste operations.
VI.A.2.b.iii. The Shakedown Period associated with ATLIC Lewisite Agent Trial Bum shall not
exceed 144 hours ofaeent oBerations and the amount ofag€nt orocessed during the
Shakedown pgriod shall be limited to the lesser of either 7.500 pounds or the contents of
three Lewisite Ton Containers.
TRIAL BURN
Trial Bum Determinations
VI.A.2.a.v
YI.A.2.a.vi
vLA.2.b.
vr.A.2.b.i.
VI.A.3.
VI.A.3.a.
Module VI - Page 2
VI.A.3.a.i..
TOCDF
Short-Term Incineration
October 2007
The Permittee shall determine during the trial burn tests whether or not the following
performance standards have been met:
TOCDF Performance Standards Agent Trial Burn
Minimum DREs for Applicable POHCs
99.9999% (LIC, Agent)
99.9999% (MPF, Agent)
99.990 (DFS, Agent)
99.990 (DFS, PEP)
Particulate Matter Emission Limit 0.013 grains/dscf (29.7 5 mgldscm) , zt 7o/o Oz
'Mercury (Hg)130 peldscm at 7oh 02
Semi-volatile Metals (Pb, Cd)230 pgldscm at 70 Oz
Low-volatility Metals (As, Be, Cr)92 Weldscm at 7o/o Oz
Hydrogen Chloride lChlorine (HCUCI) Emission
Limit
32 ppmv total HCI and Clz expressed as HCl
equivalents at 7o/o Oz
Toxic Metals Emission Limits At levels determined by the Executive Secretary to
be protective of human health and environment.
Dioxins/Furans TEQ 0.4 ngldscm at 70 02
CO Emission Limit, 60-Minute Rolling'Average 100 ppmv at 7o/o Oz
Chemical Agents Emission Limits GB I H/HD/FrT VX
0.0003 mg/m' | 0.03 mg/m3 | 0.0003 mg/m3
ATLIC Performance Standards ATLIC Trial Burns
Minimum DREs for Applicable POHCs
99.999906 each (Surrogates: Monochlorobenzene
and Tetrachloroethylene)
Particulate Matter Emission Limit 0.0016 erains/dscf (3 .7 ms,/dscm). at 7o/o O,
Mercurv (He) Emission Limit 8.1 ueldscm at 7oh O,
Semi-volatile Metals (Pb. Cd) Emission Limit l0 us,/dscm at 7oh Oz
Low-volatility Metals (As. Be. Cr) Emission Limit 23 uddscm at 7o/o Ot
Hydrosen Chlori de I Chlorine (HCVClr) Emission 21 ppmv total HCI and Clz expressed as HCI
equivalents at 7oZ OeLimit
Toxic Metals Emission Limits At levels determined by the Executive Secretary to
be orotective of human health and environment.
DioxinslFurans TEQ Emission Limit 0.2 ng/dscm at 7o/o Oz
CO Emission Limit" 60-Minute Rollins Averaee 100 ppmv at 7o/o Ot
Chemical Agents Emission Limits GA I Lewisite
,0.003 mg/mr* | 0.03 mg/m'*
Z(
*Continuously demonstrated by exhaust stack agent monitoring.
VI.A.3.a.ii. Emissions from each trial bum shall be measured to quantiff total organics.
.i
Module VI - Page 3
vI.A.3.b.
vI.A.3.b.i.
vI.A.3.b.ii.
VI.A.4.
VI.A.4.a.
VI.A.4.a.i.
VI.A.4.a.ii.
TOCDF
Short-Term Incineration
October 2007
The Permittee rnay use Cr{ test data collected during the agent trial burn to quantifr the
amount of the total chromium that is subject to the Toxic Metals Emission Limits in the
table above.
Trial Burn Data Submissions and Certifications
The Permittee shall submit a sunmary of all stack sampling data collected during the trial
bum to the Executive Secretary upon completion of each trial burn run. The Permittee
shall submit to the Executive Secretary a trial burn test report within 90 calendar days of
completion of each trial bum. All submissions shall be certified in accordance with R315-
3-2.2.
If the preliminary calculations show that the Permittee has failed to meet one or more of
the performance standards listed in Condition VI.A.3.a. during the trial bum, the Permittee
shall immediately stop waste feed to the incinerator system tested. The Executive
Secretary shall be orally notified within 24 hours of this discovery. A written notification
and explanation shall be submitted within 15 days of the oral notification. As ne,cessary
for protection of workers, the Permittee may propose a revised post-trial burn feed rate for
approval to dispose of open munitions/bulk containers and the hazardous waste remaining
in the tank systems.
MONITORING. INSPECTION. AND RECORDKEEPING REOUIREMENTS
Monitorine Reouirements
The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Attachments 3 (Sampling, Analytical, and QA/QC Procedures), 6 (Instrument
Calibration Plan and Incinerator Waste Feed Interlock Function Test), 19 (Instrumentation
and Waste Feed Cut-off Tables), 20 (Continuous Emission Monitoring System Plans), and
22 (Agent Monitoring Plan).
Monitoring of oxygen (O2), carbon monoxide (CO), and agent shall be provided at all
times during waste feed to a fumace or incinerator. If an intemrption in monitoring (CO,
02 or agent) occurs, feed to that furnace shall be discontinued except as allowed in
Attachment 19 (Instrumentation and Waste Feed Cut-off Tables). If the duct is not
monitored by an ACAMS, then the DAAMS tubes shall be analyzed for that time period
the ACAMS was off-line. Monitoring shall resume in accordance with Attacbnent22
(Agent Monitoring Plan).
The Permittee shall provide continuous monitoring in the TOCDF common stack for
agents being processed. The continuous monitoring shall consist of two staggered
ACAMS monitors for each agent and DAAMS tubes for each agent being processed per
Condition Vl.A.4.a.xvii. If an intemrption in monitoring occurs, feed to all of the fumace
systems shall be discontinued.
VI.A.4.a.iii.a
ie+in
mon The Permittee shall provide
continuous monitorins in the ATLIC stack for agents beins processed. The
continuous monitorins shall consist of two staggered NRT monitors for each asent
Module VI - Page 4
_rL,i*( u TocDF
L v' Short-Term Incineration
October 2007
(ACAMS for GA and MINICAMS for Lewisite) and DAAMS tubes for each asent
being processed oer Condition Yl.A.4.a.xvii.a. If an hterruption in monitorine
occurs. feed to the ATLIC shall be discontinued.
DA"qAA$+$es.
Vt'+,+,a,iii,e,Z
V[^.1,&iii'4,3
reeei
inei
VI.A.4.a.iv. The Permittee.shall maintain and operate Depot Area Air Monitoring System (DAAMS)
tubes and an Automatic Continuous Air Monitoring System (ACAMS) monitor on each
TOCDF fumace exhaust duct and DAAMS tubes and staggered ACAMS monitors on the
corlmon stack for each agent being processed. If one of the redundant monitors fails or
malfunctions, the Permittee shall replace or repair the monitor within 24 hours. If both
monitors fail or malfunction, then feed to the incinerator or fumace shall be stopped.
VI.A.4.a.v. The oxygen (Oz) and carbon monoxide (CO) monitors specified in Condition VI.A.4.a.ii.
shall be initially certified in accordance with R315-50-16 [40 CFR Part266, Appendix
IXl. and 40CFR Part 60, Appendix B, using the most stringent requirements.
VI.A.4.a.v.a. Certification must be accepted by the Executive Secretary.
VLA.4.a.v.a.i Interim approval of certification or recertification test results may be granted by the
Executive Secretary, based upon a review of.preliminary data and observations made
during the certification testing, to allow operation of the monitor for compliance prior to
submission of the final certification report.
VI.A.4.a.v.b. Certification shall expire at the end of the calendar quarter associated with the certification
anniversary.
VI.A.4.a.v.c. The certification date shall be the first day of certification testing.
VI.A.4.a.v.d. Any monitor failing certification shall not be used for compliance.
VI.A.4.a.vi. A certified monitor may only receive minor modifications and still remain certified. A list
of minor and major changes and the corrective action is listed V.A.1.h.i.
VI.A.4.a.vi.a. Written approval from the Executive Secretary shall be required for downgrading from
majorto minor.
Module VI - Page 5
VI.A.4.a.vii.
TOCDF
Short-Term lncineration
October 2007
Major maintenance changes require recalibration of the CEMS in accordance with R3l5-
50-16 [40 CFR Part 266, Appendix D(, Performance Specification Tests], 40CFR Part 60,
Appendix B, Condition V.A.l.h. and Attachment 20 (CEMS Monitoring Plan), using the
most stringent requirements
Vl.A.4.a.viii. Replacement -*itoii shall be available for the monitors specified in Conditions
VI.A.4.a.ii. through VLA.4.a.iv. The oxygen (Oz) and carbon monoxide (CO) monitors
specified in Condition VI.A.4.a.ii. shall be certified in accordance with Conditions
VI.A.4.a.v. through vii. Replacement ACAMS and MINICAMS shall be certified in
accordance with Attachment 3 (Sampling, Analytical, and QA/QC Procedures).
VI.A.4.a.ix. Replacement of the oxygen (Oz) and carbon monoxide (CO) CEMS specified in Condition
VI.A.4.a.ii. shall be in accordance with the following:
VI.A.4.a.ix.a. The replacement CEMS shall be calibrated in accordance with R315-50-16 [40 CFR Part
266,AppendixW.,2.l.6.2. forResponseTime, atd2.1.6.3 forCalibrationError]
immediately after installation.
VI.A.4.a.ix.b. The replacement CEMS shall be calibrated when installed and checked daily thereafter for
Calibration Drift.
VI.A.4.a.ix.c. The replacement CEMS must be calibrated and on line before the calibration of the first
monitor has expired. If this carurot be accomplished, feed to the specific fumace system
shall be discontinued
I VI.a.+.a.ix.a. Both monitors for one TOCDF incinerator monitorine location may not be replaced within
one 24-hour period without approval from the Executive Secretary.
VI.A.4.a.ix.e. Replacement CEMS information shall also be included in the annual report specified in
Condition I.AA.
VI.A.4.a.x. A report speciffing the following information shall be submitted to the Executive
Secretary within 14 calendar days of replacement of any monitor specified in Condition
I vl.A.4.a.ix.eandATLIC CEMS:
VI.A.4.a.x.a. The calibration data, raw and Process Data Acquisition and Recording System (PDARS),
in accordance R315-50-16 [40 CFR Part266, Appendix D(];
VI.A.4.a.x.b. Failed and replacement monitor serial numbers, type and range of the monitors;
VI.A.4.a.x.c. Date and time monitor failed;
VI.A.4.a.x.d. Maintenance to be performed; and
VI.A.4.a.x.e. The identity of the furnace.
VI.A.4.a.xi. A CEMS maybe taken off line for calibration and minor maintenance as specified in
Condition V.A.l.h. However, when taken off line for major maintenance or
modifications, recertification of the monitor will be required as specified in Condition
v.A.1.h.
Module VI - Page 6
TOCDF
Short-Terrn Incinerati on
October 2007
VI.A.4.a.xii. Data from the CEMS shall be recorded in the operating record.
Vl.A.4.a.xiii. Data from all monitors on-line will bcteported in the operating record. Worst-case data
will be used for reporting requirements.
VI.A.4.a.xiv. All monitors shall be connected to the waste feed cut-off.
VI.A.4.a.xv.Hazardous wastes shall not be fed to a furnace if any waste feed cut-off instrument
associated with that fumace listed in Attachment 19 (Instrumentation and Waste Feed Cut-
off Tables) fails to opeffite properly.
VI.A.4.a.xvi. All monitoring, recording, maintenance, calibration and test data shall be recorded and the
records shall be placed in the Operating Record for the specific fumace.
Vl.A.4.a.xvii. ACAMS on the TOCDF common stack shall be comprised of two primary monitors in
staggered mode of sampling for continuous monitoring for agent. A back-up monitor shall
be calibrated and stationed in the stack-monitoring house for contingency purposes, i.e.,
primary monitor malfunctions or calibration.
Vl.A.4.a.xvii.a. ACAMS used to monitor for Aeent GA and MINICAMS used to monitor for Lewisite
on the ATLIC stack shall be comprised of two primary monitors in stageered mode of
sampling for continuous monitorine for aselrt. A back-up monitor shall be calibrated and
stationed such that it is available for contingency purposes. i.e.. primary monitor
malfunctions or. calibration.
orevidr
Vl.A.4.a.xviii. DAAMS tubes on the TOCDF common stack and ATLIC PAS stack{if*ed}shall be
analyzed at a frequency of one tube per four hours of sampling with a corresponding QP
sample for each agent.
,].
VI.A.4.a.xix. Data from aIITOCDF ACAMS (specified in Attachment 22, AgeriMonitoring Plan)
shall be reported on PDARS.
VI.A.4.a.xix.1 Data from all ATLIC NRT monitors (ACAMS and MINICAMS) (specified in
. Attachment 22a. Asent Monitoring Plad shall be recorded by the ATLIC process data
acquisition and recordins systern.
VI.A.4.a.xx. Data from all DAAMS analyses shall be reported in the Operating Record.
VI.A.4.a.xxi. C-onfirme'd agent alarms shall be orally reported to the Executive Secretary withn24
hours of confirmation.
Module VI - Page 7
Short-Term rr.rlff3:
October 2007
VI.A.4.b. Inspection Requirements
VI.A.4.b.i. The Permittee shall comply with thb inspection requirements specified in Condition
v.A.3.
VI.A.4.c. Recordkee,pine Requirernents
VI.A.4.c.i. The Permittee shall comply with the recordkeeping requirements as specified in Condition
v.A.6.
II vI.B. TOCDF LIQUID INCINERATORS (LICs)
VI.B.l. SHAKEDOWN
VI.B.I.a. Allowable Waste Feed
VLB.I.a.i. During the shakedown periods, the Permittee shall limit the hourly feed of hazardous and
non-hazardous wastes, decontamination solutions and Munition DemilitarizationBuilding
aqueous liquid wastes to the LIC to that specified in the LIC Agent Trial Bum Plan
specific to the agent being processed.
' VI.B.1.a.ii. The Permittee shall not feed the following wastes to the LIC during the Shakedown
Periods.
VI.B.1.a.ii.a. Hazardous Wastes F020 through F023,F026, andF027.
VI.B.1.a.ii.b. Any wastes containing polychlorinated biphenyls.
VI.B.1.a.iii. The feed rate of chlorine to each LIC shall not exceed 7356 pounds, over a twelve-hour
rolling average during the shakedown period. The Permittee shall speciff expected feed
rates in each trial burn plan for the shakedown and trial bum periods.
VI.B.I.a.iv. Decontamination solution with the F999 waste code, and other applicable waste codes,
maybe fed to the secondary chamber of the LIC during the shakedown period only if the
operating conditions specified in Condition VI.B.1.b. are satisfied and the waste feed cut-
off limits specified in the trial bum plans are in effect
VI.B.l.a.v. Changes to the LICs shall be certified as specified in Condition I.S.
VI.B.I.a.vi. Throughout the shakedown periods, the Permittee shall conduct waste analysis in
."accordance with the approved trial burn plan and Attachments 2 (Waste Analysis Plan)
: . and 3 (Sampling, Analflical, and QA/QC Procedures) for agent and other hazardous
-.'.
'
waste.
' VLB.1.a.vii. The Permittee shall determine waste codes for each waste stream as specified in
Attachment 2 (Waste Analysis Plan).
i:,
vI.B.l.b.
Module VI - Page 8
Short-Term rr.,;T*:il:
October 2007
VI.B.1.b.i. During the shakedown periods, the Permittee shall operate the LIC furnace system in
accordance with the approved trial burn plans and the following conditions:
VI.B.I.b.i.a. The Permittee shall monitor emissions from the LIC duct and the common stack for
chemical agent as specified in Condition VI.A.4.a. The waste feed to the incinerator shall
be automatically cut-off if any of the monitored emission levels exceed the values
specified in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
VI.B.1.b.i.b. Primary combustion chamber exhaust gas temperature shall be maintained at or above
2500" F, over a one hour rolling average, but shall not exceed 2,850o F.
VI.B.l.b.i.c. Secondary cornbustion chamber exhaust gas temperature shall be maintained at or above
1,800o F, over a one-hour rolling average, but shall not exceed 2,200" F.
VI.B.1 .b.i.d. Carbon monoxide concentration at the exhaust blower exit, correct ed to 7oh oxygen in
accordance with the formula specified in Condition Y.A.2.e., shall not exceed 100 parts
per million (ppm) dry volume over a one-hour rolling average.
VI.B.1.b.i.e. The LIC exhaust gas flow rate, or unit production rate (as measured by the V-Cone) shall
not exceed 9,500 standard cubic feet per minute, over a one-hour rolling average.
VI.B.1.b.i.f. Oxygen concentration at the exhaust blower exit shall be maintained at or above 3Yo,bttt
. shall not exceed l5%o on a dry volume basis.
VI.B.1.b.i.g. Reserved
VI.B.1.b.i.h. Atomizing air pressure for the waste burner nozzles, for both chemical agent and
decontamination solution shall be maintained at or above the following set points:
VI.B.I.b.i.h.l. Primary Combustion Charnber, All Feed Rates (1-100%) - 60 psig
VI.B.1.b.i.h.l .a. The Permittee may disable the Automatic Waste Feed Cut-Off associated with Condition
VI.8.1.b.i.h.l. when the waste burner nozzle for the primary chamber is removed and
agent feed to the LIC is isolated.
VLB.1 .bJh.Z. Secondary Combustion Chamber, All Feed Rates (1-100%) - 60 psig
VI.B. 1 .b.i.i. The Permittee shall control fugitive emissions by the seal system design of the LIC
combustion chambers.
VI.B.1.b.ij. Quench tower exhaust gas temperature shall not exceed 225o F.
VI.B.1.b.i.k. Exhaust gas pressure drop across the venturi scrubber shall be maintained above 30 inches
of water column, over a one-hour rolling average.
VI.B.1.b.i.l. Clean liquor flow rate.to the scrubber tower shall be maintained at or above 400 gpm, over
a one-hour rolling average.
VI.B.1.b.i.m. Clean liquor pressure to the scrubber tower shall be maintained at or above 35 psig, over a
one-hour rolling average.
Module VI - Page 9
VI.B.l .b.i..n.
VI.B.1 .b.i.o.
VI.B.1.b.i.p.
VI.B.l.b.i.q.
VI.B.l .b.i..r.
VI.B.1 .b.i..s.
vI.B.1 .b.i.t.
VI.B.1 .b.i.u.
VI.B.1.b.i.v.
VI.B.l .c.
VI.B.1 .c.i.
VI.B.1.c.ii.
TOCDF
Short-Temr Incineration
October 2007
Quench brine liquid feed rate to the venturi scrubber shall be maintained at or above 100
gpm over a one-hour rolling average. Quench brine delivery pressure shall be maintained
at or above 40 psig.
The specific gravity of the quench brine effluent shall not exceed 1.20 over a twelve-hour-
rolling average.
The pH of the quench brine shall be maintained at7.0 or above, over a one-hour-rolling
average.
Reserved
Reserved
The Permittee shall monitor and control the emissions from the LIC systern. The emission
levels from each monitoring system shall not exceed the agent concentrations specified in
Condition VI.A.3.a.
During cold start-ups, the individual LIC's primary chamber wastenozzle shall not be
installed and the waste feed control valve shall not be opened until the secondary
combustion chamber is at 1,550o F or higher as measured by thermocouple 13-TIC-103
(LICI) or l3-TIC-781 (LIC2).
If the exterior shell temperature of the slag removal system exceeds 500o F, all waste feed
to the LIC system shall be stopped. Shell integrity shall be verified, and recorded in the
Operating Record, before wastes are re-introduced into the fumace system.
Toxic metals emissions shall be controlled by limiting the agent and agent contaminated
waste feed rates to the furnaces. LIC metals feed limits are in Table V.1 in Module V.
Metals feed shall be determined using procedures specified in Attachment 2 (Waste
Analysis Plan).
Waste Feed Cut-Off Requirements
The Permittee shall identi[, the waste feed cut-off instruments in each individual trial burn
plan. The Permittee shall identifu the instrument number, the operating parameter, and the
set point. When the waste feed cut-off tables for LIC1 and LIC2 are approved as part of
the revised trial burn plans, the waste feed cut-off TAG identification numbers and
associated set points shall be incorporated into Attachment 19 (Instrumentation and Waste
Feed Curoff Tables).
In the event of a malfunction of a LIC automatic waste feed cut-off instrument identified
in the approved trial burn plan, the Permittee shall immediatelymanually cut off the waste
feed to the LIC and correct the malfunction prior to resuming waste feed. The Permittee
shall record in the Operating Record any waste feed cut-off system malfunction, the time
of the malfunction, the time of resuming waste feed, the apparent cause of the
malfunction, and specific steps taken to repair the malfunction and avoid similar future
malfunctions.
Module VI - Page l0
TOCDF
Short-Term Incineration
October 2007
VI.B.1.c.iii. All waste feed cut-off instruments shall be maintained and tested in accordance with
Condition V.A.4.
VI.B.1.d. MonitoringRequirements
VI.B.I.d.i. The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VI.A.4.a and V.A.1.h.i.
VI.B.2. TRTAL BURN PERIOD
VI.B.2.a. The Permittee shall operate and monitor the incinerator during the trial burn period as
specified in each of the trial bum plans approved by the Executive Secretary. Each trial
bum plan shall include procedures to insure that the data critical for conducting a risk
assessment (e,g. dioxins/furans, metals, agent, etc.) meets the standards in the qualrty
control plan accompanyrng the trial bum plan.
VLB.2.b. Trial BurnDeterminations
VI.B.2.b.i. The Permittee shall make the performance determinations specified in Condition VI.A.3.a.
during the trial bum tests.
VI.B.2.o. Monitoring Requirements
VI.B.2.c.i. All continuous smission monitoring will follow the requirements as specified in Condition
VI.A.4.a and V.A. 1.h.i.
VI.B.3. POST-TRIAL BURN PERIOD
VI.B.3.a. During the post trial burn periods in accordance with R315-8-15.5(c)(3) and for the
minimum period sufficient for the Permittee to analyze samples, compute data, and submit
trial burn results, and for the Executive Secretary to review the trial bum results and make
any modifications necessary to the permit, the Permittee shall comply with the following
conditions:
VI.B.3.a.i. Limitation on Waste Feed
VLB.3.a.i.a. After successful completion of an agent trial bum, the Permittee may feed permitted
hazardous waste to the LIC up to 50% of the feed rate demonstrated during the trial bum.
The Permittee may feed up to 75Yo of the demonstrated feed rate after approval of
preliminary results by the Executive Secretary for the metals train, dioxin train,
particulate/acid gas train(s), and Mustard DAAMS, including a preliminary DRE
calculation.
VI.B.3.a.i.b. Only one type of chemical agent shhfl be bumed in the LIC System at anygiven time.
VI.B.3.a.i.c. Decontamination solution may be fed to the secondary chamber of the LIC during the
agent post trial bum period only if the operating conditions specified in Condition
VI.B.3.a.ii. are satisfied and the waste feed cut-off limits specified in the trial burn plans
are in effect
Module VI - Page I I
VI.B.3.a.i.d.
VI.B.3.a.i.e.
VI.B.3.a.i.f.
Short-rerm..'ffi"!31
October 2007
The Permittee shall not incinerate the miscellaneous agent contaminated liquid wastes in
the LIC secondary combustion chamber except as allowed in Attachment 2 (Waste
Analysis Plan).
The feed rate of chlorine to each LIC shall be in accordance with VI.B.3.a.i.a.
Throughout the post-trial burn periods, the Permittee shall conduct analysis of the waste to
be treated in the LICs to veriff that the waste feed is within the physical and chernical
composition limits specified in Module V and Attachment 2 (Waste Analysis Plan). The
procedure shall follow the waste analysis requirements in the trial bum plan and
Attachments 2 (Waste Analysis Plan) and 3 (Sampling, Analytical, and QA/QC
Procedures) for agent and other hazardous waste.
The Permitee may feed hazardous waste up to 100 percent of the agent trial burn
demonstrated feed rate provided;
VI.B.3.a.i.g
VI.B.3.a.i.g.1 The Executive Secretary has previously approved the preliminary data referenced in
Condition VI.B.3.a.i.a;
VI.B.3.a.i.g.2 The Permittee has submitted the Notification of Compliance required by Title 40 of the
Code of Federal Regulations, Part 63, Subpart EEE to the Utah Division of Air Qualrty;
VI.B.3.a.i.g.3 The Permittee has submitted revised Conditions V.B.1.a, V.B.1.d, V.B.2, Table V.1. and
revised Attachment 19 Tables D-5-2 and D-5-2B (Automatic Waste Feed Cut-off tables
for LICs I and2 respectively) that incorporate operating parameter limits;
VI.B.3.a.i.g.4 The Permittee has submitted the trial burn report and the Executive Secretary has
reviewed the Executive Summary included in the report.
VI.B.3.a.i.g.5 The Permittee shall comply with the requirements of Conditions V.A and V.B when the
requirements of Conditions VI.B.3.i.b.g.2 throughVI.B.3.a.i.g.4havebeen fulfilled.
VI.B.3.a.ii. Operating Conditions
VLB.3.a.ii.a. The Permittee shall not treat any hazardous waste in the LIC during the post-trial burn
period unless the system is operating in compliance with Condition VI.B.1.b., excluding
the feed rates in Conditions VI.B.l.b.i.v.
Waste Feed Cut-Off Requirements
VI.B.3.a.iii.a. The Permittee shall comply with the waste feed cut-off instrument settings specified in
Attachment 19 (Instrumentation and Waste Feed Cut-Off Tables).
Vl.B.3.a.iii.b. ln the event of a malfunction of a LIC automatic waste feed cutoff instrument as specified
in the approved trial burn plan, the Permittee shall immediately manually cut off the waste' feed to the LIC and correct the malfunction prior to resuming waste feed. The Permittee
shall record in the Operating Record any waste feed cut-off system malfunctions, the time
of the malfunction, the time of resuming waste feed, the apparent cause of the
malfunctions, and specific steps taken to repair the malfunction and avoid similar future
malfunctions.
Module VI - Page 12
o
VI.B.3.a.iii.c.
VI.B.3.a.iv.
VI.B.3.a.iv.a.
VI.C.
VI.C.1.
VI.C.1.a.
VI.C.1.a.i.
VI.C.1.a.i.a
VLC.1.a.ii.
VI.C.1.a.ii.a.
VI.C.1.a.ii.b.
VI.C.1 .a.ii.c
VI.C.1.a.iii.
VI.C.1.a.iv.
VI.C.1.a.v.
VI.C.1 .a.v.1
TOCDF
Short-Term Incineration
October 2007
A11 instrumentation shall be maintained and tested in accordance with Condition V.A.4.
Monitoring Requirements
The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VLA.4.a. and V.A.1.h.i.
METAL PARTS F'T]RNACE
SHAKEDOWN
Allowable Waste Feed
During the shakedown periods, the Permittee shall limit the hourly feed of hazardous and
non-hazardous waste test materials to the MPF to that specified in the MPF Agent Trial
Burn Plan or Demonstration Test Plan specific to the agent being processed.
During the Shakedown period for mustard 155mm projectiles, the Permittee may process
secondary wastes in accordance with Module V.C.l.a.ii. for secondary waste without
using mustard 155mm projectile shakedown hours.
The Permittee shall not feed the following wastes to the MPF during the Shakedown
Period.
Hazardous Wastes F020 through F023,F026, andF027.
Any wastes containing polychlorinated biphenyls.
Mustard ton containers, indicating a liquid mercury sample result of one part per million
or greater.
The feed rate of total halogens to the MPF shall not exceed 2490 total pounds over a 12-
hour rolling average during the shakedown period.
The hourly feed rate of the residual chemical agent contained in the MPF feed shall not
exceed the limits provided in the approved trial bum plan.
The Permittee may submit data generated during the Mustard Baseline Shakedown Period
to the Executive Secretary for approval which supports a correlation between ton container
heel depths and heel weight for Baseline Ton Container Processing. The method used to
develop the correlation shall be described in the approved MPF Trial Bum Plan.
Upon approval by the Executive Secretary of the heel depth-heel weight correlation, the
Permittpd may use the Bulk Drain Station (BDS) Drain Tube System (DTS) to confirm
drained ton container heel weights and extend the calibration frequency of the BDS load
cells as specified in Attachment 6 from 90 days to 360 days.
Changes to the MPF shall be certified as specified in Condition I.S.VI.C.1 .a.vi.
Module VI - Page l3
VI.C.1 .a.vii.
VI.C.I.a.viii The Permittee shall determine waste codes for each waste stream as specified in
Attachment 2 (Waste Analysis Plan).
TOCDF
Short-Term Incineration
October 2007
Throughout the shakedown periods, the Permittee shall conduct waste analysis in
accordance with the approved trial bum plan and Attachments 2 (Waste Analysis Plan)
and 3 (Sampling, Analytical, and QA/QC Procedures) for agent and other hazardous
waste.
The Permittee shall collect brine samples at a regular interval specified in2.2.2.13.8 to
evaluate metals concentrations in the mustard baseline ton containers and mustard 155mm
projectiles.
The Permittee shall collect a treatment residue sample from each of the first three ton
containers processed for each of the charge weight and charge interval sets that will be
used during Baseline processing and evaluated by the Executive Secretary during the
Shakedown Period. The samples shall be analyzed to ensure the agent content in the
residue is below the Waste Control Limit specified in Attachment 2 for the agent being
processed.
The Permittee shall collect treatment residue (ash) samples from five projectiles (one (1)
projectile from each of the first frve (5) trays processed) from 155mm mustard projectiles.
The samples will be analyzed to ensure the agent content in the residue is below the Waste
Control Limit specified in Attachment 2 for Mustard"
Operating Conditions
During the shakedown periods, the Permittee shall operate the MPF furnace system in
accordance with the approved trial burn plans or demonstration test plans and the
following conditions:
The Permittee shall monitor emissions from the MPF duct and the common stack for
chemical agent as specified in Condition VI.A.4.a. The waste feed to the incinerator shall
be automatically cut off if any of the monitored emission levels exceed the values
specified in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
The number of munitions units fed to the MPF per batch feed shall not exceed the limit
specified in the approved trial bum plan.
The temperature of all three zones of the primary chamber shall be maintained at or above
I l50oF, but shall not exceed 1,800o F.
The MPF secondary combustion chamber temperature shall be maintained at or above
1900o F, over a one -hour rolling average, but shall not exceed 2,175o F.
Carbon monoxide concentration at the exhaust blower exit, correctedto 1Yo oxygen in
accordance with the formula specified in Condition Y.A.2.e., shall not exceed 100 ppm
dry volume over a one-hour rolling average.
VI.C.1 .a.ix
VI.C.1.a.x
VI.C.1.a.xi
vl.c.1.b.
vr.c.1.b.i.
VI.C.1.b.i..a.
VI.C.1 .b.i.c.
vl.c.1 .b.i.d.
VI.C.1 .b.i.e.
vl.c.1.b.i.f
VI.C.I.b.i.b. Only one loaded tray containing the waste materials shall be fed into the MPF at any given
time, with a minimum 20-minute interval between each tray feed.
Module VI - Page 14
Short-Term rr",H;3:
October 2007
VLC.I.b.i.g. MPF exhaust gas flow rate, or unit production rate (as measured by the V-cone), shall not
exceed 9,500 standard cubic feet per minute, over a one-hour rolling average.
VI.C.1.b.i.h. Reserved
\/I.C.l.b.i.i. Oxygen concentration at the exhaust blower exit shall be maintained at or above 3o/o,but
shall not exceed l5Yo on a dry volume basis.
The Permittee shall control fugitive emissions from the cornbustion zone of the MPF by
maintaining the pressure in the primary chamber below the pressure of the MPF furnace
room.
Quench tower exhaust gas temperature shall not exceed 225" F.
Exhaust gas pressure drop across the venturi scrubber shall be maintained above 20*
inches of water column, over a one-hour rolling average.
VI.C.I.b.i.m. Clean liquor flow rate to the scrubber tower shall be maintained at or above 400* gpm,
over a one-hour rolling average.
vl.c.1.b.i.k.
vl.c.1 .b.i.1.
VI.C.1 .b.i.n.
VI.C.1.b.i..o.
VI.C.1.b.i.p.
VI.C.1.b.i.t.
Clean liquor pressure to the scrubber tower shall be maintained at or above 35 psig.
Quench brine feed rate to the venturi scrubber shall be maintained at or above 85 gallons
per minute, over a one-hour rolling average.
The pH of the scrubber liquid effluent shall be maintained at 7 .0 or above, over a one-hour
rolling average.
VI.C.1.b.i.q. The specific gravity of the scrubber brine shall not exceed 1.20 specific gravity units over
VI.C.1.b.i.r.
a twelve-hour rolling average.
Toxic metals emissions shall be controlled by limiting the agent and agent contaminated
waste feed rates to the furnaces. MPF non-ernbedded metals feed limits are in Table
V.C.l., V.2. and Y .2a in Module V. Non-embedded metals feed shall be determined
using procedures specified in Attachment 2 (Waste Analysis Plan).
The Permittee shall monitor and control the emissions from the MPF system. The
emission levels from each monitoring system shall not exceed the Chemical Agents
Emission Limits specified in Condition VI.A.3.a.
The Permittee shall comply with Conditions V.C. for processing munitions, bulk
containers and secondary wastes in the Discharge Airlock utilizing either high temperature
or low temperature monitoring. Low Temperature monitoring will be required if the
specified upset conditions in Y.C.2.r. are exceeded. The Permittee shall perform low-
temperature monitoring in the MPF Discharge Airlock for all secondary waste.
Waste Feed Cut-Off Requirements
VI.C.1 .b.i.s.
VI.C.1 .c.
Module VI - Page l5
VI.C.1.c.i.
VI.C.1.c.ii.
VI.C.1 .c.iii.
vl.c.1 .d.
vl.c.1 .d.i.
vl.c.1.d.ii.
YT.C.2.
VI.C.2.a.
vl.c.2.b.
vl.c.2.b.i.
VI.C.2.c.
VI.C.2.c.t.
VI.C.3.
VI.C.3.a.
TOCDF
Short-Term Incineration
October 2007
The Permittee shall identiffthe waste feed cut-off instruments in each individual trial bum
plan. The Permittee shall identiff the instrument number, the operating parameter, and the
set point. When the waste feed cut-off tables for the MPF are approved as part of the
revised trial bum plans, the waste feed cut-off TAG identification numbers and associated
set points shall be incorporated into Attachment 19 (Instrumentation and Waste Feed Cut-
off Tables).
In the event of a malfunction of a MPF automatic waste feed cut-off instrument identified
in the approved trial burn plan, the Permittee shall immediatelymanually cut off the waste
feed to the MPF and correct the malfunction prior to resuming waste feed. The Permittee
shall record in the Operating Record any waste feed cut-off system malfunction, the time
of the malfunction, the time of resuming waste feed, the apparent cause of the
malfi.rnction, and specific steps taken to repair the malfunction and avoid similar future
malfunctions.
All instrumentation shall be maintained and tested in accordance with Condition V.A.4.
Monitoring Requirements
The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VI.A.4.a and V.A.l.h.i.
MPF Discharge Airlock Monitoring will comply with V.C. 1 ., VI.B.1 .b.i.v. and
Attachment 22 (Agent Monitoring Plan).
TRTAL BURN PERIOD
The Permittee shall operate and monitor the incinerator during the trial burn period as
specified in each of the trial burn plans approved by the Executive Secretary. Each trial
burn plan shall include procedures to insure that the data critical for conducting a risk
assessment (e.g. dioxins/furans, metals, agent, etc.) meets the standards in the quality
control plan accompanyrng the trial bum plan.
Trial Bum Determinations
The Permittee shall make the performance determinations specified in Condition VI.A.3.a.
during the trial bum tests.
Monitoring Requirements
All continuous emission monitoring will follow the requirements as specified in Condition
VI.A.4.a and V.A.1.h.i.
POST-TRIAL BURN PERIOD
During the post-trial burn periods, in accordance with R315-8-15.5(c)(3), and for the
minimum period sufficient for the Permittee to analyze samples, compute data, and submit
trial burn results, and for the Executive Secretary to review the trial bum results and make
any modifications necessary to the permit, the Permittee shall comply with the following
conditions:
Module VI - Page l6
VI.C.3.a.i..
VI.C.3.a.i.a.
VI.C .3 .a.i.a.3.i.
VI.C .3.a.t.a.3.ii.
VI.C.3.a.i.a.3. The Permittee may feed hazardous waste up to 100 percent of the agent trial burn
demonstrated feed rate provided;
TOCDF
Short-Terrn Incinerati on
October 2007
Limitation on Waste Feed
After successful completion of an agent trial burn, the Permittee may feed approved
hazardous waste to the MPF up to 50% of the feed rates demonstrated in the trial burn.
The Permittee may feed up to 75oh of the demonstrated feed rate after approval of
preliminary results by the Executive Secretary for the metals train, dioxin train,
parliculatelacid gas train(s), and Mustard DAAMS results, including a preliminary DRE
calculation.
Forton containers the Permittee shall comply with the feed rate limitations by adjusting
the charge weights and charge intervals such that the equivalent feed rate, on a pounds per
hour basis, does not exceed the applicable percentage of the trial burn demonstrated rate.
The post trial bum feed rates shall be calculated as follows:
Post ATB feed rate: (Charge WLtu * Charge InLu)* Pct: Charge Wtlostatb * Charge Intpostatb
Where:
Pct :Applicable post trial burn feed rate (i.e.,0.5 or 0 .75)
Charge Wtu6: Charge Weight demonstrated during the Agent Trial Burn
(pounds /charge).
Charge lntu6= Charge interval demonstrated during the Agent Trial Bum
(Charge/hour)
Charge Wtpo.t 6:Post ATB charge weight (pounds/charge); charge weight shall
not exceed maximum weight demonstrated during Agent Trial
Burn.
Charge Irrtposts-atu=Post ATB charge interval (charge/hour); charge time shall be the
greater ofthe result calculated from the equation above or the
minimumcharge timeof 42 minutes (35 minutes forZone 1 timer
plus 7 minutes for zone to zone tray transition time.)
The Permittee shall comply with the agent and halogen feed rate limitations by feeding 1)
less-than-full trays of projectiles at reduced feed intervals or, 2) full trays of projectiles at
extended feed intervals or 3) comply with the conditions specified in Module V.C.1 and
Y.C.2 for baseline ton containers. For Module V use, the Permittee will submit to the
Executive Secretary the Zone time and number of projectile per tray that equal the
limitation specified in Module V.C.l.d.i and the agent feed rate in V.C.1.a.i.
The Executive Secretary has previously approved the preliminary data referenced
in Condition VI.C.3.a.i.a;
The Permittee has submitted the Notification of Compliance required by Title 40
of the Code of Federal Regulations,Part 63, Subpart EEE to the Utah Division of
Air Quality;
Module VI - Page 17
VI.C.3.a.i..a.3.iv.
VI.C.3.a.i.a.3.v.
VI.C.3.a.i.b.
TOCDF
Short_rerm rnc"TJfs;
The Permittee has submitted revised Conditions V.C.l.a, V.C.l.d, Y.C.2,Table
Y.2, andrevised Attachment 19 Tables D-6-2 (Automatic Waste Feed Cut-Off
Table for MPF) that incorporate operating parameter limits (i.e., AWFCO limits)
identical to those specified in the Notification of Compliance for the regulated
operating parameters that are common to both this Permit and the Deseret
Chemical Depot Clean Air Act Title V Permit;
The Permittee has submitted the trial burn report and the Execr.ltive Secretary has
reviewed the Executive Summary included in the report.
The Permittee shall comply with the requirements of Conditions V.A. and V.C
whsn the requirements of Conditions VI.C.3.a.i.a.4 .i through VI.C.3.a.i.a.4.iv
have been fulfilled.
Only one type of chemical agent contained in munitions or bulk containers shall
be feed into the MPF, at any given time. Secondary waste generated during
different agent campaigns may be fed on the same tray provided a DRE for the
agent contaminating the wastes has been demonstrated to comply with the
performance standards specified in Conditions VI.A.3.a.i and the MPF exhaust
ducts, DAL and cornrnon stack are configured to monitor the agents
contaminating the wastes..
After successful completion of the Secondary Waste Dsmonstration Test, the Permittee
may feed waste at 50% feed rate listed in Table V.C.1. For each new waste itream, an
inspection and loading criterion shall be developed by the Permittee and approved by the
Executive Secretary for WlCs/containers containing potentially agent-contaminated
secondary wastes that are combustible, fibrous or porous (e.g., wood, paper, cardboard,
cloth, etc.) before these wastes are treated in the MPF and the following is met:
The Permittee shall configure each Secondary Waste load and inspection of each treated
load in accordance with waste load configurations and inspection criteria approved by the
Executive Secretary. The Permittee shall comply with this requirement by adhering to
waste load configurations/inspection criterion developed through function tests that are
performed to determine the optimum weight and load configuration for specific
combinations of secondary wastes fed on the same bum tray and to determine if the waste
is processed effectively.
VI.C.3.a.i.b.2 A function test shall be performed for each waste load configuration containing
combustible waste that differs from those previously tested because of either increased
weight or types of wastes placed on the burn tray.
VI.C.3.a.i.b.3 The Permittee shall provide notice to the Executive Secretary a minimum of seven days in
advance of conducting a function test. Following each function test, and prior to
implementation of resultant waste load configurations, DSHW shall provide written
approval that such waste load configurations may be utilized.
Upon approval by the Executive Secretary of preliminary results for the metals,
dioxin/furans, and particulate/acid train(s), the Permittee may feed secondary waste at
75o/o of the feed rate demonstrated during the Secondary Waste Demonstration Test for the
limiting parameters of halogens, ash, non-ernbedded metals, BTUs and carbon filter
VI.C.3.a.i..c.
Module VI - Page l8
Short-Term rr.rffi;3:
October 2007
cartridges. The Permittee shall include in the preliminary data submission arwisedTl%o
secondary waste feed rate table based on test results.
VI.C.3.a.i.c.1 Non-munition agent contaminated debris, Agent Collection System residues,
Quantification System maintenance residues, MDB process equipment, MDB HEPA
filters, MDB carbon filter trays, munitions overpack containers, discarded tools and the
non-munition wastes listed in Table2-5 in Attachment 2 (Waste Analysis Plan) may be
processed in the MPF after the associated agent trial bum period. Further function testing
for the non-munition waste is not required provided the following feed limits are not
exceeded:
WASTE DESCRIPTION
MAXIMUM FEED RATES
POUNDS
PER HOUR
CHARGES
PER HOUR
MAX.
POUNDS PER
CHARGEI
Hazardous waste as identified in Attachment?
(Waste Analysis Plan), Table 2-5
290 3 100
l. The charge weight limit and feed rate limit do not apply to overpack/overpack-sections, or to
steel objects, provided they are 1) fully disassembled, 2) have no obstructed crevices or volumes that may
entrap residual agent and 3) are fed individually to the MPF . Overpacks and steel objects discussed above
that weigh more than the above charge weight limit will be dismantled to the extent possible before
feeding to the MPF. Agent feed rate limits will be maintained as listed in V.C. I .a.i. if any liquid agent is
present in an overpack.
2. The MPF Discharge Airlock shall be iooled to less than 600" F prior to agent monitoring
VI.C.3.a.i.d. All non-munition wastes that envelop an interior space (e.g. gauges, cans, escape air tanks,
overpacks, glassware, etc.) must be opened or punctured before being placed in the MPF.
VI.C.3.a.i.e. The combustible wastes identified in VI.C.3.a.i.c. shall not be inside the MPF at the same
time the wastes identified in VI.C.3.a.i.a. are in this incinerator.
VI.C.3.a.i.f. The feed rate of halogens to the MPF shall be in accordance with Condition VI.C.3.a.i.a.
VI.C.3.a.i.g. The feed rate of ash to the MPF shall be in accordance with Condition VI.C.3.a.i.b.
VI.C.3.a.i.h Throughout the post-trial burn periods, the Permittee shall conduct analysis of the waste to
be treated in the MPF to veriff that the waste feed is within the physical and chemical
composition limits specified in Module V and Attachment 2 (Waste Analysis Plan). The
procedure shall follow the waste analysis requirements in the trial bum plan and
Attachments 2 (Waste Analysis Plan) and 3 (Sampling, Analytical, and QA/QC
Procedures) for agent and other hazardous waste.
VI.C.3.a.i.i. Reserved.
VLC.3.a.ij ln accordance with an approved trial burn plan; the Permittee shall demonstrate
compliance with the Performance Standards in Condition V.A.2. for the highest rate at
which it will feed waste to the MPF.
Module VI - Page 19
Short-Term ,"",ffi;3:
October 2007
VI.C.3.a.ii. OperatingConditions
VI.C.3.a.ii.a. The Permittee shall not treat any hazardous waste in the MPF during the post-trial burn
period unless the MPF system is operating in compliance with Condition VI.C.1.b.
excluding the feed rates in Conditions VLC.1.b.i.c. and VI.C.I.b.i.r.
VI.C.3.a.iii. WasteFeedCut-OffRequirements
VlC.3.a.iii.a. The Permittee shall comply with the waste feed cut-off instrument settings specified in
Attachment 19 (lnstrumentation and Waste Feed Cut-Off Tables).
VI.C.3.a.iii.b. In the event of a malfirnction of a MPF automatic waste feed cut-off instrument as
specified in the approved trial burn plan, the Permittee shall immediately manually cut off
the waste feed to the MPF and correct the malfunction prior to resuming waste feed. The
Permittee shall record in the Operating Record any waste feed cut-off system
malfunctions, the time of the malfunction, the time of resuming waste feed, the apparent
cause of the malfunctions, and specific steps taken to repair the malfunction and avoid
similar future malfu nctions.
Vl.C.3.a.iii.c. All instrumentation shall be maintained and tested in accordance with Condition V.A.4.
VI.C.3.a.iv. MonitoringRequirements
VI.C.3.a.iv.a. The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VLA.4.a and V.A.1.h.i.
vr.D. DEACTTVATTON FURNACE SYSTEM (DFS)
VI.D.l. SHAKEDOWN
VI.D.I .a. Allowable Waste Feed
VI.D.1.a.i. During the Shakedown Periods, the Permittee shall limit the hourly feed of agent and ECR
maintenance residue to the DFS to that specified in the DFS Agent Trial Burn Plan
specific to the agent being processed.
VI.D.I.a.ii. The Permittee shall not feed the following wastes to the DFS, during the Shakedown
Period:
VI.D.1.a.ii.a. Hazardous Wastes F020 through F023,F026, andFO2l.
VI.D.1.a.iii. The feed rate of chlorine to DFS shall not exceed 8.4 pounds total in a twelve hour rolling
average period during the agent shakedown periods.
VI.D.I.a.iv. The hourly feed rate of the residual chemical agent contained in the DFS feed, which was
calculated using a 5o/o agentheel, shall not exceed the limits provided in the approved trial
burn plan.
VI.D.1.a.v. Changes to the DFS shall be certified as specified in Condition I.S.
Module VI - Page20
Short-Term rr.,f*:31
October 2007
VI.D.I.a.vi. Throughout each Shakedown Period, the Permittee shall conduct waste analysis in
accordance with the approved trial burn plan and Attachments 2 (Waste Analysis Plan)
and 3 (Sampling, Analyical, and QA/QC Procedures) for agent and other hazardous
waste.
VI.D.l.a.vii. The Permittee shall determine waste codes for each waste stream as specified in
Attachment 2 (Waste Analysis Plan).
VI.D.1.b. OperatingConditions
VLD.1.b.i. During the shakedown periods, the Permittee shall operate the DFS furnace system in
accordance with the approved trial burn plan and the following conditions:
VI.D.I.b.i.a. The Permittee shall monitor emissions from the DFS duct and the coflrmon stack for
chemical agent as specified in Condition VI.A.4.a. The waste feed to the incinerator shall
be automatically cut off if any of the monitored emission levels exceed the values
specified in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
VI.D.1.b.i.b. The number of munitions units fed to the DFS in one hour shall not exceed the limit
specified in Condition V.D.l.a.
VI.D.I.b.i.c. The temperature of the unquenched DFS rotary kiln exhaust gas shall be maintained at or
above 954o F, over a one-hour rolling average.
VLD. 1 .b.i.d: Th" temperature of heated discharge conveyor shall be maintained at or above 1 ,000o F.
VI.D.I.b.i.e. The DFS secondary cornbustion chamber temperature shall be maintained at or above
2065" F, over a one-hour rolling average, but shall not exceed 2,400o F.
VI.D.I.b.i.f. The rate of movement of the heated discharge conveyor shall be controlled so as to
provide a minimum solid retention time of 15 minutes inside the heated enclosure.
VI.D.1.b.i.g. The rotational speed of the retort shall be maintained within the following parameters:
VI.D.I .b.i.g. 1 . The speed shall not exceed two revolutions per minute (rpm);
VI.D.I .b.i.g.2. Except when in oscillation mode, the speed shall not drop below 0.33 rpm;
VI.D.1.b.i.g.3. Hazardous waste may not be fed to the DFS while the retort is in oscillation mode except
as provided in Attachment 19 (Instrumentation and Waste Feed Cut-off Tables).
VI.D.1.b.i.h. Carbon monoxide concentration at the exhaust blower exit, correct ed to 7o/o oxygen in
accordance with the formula specified in Condition V.A.2.e., shall not exceed 100 ppm
dry volume over a one-hour rolling average.
VI.D.1.b.i.i. DFS exhaust gas flow rate, or unit production rate (as measured by the V-Cone), shall not
exceed 13,210 standard cubic feed per minute, over a one-hour rolling average.
VI.D.1.b.ij. The gas flow of the DFS shall be maintained between 22,000 and 40,000 ACFM at the
exit of the exhaust blower. This parameter is measured during the Trial Burn Period.
Module VI - Page 2l
Short-Term ,"",H;3:
October 2007
VI.D.1.b.i.k. Oxygen concentration at the exhaust blower exit shall be maintained at or above 3o/o,but
shall not exceed l5o/o on a dry volume basis.
VI.D.I.b.i.l. The Permittee shall control fugitive emissions from the combustion zone of the DFS by
maintaining the pressure in the kiln below the pressure of the DFS furnace room.
VLD.1.b.i.m. Quench tower exhaust gas temperature shall not exceed 225" F .
VLD.I.b.i.n. Exhaust gas pressure drop across the venturi scrubber shall be maintained above 30*
inches of water column, over a one-hour rolling average.
VI.D.I .b.i.o. Quench brine feed rate to the venturi shall be at or above 3 10 gpm, over a one-hour rolling
average with a liquid delivery pressure at or above 40 psig.
VI.D.I.b.i.p. Clean liquor feed rate to the scrubber tower shall be maintained at or above 800 glm, over
a one-hour rolling average.
VLD.1.b.i.q. Clean liquor pressure to the scrubber tower shall be maintained at or above 35 psig, over a
one-hour rolling average.
VI.D.1.b.i.r. The pH of the quench brine shall be maintained at 8.7 or above, over a one-hour rolling
average.
VI.D.1 .b.i.s. Quench brine effluent specific gravity shall not exceed 1 . 10 specific gravity units, over a
twelve-hour rolling average.
VI.D.I.b.i.t. The Permittee shall continuously monitor and control the emissions from the DFS system.
The emission levels from each monitoring system shall not exceed the Chemical Agents
Emission Limits specified in Condition VI.A.3.a.
VI.D.I.b.i.u. The temperature of the quenched DFS rotary kiln exhaust gas, shall not exceed 1,650o F.
VI.D.I.b.i.v. Reserved
VI.D.1.b.i.w. Toxic metals emissions shall.be controlled by limiting the agent and agent contaminated
waste feed rates to the fumaces. DFS non-embedded metals feed limits are in Table V.3
in Module V. Non-embedded metals feed shall be determined using procedures specified
Attachment 2 (Waste Analysis Plan).
VI.D.I.c. Waste Feed Cut-Off Requirements
VI.D.1.c.i. The Permittee shall identiff the waste feed cut-off instruments in each individual trial bum
plan. The Permittee shall identiff the instrument number, the operating parameter, and the
set point. When the waste feed cut-off tables for the DFS are approved as part of the
revised trial bum plans, the waste feed cutoff TAG identification numbers and associated
set points shall be incorporated into Attachment 19 (Instrumentation and Waste Feed Cut-
off Tables).
Module VI - Page 22
Short-Term,r",ffi;3:
October 2007
VI.D.I.c.ii. In the event of a malfunction of a DFS automatic waste feed cut-off instrument identified
in the approved trial bum plan, the Permittee shall immediately manually cut off the waste
feed to the DFS and correct the malfunction prior to resuming waste feed. The Permittee
shall record in the Operating Record any waste feed cut-off system malfunction, the time
of the malfunction, the time of resuming waste feed, the apparent cause of the
malfunction, and specific steps taken to repair the malfunction and avoid similar future
malfunctions.
VI.D.I.c.iii. All instrumentation shall be maintained and tested in accordance with Condition V.A.4.
VI.D.1.d. MonitorineRequirements
VI.D.I.d.i. The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VI.A.4.a and V.A.1.h.i.
VI.D.I.e. lnspectionRequirements
VLD.1.e.i. The Permittee shall comply with the lnspection Requirements specified in Condition
v.A.3.
VI.D.I.f. Recordkeeping
VLD.1.f.i. The Permittee shall comply with the recordkeeping requirements as specified in Condition
v.A.6.
VI.D.I.f.ii. Every time ECR residues are fed to the DFS the following information shall be recorded
and kept on file in accordance with R315-8-5.3:
VI.D.1.f.ii.a. The exact weight of the waste.
VI.D.1.f.ii.b. The location of the waste feed identified as Line A or Line B chute.
VI.D.1.f.ii.c. A brief description of the waste.
VI.D.I.f.ii.d. The date and time the waste was fed to the DFS.
VI.D.2. TRTAL BURN PERIOD
VI.D.2.a. The Permittee shall operate and monitor the incinerator during the trial burn period as
specified in each of the trial burn plans approved by the Executive Secretary. Each trial
burn plan shall include procedures to insure that the data critical for conducting a risk
assessment (e.g. dioxins/furans, metals, agent, etc.) meet the standards in the quality
control plan accompanyrng the trial burn plan.
VI.D.2.b. Trial Burn Determinations
VI.D.2.b.i. The Permittee shall make the performance determinations specified in Condition VI.A.3.a.
during the trial bum tests.
O VI.D .2.c. Monitoring Requirements
Module VI - Page 23
VI.D.2.c.i.
VI.D.3.
VI.D.3.a.
TOCDF
Short-Term Incineration
October 2007
All emission monitoring will follow the requirements as specified in Condition VI.A.4.a.
and V.A.l.h.i.
POST-TRIAL BURN PERTOD
VI.D.3.a.i.
VI.D.3.a.i..a.
During the post trial burn periods in accordance with R315-8-15.5(c)(3) and for the
minimum period sufficient for the Permittee to analyze samples, compute data, and submit
trial burn results, and for the Executive Secretary to review the trial bum results and make
any modifications necessary to the permit, the Permittee shall comply with the following
conditions:
Limitation in Waste Feed
After successful completion of an agent trial bum, the Permittee may feed permitted
hazardous waste to the DFS up to 50% of the chemical agent and combined Propellant,
Explosive, and Pyrotechnic (PEP) feed rates demonstrated during the trial bum. The
Permittee may process tp to 75oh of the demonstrated agent and PEP feed rates after
approval of preliminary results by the Executive Secretary for the metals train, dioxin
train, particulate/acid gas train(s), and VX DAAMS results, including a preliminary DRE
calculation. Full feed rates may be incorporated into Module V after the final report has
been reviewed and approved by the Executive Secretary.
VI.D.3.a.i.b. Only one tlpe of chemical agent (e.g., GB or VX) shall be burned in the DFS at any given
time. The Permittee shall follow the requirements of R315-3-4 prior to simultaneous
processing of multiple munition types.
VI.D.3.a.i.c.The Permittee may only treat those ECR maintenance residues listed in Table}-Za of
Attachment 2 (Waste Analysis Plan). The maintenance residue feed rate shall be limited
to 50Yo of the agent feed rate demonstrated during the Trial Bum Period. This residue
weight is assumed to be agent. The maximum drop weight shall not exceed 50% of the
maximum agent drop weight demonstrated during the trial burn. The Permittee may
increase the feed rate and drop weight of maintenance residue to 75oh of the agent feed
rate and drop weight demonstrated during the trial burn after the Executive Secretary
approves the preliminary results specified in Condition VI.D.3.a.i.a. The kiln speed shall
not exceed one rpm for a minimum of l5 minutes after the feed of maintenance residues.
The HDC shall be placed in slow speed for a minimum of one hour after the last feed of
ECR maintenance residues.
VI.D.3.a.i.d. The feed rate of chlorine to DFS shall not exceed three pounds per hour during the agent' post-trial burn periods.
VI.D.3.a.i.e.Throughout the post-trial burn periods, the Permittee shall conduct analysis of the waste to
be treated in the DFS to verifu that the waste feed is within the physical and chemical
composition limits specified in Module V and Attachment 2 (Waste Analysis Plan). The
procedure shall follow the waste analysis requirements in Attachments 2 (Waste Analysis
Plan) and 3 (Sampling, Analytical, and QA/QC Procedures) for agent and other hazardous
waste.
Module VI - Page 24
TOCDF
Short-Term Incineration
October 2007
VI.D.3.a.i.f. 'ln
accordancE with an approved trial burn plan, the Permittee shall dernonstrate
. compliance with the Performance Standards in Condition Y.A.2. for the highest rate at
which it will feed waste to the DFS.
VLD.3.a.ii. OperatingConditioris
VI.D.3.a.ii.a. ' The Permittee shall not treat any hazardous waste in the DFS during the posttrial burn
period unless the DFS system is operating in compliance with Condition VI.D.1.b.,
excluding the feed rates in Conditions VLD.1.b.i.b. and VI.D.1.b.i.w.
VI.D.3.a.iii. WasteFeed Cut-OffRequirernents
Vl.D.3.a.iii.a. The Permittee shall comply with the waste feed cut-off instrument settings specified in the
approved trial bum plan.
Vl.D.3.a.iii.b. In the event of a malfunction of a DFS automatic waste feed cut-off instrument as
specified in the approved trial burn plan, the Permittee shall immediately manually cut off
the waste feed to the DFS and correct the malfunction prior to resuming waste feed. The
Permittee shall record in the Operating Record any waste feed cut-off system
malfunctions, the time of the malfunction, the time of resuming waste feed, the apparent
cause of the malfunctions, and specific steps taken to repair the malfunction and avoid
similar future malfunctions.
Vl.D.3.a.iii.c. All instrumentation shall be maintained and tested in accordance with Condition V.A.4.
O VI.D.3.a.iv. Monitoring Requirements
VI.D.3.a.iv.a. The Permittee shall maintain and calibrate the monitoring and recording equipment as
specified in Condition VI.A.4.a and V.A.1.h.i.
].
, Module VI - PageZl')'
TOCDF
Short-Tenn Incinerati on
October 2007
VI.E. AREA 10 LIOUD INCINERATOR (ATLIC)
VI.E.T. SHAKEDOWN
VI.E.1.a. Allowable Waste Feed
VI.E.l.a.i. Durins the shakedown periods. the Permittee shall limit the hourly feed of hazardous and
non-hazardous wastes. decontamination solutions and aqueous liquid wastes to the ATLIC
VI.E.I.a.ii. The Permittee shall not feed the followine wastes to the ATLIC during the Shakedown
Periods.
VI.E.I.a.ii.a. Hazardous Wastes F020 throueh F023. F026. and F027.
VI.E.I.a.ii.b. Anv wastes containine Bolychlorinated biohenyls.
'
feed rate of chlorine to
rates in each trial burn plan for the shakedown and trial buffi-iieriods.
VI.E.1.a.iv. Decontamination solution with the F99/waste code. and other apolicable waste codes.
may be fed to the secondary chamber of the ATLIC during the shakedown oeriod only if
itions soecified i ition VI.E.I.b. are satisfied and theAutomatic
with the exceDtion of those AWFCO set-Doints sDecified in Conditi
VI.E.1.a.v. Chanees to the ATLIC shall be certified as snecified in Condition I.S.
VI.E.I.a.vi. Throushout the shakedown periods. the Permittee shall conduct waste analysis in
accordance with the approved trial burn olan and Attachments 2 (WaSte Analysis Plan)
and 3 (Sampline. Analytical. and OA/OC Procedures) for ag€nt and oth€r hazardous
waste.l?a u66t4*b
VI.E.1.a.vii. The Permittee shall determine waste codes for each waste stream as specified in
Attachment 2 (Waste Analysis Plan).
VI.E.l.a.viii e Permittee shall not besin the Shakedown Period associat e Lewisite
Comorehensive Performance Test (LCPT) unless'the Executive
the preliminary data for the ATLIC SurroESG Trial Burn.
VI.E.1.a.ix. Prior to beernnins the Shakedown Period associated with the LCPT the Permitee shall
develoo the AWFCO setpoints for Minimum Primary Combustion Chamber (PCC)
Temperature. Minimum Secondary Combustion Chamber (SCC) Exhaust Gas
Temperature. Maximum PCC Waste Feed Rate. Maximum SCC Waste Feed Rate. and
Maximum Exhaust Gas Flow Rate from process data qenerated during the ATLIC STB
oer the methodology specified in 40 CFR 63.1209.
M.E.l.a.ix.a If the Permittee provides to the Executive Secretary a revised Attachment 19. Table D-8-2
that incomorates the AWFCO set-ooints referenced in Condition VI.E.l.a.ix prior to the
e
L,l p,t, l
Module VI - Page 26
: TOCDF
Short-Term Incineration
October 2007
initiation of the Lewisite Comprehensive Performance Test (CPT) Shakedown Period and
k"do*n. Tot. *d Port-t'ot poiod, *ith th"."
same AWFCO set-points in effect then the Permittee is not required to demonstrate a
Destruction and Removal Effrciency (DRE) for Lewisite during the LCPT.
VlE.l.a.ix.b If the Permittee does not provide the Executive Secretary a revised Table D-8
incomoratine the AWFCO set-points referenced in Condition VI.E.l.a.ix. prior to the
initiation of the LCPT Shakedown Period and instead operates the ATLIC throuehout the
Shakedown. Test. and Post-Test periods with one or more of the AWFCO set-points
specified in Permit Conditions VI.E.l.b.i.b throueh VI.E.1.b.i.e. and VI.E.1.b.ij. then the
Perqittee shall demonstrate a DRE for Lewisite durine the LCPT.
VI.E.l.a.r The Permittee shall nerform a Mini-Burrr consisting of a minimum of one run
durins which:
YI.E.l.a.x.a. The feed rate of Lewisite to the ATLIC shall not exceed 50%o of the rate srecified in
the aporoved Lewisite Trial Burn Plan. The Speirt Decon feed rate shall not exceed
1007o of the rate specified in the approved Lewisite Trial Burn Plan.
VI.E.1.a.x.b. Particulate and metals shall be collected as ed in the
aDDroved Lewisite"Trial Burn Plan
VI.E.l.a.rc" The ash and metal feed rates to the ATLIC shall be quantified in a manner to allow
for a particulate and metal removal efficiencv to be determined.
VI.E.1.b. OperatingConditions \ ,' .
VI.E.I.b.i. During the shakedown periods. the Permittee shall operate the ATLIC fumace system in
accordance with the aoproved trial burn plans and the followins conditions:
VI.E.I.b.i.a. The Permittee shall monitor emissions from the ATLIC PAS stack for chemical asent as
, specified in Condition VI.A.4.a. The waste feed to the incinerator shall be automatically
' @ emission ler"ls
"xceed
the',ralues soecified in Attachment
VI.E.I.b.i.b. The ma,tiffiih waste feed rate to the ATLIC primary combustion chamber shall not
"*"",,*1"
VI.E.1.b.i.c. .'The maxi rate to the ATLIC secon combustion chamber shall not
reach or ex ounds over a one-hour rollin
VLE.I.b.i.e. Secondarycombustion chamber exhaust eas temperature shall be maintained at or above
1.850*" F. over a one-hour rolline average.
VI.E.l.b.i.f. Atomizins air pressure for the waste burner nozzles. for both chemical aeent and
decontamination solution shall be maintained at or above the following set points:
/;
VLE.I.b.i.d. ' Primary combustion chamber eihaust gas tanperature shall be maintained at or above' 2.550*" F. over a one-hour roJlipg average.
Module VI - Page 27
TOCDF
Short-Teffn Incineration
October 2007
VI.E.I.b.i.e. PrimaryCombustion Chamber. All Feed Rates (1-100%o) - 35t psie.
VI.E.I.b.i.h. Secondary Combustion Chamber. All Feed Rates (1-100%o) - 35* osig.
VI.E.I.b.i.i. The Permittee shall control fugitive ernissions from the combustion zone of the ATLIC by
VI.E.l.b.ij. ATLIC exhaust eas flow rate or unit production rate (ps measured by in$trument 819-FIT-
8932 and corrected to standard conditions) shall not exceed 2=5e0 960* standard cubic
fu per minute. over a one-hour rolling average.
VI.E.1.b.i.k. Scrubber liquid feed rate to each scrubber tower shall be maintainod above 40+ eallons p€r
minute. over a one-hour rolling averase and deliv€ry pressure shall be maintained above
25t Bsie.
VI.E.I.b.i.l. The oressure drop across,each oack bed scrubber tower shall not maintained above 0.3 *
inches otwater column over a one-hour rollins averaee
VI.E.1.b.i.m. The average of the scrubber liquid oH as measured by the three pH orobes in the common
scrubber sumo shall be maintained above a oH of 7.0 iover a one-hour rolling average.
iouid effluent shall
uiiits.-ove,f a twelve hour rolline av€raee.
VI.E.I.b.i.o. The Veirturi Scrubber liquid oH shall be maintained above a pH of 7.0 fovar a one-hour
rolling averaee.
VI.E.I.b.i.p. Venturi Scrubber Sump liquid effluent shall not reach or exceed 1.28* specific gxavity
units. over a twelve hour rollins average.
VI.E.I.b.i.q. Exhaust cas pressure droo across the venturi scrubber shall be maintained above 12 *
inches of water column over a one-hour rolling average.
VI.E.I.b.i.r. Scrubber solution feed rate to the venturi scrubber shall be maintained above 8* gallons
oer minute over a one-hour rollins averase and delivery pressure shall be maintained
above 25* osie.
ivated carbon iniecti n rate to s
per hour over an hour rolling average.
VI.E.1.b.i.t. The Bowdered activated carbon carrier fluid (compressed air) diffrentialBresoure shall be
maintained above 15 standard cubic feet per minute M
over a one-hour rolline average.
VI.E.I.b.i.u. The temoerature of exhaust eas enterine the baehouse shall not exceed 240*oF over a one-
hour rolline average.
VI.E.1.b.i.v. The differential pressure across the baghouse filter elements shall be maintained above 0.1
inches of watqr column over a one-hour rolline averaee.
Module VI - Page 28
VI.E.I.b.i.aa. Toxic metals emissions shall be controlled by limitine the agent and ag€Nrt contaminated /
*urt" f".d *t", tp th" fu^u..r;tllc ,o"tul, f".d ti*itr "r" in rubG
-vJ
in tvtod,rl. v. 5
trtetdr fe"O rtrAt U" A"ternrined wine proc"dure. tpe"ified in Atdchm*;tnM;F- (
A""tyttt Pt""\ )
TOCDF
Short-Term Incineration
October 2007
VI.E.I.b.i.w. Oxyeen conc€ntration in the exhaust blower exit eas. shall be maintained above 3 %t but
shall not exceed l5olo oxyeen on a drv volume basis.
VI.E.I.b.i.x. Carbon monoxide in the exhaust blower exit gas. shall be correcied to 7 % oxygen in
accordance with the formula specified in Condition V.A.2.e.. and shall be maintained
below 100* ppm. dry volume. over a one-hour rolling averaee.
VI.E.I.b.i.y. The differential oressure across the onJine fixed bed carbon filter shall be maintained
above 0.3 inches of water column over a one-hour rolline average.
VI.E.I.b.i.z. The temperature of e,xhaust eas enterine the fixed bed barbon filter shall not exceed
240*oF over a one-hour rolling averaee.
VLE.1.c. WasteFeedCut-OffReouirements
VI.E.l.c.i. The Permittee shall identi& the waste feed cut-off instrumeirts in each individual trial burn
plan. The Perrnittee shall identi& the instrument number. the operatine param€t€r. and the
set point. Whelr the waste feed cut-off tables for the ATLIC are approved as oart of the
revised trial bum plans. the waste feed cut-offTAG identification numbers and associated
set points shall be incorporated into Attachment 19 (lnstrumentation and Waste Feed Cut-
offTables).
VI.E.l.c.ii. In the event of a malfunction of an ATLIC automatic waste feed cut-offinstrument
identified in the approved trial burn plan. the Permittee shall funrnediately rnanually cut off
the waste H to the ATLIC and correct the malfunction prior to resuming waste fM.
The Permittee shall record in the Operatine Record any waste feed cut-off systern
malfunction. the time of the malfunction- the time of resunrine waste feed. the aoparent
cause of the ma$unction. and specific steps taken to repair the malfunction and avoid
similar future malfunctions.
VI.E.l.c.iii. All waste feed cut-off instruments shall be maintained and tested in accordance with
Condition V.A.4.
VLE.1.d. MonitoringRequirernents _
j
VI.E.I.d.i. The Permittee shall maintain and calibrate the monitoringand recording equipment as {ro."ifi-"d- it, cooditioo Yte.+.u *d v.e. t.t .i. --l
VI.E.2. TRIAL BURN PERIOD
VI.E.2.a. The Permittee shall operate and monitor the incinerator during the trial burn period as
specified in each of the trial bum plans approved by the Executive Secretary.
Module VI - Page}9
Short-Term rr"rH:3l
October 2007
VI.E.2.b.i. The Permittee shall make the performance determinationi during the trial bum tests as
specified for the ATLIC oer Condition VI.A.3.a.
VJ.E.2.c. Monitoring Requirements
VI.E.2.c.i. All continuous emission monitoring will follow the requirernents as specified in Condition
VI.E.3.
VI.A.4.a and V.A.l.h.i.
POST-TRTAL BURN PERIOD
VI.E.3.a. Durine the Bost trial burn Beriods in accordance with R3 l5-8-15.5(cX3) and for the
minimum period suffrcient for the Permittee to anallze samDles. compute data. and submit
trial burn results. and for the Executive Secretary to review the trial burn results and rnake
any modifications necessary to the permit. the Permittee shall comply with the followine
. sonditions:
VI.E.3.a.i. Limitation on Waste Feed
VI.E.3.a.i.a. After successful comoletion of the ATLIC Surrosate Trial BurrL the Permittee may feed
Agent GA. associated GA Ton Container Rinsate and spent decontamination solutions to
theATLIQ
orovided:
VI.E.3.a.i.a.1 . The Permittee has submitted data from the ATLIC Surroeate Trial Burn to include results
iculate/acid qas train(sS
calculations. and ){"
VI.E.3.a.i.a.2. The Executive Secretary has approved the ATLIC Sufrogate Trial Burn Preliminary Data,
YI.E.3.a.i.a.3 The feed rate of GA to the ATLIC Primarv Combustion Chamber does not exceed
507o of the combined Princinle Orsanic Hazardous Constituents Primarv
Combustion Chamber feed rate demonstrated durine the trial burn.
VI.E.3.a.i.a.4 The feed rate of GA Ton Container Rinsate and spent decontamination solutions to
. the ATLIC Secondarv Combustion Chamber does not exceed 1007o of feed rate
, . demonstrated during the trial burn.
VI.E.3.a.i.a.5 The oreanic content of the wastes fed to the ATLIC Secondarv Chamber do not
exceed 507o of that demonstrated durine the trial burn.
YI.E.3.a.i.a.6 The feed rate of ash to the ATLIC Primarv and Secondarv Combustion Chambers
does not exceed 100%o ofthe ash feed rate demonstrate durins the trial burn. and
VI.E.3.a.i.a.7 The metals feed rates do not exceed 507o of the metals feed rates demonstrated
durine the trial burn.
After successful comoletion of theATLIC Lewisite Asent Trial Bum the Permittee ma
iiocess Lewisite. and sBent decontamination solution which is cominsled with the
Lewisite and/or Transparencv Ton Container water rinses at ffi
Module VI - Page 30
VI.E.3.a.i..b.
r#:ertui;#W #fi#
ffi feed rates demonstrated durine the Lewisite Mini-
BurnTiolBum provided:
VI.E.3.a.i.b.l. The Permittee has submitted data from the Lewisite Tiol*um*ssoeiakC Mini-Burn and
the results show that when orocessine Lewisite and spent decontamination solution at
the Mini-Burn iatended demonstrated feed rates that metal and particulate emi
cbncentrations are less than the values specified in Permit Condition VI.A.3.a.i.
ien*
i
DA"AA4S-. Reserved
VI.E.3.a.i.d. The Permittee may feed up to 75% pf the ATLIC Lewisite Aeent Trial Bum dernonstrat€d
feed rate after aoproval of the ATLIC LIC Lewisite Agent Trial Burn oreliminary results
by the Executive Secretary for the metals train. dioxin hain. and particulatdacid eas
train(s).
VI.E.3.a.i.e. Only one type of chemical aee,nt shall be bumed in the ATLIC at any siv€n time.
VI.E.3.a.i.f. Aeent GA and Lewisite may be fed to the ATLIC during their respective oost trial burn R e --,r a r {
oeriods only if the operating conditions specified in Condition VI.B.3.a.ii. are satisfied and S'1o"
the waste feed cut-offlimits specified in the trial burn plans are in effect.
VI.E.3.a.i.e. The Permittee shall not incinerate the miscellaneous asent contaminated liquid wastes in
the ATLIC secondary combustion chamber exceot as allowed in Attachment 2 (Waste
Analysis Plan).
VI.E.3.a.i.h. The feed rate of chlorine to ATLIC shall be in accordance with VI.E.3.a.i.a through
VLE.3.a.i.d respective to the agent being orocessed.
VI.E.3.a.i.i. Throuehout the nost-trial bum p€riods. the Permittee shall conduct analysis of the waste to
be treated in the ATLIC to verify that the waste feed is within the physical and chemical
comoosition limits specified in Module V and Attachment 2 (Waste Analysis Plan). The
procedure shall follow the waste analysis requirsrnents in the trial burn olan and
Attachments 2 (Waste Analysis Plan) and 3 (Samplins. Analytical. and OA/OC
Procedures) for agent and other hazardous waste.
VI.E.3.a.ij The Permitee may feed hazardous waste up to 100 oercent of the trial burn demonstrated
feed rates provided:
'VI.E.3.a.ij.1 The Executite Secretarv has previously approved the preliminary data referenced in
VI,E.3,.a.ij.2 ThePenrrittee ha.s s}&mitted the Notification of Compliance required by Title 40 of the
: : Code of Federal Regulations. Part 63. Subpart EEE to the Utah Division of Air Oualitv:
Module VI - Page 3l
TOCDF
Short-Terrn Incineration
October 2007
VI.E.3.a.i..The Permittee has submitted revised Conditions V.E. I .a. V.E. I .d. V .8.2. Table V. I and
revised Attachment 19 Tables D-8-2 (Automatic Waste Feed Cut-off Table for the
ATLIC) that incorporate operatine oarameter limits:
VI.E.3.a.ij.4 The Permittee has submitted the trial bum reports and the Executive Secretary has
reviewed the Executive Summary included in the report.
VLE.3.a.ij.5 The Permittee shall comply with the requirements of Conditions V.A and V.E. when the
requirements of Conditions VI.B.3.a.i.k.2 through VI.B.3.a.i.k.4 have been fulfilled.
VI.E.3.a.ii. Operatine Conditions
VI.E.3.a.ii.a. The Permittee shall not treat an), hazardous waste in the LIC durine the post-trial bum
period unless the s)rstern is operating in compliance with Condition VI.E.I.b.. excluding
the feed rates in Conditions VI.E.1.b.i.),.
VI.E.3.a.iii. WasteFeedCut-OffRequirernents
Vl.E.3.a.iii.a. The Permittee shall comply with the waste feed cut-offinstrument settings specified in
e-*trn* tq (h.--*"i"..
Vl.E.3.a.iii.b. ln the event of a malfunction of a ATLIC automatic waste feed cut-offinstrument as
, sDecifid-intheapprovedtrial-bumptan. the Permittee shall immediately manually cut off
the waste feed to the ATLIC and correct the malfunction prior to resuming waste feed.
The Permittee shall record in the Ooeratine Record any waste feed cut-off system
malfunctions. the time of the malfunction. the time of resumine waste feed. the apparent
cause of the malfunctions. and specific stsps taken to repair the malfunction and avoid
similar future malfu nctions.
Vl.E.3.a.iii.c. All instrumentation shall be maintained and tested in accordance with Condition V.A.4.
tested to the frequency specified in Condition V.E.3.c using the methods soecified in
Attachment 6.
VI.E.3.a.iv. MonitorineRequirements
Vl.E.3.a.ivra. The Permittee shall maintain and calibrate the monitorine and recordine eouipment as
specified in Condition JI.A.4.a. and V.A. 1 .h. i.
Module VI - Page 32
oa-
F.
o
oo
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
MODI]LE YItr
MISCELLAI\EOUS TREATMENT TINITSo,--
VIII.A. APPLICABILITY
VItr.A.1. The requirements of this module pertain to the miscellaneous units described in
Attachment 14 (Miscellaneous Treatment Units) and listed below in Conditions VIII.A.l.a
through VtrI.A.1.f.
VtrI.A.l.a. Two Drum Ventilation System (DVS) Enclosures located iri OCO Area l0 Igloo 1632
Vm.A.1.b. Two Prqjectile/l\dortar Disassernbly Machines (PMDs) located in the ECRs.
VItr.A.1.c. ,Three Multipurpose DemilitarizationMachines (MDMs) and the associated Pick and
Place Machines (PKPLs) located in the Munitions Processrng Bay (MPB).
VItr.A.1.d. Two Bulk Drain Stations (BDSs) located in the MPB.
VItr.A.1.e. One Drum Ventilation System Sorting Room (DVSSR) located in DCD Area l0 Igloo
1632.
VItr.A.l .e. 1 Prior to hazardous waste operations in this Igloo, standard operating procedures must be
submitted to the Executive Secretary for initial evaluation.
VtrI.A.l.f. One Air gperated Remote Ordnance Access System{Cutter Machine), which can be
located in either ECR, or in the MPB.
VIII.A. 1 .fg One AutoclavJ fo, tt
"
treatrirent of Secondary Waste located in DCD Area 10 Igloo 1 63 1 .
VIII.A.1.fg.l Prior to hazardous waste operations in this Igloo, standard operating procedures must be
' submitted to the Executive Secretary for initial evaluation.
VtrI.A.1.h. Two ATLIC Gloveboxes located in DCD Area l0 Ieloo 1639 @
@
VIILA.1.i. Reserved
-' Vil.A.Z The Permittee may feed uncut busters from M104, M110, mustard 155mm projectiles and
. 4.2" HT mortars to the DFS.
VIII.B. ALLOWABLE WASTE F'EED
Vm B.1. Reserved
VIII.B.2. The Permittee may treat 155-mm projectiles, and 4.Zinch mortars (hazardous waste codes
P999,D002, D003, D004, D006 through D010, D028, D034, and D039) in the PMDs and
the MDMsiPKPLs to comply with rates specified in Modules V and VI for the DFS and
MPF.
Module VIII - Page I
VIII.B.7. Waste treated in the ATLIC Gloveboxes shall be limited to the Aeent GA. Lewisite. and
"Transparency''ton containers with one more of the followine waste codes: P999. F999.
D002. D003. D004. D007. D008. D009. D010. and D021.
VIII.B.3.
VIII.B.4.
VIII.B.5
VIII.B.6
V[I.C.
VIII.C.1 .
v[I.c.2.
VIII.C.3.
VIII.D.
VIII.D.1 .
VIII.D.2.
DemilitarizationMiscellaneorrr."r*1lOr!,lrl
June 2009
The Permittee may treat ton containers, (hazardous waste codes P999,D002, D003, D004,
and D006 through D010, D028, D034, and D039) in the BDSs to comply with rates
specified in Modules V and VI for the MPF.
The Permittee is prohibited from treating waste in the miscellaneous units, identified in
Condition VtrI.A.1 that is not identified in Conditions VIILB.2, VIILB.3, VItr.B.5 and
VtrI.B.6.
Wastes treated in the DVS Enclosures and the DVSSR shall be limited to TOCDF-
generated secondary wastes with the following waste codes P999, F999, D002, D003,
D004, D005, D006, D007, D008, D009, D010, D011 and F001-F005 for TOCDF-
originated laboratory sample waste.
Waste treated in the Autoclave shall be limited to secondary waste with the following
waste codes:P999, F999, D002, D003, D004, D005, D006, D007, D008, D010 and D011
after approval.
IGNITABLE AIID INCOMPATIBLE WASTES
Ignitable wastes (D001) shall not be treated in the ECRs or MPB.
The Permittee shall place only munitions or bulk containers with one type of chemical
agent (e.g., GB, VX or Mustard) in the MPB at one time. Only one chemical agent may
be placed in the ECRs.
The Permittee shall not place chemical agent or munitions containing that chemical agent
in a container that previously held a different chemical agent or munitions containing a
different chemical agent until the container has been decontaminated to less than 1 VSL.
The Permittee shall comply with the design and operating requirements specified in
Attachment 14 (Miscellaneous Treatment Units) of the Permit.
The Permittee shall comply with the requirements specified in the Attachment 9
(Contingency Plan) when there has been a release that escapes engineering controls or a
fire, explosion, or detonation from the operation of the PMDs, MDMs, or BDSs.
If equipment in the ECRs or down line of the ECRs shuts down, any munitions or
munition components being processed in the ECRs may remain in the ECRs until the
equipment in question is operational. Altematively, facility personnel may don
appropriate PPE and physically retrieve the munitions or munition components from the
ECRs and manually place the item(s) into an appropriate overpack for subsequent storage
VIII.D.3.
Module VIII - Page 2
VIII.D.4.
VIII.D.5.
VIII.D.6.
VIII.D.7.
VIII.D .7 .7..
VIII.D.7.2.
VIII.D .7 .3.
in the Toxic Maintenance Area (TMA).
of occurrence in the Operating Record.
TOCDF
Demi I i t anzation M i scel I an eou s Treatmen t Un i ts
June 2009
These activities shall be documented for each day
If the equipment in the MPB or down line of the MPB shuts down, any bulk containers,
munitions, or associated components being processed in the MPB may remain in the MPB
until the equipment in question is operational. Altematively, facility personnel may don
appropriate PPE and physically retrieve munitions or munition components from the MPB
and manually place the item(s) into an appropriate overpack for subsequent storage in the
TMA. These activities shall be documented for each day of occurrence in the Operating
Record.
The Permittee shall maintain sensors and interlocks identified as critical in the tables of
Attachment 14 ( Miscellaneous Treatrnent Units) so that they are functional whsn the
associated miscellaneous unit is operating. The Permittee is allowed to complete
processing of any partially processed munition when a sensor or interlock identified as
critical ceases to function.
Munition rejects exiting any of the miscellaneous units identified in Condition VIU.A
shall be transferred to the ECV, UPMC, MPB, or the TMA for pre-treatment under an
Emergency Permit, retumed to storage, or placed back into the miscellaneous unit to
complete treatment with the exception of 155mm mustard projectiles rejected by the
PMDs solely because of stuck bursters or 4.2 inchHT mortars rejected by the PMD for
failure to remove the fuze. The mustard 155mm projectiles that have been rejected by the
PMDs solely because of stuck bursters or 4.2 inch HT mortars rejected by the PMD for
failure to remove the fuze. may be rejected back to the ECV for storage until the PMD has
been retooled to enable mechanical dislodging of the buster or commencement of the
associated leaker/reject campaign. The mustard 155mm projectiles permitted storage
capacity of the ECV shall not be exceeded. These activities shall be documented for each
day of occurrence in the Operating Record.
Igloo 1631 Autoclave Operating Requirement
The Permittee shall conduct an Autoclave Demonstration Test in accordance with a test
plan approved by the Executive Secretary for the purposes of establishing the minimum
temperature and temperature exposure time needed to destroy and remove the agent
contamination associated with the Secondary Wastes being treated.
The Permittee may process up to 880* gallons of Secondary Waste per treatment cycle
based on the collective volume of the drums either directly charged to the Autoclave or the
drums emptied into the Autoclave Waste Bins.
Secondary wastes may be treated in the Autoclave in the High Density Polyethylene
(HDPE) containers or in the metal drum used to store the waste provided the Permittee
demonstrates the effectiveness of treating secondary wastes in the storage containers
during either the demonstration test or a function test as required by Conditions
VItr.D.7.5.a and VIII. D.7.5.b
Secondary wastes shall be processed in the Autoclave per the requirements specified in the
Table VIII.A below.
VIII.D.7.4.
Module VIII - Page 3
TOCDF
Demi I it arization M i scel I an eou s Treatmen t Un i ts
June 2009
VIII.D .7 .5.Based on approval by the Executive Secretary of the results of testing conducted in
compliance with Conditions VIII.D.1.5.a and VtrI.D.7.s.b, the Permittee may treat in the
Autoclave secondary wastes as described in Table VIII.B.
Table VIII.B Secondary
Wastes Permitted for Autoclave Treatment
Maximum Combined Drum Volume per Treatment Batch = 880 gallons
Waste Stream
Maximum Packing
Density
(lbs/ft3)
TOCDF Generated:
Contaminated DPE Suits in Poly-Drums TBD
Contaminated LSS Air Hoses in Poly-Drums TBD
Contaminated wood (dunnage associated with pallets) in
Poly-Drums TBD
TBD = To be Determined from Autoclave Demonstration Test
VIII.D.7.5.a. The Permittee may perform function tests to demonstrate the effectiveness of Autoclave
treatment to allow the treatment of wastes not listed in Table VItr.B. The function test(s)
shall determine and establish:
Table VIII.A Secondary Waste Autoclave Processing Requirements
Autoclave Process Step Tag ID Requirement Step Duration
(minutes)
Autoclave Treatment Heat-
Soak
A10-TtT-241
A10-TtT-242
A10-TrT-243
A10-Trr-244
oF 180* minutes
Post-Treatment Evacuation A10-PtT-203 Minimum Autoclave Maintained for minimum
TBD minutes
M inimum Post-Treatment
Cooling & Drying Minimum TBD minutes
Minimum Post Treatment
Equilibration time before
Autoclave Headspace
Monitoring
A10-PtT-203
A10-Trr-201
Minimum Autoclave
Pressure S Atmospheric
Minimum Autoclave
Maintained for TBD
minutes before Autoclave
Headspace Monitoring
Autoclave Headspace
Monitoring
TEN-083V
TEN-083G
TEN-083H
Minimum One Complete
ACAMS Cycles
VX - 6 minutes/cycle
GB-3minutes/cycle.
HD: 5 minutes/cycle
TBD _ To be determined from Autoclave Demonstration Test
Module VIII - Page 4
VIII.D .7 .5.b.
VIII.D .7 .5.c
TOCDF
D emi I i t arizati on M i scel I an eou s Treatment Un i ts
June 2009
The maximum individual drum weight (i.e., packing density [drum weight/drum
volumel) or waste bin weight applicable to the waste stream being tested,
The acceptability of the storage container's material of construction for treating
waste if the Permittee desires to treat the waste in storage containers,
The optimum placement of the control thermocouples within the waste bin or
waste storage container to determine when a representative section of the waste's
mass has reached the treatment temperature, and
The penetration of steam or moisture into a representative section of the waste(s)
mass by either visual inspection of the treated waste(s) or post-treatment
inspection of moisture indicators placed into representative sections of the
waste(s) for the purpose of testing.
The Permittee shall provide function plan for each new waste stream and a notice to the
Executive Secretary a minimum of fourteen days in advance of conducting a function test.
Following each function test, and prior to continue processing of the waste(s) tested,
Executive Secretary shall provide written approval that such waste(s) may be processed in
the Autoclave by the inclusion of the waste stream(s).description in Table VtrI.B.
The Permittee shall continuously operate the Carbon Adsorption Filtration system which
supports the Autoclave and DVS/DVSSR operations from the time hazardous waste
management activities begin in Igloo 163 1 and 1632 to the time hazardous waste
management activities cease and 1) both igloos and associated equipment within the igloos
has been decontaminated sufficiently to achieve a WPL monitoring level and 2) the filter
system activated carbon banks which have been exposed to chemical agent have been
removed from the filter system.
VIII.D.8. leloo 1639 Glovebox Operatinq Requirements
VIII.D.8.a. The Permittee may use the ATLIC Gloveboxes to drain. dnse decontaminate. rinse. and
, . monitor Agent GA. Lewisite. and "Transparency''ton containers.
VII[.D.8.b. The Pemrittee shall not begin draining agent froni ton containers placed in the ATLIC
Gloveboxes until the pressure within the affected Glovebox is below - 0.25 inches of
water column as measured relative to the ATLIC Proceqsine Bay pressure.
VItr.D.8.c: The Permittee shall maintain the pressure within the affected Glovebox below - 0.25
inches of water aolumn as measured relative to the ATLIC Process Baypressure until the
asent concentration within the affected Glovebox is determined to be less than * 0.5 and
0.4 Vaosr Screenine Limits (VSL) for Aeent GA and Lewisite. rgspectivelv.
:
VItr.D.8.d. The Permittee shall transfer the asent drained from Agent GA ton containers that are
processed in the Gloveboxes directly to the ATLIC Primary Combustion Chamber.
VtrI.D.8.e. The Permittee shall transfer the asent drained from Lewisite ton containers that are
processed in the Gloveboxes to LCS-Tank-8511 for processine in the ATLIC Primary
Combustion Charnber.
Module VIII - Page 5
TOCDF
Dem i I i t artzation M i scel I an eou s Treatmen t Un i t s
June 2009
VIII.D.8.f. The Permittee shall ensure Aeent GA and solid heel residues have been completely
renroved from the in-process ton container by performins a minimum of one ton container
rinse using a sodium hydroxide based decontamination solution followed by a minimum
. .of three rinses using process water. For each rinse the ton container with added
rinsate shall be rotated for a minimum of one hour before the rinsate is drained.
VIII.D.8.f.1. The Permittee shall drain the contents of the in-process TC between each rinse and
transfer the solutions removed to ATLIC SDS-Tank-8523 for processing in the ATLIC
LIC Se,condary Combustion Chamber.
VItr.D.8.g. The Permittee shall ensure Lewisite and solid heel residues have beeir comoletely removed
from the in-process ton container by performing a minimum of eae two ton container rinse
using a Nitric Acid based solution. followed by a minimum of three rinses using process
water. For each rinse the ton container with added rinsate shall be rotated for a
minimuqt'of one hour before the rinsate is drained.
VIII.D,8.q.1. The Permittee shall drain the cont€nts of the in-process Lewisite TC betwe€n each rinse
and transfer the:
VIU.D.8.g.l.i. SpeNrt Nitric Acid to eitherNitric Acid Holding Tank (NSF-TAI.IK-8514 or LCS-TANK-
8516). and
VIII.D.8.g. t .ii. Water rinses to Spe,nt Decontamination Tank SDS-Tank-8523 for orocessing in the
ATLIC Secondary Combustion Chamber.
VIILD.8.h . The Permittee shall ensure Transparency Ton Containers have been thorouehly
decontaminated by:
VIII.D.8.h.1. Performing a minimum of one ton container rinse using a Nitric Acid based solution
followed by a minimum of three rinses usins grocess water.Ms
in€
ine
ffi For each rinse the ton container with added rinsate shall be
rotated for a minimum of one hour before the rinsate is drained.
VIII,D,8,h,2, P in
ine
M
VIII.D.8.h.32. The Permittee shall drain the contents of the in-process Transparency Ton Container
between each rinse and transfer the:
V[I.D.8.h.3.i. Spent Nitric Acid to eitherNitric Acid Holdine Tank (NSF-TANK-8514 orNSF-TA]',IK-
8510. and
VIII.D.8.h.3.ii. Water rinses to Spent Decontamination Tank SDS-Tank-8523 for processine in the' ATLIC Secondarv Combustion Chamber.
Module VII - Page 6
O
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009,:
VIII.D.8.i.
ffi In the event of a soill from tanks LCS-TAI\K-8511. NSF-
TAIIK-8514. LCS-TAI\K-8516. SDS-TAI\K-8523. a ton container. or associated
transfer svstems soecified above. the Permittee mav use tank LCS-TAIIK-8534 as an
alternate storase,tank as allowed bv Condition fV.J.2.
VIII.D.8 j. The Permittee shall dernonstrate the effectiveness of the ton container decontamination' and rinsing by collectine and analyzing a samole of the rinse water. Ton containers are
, dptermined to successfully emptied and treated if the asent concentration in the final water' .rinse sample is less then the Waste Control Limit for the agent beine proeessed (20 oarts
VItr.D.8.k. The Permittee malr rernove ernptied and rinsed ton containers from the ATLIC
VIII.E.2.
Gloveboxes when the affected Glovebox interior monitoring results are less than 03 0.5
and 05 0.4 VSL for aeents GA and L. respectively.
DETECTION. INSPECTION. AI\D MONITORING REOTJIREMENTS
As described in Attachment 14 ( Miscellaneous Treatment Units), the Permittee shall
monitor the waste throughput for each miscellaneoud unit by use of the Process Data
Acquisition and Recording System (PDARS) and the manual records maintained by the
control room operators or the Area 10 Igloo (DVS/DVSSR and Autoclave) Operators.
The Permittee shall use weighing, before and after draining, to quantifu the amount of
agent removed in the BDSs.
The Permittee shall use the bubbler system and load cells associated with the BDS to
determine the quantity of liquid agent drained from a bulk container processed in the
BDS. The amount of residual liquid and solid heel remaining in the bulk container shall
then be determined by comparing the ton container's initial frll weight with the amount of
liquid drained. If the Permittee is uhable to determine the quantity of liquid and solid
residual heel in the bulk container or the Drain Tube System (DTS) encounters a solid
heel before reaching the programmed drain level, the Permittee shall orally notify the
Executive Secretary within 24 hours. The Permittee shall record the bubbler reading and
load cell reading for each bulk item drained in the Operating Record. If the quantity of
agent removed, as determined in Condition VtrI.E.l, is not consistent with the bubbler
system or the DTS programmed drain level, then the Permittee shall not feed the bulk
c3nlainer to the MPF until a resolution is agreed to orally by the Executive Secretary.
As an alterative to using weights, before and after draining, to quantify the amount of
agent removed in the BDS for Baseline Ton Container Processing, the Permittee may
confirm the heel weight of drained bulk containers using the DTS and its associated
programmed drain levels after the Executive Secretary has approved the correlation
between heel depths and heel weights developed during the Mustard Baseline Shakedown
Period as allowed by Condition VI.C.1.a.v.
The Permittee shall record the results of drain condition in the Operating Record.
If the evaluation conducted in accordance with Condition VIILE.3 indicates that the drain
is insufficient to enable feed of the bulk container to the MPF, then the Permittee shall
,,r$j:J($'*
VIII.E.
VIII.E.1.
VIII.E.2.a
VIII.E.3.
VIII.E.4.o
Module VIII - Page 7
VIII.E.4.a.
VIII.E.4.b,
VIII.E,4,C.
VIII.E.5.
VIII.E.6.
VIII.E .6.a.
VIII.E.6.b.
VIII.E.7.
VIII.E.'7 .a.
TOCDF
Demilitarizati on Mi scellaneous Treatment Units
June 2009
notifu the Executive Secretary as to which one of the following courses of action shall be
implemented:
The Permittee shall perform corrective maintenance on the BDS. The bulk container will
then be drained again. The drain status will be re-evaluated according to Condition
VtrI.E.3 or;
For Mustard ton containers only, the bulk container shall be processed in accordance with
the procedures demonstrated in the approved Mustard trial bum. The maximum feed
weight is inModule V; or
The Permittee shall comply with the requirements in Condition Vm.E.11.
If the evaluation conducted in accordance with Condition VItr.E.3 indicates that the drain
is sufficient, then the bulk container may be considered adequately drained and fed to the
MPF. This determination shall be documented in the Operating Record.
If the fill weight for a given ton container, as listed in the Deseret Chemical Depot (DCD)
inventory, is less than the standard fill weights (1800 lbs Mustard), then the Permittee may
opt to apply the following criteria when evaluating consistency between the quantity
removed and the bubbler reading.
If the quantity of agent removed from a ton container by the DTS is less than the minimum
required to enable feed to the MPF, indicating that the residual liquid and solid heel is
greater than the maximum allowed the Permittee shall 1) remove additional heel material
at the HTS until the net weight is below the maximum allowed, or 2) comply with
Condition VIII.E.3 and Condition VIII.E.4 or VIII.E.5.
If the quantity of agent removed from the ton container is greater than or equal to the
minimum required to enable feed to the MPF indicating that the residual liquid and solid
heel is less than the maximum allowed then the ton container may be considered
adequately drained and fed to the MPF.
The Permittee shall use the bubbler system and the AQS associated with the MDM to
determine if projectiles or mortars processed in the MDM are drained. If the Permittee is
unable to determine if the projectile or mortar is drained using the bubbler system and the
AQS, the Permittee shall orally notify the Executive Secretary within 24 hours. An AQS
adequate drain determination consists of an indication of flow into the AQS. The
Permittee shall record the bubbler readings and the AQS reading for each projectile or
mortar drained in the Operating Record. If the quantity of agent removed is not consistent
with a complete drain for the munitions on that tray, then the Permittee shall not feed the
tray of projectiles or mortars to the MPF and shall follow the requirements specified
below:
The Permittee shall conduct a visual inspection and physical measurement to ascertain the
drain status. The Permittee shall record the results of this evaluation in the Operating
Record.
If the visual inspection and physical measurement evaluation conducted in accordance
with Condition VIILE.7.a indicates that the drain is insuffrcient, then the Permittee shall oVIII.E.8.
Module VIII - Page 8
Dernil i tari zati on M i scel I an eou r r.""*"]:;1,,:
June 2009
orally notiff the Executive Secretary as to which one of the following courses of action
shall be implemented:
VItr.E.8.a. The Permittee shall perform corrective maintenance on the MDM. The munition will then
be drained again. The drain status will be re-evaluated according to Condition VtrI.E.7.a
or;
VIILE.8.b. The Permittee shall comply with Condition VIII.E.l 1.
VtrI.E.g. If the visual inspection and physical measurement evaluation conducted in accordance
with Condition VtrI.E.7.a indicates that the drain is sufficient, then the munition may be
considered adequately drained and fed to the MPF.
VItr.E.l0. The method used to determine if a bulk container, projectile, or mortar is adequately
drained shall be recorded in the Operating Record for each of these items processed except
for the mustard 155mm projectiles which will not be drained.
VIII.E. 1 1 . Within 24 hours of discovery of any bulk container, proj ectile, or mortar which cannot be
processed under Conditions VItr.E.2 through 6 and VIII.E.7 through 10, the Permittee
shall notifu the Executive Secretary and (l) properly manage the munition or bulk
container in the Munitions Demilitaization Building; (2) request and receive approval for
further processing; or both. A sample of the undrained liquid, or solid, or both shall be
taken and analyzed for agent purity and metals content, unless a treatment method for the
bulk container or munition tlpe has been approved by the Executive Secretary in
accordance with the procedures in R315-3-4.
VIII.E.12. The Permittee shall follow the inspection requirements for the equipment/processing lines
associated with the miscellaneous units as specified in Attachment 5 (Inspection Plan).
VIILE.I3. The Permittee shall initiate repair of all chips and cracks in the epoxy coatings on the
floors of the ECRs and MPB within 72 hours of detection.
VIII.E.14. The Permittee shall not conduct any DPE or related entries into areas which are
contaminated with agent above the 140IDLH Mustard and 500IDLH GB and VX.
VIII.E.15. The Permittee may use the Air Operated Remote Ordnance Access System (Cutter
Machine) to cut into cylindrical items that have been rejected or require special handling.
It may be used for nose closure removal, fuze removal, and access to interior components.
The Cutter Machine will be used in accordance with site approved operating procedures.
VIII.E.16 DVS Inspection and Monitoring Requirements
VIII.E.16.a The Permittee may use the DVS Enclosures and DVSSR to gain access to the internal
volume of secondary waste drums for the purpose of sorting, characterizing and
determining the agent-contamination status (e.g., monitoring) of the drum's contents.
VIILE.16.a.i The application of decontaminatibn solution in order to enable shipment of the waste is
permitted only if such treatment is described in the WAP (CAL Aqueous Wastes, CAL
Solid Wastes and MSB Solid Waste) to ensure agent concentration of the residual spent
decontamination solution is below 20ppb GBNX or 200 ppb Mustard).
Module VIII - Page 9
VIII.E.16.a.ii
VIII.E.16.b
VIII.E.l6.b.l
VIII.E.16.d
VIII.E.16.e
VIII.E.I7
VIII.E.l7.a
VIII.E.I7.b
Demi I i tari zati on M i scel I aneou. r.".*.]rOr!rl, rl
June 2009
The drum and its contents may be treated by the application of decontaminant or other
cleaning compound with the goal of reducing risk to personnel or reducing the level of
PPE for further handling. The P999 waste code shall thus be retained by the waste
throughout the DVS treatment process.
The Permittee may use the DVS Enclosures and DVSSR, only as specified herein, to
characterize the "as-received" agent-contamination status of secondary waste drums by
headspace monitoring.
To add new waste streams to the list of approved waste streams specified in VItr.E.l6.d, a
headspace monitoring demonstration test shall be performed for each waste stream. A
plan must be approved by the Executive Secretary and a minimum of fourteen days
advance notice of the demonstration test performance. The Executive Secretary shall
provide written approval of the demonstrated headspace monitoring procedure for that
waste stream. If headspace monitoring is not demonstrated the waste must be processed
in the Autoclave or MPF after waste stream has been demonstrated per Module VItr.
Once an approved headspace monitoring procedure is approved for a specific waste stream
by the Executive Secretary, then the drum's contents may be classified into one of the
following agent-contamination categories; destined for treatment or disposal indicated:
Headspace < 0.2 VSL, ship and dispose offsite at a Subtitle C TSDF as F999
Waste (i.e., P999 Not-Applicable)
Headspace 2 0.2 VSL and <1.0 VSL. ship and dispose offsite at a Subtitle C
TSDF as F9991P999 with additional offsite controls (special handling through
contract requirement) as an added measure of control to reduce potential contact
with waste.
Headspace 2 1.0 VSL, treat in a hazardous waste management unit (Autoclave) or
TOCDF MPF permitted for treatment for that P999 waste stream.
A Secondary Waste Drum Headspace Monitoring method is currently approved by the
Executive Secretary for the following waste streams:
Secondary Waste Drums Having a DSHW-Approved Headspace Agent Monitoring
Method for Determination of Drum's Agent Contamination Status
1) DPE Suits
Unapproved P999-characterized secondary waste types not listed in VIILE.l6.d shall be
treated in a hazardous waste treatment unit (HWMU) permitted for P999 treatment. In
lieu of performing headspace monitoring, the Permittee may conservatively treat approved
waste types in a permitted HWMU as P999 waste.
Autoclave Inspection and Monitoring Requirements
The Permittee shall monitor and record the temperature and time of temperature soak
associated with each batch of Secondary Waste treated in the Autoclave.
The Permittee shall perform post-treatment agent monitoring on the Autoclave headspace
to determine the applicable waste management practices for the treated wastes.
O
1)
2)
3)
Module VIII - Page l0
VIII.E.17.b.iii Autoclave treated secondary wastes with post-treatment headspace agent monitoring
results equal to or greater than 0.5 VSL shall be retreated in the Autoclave.
Vltr.E.17.b.iv The Permittee shall notiff the Executive Secretary of each instance when a batch of
Autoclave treated wastes receives an additional Autoclave treatment. The Executive
Secretary may require additional testing or an adjustment to Autoclave operating
panrmeters and drum weight limits for secondary waste streams requiring repeated
multiple treatments.
VItr.E.l8. ATLIC Glovebox lnspection and Monitorine Reouirernsnts
VIII.E.18.a.The Permittee shall insnect each ATLIC Glovebox as s ified in Attachment 5 of this
Permit.
VItr.E.18.b. The Permittee shall monitor the pressure differential between the interior of the Glovebox
and the ATLIC Processing Bay throughout ton container drainine and rinsing operations
in accordance with Conditions VIII.D.8.b and VIII.D.8.c.
VIII.E.18.c. The Permittee shall monitor the interior
of the Glovebox before removine the treated ton container in accordance with
VIII.D.8.k
VIII.E .I7 ,b,i
VIII.E.l7 .b.ii
VIII.F.
VIII.F.1.
VIII.F.2.
VIII.F.3.
VIII.F.4
TOCDF
Demi 1 i t arization M i scel 1 an eou s Treatment Un i ts
June 2009
Treated secondary wastes with post-treatment headspace agent monitoring results of less
than 0.5 Vapor Screening Limit (VSL) and a demonstrated WCL of less than 20ppb for
V)V GB and 200ppb for mustard may be managed in roll-offs for off-site transport to a
Subtitle C TSDF as F999.
Treated secondary wastes with post-treatment headspace agent monitoring results of less
than 0.5 Vapor Screening Limit (VSL), but without a demonstrated WCL of less than
20ppb for V)V GB and 200ppb for mustard, may be managed in roll-offs for off-site
transport to a Subtitle C TSDF asP9998999 with additional offsite controls (special
handling through contract requirement) as an added measure of control to reduce potential
contact with waste..
STORAGE REOUIREMENTS
The Permittee may store waste in the form of maintenance residues on the equipment in
the ECRs or on the floor of the ECRs provided that Conditions VIII.F.2 and VIII.F.3 are
satisfied. - .,.-.
Waste in the ECR sumps shall be removed within 24 hours as required by Module IV.
The explosive limits of each ECR, as specified in Attachment 14 (Demilitarization
Miscellaneous Treatment Units), shall not be exceeded.
The Permittee may store open containers of secondary waste in the DVS enclosures and
the DVSSR provided the DVS enclosure, the DVSSR doors, and Igloo doors are properly
Module VIII - Page I 1
TOCDF
Dernilitarization Miscellaneous Treatment Units
June 2009
closed and the igloo carbon adsorption filtration system is operable with the primary filter
online.
VIII.F.S The Permittee may,store in-process ton containers in the ATLIC Gloveboxes proyided that
VIII.G.
VIII.G.1 .
the affected Glovebox is sealed and the oressure within the Glovebox is maintained
neqative relative to the ATLIC Processine Bav oressure.
CLOST]RE
At closure, the Permittee shall follow the procedures specified in Attachment l0 (Closure
Plan).
VIII.H. Reserved
Module VIII - Page 12
x.A.
x.A.1.
x.4.2.
x.A.3.
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
MODTILE X
ArR EMTSSTON STANDARDS FOR EQImMENT LEAKS, TANKS, CONTATNERS,
AI\D TIIE ITVAC
APPLICABILITY - EOUIPMENT LEAKS
The Permittee shall follow the procedures and requirements specified by R315-8-18 [40
CFR 264.1050 through 264.10651.
The Permittee shall, as required by R315-8-2.4, determine for each piece of equipment
specified by R315-8-18 whether this equipment contains or contacts a hazardous waste or
hazardous wastes residue that equals or exceeds 10 percent by weight organic
concentration using the analytical test methods and procedures in Attachment 2 (Waste
Analysis Plan). The Permittee shall maintain records of these determinations as required
by R315-8-18 [40 CFR 264.t064].
R315-8-18 applies to the equipment identified in Table 17-1 of Attachment 17
(Equipment Lists) that is associated with the management of agent iry
X.A.3.a.The TOCDF ACS tank system boundary begins at the suction wands at the drain locations
(Bulk Drain Stations (BDSs) and Multipurpose DemilitarizationMachines (MDMs)
located in the Munitions Processing Bay (MPB) and includes equipment in the Upstairs
Munitions Corridor (UPMC) and the Toxic Cubicle (TOX), and ends at the Liquid
Incinerator (LIC) primary chambers.
X.A.3.b. The ATLIC Lewisite Agent Collection System boundary begins at the exit of each
Glovebox Miscellaneous Treatment Unit located in the ATITIC Processing Bay. and
includes Lewisite Aeent Holdinq Tank LCS-TANK-8SIl. ancillary equipment comprising
the re-circulation loop. and ATLIC Lewisite feed oumos and lines. and ends at the ATLIC
Primary Combustion Chamber.
X.A.3.c. The ATLIC Agent GA Feed System boundary beginning at the exit of each Glovebox
x.A.4.
Miscellaneous Treatment Unit located in the ATLIC Processing Ba), and ends at the
ATLIC Primary Combustion Chamber.
The Permittee shall mark each piece of equipment covered by the requirements set forth
by R3l5-8-18 [40 CFR 264.1050(d)] in such a manner that the equipment can be
distinguished readily from other pieces of equipment
CHANGE IN PROCESS
Except as described in Condition X.E}.3, the Permittee shall perform a waste determination
as specified by Condition X.A.2 if there is a change in process that could increase the total
organic content of waste contacted by the equipment or the addition of new waste
management units.
x.B.
x.8.1.
ModuleX-Page1
x.8.2.
x.B.3.
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, -a Hg;[;
The Permittee shall modifu Table 17 -Z in Attachment I 7 (Equipment Lists), via a permit
modification, to reflect the addition of equipment regulated under R3 I 5-8-1 8 if a waste
determination as described in Conditions X.A.2. and X.8.1. indicates that R315-8-18 [40
CFR 264.1052 through 264.10601applies to the equipment, other than that described in
x.A.
Equipment identified in Condition X.C. and Attachment l7 (Equipment Lists) may be
excluded from the requirements of R315-8-18 [40 CFR 264.1052 through 264.1060], and
Condition X.C. and X.D. if the Permittee demonstrates that the equipment contains or
contacts hazardous waste with an organic concentration of at least 10 percent by weight
for a period less than 300 hours per calendar year.
ModuleX-Page2
o
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
X.C. STAI\DARDS. EOUIPMENT
X.C.1. The Permittee shall comply with the following requirements:
X.C.l.a. R315-8-18 [40 CFR 264.1054] for operation of pressure relief devices in gas/vapor
service defined by R315-8-18 [40 CFR 264.10311;
X.C.l.b. R315-8-18 [40 CFR 264.1058) for operation of pressure relief devices in heavy liquid
service and light liquid service defined by R3 15-8-1 8 [40 CFR 264.1031];
X.C.1.c. R315-8-18 [40 CFR 264.1058] for operation of connectors and flanges;
X.C.l.d. R315-8-18 [40 CFR 264.1058) for operation of pumps in heavy liquid service defined by
R315-8-18 [40 CFR 264.t03t];
X.C.l.e. R315-8-18 [40 CFR 264.1057] for operation of valves in gas/vapor service defined by
R3ls-8-18 [40 CFR 264.103t];
X.C.1.f. R315-8-18 [40 CFR 264.1055] for operation of sampling equipment connections systems
outlined in Tables 17-l and l7-2 inAttachment 17 (Equipment Lists);
X.C.l.g. R315-8-18 [40 CFR 264.1056) for operation of open ended valve or lines identified in
Table 17-1 and Table l7-2 of Attachment 17 (Equipment Lists); and
O x.c.l .h. R315-8-18 [40 cFR 264.10531 for operation of applicable compressors.
X.C.Z. The Permittee shall perform leak detection monitoring required by Conditions X.C., and
X.D., in such a manner to meet the minimum leak detection procedures, requirements, and
performance standards specified in Section 22.38 of Attachment 22 (Agent Monitoring
Plan).
X.D. LEAKING EOUIPMENT
X.D.1. The identification and repair of leaking equipment shall comply with Condition X.C. and
the additional requirements listed in Conditions X.D.1.a through X.D.1.c.
X.D.1.a. As soon as conditions allow an entry, equipment shall be tagged with an identification
number and the date the leak was detected. The tag shall be readily visible as outlined in
R315-B-18 [40 CFR 264.1064].
X.D.1 .b. The identification tag required by X.D. 1 .a. may be removed after the leak has been
repaired.
X.D.l.c. lnformation associated with the leaking equipment shall be recorded and kept in the
Operating Record for a minimum of three years. The record shall include the following
information:
X.D.l.c.i. Theequipmentidentificationnumber.
ModuleX-Page3
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, .*,ff Yfi;
X.D.1 .c.ii. The date the leak was detected and the dates of each attempt to repair the leak.
X.D.1.c.iii. Repair methods applied to each attempt to repair the leak.
X.D.l.c.iv. "Repair Delayed" and the reason for the delay if a leak is not repaired within l5 calendar
days after discovery of the leak.
X.D.l.c.v. Documentation supporting the delay of repair of a valve in compliance with 40 CFR
264.1059(c).
X.D.1.c.vi. The signature of the Plant Shift Manager (or designee) whose decision it was that repair
could not be effected without a hazardous waste management unit shutdown.
X.D.1 .c.vii. The expected dat'e of successful repair of the leak if a leak is not repaired within 15
calendar days.
X.D. 1 .c.viii. The date of successful repair of the leak.
X.F" RECORDKEEPING AI\D REPORTING
X.F.l. The Permittee shall maintain a log for all equipment listed in Conditions X.A. and X.B.
The log shall contain the following information:
X.F.1.a. Equipment identification number and waste management unit identification;
X.F.l.b. Approximate location of the equipment within the facility;
X.F.l.c. T1,pe of equipment;
X.F.1.d Percent of total organics by weight of the hazardous waste stream at the equipment;
X.F.1.e. Physical state (e.g., gas, vapor or liquid) of hazardous waste at the equipment; and
X.F.l.f. Method used to achieve compliance with R315-8-18.
X.F.2. The Permittee shall record, in the Operating Record, a list of exempted equipment and
supporting waste analysis as required by R315-8-18 [40 CFR 264.1064(k)].
X.F.3. The Permittee shall record, in the Operating Record, the inspection of equipment,
detection of leaks, and repair of equipment
X.F.4. The Permittee shall submit a semi-annual report each August I and February 1 to the
Executive Secretary in accordance with R315-8-18 [40 CFR 264.1065]. The semi-annual
reporting period shall be defined as from January I to June 30 or from July 1 to December
31'
X.F.5. A report to the Executive Secretary, in accordance with Condition X.F.4., is not required
for the leaks that are detected and repaired as required by Conditions X.C. and X.D
ModuleX-Page4
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
X.G. APPLICABILITY. TAI\KS AI\D CONTAINERS
X.G.1 . The Permittee shall comply with the requirements of R31 5-8-22, ak emission standards
for storage of hazardous waste in tanks and containers at the facility.
X.G.2. The Permittee is exempt from the requirements of R315-8-22140 CFR 264.1084 through
10871 provided the Permittee demonstrates compliance with X.G.2.a. and X.G.2.b. or
demonstrates compliance with X.G.2.c.
X.G.Z.a. All hazardous wastes entering a container, tank, or primary containment sump have an
average volatile organic concentration (VOC) at the point of waste origination of less than
500 parts-per-million by weight as determined by Condition X.G.3.;
X.G.2.b. All waste determinations specified by Condition X.G.1., have been updated at least once
every 12 months following the date of the initial determination for hazardous waste
streams entering container and tank units to be exempted;
X.G.2.c. The VOC of the hazardous waste has been treated by an organic destruction or removal
process that satisfies any one of the requirements and conditions of R315-8-22 [40 CFR
264.1082(c)(2)1, provided the VOC of the treated wastes have been determined by
Condition X.G.3. for treated wastes which are not controlled and monitored as required by
R315-8-22 [40 CFR 264.1084 through 1087].
X.G.3. If the Permittee exempts the waste pursuant to Condition X.G.z., the Permittee shall
determine the VOC as follows:
X.G.3.a. lnitial or change of process waste determinations, at the point of waste origination, for
average VOC(s) of hazardous waste streams and treated waste streams identified in
Attachment 2 (Waste Analysis Plan) shall be performed in accordance with Attachment 2
(Waste Analysis Plan), R315-8-22140 CFR 264.1083, which references 40 CFR
265.1084(a)(3)1, and subject to the procedures and requirements of Attachment 3
(Sampling, Analytical, and QA/QC Procedures).
X.G.3.b. The Permittee shall update all waste determinations as necessary at least once every 12
months following the date of the initial determination for hazardous waste streams.
X.G.4. Except as allowed by X.G.5., the Permittee shall follow Attachment 2 (Waste Analysis
Plan) to determine the maximum organic vapor pressure (MOVP) for hazardous wastes in
tanks using level one control specified by R315-8-22 [40 CFR 264.1084] through direct
measurement to include a sufficient number of samples to be representative of the waste
contained in the tank in accordance with Attachment 2 (Waste Analysis Plan). Within 30
days after sample collection, the MOVP data and results shall be submitted to the
Executive Secretary to meet the requirements of R31 5 -8-22 140 CFR 264.10841 for
MOVP analysis. Samples shall be taksn in accordance with Attachment 2 (Waste
Analysis Plan).
X.G.5. The Permittee may choose to use generator knowledge to determine the MOVP for
hazardous waste in tanks as outlined by R315-8-22 [40 CFR 26a.1083(c)].
ModuleX-Page5
x.G.6.
x.G.7.
x.G.8.
x.G.9.
x.G.l0.
X.G.10.a.
x.G.10.b.
X.G.10.c.
x.G.1 1.
x.G.12.
x.G.13.
X.G. 13.a.
x.G.13.b.
X.G.13.c.
x.G.14
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
The Permittee shall update all vapor pressure tests as necessary, at least once every 12
months, following date of initial determination for hazardous waste entering tank units.
The Executive Secretary may request a waste characteization to determine compliance
with R3l5-8-22.
The Permittee is prohibited from treating hazardous waste subject to the requirements for
containers, tanks, and primary containment sumps unless air emission control is
maintained in accordance with R3l5-8-22 [40 CFR 264.1084 through 1087].
Reserved.
The Permittee shall control air emissions from hazardous waste in containers for the
container managernent units identified in Table 2 as specified by R315-8-22 [40 CFR
264.10861 and as follows:
For containers with a design capacity greater than26 gallons and less than 121 gallons, air
emissions shall be controlled by level one control as specified by R315-8-22 [40 CFR
264.1086(c)1.
For containers with a design capacity greater than l2l gallons, which are in light material
service as defined by R315-7-30 [40CFR 265.1081], air emissions shall be controlled by
level two control as specified by R315-8-22 [40 CFR 264.1085(d)].
For containers with a design capacity greater than l2l gallons, which are not in light
material service as defined by R315-7-30 [40CFR 265.1081], air emissions shall be
controlled by level one control as specified by R315-8-22 [40 CFR 26a.1086(c)].
Containers used for storage must be composed of suitable materials to minimize the
exposure of VOCs to the atmosphere and the organic permeability of vapors. The
container must form a vapor-tight seal.
The Permittee shall control air emissions from hazardous waste tanks used as primary
containment devices in accordance with R315-8-22 [40 CFR 264,1084] for the tanks
identified in Table 2 and Table 2-A.
The requirements of R315-8-22 and this Module do not apply to the following
management units regardless of the waste determination:
Containers that have a design capacity less than or equal to 0.1m3;
Satellite containers;
Process bulk feed tanks.
For Area 10 Igloo 1631 (Autoclave) and Igloo 1632 (DVS/DVSSR) miscellaneous
treatment units, air emissions shall be controlled by level three controls as specified in
R3 1 s-8-22 (40 CFR264. I 086(e)).
ModuleX-Page6
x.H.
x.H.1.
x.H.z.
x.H.3.
x.H.4.
x.H.5.
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
X.G.15. For the ATLIC hazardous waste storage and treatment tanks and miscellaneous treatment
x.I.
x.I.1 .
x.r.z.
units. air emissions shall be controlled by the level three controls as specified in R315-8-
22 (40 CFR264.1086(e)).
INSPECTION AND MONITORING
The Permittee shall follow the inspection plan and schedule in Attachment 5 (Inspection
Plan).
The Permittee shall monitor air emission controls as specified in Attachment 22 (Agerrt
Monitoring Plan).
If any container greater than 0.lnt' in capacity (e.g., 55 gallon drum or ton containers) is
stored for a period of one year or longer, the Permittee shall visually inspect the container
and its cover and closure devices initially and thereafter at least once every 12 months.
The container shall be inspected for visible cracks, holes, gaps, or other open spaces into
the"interior of the container. For storage in the Container Handling Building (CHB) and
Unpack Area (JPA), monitoring of the interior of the overpack can be used instead of this
visual inspection..
With the exception of ton containers the Permittee shall make a first attempt at repair of
any defect detected during the inspection described in Condition X.H.3. no later than24
hours after detection. Repair shall be completed as soon as possible but no later than five
calendar days after detection. If repair of the defect cannot be completed within five
calendar days, the hazardous waste shall be removed from the container and the container
shall not be used to manage hazardous waste until the defect is repaired. Any ton
container with a defect shall be managed as described in Attachment 5 (lnspection Plan)
and Attachment 12 (Containers).
The Permittee shall inspect containers and maintain a record of the inspections and a copy
of the procedure used to determine that containers with a capacity of 0.46m3 or greater,
which do not meet applicable DOT regulations as specified by R315-8-22 [40 CFR
264.1086(01, afe not managing hazardous waste in light material service.
REC ORDKEEPING AI\D REPORTING
The Permittee shall maintain records for each container or tank exempted from the
standards of Condition X.G.
As required by R315-8-22 [40 CFR 265.1084(b)(2)] and Attachment 2 (Warste Analysis
Plan), the Permittee shall record the information from each exempted hazardous waste
determination as identified in Condition X.G. (e.g., test results, measurements,
calculations and other documentation) including the date, time, and location for each
hazardous waste sample collected.
If exempted under Condition X.G., the Permittee shall record the identification nurnber of
the hazardous waste management unit in which the waste is treated.
x.I.3.
ModuleX-Page7
x.I.4.
x.I.5.
x.I.6
X.I.6.a.
x.I.6.b.
x.I.7.
X.I.7.a.
x.I.7.b.
X.I.I .c.
x.J.
x.J.1 .
X.J.1 .a
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, *a
T":"9#;
The Permittee shall orally report to the Executive Secretary, within 24 hours, each
occrurerrce when hazardous waste is placed in a waste management unit identifred in
Table2 or Table 4 in noncompliance with the conditions specified in Condition X.G.
The Permittee shall submit a written report within 15 calendar days of the time the
Permittee becomes aware of the occurrence specified in Condition X.I.4. The written
report shall contain the EPA identification number, the facility name and address, a
description of the noncompliance event and the cause, actions taken to correct the
noncompliance and prevent recurence of the noncompliance and the report shall be
signed and dated by a authorized represe,ntative of the Permittee.
The Permittee shall maintain the following information for all container management units
identified in Table 2that are subject to the air emission requirements of R315-8-22140
CFR 264.10861: type of container; bpe of air emission control; and records of
Inspections/I\4onitoring Information with the required information specified below:
For all container management units identified in Table 2 tl:.ort are used to store containers
having a design capacity greater than 121 gallons, the Permittee shall maintain the
information used to determine the status of the material as either light or heavy in
accordance with R315-7-30 [40 CFR 265.1081].
For all container management units identified in Table 2 that are used to store containers
for which the less than 500 ppmv exemption is used, as specified in R315-8-22 [40 CFR
264.I082(c\1, the Permittee shall maintain the exemption/waste determination information
in Condition X.I.6.
The Permittee shall maintain the following information in the Operating Record for all
tanks subject to the air emission requirements of R3 15-8-22 140 CFR 264. 10841,
identified in Table 2:
An identifrcation number or other unique identification description of the tanks;
Date of inspection; t1pe, description, and location of defect; date of detection; and
corrective action taken to repair the defect; and
Maximum organic vapor pressure of the hazardous waste in the tank, determined in
accordance with Condition X.G. Where applicable, the determination shall include the
date and time samples were taken, the analytical method used, and the anallical results.
GENERAL OPERATING CONDITIONS
TOCDF MDB HVAC
All HVAC filter units and fllter unit vestibules shall be maintained at a negative pressure.
These pressures will be recorded every four hours in the Operating Record. These
pressures will also be recorded each time the unit's operating status is changed. If any of
these readings are found to be positive, agent-processing operations within the facility
shall cease immediately. A description of the filter system is located in Attachment 5
(lnspection Plan), Paragraph 5.9.
ModuleX-Page8
x.J.l .b.
X.J.1 .c.
x.J.2
X.J.2.a
x.J.2,b
x.J.3.
Air Emission Standards for Equipment Leaks, Tanks, Containerso "rO.n#filJune 2009
Seven HVAC filter units shall be operational at all times when any hazardous waste is
being managed. During power upsets, the facility shall follow contingency procedures
Attachment 9 (Contingency Plan) Paragraph ruLfor maintaining negative
pressure...
.
The Permittee shall comply with Attachment 5 (Inspection Plan) for the inspection of the
HVAC filter units. For the purpose of compliance with these conditions, each filter unit is
defined as beginning at the inlet flange of the filter unit inlet isolation damper and snding
at the outlet flange of the filter unit outlet damper.
Area 10 Igloos 163l andL632
The Permittee may perform permitted hazardous waste management activities in Igloos
1631 and 1632 when Filter-l01 Grimary filter) is online.
The Permittee shall suspend operations of the Autoclave, DVS and DVSSR and seal or
rsmove all waste drums from Igloos 1631 and 1632 during times when Filter-lOl is
offline and Filter-l02 is online.
ATLIC HVAC
X.J.3.a. All ATLIC HVAC filter units and filter unit vestibules shall be maintained at a nesative
pressure when online. These pressures will be recorded every four hours in the Operating
Record. These pressures will also be recorded each time the unit's operating status is
changed. If any of these readines are found to be positive. aeent-processing operations
within the facility shall cease immediately. A description of the filter system is located in
Attachment 5 (Inspection Plan). paragraph 5.9.2.
X.J.3.b. Two HVAC filter units shall be operational at all times when any hazardous waste is being
managed at the ATLIC. Durine oowerupsets. the facility shall follow contingency
procedures Attachment 9 (Contineency Plan) Parapraph 9. I . I .5.3 for maintainins negative
rcssue.
X.J.3.c. The Permittee shall compl], with Attachment 5 flnspection Plan\ for the inspection of the
HVAC filter units. For the purpose of compliance with these conditions. each filter unit is
defined as beginnine at the inlet flange of the filter unit inlet isolation damper and ending
at the outlet flanee of the filter unit outlet dgmper.
x.K.
x.K.1.
REPLACEMENT OF CARBON FILTERBANKS
The Permittee shall notiff the Executive Secretary within seven days after a confirmed
breakthrough of chemical agent at 3 Vapor Screening Level (VSL) for GB, VX, and for
HD in carbon bank number two of any one of the nine IV[DB HVAC carbon filter units.
Within 30 days from the time of the confirmed breakthrough, the Permittee shall begin
operations to replace carbon banks one and two in that unit. If any confirmed agent
breakthrough is detected in any other carbon filter midbed (other than midbed #1 or 2), the
Executive Secretary shall be notified within 24 hours. The Permittee shall begin
operations to replace the carbon banks associated with the confirmed readings within 30
days of the confirmed breakthrough.
ModuleX-Page9
x.K.2.
x.K.3.
x.K.4.
x.K.5
X.K.6
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
The Permittee shall perform the analyses for spent carbon removed from a filter bank in
accordance with the Attachment 2 (Waste Analysis Plan). This data shall be maintained in
the Operating Record.
The Permittee shall, at a minimum of every 18 months, perform leak test challenges on
MDB HVAC carbon filters. The CAL rnd AILIC._HVAC carbon filters shall be leak test
challenged at a minimum of every 12 months. If one or more trays in a bank are replaced,
or if maintenance to a bank is preformed that could affect the filter's integnty or leak-
tightness additional leak tests shall be performed on the affected banks before that filter is
At the TOCDF MDB_aEd TOCDE HVAC carbon filter units, periodic (18-month) leak
test challenges are not required for carbon banks one and two, and for any carbon bank
three that has been exposed to confirmed agent breakthrough of carbon bank two. At the
CAL and ATLIC HVAC exhaust filter units, periodic leak test challenges are not required
for carbon bank one and for any carbon bank two that has been exposed to confirmed
agent breakthrough of carbon bank one. The challenge data shall be submitted within
fifteen days of cgmpletion of each complete filterblank challenge to the Executive
Secretary.
The Carbon Adsorption Filtration system (primary or back-up) for Igloos 163l and 1632
shall have the first carbon filter bed replaced when any agent is detected between the frst
and second midbeds at a concentration greater than or equal to 1.0 VSL. Within 15 days
from the time the midbed agent concentration reaches 1.0 VSL, the Permittee shall begin
operations to replace the carbon in the affected unit.
Ifagent is detected beyond the second carbon bed at the exhaust stack ofthe Igloos
Carbon Adsorption Filtration system, then hazardous waste treatment and primary
containment operations shall be immediately stopped and the exhaust flow path shall be
switched to the back-up filter. All carbon within the filter train that experienced
breakthrough shall be replaced with new carbon prior to being placed back into service in
accordance with 40 CFR 264.1086(e)(2)(ii) via $264.10S7(c)(3)(i) via $264.1033(h)(1). \
X.K.7. The Carbon Adsomtion Filtration systern for ATLIC shall have the first and*eeend
carbon filter beds replaced when any aeent is d€t€edconfirmed between the s€e€nd€nd
third first and second midbeds at a concentration greater than or equal to L0 VSL.
Within 15 days from the time the midbed aeent concentration reaches 1.0 VSL. the ,.
Permittee shall beein ooerations to replace the carbon in the affected unit. ,i:l
x.L.MONITORIN G REOUIREMENTS
Module X - Page l0
x.L.1.
x.L.z.
x.L.3.
x.L.4.
x.L.5.
x.L.6.
X.L.J
x.L.7.1
x.L.7.2
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, *,
T;##;
The Permittee shall stop the feed of munitions to the demilitarization equipment identified
in Attachment 14 (DemilitarizatioiEquipment) when an ACAMS alarm occurs for two
consecutive cycles in the HVAC filter stack. If the ACAMS alarm is confirmed, the
Permittee shall stop fumace operations once all drained agent and partially disassembled
munitions have been thermally treated, until a determination has been made as to the cause
of the alarm and actions have been taken to prevent the re-occurrence of the alarm. The
Executive Secretary shall be notified within 24 hours pursuant to Condition I.U. of a
release from the HVAC filter stack.
A Depot Area Air Monitoring System (DAAMS) tube sampling the HVAC stack shall be
pulled at least every twelve hours and aralyzed. A corresponding Quality Plant (QP)
sample shall be pulled at least daily and analyzed. The QP sample shall correspond to one
of the twelve-hour samples.
The DAAMS tubes monitoring the most downstream midbed location shall be analyzed
immediately if an HVAC stack ACAMS alarms is confirmed. The DAAMS tubes shall be
pulled and analyzed in accordance with Attachment 3 (Sampling, Analytical, and QA/QC
Procedures)
The HVAC filterunit vestibules shall be monitored in accordance with Attachment22
(Agent Monitoring Plan) for the presence of chemical agent when the associated filt'er unit
is placed in a standby condition. Feed to the demilitarization equipment described in
Attachment 1 4 (DemilitarizationEquipment) shall cease immediately upon a confirmed
agent alarm from a HVAC vestibule.
When the HVAC stack ACAMS is off line for more than 10 minutes, the DAAMS tube
sampling the HVAC stack shall be pulled and analyzed as soon as the ACAMS is back on
line.
TIVAC DAAMS tubes are located in the midbeds as specified in Attachment 22 (Agent
Monitoring Plan), for GB, VX, and Mustard agent.
Igloo 1631 (Autoclave) and Igloo 1632 (DVS/DVSSR) carbon filtration systern shall
continuously monitor for agent breakthrough.
The Permittee shall continuously sample the exhaust air from the carbon filter train
between the first and second carbon bed using DAAMS tubes. The DAAMS tubes will be
analyzed for each potential agent that has exhausted into the carbon filtration system, and
The Permittee shall sample the exhaust air from the carbon filtration system exhaust stack
using ACAMS with confirmation DAAMS. All instances of breakthrough beyond the
first carbon filter midbed shall be reported to the Executive Secretary within 24 hours.
X.L.8. The ATLIC HVAC filter shall be monitored for breakthroueh of aeent between the
individual carbon beds as specified in Attachment 22A.
X.L.8.1. Thb Permittee shall monitor the exhaust air from the ATLIC HVAC Filter System Stack
for agent as specified in Attachment 22A.
FILTERS EXPOSED TO MORE THAN ONE AGENTx.M.
ModuleX-Pagell
x.M.l.
TOCDF
Air Emission Standards for Equipment Leaks, Tanks, Containers, and the HVAC
June 2009
Before carbon filters exposed to more than one type of chemical agent may be fed to the
DFS, the Permittee shall: (l) ensure the monitors for all agents to which the carbon
potentially is exposed are in place in the DFS furnace duct, commol stack and processing
areas; (2) submit a multi-agent monitoring plan to the Executive Secretary for approval;
(3) submit a sampling and analytical plan to the Executive Secretary for approval in order
to ensure that a determination can be made for further management of carbon in
accordance with R3 I 5-3-4.3.
ModuleX-Page12
TOCDF
Tables
July 2008
TABLE 1
AGENT EXPOSURE LIMITS AND AGENT STACK LIMITS
LOCATION Concentration (mg/m3)
GB or GAs H/HD/HT VX L5
Source Emission Limit (SEL)|'2 0.0003 0.03 0.0003 0.03
General Population Limitl'3
(Averaging time: 24 houis GB/VX and 12 hours
Mustard)0.000003 0.0001 0.000003 0.003
Short Term Exposure Limit (STEL)'''' (15 minutes)0.0001 0.003 0.00001 0.003
Worker Population Limit4 lWff;
( l2 hours)
0.00002 4.00027 0.0000006 0.003
WPL4 (8 hours)0.00003 0.0004 0.000001 0.003
WPL4 (4 hours)0.00006 0.0008 0.000002 0.003
Vapor Screening Level (VSL)0.0001 0.003 0.00001 0.003
1. Public Law 9l-l2lll44 (USC 1512) mandates that the United States Department of Health and Human Services (HHS)
review the plans for transporting and/or disposing of lethal chemical agents and make recommendations for protecting human
health and safety. HHS delegated review and recommendation authority to the Centers for Disease Control (CDC).
2 The Department of Army proposed the maximum allowable stack concenffations indicated in Table 1. HHS reviewed the
concentrations and announced in the March 15, 1988 Federal Register (53 FR 8504) [conected in 53 FR I 1002, April 4,
1988] that the concentrations "met HHS criteria and appear to be more restrictive than limits set on a health base alone", and
therefore made no recommendation for changes.
3 CDC published in the Federal Register (FR) Volume 68, Number 196, October 2003 the final AELs for GA, GB and VX.
CDC also published in the FR, Volume 69, Number 85, May 3,2004, recommended AELs for mustard.
4. T\e 12- hour WPL monitoring level is used for routine historical monitoring. The 8- hour monitoring level is used for LSS
air monitoring irregardless of actual sample time. The 4-hour monitoring level is used only for VX if the detection limit
cannot be achieved due to interferences.
5. Processed exclusively at the ATLIC
NOTE:
CDC determined that the current available data precluded acceptable exposure limits for mustard agent being precisely
defined. CDC concluded that the work-place limits will amply protect a general population 1000 meters or more from the
demilitarization site for transportation route. Therefore, protection of the general public is dependent upon meeting the
work-place limits within the facility.
Tables - Page I
TOCDF
Tables
July 2008
TABLE 2r
HAZARDOUS WASTES/PERMITTED HAZARDOUS WASTE MANAGEMENT UNITS
WASTE TYPE ASTE CODES
15
HAZARDOUS WASTE MANAGEMENT UNITS
INCINERATORS MISC
UNITS
TANK STORAGE
TREATMENT
CONTAINER STORAGE
MUSTARD
EXPLOSIVES
FUZES
DETONATORS
INITIATOR
BURSTER
MUNITIONs BODY
COMPONENTS
DRAINED6 BULK
ITEMS
FILTERST
METAL8
MISCELLANEOUSIO ee Note 10
MISCELLANEOUS
LIQUID WASTES '4
BRINE SOLUTION 9 D002, D004
rough DOl I
SPENT DECON
SOLUTION
Fggg, PgggtT
D009, D0010,
D019,D022,
D029, D034,
D039, D040 and
D043
LIQUID MONITOR
SUPPORT AND LAB
WASTES
F999, D00l ,
D002, F002,
F003, F005
Tables - Page 2
TABLE 21
HAZARDOUS WASTES/PERMITTED HAZARDOUS WASTE MANAGEMENT UNITS
WASTE TYPE ASTE CODES
l5
HAZARDOUS WASTE MANAGEMENT UNITS
INCINERATORS TANK STORAGE
TREATMENT
CONTAINER STORAGEMISC
UNITS
DFS CYCLONE
RESIDUE
ECR MAINTENANCE
RESIDUEI6
ts, F999,
INCINERATION
RESIDUE
l. A list of the wastes that will be managed at this facility is shown in Attachment 2.
. Sumps used as primary containment devices
. Sumps used as secondary containment devices.
. Reserved.
. Includes munition body components other than rockets and mine bodies.
. Includes ton containers.
. Includes pre-filters and HEPA filters (from the ventilation system).
. Includes steel pallet bands, parts/equipment, and nails.
. Includes wood and wood preservatives as applied to pallets.
. Includes agent contaminated debris, trash, baghouse debris, lightbulbs, demister candle packing, paint debris, ignitable wastes (aerosals,
labpacks, isopropyl alcohol/glycol), batteries, refractory, slag, M40 canisters, MPF vacuum ash, spent cleaning solutions, scrap metal,
piping, PAS solids, lamps, spent decon solution, sump sludge/solids, tap gear, paper, glass, plastics, demilitarization protective ensemble
suit material, solid monitor support building and laboratory wastes that may include the following waste codes: D001-D0l 1, D018, D019,
D021,D022, D035, D039, D040, F00l through F005, U002, U003, U037, U044, U080, Ul31, Ul54, U159, U210, U220,F999,and
P999. Refer to Module III for the list of waste codes that can be placed into a specific container storage area.
I 1. Reserved
12. Any abbreviations or acronyms found on this table, which are not defined in these footnotes, can be found in Appendix A.
13. Normally, the energetics (e.g., burster, explosives) will be rernoved from the projectiles/mortars in the ECRs before storage in the UPMC.
However, if the burster detection systems, located at the Projectile Output Conveyor discharge stops in the UPMC, detect energetics, then
the munitions with the detected energetics will be reloaded onto reject tables in the UPMC for storage.
14. The miscellaneous liquid wastes include agent contaminated hydraulic fluid, and lubricating oil
15. In addition to the waste codes listed in this table, additional waste codes may apply.
16. The ECR maintenance residues are identified in Attachment 2 (Waste Analysis Plan). The only ECR maintenance residues that can be fed
to the MPF are unserviceable hand tools and metal hardware that are not contaminated with explosive residues (i.e., do not carry the D003
waste code).
17. Per Condition IV.E.6.
TOCDF
Tables
July 2008
Tables - Page 3
TOCDF
Tables
July4gg*
x{, A,'rV
.\ \1,.'V \Fl
tAu
rlgltr z-lt
AREA TO LIOUD INCINERTOR (ATLIO FACILITY
HAZARDOUS \ilASTES/PERMITTED HAZARDOUS WASTE MANAGEMENT UNITS
WASTE CODES INCIhTERATOR MISC
IJI\[ITS TANK STORAGE TREATMENT
il
El sr
ilEl3l
il
€l
*lglst ElflgI
EEI
EIgI
AHo.-
{'l
€tltli.Fltrl-a
ctl
!l
EI E
flfirlt-l
clol.-l!. I
=l-lolat
BEI
:l $
:EIEIzlEl
HIfir!
=l
dlodl
OJal-lol'Fl
>I
,gent GA P999. D004.
D007. D008. D02l x x x
ewisite
P999. D004.
D007. D008.
D009. D0l0
x x x x
\
pent Decontamination
olution
F999. D002.
D004. D007. 'i
D008. D02l
x x x
pent Nitric Acid
P999. F999. D002.
D004. D007.
D008. D009. D0l0
x x x
C Rinsg Water
F999. Dq02.
D004. D007.
D008. D009
\,t\r. ,,
1.: x x , XI.\
x
. ,A list of the wastes that will be manaqed at this facility is shown in Attachment 2
, Maior Spill Tank is maintained einotv unless it is requirad to store a release of liquids sreat€r than the accumulation sumo in
the AfLIC Facility Toxic Area.
Tables - Page 4
TOCDF
Tables
July 2008
TABLE 3
RESERVED
Tables - Page 5
TOCDF
Tables
July 2008
TABLE 4
HAZARDOUS WASTE SUMP 1 SYSTEMS
T
SUMP
I.D.NUMBER2
MAXIMUM
ALLOWABLE
CAPACITY
(GALLON)
DIMENSIONS OF
SUMP(FEET)
SECONDARY
CONTAINMENT
voLUME(GALLON)
LOCATION REFERENCE
UTAH
WASTE
CODE
DRAWING3
COLUMN-
ROW FLOOR ROOM4
SDS-PUMP-1OI 89 2.3x2.3x2.25 none required (MDB)B.l -14 2 UPA Fgggs
SDS-PUMP-I02 89 2.3x2.3x2.25 none required (MDB)D-l4 2 UPA Fgggs
SDS-PUMP.I03 89 2.3x2.3x2.25 none required (MDB)l-14 2 UPA Fgggs
SDS-PUMP-I04 89 2.3x2.3x2.25 none required (MDB)A-8 2 UPA Fgggs
SDS-PUMP-I 06 89 2.3x2.3x2.25 t34 H-6 2 ECR FgggsP 9996
SDS-PUMP-I07 59 2.33x2.33x I .46 t34 c-6 2 ECR FgggsP 9996
SDS-PUMP-108 89 2.3x2.3x2.25 t34 J- 10 2 ECV FgggsP 9996
SDS-PUMP-I09 89 2.3x2.3x2.25 134 D-10 2 ECV FgggsP 9996
SDS-PUMP-I I O 89 2.3x2.3x2.25 t34 B- l0 2 ECV Feee5Peel
SDS-PUMP-I I2 89 2.3x2.3x2.25 t34 B-7 2 M-CR FgggsP 9996
SDS-PUMP- I I3 89 2.3x2.3x2.25 134 M-3 2 M.CR FgggsP 9996
SDS-PUMP-I I4 89 23x2.3x2.25 134 J-3 2 M-CR FgggsP 9996
SDS-PUMP-I I5 89 23x2.3x2.25 t34 D-3 2 M-CR FgggsP 9996
SDS-PUMP- I I6 89 2.3x23x2.25 134 B-3 2 M-CR FgggsP 9996
SDS-PUMP-1I7 89 23x2.3x2.25 134 N-3 2 M-CR FgggsP 9996
SDS.PUMP-I I8 89 2.3x2.3x2.25 t34 B-5 2 M.CR FgggsP 9996
SDS-PUMP-123 8e 23x2.3x2.25
None required
(MDB)A-3 2P AL Fgggs
SDS-PUMP.I24 89 2.3x2.3x2.25 t34 B-4 2P .AL Fgggs
SDS-PUMP-I25 89 2.3x2.3x2.25 134 L-5 IP AL Fggg5
SDS-PUMP.I26 89 2.3x2.3x2.25 t34 L-8 2P AL Fgg95
Tables - Page 6
TOCDF
Tables
July 2008
TABLE 4
HAZARDOUS WASTE SUMP 1 SYSTEMS
SUMP
I.D.NUMBER2
MAXIMUM
ALLOWABLE
CAPACITY
(GALLON)
DIMENSIONS OF
SUMP(FEET)
SECONDARY
CONTAINMENT
voLUME(GALLON)
LOCATION REFERENCE
UTAH
WASTE
CODE
DRAWING3
COLUMN-
ROW FLOOR ROOM4
SDS-PUMP-127 89 2.3x2.3x2.25
None required
(MDB)L-7 2P AL Fggg5
SDS-PUMP- I30 89 23x2.3x2.25
None required
(MDB)P-l I I MON Fgggs
SDS-PUMP-I3I 89 2.3x2.3x2.25
None required
(MDB)M-13 I OBS Fgggs
SDS-PUMP-I33 89 2.3x23x2.25
None required
(MDB)M-2 I OBS Fgggs
SDS-PUMP.I34 89 23x2.3x2.25 134 T-6 I M-CR.AL Fgggs
SDS-PUMP- I35 89 2.3x2.3x2.25 t34 M-3 I TMA Fgggs
SDS.PUMP-136 89 23x2.3x2.25
None required
(MDB)c-2 2 OBS Fgggs
SDS-PUMP-I37 89 23x2.3x2.25
None required
(MDB)H-2 2 OBS Fgggs
SDS-PUMP-I38 89 2.3x2.3x2.25
None required
(MDB)M-2 2 OBS F9g95
SDS-PUMP- I39 89 2.3x2.3x2.25
None required
(MDB)P-4 2 OBS Fgggs
SDS-PUMP-I40 89 2.3x23x2.25
None required
(MDB)P-6 2 OBS Fgggs
SDS.PUMP.I4I 89 2.3x2.3x2.25
None required
(MDB)P-l I 2 OBS Fgggs
SDS-PUMP-142 89 23x2.3x2.25
None required
(MDB)L-9 2 OBS Fggg5
SDS-PUMP-144 89 2.3x2.3x2.25
None required
(MDB)w-ll r (Pit)LIC Fgggs
SDS-PUMP.I45 89 2.3x2.3x2.25 134 N- l0 2 MPB Fggg5P 9996
SDS-PUMP-I46 69 2.33x2.33x I .l I t34 N-8 2 MPB FgggsP 9996
SDS-PUMP-147 69 2.33x2.33x I .11 134 L- l0 2 MPB FgggsP 9996
SDS-PUMP-I48 89 23x23x2.25 134 L-8 2 MPB FgggsP 9996
SDS-PUMP- I49 59 2.33x2.33x 1.46 95 L-6 2 MPB FgggsP 9996
SDS-PUMP-I5O 85 2.25x2.25x2.25 None required (tank)H-7 SDS Fggg5 Pggg6
SDS-PUMP- 15I 5t2 4.42x4.42x3.5 None required J-8 TOX FgggsP 9996
Tables - Page 7
TABLE 4
HAZARDoUS wASTE suMP 1 sYsrEMs I
SUMP
I.D.NUMBER,
MAXIMUM
ALLOWABLE
CAPACITY
(GALLON)
DIMENSIONS OF
SUMP(FEET)
SECONDARY
CONTAINMENT
voLUME(GALLON)
LOCATION REFERENCE
UTAH
WASTE
CODE
DRAWING,
COLUMN.
ROW FLOOR RooM4
SDS-PUMP- I53 89 2.3x2.3x2.25 134 P-5 I DECON Fggg5
SDS-PUMP-I54 89 2.3x2.3x2.25 134 M-6 I TMA Fgg95
SDS-PUMP-156 89 2.3x2.3x2.25
None required
(MDB)u-l I r (Pi0 LIC Fgggs
SDS-PUMP-I57 89 2.3x2.3x2.25
None required
(MDB)u-9 I LIC Fgggs Pggg6
SDS-PUMP-I60 89 2.3x2.3x2.25
None required
(MDB)u-6 I AL Fgggs
SDS.PUMP-16I 89 23x23x2.25
None required
(MDB)J-9 I AL Fgggs
SDS-PUMP.164 89 2.3x2.3x2.25 134 M-ll I BSA Fgggs
SDS-PUMP-I67 89 2.3x23x2.25
None required
(MDB)M-13 2 OBS Fgg95
SDS-PUMP.168 69 2.33x2.33x 1 .71 134 N-6 2 MPB FeeesPeeqL
SDS-PUMP-I69 89 2.3x2.3x2.25 134 l-6 2 M.CR
T
FgggsP 9996
SDS-PUMP-I73 89 23x23x2.25
None required
(MDB)M-3 IP OBS Fgggs
SDS-PUMP-I74 89 2.3x2.3x2.25 134 D-6 2 M-CR FgggsP 9996
SDS-PUMP- I75 89 23x2.3x2.25 134 M-ll 2 MPB FgggsP 9996
SDS-PUMP-I79 89 2.3x23x2.25 t34 Q-6 M-CR Fgggs
SDS-PUMP- 1 8O 89 23x23x2.25
None required
(MDB)T-7 I AL Fgggs
SDS.PUMP- I 82 89 2.3x2.3x2.25
None required
(MDB)L-4 IP AL Fgggs
SDS-PUMP- I 84 89 2.3x2.3x2.25 134 M-6 I M-CR Fgggs
SDS.PUMP.I 88 89 2.3x2.3x2.25
None required
(MDB)s-9 I LIC Fggg5 Pggg6
SDS.PUMP-I89 89 23x2.3x2.25 134 K-7 2 M-CR Fggg5P 9996
SDS-PUMP-I90 89 2.3x2.3x2.25 134 M-9 I BSA Fggg5
SDS-PUMP-192 89 2.3x2.3x2.25
None required
(MDB)L-6 2P OBS
TOCDF
Tables
July 2008
Tables - Page 8
Fgg95
TOCDF
Tables
July 2008
TABLE 4
HAZARDOUS WASTE SUMP 1 SYSTEMS
SUMP
I.D.NUMBER2
MAXIMUM
ALLOWABLE
CAPACITY
(GALLON)
DIMENSIONS OF
SUMP(FEET)
SECONDARY
CONTAINMENT
voLUME(GALLON)
LOCATION REFERENCE
UTAH
WASTE
CODE
DRAWING3
COLUMN-
ROW FLOOR ROOM4
SDS-PUMP-I93 89 2.3x2.3x2.25
None required
(MDB)K-9 I OBS Fggg5
SDS-PUMP-I97 89 2.3x2.3x2.25
None required
f I\/tT-lEl\L-6 I LAB Fgggs
BRA-PUMP-I03 85 2.25x2.25x2.25 None required (tank)diked area BRA Fgggs
BCST-PUMP-I 07 400 3x3x6 None required (tank)N/A
UNLOAD
STATION Fgggs
I Hazardous waste sumps (meeting the RCRA definition of a tank) must comply with all applicable hazardous waste tank systern
requirernents (R3 I 5-8- I 0).
2 MDB = Munition Demilitarization Building, SDS : Spent Decontamination Solution/Syston, BRA = Brine Reduction Area.
3 Referencebuildingcolumn-rownumbersfromDrawingsTE-l-G-504, -5,-6,-7,-8,-9,-l0,and-ll,TE-16-P-4.
4 TMA: Toxic Maintenance Area, DECON : Decontamination, MCR = Munition Corridor, BSA = I st Floor Buffer Storage Area,
MCR-AL = Munitions Corridor Airlock, AL: Airlock, ECV = Explosive Containment Room Vestibule, ECR = Explosive
Containment Room, TOX = Toxic Cubicle, SDS = Spent Decontamination Solution area, BRA = Brine Reduction Area, LIC = Liquid
Incinerator, MON: Monitor Room, OBS: Observation Corridor, UPA = Unpack Area.
5 Spent decontamination solution. One agent per campaign. Other applicable waste codes are D002, D003, D004, D006, D007, D008,
D009, D010, D019, D022, D028.
6 Liquid agent routinely in area. Potential for collection and containment ofmajor agent spill.
7 BCS = Bulk Chemical Storage
TABLE 4a
ATLIC HAZARDOUS WASTE SUMP I SYSTEMS
SUMP
I.D.NUMBER2
MAXIMUM
ALLOWABLE
CAPACITY
(GALLON)
DIMENSIONSq
SUMP(FEET)
SECONDARY
CONTAINMENT
VOLUME(GALLON)
LOCATION REFERENCE
UTAH
WASTE
CODE
DRAWING3CO
LUMN-ROW FLOOR ROOM4
SDS-PUMP-8526 89 2.3x2.3x2.25 t34 c-5 I Entry
Airlock
B
Fggg5
SDS-PUMP-8527
89 2.3x2.3x2.2,5 t34 A-5 -L
LIC
Room Fgggs. Pggg
SDS.PUMP-8529
89 2.3x2.3x2.25 134 B-5 I Entry
Airlock
A
Fggg5
Tables - Page 9
TOCDF
Tables
July 2008
i;r
I
'r',t fu;
I "'',
il !^1-
l,t'-"- .. c" I*, ..'hllq (i"
olno. Pi^
i,"' t't.t' \J\,
hP
TABLE 4a
ATTIC HAZARDOUS WASTE SUMP ' SYSTEMS
SECONDARY
CONTAINMENT
VOLUME(GALLON)
I Hazardous waste sumgs (meeting the RCRA definition of a tank) must comoly with all aoplicable hazardous waste tank system
requirements (R3 I 5-8- I0).
2 SDS = Spent Decontamination System
3 Rgference building column-row numbers from Drawinss EG-22-D-8217.
4 TOX: Ioxic Cubicle and LIC
=
Liquid Urcin€rator
5 Soent decontamination solution. One aqent p€r camnaign. Oth€r aoolicable waste codes are D002. fnM. D007- D008. D009. D010.
D021.
Ir
Tables - Page 10
TOCDF
Tables
July 2008
Tables-Pagell
TABLE 5
SUMPS SYSTEM DESIGN STANDARDS
SUMP AND TRENCH' NESIGN
STANDARDS
SUMP SYSTEMS
PRIMARY
CONTAINMENT2
SECONDARY
CONTAINMENT3
TOXIC CUBICLE4
Construction Material:welded carbon steel welded carbon steel welded carbon steel
Sump Capacity, gallons 8e (typ)8e (typ)stz (typ)
Specified Shell Thickness, inches 3l16 steel 3l16 steel 3l 16 steel
Dimensions, feet:2.3 x2.3 X2.25(typ)2.3 x 2.3 X 2.2s (typ)4.42x 4.42 x 3.s (tvp)
Grating, inches reinforced fiberglass reinforced fiberglass reinforced fiberglass
Protective Coating Agent Resistant Agent Resistant Agent Resistant
Secondary Containment
Capacity, gallons 134 not applicable 512 required
Corrosion Liner Material concrete not applicable concrete
Liner Thickness 6 inch 6 inch
Protective Coating Dimensions,
feet:Design Temperature, [-j F Agent Resistant Agent Resistant Agent Resistant
Leak Detection System
Visually inspect by
and level detector not applicable
Visually inspect and
level detector
I Standards apply to trenches (for sump collection systern designed with trench).
2 Corresponds to those sumps listed in Table 4 that have a numerical capacity value listed under the "secondary
Containment Volume (Gallon)" column heading.
3 With the exception of SDS-PUMP- 1 51 (see below), corresponds to those sumps listed in Table 4 that have "none
required" listed under the "Secondary Containment Volume (Gallon)" column heading. Those that are designated as
"none required (tank)" correspond to sumps that are part of a secondary containment system for a tank. Those that are
designated as "none required (MDB)" are those MDB RCRA permitted sumps that are part of a secondary containment
systern for miscellaneous operations that occur in the MDB.
4 SDS-PUMP-l5l (Toxic Cubicle Sump.)
o
o
o
TOCDF
Acronyms and Abbreviations
June 2009
APPENDIXA
ACRONYMS AND ABBREVIATIONS
AAI{ Analyzer alarn high
AAFIH Analyzer alarm high-high
AASS Automatic Agent Sampling System
ACAMS Automatic Continuous Air Monitoring System
acfin Actual cubic feet per minute
ACS Agent Collection System
Ag Silver
AIC Analyzer indicator control
AL Airlock
ALM Alarm
AMC U. S. ArmyMaterial Command
API American Petroleum Institute
AQS Agent Quantification System
AR Department of Army Regulations
As Arsenic 'i: '
ASTM American Society for Testing and Materials
ATLIC ,Area l0 Liquid Inciner,ator
ALIX Auxiliary
Ba Barium
BAT Best Available Technology
BCS Bulk Chemical Storage
BDS BulkDrain Station
Bldg Building
BRA Brine Reduction Area
BSA Buffer Storage Area
BST Brine Surge Tank
BTM Bottom
Btu British thermal unitoC Centigrade
CA Combustion air
CAL Chemical Assessment Laboratory
CAMDS Chemical Agent Munition Disposal System (located at Deseret Chemical Depot)
CCL Chemical Control Limit
CCl4 Carbon tetrachloride
CCTV Closed-circuit television
Cd Cadmium
CDC Centers for Disease Control
CDS Central Decontamination Supply
CDTF Chemical Demilitarization Training Facility
CEMS Continuous Emissions Monitoring System
AppendixA-Pagel
CERCLA
CFR
CH+
CHB
CMA
CO
COz
CON
Cr
CRO
CSS
CTC
DAAI\{S
DC
DCD
DDYR
Decon
DFS
DHHS
DIC
DOP
DPE
DRE
DSA
DSHW
DTS
DVS
DVSSR
ECR
ECV
EP
EPA
EVAP
oF
FA
FAH
FIC
FIT
FR
ft
TOCDF
Aoonyms and Abbreviations
June 2009
Comprehensive Environmental Response, Compensation, and Liability Act
Code of Federal Regulations
Methane
Container Handling Building
Chemical Materials Agency
Carbon monoxide
Carbon dioxide
Control Room
Chromium
Control Room Operator
Conditioning Settling System
CutawayTon Container
Depot Area Air Monitoring System
Direct current
Deseret Chemical Depot
Drum Dryer
Decontamination
Deactivation Fumace System
U.S. Department of Health and Human Services
Density indicator control
Dioctyl Phthalate
Demilitarization Protective Ensemble (suits)
Destruction and Removal Efficiency
DPE Support Area
Division of Solid and Hazardous Waste
Drain Tube System
Drum Ventilation System
Drum Ventilation System Sorting Room
Explosive Containment Room
Explosive Containment Room Vestibule
Emergency Power
U. S. Environmental Protection Agency
Evaporators
Degree Fahrenheit
Fire alarm
Flow alarm high
Flow indicator control
Flow Indicating Transmitter
Federal Register
Feet
Gram
Gallon
Sarin, Isopropyl methylphosphonofluoridate
Gas chromatography
ob
gal
GB
GC
Appendix A -Page2
TOCDF
Acronyms and Abbreviations
GC/IVIS Gas chromatography/mass spectrometry
GFE Government Furnished Equipment
gm/cc Grams per cubic centimeter
gpm Gallons perminute
H Levinstein mustard, bis (2-chloroethyl) sulfide
H Hish
Hz Hydrogen
HzO Water
IIPOa Phosphoric Acid
HCI Hydrochloric Acid
IID Distilled mustard, bis (2-chloroethyl) sulfide
HDC Heated Discharge Conveyor
HEPA High efficiency particulate air
IIF Hydrogen fluoride
Hg Mercury
HHS Health and Human Services
HSWA Hazardous and Solid Waste Amendments of 1984
HT Mustard, 60%lD and4}%T
HTS Heel Transfer Ssytem
IIVAC Heating, Ventilation, and Air Conditioning
HWMU Hazardous Waste Management Unit
ICU Intermittent Collection Units
ID Identification
in. Inch, inches
JACADS Johnston Atoll Chemical Agent Disposal System
kg Kilogram
L Liter
LAH Level alarmhigh
LAHH Level alarmhigh-high
LAL Level alarm low
LALL Level alarm low-low
lb(s) Pound(s)
lbm/hr Pound mass per hour
LC Lo Lowest published lethal concentration
Lctsg Lethal concentration - time product that produces 50 percent deaths among
exposed, unprotected, and untreated personnel
LDso Lethal dosage (50 percent death rate)
LDR Land Disposal Restrictions, 40 CFR 268
LIC Liquid lncinerator
LIT Level Indicating Transmitter
LOP Lab Operating Procedure
LPG Liquefied petroleum gas
LSHH Level switch high-high
LSS Life Support Systems
AppendixA-Page3
TOCDF
Acronyms and Abbreviations
June 2009
m/s
MCC
MDB
MDM
MED
mg
MIL-STD
MIN
mL
fllm
MON
MOVP
MPB
MPF
MS
MSB
MUN
mV
mol wt
N2
N/A
NaOCI
NaOH
NFPA
NIOSH
NO
NOz
NO*
NSPS
Oz
OSHA
OVT
OZ
PAHH
PAL
PAS
Pb
PCB
PDARS
PDIC
PEP
PFS
PIC
P&ID
Meters per second
Mine Component Container
Munitions D emil rtanzation Building
Multipu{pose Demil rtanzation Machine
Medical facility
milligrams
Military standards
Mine Machine
Milliliter
Millimeter
Monitor
Maximum Organic Vapor Pressure
Munitions Processing Bay
Metal Parts Furnace
Mass spectrometer, mass spectrometry
Monitor Support Building
Munitions
Millivolt
Molecular weight
Nitrogen
Not applicable
Sodium hypochlorite
Sodium hydroxide
National Fire Protection Association
National Institute for Occupational Safety and Health
Nitrogen oxide
Nitrogen dioxide
Nitrogen oxides
New Source Performance Standards
Oxygen
Occupational Safety and Health Administration
Operational Verification Testing
Ounce
Pressure alarm high-high
Pressure alarm low
Pollution Abatement System
Lead
Polychlorinated biphenyl compounds
Process Data Acquisition and Recording System
Pressure differential indicator control
Propellant, Explosives and Pyrotechnics
PAS Carbon Filtration Systems
Pressure indicator control, Product of Incomplete Combustion
Piping and Instrumentation Diagram
AppendixA -Page4
PIT
PLC
PMD
POHC
ppb
ppm
ppmv
psi
psia
psig
PSL
QA
QC
R3l5
RCRA
RDS
RDX
RTIA
rpm
RSM
RTM
SAIt\
scfh
SCFM
SDS
Se
SOPs
Spent Decon
SPORT
SPS
SRC
STD
SWMU
T
TAH
TAHH
TAL
TALL
TAP
TCLP
TDS
TEAD
TIC
TLV.TWA
TOCDF
Acronyms and Abbreviations
Pressure Indicating Transmitter
Programmable Logic Controller
Proj ectileilvlortar Disassembly Machine
Principal organic hazardous constituent
Parts per billion
Parts per million
Parts per million by volume
Pounds per square inch
Pounds per square inch absolute
Pounds per square inch gauge
Power switch low
Qualrty assurance
Quality control
Utah Administrative Code R3l5
Resource Conservation and Recovery Act
Rinse and Drain Station
Cyclotrimethylenetrinitramine
Residue Handling Area
Revolutions per minute
Rocket Shear Machine
Real Time Monitor
Superfund Amendments and ReauthoizationAct of 1986
Standard cubic feet per hour
Standard cubic feet per minute
Spent Decontamination Solution, Spent Decontamination System
Selenium
Standard Operating Procedures
Spent decontamination solution
Single Pallet Only Rocket Transporter
Secondary power distribution system
Single Round Container
Standard
Solid Waste Management Unit
Bis [2(2-chloroethylthio)ethyl] ether
Temperature alarm high
Temperature alarm high-high
Temperature alarm low
Temperature alarm low-low
Toxicological Agent Protective
Toxic Characteristic Leaching Procedure
Total dissolved solids
Tooele Army Depot, Tooele
Temperafure indicator control
Threshold Limit Value-Time Weighted Average
AppendixA-Page5
TOCDF
Acronyms and Abbrevi ations
TMA Toxic Maintenance Area
TNT Trinitrotoluene
TOC Total organic carbon
TOCDF Tooele Chemical Agent Disposal Facility
TOX Toxic Cubicle
TSCA Toxic Substance Control Act
TSDF Treatment, Storage, and Disposal Facility
TSHH Temperature Switch High-High
TWA Time Weighted Average
UPA UnpackArea
UPMC UpperMunitions Corridor
UPS Unintemrptible Power Supply
VOC Volatile Organic Concentration
VOST Volatile organic sampling train
VX O-ethyl-S(2-diisopropylaminoethyl) methyl phosphonothiolate
VXH VX Hydrolysate, the liquid residue from a treatability studyperformed at CAMDS
where water was added to 12 individual VX ton containers at approximately 10%
byweight
w.c. Water column
wt.Yo Weight percent
XXX Surface decontamination
XXXXX Thermal treatment at l000oF for a minimum of 15 minutes
AppendixA-Page6
2,,J
'-r)o
x
CD
TOCDF
Definitions
October 2009
APPBNDIX B - DEFINITIONS
For pu{poses of this Permit, the following definitions shall apply:
"Administrator" shall mean the U.S. Environmental Protection Agency, Region
VIII, Regional Administrator.
"Agent Free" shall mean the non detection of any chemical agent while
monitoring with an Automatic Continuous Air Monitoring System.
"Baseline Mustard Processing" shall mean the processing of that portion of the
DCD Mustard ton container stockpile that has a mercury concentration of less
than one part per million (<1 ppm (mglkg) in liquid phase of the ton container's
fiIl as determined through analysis of samples collected in Area 10. A Mustard
ton container having sample results meeting this criterion is referred to as a
"baseline ton container."
"Board" shall mean the Utah Solid and H*zardous Waste Control Board.
"Child Container" shall mean a vessel which a slurry of *urt". and solid mustard
heel is transferred to through use of the Heel Transfer System.
"Executive Secretary" shall mean the Executive Secretary of the Utah Solid and
Hazardous Waste Control Board.
"Facility", when used formally, shall mean all contiguous land, and structures,
and other appurtenances, and improvements on the land at the Deseret Chemical
Depot facility. This Facility description is set forth in Attachment I and includes
DCD Area 10, CAMDS, and TOCDF which possess the State/EPA LD. Number
uT5210090002.
"GB" shall mean the nerve agent Sarin with the chemical name of
Isopropylmethylphosphonofl uoridate.
"H" shall mean blister agent mustard prepared through the Levinstein process
with the chemical name of Bis(2-chloroethyl) sulfide or 2,2'-dichlorodiethyl
sulfide - sulfur mustard, that may be contaminated with trace concentrations of
blister agent Lewisite.
"HD" shall mean blister agent mustard that has been purified by washing and
vacuum distillation that may be contaminated with trace concentrations of blister
agent Lewisite
"HT" shall mean blister agent mustard that is a 60:40 mixture of HD and T
(bis[2(2-choroethylthio)ethyl] ether) , that may be contaminated with trace
concentrations of blister agent Lewisite.
"HSWA" shall mean the Hazardous and Solid Waste Amendment of 1984.
"Hazardous Waste Constituent" shall mean any constituent identified in R315-
50-10, or any constituent identified in Appendix IX of 40 CFR Part 264.
a.
b.
d.
e.
ob'
h.
J.
k.
1.
m.
AppendixB-Pagel
p.
TOCDF
Definitions
October 2009
"Hazardous Waste" shall mean a solid waste, or combination of solid wastes,
which because of its quantity, concentration, or physical, chemical, or infectious
characteristics may cause, or significantly contribute to, an increase in mortality
or an increase in serious irreversible, or incapacitating reversible, illness; or pose
a substantial present or potential hazard to human health or the environment
when improperly treated, stored, transported, or disposed of, or otherwise
managed. The term hazardous waste includes hazardous constituents defined
above.
"L" shall mean blister agent Lewisite with the chemical name (2-chlorovinyl)
arsine that may exist at trace concentrations in mustard bulk containers and
munitions.
'Non-Baseline Mustard Processing" shall mean the processing of that portion of
the DCD mustard stockpile that does not meet the definition of baseline
processing. Items meeting the non-baseline definition are 1) Mustard ton
containers and contents having a mercury concentration equal to or greater than
one part per million (mg/kg) in the liquid portion of the ton container's fill as
determined through analysis of samples collected in Area 10, and 2) all HT and
HD mortars.
"Parent TC" shall mean a Mustard Ton Container which a slurry of water and
solid mustard heel is transferred from through use of the Heel Transfer System.
''RCRA, shall mean the Resource Conservation and Recovery Act of 1976, as
amended by HSWA in 1984.
"Release" shall mean any spilling, leaking, pouring, emitting, emptying,
discharging, infecting, pumping, escaping, leaching, dumping, or disposing of
hazardous wastes (including hazardous constituents) into the environment
(including the abandonment or discarding of barrels, containers, and other closed
receptacles containing hazardous wastes or hazardous waste constituents).
"Significance Level" shall mean the observed level of contamination that has
been determined to be allowed to remain. While the concentration of a
significance level is above background concentrations, the observed level must
be below applicable maximum contaminant limits established under the federal
Safe Drinking Water Act, water classification standards, or below applicable air
quality standards.
"Solid Waste lManagement Unit" (SWMU) shall mean any discernible unit at
which solid wastes have been placed at any time, irrespective of whether the unit
was intended for the management of solid or hazardous waste. Such units
include any area at a facility at which solid wastes have been routinely and
systematically released.
"Staged shutdown" shall mean an "operator initiated shutdown to idle".
"On - Site Container ( ONC )" shall mean the vapor-tight overpack container in
which all munitions, with the exception of the spray tanks and the MKl16 bombs
q.
Appendix B -Page}
,J,::,"',:
October 2009
which are currently stored in a different overpack-transport container, will be
transported from the stockpile storage area to the Tooele Chemical Agent
Disposal Facility (TOCDF) and stordd prior to processing.
x. "Transparency Ton Container" shall mean a ton container than has been
determined to be emoty of liquids and solid and whose headspace has been
sampled for Lewisite.
,ty. "VX" shall mean the nerve agent with the chemical name O-ethyl S- (2-
diisopropylaminoethly) methylphosphonothiolate.
Acronyms and abbreviations used in this Permit shall be defined as designated in Appendix A of this
Permit.
All definitions contained in R315-1, R315-2, R315-3, R315-8, and R315-9 are hereby incorporated, in
their entirety, by reference into this Permit, except that any of the definitions used above shall supersede
any definition of the same term given in R315.
Where terms are not defined in the regulations or this Permit, the meaning associated with such terms
shall be defined by a standard dictionary reference or the generally accepted scientific or industrial
meaning of the term.
AppendixB-Page3
9D
C))
Ft
CD)
TOCDF
Facility Description
June 2009
ATTACHMENT 1
FACILITY DESCRIPTION
Attachment 1-Page I
TOCDF
Facility Description
June 2009
TABLE OF CONTENTS
1.1 GENERALDESCRIPTION
1.1.1 Introduction
1.1.2 Facility Location and Setting
1.1.3 Chemical Weapons Destruction Program Overview
1.1.4 Chemical Agent Demilitarization Process Overview
1.1.5 Hazardous Waste DisposaVGeneration
1.2 TOPOGRAPHIC MAP
1.2.1 General
1.2.2 Map Scale and Date
1.2.3 100-Year Flood Plain
1.2.4 Surface Waters
1.2.5 Surrounding Land Uses
1.2.6 Wind rose
1.2.7 Map Orientation
1.2.8 Legal Boundaries of the Facility
1.2.9 Access Control
1.2.10 Local Well lnformation and Groundwater Conditions
1.2.11 Buildings/Structures
1.2.12 Sewers (Storm, Sanitary, Process)
I.2.13 LoadingAJnloading Areas
1.2.14 Fire Control Facilities
1.2.15 Flood Control and Drainage Barriers
1.2.16 Run-off Control Systems
1.2.17 Proposed New and Existing Hazardous Waste Management Units
1.2.18 Solid Waste Management Units (SWMUs)
1.3 LOCATIONINFORMATION
1.3.1 Seismic Standard
1.3.2 Floodplain Standards
1.3.3 Onsite Drainage
1.4 TRAFFIC PATTERNS
1.4.1 General Depot Traffic
1.4.2 Traffic Control
1.4.3 Estimated Volume and Frequency of Shipments
1.4.4 Road Surfacing and Load Bearing Capacity
1.4.5 Restricted Area Traffic
Attachment I -Page2
$
TOCDF
Facility Description
June 2009
rilsT-er+rctms$
I I r eeetienef Desa* €hqr{eelnepet; datC 26 May 1998
I 3 ltrprexknoteGreurCwataMerdterWell r eeatien; datC 26 May 1998
LIST OF TABLBS
1-1 Original Stockpile e+of Chemical Weapons to Be Destroyed at TOCDF
l-2 Chemical Agents to Be Destroyed at TOCDF
1-3 Composition of Munitions and Bulk Items
Attachment I -Page3
TOCDF
Facility Description
June 2009
LIST OF ACRONYMS
ATLIC Area 10 Liquid Incinerator
BCS Bulk Chemical Storage
BRA Brine Reduction Area
CAL Chemical Assessment Laboratory
CAMDS Chemical Agent Munitions Disposal System
CFR Code of Federal Regulations
CHB Container Handling Building
CSB Communication Switch Building
CSDP Chemical Stockpile Disposal Program
CWC Chemical Weapons Conve,ntion
DCD Deseret Chemical Depot
DVS DrumVentilation System
DVSSR Drum Ventilation System and Sorting Room
DFS Deactivation Furnace System
ECF Entry Control Facility
GA Tabun: dimethylphosphoramidocvanidic acid ethyl ester
GB Sarin, Isopropyl methylphosphonofluoridate
II/HD/HT Sulflr Mustardr lDistilled Sulfrr Mustard/Distilled Mustard with 4O%Bis-[2-(2-
chloroethylthio) -ethyll ether
HVAC Heating, Ventilation, Air Conditioning
JACADS Johnston Atoll Chemical Agent Disposal System
L Lewisite: dichloro(2-chlorovinyl)arsine
LIC Liquid Incinerator
LPG Liquefied Petrolzum Gas
MDB Munitions Demilitarization Building
MSB Monitor Support Building
MPF Metal Parts Furnace
NDAA National Defense Authorization Act
NFPA National Fire Protection Association
OSIA On Site Inspection Agency
PAS Pollution Abatement System
PMB Personnel Maintenance Building
PMCD ProgramManager for Chemical Demilitarization
POT Potable Water System
PRW Process Water System
PSB Personnel Support Building
PUB Process and Utility Building
SWMU Solid Waste Management Unit
T Bis-[2-(2-chloroethylthio)-ethyl] ether
TCB Treaty Compliance Building
TMA Toxic Maintenance Area
TOCDF Tooele Chemical Agent Disposal Facility
UPA Unpack Area
VX O-ethyl-S-(2-diisopropylaminoethyl) methyl phosphonothiolate
WTS Water Treatrnent System
I Sulfur Mustard - Bis(2-Chloroethyl) Sulfide or 2.2'Dichlorodiethyl Sulfide
Attachment I -Page4
TOCDF
Facility Description
June 2009
o 1.1
1.1.1
1.1.1.1
GENERAL DESCRIPTION [R3 1 5-3-2.5ftX1)I
Introduction
The Tooele Chemical Agent Disposal Facility (TOCDF) is a multi-incinerator hazardous
waste treatment and storage facility located within the federally owned Deseret Chemical
Depot (DCD).
The TOCDF is designed and constructed for the treatment of the chemical agents and
munitions stockpile currently stored at the DCD Area l0 (a.k.a. Chemical Munitions
Storage Area). Area 10 is immediately adjacent and physically connected to the northern
end of the TOCDF.
l,l,l,2
l.I .2.2
l.r.2.3
t.t.2.4
1 . I .l ..3 The Area l0 Liquid Incinerator (ATLIC) is TOCDF operated. but located in DCD Area
1.1.2
10. separate from the TOCDF site. .The ATLIC has beeir built to treat the chemical nerve
aq€,nt GA and the blister ag€nt Lewisite (L). The ATLIC and oth€r TOCDF-oDerated
facilities are described in paragraoh 1.1.2.4.
. Facilitv Lqgltio4 and Settins
ihg-OCO is leeate*in the State irf Utatr @about 7,900 hectares,*ndjs
located approximately 26 kilometers (16 miles) south of the Cily of Tooele, off State
Highway 36 at latitude 40o 18'00" North and longitude 112" 20'00" West. DCD is
leeate*approximately 56 kilometers (35 miles) southwest of Salt Lake City,
approximately 48 kilometers (30 miles) south of the Great Salt Lake, approximately 48
kilometers (30 miles) west of Utah Lake, and approximately 61 kilometers (38 miles) west
of the city of Provo.
Teeele €erxrf 'and :ts relatien te the ether tewns; eities; arC geegraplilelan&narks in the
are*. The locationg of the'TOCDF and the ATLIC are'liee within the DCD installation
boundaries as shown in Drawing TE-16-C-2.3
DCD is generally rectangular in shape: approximately 6.5 miles in length (east-west) and 5
miles in width (north-south) and comprises 19,364 acres. Several tlpes of chemical
agents are stored at DCD in a variety of ammunition configurations, including ton
containers, projectiles and mortars. These munitions are stored in Area 10.
The processing area at the TOCDF, which is enclosed by a security fence, is comprised of
approximately 40 acres. The distance from TOCDF demilitarization site to the nearest
DCD boundary (due north) is approximately 2 miles.
There are si*seven TOCDF-operated facilities, in addition to the TOCDF plant, on the
DCD installation. but outside the site bo duie :
l.l ,2.r
l.r.2.4.1 The administration building located at 11600 Stark Road, approximately 3 miles northeast
of the TOCDF. This building houses administrative offices only.
2 All figures are addressed at the end of this attachment.
3 All drawings are addressed in Attachment 11.
Attachment I -Page5
l.l .2.4.2
1,L.2.4.3
1.1 .2.4.4
1.1 .2.4.5
1.1.3
1.1.3.1
1.1.3.3
1.1.3.4
TOCDF
Facility Description
June 2009
The Chemical Assessment Laboratory (CAL). This facility is located approximately 1.5
miles southwest of the TOCDF. The CAL has laboratory quantities of chemicals and neat
and dilute solutions of chemical agents on location, but not in quantities sufficient to pose
a danger to persons or the e,lrvironment beyond the boundaries of the lab.
The area known as Area 2 contains a number of warehouses. TOCDF controls eight of
the warehouses in Area 2. These warehouses are used for storage of various items such as
office furniture, tools, brick, product chemicals, and construction materials. Warehouses
usedby TOCDF are buildings 4001, 4002,4012,4057,4058,4108, 4109, and 4110.
TOCDF may use other buildings for the storage of material and equipment. Area 2 is
located approximately 2 miles east-southeast of the TOCDF.
The Transfer Yard is located approximately 1.5 miles easVnortheast of the TOCDF.
Storage 1633, Igloo 1632@rum Veirtilation System (DVS) and Drum Ventilation System
Sorting room @VSSR) Operations and Container Storage), and Igloo 1631 (Autoclave
Operations) are located within DCD Area 10 which is immediately adjacent to and
physically connected to TOCDF. The balance of Area 10 is permitted under a separate
Part B RCRA permit administered by DCD.
1.1.2.4.6 The ATLIC. also located at Area l0 in Ieloo 1639 (northwest of TOCDH. is designed and
1.1.3.2
constructed for the treatmeirt of chernical nervp aeentGA and blister ae€nt lewisite (L).
The ATLIC is accessible thrrough the Area I0'ECF. at the northwest end of Area 10.
Chemical Weapons Destruction Prosram Overview
The U.S. Army maintains a stockpile of chemical agents and munitions for the
Department of Defense. This stockpile was established to deter other countries from using
chemical weapons on U.S. or allied troops. In 1968, the U.S. stopped manufacturing
chemical weapons. The stockpile is no longer deemed necessary for national security.
ln November 1985, the U.S. Congress approved the Department of Defense Authorization
Act (Public Law 99-145) which directed and authorized the destruction of 90 % of the
total U.S. stockpile of unitary chemical munitions and agents by 30 September 1994.
The Act was first amended on 15 March 1988 when the Army submitted the Chemical
Stockpile Disposal Program (CSDP) implementation plan to Congress in which the
deadline for destruction of the unitary chemical weapons stockpile was extended to 30
Apnl1997. This amendment also allowed more full-scale testing of the Johnston Atoll
Chemical Agent Disposal System (JACADS) facility.
On 28 October l992,theNational Defense Authorization Act (NDAA) for fiscal year
1993 directed the Army to dispose of the entire unitary chemical weapons stockpile by 31
December 2004. The NDAA supersedes Public Law 99-145.
In April 1997,the Chernical Weapons Convention (CWC) was ratified by the United
States and supersedes the NDAA. The CWC indicates that destruction of the unitary
chemical weapons stockpile must be complete not later than 10 years after entry into force
of this Convention (i.e., the year April 2007).
o
1.1.3.5
Attachment I -Page6
O 1.r.3.6
TOCDF
Facility Description
June 2009
Chemical weapons are stored at eight separate sites throughout the continental United
States, including the DCD.a At the begiming of agent destruction activities in 1996, DCD
had the largest portion of the nation's chemical agent stockpile. Table l-1 shows the
makzup of the DClDei,ginol stockpile that was either already or yet-to=be destroyed at
TOCDF andthe ATLIC
4 The seven other sites are: Pine Bluff Chemical Activity, Arkansas; Anniston Chemical
Activity, Alabama; Umatilla Chemical Depot, Oregon; Newport Chemical Depot, Indiana;
Fdgewood Chemical Activity (Aberdeen Proving Ground), Maryland; Blue Grass Chemical
Activity, Kentucky; and Pueblo Chemical Depot, Colorado.
Attachment I -Page7
TOCDF
Facility Description
June 2009
* These agents and munitions have been destroyed as ofNovernber 2009.
** Transoarencv Ton Container were assaved and found not to contaln an recoverable liouid asent and are not
includid as oart of the DCD Chemical Stockolle.
Facilitv shown in parenthesis denotes location of treatment of the munitions end bulk containers
for the asent specified.
s The Army's Chemical Stockpile Disposal Program began destroying the chemical stockpile at
the TOCDF in August 1996. These numbers do not reflect chemical weapons destroyed since
operations began. As of June 2005, all bulk containers and munitions containing VX and GB
nerve agents have been eliminated from the stockpile.
Table 1-1
ERIGF{*LSTOCKPILE OF CMMICAL WEAPONS FOR DESTRUCTION
WTTOCDFORTHEATLIC
Agent Item Quantityt Poundss
HT-Blister
(TOCDF)
4.2" Mortars 62,590 363,020
HD-Blister
(TOCDF)
4.2" Mortars 976 5,860
Ton Containers 6,398 1 1,3 83,420
H-Blister
ffOCDF)
155mm Projectiles 54,663 639,540
GB-Nervea
ffOCDF)
105mm Cartridges I 19,400 194,620
105mm ProJectiles 679,303 1,107 ,260
M55 Rockets 28,945 309,720
M56 Rocket Warheads 1,066 11,406
l55mm Projectiles 89,141 579,417
MK-l 16 Bombs 888 308,140
MC-l Bombs 4,463 981,860
Ton Containers 5,709 8,598,200
VX-Nervel
ruOCDF)
155mm ProJectiles 53,216 319,300
lll/.23 Land Mines 22,690 238,240
M55 Rockets 3,966 39,660
M56 Rocket Warheads 3,560 35,600
TMU-28 Spray Tanks 862 1,168,880
Ton Containers 640 910,960
GA-Nerve
(ATLIC)Ton Containers 4 4.1 l0
L-Blister
(ATLIC)Ton Containers 10 25.924
TransparencY**
(ATLIC)Ton Containers 10 0
Attachmentl-Page8
TOCDF
Facility Description
June 2009
The DCD stockpile of chemical agents includes organophosphate nerve agents and blister
agents as listed below:
1.1.3 .7 .l nerve agent VX
1.1.3 ,7 .2 nerve agent Sarin (GB)
1.1.3 .7 .3 blister agents mustard (H, HD, and HT).
I.1,3.7,4. - nerye aggnt tabun (GA)
1.1.3.7.5 , . blister agent lewisite (L). an aTsine cemBound.
1.1.3.7
1.1.3.9 Information on chemical agent characteristics are briefly described in Table 1-2.
Attachment I -Page9
TOCDF
Facility Description
June 2009
* Tlrcse agents and munitienshave akeady been deskeyed,
Facilitv shown in oarenthesis denotes location of treatment of the munitions and bulk containers for
the apent specilied.
Table 1-2
CIIEI\IICAL AGENTS FOR DESTRUCTION WT TOCDT'g
ATLIC
Agent Description
GBT
(TOCDF)
GB (Sarin) is a rapid-acting nerve agent. The action within the body is the
inactivation of cholinesterase. The hazard from GB is that of vapor
absorption through the respiratory tract, although it can be absorbed
through any part of the skin, through the eyes, and through the
gastrointestinal tract by ingestion. The agent absorption rate is accelerated
through cuts and abrasions in the skin. When dispersed as large droplets,
GB is moderatelypersistent; it is nonpersistent when disseminated as a
cloud of very fine particles.
vxt
ruOCDF)
VX is a rapid-acting nerve agent. The action within the body is the
inactivation of cholinesterase. The hazard from VX is primarily that of
liquid absorption through the skin, although it can be absorbed through the
respiratory tract as a vapor or aerosol, and through the gastrointestinal tract
by ingestion. VX is slow to evaporate and may persist as a liquid for
several days.
NIustard.
ffOCDF)
Mustard is a persistent and powerful blister agent. It acts principally by
poisoning the cells in the surfaces contacted. Both liquid and vapor cause
intense inflamrnation and may cause severe blistering of both the skin and
mucous membranes. Mustard is only moderately volatile.
Mustard is designated H, HD, and HT. H is mustard made by the
Levinstein process. It contains up to 25 percent by weight of impurities,
chiefly sulfur, organosulfir, and polysulfides. HD (distilled mustard) is
mustard purified by washing and vacuum distillation, which reduces the
impurities to about 5 percent. HT is a 60:40 mixture by weight of HD and
T. T is an abbreviation for Bis-[2-(2-chloroethylthio)-ethyl] ether.
GA
(ATLIC)
GA (tabun) is a rapidly-acting nerve agent that inactivates cholinesterase
shortllr after contact. The hAzard from QA is that of vapor absorption
throueh the respiratorv tract. althoush it can be absotred throush anv part
of the skin. through the eyes. and through the gastrointqstinal tract
(ingestion). The agent absorption rate is accelerated through cuts and
abrasions in the skin. Wherr dispersed as larse droplets. GA is moderatelv
Dersistent: it is nonDersistent when disseminated as a cloud of very fine
particles.
L
(ATLIC)
Lewisite is a powerfrrl irritant and blistering agent that immediately
damases the skin. eyes. and respiratory tract. The bigeesthazard of L is
that of vapor absomtion throush the respiratory tract. althoueh it aan be
absorbed throuch skin. eyes. and eastrointestinal tract (insestion). Breause
it contains arsenic. lewisite has some effects that are similar to arsenic
poisonins. includine stomach ailments and low blood Dressure.
Attachment I - Page l0
1.1.3.9
TOCDF
Facility Description
June 2009
The chemical agents are stored at the DCD Area 10.6 The chemical agents are contained
in mortars, artillery projectiles, and ton containers. Information on the munitions and bulk
items is summarized in Table 1-3.
6 Area 10, with the exception of Igloos 1632 and 1633, is permitted under a separate part
permit and administered by DCD.
Attachrrentl-Pagell
COMPOSITION
Table 1-3
OF MT]NITIONS AI\D BT}LKITEMS
Munition Agent Fuse Burster Propellant Dunnage
4.2 in. mortars HD, HT Yes Yes Yes Yes
155-mm projectiles H No Yes'No Yes
Ton Containers H, HD. L. GA No No No No
TOCDF
Facility Description
June 2009
Chemical Aeent Demilitarization Process Overview
The TOCDF system involves reverse asseinbly of chemical agent-filled munitions and
includes four incinerators for agent destruction.
The TOCDF-olrerated ATLIC includes a Liquid Incinerator (LIC) for th€nnal destruction
gf chemical agents GA and L. which'are stored in ton containers in DCD Area 10.
l.l. .3 eieurol 2pres€ntsa.rirryli
ffi treatment processes are based on the destruction of chemical
ageqts.and energetic materials (enersetics at TOCDF only) by incineration. The primary
processes employed at the planlTOCDF and AN€QF+ATUC andnd simplified +OGDF
layoutg 3tg.is briefly discussed below.
1.1.4
1.1 .4,1
1.1 .4.2
1.1 .4.3
l.l .4.3.1
1.t.4.4.t
1.1.4.5
| .L4.5.1
Munitions Processins
The munitions processing at the TOCDF includes initial separation of explosives and
draining of the chemical agent. The Deactivation Furnace System (DFS) processes
explosives removed from mortars, and projectiles. The Metal Parts Fumace MPF)
thermally decontaminates all drained bulk items, projectiles, and mortars from. wtrich the
energetic components have been removed.
1.1..4.3.2 The ATLIC will be disoosinq onl], of GA. L. and Transpar€,ncy ton contain€rs and soe,nt
1.t.4.4
decontamination (speirt decon) and rinse solutions: there are no explosives involved.
Aeent Processinq
The Crahe*chemical agentg mustardJGA.end_t that are drained from bulk items and
munitions'g4-eis bumed in the various Liquid Incinerators (LICs), along with spent
decontamination solution and miscellaneous waste liquids. The TOCDF has two LICs
and the ATLIC has one.
Pollution Abatement System
The flue gases from the DFS, MPF, and LICs are treated via separate wet Pollution
Abatement Systems (PAS). The scrubber liquid (brine) from the wet scrubbers is pumped
to storage tanks and transported off site for treatment and disposal.
' While the majority of these items contain bursters, some are stored without these components.
Attachment I -Page12
TOCDF
Facility Description
June 2009
1.1.4.5.2. ATLIC exhaust eases are treated in a unique PAS that is both wet and drv.
Exhaust eases first pas throush a Ouench Tower. which causes them to cool
and become saturated with water. The eases next pass throush a series of
Packed-Bed Scrubbers that have chilled scrubber solution flowine throueh
them. The chilled scrubber solution causes the water in the exhaust eas to
condense. The sases later pass throush an electric re-heater which ensures
the eases are at a temperature higher than the dew point. The remainder of
the ATLIC PAS downstream of the eas re-heater is a drv PAS and equipped
accordinelv with a Pulverized Activated Carbon (PAC) Iniection Svstenl
and a Baehouse.
1.1.4.5.2.1. Soent scrubber brines which are collected in tanks and baehouse residues
which are collected in containers are transported off-site for treatment and
disposal.
1.1.4.6 Plant Operation
l.l .4.6.1 The TOCDF is operated 24 hours per day, 7 days per week, and 52 weeks per year.
Personnel are at the site at all times.
I .1 .4.6,2 The ATLIC operates 24 hours per day and 7 days per week. Personnel are at the site at all
times.
1.1.5 Hazardous Waste DisposaVGeneration
1.1.5.1 Chemical Aeents and Munitions
1.1.5.1.1 When the munitions or bulk agents are delivered to the TOCDF or ATLIC from Area 10,
the physical and accounting responsibilitiest4s are transferred from the storage account
managed by the DCD commander to a demilitarization accountg managed by the TOCDF
or ATLIC Site Project Managerg and the items are removed from the Army's inventory of
chemical munitions. At this point, all bulk items and munitions will be classified as e
hazardous wasteg. Agents GB, VX, GA. L. and mustard ago#are classified as a
hazardous wasteg by the State of Utah.
1.1.5.2 Potentiallv Hazardous Wastes Generated at the TOCDF and ATLIC
1.I.5.2.1 In addition to chemical agent and munition wastes, there are potentially hazardous wastes
generated during TOCDF and ATLIC operations that may require either interim storage,
further on-site treatment, or shipment off site to an approved hazardous waste management
facility. Waste streams generated at the TOCDF and ATLIC are described in detail in the
Attachment 2 (Waste Analysis Plan). These wastes include but are not limited to:
I .l .5.2.I .l The brine generated from the incinerator pollution abatement system.
1.1,5.2.1.2 Reserved.
1.1.5.2.1.3 Dry residues and ash collected from the TOCDF DFS.
Attachment I - Page 13
1 .1 .5 .2.1 .4
1 .l .5 .2.1 .5
1 .l .5 .2.1 .6
1 .l .5 .2.1 .7
1.1.5.2.1.8
TOCDF
Facility Description
June 2009
Ash frtrn the operation of the TOCDF MPF.
Ventilation systern and PAS filters.
Monitoring support and laboratory wastes generated from onsite chemical analysis.
Spent Decontamination Solution.
Ton container rinsate
1.1.5.2.1.9 PersonalProtectiveEquipment(PPE)
1.1.5.2.1.10 Decontaminated ton containers
1 .l .5.2.1 .1 1 ATLIC constructioa waste
1.1.5.2.1.12 agbouse residues
1.1.5.3
1.1.5.3.1
I .1 .5 .3,2
1 .1 .5 .3.3
1.2
r.2.1
1.2.1 .l
1.2.1 .1 .1
1.2,1 .1 .2
I .2.1 .1 .3
1.2.1 .1 .4
1.2.1 .1.5
TE-16-C-2
TE-16-C-3
TE-r6-C-4
T'E-16-C-5
TE-16-C-6
RCRA Hazardous Waste Treatment and Storaee Units that are Pernitted
The hazardous waste management (process) systems consist of Container Storage, Tank
Storage, Treatment in Tanks, Liquid lnjection Incineration, Rotary Kiln lrcineration,
Multiple Hearttr Incineration, Treatment In and Using Miscellaneous Treatment Units.
Treatment codes are referenced in R315-50-2.
The incinerators are classified as hazardous waste incinerators because they are enclosed
devices that use controlled flame cornbustion to thermally break down hazardous waste.
The containers hold explosives, propellants, the various agents (e.g., ton containers and
other items of equipment that contain these materials), and brine salts and dry residues
from combustion. The storage of chemical agents, explosives, and propellants in the
munitions and bulk items are addressed as container storage with regard to the hazardous
waste regulations.
Chemical and physical characteristics of the chemical agents and explosives are described
in the Attachment 2 (Waste Analysis Plan). Tanks hold agurt, spent decontamination
solution, brine, and miscellaneous liquids listed in Module IV.
TOPOGRAPHIC MAP tR3 15.3.2.5&)(1 9)I
General
The following drawings+nd$gur6s ire used to satisff specific TOCDF fa€ility
description requirements :
Overall Site Plan & Vicinity Map
Topographic Map (restricted access - protected record)
Site Work Area I Plot Plan
Site Work Area 2 Plot Plan
Site Work Area 3 Plot Plan
Attachment I - Page 14
TOCDF
Facility Description
June 2009
| ,2.1 .1 .6
1.2.1 .1.7
| ,2.1 .1 .8
1.2,2
1.2,2.1
1.2.3
r.2.3.1
EG-16-C-7402
TE-22-C-10
TE-22-C-13
Site Work Storm Drain Plan
Sewage Lagoon Site & Grading Plan
Reservoir Site and Grading Plan
1,2,1,1,9 Figure L-l- r eeetienef Desaet €hqrdeel Depet
1,2'l'1,10 Figure I 3 rtfpreximateGrerxCwaterMeniterWell'eeetien
t.2.t.2 Drawing TE-l6-C-3 (restricted access - protected record) is a Topographic Map of the
TOCDF site and includes the local surrounding area to a distance of at least 1,000 feet
from the site perimeter. Map scale is 1 inch equals 100 feet and the contour interval is 5
feet.
I .2. 1 .3 The ATLIC is in Area 10. which includes permittd hazardous waste container storaee
1.2.2.2
units reeulat€d b), the DCD RCRA Perrnit. fuea 10 is depicted in TE-16-C-3 and the
ATLIC is detailed in EG-22-G-8221 (no scale).
Mao Scale and Date
The current revision and date of each drawing is indicated in the lower right-hand title
block. The current date of each drawing is indicated in the lower right-hand corner.
Likewise the scale of each map is shown. unless otherwise noted.
Drawings TE-16-C-2 and TE-16-C-3 are drawn to a scale of 1 inch equals 100 feet. The
DCD portion of Drawing TE-l6-C-3 is drawn to a scale of 1-inch equals 2500 feet.
Drawing EG-22-G-8221 does not indicate scale.
100-Year Flood Plain
The DCD has not been mapped for the National Flood Insurance Program and thus there
are no 100-year floodplain maps for the installation. The floodplain standard is discussed
in further detail in section 1.3.2.
Surface Waters
The DCD TOCDF and ATLIC sites altheD€D'algis located at an elevation
(approximately 5170 feet)8 overlooking a relatively flat and arid lowland basin known as
Rush Valley. The TOCDF buildings are approximately 140 feet higher in elevation than
the valley floor and more than 7,000 feet horizontally distant.e
Area 10. where Igloo 1639 (the ATLIC) is located. is built on an evenly-saded site that is
relatively unoaved. so there is little runoff. The ATLIC will not impact surface waters
because the entire facility is eirclosed. includine the PAS.
t.2.4
1.2.4.1
r.2,4.2
8 Precise TOCDF site brass cap morument elevation markers are indicated on Drawings
TE-16-C-5 and TE-16-C-6.
e The brass cap monument markers located on the commercial railway due west of the
TOCDF indicate an elevation of 5030 feet. (United States Geological Survey, Saint John
Quadrangle, edited 1993).
Attachment 1 - Page 15
L.2.4.3
F""ili,y D"J3ec,lo:
Water-related features pertinent to the TOCDF3Od A[Lrc siteg are minor in importance,
primarily because of their absence. Surface waters in Rush Valley include Rush Lake,
Faust Creek and Reservoir, Vernon Creek and Reservolr, Ophir Creek, Clover Creek, and
shallow ponds east of the town of Rush Valley. Several seasonal small streams, which
originate in the Oquirrh, Stansbury, Onaqui, Tintic, and Sheeprock Mountains, disappear
on the dry Rush Valley floor. No surface waters leave the valley. Runoff in Tooele
Valley, which lies north of Rush Valley, drains to the northwest and into the Great Salt
Lake. Most grciundwater recharge occurs through infiltration of precipitation in the
mountains, and to a lesser degree, from stream recharge and irrigation. The topography of
the drainage basin is generally smooth and uniform, sloping to the west from the TOCDF
to the Rush Valley floor. The valley floor drains to Rush Lake, which is located
approximately 1l miles northwest from the TOCDF.IO
The 460-square mile Rush Valley drainage basin is characterized as having poorly drained
alkaline soils of moderately consolidated and unconsolidated layers of sand, gravel, silt,
and clay.rr Nevertheless, floods do not occur because of the arid climate and the storm
water drainage system installed at the TOCDF. The lack of intermittent streams or defined
flow paths in the valley confirms the lack of flooding potential. The elevation of the
TOCDF above the valley floor further protects it from flood threats.
Surroundins Land Uses
The location of the TOCDF within the DCD installation boundaries is shown on Drawing
TE-16-C-2. Also located on DCD property are the Chemical Agent Munitions Disposal
System (CAMDS) facility, the CAL;!T!IQ, and associated TOCDF operated facilities as
described lr,I.l.2.?4. DCD (except Igloos 1631,1632 and 1633) and the CAMDS
facility operate separately and independently of the TOCDF and are not addressed in this
documen[howwe1, r#h€reos-the CAL and ATLIC flsloo 1639) plays an integral part in
TOCDF demilitarization operations. DCD also oversees other activities that relate to the
overall operation of the Depot. Other areas within DCD are open range and are controlled
by the military. The majority of the land surrounding DCD is likewise federally owned.
Much of the 6,919 square mile Tooele County, where DCD is located, is sparsely
populated. DCD was constructed in1942 in Rush Valley. Originally, DCD was a
relatively remote area, accessible only by a railroad that was used for collection and
r0 The elevation of Rush Lake is estimated to be approximately 5000 feet. See+igure#r
rr The Rush Valley is an elongated, north-south oriented, intermountain basin located between
the Oquirrh Mountains to the east, the Stansbury and Onaqui Mountains to the west, and the
Shiprock Mountains to the south. Rush Valley is located in the eastern Basin and Range
physiographic province and is representative of intermountain basins within the province. Rush
Valley is partially filled with alluvial sediments and lake beds. Geologic formations in the
Vicinity consist of Paleozoic sedimentary rock, along with gravel, sand, and clay. The TOCDF
is located near the bdse of the Oquirrh Mountains, where the land surface consists of relatively
porous colluvial and alluvial deposits containing sand and gravel, with some conglomerate and
clay.
1.2.4,4
1.2.5
1.2.5.1
1.2.5.2
Attachment I - Page l6
O
TOCDFa*t,,*rrTf*;;
distribution of mtrnitions. Access to Rush Valley is possible on State Highway 36 from
the north and State Highway 73 from the east.
Year 2000 population figures estimate the population for all of Tooele County at
approximately 40,000. Presently, the majority of the county's population is concentrated
north of the South Mountain geologic land formation, which separates Rush Valley from
Tooele Valley.r2
A few small communities, including Stockton, Rush Valley, and Ophir, ranches, and
mines are located between a 10-kilometer to 2S-kilometer (6-mi1e to 15-mile) radius of the
TOCDF. No crty or town lies within 10 kilometers (6 miles) of the TOCDF.
Land use outside the DCD is dominated by livestock gi:azlrl;g. Beef cattle lead as the
primary livestock, followed by sheep.
Cropland accounts for only a minute fraction of the agricultural land use around DCD.
Only 2.9% of the Rush Valley Basin has been cultivated for growing crops. Crops grown
in the area include wheat, barley, corn; oats, and alfalfa. Since rainfall in the valley is
limited, r4gation is a common practice among the agricultural sector. Water is obtained
from nearby streams and water storage reservoirs.
Wind Rose ' '
The wind rose for the TOCDF and ATLIC is included on Drawing TE-l6-C-3 (restricted
access - protected record). The wind rose plot is from data collected at the DCD weather
station located in Building 5108 and reflects 1997 -year end data from Weather Station 9.
The prevailing winds at the TOCDF area follow the orientation of the mountain ranges
flanking either side of the facility.'3 Winds are prevalent from the south through southeast
in the summer and from the north through northwest in the winter.
t.2.5.3
r.2.5.4
1.2.5.5
1.2.5.6
1.2.6
1.2.6.1
1.2.7
1.2.7 .l
1.2.8
1.2.8.1
1.2.6.2 The wind rose
reference above is applicable to all facilities within the DCD boundary since
mountains flank the entire boundary of DCD.
Man Orientation
All drawings referenced in Paragraph 1.2.1 have a north arrow direction indicator.
Lesal Boundaries of the Facilitv
Drawing TE-16-C-2 shows the legal boundaries of the TOCDF. The legal boundaries of
the TOCDF are defined as the area enclosed by the outer security fence and the portion of
the existing fence along Heart Street that connects the TOCDF to Area 10 perimeter fence.
12 Year-end population estimates are as provided by Utah Department of WorKorce Services.
'3@oquirrhMountainslietotheeastandtheonaquiandStansbury
-Mountains to the west of the TOCDF.
Attachment I -PagelT
TOCDF
Facility Description
June 2009
The only waste management units in the immediate vicinity of the TOCDF plant are those
units located at the facility itself and Igloos 1631, 1632,rnd 1633. and 1639 within DCD
Area 10, located adjacent to and connected with TOCDF.
1.2.9 Access Control
L2.9.l Access to the DCD is via County Road 198, connecting State Highway 73 to the Main
(North) Gate, and via State Highway 73 directly connecting to the Doolittle Road and the
East Gate.
1.2.9.2 Entry to the TOCDF is controlled through the Entry Control Facility (ECF) located at the
southem end of the facility. Attachment a (Security) provides a detailed narrative
describing the security measures that are in place at the TOCDF and how access is
controlled. All personal vehicles are parked outside of the TOCDF and do not impact the
traffic within the fence.
1.2.9.3 Entry to the ATLIC is controlled throueh the Area l0 ECF located at the northwest end of
1.2.9.4 Generally, all traffic (including government vehicles, commercial carriers, and privately
owned vehicles) follows the primary traffic route. Only security vehicles, conventional-
munitions transportation vehicles, and maintenance vehicles travel off of the primary
route
1.2.9.45 As shown in Drawing TE-16-C-2, the TOCDF is immediately adjacent to and physically
connected to Area 10, and therefore, the area becomes a contiguous restricted area.
Consequently, there are no over-the-road transport or demilitarization items outside of this
area. The ATLIC is inside Area 10. and there are no overthe-road transports or
demilitarization items outside this area.
1.2.10 Local Well Information and Groundwater Conditions
1 .2.1 0. 1 There are no injection or withdrawal wells located at the TOCDF_or AT'UC. fipre+g
six groundwater monitoring wells forn*near
the TOCDF sewage lagoon.
1.2.10.2 Groundwater occurs in three distinct aquifeis in Rush Valley. The most extensive aquifer
is the basin-fill aquifer. The overlying, relatively impermeable, clay-sized lacustrine
sediments confine this aquifer, and restrict hydraulic communication between it and the
playa surfaces. The sand and gravel of the alluvial fans along the flanks of the mountains
compose the second alluvial-fan aquifer. The highest quality groundwater obtainable in
Rush Valley is contained in this aquifer. The third is an unconfined, shallow-brine
aquifer, which lies just below the valley surface. Groundwater quality in the Rush Valley
ranges from fresh to briny.
1.2.10.3 Recharge to Rush Valley is almost entirely provided by rainfall and snow melt from the
surrounding mountains. The basin-fill aquifer is recharged by subsurface inflow from
adjacent alluvial fans and underlying Tertiary or Paleozoic rocks.
Attachrnent I - Page l8
I .2.10.4
TOCDF
Facilitv'rTriis;
A southwest-to-northwest trending groundwater divide, which passes through the DCD,
separates the flow of groundwater in Rush Valley into two distinct regions. Precipitation
entering the ground water beneath the TOCDF and ATLIC can flow either toward South
Mountain or the Thorpe Hills, depending upon which side of the divide they enter the
aquifer.
Buildines/Structures
Drawing TE-16-C-2 shows all existing buildings, roads, railroads and fences in the
vicinity of the TOCDF. Major buildings/structures located inside the TOCDF security
fence include the following: Container Handling Building (CIIB); Entry Control Facility
(ECF); Monitor Support Building (MSB); Treaty Compliance Building (TCB); Pollution
Abatement System (PAS); Personnel Maintenance Building (PMB); Process and Utility
Building (PUB); Various craft shops and supply warehouses; Brine Reduction Area
Pollution Abatement System (BRA PAS); Heating, Ventilation, Air Conditioning
(IIVAC) Filters; and Munitions Demilitarization Building (MDB).
Major components of the MDB include the following: Deactivation Fumace System
(DFS);Metal Parts Fumace (MPF); Two Liquid Incinerators (LICs); Control Room; and
various disassembly and support areas essential for processing the full range of the DCD's
unitary stockpile of agents and munitions.
Major buildings/structures located outside the TOCDF security fence include the
following: Chemical Assessment Laboratory (CAL); Communication SwitchBuilding
(CSB); Personnel Support Building (PSB); On-Site Inspection Agency (OSIA);
Warehouse Buildings S-7 and S-8, and Area 10 Igloos 1631, 1632,rnd 1633. and 1639.
which liaafq within the Area 10 security fence.
Sewers (Storm. Sanitarv. Process)
There are no sanitary or process sewage systems within the 1,000-foot radius of the
TOCDF, other than the one constructed for the TOCDF. Location of the TOCDF Sewage
Lagoon is shown on Drawing TE-22-C-10. Area 10 sewers are covered by the DCD
RCRAPermit.
Loadiney'Unloadins Areas
The chemical agents stored at the DCD Area 10 are stored in mortars, artillery projectiles,
and ton containers. The munitions or bulk containers are loaded into overpacks in Area
10, placed on specialized trucks, and taken to the TOCDF CHB.r4 The overpacks are
moved from the CHB by conveyor to the Unpack Area (UPA) of the MDB. At the UPA,
the air inside the overpack is monitored for agent, which would indicate a leaking
container.
A second TOCDF unload area involves the transfer of fuel and bulk chemicals from trucks
to the Bulk Chemical Storage (BCS) facilities and Liquefied Petroleum Gas (LPG) tank.rs
l.2.ll
1.2.1 1.1
1.2.1r.2
1.2.1 1.3
1.2.12
1.2.12.1
t.2.t3
r.2.13.1
t4
l5
See Drawing TE-16-C-5.
See Drawing TE-16-C-4.
I .2.r3.2
Attachment 1 - Page 19
TOCDF
Facility Description
June 2009
The BCS facilities house the concentrated chemical solutions from which the
decontamination, caustic wash, and neutralization solutions are made. The bulk chemicals
are sodium hydroxide (18% by weight) and sodium hypochlorite (12%o or less by weight).
LPG and each bulk chemical have its own storage tank or tanks, its own supply pumps,
and its own distribution system. Tanker trucks supply the feedstock for the bulk chemicals
or LPG. The trucks supply the TOCDF with bulk chemical stock solutions in the
concentrations shown above.
1.2.13.3 Ieloo 1639 (ATLIC) was selected to house the Area 10 Liquid l€A#;ncinerator because
of its close proximity to the Area 10 GA/L ton container storaee. Delivery of these tons to
Ieloo 1639 will be accomplished by open-bed truck and forklift. These tons will not be in
iroverpacks because of the short transfer distance and the small number of tons to be
orocessed at the ATLIC.
1.2.14
1.2.14.1
Fire Control Facilities
1.2.14.2
The MDB interior fire systems are designed to meet National Fire Protection Association
(I.[FPA) standards. The fire water storage requirement is 330,000 gallons. Portable fire
extinguiihers, a sprinkler system, dry chemical systems, Halon systern, and FM-200/FE-
227 system are all built into the facility to minimize the threat of fire.
The ATLIC Fire Detection and Prevention Svstem is described in Attachment 9,
Section 9.1.4.9.
D€D+k>+r{arshell
1.2.14.3 Water for the TOCDF a46lATI.rc is pumped from two wells located north of Stark Road
(approximately2tlamilesnortheastoftheTOCDF).I6 Pumpsareinstalledattheexisting
DCD withdrawal wells to produce the anticipated 616,000 gallons per day required at
DCD. The DCD withdrawal wells are located east-northeast of the TOCDF and more
than 5 miles distant. The well pumps supply water to the two existing reservoirs (with a
combined capacity of 1 million gallons). Army Regulation, Mil 1008C, prescribes the
volume of reserve water provided for fire fighting as 337,000 gallons. The two DCD
500,000 gallon water tanks serve as the ernergency fire water reserve for TOCDF.
1.2.14.4
1.2.15
1.2.15.1
The water is chlorinated at the wellhead and then moves to the two 500,000 gallon DCD
water tanks. Water flows from the DCD water tanks to the TOCDF-and AILIC via 12"
and 20" diameter water lines. A 12" diameter pipe loop around the TOCDF supplies fire-
fighting water to the site and to the fire sirppression ryrtorrr in the CHB,.PMB, and MDB.
A pipe from this loop supplies water for the Water Treatment System (WTS, located in
the PMB). Softened water from the WTS feeds the Potable Water System (POT) and
Process Water Systems (PR!V).
f,'lood Control and Drainase Barriers
Drawings TE-16-C-2 and TE-16-C-3 are topographic maps of the TOCDF and the local
surrounding area: Area 10 is depicted in the former drawines. (Note: TE-16-C-3 is
considered "restricted access - protected record.") Drainage from these facilitig$ is
16 See Drawing TE-I6-C-2.
Attachrnent I -Page20
1.2.15.2
| .2.15.3
1.2.15.4
1.2.16
1.2.16.1
1.2.17
t.2.r7 .1
TOCDF
Facility rr"if,#S;
westerly. The overall drainage gradient for the Te€nF is l%o or greater. The topography
is generally smooth and uniform, allowing no chance for ponding or pooling of runoff
waters. Natural drainage channels exist and do not direct water onto the facility.
The TOCDF covers approximately 40 acres and is largely covered by dirt, gravel, and
impermeable surfaces (for example, buildings, asphalt, and concrete paving). Runoff from
the TOCDF is controlled by the slope of the asphalt and concrete pavement and is directed
towards storm drains, ditches, and culverts within the TOCDF. All on-site surface runoff
is collected in an underground drainage system and routed to the storm drain detention
pond.rT The pond is sized for the 100-year storm. Temperatures as well as types and
amounts of precipitation are discussed in paragraph 1.2.15.3 below. No surface waters are
used as public water supplies in the immediate vicinity of TOCDF. Surface water is used
primarily for agricultural purposes in Rush Valley. The ATLIC flood control and drainage
barriers are covered by the DCD RCRA Permit.
The climate of the :FO€DF.pQL is characterized as dry continental and is heavily
influenced by the mountains surrounding the facility. Temperatures are frequently above
32'C (90'F). High temperatures of 37oC (100'F) and low ternperatures of -l7oC (OoF)
occur. The area is noted for plentiful sunshine, low relative humidity, and light
precipitation. Annual rainfall varies between 25-30 centimeters (10-12 inches),
distributed primarily from mid-fall through late spring. April is the wettest month, with an
average of 2.00 inches of rain. July is the driest month, with an average of 0.64 inches.
Snow averages 40 inches per year, with the maximum (13.2 inches average) in January,
and snowfall greater than I inch during each month from October through April.
There is minimal tornado exposure (no known touchdowns in the valley since 1984) and
minimal earthquake exposure.
Run-off Control Svstems
The location of the TOCDF and ATLIC are is+ueh+halitsiyvirtually devoid of surface
water features or intermittent streams.'8 The access road to the North and East of TOCDF
acts as a barrier to divert runoff from higher elevations. Drawings TE-I6-C-32, -33, -34
and EG-16-C-7402 detail the storm drainage features of the TOCDF.
Proposed New and Existins Hazardous Waste Management Units
The only waste management units in the immediate vicinity of the TOCDF plant are those
units located at the facility itself and Igloos 1631 (Autoclave),1632 (Drum Ventilation
System/Drum Ventilation System Sorting Room and Container Storage), an+1633
(Container Storage). and 1639 (ATLIC) located in Area 10 immediately adjacent to
TOCDF.I9
t7 The storm water detention pond lies approximately 200 feet due west of the TOCDF as
indicated on Drawing TE-16-C-3.
" See paragraphs 1.2.4 through 1.2.4.2 for a discussion of surface water features in Rush
Valley.
te See Drawing TE-16-C-3.
Attachment I -Page2l
1.2.18
t.2.1 8.1
1.3
1 .3.1
1 .3.1 .l
1.3.1,2
1 .3. | .2.1
1 .3. | .2.2
1.3.1.2.3
1.3.1.3
1 .3. 1 .3.1
1 .3. r .3.2
1 .3. I .3.3
1.3.1.4
TOCDF
Facility Description
June 2009
Spill Sites
Module VII provides information regarding spill sites.
LOCATION INFORMATION
Seismic Standard tR315-3-2.5ftX11). R315-8-2.9(a)l
The DCD is located in Tooele County, which is one of the counties listed in 40 CFR 264
Appendix VI. Since the installation is located in a political jurisdiction listed in Appendix
VI, a geologic evaluation of the area has been performed in accordance with R315-3-
2.sox11).
Findings were presented in a report to the U.S. Army Engineering Division, Huntsville,
Alabama, and the Office of the Program Manager for Chemical Demilitarization @MCD),
(which were the designated agencies in 1986). The findings of the report2o are as follows:
One inferred fault occurs within a 3,000-foot radius of the site. The fault is inferred,
presumably because geologic field evidence for the fault is unclear.
No direct geologic information is provided in geologic literature on the absolute age of the
most recent fault displacement for the inferred fault.
Interpretation and evaluation of the available geologic literature indicate that the inferred
fault could have had displacement sometime during the past 15,000 years. The Holocene
epoch began 10,000 years ago.
On the basis of these findings, a geologic study was performed to:
evaluate geologic evidence for the inferred fault,
explore for other faults associated with the inferred fault in the area of the site, and,
obtain field data that may refine current estimates as to the age of the most recent
displacement.2r
The field study resulted in the identification of faults at three locations along a 2,250-foot-
long trench. Geologic mapping of the deposits offset by the faults and development of age
criteria for the deposits indicate that none of the identified faults is younger than 14,500
years. This determination is supported, in general, by the absence in the project area of
land forms that are characteristic of youthful faulting. It is concluded that fault
20 "Geologic Evaluation for Compliance with Seismic Location Standard 40 CFR 270.14@)(ll)
for Siting a Chemical Agent Munitions Disposal System (CAMDS) at the Tooele Army Depot,
South Area, Tooele County, Utah. " The report is dated June 5, 1986.
2r See, "Geologic Field Analysis for Siting a Chemical Agent Stockpile Disposal System at the
Tooele Army Depot, South Area, Tooele County.' The report is dated December 15, 1986.
Attachrnent 1 - Page22
1.3.2
1.3.2.1
1.3.2,2
1.3.2.3
1.3.2.4
1.3.2.5
1.3.2.6
1.3,2.J
r.3.2.8
1.3.2.9
1.3.2.10
TOCDF
Facilityrr"ifrffi;
displacement has not occurred at the project site during the Holocene Epoch (i.e., the past
10,000 years), and that the site is acceptable according to 40 CFR 264 ard 270 and UAC
R315.
Floodnlain Standards tR315-3-2.5ftX1lXiiil. R315-8-2.9(b)l
The DCD has not been mapped for theNational Flood Insurance Program and thus there
are no 100-year floodplain maps for the installation. However, it has been determined that
the site is outside of the 100-year floodplain and is not subject to flooding, based on the
following:
There is no history of flooding in the area. No floods have occurred at DCD since the
depot came into existencenl942.
The overall drainage gradient for the entire TOCDF and ATLIC areag is l%o or greater.
The topography is generally smooth and uniform, allowing no chance for ponding or
pooling of runoff waters. The lack of intermittent streams or defined flow paths in Rush
Valley confirm the lack of flooding potential. The location of the TOCDF is such that it is
virtually devoid of surface water features or intermittent streams. The closest body of
surface water (i.e., 3-4 foot wide Ophir Creek) is located more than 1000 feet north of the
TOCDF fence and does not appear on the topographic maps.
Drainage forthe entire DCD is westerly, and the low area is more than 170 feet lower in
elevation, and approximately 1l miles distant (i.e., Rush Lake) from the TOCDF.
Few well-defined natural drainage channels exist in the vicinity; there are none that would
carry or direct water to or through the site.
All on-site surface runoff is collected in an underground drainage system and routed to the
storm drain detention pond sized for the 100-year storm.
No significant vegetation exists to retain runoff waters.
The area is arid to semi-arid and receives little precipitation. The 100-year 244tow
precipitation event is less than 3.3 inches.
Due to local drainage at the site, the Rational Method was used to establish the 100-year
frequency peak flow. The Rational Method is a simple, but accurate, hydrologic
estimating technique generally used in small drainage area such as the local flow area at
the TOCDF indA:[L!Q. There was no hydrologic study performed for the Rush Valley
floor, given the site's history of no flooding and the relative height of the TOCDF above
the valley floor. No computer modeling was performed for hydraulic analysis.
Because of the unique characteristics of each watershed in arid regions such as Utah, it
would not be appropriate to predict floods from the 460-square mile Rush Valley drainage
area by the Rational Method or any method other than historic records at the site. Since
there is no history of flooding in Rush Valley, it is expected that the "100-year flood"
would be practically insignificant. The TOCDF and ATLIC elevation of 100 to 200 feet
above the valley floor puts ilthem well beyond any expected flood level.
Attachment I - PageZ3
1.3.2.11
1 .3.3
I .3.3. I
I .3.3 ,2
TOCDF
a*Ut"rr"ff:rffi;
For local flooding, conservative "n" values or 0.035 were used to compute flood depths in
channels. For bare earth channels, roughness would be lower, producing lower flood
depths. In Rush Valley, roughness coefficient estimates were not needed because of the
lack of flood potential. There are no bridges or sheam channels in the vicinity of the
TOCDF or AItle for analysis.
On-site Drainaee
The TOCDF occupies approximately 40 acres and is largely covered by a variety of
surfaces (i.e., buildings, asphalt, gravel, and concrete paving) such that runoff drains
overland to the west. Runoff *emtle4e€DFis controlled bythe slope of the asphalt
and concrete pavement towards storm drains, ditches, and culverts within the TOCDF.
All on-site zurface runoff is collected in an underground drainage system, which drains to
the storm drain detention pond. The site has been carefully graded so that water does not
run towards any building and has a generally constant gradient of greater than I %. The
100-year, 24-how precipitation is less than 3.3 inches and poses no flood threat to the
TOCDF from local ponding. Area 10 drainaee is covered by the DCD RCRA Perrnit.
The site access road also acts as a barrier to runoff from the north and east of the site.
There is no site run off expected from any other direction. A culvert allows some drainage
to flow toward the TOCDF plant site. Approximately 36 cubic feeVsecond of runoff will
flow across the northern end of the TOCDF parallel to the existing exclusion fe,nce. This
drainage flows in a culvert where it passes under the security fence, and in an open ditch
within the site. All other off-site drainage is diverted around the southern end of the site.
The direction of surface water runoff flow is shown by bold arrows on the Topographic
Map, TE-16-C-3 (restricted access - protected record).
TRAFFIC PATTERNS tR31 5-3-2.5ftX10)I
General Denot Traffic
Access to the DCD is via County Road 198, connecting State Highway 73 to the Main
(North) Gate, and via State Highway 73 directly connecting to the Doolittle Road and the
East Gate.22 Both State Highway 73 and County Road 198 are two-lanes, undivided,
asphaltic concrete roads zoned from 55 to 65 mph. Neither highway is heavily traveled.
Theintcrsectionsof StateHighwayT3 andCountyRoad 198 aswellastheDoolittleRoad
rvith State Highway 73 are simple interchanges. Traffic control at the Highway/Doolittle
interchange is via a stop sign on County Road 198. Traffic control at the Doolittle
Road,iHighway 73 interchange is by a stop sign on Doolittle Road.
'Ihe DCD West Gate is used at the discretion of DCD and the gate is kept locked. Access
to the West Gate is via State Highway 36 onto Harrison Road. State Highway 36 is a two-
lane, undivided, asphaltic concrete road. The Highway 36/Ilarrison Road intersection is a
simple interchange with traffic control by a stop sign on Harrison Road.
The TOCDF and Area 10 road systerng consists of undivided, asphaltic concrete roads.
There are no one-way streets, traffic control devices, or signs within the TOCDF orjhg
1.4
1.4.1
l.4.l .l
t.4.t.2
1.4.1 .3
22 See Drawing TE-16-C-2.
Attachment 1 -Page24
1.4.1 .4
1.4.1 ,5
1.4.1 .6
1.4,2
1.4.2.1
1.4.3
1.4.3.1
1.4.4
r.4.4.1
1.4.4.2
1.4,4.2.1
TOCDF
Facility rr"ff:itS;
ATLIC. Entry to the TOCDF and Area 10 is controlled through seoarate theECFs located
at each facility. All personal vehicles are parked outside of the TOCDF or Area 10 and do
not impact the traffic within thosee facilities:r.
Generally, all traffic, including government vehicles, commercial carriers, and privately
owned vehicles, follow the primary traffic route. Only security vehicles and maintenance
vehicles travel off of the primary route.
As shown in Drawing TE-16-C-2, the TOCDF is immediately adjacent to and physically
connected to Area 10, and therefore, the area becomes a contiguous restricted area. The
ATLIC is within Area 10. Consequently, there is no over-the-road transport of
demilitarization items outside of these{s areas. Intemal traffic movement between the
storage and the demilitarization operating area is discussed in paragraph 1.4.2.
Incinerator residues are disposed of offsite at an approved hazardous waste management
facility. These materials are properly manifested and handled from the site to the off-site
facility by a licensed transporter of such materials. Traffic pattems on site for these
materials follow the primary traffic route discussed in paragraph 1.4.1.3 from the facility
plants to the depot boundary. Volumes and frequency of shipments are discussed in
paragraph 1.4.3.
Traffic Control
Because of the low volume of traffic at DCD, traffic control measures are simple. Speed
is restricted to 30 mph unless otherwise posted (e.g., office areas and parking lots), and 45
mph is posted for most of the primary fraffic route. All blind or hazardous tums are
marked and posted at reduced speeds. Yield signs and stop signs control traffic at all
major intersections. All railroad grade crossings are marked with signs. Traffic control
enforcement is by security personnel.
Estimated Volume and Frequencv of Shipments
It is estimated that 500 vehicles will pass the security gate daily. Of the estimated 500
vehicles, 10 to 15 are commercial carriers (semis or truck-trailers) traveling almost
exclusively to the TOCDF area. An additional 35 to 40 vehicles (including security and
maintenance) travel to other destinations throughout the DCD. AsT*he ATLIC is located
within Area 10. where the small number of GA and L ton containers to be processed are
located. shipments to Area 10 should not increase significantly.
Road Surfacine and Load Bearine Canacitv
Roads, parking areas, and driveways are paved. In general, all main access routes servrng
the TOCDF and ATLIC areag are of asphalt. The roads have l2-foot-wide lanes with a
minimum cross slope of 2 percent and 3-foot-wide dirVgravel shoulders.
The maximum load assumed for design is the American Association of State Highway and
Transportation Official's H20 loading:
18,000 pound axle load,
Attachment I -PageZl
1.4.4,2.2
t.4,4.2.3
1.4,5
1.4.5.1
TOCDF
Facility Description
June 2009
32,000 pound maximum axle group,
80,000 pound maximum vehicle weight.
Restricted Area Traffic
Total associated two-way traffic on the roads used for the transport of the PAS Brines,
DFS and MPF ash, and metal residue from the facility plants to the storage area ranges
between 10 to 28 vehicles per day, depeirding on the type of munitie* munitions or bulk
containers being processed. The truck traffic moving munitions between Area l0 and the
CHB, and Area 10 and the ATLIC. varies daily depending on the munition being
processed. This estimate does not include traffic associated with Area l0 maintenance,
operations, and security, which is estimated at an additional 10 vehicles per day.
a
Attachment 1 -Page26
c+
FD
C)
iJ
lJ
P
CD)c+
N)
ATTACHMENT 2
WASTE ANALYSIS PLAI\
Supporting Documentation is located in Attachment 3.
TOCDF
Waste Analysis Plan
June 2009
2.t
2.2
2.2.1
2.2.2
2.3
2.4
2.5
2.6
2.7
2.8
2,9
2.10
Table 2.0
Tabl e 2-l
Table 2-2
Table 2-3
Table 2-4
Table 2-4a
Table 2-4b
Table 2-4c
Table 2-5
IABLE OF CONTENTS
INTRODUCTION
PARAMETERS AND RATTONALE 40 CFR 264.13(bX1) [R31s-8-2.4]
ANALYSES FOR WASTES REQUIRING ON-SITE TREATMENT
ANALYSES FOR WASTES REQUIRING OFF-SITE
TREATMENT & DISPOSAL
PARAMETER TEST METHODS 40 CFR 264.13b)Q); [R31s-8-2.a]
SAMPLING METHODS 40 CFR 264.t3b)G); [R31s-s0-6]
FREQIJENCY OF ANALYSES 40 CFR 264.13(bX+); [R315-8-2.4]
ADDITIONAL REQUIREMENTS FOR WASTES GENERATED OFF SITE
40 CFR 264.r3(b)(s); [R31s-8-2.a]
ADDITIONAL REQUIREMENTS FOR IGNTTABLE, REACTIVE, OR
INCOMPATIBLE WASTES 40 CFR 264.13O)(6); [R315-8-2.4]
RECORDKEEPING REQIJIREMENTS 40 CFR 264.7 3(b)(3); [R3 1 5-7- 1 2.a]
SAMPLING AND ANALYSIS QA/QC PROCEDURES
SUBPART CC AND BB SAMPLING AND ANALYTICAL PROCEDURES
TABLES
TOCDF'WASTE ANALYSIS PLAN SUMMARY
On-site Treatment Wastes
TOCDF WASTE ANALYSIS PLAN SUMMARY
Off-site Treatment Wastes
SITE.GENERATED WASTE STREAMS
ECR Maintenance Residues, DF S
ANIALYTICAL METHOD DESCRIPTIONS
TOCDF Underlying Hazardous Constituent Analytes
Metals
Volatile Organic Compounds
Semi-Volatile Organic Compounds
Agent Contaminated Wastes
Attachrnent2-Pagel
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-l
Table 2-A-2
Table 2-A-3
Table 2-A-4
Table 2-A-5
APPENDIXA
AGENT RELATED DATA
CHEMICAL AGENT PHYSICAL PROPERTIES
CHEMICAL AGENT COMPOSITION
GB AGENTPURITY
VXAGENTPURITY
HD AGENTPURITY
APPENDIXB
BT]LK CONTAINER/IVII]NITIONS NON.EMBEDDED METAL CONTENT
Table 2-B-1 Metals in Munitions (Metals with Feed Rate Limitations-Module V)
Table2-B-2 Metals in Munitions (Other Metals of Interest)
APPENDIX C
BT]LK CONTAINER/IVIUNITIONS NOMINAL AGENT / ENERGETIC F'ILLS & ENERGETIC
COMPOSITION
Table2-C-l Energetic/Agent Nominal Weight for Chemical Agent MunitionslBulk Containers
Table2-C-2 Composition of Reactive Material in Munitions
Attachment2 -Page2
TOCDF
Waste Analysis Plan
June 2009
LIST OF ACROI\"YMS
Acronym Definition
ACS Agent Collection System
AQS Agent Quantification System
ATLIC Area 10 Liquid Incinerator
BRA Brine Reduction Area
BTU British Thermal Unit
CAL Chemical Assessment Laboratory
CAMDS Chemical Agent Munitions Disposal System
CTC Cutaway Ton Container
DFS Deactivation Furnace System
DCD Deseret Chemical Depot
DSHW Division of Solid and Hazardous Waste
DVS Drum Ventilation System
DVSSR Drum Ventilation Sortine System Room
ECR Explosive Containment Room
EPA Environmental Protection Agency
GA Tabun. Ethvl N.N.-dimethvlphosohoro- amidocvanidate
GB Sarin, Isopropyl methylphosphonofluoridate
GC/MS Gas Chromatographyimass spectrometry
H/HD/HT Sulfur Mustard'/Distilled Sulfur Mustard/Distilled Mustard with 40%
B i s l-2-(2-chloroethylthi o)-ethyll ether
HDC Heated Discharge Conveyor
HEPA Hieh Efficiency Particulate Air
HRA Hazard Risk Assessment
L Lewisite. 2-Chlorovinvl arsinedichloride
LIC Liquid Incinerator
MDB Muniti on Demi litarizati on Bui I dine
t3mg/m Millierams per cubic meter
MPF Metal Parts Furnace
MSB Monitor Support Building
ONC On-site Container
PAS Pollution Abatement System
PFS PAS Filtration Svstem
PCB Polychlorinated Biphenyl Compounds
ppb Parts per billion
ppm Parts per million
RCRA Resource Conservation and Recovery Act
RHA Residual Handline Area
SDS Spent Decontamination System
Subtitle C TSDF Hazardous Waste Treatment, Storage and Disposal Facility
TC Toxicity Characteristic or Ton Container
TCLP Toxic Characteristic Leaching Procedure
TDS Total Dissolved Solids
TMA Toxic Maintenance Area
TOCDF Tooele Chemical Agent Disposal Facilitv
TSCA Toxic Substance Control Act
TSDF Treatment, Storage and Disposal Facility
TSS Total Suspended Solids
UPA Unpack Area
UPMC, UMC Upper Munitions Corridor
VOC Volatile Organic Concentration (BB/CC)
VX O-ethyl - S - [ 2 -di i sopropyl am in o)ethyl I methyl phosphonoth i ol ate
WCL Waste Control Limit
Attachrn ent 2 Page
TOCDF
Waste Analysis Plan
June 2009
WIC I Waste lncineration Container
Note: I Sulfrr Mustard: Bis(2-Chloroethyl) Sulfide or 2,2'-Dichlorodiethyl Sulfide
Attachm ent 2 - Page 4
TOCDF
Waste Analysis Plan
June 2009
2.1.
2,1,1 .
2.1.2.
2.1 .2.1 .
2.r.2.2.
2.1.2.3.
2,1 .2,4.
2.1 .2.5.
2.2.
2.2.1 .
2.2. 1 .1.
2.2.1 .2.
2.2.1.3.
2.2. 1.3.1.
INTRODUCTION
Generators of hazardous waste are required to obtain detailed chemical analyses of
wastes they intend to treat, store, or dispose of in order to ensure proper hazardous
waste management practices.
This Waste Analysis Plan describes:
The physical and chemical analyses the Permittee shall perform before hazardous
wastes are stored, treated, or transported off site for further treatment and ultimate
disposal,
The methods and frequency to be used to collect and analyze samples,
The procedures that will be used to ensure the validity of the analytical results, and
The basis for generator knowledge.
Tables 2-0 and 2-l present a sunmary of this entire waste analysis plan. For each
waste stream specified, these tables present the selected analytical parameters and
corresponding analytical methods, sampling frequencies, and sampling methods. In
addition the tables include either a reference to the unit that will treat each waste
stream (for waste to be treated on site) or a reference to the process generating each
waste stream (for wastes to be treated and disposed of off site).
PARAIVTETERS AI\D RATIONALE 40 CFR 264. 13 ft Xl ) tR3 1 5.8-2.4I
Analyses for Wastes Requiring On-Site Treatment
Waste streams included in this section are treated on site in one or more of the four
incinerators. Analytical parameters were selected for each waste stream based on
previous analyical results obtained for similar waste streams, the homogeneity of
the waste and the ability to obtain a representative sample, and/or govemment
manufacturing specifications (in regards to munition energetic components).
The Permittee shall determine the hazardous constituents in the waste streams to be
treated on site. The Permittee shall also determine the underlying hazardous
corrstituents as applicable in 40 CFR 268.9. For wastes to be treated on site, which
are not inoluded in Table 2-0, the Executive Secretary shall be notified of the most
appropriate management practices including treatment methods and appropriate
waste analyses. This notification shall be in writing and occur within seven days
from the time when the Permittee determines a waste has been generated that is not
included in Table 2-0. The Executive Secretary will determine if the chosen
treatment is acceptable
Chemical Agents GB. VX. Mustard (HD/H/HT)
Previous analyses of chemical agents have identified agent breakdown products and
organic stabilizers (referred to collectively as agent organic content), and metal
constituents. Data compiled from these previous analyses have been used to establish
expected ranges for agent organic content (see Table 2-A-2) and metal constituents.
Attachrnent2-Page5
TOCDF
Waste Analysis Plan
June 2009
2.2.1.3.2. The Permittee shall analyze the chemical agent prior to each TOCDF agent campaign from
bulk containers. Agent samples shall be collected from a representative nurnber of bulk
containers agreed upon with the DSIIW. The containers shall be sampled and analyzed
following an approved sampling and analysis plan.
2.2.1.3.3. At the beginning of each TOCDF munition orbulk container campaign, agent samples
shall be collected using a sampling scheme that is approved by the Executive Secretary.
The samples shall be analyzed as specified in Table 2-0. The sampline and analysis
requirernents for aeents GA and Lewisite. which will be processed at the ATLIC. are
specified in paragraph 2.2.1.21 of this attachment.
2.2.t.3.4. Metals included in the HRA list are Aluminum, Antimony, Arsenic, Bariunu Beryllium,
Boron, Cadmium, Chromium, Cobalt, Copper, Lead, Manganese, Mercury, Nickel,
Selenium, Silver, Thallium, Tin, Vanadium, arrdZinc.
2.2.I.3.5. The metals analysis associated with the agent waste profile will be accomplished using the
methods described in Tables 2-0 and2-3. The metal analytes quantified will be the HRA
metals listed in Paragraph 2.2.1.3.4.
2.2.1.3.6. Baseline Mustard Ton Containers
2.2.1.3.6.1 Prior to TOCDF receipt of Mustard ton containers, each TC shall have been sampled and
analyzed at DCD Area 10 in accordance with the Area 10 Sampling Program.
2.2.1.3.6.2 During the LIC ATB shakedown for baseline Mustard ton containers, each week one
sample shall be collected from the ACS tank and analyzed for HRA metals, agent organics
content and density, provided the ton container's liquid contents have been previously
sampled and arnlyzed at Area 10 for HRA metals and shown to contain less than one part
per million of mercury (< 1 ppm (mglkg).
2.2.1.3.6.3 During LIC post-ATB and long-term incineration processing of Mustard baseline ton
containers, the DCD Area 10 liquid Mustard sample analyses results will be used by
TOCDF for characterization for the liquid Mustard in the baseline ton containers
2.2.1.3.6.4 During the MPF ATB shakedown for baseline Mustard ton containers, sludge/solid
samples will be collected in accordance with the MPF Mustard Trial Bum Plan.
2.2.1.3.6.5 The metals analysis associated with the agent samples collected in compliance with
Paragraph 2.2.1.3.6. may be performed using either the site specific or the SW-846
methods described in Tables 2-0 and 2-3. Analytes quantified by the SW-846 methods
shall be those HRA metals listed in paragraph 2.2.1.3.4.
2.2.1.3.6.6 Reserved.
2.2.1.3.6.7 Based on the results of the agent sampling and analytical, agent feed rates to the
incinerators shall be adjusted, as necessary, to ensure continued compliance with the metal
feed rate limits.
2.2.1.3.6.8 For each agent organic analysis and metals analysis, a sunmary of the results shall be
submitted to the Executive Secretary monthly.
Attachrn ent 2 - Page 6
TOCDF
*^"*1,J;:,o'3;
Appendix A of this waste analysis plan contains the following information regarding the
chemical agents to be incinerated at the TOCDF:
Table 2-A-1: Physical Properties of Chemical Agent (as a pure substance)
2.2.1.3 .6.9.2 Table 2-A-2:Chemical Agent Composition
2,2.1.3 .6.9
2.2.1 .3 .6.9 ,I
2.2.1 .3,7
2.2.1 .3 ,7 .l
2.2,1 .3.7 .2
2.2.1 .3 .7 .3
2.2.1 .3 .7 .4
2.2.1.3 .7 .5
2.2.1.3 .7 .6
2.2.1.3 .7 .7
2.2.1.3 .7 .8
2.2.1 .3.8
2.2.1.3.8.1
2.2.1 .3 .8.2
2.2.1.3.8.3
Mustard 1 55mm Proj ectiles
The initial characteization and continuing processing verification sampling will be
performed in accordance with the plans approved by the Executive Secretary.
If variation of the agent in the initial characteization sampling is found outside the
specified limits in the sampling plan, modifications of the initial and verification sampling
may be required as determined by the Executive Secretary.
Thirty additional samples will be collected from lots specified in the Mustard 155mm
Projectile Sampling Plan for continuous verification for a total of 15 samples or 30 total
for both liquid and solid matrices. One additional verification sample set shall be
collected and arralyzed quarterly until the end of the projectile campaign.
Each verification sample set shall consist of one solid and one liquid sample from each of
five separate projectiles for a total of 10 samples per verification sample set (five solid and
five liquid).
Each liquid sample from each verification sample set from the projectiles specified in
2.2.1 .3.7 .3 and 2.2.1 .3.7.4 shall be analyzed for agent organic content (i.e., purity and
impurities), and HRA metals (and chlorine for the quarterly samples).
Each solid sample from each verification sample set from the projectiles specified in
2.2.1.3.7.3 ard2.2.1.3.7.4 shall be analyzed for HRA metals (and chlorine for the
quarterly samples).
Analysis results shall not necessarily be available prior to MPF treatment of the sampled
projectiles.
Sample verification analyses results will be immediately sent to the DSHW Chemical
Demilitarization Section Manager at the same time results are reported to EG&G.
4.2lnchHT Mortars
The initial characteization will be performed in accordance with the Sampling and
Analysis Plan approved by the Executive Secretary.
Phases II and tII of the Sampling and Analysis Plan will be determined after the results
from the previous phase has been evaluated by the Executive Secretary.
Initial characteization samples results must be approved prior to processing the agent in
the LICs in Phase I, II and III for metals. The 4.2 inch HT mortar trays may be processed
in the MPF during Phase I prior to receiving the analytical results.
Attachrnent 2 - PageT
t..TOCDF**"*1H:#3;
2.2.1,.3.8.4 Sample verification analyses results will be immediately sent to DSHW at the same time
results are reported to EG&G.
2.2.1.3.8.5 On liquid mustard (HT) sample will be collected from an ACS tank once per week
throughout the HT campaign andanalyzed for metals. Every fifth sample collected will
also be aralyzed for organic content. The Executive Secretary my revise this sampling
frequency of analysis based on results obtained from performance of the 4.2 inch HT
Sampling and Analysis program.
2.2.1.4. Spent Decontamination Solutions
2.2.1.4.1. Spent decontamination solutions treated on site shall be treated in the primary or
secondary chambers of the LICs.
2.2.1.4.2. Spent decontamination solution collected in SDS-TANK-101, SDS-TANK-102, or SDS-
TANK-103 shall be sampled and analyzed per Table 2.0 Section 2.2.L4. Spent
decontamination solutions shall be anallzed for chemical agent concenhation, corrosivity
(pH), specific gravity, HRA metals, TCLP, and screened for organics by weight.
2.2.1.4.2.1 The parameters of agent concentratiotr, pH, specific gravity, and the organic screen shall
be determined for each tank of spent decontamination solution processed. The results
shall be available prior to incineration.
2.2.1.4.2.2 Confirmatory analyses for HRA metals, TCLP organics and explosives (if processing
explosive munitions) in spent decontamination solutions shall be performed quarterly. :'
2.2.1.4.2.3 The sampling and analyses of spent decontamination solutions for the purpose of
demonstrating compliance with Subpart CC regulations shall be performed as described in
Section 2.10 of this attachment.
2.2.1.4.3. If results of the organic screen show that the spent decontamination solution contains
organics in excess of five percent, the tank of spent decontamination solution shall be
analyzed per Table 2-0. The Executive Secretary shall be notified prior to treatment of the
solution.
2.2.L4.4. If chemical agent is detected above the Waste Control Limit (WCL) (i.e., 20 parts per
billion (ppb) for GB, 20 ppb for VX, and 200 ppb for Mustard), additional
decontamination solution shall be added to the tank, the contents of the tank shall be
recirculated (i.e., mixed), and another sample shall be analyzed for agent. This procedure
shall be repeated until the chemical agent concentration is below the limits specified
above.
2.2.1.5. Agent Collection System (ACS) & Agent Quantification System (AQS). Spent
Decontamination System (SDS) Maintenance Residues
2.2.1.5.1 The chemical agent contaminated debris and sludges generated from the maintenance of
the ACS, AQS, and SDS equipment located in the Munitions DemilitaizationBuilding
(MDB), but outside the Explosive Containment Rooms (ECRs), can be incinerated in the
Metal Parts Furnace (MPF).
2.2.1.5.1.1. ACS tank bottoms shall be characterized prior to treatment in the MPF. Samples shall be
analyzed for HRA metal s.
Attachment2-Page8
2.2.1.5.2.
2.2.1.5.3.
2.2.7..5,4
2,2.1.6.
2.2.1.6.1.
2.2.1 .6.2.
2.2.1 .6.3.
2.2.1 .6.4.
2.2.1 .6.5.
2.2.1 .6.6.
2.2.1 .6.7 .
2.2.1 .7 .
2.2.r.1 .l .
TOCDF*"""*lHIrtot;
Collected ACS/AQS maintenance residues shall be weighed and characterized prior to
incineration to ensure feed rates established for the MPF are not exceeded. The Operating
Record shall include a detailed description of the residues fed to the MPF.
ACS/AQS/SDS maintenance residues shall be properly managed prior to treatment in the
MPF.
ACS, AQS and SDS sludge shall be categorized as Agent Contaminated Sludge and
managed as specified in paragraph 2.2.1.18.
Secondary Waste Noncombustible Bulk Solid Waste Categorv
Noncombustible Bulk Solid Secondary Waste is composed of inert material that does not
combust when placed into the incinerator. Examples of this waste are discarded
components of MDB process equipment, and carbon filter trays (from which all carbon
has been removed).
The physical state of these wastes (i.e., debris) prevents the collection of a representative
sample. All wastes included in this category are described by the Utah Hazardous Waste
code P999. Other waste codes may apply based on generator knowledge.
Wastes included in this category shall beplaced onto MPF bum trays or thermally treated
ton containers that have been cut in half (cutaway ton containers or CTC) or Waste
Incineration Containers (!VIC$. All wastes shall be weighed and characterized prior to
being treated in the MPF to ensure compliance with this Permit. The Operating Record
shall include a detailed description of the residues fed to the MPF in each bum tray, WIC
or CTC.
Noncombustible Bulk Solid Wastes shall be properly managed prior to treatment in the
MPF'.
Management of Noncombustible Bulk Solid Waste shall be in accordance with paragraph
2.2.1.6 prior to treatment in the MPF.
Additionally, these wastes included in this category maybe processed in the Autoclave
(Igloo 1631) provided an approved function test has been demonstrated and approved by
the Executive Secretary.
For Autoclave processing, the TOCDF operating record shall include an entry for each
secondary waste drum processed in the Autoclave. Each of these entries will include a
description of the waste, tlpe of container, the total weight waste, the volume of the
container storing the waste, the hazardous waste label number, and the time and date the
waste was processed in the Autoclave per Module VIII.
Drained Bulk Containers & Undrained Mustard l55mm Proiectiles with A ent Residue
Drained bulk containers and projectiles with chemical agent residue (heel) shall be treated
in the MPF. with the exception of Ag .
Previous analytical results show some of the chemical agent to contain concentrations of
metals. ln addition, the paints used on the containers and projectiles have metal-
containing pigments.
Attachm ent 2 - Page 9
TOCDF**"*1HI;o'#
2.2.I.7.2. The chemical agents and item surface coatings (i.e., paint) are both organic matrices
containing metal constituents. Metal constituents contained in organic matrices are
referred to as non-embedded metals. Non-ernbedded metals may potentially volatilize
during incineration.
2.2.1.7.3 Appendix B contains the following tables regarding the metals associated with each type
of chemical agent munition and bulk container to be treated at the TOCDF:
2.2.1.7 .3.1 Table 2-B-1: Metals in Munitions (presents by munition or bulk container, the
total metal loading for non-embedded metals whose emission rates are regulated
by this Permit).
2.2.1.7.3.2 Table2-B-2: Metals in Munitions (presents, by munition or bulk container, the
total metal loading for non-ernbedded metals whose emission rates are considered
inthe TOCDF HRA).
2.2.1.7.4 Data included in these tables can be used to determine the quantrty (and associated feed
rate) of non-embedded metals fed to the incinerator. Note data for GA and Lewisite ton
containers are included in the table for completeness. Drained Agent GA and Lewisite ton
containers will be treated at the ATLIC.
2.2.I.7.5 Mustard 155mm projectiles are included for the purposes of the Waste Analysis Plan;
however, the mustard l55mm projectiles are not required to be drained prior to
incineration in the MPF.
2.2.1.8. Energetic Munition Components
2.2.l.8.L Energetic munition components shall be incinerated in the DFS.
2.2.1.8.2. The Permittee may use generator knowledge to determine the type and amount of
explosive and propellant being fed to the DFS.
2.2.1.8.3. Appendix C contains the following tables pertaining to explosive/propellant and agent fill
weights and compositions:
2.2.1.8.3.1. Table 2-C-1: Energetic/Agent Nominal Weight for Chemical Agent Munitions and
Bulk Containers
2.2.I.8.3.2. Table2-C-2: Composition of Reactive Material in Munitions
2.2.1.8.4. Explosive formulations are organic matrices containing metal constituents. The metals
contained in these formulations will potentially volatilize during incineration (i.e., the
metals are non-embedded). '
2.2.1.8.5. 'Thequantityofeachmetalidentifiedin
TableZ-C-2hasbeenincorporatedintoTables2-
B-1 and 2-B-2 found in Appendix B which present the total non-embedded metals for
each munition and bulk container type to be treated at the TOCDF.
O 2.2.1 .g. ECR Maintenance Residues
Attachment2 - Page 10
2.2.1.9.1 .
2.2.1 .9.2
2.2.t.9.3
2.2.t.9.4
TOCDF
**"*1,J;Irt'ffi
Maintenance performed on the demilitarization machines, Agent Quantification System
(AQS) components, and Agent Collection System (ACS) components that are located in
the Explosive Containment Rooms (ECR) will generate waste residues. Dryresidues and
sludge shall be placed into paper buckets prior to being fed to the DFS. A list of the ECR
Maintenance Residues is provided nTableZ-2a.
The Permittee shall decontaminate the unserviceable hand tools and metal hardware
identified in Table 2-2a and process them in the MPF. If the explosive residue remains on
the tools after decontamination, the metal tools and hardware shall be processed in the
DFS. The maintenance residues in Table 2-2amay be contaminated with small amounts
of spent decontamination solution, agent, hydraulic fluid, or lubricating fluid. Explosives-
contaminated rags generated by personnel wiping explosive residues from reject munitions
in the UPMC or ECV shall be fed to the DFS.
ECR maintenance residues shall be weighed and properly identified as to the origin and
physical characteristics prior to incineration to ensure the DFS feed rate limits are not
exceeded.
ECR maintenance residues are typically discarded items having agent surface
contamination, explosive surface contamination, or both. Operation of equipment in the
ECRs can generate explosive powders. ECR maintenance residues composed of
powdered explosive and munitions components shall be managed separately from other
ECR maintenance residues. The feed rate of ECR maintenance residues composed of
explosive powders and munition components shall be limited to 3.6 pounds per drop with
an internal kiln spacing of one flight between successive drops. The hourly feed rate is
specified in Modules V (Long-Term lncineration) and VI (Short-Term lncineration).
ECR maintenance wastes charged to the DFS that do not contain explosive components or
containers of explosive powder may be fed at the feed rates specified in Module V.. When
155mm mustard projectile bursters are not sheared, no significant explosive contamination
of the ECR will occur from processing. Otherwise, when bursters have been sheared, then
the ECR maintenance waste charged to the DFS are assumed to consist entirely of
explosives.
TABLE 2-2a: Contaminated Waste
ECR Maintenance Residues Waste Stream Allowable Waste
Codes(s)
Filter elements and bags
Munition fragments (metal and explosives)
Dust, dirt, debris, ECR sump sludge
Munition components/fragments (i. e., burster fragments,
supplementary charges, spacers, support cups, lifting lugs, and
fuze adaptors that fall onto the turntable or floor)
Clean-up material (e.9., rags, absorbent pads)
Cotton goods (e.9., coveralls, mop heads)
ECR Sump strainers
Unserviceable hand tools and metal hardware (e.9., nuts, bolts,
washers)
Burlap bags
P999,F999, D002,
D003, D004, D005,
D006, D007, D008,
D009, D0l0
2.2.1 .9.5
AttachmentZ - Page I I
2.2.1 .10.
2.2.1 .10.1
2.2.1 .1 0.2
2.2.1 .10.3
2.2.1 .1 0.4
2.2.1 .1 1 .
2.2.1 .1 1 .1 .
2.2.1 .1 1 .1 .1 .
2.2.1 .1 l.l .2.
2.2.1 .1 1 .1 .3.
2.2.1 .1 I.2.
2.2. 1.11.3.
2.2.1.1 r.4.
2.2.1.1 1 .5.
2.2.1 .1 1 .6.
TOCDF*^"*lHIiJ;;
Spent Activated Carbon
Prior to completion of closure of the TOCDF, the Permittee shall treat agent contaminated
site-generated carbon using Autoclave technology. The effectiveness of Autoclave
technology for treating agent-contaminated carbon shall be made in a separate function
test.
The Permittee shall submit a function test to dernonstrate the effectiveness of Autoclave
technology for the treatment of agent-contaminated carbon that includes an analytical
method to determine the amount of agent absorbed onto the carbon. Upon approval of the
test plan and associated carbon analyical method by Executive Secretary, the Permittee
may execute the plan per the requirements of Module VItr.
The spent carbon shall be placed into permitted storage areas designated to store waste
contaminated with the same type of chemical agent until the results of a function test are
approved by the Executive Secretary.
PPE respirator carbon canisters and ACAMS filter canisters may be processed in the MPF
per the specified feed rates in Table V.C.1. or in the Autoclave upon approval by the
Executive Secretary of results of the testing specified in Module VIII.
Agent Contaminated Dunnage
Dunnage meeting the following definition shall be characteized as P999 hazardous waste.
Agent contaminated dunnage is defined as:
All dunnage held within an ONC or munitions overpack that is found to contain leaking
munition(s) as evident by agent monitoring results of the air within the sealed ONC or
overpack having a concentration of 0.5 VSL or above, or
Dunnage that contacted leaking munitions or is contaminated with liquid agent, or
Dunnage that has been sampled and the analytical results of an extract prepared from a
representative sample have been found to contain agent at concentrations equal to or
greater than 20 ppb for GB and VX, and 200 ppb of Mustard (IVHD/HT.)
Dunnage characteized as P999 hazardous waste shall be treated in the MPF or Autoclave
based on approval of the Executive Secretary upon completion of a successful
performance test in accordance with an approved test plan.
Reserved.
Reserved
Dunnage associated with M55 rockets will not be processed in the autoclave or
incineration system unless TOCDF can veriff the dunnage is not PCB related.
The dunnage shall be placed into permitted storage areas designated to store waste
contaminated with the same type of chemical agent until results of the test are approved by
the Executive Secretary.
Combustible Bulk Solid Secondary Waste Category2.2.t.t2.
Attachment2-Page12
2.2.1 .12.1 .
2.2.1 .12.2.
2.2.1 .l 2.3.
2.2.1 .12.4
2.2.1 .1 2.5
2.2.1.1 2.6
2.2.1 .13.
2.2.1.13.1.
2.2.1 .1 3.2.
2.2.1 .1 3.3
TOCDF*^"*1H:io,3;
Upon successful completion of the Secondary Waste Demonstration Test, wastes included
in this category may be processed in the MPF. Wastes included in this category evolve
combustion gases, and generate ash residues when incinerated. Examples of these wastes
are Demilitarization Protective Ensemble (DPE) suits, and butyl rubber components.
TOCDF will either analyze a representative sample of these wastes or use generator
knowledge to determine proper feed rates. If generator knowledge is used, it will be
documented in the operating record.
Each waste feed charge shall be weighed prior to incineration to ensure TOCDF Permit
conditions are not exceeded. The TOCDF operating record shall include an entry for each
WIC of waste fed to the MPF. Each of these entries will include a description of the
waste, the weight of the waste, metals content (the concentration if applicable), and the
basis for categorizing the waste as a Combustible Bulk Solid.
Combustible Bulk Solid Wastes may be fed in the same WIC as other secondary waste
categories provided all conditions of this attachment and Modules V and VI are met.
Additionally, these wastes included in this category may be processed in the Autoclave
(Igloo 1631) provided an approved function test has been demonstrated and approved by
the Executive Secretary.
For Autoclave processing, the TOCDF operating record shall include an entry for each
secondary waste drum processed in the Autoclave. Each of these entries will include a
description of the waste, tlpe of container, the total weight waste, the volume of the
container storing the waste, the hazardous waste label number, and the time and date the
waste was processed in the Autoclave Module VIII.
Personal Protective Equipment (PPE) Respirator and ACAMS Carbon Filter Canisters
Three types of PPE respirator canisters are used at the TOCDF to prevent the inhalation of
chemical agent (pre-l993M-40, post-l993 M-40 and DPE backpack). Two tlpes of
ACAMS activated-carbon filter canisters are used to control agent emissions from
ACAMS sample line exhaust (aluminum housing and plastic housing). The respirator
canisters are filled with approximately five ounces of carbon that is impregnated with
copper, zinc, silver, and molybdenum, the approximate weight percent of each being: six,
six, one one-hundredth, and three respectively.
PPE respirator carbon filter canisters generated in areas where the user is exposed to
chemical agent vapors at concentrations at or above the STEL are considered
contaminated with chemical agent.
The number of PPE or ACAMS carbon canisters added to each WIC and the material used
to fabricate the outer shell of the canisters (PVC or aluminum) shall be noted in the
operating record. The weights of carbon canisters shall be subtracted from the allowable
weight of the secondary waste categories it is associated with e.g., PVC (combustible),
aluminum (non-combustible), and carbon (metals/ash etc.)
Additionally, these wastes included in this category may be processed in the Autoclave
(Igloo 1631) provided an approved function test has been demonstrated and approved by
the Executive Secretary.
2.2.1 .1 3.4
Attachrnent2 - Page 13
2.2.1 .13.5
2.2.1 .14.
2.2.1 . I 5.
2.2.1 .15. 1 .
2.2.1 .1 5.2.
2.2.1 .15.3.
2.2.1 .1 5.4.
2.2.1.15.5.
2.2.1 .16.
2.2.I .17
2.2.1 .18
TOCDF
**"*1,J;;,o'6;
For Autoclave processing, the TOCDF operating record shall include an entry for each
secondary waste drum processed in the Autoclave. Each of these entries will include a
description of the waste, type of container, the total weight waste, the volume of the
container storing the waste, the hazardous waste label number, and the time and date the
waste was processed in the Autoclave per Module VItr.
Reserved
Miscellaneous Agent-Contaminated and Non-Aeent-Contaminated Liquid Wastes
Agent-contaminated hydraulic fluid and lubricating oil generated in the MDB shall be
either contaiteized and placed into permitted storage or containerized and transferred to
the ACS tanks (e.g., via BDS) and subsequently treated in the LIC primary chambers.
Before transfff to the ACS tanks, the container(s) shall be weighed (e.g., via BDS load
cells or a calibrated scale in the TMA) and the contents shall be sampled and analyzed
(ref: Table 2-0). The corresponding results shall be documented in the Operating Record.
(Agent-contaminated shall be defined as being at or above 20 ppb for GB and VX, and
200 ppb for Mustard.
Agent-contaminated hydraulic fluid and lubricating oil may also be pumped to the ACS
tanks, via the SDS collection system, and processed in the LIC primary charnbers. A
sdmple shall be collected from the spuil decontamination tank before it is transferred to
'the ACS tank (ref: Table 2-0) for analysis.
Before treatment in the LICs, the samples described abov'e shall be malyzed,for HRA
metals. The analytical results shall be used to ensure that LIC metal feed rate limitations
are not exceeded. Additionally, the associated manufacturer information (e.g., MSDSs,
product data sheets, etc.) shall be reviewed to identifu organic hazardous constituents
having a heat of combustion less than tetrachloroethylene (i.e., 2,141BTUllb). If any of
these organic hazardous constituents are present, the waste shall be placed into permitted
storage until an appropriate management option is identified by the Permittee and
approved by the Executive Secretary. The results of the above analyses shall be
documented in the Operating Record.
Non-agent contaminated hydraulic fluid and lubricating oil generated in the MDB shall be
containerized and managed properly or transferred to the ACS tanks (e.g., via BDS) and
subsequently treated in the LIC primary chambers. Before transfer to the ACS tanks, the
container(s) shall be weighed (e.g., via BDS load cells or a calibrated scale in the TMA)
and the contents shall be sampled and analyzed (ref, Table 2-0). The corresponding
results shall be documented in the Operating Record.
Non-agent-contaminated hydraulic fluid and lubricating oil may also be pumped to the
ACS tanls, via the SDS collection system, and processed in the LIC primary chambers. A
sample shall be collected from the spent decontamination tank before it is transferred to
the ACS tank (ref: Table 2-0) for analysis.
Reserved
Reserved
S econdary Waste Management
Attachm ent 2 - Page l4
2.2.1 .18.1
2.2.1.18.2
2.2.1 .18.3
2.2.1 .18.4
2.2.1.19
2.2.1 .19.1
2.2.1 .l 9.2
2.2.1 .19.3
2.2.1 .20.
2.2.I .20.1 .
TOCDF*^"*1HI;o'3;
Each MPF charge interval and weight shall meet the limits for agent, halogens, ash, metals
and BTU.
Noncombustible form core sandwich panels make up the outer walls of the MDB and
concrete rubble generated during closure are not allowed to be processed until process for
new waste streams from Module VI is followed and approved bythe Executive Secretary.
Wastes containing metals must meet the requirements per Table V.C.l. by waste analysis
if a sample can be obtained or by engineering evaluation based on manufacture literature.
Manufacture information will be documented in the operating record.
Secondary wastes are in process once placed on a WIC, provided the WIC is located in the
tower Buffer Storage Area or the TMA A/B Area.
Waste is classified as sludge when it cannot be managed by the LIC system because of the
inability to transfer to the ACS tanks. Sludge is generated from the maintenance of the
ACS, AQS and SDS equipme,nt maintenance and is managed separately from other
secondary waste. Sludge is fed alone on a WIC. Sludge will be spread across the bottom
of the WlC/container with a uniform thickness of less than 1.5 inches and verifiedprior to
feeding into the MPF. Aqueous Waste* shall be fed to the MPF in S-gallon container with
fusible spout.
A representative sample of sludge shall be collected and analyzed prior to treatment in the
MPF. The samples will be aralyzed for HRA metals. Sampling and analysis is required
for each WIC of sludge treated in the MPF.
Aqueous Wastes* are generated from the residue of the decontaminated drums of
secondary waste and can either be processed through the LIC or processed in the MPF. If
processed in the MPF, Aqueous Wastes shall be containerized and the containerized waste
shall not be fed with other wastes on the WIC. The waste analysis requirements specified
in Paragraph 2.2.1.19.2 shall be applicable to containerized Aqueous Waste treated in the
MPF. The Aqueous feed rate shall not exceed the waste feed rate equivalent to the sludge
feed rate.
Autoclave Seconda{v Waste Manasement
The secondary waste matrices contaminated with Agents VX, GB, or Mustard that are
listed in Condition VIII.D.7.vi may be treated in the Autoclave upon approval of the
Executive Secretary.
2.2.1.21. Aeent GA - ATLIC
2.2.1.21.1. Aeent GA is destroyed exclusively at the ATLIC and is discarded oroduct characterized
by the State and Federal hazardous waste codes P999. D004. D006. D008. D009. and
D021: Previous anal]rtical results show Asent GA to contain arsenic at concelrtrations of
approxinrately 40 parts per million (pDrm) lead at concentrations of aporoximately 20 ppm.
and chlorob€nzene at concentrations of approximately 14 weisht percent. The analysis
also showed the oresence of chromium at concentrations of less than 3 oom.
Attachrn ent 2 - Page l5
TOCDF
Waste Analysis Plan
June 2009
2.2.1.21.2. The Aeent GA drained from each ton container is led directly to the ATLIC Prfunary
Combustion Chamber (PCC). Because an int€mnediate storage vessel is not used to
accumulate the agent drained from thg ton containers. each GA ton container has beeir
sampled and anallzed before processing. Samples of Ae€nt GA were coll€cted from each
ton container and anallzed for ae€lrt oreanic cont€nt and HHRA metals. The results are
provided in Table 2-A-2. A detailed relrort of the Agent GA Analytical results was
submitted to the Executive Secretary.
2.2.22. Iewisite- LTLIC
2.2.1.22.1. Lewisite is destroyed exclusively at the ATLIC and is discar{ed product characterized by
the State and Feder,al hazardous waste cqdes P999. D004. D007. D008. D009 and D010.
Previous analytical results show Lewisite to contain arsenic at concentrations of 34 weieht
Ber_ceirt. mqqur. at concelrtrations of apnroximately 500 oom and selenium at
concenlration up to approximately 6 ppm (see Table 2-A-2).
2.2.1.22.2. The Lewisite drained from each ton container is transferred to the agg, rt storaee tank
located in the ATLIC Toxic Area. Each Lewisite ton container is dfained to the ereatest
extent oossible. however the amount removed is not quantified. Additionally the tank the
_ Lewisite is transferred to is a relatively large diameter tank so the change in tank volume
caused by the addition ofagent from successively drained ton containers caqnot be used to
accurately deterrrine the amoufrt of agent drai4ed tom each Lewisitq to{r container which
is necessary to determine metal concErtrations via a mass balance. Therefore the content
of thq agent collection tank (LCS-TAI.{K-8511) shall be sampled and analfagd.for HHRA
metals before beins processed in the ATLIC ntimary combustion chamb€r (i.e.. each tank
orocessed as a batch).
2.2.1.22.3. Organic analysis is not performed because: 1) an orsanic apalysis has been performed on
Lewisite and those results have been orovided to the DSHW. 2) the organic comoounds
contained in Lewisite are easier to destrqy their the comDounds that were incinerated
during the performance testingthat established the ooeratine parameter limits that assure
comoliance with the organic comDound Destnrction and Removal Efficiency (DRE)
Performance Standard. and 3) additional organic analysis would provide no useful
information to lhe operator.
2.2.1.23 Spent Decontamination Solution - ATLIC
2.2.1.23.1 Speirt Decontamination Solutions are een€rated at the ATLIC from the rinsine out of GA.
and maintenance activities. This waste stream also includes the water rinses that are
drained from the GA. L and Transparency ton containers (.see Paraeraoh 2.2.1 .25). Whexl
a ton container is drained of its Agent GA fill it is filled more than half-way with a
Sodium Hydroxide (NaOH) based decontamination solution. The ton container is then
slowly rotated within the Glove Box for a pre-established period of time.
2.2.1.23.2 When the decontamination step is comoleted the Soent Decon Solution is transferred from
the ton container to a permitted hazardous waste storage tank (SDSJANK-8523) for later
processing in the Secondary Combustion Chamber (SCC) of the ATLIC.
2.2.1 .23.3 Prior to processing. the tank's conteirts are anallzed for aeent contmt to ensure, the Agent
GA conceirtration is less than 500 parts ner million (ppm) @
. percent orsanic content. and for
HHRA metals. Note: if thg Aeenl GA eoncentration is eoual to or ereater than 20+ob 500
Attachmentz - Page I6
TOCDF**"*IJ;:rto'#
ppm NaOH based Decon Solution is added to the tank and the contents are sampled and
anallzed again for aeent.
2.2.1.24 SBentNitricAcid-ATLIC l
2.2.1.24.1 After each Lewisite ton container is emotied of its agent fill. the to{r container is frlled
more than half way with a 3 Molar Nitris Acid solution and rotated for a specified period
of time. This processine step is Berformed to remove the high metal content solid phase of
Lewisite and breakdown products which cling to the inner surface of the ton containers.
Each Lewisite ton container undergoes at least one acid rinse.
2.2. 1 .24.2., The Soer.rt Nitrig Acid is trai'rsferred to one of two germitted tgaardous waste. storaqe and
treatment tanks (NFS-Tank-8514 or NFSJA}{K-851,6) which arq located in the ATLIC
Toxic Area. This waste stream is de.scribed by waste codes P999. D002. D004. D007.
D008. D009. and D010.
2.2.1.24.3. The Spent Nitric Acid is-accumulated in the Nitric Acid Holdins Tanl$ until the tank's
conte,lrts are sampled and anallzed for psent conc€ntration. If the results show the L
concentration to be eoual to or ereater thq the WCL (200 ppb) nitric acid of 3 M or
hieher concentration is added to the tank and the cont€,nts are circulated and re-sarnpled.
2.2.1.24.4. When the results show the L concentration to be below the WCL (200 oob) the spent acid
is transferred to. a 90day accumulation tank located in the PAS Enclosure where it is
, stored Dendinq transf€r to an off-site TSDF for deqr well injection. Note the mctals
analysis for this waste stream is associated with the 90day accumulation tank samoling
and analysis requirernents (see paraeraph 2.2.2.30),
2.2,1.25 Ton Container Rinse Water - ATLIC
2.2.1.25.1 UDon comlrletion of the rinsingpnd drainingof the NaOH based Decon Solution from GA
ton containers and the draining of the Soent Nitric Acid Rinsate fromthe Lewisite ton
containers.the emDty ton containers are further rinsed with at least three separate rinses of
nroeess water. The volume of nrocess water used for each rinse is equivalent to at least
half the voltrme of the ton contaher. Water is addd to the drained ton container then the
container is rotated for a sDeci0ed Fefrixtof time, For GA this waste stream is described
by the Heral and state waste\qddsE99*-D002. D004. D007. and D021. The applicable
wastc codes for Le*isite Toffier a.e F999. D002. D004. D007. D008.
D009. and D010. Ton container rinse water is drained and transferred'to SDS-TANK-
8523 located in the Toxic Area of the ATLIC forprocessing in the ATLIC SCC. During
' the orocessine of GA ton containers the rinse water is comingled with the Sp€nt Decon
Rinsate e€,nerated from the rinsine of the GA ton containers.
2.2.1.25.2 Durine Agent GA processing. the sampling and analvsis applicable to this waste stream
occurs when the contents of the SDS tank is filled and the applicable analyses are Aeent. GA concentration. percent orsanic content,ggdn$RA metals.
2.2.1.25.3 Durins Lewisite orocessine the solution accumulatine in the SDS tank (SDS-TAI.{K-
8523) is orimarily spent rinse water. The samplins and analysis requirements remain the
same as durine GA procassing: i.e.. orior to beins processed in the ATLIC Secondary
Combustion Chamber Droeesohs the tank's,conte,nts will be sampled and anallzed for
agent conte'nt to deterrninethe Lewisite concentration. ffi
de*omino+ho The rinse water is also analvzed for percent oreanic content and
Attachm ent 2 - Page 17
2.2.2.
2.2.2.1 .
2.2,2,1 .l .
2.2.2.1 .2.
2.2.2.2.
2.2.2.2.t.
2.2.2.2.2.
2.2.2.2.3.
2.2.2.3.
2.2.2.4.
2.2.2.4.1
TOCDF
Waste AnalVsis Plan
HHRA metals concentrations.
Analvses for Wastes Requirins Off-Site Treatment & Disnosal
The waste streams included in this section shall be transported off site for further
treatment and ultimate disposal. The analytical parameters were selected based on process
knowledge, TOCDF analytical data, and Land Disposal Restriction Notification
requirements. The extraction method that will be used to determine Toxicity
Characteristic parameter concentrations will be the Toxicity Characteristic Leaching
Procedure (SW-846 Method 1311).
All waste streams included in this section (with the exception of the dunnage generated in
the UPA, treated scrap metal, and liquids generated in SUMP 110) shall be characterized
as F999 hazardous waste. Treated scrap metal is defined as metal from bulk containers,
projectiles, and mortar rotrnds which has undergone thermal decontamination in the MPF
under normal operating parameters and has no residue remaining internally or externally
on the scrap metal. Treated scrap metal shall be managed in accordance with Section
2.2.2.7.6 of this attachment after approval from the Executive Secretary for each agent
campaign. Each shipment of F999 waste transported off site shall be accompanied by a
hazardous waste manifest.
The Permittee shall determine the hazardous constituents in the waste streams to be treated
off site. The Permittee shall also detennine the underlying hazardous constituents as
applicable in 40 CFR 268.9 and give proper notification with the hazardous waste
manifest.
LIC Slae
The incineration of chemical agent and spent decontamination solutions in the LICs cause
the generation of a o'glass like" slag waste stream. Slag (in a molten state) accumulates in
the secondary chambers of the LICs.
Each batch of slag shall be removed by tapping the slag extension of the secondary
chamber and draining the molten slag into insulated drums or by chipping the solidified
slag and placing the slag into containers. Each LIC secondary chamber is equipped with a
view port that allows the operator to visually determine the slag level within the secondary
chamber. The slag shall be removed before the slag level reaches the top of the view port.
Each batch of LIC slag generated shall be analyzed for TCLP metals after each re-bricking
until the metal concentrations drop below the regulatory limits.
Reserved
Treated Burster Casings/Fuse Bodies/Ash
During the 155mm mustard projectile c4mpaigns, residues collected at the DFS HDC
output will consist of ash, empty burster casingsnose closures/lifing lugs and fuze well
cups. The bursters are removed in the ECRs leaving the projectile's burster well intact and
theprojectile's agent cavityunopened. Projectile agsnt cavities are opened inthe
Munition Processing Bay (MPB) just prior to the agent draining process step.
AttachmentZ - Page 18
2.2.2.4.2
2.2.2.5
2.2.2.6
2.2.2.6.7
2.2.2.6.2
2.2,2,6,3
2.2.2.6.4
2.2.2.7
2.2.2.7.1
2.2.2,J.2
2.2.2.7.3
TOCDF
Waste Analysis Plan
June 2009
The ash and debris generated from this waste stream shall be analyzed for agent
concentration, TCLP metals, TCLP organics and Universal Treatment Standard (UTS) as
required.
Reserved
DFS Cyclone Residues
DFS cyclone residues shall be arnlyzed per Table 2-l for the parameters of chemical agent
concentration, TCLP metals, and TCLP organics. If analytical results demonstrate this
waste to be Toxicity Characteristic for organics, this waste stream shall additionally be
amlyzed for dioxins/furans and explosives.
Reserved
DFS cyclone residues having a chemical agent concentration below 20 parts per billion
(ppb) for GB and VX, and 200 ppb for Mustard, shall be transported to an off-site Subtitle
C TSDF.
DFS cyclone residues having an agent concentration equal to or greater than 20 ppb for
GB and VX, and 200 ppb for Mustard shall be placed into permitted container storage
until a treatment method is approved by the Executive Secretary.
Treated Bulk Containers/Projectiles/Ivlortar Rounds (Scrap Metal)
Each burn tray exiting the MPF undergoes an agent assessment to ensure adequate thermal
treatment. The presence of chemical agent is determined by an Automatic Continuous Air
Monitoring System (ACAMS) located at the MPF discharge airlock. If chernical agent is
detected above 0.5 VSL, the munitions/bulk containers are moved back into the MPF to
undergo further thermal treatment. Munitions/bulk containers will be processed through
the discharge airlock in accordance with Module V, VI, and Attachmerrt22 using either
high temperature or low temperature monitoring of the discharge airlock.
The MPF is designed with double-door airlock systems located on both the charge and
discharge end of the primary combustion chamber (PCC). These systems prevent PCC
combustion gases and agent vapors from being discharged to the MDB or the atmosphere
when burn trays are charged and discharged respectively.
The MPF primary cornbustion chamber is divided into three zones. Treatment through the
MPF requires that each burn tray charge remain in each zone for a preset period of time as
specified in Module V. When a bum tray advances to the discharge airlock, one zone
must remain empty while the ACAMS in the discharge airlock is used to monitor the
treated munition(s).
While in the discharge air lock, the contents of the burn tray are monitored for the
presence of chemical agents using ACAMS. The burn tray remains in the MPF discharge
airlock for the ACAMS to monitor two complete cycles.
2.2.2.7.4
Attachment2 - Page I9
2.2.2.7.s
2.2.2,7.6
2.2.2.t.7
2.2.2.7.8
2.2.2.8
2.2.2.8.1
2.2.2.8.2
2.2.8.3
TOCDF*^"*1,J;:;#;
If chemical agent is detected at or above the action level of 0.5 VSL, the burn tray in the
MPF discharge airlock is moved back into Zone3 (or Zone2 if the MPF is in a two-zone
operation) for additional processing. If no agent is detected, the burn tray exits the MPF
discharge airlock by being advanced to the MPF cool-down conveyor. Flaming or
smoking munitions/bulk containers or waste trays shall be placed back into the discharge
airlock for additional processing.
F999 scrap metal (i.e., "disposable scrap metal") shall be managed as a hazardous waste
and disposed at an approved, off-site Subtitle C TSDF unless the scrap metal is destined
for recycling by smelting (i.e., "recyclable scrap metal") per 2.2.2.7.7 below. Before
disposal of the scrap metal, residue in the interior and on the exterior of the scrap metal
shall be removed (e.g., vacuumed) and the scrap metal shall be visually verified as clean.
The residue removed from disposable scrap metal shall be analyzed and managed
according to the requirements described for MPF Munitions and Ton Container Residues
(ref: section 2.2.2.10). The residue removed from recyclable scrap metal shall be anallzed
and managed as describedin2.2.2.7.7 below.
For scrap metal destined for recycling exclusively by smelting, the recyclable scrap metal
shall be managed as F999 disposable scrap metal hazardous waste and be transported with
a hazardous waste manifest describing waste as an F999 Utah listed hazardous waste until
1) a test plan and report for the scrap metal has been approved by the Executive Secretary,
afi2) verification testing has been accepted. Before shipment of recyclable scrap metal
offsite, residue in the interior and on the exterior of the scrap metal shall be removed (e.g.,
vacuumed) and the scrap metal shall be visually verified as clean. The residue removed
shall be analyzed and managed according to the requirements described below for the
MPF Burn Tray, WIC and CTC residues (ref: section 2.2.2.9). Any MPF treated bulk
container/projectile/mortar that contains residue that cannot be removed shall be
considered aF999 hazardous waste (not recyclable scrap metal) and the requirements
specified in paragraph 2.2.2.7 .6 shall be followed. All mustard 155mm projectiles shall
be managed per paragraph 2.2.2.7 .6.
Mustard 155mm projectile residue for the initial and on-going verification sampling will
be sampled and aralyzed per Table 2-l in this Attachment.
MPF Treated Debris
Pre-filters, HEPA filters, carbon filter trays (from which the carbon was removed prior to
treatment in the MPF), munition overpacks, shipping containers, process equipment, and
tools are treated in the MPF to remove surface contamination.
Each burn tray, WIC or CTC exiting the MPF is analyzed for chemical agent as described
in Attachment 2 (Waste Analysis Plan) and Attachment 22 (Agent Monitoring Plan).
This MPF treated debris waste stream shall be managed separately from the scrap metal
waste stream and shall not be recycled, with the exception of the following miscellaneous
metal wastes; munition overpacks, piping, conveyors, drain probes, and shear blades.
Miscellaneous metal wastes may be treated as scrap metal and recycled in accordance with
paragraphs 2.2.2.7 .6 and 2.2.2.7 .7 .
MPF Bum Tray. WIC and Cutaway Ton Container Residues2.2.2.9
Attachm ent 2 - Page 20
2.2.2.9.1
2.2.2.9.2
2.2.2.9.3.
2.2.2.10
2.2.2.10.1
2,2.2.10.1 .1
2.2.2.10.2
2.2.2.10.3
2.2.2.10.4
w.r,"A.d;8;Dlr:
June 2009
An inspection of the residue will be performed per criteria approved by the Executive
Secretary. If the inspection criterion is met demonstrating complete treatment, then the
waste will be sampled and anal)zed, if required, and managed off-site. If the residue does
not meet the criteria, the residue will be drummed and placed in storage for further
processing. The MPF residues ge,nerated shall be analyzed due to the variability of the
waste steams. Additional sampling is necessary to ensure compliance with the 40 CFR
268.7 to identifi underlying hazardous constituents that may be present in the residue that
could prevent land disposal.
Each shipping container (i.e., drum or roll-off which ever is used) generated will be
sampled. The samples will be screen for the agents contaminating the wastes. To
determine applicable Toxicity Characteristics, samples will be additionally analyzed for
TCLP metals and organic. To determine the presence of underlying hazardous
constituents, samples will also be analyzed for metals as specified in Table 2-4a (note
Toxicity Characteristic metals are a subset of this list), total volatile organic as specified in
Table2-4b, and total semi-volatile organics as specified n2-4e. The volatile and semi-
volatile organic analytes specified in Tables 2-4b xd 24c were selected base on their
potential to be present in the residue as products of incomplete combustion.
The residue waste stream resulting from the MPF incineration treatment of secondary
waste shall be managed separately from the munitions metal residues and shall not be
recycled. This waste stream shall be shipped to an approved hazardous waste facility for
disposal.
MPF Munitions and Ton Container Residues
MPF munitions and ton container residues will be composed primarily of incinerated paint
flakes and residues removed from the interior and exterior of the munition and ton
containers as well as their burn trays. Residues shall be removed from each ton container
or munition and associated bum trays and managed as hazardous waste separately from
munition/ on container.
MPF munitions and ton container residues shall be analyzed for chemical agent
concentrations, HRA metals, TCLP metals and TCLP organics.
Residue generated from the processing of ton containers and munitions shall be sampled
and analyzed per Table 2-1. The sampling frequency may be extended to quarterly if
supporting information is submitted and approved by the Executive Secretary that
demonstrates the consistency of the analytical results relative to the hazardous waste codes
applied to this waste stream
The agent cavities of the mustard 155mm projectiles are obstructed by the burster well
which prevents access to the projectiles' interior surfaces. The interior of the projectile
will not be cleaned out prior to disposal at an approved hazardous waste facility.
The small opening at the top of the 4.2-inch Mortars coupled with the obstruction caused
by the interior baffle prevents access to the mortars' interior surfaces, thereby precluding
cleanout. Therefore, the interior of the mortars will not be cleaned out prior to disposal at
an approved hazardous waste facility.
Incinerator Refracto2.2.2.11
Attachm ent 2 - Page 2l
2.2.2.11.1
2.2.2.12
2.2.2.12.1
2.2.2.12.2
2.2.2.r2.3
| 2.2.2.13
2.2.2.13.1
2.2.2.13.2
2.2.2.r3.3
2.2.2.13.4
2.2.2.13.5
2.2.2.13.6
2.2.2.13.7
2.2.2.13.8
TOCDF*^**1*Iiot;
Upon change out, the discarded refractory lining of the incinerator primary and secondary
chambers shall be amlyzed for TCLP metals and properly managed.
PAS Residues
PAS residues are comprised of scrubber brine precipitate and filter elements. The
precipitate is collected in the bottom of the PAS process vessels (i.e., the quench towers,
packed bed scrubbers, and demister vessels), and the PAS brine filters.
Reserved
The PAS residues shall be analyzed for the parameters of chemical agent concentration,
corrosivity (pH), free liquids, TCLP metals, and TCLP organics.
TOCDF Spent Scrubber Brines
Scrubber brines are removed from the PAS as they are generated by the process control
equipment. Spent scrubber brines shall be stored in BRA-TANK-101, BRA-TANK-102,
BRA-TANK -20 l, and BRA-TANK-202.
The scrubber brines are shipped to an off-site TSDF for further treatmeirt as necessary and
ultimate disposal.
Spent scrubber brines from each BRA tank to be transferred off site for further treatment
and ultimate disposal shall be analyzed for chemical agent concentration, conosivity (pH)
and specific gravity.
On a monthlybasis or each munitions campaign change, whichever is sooner, a composite
sample comprised of a sample from each BRA Tank shall be atalyzed for TCLP metals
and TCLP organics. This analysis is to confrm the current waste profile for scrubber
brines. The brine from which the confirmatory sample was taken may be shipped off site
under the current brine waste profile.
For Subpart CC VOC demonstration compliance, spent scrubber brines shall be sampled
as the tank is being filled as required in Table 2-1 and specified by Section 2.10.
Spent scrubber brines shall only be shipped off site for further treatment and ultimate
disposal if the agent concentration in the brines is below 20 ppb for GB and VX, and 200
ppb for Mustard.
Reserved.
MPF brine samples shall be collected and analyzed after the initial agent verification
sampling the fumace is completed and trays are fed back to back, but no longer than 4
weeks after commencemsnt of the mustard 155mm projectile campaign. Brine samples
shall be collected from the discharge of the on-line MPF PAS brine pump. The samples
shall be collected weekly, within the last four hours of the l2-hour day shift, and before
any manual adjustment is made to MPF PAS liquid levels (excluding adjustments required
addressing contingencies.) The samples shall be collected weekly until approval of the
Executive Secretary to discontinue this sampling frequency has been granted. The
samples shall be analyzed for HRA metals.
Attachrnent2 -PageZ}
| 2.2.2.14
2,2,2,14.1
2.2.2.14.2
2.2.2.14,3
2.2.2.15
2,2,2,15,1
2.2.2.15.2
2.2.2.16
2.2.2.16.I
2.2.2.17
2.2.2.I8
2.2.2.1.9
2.2.2.20
2.2.2.20.1
2.2.2.20.2
TOCDF**" *lHIrno'#
TOCDF SDS Tank Sludges
Filters associated with the SDS tanks collect solids that have precipitated out of spent
decontamination solution. The sludge removed from the filters associated with the SDS
tanks shall be anal)zed for chemical agent, corrosivity (pH), free liquids, explosives,
TCLP metals, and TCLP organics.
SDS tank sludges shall only be shipped off site for further treatment and ultimate disposal
. if the agent concentration in the sludges is below 20 ppb for GB and VX, and 200 ppb for
Mustard. If the agent concentration is found to be greater than or equal to these values,
decontamination solution shall be added to the accumulation container and the analysis for
chemical agent, pH, and free liquids shall be repeated.
Sludges from SDS sumps located outside of the ECRs shall be managed in accordance
with Paragraphs 2:2.2.1 4.1 and 2.2.2.1 4.2.
BRA Tank Sludges
Between agent campaigns, the scrubber brine sludge which has collected in the BRA tanls
is removed. During scheduled maintenance of a BRA tank, scrubber brine sludge may be
removed.
BRA tank sludges shall be analyzed for agent concentration, pH, free liquids, TCLP
metals, and TCLP organics.
PAS Demister Candle Sleeves
Prior to shipment, the demister candle sleeves from each PAS shall be analyzed for
chemical agent concentration, TCLP metals and TCLP organics.
Reserved
Reserved
Reserved
Dunnase Generated in the Unpack Arca (UPA)
The initial waste characterization of dunnage received in the UPA is based on a
determination by Area 10 personnel.
UPA personnel shall use ONC/overpack agurt monitoring to determine if dunnage has
bbcome contaminated during transport to TOCDF. Dunnage present in ONCs/overpacks
having agent monitoring results of 0.5 VSL or greater shall be characterized as P999
hazardous waste and managed as specified in paragraph 2.2.1.11.2.
Attachrnent? - Page23
2.2.2.20.3
2.2,2.21
2.2.2.21 .l
2.2.2.21 .2
2.2.2.2I .3
2.2.2.21 .4
2.2.2.2I .5
2.2.2.21 .6
2.2.2.21 .7
2.2.2.2t.8
TOCDF
*^"*1,J;I;o'6;
Samples of dunnage (that have not been declared hazardous waste by Area 10) shall be
taken in accordance with Table 2-1 from ONCs/overpacks that monitorbelow 0.5 VSL
and do not contain leaking munitions. If an analysis of representative samples of dunnage
shows agent concentrations at or above the WCL, the dunnage shall be characterized as
P999 hazardous waste and managed as specified in paragraph2.2.Ll l.2. If the agent
analytical results show the agent concentration is below the WCL and exhibits no
hazardous waste characteristics or listings, the dunnage is not considered a listed
hazardous waste.
Personal Protective Equipment (PPE)
This waste stream includes items wom during the course of operations a TOCDF in areas
where the potential for liquid or agent vapors are known to exist. Examples of these items
can be described as either commercially available items, such as those known by brand
names Saranex@, Tyvek@, or Responder@ suits, or Army specialty PPE items, such as the
Demilitarization Protective Ensernble (DPE) suits or Toxicological Agent Protective
(TAP) gear or suit. The PPE items are typically made of a mixture of PVC, chlorinated
polyethylene resins, plasticizers, and metal stabilizers, or butyl rubber. Each PPE suit is
decontaminated before the "Entrant" is removed from the suit. The decontaminated suits
are bagged in containers (typically plastic bags, with two to three suits per bag), where
they are segregated based on monitoring results for further waste handling. The bags that
contaiq these items or other plastic sheeting material may also be included as part of this
waste strea1tr and will follow the same requirements as the PPE for monitoring and waste
characterization.
Discarded PPE shall be characterized as P999,F999, or a combination of P9998999
hazardous waste.
PPE that is not monitored for agent shall be characterized as P999 hazardous waste and
managed as specified in paragraph 2.2.2.21.8.
PPE may be characterized as F999 hazardous waste if the agent monitoring results of the
volume of air within the suit's container shows an agent concentration less that 0.2 VSL.
PPE may be characterized as PggglEggg hazardous waste based upon and agent
monitoring results of less thanl.0VSL and will be managed in accordance with paragraph
2.2.2.21.10.
Containers of PPE having agent-monitoring results equal to or greater than
1.0 VSL shall be characteized as P999 hazardous waste and managed as specified in
paragraph 2.2.2.21.8
Reserved.
PPE to be managed as a P999 listed hazardous waste shall be treated in the MPF based on
the results of the MPF Secondary Waste Demonstration Test. The treated PPE residue
shall be managed off site as an F999 hazardous waste in accordance with condition
2.2.2.9.
Reserved.
Attachm ent 2 - Page 24
2.2.2.21 .9
2.2.2.21 .10
2.2.2.22
2.2.2.22.1
2.2.2.22.2
2.2.2.22.3
2.2.2.22.4
2.2.2.22.5
2.2.2.23
2.2.2.24
2.2.2.24.1
2.2.2.24.2
2.2.2.24.3
2.2.2.25
2.2.2.25.1
. TOCDF*^"*1H:#3;
PPE shipped off site as F999lP999 hazardous waste shall be managed at a Subtitle C
TSDF. F9991p999 waste that is greater than 0.2 VSL and less than 1.0 VSL will require
off-site controls (hrough contract requirements) as an added measure of control to reduce
potential contact with the waste.
SpentNon-Aeent Contaminated MDB Equipment Hydraulic Fluid and Lubricating Oil
Spent hydraulic fluid and lubricating oil generated in the MDB to be transported off site
for treatment shall be arnlyzed for chemical agent concentration, HRA metals, and TCLP
organics.
MDB-generated spent hydraulic fluid and lubricating oil having agent concentrations less
than 20 ppb for GB and VX, and 200 ppb for Mustard may be managed at an off-site
Subtitle C TSDF ortreated in the primary chamber of one of the LICs in accordance with
Section 2.2.1.15.
MDB-generated spent hydraulic fluid and lubricating oil contaminated with chemical
agent at or above 20 ppb for GB and VX, and 200 ppb for Mustard, shall be managed in
accordance with Section 2.2.1.15.
The failure of a mechanical system inside the MDB could result in the generation of fluids
contaminated with chemical agent and be commingled with spent decontamination
solution. These fluids shall be collected in sumps and transferred to SDS-TANK-I0I,
SDS-TANK-I02 or SDS-TANK-IO3 and managed as described in Section 2.2.1.4 or
2.2.2.28.
Rags and absorbent materials from cleanup of hydraulic fluid and lubricating oil spills
shall be characterized and managed appropriately.
Reserved
CAL Aqueous Wastes
Operation of analytical equipment within the CAL results in the generation of an aqueous
waste stream.
CAL aqueous waste shall be analyzed for agent concentration, corrosivity (pH),
ignitability, TCLP metals, and TCLP organics.
CAL aqueous wastes may be transported off site for further treatment and ultimate
disposal at a Subtitle C TSDF only if the agent concentration in the waste is below 20 ppb
for agents GB and VX, and 200 ppb for agent Mustard.
CAL Solid Wastes (debris)
CAL generated solid wastes consist of but are not limited to discarded glassware, wipe
cloths, paper, PPE, plastic, wood, pipet tips, DAAMS tubes, transfer tubes, silver-fluoride
pads, discarded analytical equipment components, and vermiculite.
Attachrn ent 2 - Page 25
2.2.2.25.2
2.2.2.25.3
2.2.2.25.4
2.2.2.26
2.2.2.26.1
2.2.2.26.2
2.2.2.27
2.2.2.27.1
2.2.2.27.2
2.2.2.27.3
2.2.2.27.4
TOCDF
Waste Analysis Plan
Each individual item comprising this waste stream is decontaminated before it is placed
into the accumulation container. Overtime as the container is filled, decontamination
solution residues (that once clung to the item) collect in the bottom of the container. A
sample of this residual decontamination solution shall be taken from the bottom of each
container of CAL solid debris generated and anallzed for chemical agent.
Containers having analytical results demonstrating the agent concentration in the
decontamination solution is below 20 ppb for GB and VX, and 200 ppb for Mustard, shall
be classified as F999 listed hazardous wastes.
Containers having final analytical results demonstrating the agent concentration in the
decontamination solution is at or above 20 ppb for GB and VX, and 200 ppb for Mustard
shall be placed into permitted storage until the Executive Secretary approves a treatme,nt
plan.
MSB Solid Waste (debris)
MSB generated solid wastes consist of but are not limited to wipe cloths, PPE, discarded
monitoring system components, tygon tubing, silver-fluoride pads, DAAMS tubes, pre-
concentrator tubes, and discarded analytical equipment.
This waste stream shall be sampled, analyzed, and managed as described in paragraphs
2.2.2.25.2 through 2.2.2.25.4
Sump 110
Sump 110 is a collection sump designed to receive precipitation run-off collected on the
incinerator PAS concrete pads. In the event of a PAS process equipment leak, the
potential exists for Sump 110 to also accumulate incinerator PAS liquids/solids (e.g.,
scrubber brines). These liquids/solids generated from the treatment of chemical agents
and chemical agent munitions are a listed hazardous waste in Utah.
lf the material (either liquid or solids) accumulated in Sump 110 is to be transferred off
site for treatment and/or disposal, a sample of the material shall be analyzed for agent
concentratioo, pH, TCLP metals, and TCLP organics. If the agent concentration is below
20 ppb for GB or VX or below 200 ppb for Mustard, then the material may be transferred
off site for treatment and/or disposal.
Unless the Permittee can demonstrate in accordance with R315-2-3(d) that the material
removed from the sump is not ahazardous waste, the material shall be managed as a
hazardous waste.
To determine if liquid collected in Sump 110 shall be treated on site or transferred off site
for further treatment and disposal, the liquids shall be visually inspected for the presence
or absence of a surface oil sheen. Sump 110 liquids having a surface oil sheen, which is
evidence that organics were mixed with the sump contents, shall.not be transferred to the
BRA for on-site treatment.
When material accumulated in Sump 110 is transferred off site in tankers, the material in
each tanker shall be sampled and aralyzed for pH, TCLP metals and TCLP organics. The
material shall also be analyzed to confirm that agent concentrations are at or below either
20 ppb for GB and VX, or 200 ppb for Mustard.
2.2.2.27.5
Attachrn ent 2 - Page 26
2.2.2.21 .6
2.2.2.27.',7
2.2.2.28
2.2.2.28.1
2.2,2.28.2
2.2.2.28.3
2.2.2.28.4
TOCDF**"*1,J;I;rT;
If no surface oil sheen is visuallypresent on the liquid accumulated in Sump 110, the
liquid may be transferred to one of the BRA-Tanks. Any solid material removed from the
sump shall be managed as a hazardous waste.
Instead of off-site treaknenVdisposal, the liquid accumulated in Sump 110 maybe
transferred to one of the BRA-Tanks provided no surface oil sheen is visually present.
Likewise, any solid material removed from the sump may be containerized and then stored
and/or treated on site.
Autoclave Treated Waste
Each batch of waste treated in the Autoclave is subjected to a minimum temperature for
minimum time-period. The final process step is to fill the previously evacuated Autoclave
with ambient air. After a predetermined time to allow for mixing and evaporation of
moisture from the treated waste, the interior of sealed Autoclave is monitored for agent.
Treated secondary waste with post-treatment headspace agent monitoring results of less
than 0.5 vapor screening level rySL) and demonstrated WCL of less than 20 ppb for VX
and GB and 200 ppb formustard maybe managed in roll-offs for off-site transport to a
Subtitle C TSDF as F999. Other waste codes may apply.
Treated secondary wastes with post-treatment headspace agent monitoring results of less
than 0.5 VSL, but without demonstrated WCL of less than 20 ppb GB and VX and 200
ppbl mustard, may be managed in roll-offs for off-site transport to a Subtitle C TSDF as
P999/F999 with additional off-site controls (special handling through contract
requirements) as an added measure of control to reduce potential contact with waste.
Other waste codes may apply.
If the agent monitoring results of the Autoclave headspace shows an agent concentration
equal to greater than 0.5 VSL the batch of wastes must undergo a new treatment cycle in
the Autoclave.
2.2.2.29 Spent Scrubber Brines - ATLIC
2.2.2.29.1 Spent Scrubber Brines are generated from the oBeration of the ATLIC Pollution
Abatement System (PAS). Purged scrubber brines are transferred to one of three 12.000
eallon 90-day accumulation storase tanls. The federal and state waste codes applicable to
this waste stream are F999. D002. D004. D007. D008. D009. and D0l0Jeeause€pent
SeruUUer grhes are E€r,r€ratC frem an iircin
in€s"
2.2.2.29.2 Each Tank of SBent Scrubber Brines is samoled and anallzed for the aeent being
processed to ensure the asent conc€Nrhation is below the WCL (20 pnb for GA. 200 ppb
for Lewisite). Samples will be collected from one tank at the beeinning of each aeent
camoaign and quarterly thereafter. The oeriodic samples will be anallzed for TCLP
metals includine the anaMes specified in Table 2-4a and TCLP organics. Additionally'
samBles will be collected and analyzed for the organic compounds listed in Tables 2-4b
and 24c if the brinps are Toxicity Characteristic for organics.
2.2.2.30 Less Than (9 WCL Spent Nitric Acid - ATLIC
Attachm ent 2 - Page 27
TOCDF
Waste Analysis Plan
2.2.2.30.1 Spent Nitric Acid is first collected in one of two permitted hazardous'waste storaqe tanls
located in the ATLIC Toxic Area. Once the Lewisite co,ncenhation in the conteirts of a
tank is demonstrated to be less than the 200 ppb WCL they are transferred to a 90-day
accumulation tank located in the ATLIC PAS Enclosure.
2.2.i.30.2 Less than WCL Spent Nitric Acid is anticioated to have hiqh concqnhations of arsenic and
mercury based on the analytical results for the solid ohase Lewisite that was found to.cling
to the interior of the Lewisite ton containers. The federal aqd state waste codes apolicable
to this waste strearrr are F999. D002. D004. D007. D008..D009.and D010.
2.2.2.30.4 TOCDF will collect samples from each< WCL Soent Nitric Acid Tankprior it centents
beins shipI)ed offsite to a Subtitle C TSDF. Samples will be anallzed for TCI,P metals
includine the analyt€s soecified in Table 24a and TCLP organics. Additionally samplps
will be collected aqd analyzed for the or$anic compounds listed in Tables 2-4b and 24c if
the < WCL reject water results are Toxigity Characteristic for orqanics. -incc this w?ste
stream will be disposed off-site throueh de€p wpll injectioq fOCDF will additionally
collect samples to be anallzed for total susnended solids. and oH.
2.2.2.31 Spent Powdered Activated Carbon OAC) - ATLIC
2.2.2.31.1 The ATLIC PAS includes equipment to inject PAC into the elhaqst gas,stream. The PAC
is injected after the Exhaust Gas Re-Heater. The PAC adsorbs.Mercurv and (if anv)
residual organic vaDors from the exhaust gas. Soent PAC is g€neratod from o[cration qf a
baehouse filter syst€,m which rqnoves the PAC from the exhaugt qas. So€nt PAC is
dischareed from the hopDer located.below the baghouse into a storage contain€r. The
fderal and state waste codes aoplicable to this waste steam are F999. D004. D007. D008.
D009. and D010.
2.2.2.31 .2 Each drum of Sperrt PAC e€n€rated is saml,led and analyzed for the ag€Nrt beins processed
to ensure the aeent conc€,rtration is below the WCL (20 ppb for GA.200 pob for
Lewisite). Samoles will be collected from one qontainer at the becinninq of each aeent
campaien or quarterly and anabzed for TCLP metals includinq the analytes soecified in
Table 2-4a. TCLP organics and total metds. Additional samoles willbe collected and
anallzed for the oreanic comoounds listed in Tables 24b.and 24c if the PAC is Toxicity
Char. acteristic for organics.
2.2.2.32 Bashouse Fabric Filters - ATLIC
2.2.2.32.1 Discarded baghouse fabric filters are contaminated with the PAC. The apolicable federal
and state waste codes are the same as those for PAC: i.e.. F999. D004. D007. D008.
D009. and D010. Orsanic compounds are not expected to be present at this point in the
nrocess because they are destroyed in the ATLIC combwtion chambers.
2.2.2.32.2 Because discarded baghouse fabric filters are contaminated with PAC. the waste
characterization that is applicable to the PAC will be apolied to the baehouse filtors.
Sampline of baghouse fabric filters is not required.
2.2.2.33 Spent PAS Fixed Bed Activated Carbon System Pre- and HEPA Filters - ATLIC
Attachm ent 2 - Page 28
{
w**A"d;:;lrl
June 2009
2.2.2.33.1 The final ATLIC PAS componeirt exhaust eas flows thoush before it is released to the
ambient air is a fixed bed activatod carbon filter system. There are two carbon filter
systems with one beine on-line whenev€r the incinerator is at op€ratine temo€rature. Each
filtruonsists gf a pre-Iiltq followed by a Hieh Efficiency Particulate Air (HEPA) filter.
followed by a single bank of sulfur impreenated activated carbon. followed by a second
HEPA filter. SLent PAS Fixed Bed Activate Carbon Filter systern ore- and HEPA filt€rs
may be co{rtaminated with Arserric. Chromium. Lead. and Mercury. The applicable
federal and state waste codes associated with this waste steam are F999. D004. D007.
D008. and D009. The filters are not exoected to be contaminated with organics because
they are located downstream of the combustion chambers and are also located 4ownstream
of where the PAC is injoQted and rernoved (see prwious section).
2.2.2.33.2 SBent ATLIC pre- and HEPA lilter are sampled and analFed for TCLP metqls. includine
the analytes specified in Table 24a. These wastes are manaqed oftsite at a Subtitle C
TSDF.
2.2.2.34 Soent PAS,Fixed Ped Activated Carbon - ATLIC
2.2.2.34.1
-The
sge,nt activated ca$onreuroved from the ATLIC PAS carbon filter systans is
anticipated to be contaminated with mercury and arsenic. the apolicable waste codes beins
F999. P004. and D009. The carbon in the fixed bed units is not exDected to be
contaminated With organics because units are lpcated downstream of the combustion
chanrbers and are also located downstream of where the PAC is injected and removed (see
orevious section).
2.2.2.34.2 The carbon will be samDled and anallzed for as€ots that w€re processed while the oarbon
was beine us€d as a filter media to €,nsure this waste is below the WCL orior to it being
transfcrred off-site for treatme,nt and dispgsal at a Subtitle C TSDF. This wasta stream
includins the anal ified in Table 2-
2.2.2.35 Spent ATLIC HVAC System Pre- and HEPA Filters - ATLIC
2.2.2.35.1 The ATLIC Heatine Vartilation and Air Cpnditionins GryAC) Systern consists of three
filter units- with any trro on-line at all times that agelrt is in the facility. Within each filter
is a bank of ore-filters followed by a bank of HEPA filters. followed by three banks of
activated carbon filters. followed finally by a second bank of HEPA filter. These filter
elemeirts will be relrlaced on an as-need basis. The applicable waste code is P999 for the
pre- and HEPA filter located in from of the carbon beds and F999 for the HEPA filter
located behind the last carbon bed provided no conlirmed asent alarm on the stack
gggurs.
2.2.2.35.2 Discarded ore- and HEPA filters located before the carbon beds have a high poteirtial of
being contaminated with ageirt and are therefore managed on-site per the reouirements
found in Module VItr which are associated Autoclave and Drum Ventilation
Ventilati ins S Room DVS/DVSSR) s
Filters found to be contaminated with chemical asent abo 1.0 vs
are treated in the onsite Autoclave Subpart X Treatment Unit.
Facilitv Spent HVAC Activated Carbon - ATLIC
2.2.2.36.1 The ATLIC HVAC Filter Svstem uses activated carbon as a filter media to control
, {_/
I
i'\
n
..
,,..
. l" {
^t, ,\Ii: 1,,ury
2.2.2.36
Attachment2 -Page29
TOCDF
Waste Analysis?lan
chemical aeent €rnissions. Th€re are three filter units. each containing three banks of
activated carbon. Agent monitoring is conducted after the fir.st and second carbon banks
in each filter unit. The first bank of carbon will be contaminated with agent throush use.
The second and third carbon beds of each filter are determined to be centaminated with -
,i
ueent bu.ed d;umpliil una analyrir oJ@ results otthe HVeC l.
fiiterunit mid-bed agerrimonitorine results. ..-J'
2.2.2.36.2 Aeent contaminated earbon is treated on-site in the Autoclave Subpart X Treatment '
rT.:4L-'aL^^JI:}:^-^fI\^^^-.^-:.^.:^.o^l...:^-.^.L^..'^^.^^.^..-..'-ffiA,fUnit
ien
2.2.2.36.3 Activated carbon removed from cafbon banls that were positioned after a carbon bank
that did not experience aeent brqakthroush aq det€nnined by int€r-bed ag€nt monitorins is
sampt"dfanO anaFeA for usmt io di;onstrute th" corrcentration is t"to* the WCI, fZO \
'{*IIldescribe4 in the Drevioui oaraeraoh. If the results are less thanthe WclJie-ca.bon is 0 iY" -
transf€rred to an off-site Subtitle C TSCF as,aq F999 waste. { ,-
2.2.2.37 SecondaryWaste - Ageirt MonitpringWaste - ATLIC
2.2.2.37.1 Asent Monitoring Waste is qenerated from routine maintenange conducted on the. ATLIC
aeqrt monitoring systerns and includes manufactured iterns contaminated with as€nt.
Examples include nitrile gloves. pre-conceirtrator tubes (glass tube filled with activated
carbon) eas chromatoeraDh analytical colurnns. stainless steel connectors. and Teflon
tubinq. The waste code apl,licable to this waste stream is P999.
2.2.2.37.2 Aeent monitorinc wastes are managed on-site p€r the rgouirements found in Module VtrI
which are associated with Autoclave and Drum V€ntilation Syst€fi,/Drum Yentilation and
Sortine Syst€ur Room (DVS/DVSSR) secondary waste managelnent.
2.2.2.31.3 Spent PAC will be placed into onsite permitted storase if a method to analvze this
waste stream for asent has not been annroved bv the Executive Secretary.
2.2.2.38 Secondary Waste - Discarded PPE Gevel A Suits. Butvl Rubber eear) - ATLIC
2.2.2.38.1 Discarded Personal Protection Equipment (PPE) is senerated bvo€rsonnel who make
entries into contaminated areas of the ATLIC (i.e.. the Toxic Area where the hazardous
waste storase tanl$ are located). This waste stream is comoosed of manufactured iterns
tiallv contaminated wi suit
butvl rubber sloves and etc. lfhe eoui rior to bein
ved bv the "Entrant".te code aDDlicable to this w
PPE w
iated with Autoclave and Ventilation S
decontamination procedure is not successful and F999 if it is successful.
Sortifrg System Room (PYS/DVSSR) secondary waste management.
Attachrnent? - Page 30
if the
TOCDF
Waste Analysis Plan: June 2009
:2.2.2.39 SecondarvWaste- Life Supgnt Svstem (LSS) AirHoses - ATLIC
22.2.39.1 The.LSS air hose waste stream is generated by the oersofrnel eirtries into the aeent O
contaminated area of the ATLIC LSS air hoses are discarded when they contact or are
susoected to have contactod liquid chemical agent. This weste codes applicable to this
ga!teigeauds-8999"
2.2.2.19.2 Disbarded LSS air hoses are managed on-site per the requireme'nts found in Module VItr
that are associatod with Autoglave and DrumV€xrtilation Systfln/DrumV€,ntilation and
2.2.2.40 fiecondaryWaste - Agent Feed Systern Strainers - ATLIC
2.2.2.40.1 There is a feed systsm associated with each hazardous waste storaee and treatrnent tank.
Each feed system includes strainers oositioned before the oump that is used.to transfer the
liquid waste to the incinerator. Note thse is a Id svstern sDecifig to GA however this
aq€,nt i$ not transferred to a storage tank Brior to ilcincration: rath€r it is fed to the Primary
Co.rnbustion Chamber of the ATLIC directly from the ton container. The Strainers are
2.2.2.40.2 The federal and State waste codes aoplicable to soe, rt strainers een€ratod from feed
systems that manase chernical ag€nts are P999. D004. D007. D008. D009. and D021.
2.2.2.40.3 Snent Aeertt Feed Svstem strain€rs will he treat€d on.site in the Autoclave Suboart X
Treatment Unit durins the Secondary Waste Camoaien associated with the t)Oe of aqent
contaminatins the strainers.
2.2.2.41 SecondarJr Waste - Spent Decon Tank System Strainers - ATLIC
2.2.2.41.1 Soent Decon tank systern straiuers are included in a sepaxate cateeory because they are not
exDected to be contaminated with agart. GA Ton containers are filled more than half way
with a NaOH based decontamination solution after their agent fill has beeq removed. The
NaOH based decontamination solution is known to destroy the chenrical as€nts. Waste
codes associated with this waste stream are P999. D004. D007. and D008.
2.2.2.42.1 Soent Nitric Acid Holding Tank Syi.tem strainers are geirerated from the {ilterine of the
soent acid used to rinse out L TCs. Beirch scale studies showed this waste stream to have
L concentratiprrs above the WCL depending on the shength of the acid.
2.2.2.42.2 Three (3) M nitric acid is used to rinse out the Lewisite Ton Containers after they are
drained of their agent frll and to etch the interior of Transoarencv Ton Containers.
The dcid's streirsth is diminished after use. Based on bench scale testing the
concentration of Lewisite in the weakened acid is ereater then the WCL. The addition of
3 M or greater strength nitric acid drives the Lewisite concentration to below the WCL.
The waste codes anticipated to be applicable to this waste steam are F999. D004. D007.
D008. D009. and D010.
Attachment 2 -Page3l
TOCDF
Waste Analysis Plan
June 2009
2.2.2.42.3 A representative sample of this waste steam will be sampled and screened for aeent L and
analyzed for*etels TCLP metals. including the analytes specified in Table 2-4a.
Organics are not expected to be oresent due to the hieh concentration of the Nitric Acid
solution. ;/-L 2 ,L "7 10 " Lt t*r X,,r€ .
, . ^1:/, rz2.2.2.43 Decontaminated Ton Containers - ATLIC -Y:'*, ,'^ /
t, r{-t\t' , ,
2.2.2.43.1 GA. Lewisite. and Transparency Ton Containers are determined to be decontaminated . 1.,,, i;/i r*6(;(-'
bur"d on ih" Ag*t S"r.*.".r'lt, obtuir"d frorn u ,u-pl" of th" thi.d or fi*l *ut"r.irrr". ^" .. ;
that is perfonnedJf the results show the agent conceniration in the rinse water samole is i
below the waste contrel limit (20 ppb for GA. 200 ppb for Lewisite) the ton container is i
determined to be decontaminated. Decontaminated ton containers are transferred to d,.permi@ardous waste and wiil be cut in half priorto being , o
g ),. '' *,',0../
transferred to ; off-site Subtitle C TSDF. t ra' ^i'
2.2.2.44 Spent Decontamination Solutions Generated Durine ATLIC Closure
2.2.2.44.1 T.he ATLIC will process the chemical agent GA and Lewisite and the resulting solutions
generated from the rinsins of the ton containers and decontamination activities performed
to support day to day ooerations. Once the GA. Lewisite and "Transparency''TCs have
been processed. closure of the ATLIC and associated support systems will beein. Spent
Decon generated in support of closure activities maLbe treated at an off-site Subtitle C
TSDF. This will allow the ATLIC to be closed in a shorter period of time.
2.2.2.44.3 ATLIC closure eenerated Spent Decon Solutions may be treated at an off-site Subtitle C
TSDF. The apBlicable waste codes are anticipated to be F999. D002. D004. D007. D008.
D009. D010. and D021. Samples will be collected from each accumulation tank of
solutions eenerated and analyzed for Agents GA and Lewisite. Te[,P Total metals.
including the anal]4es specified in Table 2-4a. TCLP organics. pH. total suspended solids.
and total dissolved solids.
2.2.2.44.4 Closure generated spent decontamination solutions may be transferred to an off-site
Subtitle C TSDF provided the aeent concentration in the waste below the WCL (20 ppb
and 200 ppb for GA and Lewisite. respectivelD. and the waste is treated by direct
incineration.
l'rI riL",
' :J nl k''
2.3
2.3.1
2.3.2
2.3.3
2.3.4
PARAMETER TEST METHODS R315-8-2.4 t40 CFR 264.13(bX2)lr
Table 2-3provides a listing of the analytical methods that shall be used to detect and
quantiff the selected parameters. This information is presented in a relational format in
Tables 2-0 and 2-l (the WAP Summary Tables).
The on-site Chemical Assessment Laboratory (CAL) shall perform the analyses related to
chemical agent and other CAl-assigned analyses listed in Tables 2-0 and2-1.
The CAL shall be Utah-certified to perform analyses for the parameters that require Utah
certification.
Off-site analyses shall be performed by a Utah-certified laboratory for the parameters
listed in Table 2-3.
Attachm ent 2 - Page 32
2.3.5
2,4
2,4.1
2.5
2.5.1
2.6
2.6.1
2.7
2.7.7
2.8
2.8.7
2.9
2.9.1
TOCDF
**"*1HIrto,8;
The off-site laboratories selected shall be certified by the State of Utah for the methods
referenced in this waste analysis plan. When new promulgated methods are approved by
EPA, the Permittee shall notifu the off-site laboratories of the required change and request
a time frame of when the change will occur. A laboratory will have six months to submit
documentation to the Permittee of the change or a time frame when the change will be
completed. The laboratory must use the most recently approved method within 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 altemate method is approved by the Executive Secretary.
SAMPLING METHODS R315.50.6 I4O CFR 264.13&X3)I :
The sampling methods to be used for each waste stream are found in Tables 2-0 and2-l
(the WAP Summary Tables).
FREOT]ENCY OF'ANALYSES R}15-8-2.4 t4O CFR 264.13ftX4)I:
The frequencies at which each waste stream shall be sampled ard analyzed are found in
Tables 2-0 and 2-1 (The WAP Summary Tables).
ADDITIONAL REOI]IREMENTS FOR WASTES GENERATED OFF SITE R315-
8-2.4 t40 CFR 264.13ftXfl1:
The Permittee is not permitted to store or treat waste generated off site. The Permittee is
only permitted to store and treat wastes generated by the facility having EPA ID Number
tIT5210090002.
ADDITIONAL REOTJIREMENTS FOR IGNITABLE. REACTTVE. OR
INCOMPATIBLE WASTES R315-8-2.8 t4O CF'R 264.13ftXOI:
The Permittee shall comply with R315-8-2.8 for management of ignitable, reactive, or
incompatible wastes.
RECORDI(EEPING REOTIIREMENTS R3 1 5.8.5.3 t4O CFR 2 64. 73 OX3)I :
In accordance with Module II.I, analyical results generated in compliance with
Attachment 2 (Waste Analysis Plan) shall be maintained on file at the TOCDF as part of
the Operating Record.
SAMPLING AI\D ANALYSIS OA/OC PROCEDT]RES
The Laboratory Quality Control Plan in Attachment 3 describes the Quality
Assurance/Quality Control procedures established at the TOCDF to ensure integrity and
accuracy of the waste sampling and analysis effort.
ST]BPART CC AI\D BB SAMPLING AI\D AIIALYTICAL PROCEDT]RES2.10
Attachrn ent 2 - Page 33
2.10.1
2.10.2
2.10.2.1
2.10.2.2
2.10.3
2.10.4
2.I0.5
2.t0.6
2.t0.7
2.10.7 .l
2.10.7.2
2.10.7 .3
2.I0.7 .4
2.10.7 .5
2.10.7 .6
2.t0.7 .7
TOCDF
Waste Analysis?lan
The Permittee shall perform initial or change-of-process waste determinations for
hazardous waste listed in Tables 2-0 and 2-l for wastes managed in containers, primary
containment sumps, and tanks identified in Table 2 entitled "Hazardous WastelPermitted
Hazardous Waste Management Units" and Table 4 entitled "Hazardous Waste Sump
Systems". These determinations shall be made at the points of waste origination for
average VOCs before the first time any portion of the waste stream is placed in an
applicable container, primary containment sump, and tank system.
The average VOC is the mass-weighted average of a hazardous waste as made in
accordance with Section 2.10.1. The Permittee may choose from the two following sets of
requirements for waste determinations:
Direct measurements or methods specified in Table 2-3 or
Knowledge-based determinations.
Waste determinations for VOC through direct measurements shall document the point of
waste origination and the average VOC for an averaging period. The averaging period for
all waste streams shall be designated and documented in the Operating Record. The
averaging period can represent any time interval that the Permittee determined is
appropriate for each hazardous waste stream ofthis section, but shall not exceed one year.
Direct sample measurements shall be taken at the points of waste generation in manner to
eliminate volatilization, biodegradation, reaction, or sorption during the sample collection
storage and preparation steps. For ACS and SDS tank systems, the point of origination
shall be considered the tank. A minimum of four samples shall be collected at the points
of origination for applicable waste streams identified in this attachment. A1l samples for a
given waste determination shall be collected within a one-hour period. The average of the
four sample results constitutes a waste determination for the waste stream. All samples
used for waste analysis shall be representative of the highest VOC.
All samples shall be collected andanalyzed in accordance R315-7-30 [40 CFR 265.1084],
Attachment 3 (Sampling, Analytical, and QA/QC Procedures), and this Attachment.
The Permittee may also apply other methods and requirements of R315-7-30 [40 CFR
265.1084(a)(3)l for samples collected and analyses to determine VOC, provided the
methods are approved by the Executive Secretary as required by R315-3-4.
All direct measurements used for sampling and analytical results which require
implementation of Module X and Section 2.10, Subpart CC waste analysis requirements
shall be documented in the Operating Record and shall include the following:
Point of waste generation
Averaging period
Sampling plan used (See 40 CFR 265.1084(bX3XiiXC))
Date, time, and location where the samples were collected (40 CFR 264.1089(0)
Quality assurance program including procedures to minimize loss of organics during
sampling and measurement of accuracy of procedures (40 CFR 265.1084(a)(3xiii)(F)
Analyical method used (40 CFR 264.13(b)
Identification of the analyst who performed the anallical tests, and Analytical operating
conditions.
Attachrnent 2 -Page34
2.10.8
2.10.9
2.10.10
2.1 0.1 I
2.10.r2
2.10.12.t
2.10.12.2
2.10.13
2.10.14
2.10.r4.r
2.10.14.2
2.r0.14.3
2.10.14.4
TOCDF
**"*1Y;:'io'6;
Knowledge-based determinations may be used for making waste determinations provided
that there is sufficient information to meet the requirements found in R315-8-22 [40 CFR
26s.1084(a)(4).
The Permittee shall make and update all analytical determinations required by Section
2. 10 annually or prior to an agent campaign change for waste streams identified in this
Attachment.
For waste streams identified in Tables 2-0 and 2-l that are determined during sampling to
have VOC above 500 ppm and are not managed with air emission controls as required by
R315-8-22 [40 CFR 264.1084 through 264.1087], the Permittee shall notifuthe Executive
Secretary of each occrurence of non-compliance and prepare plans for the adoption of air
emission control requirements or waste determinations as required by this section.
The maximum organic vapor pressure waste determinations shall be performed by either
direct measurement or knowledge of the waste prior to the first time hazardous waste is
placed in the tank unit. Waste determinations for tank systems listed on Table 2 entitled
"Hazardous WastelPermitted Hazardous Waste Management Units" shall be performed as
specified by R315-8-22 [40 CFR 265.1084(c)] for tank systems using Level One control.
Direct measurements for maximum organic vapor pressure shall be one of the following:
Method 25Ein 40 CFR 60, Appendix A;
ASTM Standard Test Method for Vapor Pressure, ASTM 2879-92 (40 CFR 260.11).
Knowledge of the waste for maximum organic vapor pressure shall be determined in
accordance with Paragraph 2.10.1 1.
As indicated below, the following wastes and waste management units are exempt from
certain Subpart CC and sampling and analytical requirements of this Section:
Hazardous waste that has been treated or reduced by an organic destruction or removal
process that satisfies any one of the requirements and conditions of R315-8-22 [40 CFR
264.1082(c)l is not subject to waste analysis requirements of Section 2.10.
Hazardous waste and residues, which are to be managed in containers, sumps, and tanks,
which are complying with the air emission control standards of R3l5-8-22 [40 CFR
264.1084 through 10871 are not subject to waste analysis requirements of Section 2.10.
Wastes which are collected subject to chemical events and discharges of wastes subject to
spill clean-up requirements are not subject to the waste analysis requirements of Section
2.10.
The sumps and tank systems that must meet Level Two air emission control standards
specified by R315-8-22 [40 CFR 264.1084(b)(2)] are not subject to maximum organic
vapor pressure determinations of Section 2.10.
Wastes that satisff the requirements specified in R3 1 5-8 -22 140 CFR 264.1 082(c)(4)l are
not subject to waste analysis requirements of Section 2.10.
2.10.14.5
Attachm ent 2 - Page 35
TOCDF**"*lHIio'ffi
2.10.15 The Permittee shall perform required waste analysis determinations for Subpart BB
equipment identified in 40 CFR 264.1052 through 264.1062, that contains or contacts
hazardous waste with organic concentrations that equal or exceed 10 percent by weight
using the analytical methods listed in Table 2-0 and Table 2-lby either direct
measurement or by using knowledge-based determinations in Section 2.10.19 .
2.10.16 Direct measurements shall be obtained by collecting Subpart BB samples and performing
an analysis as specified by Section 2.10.5 to determine organic concentration levels for
equipment.
2.10.17 All samples and analysis results required by Section 2.10.19.2 shall be documented in the
Operating Record.
2.10.18 All analytical samples collected shall be representative of the highest total organic content
of hazardous waste that contacts equipment.
2.10.L9 Application of knowledge of the nature of the waste or the process may be used for waste
determination for Subpart BB equipment provided that the Permittee documents the waste
determination by one of the following procedures:
2.10.19.1 A demonstration that shows that no organics are used or are in contact with the equipment
at a particular point in the process.
2.10.19.2 Direct measurement data for waste streams listed in Table 2-0 and 2-l maybe used for
equipment in contact with an identical hazardous waste stream that contains a total organic
concentration of less than 10 percent by weight. If direct measurement methods are used
to supplement knowledge-based determination, the following shall be maintained:
2.10.19.2.1 The analyical method
2.10.19.2.2 Samplingprocedures
2.10.19.2.3 Samplevariability
2.10.Ig.2.4 Analytical variability associated with the test method that was used [40 CFR
26s.108a(aXa)l
2.10.19.2.5 Location of sample collection
2.10.19.2.6 Date and times samples were taken
2.10.19.3 If knowledge is to be used instead of the specified test method for a specific waste, then
the following shall be documented in the Operating Record to support the knowledge-
based determination:
2.10.19.3.1 Organic material balances of the source generating the waste or
2.10.19.3.2 Previous organic constituent test data or
2.10.19.3.3 Any other information, including but not limited to manifests, shipping papers, and waste
certification notices.
Attachrn ent 2 - Page 36
TOCDF**"*1,J;I#;;
2.1.0.20 Samples collected for leak detection monitoring requirements specified by Module X.C
and X.D, shall be obtained to meet the performance standards of 40 CFR 60, Method 21.
Monitoring requires that samples be taken in close proximity to the Subpart BB
Equipment, and documented exceedance of Method 21. Sampling shall be performed in
accordance with the frequencies established by Module X.C.
Attachm ent 2 - Page 37
il
ts
lzETaJOzF]F{
ea
I
lr
l
N:
/
)
.g
t
El
.
l
FZ
FqFaBtreUoE-
{
t-zf-
]
t-aFrddFl.
l
t--OIzo()zaDoI{
ilaE]FOFt-
{
a
6l
t-
i
raaoIt*aFrdIz:aJ0r
tr
(ea
trc,E
ri
AOaB5
<dEE
8B
'
Et
r
#5
GIE
n.
2
Oa
ts
C
€
R5<;
EE
8E
'
Et
r
#E
b0aH(da"E
)oLHss
H'
o
.
f,

'2
ad
a
-
..
i
Xc
l
E<
.y
'
)
4
.
!
.
GI
XME
au
s
F

tE
$i
i
E
8
E
€
EE
A
t
s
g
;

b
Fg
E

g5
F
E

E
U)
l-al-{
-q
)
ZE
fr

Er
Os
>f
i
rr
!7gEH
,\
,
oEl&t\
a0
ad
:,

.F
{
-a
-
Ho!
f
tr
t
s
-E

E
h'
E

.9
$r
E
EH
B
o-
b
:
EE
$
cr
,

bl
b

.r
a-
H
a.
H

o
-
-
3r

O"

'!
2
8
H
H-
E
O.
,
r

A'
O

O
TJ

HF
Er
E
g
E
g.
q

E
>:
E
e
gA
E
E
-c
l

i5

U
a
H
9
cO
?
i.
E

E
H
$$
$
E
cd
qE
o
5
ii

r=
t
lE
e

,
l
-*BE
g

=g
EE
E

E€
E;
E
-

Eg
TE
E
$

ET
-E
r
E
E

ce
.
e
{

EE
r
v)

x
cu

o
qY
T
T
T

)
83
E-
B
E

rr
i
i
i

g€
g
FE
g
E

fi
f
i
f
i
f
i
f
i

*
HE
EC)
tr0.
)
()aoeoF
Ot
<
tr
o3
sE
5b

.E
H
AY
cd

ri

!#
&
BE

E
7,
!1

o
C)
'
-
Uh
t
r
b
;+
Y
g
B
O
'(
,

'-
'
!,

$.
8

E
.!

r-
a

A
r-
r
H
E;

}
A_
Eo
*
:
E

E
.E

E'
E

E
oS
E
d
-
-(JdId
-f
*
^
z<
3
99
3
,.IFF
^<>
x
4
)i
,
il
2
H
r{
<
e
&0r
E>€
ot
r
Hd5s
.
E
ts
S
s8
E
I
bE
tr

bo
t
r
c0
<
<
rE
l
O.
i
3
b"
s
-r
_

-(

(\
l
El
r
n
O
Fo
r
o
-
(f
)

ti
Hl
<
o
cd

e-
*E
E
d.
a
6
E
ab
E
)-
l

^(
\

O
,-
1
.

l-

tA

f-
FH
n
O
+
ts
t
n
e
a
t
-
d.
E
bo

3
?S
E
ur
r
^
x
-8
8
E
.r

(r
t

tr
E
E
bs
\r
t
c

v(
oo
o
o

-.
i
3
tr
)
t
.
)

tf
)
d
-
d.
d
.

d.
;
6
?
aa

a
b
E
-)
4
_
a

rJ

.N
O
dd
P

Fr
E
8
5
FF
F

Fr
t

6r
-
d,
,o
bo
J
.E

rn
3F
=E,.
E
E
\f
,
.
+

t
oo

oo

oo
9?

?
O.
F
-
r

Pr
oo

o
JJ

a
J
dd
P

Fr
E
FF
F

FN
d.
E
-)

ti

cd
J
oe
-
t_

a
(r
.
l
HE
E
'd
c
o

X
E
5;
SS
d
-

S
??
3
:
-
,

T
O.
O
.
.
i

=
=
O-
33

bS
S

3
dd
E
8
5

I,
]
FF
t
r
;
6
r
-

F
,r
ia
)&<
fr
l
UF
FI
{
Fr
-3t
<4et
,
g,

-E
(
o.
,
.
ri
A
OaBt
s
ii
.
H
a.
<
(-
oEE
s
.i
'
.O

li
()
=
#5
oatrocdoUO(
n
?-Fe
0
U
o0
)
=a(D
)
u)

<.
ed

^)
co
H
\/

J.
r
a-a
\-
,=-
cr

.y
--
fr

s*

3
.l

V)
x
tr
o
)

9
U
O:
E

H
9=

P=

E
O-
=
=
=
_
UE

C'
F'
-
-
-
-
=E
J
J
y
\.
/

:Z

\/
-(.
-
)

>'
t
r

a
(A

.F
F
"

E
HW
5
'
:1

ir

C)
E
do

=
(t
I
H
P
3(
)
(
)
=
5o
5
o

il
,
d\J?aHcdbo
.E
?
-
L\
)
l*
i

_
tr

o.
,
,
I
"t
,
r
+
sl

E+
EI

i,
E
.
HI

EE
i
,e
<
l
61

6'
3

n
eI

E
>;
sl

#E
t
rdcdo.0)oUotr
aSo
a
E
!O
(
)Y:
F
>

b
tr

=4

a
80

3i

6
<E
:
E

O
FZE3
Fi
-
(
<z
E]

D
il
IIF
-g
l

,-t&
OU
o
.
Hl
-
t
rJJ
>
33
g
E
IzH&FOrdFU)E
C)
q=o
tr
O
.
9o
g
EB
t(
n
o.
=
{.ic\
a
2abi
bo
(
d
1{
8s
'=

(.
)
F(
)oOc9
(.
'
l
.iN
qE
trga63
ooeo0)bo
cd
tu
IN0)O63
il
ts
leEiz)azt]R{
(}
O
I
lr
{
(\
A
-g
x
AH6n
4
HiFE
I
FrOBFr
reUcEl
FzE]
lraFri*ttFrI
1F-a!zo()z-*Hlr
l)oH&at.
1FO-t-
fNcr
i
raaol
T
r.
lFriIz-JEi
l(aa
O0

+.
lr

F.
Ee
s
$
cd

o-

c)
=E

b€

c
*i
=
E
B
EE
f
i
*
E
/\
.
J
-
!
ER
r
-
'
5
9
O
-'
J

tr
g#
.
E

gE
trCUE
n.
2
oaB5<;
EESB
'
cE(.
)

=
aEAS
clE
n.
2
00
)
a
ts
c
u
ii
t
r
t"
.
<
doEE
5B
'
Et
r
#5
O-Ots
f
^
I'
o
t
\-
aZE
fr

!r
Os
>f
i
rr
E
Y
-
zi
:
ti

ta
)
EE
l
,\
-
ordiltr
Es
f
,
{H
E
qJ
-
)
El
{
'
dH3

HE
fi
E

E
i
Et
g
E
PE

E
fl
VJ
AE
06
)

)s
4
.5
s

E
=6

i
oB
E

E
r-
FE

e
E
cI

.^
^
l
'
gg
g
g
g
g
i
*
*
i
r
E
E=
E

$E
$
$
$
T
+
sE
E
t

fi
s
f
i
f
i
f
i
f
i
f
i
9r
=3
(
)
bg
EH
h-EE
Sc
>
6e
o-
t
r
*sH-
9
(r
)

0)
eB5€
-vdId
-I
*
-
z<
3
99
3
?.
-FF
/
T
<>
Y
4.
2
il
t
t
s
rd
<
e
N-Cr
..
'

E
E
bI
^V
t-
-
G
I
El

rn
O
FO
\
O
r
(f
)

$<
\J.a
l
r
v
(d

eo
S8
e

SS
ta
)

(-
)

-
tA

tA
d.
;
6
E

d.
d
.
a
b
E
aa
rJ

.C
!
O

rJ
r
J
Fr
E
S
$

Fi
d
Fr
;
6
r
-

FF
d"
E
bo

3
6.
5
.E

rn
;
g
'd
i=
-o
'
c
E
E:

b
-=

E
-o
S
t
SB
e
tA
t
\
a
)
A
v
d.

d.

d.
-
E
a
a
ab
E
LJ

-J

A
bJ

.e
\
O
l,
r

d9

Fr
E
3
5
F
FF

F,
r
;
-
r
_
d.
E
I0

3
6"
5
.=

-l
-

'<

6l
E
Ll
r
n
O
=
Fg
g

\c
o
E'
i
5

I
E
.d

ec
)

6
.t

$
^-

=\
oo

oo

S8
P

S
\a

(a

tr
)
A
-

ra
Bl

d.

d.
;
6
E

d.
a
a
ab
E

a
rJ

LJ

A
LJ

.C
\
O

rJ
l,
l

pi
P

Fr
f
i
8
S

d
F
FF

F,
r
;

-r
_

F
ha
'l

E(
<E
]
UF
-
fr
l
F
!:
(
:?4.
f
r
4t
,
E?1Hcd+)
.Fxt)O.
\-
/
!,()
+JF-oU()
.F
l
tn
t
rE
&a
oi
0
)
.=

.J
'
s

i'
-4-f
t
r
=
a
t
So
B
E
:E

<E
O
d\J'3
-
(,

.9
-i
Ec
3
3
Fl

-\
-v
)
-4
8
:
E

E
9'
o
=
E
A-
t
l
l
-
I.
I
r
J
=
-
)
(r
=
q
=J
;
J
\/
!
.
\
/
-\.
,
'
E
S
^
E
EE
5

g
CI
H
HE8
r
9
r
d
-\J
.d
6p
'o
-U
G
?
c
h
-v
)
-
-=
(
D
(
J
\
r
85
:
E

E
E
'F
E
5
'
o
t
a
E'
3
3
'
3
{
Ei
-
=
.
i
p
tr
3
e
A
=
=
'E

8o
-

E
J
E
E
e=

S
3
E
E
-a
r
h

4
E
E
80

&=

d
i
FzHO
=l
-
Fr
r<z
ri
l
D
dF
-iIVzFIaU9
I
<=
IJ
.O.
Fard&FariFaE
()A.
c0a
ts
(
O)

,F
bo
E
E>
,
^
.
Oa
a
.-

.^

.H
tr
[
i
?
t'
o
-
4
Xo
d
!-

t<

c<
.
u
3<
tJ
.
.
.

tr

o\
n
cg
o
l-
{

Fr

A
7\

A
\J
L/

l+
'
t

,\
l
o
.g
,
'
d
F?
t
r
AF
t
-cd

-)
f-
.oacd>
o\
e.
)C)bo
C€
a<
I?r
0)
troC€
il
l-
{el.
lz)OzFI
F.
{
oa
I
fr
{
Nr
/
)
-g
x
EF
t
c€

41
t-
{

iFq
t'
{0BFE
{
A-tUot'
l
FzrI
]
13aFtdilFrdt'
r
t-aIzo()z-&=i)oHilaE1Fa-Fl
a
t\c.
i
lanoHFl
lFrd-Z(Jzlr
l
t]tr-aa
A.
(dF
A.F
(n-atl

,^
10
)
\{
-
ZE
rr

Ei
Os
>f
r
rr
E7g
Er
d
,\
,
oE1&tr
go
o
,9
a
'=

Gl

t-
(
H
=t
3
BE
*
&E
E
HO
.
?
tg
-b

-q

,6
J
(E
.
r
{
I
'r
i
E
ir
s
5
rn
E
ol-
rol-
.aVzFIa!
)AE
od
(d

0.
)
IJ
.
I

ts
abag
AHEE95
E
cE
t
Er
e
ts
F
=0
)
(,
PoHRA
a
V
-.
r
=v
aH'
g

B
(s
=
c
A
jJ

cd
ps(a
dE
a0

-q
.H

Lr
EHT&
Zr
.3E
ti
<aoo:
A.
Y
l
J
F{

Si
S
H'
a
b
,E

SB
-|JdI6
J*
.
z<
3
99
k
t?
-FF
^<>
x
4;
i
il
i
E
rd
<
z
ilFr
Ip.
.oJb
0
lF
r
rI
J
.
E
tr
E
\
o
E=
t
.
)
-i
oGt

-:
i

O.
.+
.
f
,
.
f
,
+
oo
o
o
@
o
o
[.
)

\a

\a

rn
d.

o:

d.

d.
oo
o
o
J
J
Ja

J
rn
E

rn

rn
g

rn
-,
r
;

F
F-

F
\J
,$A\Jo\\/
NN
:
+
.
+
f-

f-

f-

f-
r.
)
(

(
ra
tt
t
t
0<
p
<
o
<
0
<
oo
o
o
JJ
J
J
ll
t
l
IJ
.
1

tI
.
1

EI

TJ
.
I
FF
F
F
O
.
tn
-
lr
t
t

-t

O
O
|'
1

o
ro

\o
t-

eo

,-
.

N
sb
E

=
(.
.
)

^
-,
4

d
oO
=
,
-
r
(

cd
'd
o
!
Q
+
o
E:
H
:
3
g>

o
H
E\
a
3N
8
R

E
tr
d
n
'
O
O
'
-
<
=f
,

X
c.
r

\O

,-
r
nW

L
Le
.
)
eo
J

O
O-
r
O
ka

o\
"X
t

\O
o
o
sB

$=
Ot
i
t
c
U
c.

c
EC
5e

Ji
l
=:
8

8?
OO
-

tr
)

O
-(
r
i

=o
E
O
rr
r
=
f
-
Q
-
O
O
"s

cg
r
a
O
O
Jr
-
,
-
r

d)
NF
(
\
-
t
€
-
,
E
OO
O

tr
C
A

tr
-e
Q
e
Q

G|
t
-
i

(d
*a
)&<r
d
UF
.
FE
]
F=3A<44f
,
E
,,
t
gEI

E
EI

U
ot
(-
1
l

o
=l

.=
FI

E
.E

$
;I

E
E6

9
=I

<
E
E
E
Nl

&5
0
5
0
.
t
r
oCB
,
^
.
\
Fi

H
a.
r
1l

*r

.=
b
e:
o(
,
-
U
tr

()

6r
-
i
.-
-

v
?
H,
i
e
i
l<

(J
'
n
-A
L
(
JS:

-a

&
{o
\
l
)
A
oaoxoo0aaoooir
*A.
a
,.
o-'-
>
0
t
r
(,

^
ct
r

L'
r
H
Eg

6
O.
=

/
O-
-F

-<

J
i=
e

u
EI

FT

F
I
>,
N
.:
6
i\

.?E<

3
_s
f
f

P
oo-.ic!o(t
)C)0)U(,
)OO.
Fz=e
--
Fr
-<z
r{
p
ilF
r-
r

(r
l
(J
U
JJ
E
E'
r
(s

E.
o
-(
\

E
E
UU

T
S
qJ

!-
r
J
J
al
)
EO.
t-erdilFardFU)B
\.
/
'.
=

:.
o
-1

o\
=
rr
^
)
oa.
2
/
\
av
\
L_^-
a
i
L/
-
H
'5

cd

92
HE
-
6
.E
<

6
tr
=
(
)
s
=.
9
"<

(J
H.
-
H8E

$
(l
)
-
=

ir
ot
9
()A.
a
ooao
OT
|r
'
]
i
:
o0)
.+
O
.ic!
E
c1

Cd

F'
t
o
tr
o
'5

Fi

'*
5

0.
)
B
EE
B
=
'-
r
'
=

cU
rl
U
)
H
=
CE
E
E
g
+r
0
)
(
J
C
,
k
F,
T
E

E
S-
,
6E
F
d
€
U-
H
U
.
d
'a

9l

O-
a
a
-
B-

aE
A
&
,
-..ic\
QE
trgOcd
ts
$obo
cd
o<
INO()od
ilF{ef.
ie-0zF]F{
OO
I
lr
l
NA
.g
t
SHcn
4
tr
2
F{
t'
.
{0BFraUoE{
FZ1.
1=aFH*-FriF-0Izo()z-il
)r
l)oE]&ardFa-F(t\(r
i
|aaoH;r
rHri
tlz()zltF1Ci=aa
a-i0r]
^
I'
o
t
\lZE
tr

0r
Os>f
i
rr
&ZE
Er
d
,\
-
ord&tr
-.
:
.iC.
l
troo0)ac)oa
->rd
rl
*
.
z<
3
99
k
.i
-FF
^<>
x
{i
H
il
z
=
r{
<
e
xO.
E
E-
6
sF

E.
q
9
!E
E
-
5
.y
a

gc
!
g>
.
,
E
g
r
r
e
{
_r
-
:
v
FE
H
rl
a

\.
,

)
EE
E
E
i
E
gE
E
E
T
E
gE
€
g
E
H
uta
)d<
f.
l
UF
-E
l
Fr
-
:a4&1t
€cd

?l
oo
o0
.
.
=
Ei
n
o3Bs
=(
)
J
bI
)
o'
t
r
=0
)UoOt
r
xb
n
(r
6
-(
.
r
d\v
t
bE
.
g
H-
b
q
r
[r
c
l
E
il
E
;
e:
i
*
E
AS
.
E
Hr
g
;
-
ES
E
E
T
2
2oGIoEC)
(l
)
-f:
9)
r
d
E(
)
bo
.(
d

o.
E<
c!
3
C)
;E
55
'd
E
(D
-
H
E{
+J
r
-
-S.
*
^
i
'd

;
Ct
l
o-
,
-
.
-
?A

\J
-d
:
a
a)
t
u
\-
,
,

)
g
E"
t
E-
t<
-O
'c
i

Ct
l
UF,
.
Y
N
9,
_
>
2
l-
i
Fo}
i
i
i
O
H.
E
FzEO
a,Fl
-<z
r{
D
tVEF
0.
)oi<
fJ
.
gi
r&A
aIJ
.o
alL
,
,o
9,

E€
5
€-
a
A
g
Er
'-
r
'
H
-
9
0
)
sE
E
T
8
,
q
9,

E€
E
€;
-
tE
g
g
s
s
tleE1
ilFardFaB
JmO,o(n
.oOoz
a.d
.o
\O

(,
.ic{
€C)
i€
E
Lr

t-
r
'H

0)
=
bI
)
.,
5

F<
Es

Ee
co

H
d{
'
E
EE
:

E
.E

HE
E

9
ts
'
=

6J

o=
6
E
E
ts
:
;
\E
5
E
E
,
-6lc\
ao!i2oc)p,
o

j3
Y0
)
rr
.
t

6o
oo

(J
.ic\
EAJ
I
gb
E
S@
u
=.

=.
=
=
.:
j
O
c
n
L
.E

P
E€
s
Hi
S
=
9,
-
^
H
s
5
cE

E
-J

HE
g

S
,i.lN
EA
H
U'
.H
E
o>
t
1"
c
i

?
tr

x<

c)
gE

>
E
a
a]
E
,
,
r
r
B
Bx
2
b
o-
Q
H
<
H
-r
Q
)
Z
?
l
\
J.iN
'r
,

€
(L
)
o
5'

+)
(d
c
n
?a

i<
.=
o
A?
1E.
E
E
\.
/
IUo
.
E)
()
E
a.
o

ar

tr
E<E>
-A
F
-
l-
{

\-
/
J.ic{
E
tr
O
\
,1

60
O
F{

F{
7\
A
\
/
\J

l+
<

,\
t
9.
r
'
d
F?
t
r
-3
E
F-
)
0)ad>
\robo
cdnINOocd
il
ft
laEIe)azJFr
OA
l-Na
.g
I
EiFZ
HFl0FFraUoH
FZHt3aFrd*-lFf.
lF-0Izo()z:-
l&FI)orI
1&af.
lFOB!-
f
tN(r
i
iaaoH:.
lFrd
tt
'
(zIz-t]Fr-dU)
b0
troo()oc,aaI
'd
dori
A.
GIF
c,aCdBoUd,oooa+iotr
o0.
)a0.
l-
roCUaG,BoU
OHat]
,
^
40
)
\iZEEe
r
Os
>gU€
7g
=r
d
P\
,ori
iltr
+.
C
tr
C
€
80
€
Gl
t
r
R,
g
g.
E
'i

.b
0
-E
b
ru
E
ft
#
,.

l<
ou
0
a0
.
=

\
cl

S<

F{
-o

Qa
-L
E'
A

'
v
A
^
i{

\-
/

LJ
ri
i

E
-;
oa(t
)

i-
€H
tr
N.
-

O
E:
do
-o

.t
r
()
!
a
B-
H
4=
A
0)
o
()
o
5-
s
ob0E)aB
'1
,
,EUEo(l
,EI
UEoG,H
IId
l-
-
z<
3
99
k
;;
-
FF
.
i
<>
x
4;
i
tZ
E
ri
<
z
ilE(
E
;"
r
6
sF

Eq
e
k8
t
s
-
U
.=
a

ge
{
g-
E
P
r
r
e
'
i
--
t
-
:
s
-
q
-
i-
i

\J

2
->
=
o0
0
)

tr

Gl

H:
EE
E
E
€
P
#E
E
E
E
f
rI
.
lt\f
,c{?oroJrnFEN
2n<d
.
qo
<J
O
r-

Gl
OO^\
o
OL
r
\a
o
ea
O
f-
O
r.
l

\o
lh
:
tl
l
^H5
F
ri
Y
f
E
iv
l
_
{
Fe
a

cd
'1
3

t<
ALi

\_
,

_
l_
(d
H
b
g
b8

H
E
E
f,
E

r
H
I
s
O!
)
O
v
.
L
.
ea
o

17
,

H
5
O
cF

ra
\

Lr

G
f-
O

;
O
C{

e!
qE

f
s,
F
,
e
,
=

s.
q

i'
qI
-
3
9
:
g
E
E
q
$
HH
F
?
E
H
E
?
E
E
E
ra

r\
O$
(r
)
r
\
OC
,
s5
Fj
P
rn
X
(a

!.
,
d.
=
3e
rr
r
E
FR
I
ha
e&
<r
d
UF
-
fr
l
Fr
-3t
<,
4
?n
?1H
bo
o
-T
E
E

?
E
D
o,
-
'
o
.
8
.
.

E
E
E
iE

E
E
g
1
E,
E
E
E
E
E
f
l
i
5[
;
s
e
r
E
#
rE
a
g
:
e
E
g
s
r,

E
rt

H
E5

.e
E(d
t
i
(.
)

o
bo

.E
Ed0(
)
t
Bs
xo
-q

bI
)
i<
do'
t
r
=c
)
E0
)
ot
rES
\-
/

o
trotdoooU0.
)ao
li,^
r
4
.v
F
*{

't
r
aEE,
g
.-

*,
1
at
r
'
.
5
^r
-
O
t
r
o
A.
q
E
9E
H
O.
,
,

a
vl

!,
,c
t
r
=

t
E(
B
C
)
Jt
:'
r
,
I
!
J
A
E€

H
-h
.
{
-H
LBt
s
E
S
/,

o
F'
E
'
=
}
XE

$H
:E
d
.
E

5d
t4Ho.-5)tuH+'
Jc4
HC)o-1HoU+.
(-
'
!C)
.o
o
,;

A
1
=o
{
r
t
r
iv
o
a
a\

-
+.
,
v
-L
v
L&(
-
?
<
Z
acdo&
oocUou00)
-A
}E
JH
j5
d
ub
0
Ot
r
Oa
ri
o
Fz=c
-t
r
Fl
-<z
rd
D
&F.
ocdooo
fJ
.P.
t&O.
tJ
-O.
c{UJUtFH
>R
F-
-d
t
r
t-

i<
r\

=
d
V.
-
HL
-Jo
-
U
tJ
.Or
tLor
()cgC)
lizrd
I-t-aE]Fa-
Jm0)
,oC'
)
,ooQ
0
c!
o
-t
A
.ic{
a
.e
a
tu
<
.=

LJ
B<

?,
&,
p
g
r-

.t
t!
c
s
t
r
AU
)
(
gEE
:
AA
v
IP
en
,
(

E
'-
(

\,
/

()
J".
i
C{
r!A.O.
t+i.iN
5'
E
.l
Po
,
+
3z
E
EE
E
=
(d
.
=
(\
)
-F
l
v-
c)
(
)
G
l
9.
U
s
H-
8
z
EY

E
EF
A
3I

r#
J.ic\
oOao&\o-.iC\
C)
(hcd>hCdoooaoo-.iol
oacB
E}
cd
a
tr
)EgEg
?E
tr
(
o
(D
r
r
S€
'
o,
E
.-
t

A
aC.
l
c!
t'
.
cd
'(
,
odo0
)
q)

r4
.
aE
O
bI
)
cd
dEg
is
cB
EB
.iN
QE
sLr
-9acd
ts
c{
\f
,obo
cd
o<
INo)<Ocd
&F(ats
{e)azIF{
(3
4
!
lr
{
NA
.g
x
SHFz
H-aBFraUoE{
Fzrd
ts
raFHilFlE
l
t<-0IzoIz-/,Et
H)cr{&OriF0Bt
a
6l
t.
i
iaaotiHtHtlzUZl(lJCr
tle0
<t>t
EI€lRl

*rfl
ol

El
.r
l

ol
EI

EI
al

Bl
#l

sl
ol
G,
I
FI
al
cl
l
FI
ol
(!
l
FI
-f
.
a8'
o
e
-
E
Eo
.
r
=
E
E
$;
E
3
a
€E
g
E
E
EH
E
dg3
s
tt
E
O
b
kH
)
s
F
g;
[
E
E
Eb
8
E
f
gH
F
O
O
F(
-
E

co
rJ

i
o.
,
I
P
!e
#
3
q
EE
?
sE
+
)
\
'
o
E
e
3
gg
s
ri

c.
i

E
='
E

=
I
a
E
;E
"
j
O
'E

_r

go
-
E
x
ir
a

g€
f
o
=
-
-E
O'
-
;
<
u
-
,*
i

r?
E

'E
:
i
I"
Es
i

'l

gf
,
6i

HE
E

EE
E
IE
$E
E
i

li
8
EE
3

iE
A
f
l

EE
$
5E
;

EE
i
i

FE
;
Is
E

B$
i
E

E;
i
EH
g

EE
A
E

EH
E
Xr
f

tg
e
E

EE
E
q:
f
i

,i

dE
€

-=

>=
J
E-
.
EE
E

?
#g
?

iE
g
-=
d
.

;;

S
=
f
€Z
€f
;
U

f
Ei
E

co
E
AA
X

EE
i
s

EE
E
gE
E
g

E
E
x
E
:
il
:

S
E=
n
;
E
E
5
E

Ei
E
E
;E
E
i
i
g
i
a
i
i
E
E
3;
E
s
B
g
g
g
.
Eg
€
A
t
*
s

Ef

EE
t
€
iE
E
A
E
E
E
E
E
E
E
E
t
Et
I
g
e
*
*
E
i
E
E
=
u
Ef

rE
?

E
E
E
r
5g
g
3
gE
i
i
l
H
E

E
E
*E
E,E

,
c.
i

.*
i

+
,r
;

\o

r-

od
?,
,-atl
,
-
1€
)
ai
-ZE
JO
\r
r
rr

Er
O^
e
>€
rr
&ZE
l=

rd
il

\-
ard&tr
HI
FI
-c
l
()
l
sI
1
RI
alEEI
o-
l
-E
l
Gt
l
FI
-q
lol
ct
l
l
IJ
.
I
I
Elal
?,
1sl
o.
l
JIct
(t
l
l
FI
-c
lol
rS
l
€l
'r
l

*t
s{

€l
€l

El
HH
a
Hf
l
H
,f
;
I

"H
t
E
l
-IaId
-l
*
.
z<
3
99
k
FF
,
^
<>
x
4)
Z
f,
*
E
ra
<
e
&ti
{lzl
xlBI+lHI
il
i
l
x
aX

d.
l

Et
ol
o
l

o
JI
J
I
J
I-
i
l
k
l
l

r,
t
FI
F
I
F
xl8l
ilHI
xl

il
81
8
l
JI

JI
FI

HI
ha
Jd<
fr
f
UF
-t
{EE<4
4A
EI
C)
I
EIol

',
,
dl

cl
l
f,
E
l
s
(a
l
EI>l#l
rl
a<t
()
tY
ra
r
El

El

.s
f,
E
l
$
tr
tot
6.
)
t
LlOI
?l
tr
tot
a0<t
edHf
t
HE
I
Fz=e
--
F-
t<Z
Et
p
?4xF
UIUI
o'
l
(J
I
r-
lJIFI<t
UIUI
o-
l
c.
l
l
JIFI<t
UI
(J
IalUI=lFI<t
$l

\O
l
-l

-l
(a
)
l

r
l
"P
l

"l
{l

-E
l
ct
l

Gl
l
Hq
t
Lr
-
l

tJ
-
l
al
a
l
zl
z
l
UIUIal
c.
,
l
=lFI<t
r-aHilFof-
I
t-0B
<tot
-r
l
tr
t
0)
l
a0
:tot
l
-lot
l
c.
t
l
0)
Ial
}Isldc.
t
l
c.
i
l
tr
lOI
!.
1cl
lqEISl

Er
gs
|

;I
Rl

ll
:l

ll
NI
'd
l
'6
1<lol
'E
l
7l8t
alxl
ilc{
l
c.
i
l
c)
l
3l
rlol
tr
l
.s
l
tr
totul

br
El

5l
il
l
I!

tr
o
\
N
c,
O
t-
{

t-

/-
\
7\

A
\/
\J
H
^
t
O
.2
-
o
i
.F

?
tr
-iE
F-
,
IL.O+lacd
ca$C)bo
Cdor?o
oc0
il
l-
{ats
le)OzIF.
{
r-
,
1

A
lF
{Nu
)
.g
x
E
F-
l
6C

11
F{
i
FE
I
t-
{aBEra(,oEl
>lOo
9.
^
ZA
:r
l

\J
dE
>i
n
a'
P
r'
EEObbEe

E
H.
-

.-
(d
5

()
EU
O
t-
rOO
AOooon"a
(l
.
i
'

tr
O.
H
-d
oFU
b0oUl-
t3.
.
s
R6
da
aU
rna-iaJ<6
ZE
,
L
tr
oO-
q
>f
i
U€
zi
3
r.
1

8
-oHiltr
E-

e
-
i-
l

l\
)
'F

.-

+-
,
!i
-
5
8
0
.
)
r]
F
r
)
i
<
b
0
EE

5
F:

A
sE
E
e
=
:
9c
t
r
E
'
E
U
E
r
E
gr
e
i
BF
*
E
s
s
^
iz

t<

UD
=

R,
9p
:

E
I
E
B
E
Bi
*
3
*
EE
E
E
€
g
I
O
i-
P
=
Fr
(
)
"
t
r
l

o.
r
.
r
t
i
tx

NE

6
a-
cu
X
h
r
a
A
O
i
He
E
g
E
a
EE
3

6E

E
B
>l
s

o,
E
=E
d
a
gE

?;
E
o
*Y
'
e
HE
c
.
E
"
i
!r

tr

ci

'-
r

'-
OE
d
d
c
?1

A'
-
l

.E

I
Eo
.
o

!
P
.H
'E
8
9
E
3
3i
l
E
E
T
;
o
eo
i
Z
ts
l

lr

lt

>)
.9

95
i
l
.
s
E
Ee
r
g
2Z

H
or

I
€.
9

!-
t

H
E"
g
B
E
&
r
A'
9
:
t
r
E
-
E
H
E€
E

BH
H
t<0)
(dtrooocUotro,t
soO.
trclagE8E
q9
5U
,
?.9
o
d
.t
s
X
a
o
E
E
Et
EO

3E
H,
E

!i

E
€6
b
o
EI
E
E
XU
;
b
8.
E
Ef
i
E
E
BE

E
g
gH
E
i
a
EE
E
g
E
6
8
HS

H
eg3

E
!\
)
-
r
l
y
'
)
=E

o
Ef

*
'+
r
t
r
O
g
H'
o
Eg
E
Qa
a
ts
E
(-
a
k
tr
G
t
i
€
B5
sg
l
'J

,1
i^
L
Ve
$E
.-

L
IJ
E
o.
o
()
3
.
-
r
'{
5
.
9
€
*r
H

C)
Ep

S,
L'
i

hi

r-
t
i'
d
'

cl
Ii
-
8

E
ooq-
.o)'
rdt-
(ooxtdL.FE)m-d
o
't
:

"l
rf
i
f
9-LeC

'r-63
2
|-

-
'^
'
f-

f-

(J
k>
E
tr
'
l
!
:
fl
i
E
14
<
fr0r
€d\n
o
r-
t

f-
O$
ei

f-
KE
Oc
d
H8
6r
o
Gl
o
F(
-ca
O
t-
t

\O
!
EE
EO3^
s
R
oE
o
o
i
\
ea

<.

rd

oO
Lf
-

d+
r
oL
{
c
d
E
o
06

G,
il
H
8
H
f
i
t'

'z
f

tO

r-
f

Ca
l
BE
b
E
b
J'
-
.
l
O
'
-
r
O
r.
l
r

H
F(

F{

F{
H(
.
a
O
c
a
\
a
[<

-r

\O

'-
r

Cr
)
C.
l
f-\n
I
p<oJIHF
JU\J

at
t4

(\
=
r^
r

1/
)

u+
.
;,
-
F
:
-
E
=F
o
o

o'
E
iF
E
=
t
6E

lr
3
.
i
O
co
o
-
{

n
s=
8
H
E
C
^I
E
g
E

qO
I+

d
L
d
(I
)
r
\
O
cd

o
dE
N
+)
:
J-
i
r
E
O
C
r-
-
r
F
-
F
I
l
p
E=
B
=
5
F
c!
oc
aRs
oo

.d
t-
r

tr
odOO
oo

ea
c!

ea
oo

oo
\o.
!ol
e{ooC)aq)oa
taail
rdFri
te&0rJU-F-
Iz
I(dOzo.
,
,JUF
otd

e.
)
HA
-r
<

C)
6J
a

'E
H8

$
5>

5
ts
O
.

O.
i<
'
r
l
(l
)
l
ibP
U

U
<F

F
o(do()oU0.
)bo
otg

.7
.
;
l-
l

A
7o6J
2

'E
H.
E

F,
d>

5
ts
O
.

O.
Ir
l
'
l
(D
F
{

F{
bO
U

U
<F

F
tr
rRa
L/

C)
H-
e
UT
o.

l!
oCd
t<(.
)ooUobo
(dooU
O-oFzrd13aFE]
ilF
z9,
F1

U
<c2a
I
-r

(r
l
UU
JJ
UaaI&o
V)
tLo
tJ
-
,
Or
l<z.
rdF-'
(
(t
)
I
frtro()zl-
l&t.
l)oHilof.
lF0-NaNti
=4Hd,Falr
lFa
o0
6daUJololo|N
(.
)oa0)
il
(\
1olol
c.
l
oq
IJ
r€i<0.
)?'
)

.1
=
ct
)
m<
'c
-
D
C)
(
u
ii
Eoo
f,
c
a
n6!
c.
l
c!
ooao&ulol
o{c{
aC))
rda(.
)&oIoUatJ
.
,nqc.
lol
c!
ao&t<Cd
troEaC)
ru
E
Ft
(
)
6.
e
'd
goo
-
ed
6gb
Ft
r
cd
\E
ololN
qE
s<F'go6dB
.+\f
,ob0
cO
o<
Ic!oocd
l11lIIIIIIIIIIIIIIIII
il
ts
{e=a>)U)zF]F.
(
t-
{

A
tHNA
-g
x
Eict
4
F{
i
F{
t'
(aFtrRUcH
Jaotra-aFzrd
lra3rd
il
ttFrdFl-
(0IrrfroIz-&ts)oE]
llttariFO-Na
6l
e.
i
9^z=
-\
JdE
>
i.
i
#>
(D
-
-
.
A
'r
=
6

U
rE

:
g
gt
r
o
*
r
o
Q-
i

O-
t
r

(l
)

r.
:u
g
-
(J

tr

-^
'
5

hi
;;
E
H
g
aU
ia0HaJ<6
ZE
L
fL

Et
Os
>€U€
zi
r
rd
8
-ordiltr
>\

'd
tu
'
d
J5
(
)
=
A
oi
d8
E
a.
-
+,

!J

+r
,g
E
g
-A
(
a
o;
r

o)

6
:.
E
E
E
BE
EE

E
H3
.
E
g;
E
EE
;
E
2
t'
-
,
o
ts
o
.
3=
E
E,
:

O
OE
€
€€
q=
=
L
=
=
ir

ir
ts
a
E
g
a
jr
3

Jr
3
o(
J

o(
)
tr
o

c
o
Oh

Oi
r
_4
.
E(
n
=
u
)
,E
f
r

a
€#
.
0
sq
H

sq
.
-
,
8
r=
i
F
]
g
l
f
r
gE
E

gE
E
BE

E
gE

3
E=

E
5T

E
os
,
:

5i
q
.
-
oA
*

cl
U
l
L

O
5E
=

5E
=

P
oo
(a
-
,
.
o))<cUtiooxEFEca5c
)
'o

"i
rS
f
E-IGl

'!
ts
33
r
.
E-
'
-
-
fr

fr

(J
<!
F
tr
'
i
!
1
{*
E
r-
l

<
fr0r
C)

'c
t
)
E
E
'(

K5
S
fi

Bl

3?
e{

-(
-

$
5
Ft
o
qF

oo
:

ot
r
l
=
\O

eo
+

.O
'
9

e7
Lr

f-

f\

C
.^

,-
f

LJ
o
o
L
cu
l
i

EU
a
O
O
O
O-

O
cd
p
#
il

q
=t

HE

S
fi
t
r
H
^r

E
.6
r
.
9

'O

ut
O

ta
1

ca
i
-
,
h
0
a
,"
6

==
i

=
68
=
rJ

OO

-6

-
6q
l
.
x
l

r
Oe
l
o
6
,i
,

tf
i
i
\

FF

-7
E

ca

.+
c
c
.
O
I
O!
f
,

ca
o

ce

y
E
O
(
rr
O
t-
c
i
C
-
-
.
O
-
i
-
,
G
l
r
A
(
.
r
l
Q
-
'o
Al-
{G,
(t-
{

'-
oF
ca

<,
f.

l-
Ok
g>
O
il

H8
l-

'7
t

\O
t!
Ao
E6
l-
a
-
A
/
.
\P
;5

F
-
-E

-
$c!?O.o
"q
+
ct

tr
l
c.
i

F
oi

5
tr

c.
l
.9
?
ti

o.
"x
3
8L
u
a?
?t
,&r{FrdFail
AHjUFTFJz
EG
.
A
(n

-Y
.
g
(n
[
,

c!

tr
--
o
c
B
'-
#
,
,
g
o
EH

c-

E
.e

A
Cu
.
a
,

=
F
E
;
A
9'

'E

qr

Fr
-
-
-
t
=E

E
e
n.
,
,
,

5e
.
E
a
tr

E
v
o
lx
s
i
f
r
-t
O

7,
,
9
.p

I
*
E
a
E!
:
*
t
E
.=
c
B
E
S
'
E
g
s
=
6
gE
s
E
E
=
=
o-

q
'=
\
:
i
.
j
y
$*

p
p
E8
s
8
E
p
9s
Jl-
-
'
=s
hE
aP
-
)
.d
t
r
E
E
$s
o
ct
-
d
'
5
,2
8

gE
N
7)
-

u1

E'
t
r
\-
.
-
(
d
J
J
o
)
fr

r-
r

?.
F
:u

x
o
.2

f'
E
is

E
aE
E
E?

s
E
€g
;
'E
F

A
E
Ek
:
=
=(
n

E
q
:=

d
I
gF
I

$
E
E,
8
E
tuoooUc)o0
z9,
?e
:E
N>
;
-JEE
J

Aai
I
tJ
.
o-
i5ard&FOrdFaE
Q(.
)
an
ti

V)
,o
!
)
(D
L
.
og
dqHB
0)

(a
)
Lr
'
F
c.
t
u9
Or

.O
a?
oqo.
!
c.
l
c{
tJ
.

tr

O\
A
cd
o
l-
{

-a
r\

A
v
LJ

-r

lt
Q
.s
'
d
F?
t
r
-tE
Ft
trOJacd
\n\f
,Ooo
63
O-
,
IGI

,
EIotr()cd
il
ts
lel.
ra-U)zF]Fr
t-
{

0
I
lr
i
NA
-g
I
E
r-
l
Fz
H-aBFrAlr
lUcE-
{
-lao0.alraFZrd=2Frin-FriFt-aI
frfro(,z!r*-=pordrl
IIOr{Fo-6l
aN(^
.
i
9^z=
-\
JdE
>
i'
r
a'
t<OO
AOoo
()
n
a-^4
0
+i
'

c
O.
H
-l
oFU
LOO
At
)8A
"T
,
+i
'

c
o.
H
-E
O
F-
.
U
s
'd

'E
EObbEe

E
H.
-
-
cd
-
d

o
EU
O
?t
)-aJ<6
ZE
,
tr
t
r
Os
>f
r
U€
zi
j
rd
8
-afr
l&tr
r
o*ot-
rko
i
O.
€H
..
-
,

C)
O'
.
5
tr
i
n
EE8g
ep
B
Hl
i
Oc
g
Q
t-
r
-i
aaF
.q
b
qc
_c
q

o
LI
J

AO
o=

.2
E
Ei

-e
E
$
s
5
E
Ea
IE

E
E€

EA
tr
=
E

Eo
E
E
E
[*

iE
g
E
:=
;
E

EE
E
E
;t
*

fi
$
E
g
E€
E
E
,

E;
I
E
&E
E
E

EE
E
*
gatr
(
d
E
$,
a.
i
l
-
O
=
a*
b.
'
[

*
o.
l
t
r
t
s
4
dFLA
t
r
ro5
3
eo
ts
O
t
r
)t
4
a
\
+-
<

v
oS
g
AO
E

tr
tr

o'
F
E
o-
O
r
e.
g
t.
E

cn
#r

E.
El

..
.
o

E
s8

g
a
O
r-
<

^'
A
EE
E
E
-rJtIet
l

''
l
l-
l
63
2
-
-'
^
'
fi
k
(
J<!
F
E(

'l

11
{*
E
r.
l

<
&0r
b
.
3A
'-
r
o

E
P
g
H5

H
9N

lQ
c'
l

f-

Lr
^
r

rO

';

C
=!

:.
,
:

.-
,

N
b
c<
+
=
=
cF

€
-
or
A
8:

ea
<
'

.:
Y

-E
Ai
r

5:

=r
,

=
il

;?

;5

HE

E
#E
t
r
g
He
-

E!

!*
S

;
ln
g
d
iE
$

;E

EE
E

8
t?
€
t-

I-

CU
f
\

-.
O

-{
-
r
(
g

f;

ca

Q-
!
E
E
E8
i=
i
=
R
I

eE
BN
s
s
=
;

$E
$E
S
i
E
E
B
-

E
$g
f
,
*.
"
E
E
:
E
g
S

I
ba
s
)-
l
C
)
O
-
r
O
'
-

(d
t
x
l

r1
.
1

CC
{
O
O
,,
r
,

tf
i

(\

-
F
F
7
t
ca

$
cO

\O
pt
O
O
c
A
O
c
a

y
E
O
ra

t-
r
O
Fe
O
.
O
-
.
O
-
i
-
,
O

Vt

eA

Q-
E63
!oo\Tx
oh
rr

Cr
l
:t
sHo
F{
Oeo
O
-r

\O
?nil
rdFE]
Iz<il0r
tlU-FJz
e(
n
*(
)
r
.-
l
c!
asq
$
tr

F
E5
oF
E
o
!.

(.
)

bb
^
H
E
a
g
:s

gf
l
l
3
n
E
E
$
$
,E
g
E
e
,
E
?
g
=
5
sE
.
g
E
E
=
1
o.

o_

='
.
)
.
=
t
-
.
=

q
$*

p
p
ss
s
a
E
p
cB
a
-f
,
o
|
.t-
c\
qC)
c
o
E
8
g
cl
b
F
H?
'E
c
r
o
o
=
E
g
-8

SO
E
e
E:

€
H
f,
l
f
I
ES

U
Fb

.E
-
e
'
E
g
iz

=
3
f
Et
E
F<

=
=
E-
o

.o

o)
St
r

P
P
E8
E
€
,9cdoO-JUF
9,
tUae
z=
a
I
IJ
-
,
O-
,
Ir
.
,
,
OrZ,
33
E
E
=4E]&FaE]FU)-
vc!
a
Uan

Y
-{
)
tH
-
^x
i
o
u
3&
i'

\.
,

t-
5'
B

E
!r

'
F-
r
fo
r
g
FE
.
q
t4

6)
V
l-
'
=
r
a9
=
m
ai
O-
,

=
cd
>f
i

a
\a
€-
)U
qc\
lclN
atroc6oooF,;o
fJ
.
,O-

,;
1)
.d
Oa
F{

C)
ololol
a-
'
o()
tn
(E0)dtuoo".
i
C.
l
c!
QE
F4Hga63
ts
\o\f
,Obo
Cd
O-
.
.
INO()cd
il>)azF1F{
F,
{

A
It
s
i
NA
-g
x
A
)-
l
cl

4Hi
,HE-
{0BFraUcH
JOoOradA-\L2LC
ts2,Frd*,1Ft.
lF-aIErho(JzH&--lot4&ardFa-o!N6l
(,
^
z=
-
L.
/
dE>i
a
#>
bo
.F
oUIgEE
b0oUEc
)
:-
oEE
?l
.H5
p.
g
j.
=

t!
LU
-E[
!
E:

H
^o

c,
P.
=

a
fl
f
i

I
b
eE
d€

E
rA

\J
6
b-
9
.=

Be
8:
3
^o

cd
O.
=

a
€f
i

I
O-aJ<6
zE
fr
oO^
q
>gU€
zi
:
rd
8
-oE]&Ir
i
aaR,
cr
t
tr€C)a(Ua(.
)
tioo0)dot{otrGI
tro()()
(g
tJ
J
b0
cdaFcdo
'E

c)
'=
E
=(
ga9
ir

c)
b€
eAoP
-
sr
E
Bt
s
oc
)
tr
p
c,

-q
,o
h
-0
)
-a
>
H0
)
:E
E
.doF
.g

,6
9.
,

E
(E
c
u
8,
9
,O
L
+.

0)
or
J
4
Hs
E.
c
a(
)
G,
E
Bt
V
^t
r
.
eE
e
FH
t
r
tE
E<E
.
g
,\
/

A
*1
Ee
e
€5
8
rf
r

'E
"

€
J
^(
D

i
&t
r
e
Lj

H
E
E<
tl
r

(n

t\
/
,\
E:.
s
o
Eo
'
A

-c
'=
O
o
X
O.
c
,
=E

o
E5
t
r
uo
6
tr

f
,i
.X
o
o
)
Ed
B
JA
EEE
E
h
A
G,
-E

.-
'
E
E
bE
E
io
.
?
F-
F
'
.c
t

+
TE

E
EaIGt

-t-33
r
--
'
fr
L
L
J
k>
E
E-
l
H
{z
"
E
r{
<
frOr
(.
l.f
,O6t<otfOo\
c.
l

t+
f-

f-
(n

\a
lto.
p
r
oo
J
-.
1
tt
lu

tr
l
FF
CO5S
€
C)
e
e
^
E
F
5-
l
!
,^
.
8

oo
^
'
i
5
8r

E;
€
3,
-

c'
o
.
=
sb

38
6
ra

o
h
a.
.
3
e.
5
,
-
,
E
-
q
R
3:
5
:
E
s
rr
l
r

-
l\

-
-O

rO
F=
5
!
a
E
O$Oo\
e{
s
s
f-

f-

f-
tn

t,
1

t.
)
tt
t
O.
,

Pr

O.
oo
o
JJ
J
tt
r
rr
l

El

tr
l
FF
F
dvXc
{
H
o9
!R
F

i
C!
f
,
o
O
:
"A
f
-
g
q
J
bE

En
o
cg
o
-
F{
-
e
O

!l
3N
8

H
.o

6'
o

?o
Al
<
d
Q
)
f
-
cU

O
6d
E
e
.
{
-<
O
,
-
<
E
o
o
Fi
-
-
E
t
r
t
3B
=
5
E
?a*-riFt.
l
FizilOr
t]U-FJz
oco

.,
a
EE
E.
t
s
o.
zE8
()
t
r
bo
o
<U
a()
a9

'E
E8

F,
.g
'
>

5
J
p.
,
,

o.
o.
r
J

J
gU

U
t:
-
F

F
oGl
a
,
r
3r
H
-
\
=
tJ
-

.t
s
be
:
OI
:
t
-r

-'
l
;
6.
t
s
u
u.
;
3
E
9'
a
q,

:-

a)
TS
s
eO
ao
a'
=
L
!q
d
6p
0
O.

O.
JJUU
FF
z9,
1e
'!
E
^,
-
:
!.
!
F
J
I-
I

A
ad
7lt/
?3
3

3
E3
3
E
u
33
3
3
3
EB
B
g
*
=aH&FardFaF
ao
td
(hO&aOrN.i
c.
l
c\
aOoL<C)
.o-oP()aca.lol
c!
tJ
-

tr

O\
A
co
o
r-
()
o
.
X
o
.2
'
d
F?
t
r
--
EF
-
ood>
f-.f
,
(.
)b0
cOOrINo()oo
oo
.+obo
CO
o<
INotroc0
ilFIa!laJazF]F{
F{

O
I
lr
l
6l
|
4
)
.g
x
E
)-
l
cd
4
F{

i,rcE{aFF=aUo3
Jaoera-aFZri=aFE1
ilFrdF!(0IFr
troIzlr
lilFi)ofr
l&ardFa-t\
aNc.
i
Ea
dE>i
n
a'
I.=

o)
tl
roc
Q
9q
ir
<
(r
r

O-
o;
_

o
I4
r

r-
!
Bg

E
Fz
o
.
.HL6
bo
.
y
^q
1
J
-
.F
!

l\
l
LU
-
rA
\
J
Vs
br
r
.A

Rr

o)
Et

a
^q

G,
A.

E
c'
)
Fr
f
i

g
b0
't
r
oUEG
)
l-
oEE
oaSiB5
E8
'!
!

o
E
g
e
E
Bg
la
)
a-(aJ<6
ZE
I
,\
cO.
q
>f
i
U€
zi
:
rd
8
-aEl&tr
ao'8
J&8
tr
B
!f

Li
E0
)
ri
i
A
(.
l
o
a
'9
EEH
6a
)Oa5
C)o0
rd)(n+rosC)
CU
pso(d
rI
]
.9
3
r
3g
s'
E

E'
=
r-
l
E
g
<
E
F
E'
=

95
E
.E

E,
H
a:
i

AJ
-
.;

E=
E
.O
E

E
co
E
'{
E

E
l-
a

r\

tF
a

u
BE
T

$
()
7
-
.E
EE
.
E
o,
t
i

?-
3'
E

E
g
E
g;

E
()a0€)a+rooCdpoCI
,
EI
C)
.=
o
GIts
o
o'
t
r
a6
(D
-
F.
E
EE
O.

tr
i
EO
ad
.
o
At
l
-o
EEB
UE
:!

Cl
l
E0
)oa
8r
e
c'
J

cU

!
tl
b
:e
E
Et
5
.
g
rf
i
t
s
#
ro/tsGl

't-38
2
--
'
Ei

fi

lJ
<!
F
tr

r-
l

!'
:
f,
i
=
rI
]
<
xCr
ta
)Hs
bF
oE
oc
,
ca
O
uNOO
r-
Y
ra
X
ra
v
O.
=
3e
I!
HFC
d
G.
E
sE
(
d
(J
-o\
t
u
v
-!
^

ls
$
S
33

;6
N
s
c
c
aa
^
r
E
S
E
il
*
*
$
=
8
H
f
i
^l
^
l
^
t
O
-
.
t
O
'
O
c
a
aa
a

E
E
5
F
5
JJ
J
a
:
-
3
.
-
a
dd
F
r
g
E
a
;
i
l
[.
.
t
q
t
-
O
O
-
\
O
-
(
.
.
)
(.
)$Oo\
t-
{o
,_
.
Ot
a
=f
,

o\
OO
O\

O\
\.
/

\/
c!
.
+
$
f-

f-

f-
\.
)

(a

\a
ll
tOr

Or

Oi
oo
o
Fl

Fl

Fl
tt
r
El

tI
]

tu
FF
F
-=
r.
)
-
-
I
E=
s
O.

-O
-
,
l-
(

\a

f-

X
€n
=
i
S
-
AA
T
;

S
R
N\
f
.
+
i
O
E
o
o
EE
E
a
8

EE
^'
^
t

^t
.
-
r
€
O

cl
33
3
E
S
H
f
i
dd
r
I
r
E
S
E
:
t-
t
-
t
-
-
r
O
f
i
r
O
.d
EF
{

E
cd
o

o
3R

SR
o$

oa
N
ca

f-

rg

oO
bP

EE
OE

OE
il
H
8

Hf
i
^,
'

.O

.O

rg

er
t
6E
b

Eb
J-
A
-
-
A
r.
l
\
F
-
f
:
F
H
He
a
O
!
+
e
a
(
n
t-
F
\
O
f
-
-
(
r
l
?nil
rd
I-
{
rdraa&trIU-t-Jz
acdC)H&
.9Fa
F
)
-H
AE*

5
Q5
.
"

e
'E
5,
E
B
E
g

S
+r

?J

?n
E
PT
€
r

3
$5
g
F
P

p
.9(d

,^
.
lJ

tJ
<
E
9+
a
8g
i
u.
=
.
q
ts

8J
nF
o
.
)
TS
f
i
otE
t

.-
.
g;
F

"a
FE

A
'g
5s
g
s

g
ts

8J
o
-

o-
6
F
or
J

J
TE
#
P

P
otU

..
HAEo6J
2

'E
Hf
i

$
d>

5
ts
O
.

O.
t<
l

1
(D

)-
{

F{
OO
U

U
<F

F
z9,
**
()
d
\J

-l
-Lt-
(

L;
(t
r
H
a
3.
o
f,

s€

E
tr
-
'
E

9?
gS
E
E
VZFIaoa
vzF;&c0
aa
_
^
?s
t
3
P-
-
^
3
Eo
u
H
o=
=
>
E(aHilF.
lF-
{OHFaB
t)o
.Fcai-
(C)
.o.oPoa,ocA.iole\
C)o0E)aMzFIanV)+".
io!N
aobo€2avzFI&a.r
;
".
i
e.
l
c{
rnoOOaO€oiUtioa0)naAr
\o.iolN
€ooa0)dt-
-.iol
c{
otOV)C)&o<
,
.i
c.
l
c{
.dooa()&O,
.iqc!
qE
trgOcd
tso
il
l=
{aEIe)azF]F.
(
F{
A
lE
t
NA
.a
l
.
]
6g

4l
Fi
r{HaBFraUcE-
(
J(ho!rO-oFzrd
lt
raFII
]&Fri!aI
fr
fr
(oIzriIH)crdiloklFa-6l
a
6l
c.
i
9^Z=
-
\-
,
dE>i
n
#>
s
$-
^
E

H
B
E
H'
g

!.
U
g{
E
E
E
E
f
l
HP
p.
'
t
r
ao
ll
,€'
=
cl
x
fi
:
C6actBoU
clafi
lBEoU
G,aCdBoU
(BaCdBoU
ia0-a-]<6
ZE
,
I
tr
aOs
>f
i
U€
zt
:
rr
]

8
-ordil
I
B}
|i
(
)g,
i
o,
2
a0
'd
E
>\

rr
-
J
Eb
Lt
<€5
oc
t
=G
l
tr
t
r
Eo
al
<sE
^
.i
{

.F
a

'-
-
-
2.
E
t
s
+8
E
F
2)

(J
EJ8.
o
H
EE
g
Bo
EE
()

rJ
-
'
J
'=
a
L_0)
5
q
)
€u
E
EE
E
B
}E
H
9o
v.
l
a
\
!,

,-

\l
/
'E
,
i

H.
E
-i
.
g
,r
i
s
:
Fi
l
P
il

q.
-

t'
3'
,
0
;
EE
>
fi

$=
0.
)
(.
-
.

O
-O

.i
.
i
o\

,-
r
\-
/

(,
)
tr
9FA
€E&o
oo
cl

6
o-
q
-g
g
,
;
l\
r
a
.
-
=-
o

a
cd

sv
.
E
a
ao
;
i
cl
t
r
E
ii
A
LO.
E
€
-
'q
F
q
)
€E
B
A:
.
*t
a
G
l
Et
r
a
qE
c
)
rf
f
€

I
aa(gCd
t<€oatrclaoot<0)
liCBoooGI
t!
d-c)
OJ
4
-t
r

!q
{-
J

v
!,

tr
ct
(
)
c.
l

'o

.E
-E
O
C
'
€s
E
oo
-
tr
:

E
E.
E
E
a
E
5
oE

tr
E
?,
3
:B
H
B'
E

e
'=

tr
:
E

a
E
Et
s

9
EE
E
E
t5
9
E
'f
r
€
E
e
-l-
r0'
)
or
J
'q
(
q
.a
-
'
,

-
!,

t<
CU

C)
ot
.
E
-E
O
C
I
'
'!
,

+-
,

t,
bE

E
oo
-
Eo

b
Fr
i
E6
H
lv
.
-
-a
ti

J
o=

tr
E
?,
3
\,
/

o
ii
E
H
9'
E

o
t-
{

l\
.

s1
'=

tr
l
i
5

a
t\
J

.;
J

--

.H
E
Et
s

E
EE
E
E
r6
g
E
,S
.
g
E
E
-IJaIGl

'!-33
2
--
^
Er

fr

(J
k>
F
E(

'l

!1
f,
*
E
hl
<
&A.
.?E
oH
a
'
3R
F
'
i
€
o$
o
o
^
z
H
!!
E
;
E
iI
;
X

E
il
e
E
s

Fg
JE
:
E

8R
a
d
c
oE
s
J-
r
n
r
E
C
C
F]
A
5
E
E
E
t-
-
\
O
-
\
-
,
C
g
c\N?O.o
,JHe
rn
€
t-
I
g^
1
?i
l
gI
HE

L
=R
9E
:

5F
n'
=
E

oE
E:
5
6

5
E
ir

=
oF

ca
o
ir
=
v
t
r
r
-
G
l
o:
o

cs

oo
il

H
ES

5
5
h:
a
E
gE

!
!
a
=
rt

rO
O
O
O

EJ
\
r
rl
r
;
s
i
l
8
$

iE
t-
-
O
O
C
A
C
O
f
-

t<

CU
'(
,

E
F(
g
-CO
O
(r
1
O
r
O
6
-r
\
c
\
r
\
O$
c
C
6
r
;
O
eO
f
_
.
6
O
O
H
bE

E:
U
O
al
6

cl
il
*
8
H
8
H
f
i
^t
^
t

-6
r
O
'
6
e
a
od

6
a
6
E
6
JJ
A
-
O
-
O
dF
i
E
;
E
;
6
t-

t-

ro

-
rf
r
c.
{
f-(a
IO.3t
q.
tF
c\
f-r.
l
t
A.
roJtr!F
ia0ilrdFrdEa&nr
F]Ut-F:.
]z
FAFi
o
Xo

J4

'Z
1f
;

F,
8>

5
'E

o.

o-
tp

p
t<cootuc)oU0)bo
Cnd()
il
o!d

-,
HA
F(
)
(.
)

c
()
r
i
ltsUO
C)
F
{
bp
u
<F
.EF-
?
,
r-
a
=*

,J
A-
9

e
'=
B
eE
E

$
a.
=
E
>

6
-=
-
-
^
'
r
.
\
5
F.
=
J

J
tr
s

_s
P

P
,uC)
(,
)oU0)bo
otco()=
ta
)
Oo
l
,p
NE.
i
bo
N
-9
Fl

.r
HE
=a
(D
,
\5s
o.
.
-E
r
J
3Ee'
a
U
o.
,
,3
mo
a0oz
-lU
JU
c0a
tle14
ilFahlF0-
C)
'(
,
c)
tdC)?$
b0

J4
GO
tr
c
d
at
rOD
Oolol
C.
l
c{
t)aI!O.nc.
l
ol6l
c\
Et&oatdH-
r-
a

.H
\J
^
=
>.
(
J
bE

bo
bO

'.
-
r

tr
r-
S
\
)
EE
.
e
-a
-
\r
/

.-

-
-7

H-
o
a<

F
'r
FJ
!r

CB

'l
F!
r
-
,t
)
!
-E.
,
Q

E
Al
)

cd
c.
i
C.
l
o!
c.
l
ol
0.
)oaq)&e.
;ololo|N
c)U)
cd
tst,)o0)cr
JU+o.
!
o'
!
c.
lN
a
,.
o
o.t
)0)acdBaJU.'
r
;
o{
oJc.
l
c{
a-o0.
)oacd>=oama\C
j
ol
C.
l
olN.
IL

tr
O
\
/a

03
O
l-
{

-r
7\

A
\J
\J

l*
r

(\
l
O.
3

o
F?
t
r
-3EhC)acd
O.
$C)bo
(dO.tC!O()
cO
ilFTats
{eJazF]F{
t-
{

A
It
s
t
NA
.g
t
EF
I
cl

4
t-
{

iF{
F'
taBFraUcF{
Iao0.U)-aFzrI
]EraFH&FriF-aI
trfroIz-&-)oEl&0rdFaBNaNt.
i
2aEE
>
i'
i
3>
claCUB5oU
?1-o
.F
l
!,E
a
hU
)

H
u'
F

<
,q
<U
O
Y
BI
FI
8t
FI
ttFI
|.
)0:ra.l<6
ze
Li
l*
oO.
c
>f
r
U€
z;
:
rd
8
-ordilfr
aaGI
CUti€0)aEcdaotrotioJ1c,
tocl
t4
'1
,
C)cl
c)
liFtoGImocBE]
xl-
lolEIol
EI
tr
l
Gl
ldGl
lOIEI
?l
tr
l
(D
l

lr
t
q*
t
Et

$t
HIFI
-c
lol
sl
l
#tEI
-c
l
()
I
fi
t
1t-
.,
1
cd

't
E63
s
-
ts
'
^
'
f-

Er

L,
<>
F
tr

'l

!'
:
t
z'
E
ra
<
fr0r
rdA
EHHO
ra
o
H
o
5s
-
_
R
ca
r
-

:o
o

o
:E
E
;

H
o
G,

_.

G'

\.
/
s=
8
H
f
i

*
aE
E
;
!

a
=-
=
Fr
E
S
;
;

d
FJ
6
-
c
.
i

F
/t<
s
No
c{

e{
E
\a

^t
a

d
I
'-
\

,
t4
P.
,
.

C
O.
'
.

F
3
E3
E
l.
F
l
l
A
El

,t

El
r
x
FU
F
V
;l

sr

sr
ll
i
3
g
f
l
?r
)
ilr{t-
lE
l
tteilFr
'.
1Ul-
iFt]z
.9I
..
,
^
E
.^
.
i

IE
oJ
i

tr

o.
H-
E
$

ts
o>
o

.=
Eq
q

6
5=
J
-
J

t
bO
U

U
O
<F
F

U
0)bo
qe
,
il
s
;
sl

El
E
|
3
H
rl

rl

i
ll

l|
i
zP,E;
I
OA.
tr)a
sbo=
Is
vr
\
v
F
-
.o
3
H
.
8
Oc
o
€
E
i:

a4
al<t
o-
tul=tFI<t
O\
l
\O
l
r)
l
"l*l
cE
l
ql
al
o.
<
l
al<l
o-
l
ul=tFI<l
EraHilF0rdF-0B
OO.)af-o.
lolol
c!
0)acB>o(66)
trF()co()ooda.
!ot
c\
l
c\
EI
tr
l
't
r
]
co
l
IlEI
()
l
alrlolot
:tol
l
nt
l
EIol
:l
'E
l7lOIOI
aldl?l
-l
cq
l
xt
a3I
€lBI
dt
3t

3l
rr
l

tl
gt

Idt
oi
l
e.
t
l
ot
l
e.
i
l
.r
l
o{
l
QE
trgacdB
(.
)obo
cdO.Ie{OocO
il
It
t
aaIt
la)OzF]Fr
t-
,
{

A
I
lr
{
6l
1
/
)
sx
Er
.
I
c{
4
Fr
2
F{
t'
{U)FFrRUot'
{
rlOAvAHT2oFzrc=aFtI
]*HFHF-aI
trfroIz-*EIH)oIiFl
ttardFU)-el
6l
a
6l
9^ZA
-vdE
>i
n
a'
btEI
brEI
iaO-laJ<6
ZE
L
fr
r

O
O-
c
>E
Q€zi
:
rd
8
-ordilfr
{lzl
tr
lol
+r
l
lE
I
;tol
(l
lol
od;l
't
r
!
olEI

EI
;l

$
5I

EI
El

€l
EI

EI
tl

Bl
gl

*l
Ht
r
l
al

,D
l
Llol
.a
-
r
l
EI
-c
l
()
l
(B
l
ol
adeI
.e
l
t-
lol
EIsl

El
EI

Hl
HA
EI

EI
tl

el
Hk
l
al

.o
l
,.
E
lEl

;t
Ht

HI
EI

?
EI

fr
I
fl
H
s
G)
t
a0
EI

fJ
5I

FI
El

€l
3l

El
EI

EI
Et

H
q-
.
1

-t
r
|
ol

ol
a.
r
l

ol
Bf
r
I
8l

)l
El
E
l

a
Ll€lEl

;l
il
H
l
il
a
!|
f
l
fl
H
s
l-
l
-o
lE|
;
I
il
l

=l
E|
?
El

nl
$H
s
L.
l
-o
l
El

*r
El

#l
gl

3l
Et

SI
il
e
l
E|
f
,
$H
s
ti
l€lEl

;t
HI
H
I
E|
?
El

nl
fl
H
s
-(r
J
tIcl

-r-
33
2
--
(
'
^
fr
f
r
t<>
F
(J
H
r*
E
ri
<
&Or
<tzl
EIct
((
l
l
.r
J

ot
-l

l-
l
Ol

\f
l
"a
i
l

l.
-
l
sl

nd
l
I|
i
l
f
,
g
H
=l
E
l

Hl
'o
t
ct
ft
l
l
.a
l

or
-l

f-
l
ol

+l
cd

f-
r-
l

€1
Il
f
l
E
]
Hl

=l
E
l
{lzl
xt
o-
l
3lHI
<tzl
slzl
{lzl
<tZI
v.(r
)*ts
l
rdFfE
l
15a&0rJUt.
lFJZ
EIal
;1ol
cl0)
lHl

sr
-o
l

=l
al

dl
ss
l
st

Et
'l

.e
i
9l

B
vI
g
t
al

;l
Et

it
EI

*'
ol
aYI
or
l
c.
t
l
-l-o
l
cl
l
FI
\_
{
si

El

El
Hr
l
e
l
ct
l
l
al
tr
r
lol
EIFI
EI

TI
"E
l

sl
;l

ql
sE
t
c)
I
o0EIEIol
tr
l
VI
r-
lol
!.
1EIolEI
()
l
tr
l
ol
l,
)
I
tr
l
ol
"l
tr
lol
a0<I
(.
)
t
o0EI
'lol
tr
l
VIalEIol
tr
lot
ol
G)
i
b0
€lot=lCI
tr
l
vlbl
EI
tr
lol
el
0)
to[
€I0)
t
}ICI
ct
vt
r-
lolEIot
tr
l
c)
I
ol
c)
t
b0
'o
l
0.
)
l
EIgl
r-
lol
-.
tEIol
tr
l
()
Iul
z9,
.?
T
tY

;.
-J
ti
l
"

A
ac
U
al<t
o'
l
c-
i
JIFI<t
al
rlUI
-l
LJ
!FI<t
al<!
o-
l
ul=lFI<t
gE
t
'6
1

ul
El
;
t
ul

ul
=l

sl
<l

:E
l
gE
t
'6
1

6l
Et
;
t
ul

c-
,
,
1
il
*
l
UI
JIFI<t
UI=lFI<t
UI=lFI<t
UI=l
<t
l(aE]
?,
r
l
HFU)
rdFaB
()
l
't
r
l
3IGt
l
tJ
-
l
Or
l
al3l€l

I
(r
t
l

=l
6l

lt
.
l
dt
BIHI>l
()
I
<l
't
r
,
1fl

=,
El

€l
:l

"l
:l
l

I
<t
o-
l
r!
l
:c
l
YIol
tr
lo-
l?l

Hl
il
=
l
ttot
!)
lcl
l
>t6l
il

*r
:E
I

UI
*t

I
ooEIol
'E
l
ol
>t
-r
l

ol
qs
l
HI
r!
t
o-
l
o-
l
€t
"r
l
at
l
EIalol
TI<Ial
alJI-l
.1
1
a.
t
l
EIotalxalolot8l

Et
EI

.E
I
3s
l
sl
er
l
c.
i
l
".
t
l
c\
t
l
or
l
ot
l
ot
l
or
l
o{o{
ot
l
or
l
ol
l
or
l
ol
l
or
l
ot
l
e.
i
l
LJ
-
t
r
6
/a

cl
O
l-
a

r<
Uo
.
X
o.
e
'
d
F?
t
r
-r

Ft
;-
.cd

f-
)
orr
)
cd>
\n0)bo
(oOrIC.
lO()cd
il
l-
{al.
la-azF]
tr
r-
,
(

A
tHNA
.g
x
Ei
cl

4
t-
{

i,
rdHaFFraUoF{
IOonrahtoFzfr
l=2.Fr{&FriFlr
taI
trtroIz-il
ts
l)cE]
ilOHFa-NaNt-
i
9^ZA
:<

\r
,
dEEi
i
#>
EI
FI
raa-aJ<6
zE
I
tr
cO.
q
>.
3
U€
z+
:
rd
8
-ordil
tu
br
Fr
lEl
s
EI

rI
fl
B
br
tr
lE|
H
EI

€I
EI

EI
EI

El
aJ

.9
1
EI

EI
flal
.E
t
:tot
!.
1cr
i
l
El

a
EI

EI
gg
QT

(J
I
HI

EI
sl

El
EI
(t
)
t
EI
tr
l
(.
)
Ia[
,E
l
sl
-c
lol
cl
l
Ir
.
l
l
ro-Icl

't-
53
8
F(
-
h
'
Er

fr

lJ
<!
F
tr
F
l
H
ri
E
ri
<
ile(
EI
tr
ldl

or
nl

ot

r-
l
-l

c-
l

Nl
ol
+
l

€l
rl
i
|
E
|
=
l
f
l
€t
tr
l
(E
l
nl

o
-l

f\
ol

r
eo
l

f-
r-
l

!
il
t

;l
s
EI

?l
:
l
Fl

=l
=
Fl

_l

rO
!lEI
1AailElFf.
1Fia/FrJUlr
lFFIz
$
=l

H
n3
f
l
E
l
^1
,
c,
I
TI
rN
lol
-1-o
l
cl
lU
tr
r

al
sl

El
El

3l
<l

Fl
6tolLIol
alEI
a0<t
-1
,
ct
l
YI
6r
l
sl
s$
l
z9,
HX
I
ca
l
cr
l
rr
l
"p
l
}1
t
tr
l€l

Er
HI

Et
d,<
lqE
t
El
E
l
al

-l
2l

+l
UI=IFI<t
0)
t
3r
l
alol
UIul=lFI<t
=aHilFaE]FOB
El
g
El
g
=l

I
EIol
:l
;
l
Et
E
t
il
-
l
tr
tol
FI
tc
l
C)
I
+a
l
cr
l
l
ctEl
E
l
BI

5I
ol
'
l
Il
t
tr
tot
;l

El
da
l
8l

El
BE
|
g
|
fl
l
t
ot
l
ot
l
o{o{
ot
l
ot
l
or
l
ot
l
QE
trgad
c\
\nob0
6d
o<
tNOF()cd
il
ts
lets
{z-azjFr
F{
O
I
lr
l
Nu
)
.a
l
cg

41
Fr
i
HHaFtraUcF{
JaAvFraHoF-zrdaFri*-FriFt.
lat
latro()zts
l&H)oH&arI
]FaBqN6l
7l\J
Az^
-v
,dE
>i
n
3>
.o

e.
i
.-
_

CO
gg
E

3
gr
.
q

H
b
Ei
E

s
h
o=

=
o
-
5o
F

5
-
U
E-
=

9
^
*,
i$
?

a
=
E
E
Fe

o
.X
t
;

rj

?
?
Tg
;

$
E
P
E:
:

n
9
6'
s

^
{-
r
-

(i

(\
t

€
=
!;
i

E
.E

E
tF
f

,r
i

8
E
E9
E

8
E
q
EE
E

E
€
i
*!
t

$
g=
a
€6
8

o
o'
=
=u
.
l

H
5!
;
Jv
J
Eo
A

c.
i

E=
.
t
r
li
i

N
ts
E

E
EB
:

=
AH
=
1
fi
s
;

Ei

,$
E
3
g
it
s

ga

:E

It
?
BE
e

H3

g*
A
A
lE
E

i€

s:
E

r
FE
E

iE

EB
=
i
9E
H
IE
j

oo

.s

EX
'
.
:
EE
E

fi
;

U
1=
;
t=

a
cg

,.
.
'
-
O

tr

tr
-

=
E€
i
'
:
X

iE
$
€
Fa
Fx*

E
,E
s
$
?

f
i
q
EE
,
F

;d
a
o
.
g

E
E
EI
:

fr
5
3
r
E
I

=
Es
g
,

Hg
E
"
E

g
5
E
E=
=

$i
H
E
E
E
?
J
2
=,
=

:=
S
:

1
S
E5
}E
i

E€
8
E
-j
i
:
oHE
E

EE
d
E
g
I

i=
3P
;

P-
,

OI
J
o
,

E
E<
E
;:
$

Is
n
;
E
f
;

rs
is
E

EE
;
F

ry
1
f

r
E;

E
rf

Et
>
EE
E

!{
s
F
i
!
i
+
e
Ee

I5
1
;

H,
E

eq
fi

o
6
-c

g!
!
.
-
-

d
\.
,

;-
v
EE
i
,

EI
E
a

€
H
EE
E€

e
E
is
3

s
*
i1
Ei

i
.
*I
?

E
E
E
H
:l
I
E
I
+
:
i
*
f
l
i
f
s
q)-qioLc--tA.--EGI
t,taq)
ra0-Ol]ztroUzrd)ori&tr
--IGl

'!
-t
33
2
-t
-
a
f-

f-

(J
<>
F
tr
.
l
H
fl
,
8
r.
l

<
fr0(
O&E]Frd
ll
ra&Or
t]Uts
tFjz
z9,
EH
t)
llaE1H/
xFardFa,.
tJ
.

tr

o\
n
cu
O
r-
7\
A
\
J
\J

tr
{

tr
t
Q
.E
.
d
F?
t
r
-tEh
good
ca
(nobo
(BAc\Otroc0
TOCDF
Waste Analysis Plan
June 2009
Table 2-2:
Site-Generated Waste Streams
Waste Stream Description EPA Waste Codesr
Utah
Waste Code
MPF Metal Metal parts after incineration.N/A F999
MPF Residue MPF maintenance residue.D006, D008 F999
LIC Slag (hazardous)Slae generated in LIC secondary chamber.D007 F999
LIC Refractory (hazardous)Produced during refractory changeout.D007 F999
DFS HDC Ash (hazardous)Produced during the inc neration of mun tions.D006, D00g F999
DFS Cyclone Residue Produced during the inc neration ofmun tions.D006, D007, D008 F999
DFS Refractory Produced during refractory changeout.N/A F999
Brine Tank Sludge (hazafious)Produced during the cleanout of tanks that store
scrubber brine.
D006, D007, D008 F999
Demister Filters (hazardous)Produced during the changeout of demister
filters.
D006, D008 F999
PAS Quench Tower Residue Produced during the cooline of the off-gas.N/A F999
PAS Sump Sludge (hazafious)Generated during the cleanout of the PAS
sumps.
D005, D006, D007,
D008, D0l I
F999
RHA Baehouse Residue Residue collected from baghouse.D006, D008 F999
Decontamination- Neutral ization
Solutions
Produced from site decontamination and
laboratory operations2.
D002, D008, D0l g,
D022, F002, F003,
F005, D019, D022,
D028
F999
Waste Heavy Metal Solution - Acidic,
Oxidizing
Generated at the Laboratory.D001, D002, D004,
D006, D007, D008,
D009. D010
F999
Waste Acid Solution Generated at the Laboratory.D002 F999
Waste Organic Solvents Generated at the Laboratory.D001, F002, F003,
F005
F999
DPE Suits Generated during toxic operations.D003 F9991P999
Wood Pallets Produced during the unpacking of ONCs and
rnunitions.
N/A F999tP999
Spent Activated Carbon Produced during the changeout of carbon filters.D003 F999, P999
Miscellaneous Metal Parts Worn out equipment and parts.D006, D008 F999
Clean-up Materials Miscellaneous materials generated during the
decontamination and maintenance of the plant.
N/A F999
Incinerator Byproducts Byproducts fi om maintenance activities.D007 F999
Spent Hydraulic Fluid Produced during maintenance activities.N/A F999
Waste Oil Produced during rnaintenance activities.F00l , F002, D00l F999
Waste Paint Liquids Produced during rnaintenance activities.D001, D005, D007,
D008, F002, F003,
F005
F999
Waste Paint Solids Produced during maintenance activities.D007, D008, F002,
F003, F005
F999
Spill Cleanup Materials Generated during single substance spill response
cleanup.
N/A F999
Trash, Debris, & PPE Produced during maintenance act V ties.D003 P999lF999
Broken Fluorescent Liehtbulbs Produced during maintenance act V ties D009
CAL Lab Liquids Miscellaneous materials generated after
decontaminati on activities
D001, D002,D022 F999
CAL Lab Solids Miscellaneou
decontaminat
i materials generated after
on activities
F003, F005,F999
DFS Demister Candle Packine Produced during change out of demister candles P999
Flamrnable Aerosols Off-spec/expired shelf I ife rnateri al D001, D007, D008,
D035, D039
Flammable Labpacks Off-spec/expired shelf life materi al D00l P999, F999
Attachm ent 2 - Page 54
TOCDF
Waste Analysis Plan
June 2009
S it e- G. ".,Il3i'-i;1; e s tr e a m s
Waste Stream Description EPA Waste Codesr
Utah
Waste Code
IPA/Glycol Surrogate during systemization of plant
equipment
D00l F999
Lab acids Off-spec/expired shelf life material D001, D002, D006,
D008, D019,D022,
F003
F999
Lab Solvents Off-spec/expired shelf life material D001, D002, F003,
u080
F999
Lead Acid Batteries Battery Change out D002, D008 F999
Lithium Batteries Battery Change out D003 F999
M40 Canisters Generated during toxic operations F999, P999
Monitoring Solids Discarded monitorine and sampline equipment.F999,P999
MPF Brick MPF refractory replacement D007 F999
MPF Vacuum Ash Residue removed from MPF burn trays and
munitions.
D006, D007, D008 F999
MSB Cleanine Solutions Cleaning of sampling equipment F999
NiCad Batteries Battery Change out D006,F999
PAS Pipine PAS pipine repairs and replacements F999,P999
PAS Solids Solids collected in PAS filters and removed
from quench towers and scrubbers
D006, D007, D008 F999, P999
Sodium Lamps Lieht Bulb replacement D005, D008, D009 F999,P999
Spent IPA Cleanine ACAMS equipment D00l F999, P999
Spent Scrubber Brine Generated from incineration operation D004" D007. D008 F999,P999
Surnp I l0 Sludge Sump I l0 clean out F999,P999
Tap Gear Generated during toxic operations F999, P999
Footnotes:
l. The waste codes are determined by analysis and/or generator knowledge. Additional waste codes may apply.
Attachm ent 2 - Page 55
TOCDF
Waste Analysis Plan
June 2009
Table 2-32
Analytical Method Descriptions
Method Description/Title
ASTM D 482 Test Method for Ash from Petroleum Products
ASTM D5865 Test Method for Gross Calorific Value of Coal and Coke
sw-846 1010 Pensky - Martens Closed-Cup Method for Determinine Ienitabilitv
sw-846 10204 Setaflash Closed-Cup Method for Determining Ienitabilitv
sw-846 1311 Toxicity Characteristic Leaching Procedure.
sw-846 3010A Acid Digestion of Aqueous Samples and Exkacts for Total Metals for Analysis by FLAA or ICP
Spectroscopy
sw-846 30r5 Microwave Assisted Dieestion of Aqueous Samples and Extracts
sw-846 3050 Acid Digestion of Sediments, Sludees, and Soils.
sw-846 3051 Microwave Assisted Acid Digestion of Sediments, Sludges, Soils and Oils
sw-846 3s10C Separatory Funnel Liquid-Liquid Extraction.
sw-84 6 3052 Microwave Assisted Digestion of Siliceous and Organically Based Matrices
sw-84 6 3520C Continuous Liquid-Liquid Extraction.
sw-84 6 3s4t Automated Soxhlet Extraction
sw-84 6 3s40C Soxhlet Extraction
sw-84 6 3s45 Pressu rized Fluid Extraction
sw-84 6 35804 Waste Dilutron.
sw-846 5030B Purge and Trap
sw-846 5035 Closed-System Purge-and-Trap and Extraction for Volatile Organics in Soil and Waste Samples
sw-846 6010B Inductively Coupled Plasma - Atomic Emission Spectroscopy.
sw-84 6 6020 Inductively Coupled Plasma-Mass Spectrometry
sw-84 6 74704 Mercury in Liquid Waste (Manual Cold-Vapor Technique).
sw-846 747rA Mercury in Solid or Semisolid Waste (Manual Cold-Vapor Technique)
sw-846 82608 Volatile Organic Compounds by Gas Chromatography/Mass Spectrometry (GC/IvIS): Capillary
Column Technique.
sw-846 8270C Semivolatile Organic Compounds by Gas Chromatography/Ivlass Spectrometry (GC/\4S):
Capillarv Column Technique.
sw-84 6 8290 Polychlorinated Dibenzodioxins (PCDDs) and Polychlorinated Dibenzofurans (PCDFs) by High
Resolution Gas Chromatorgraphy/High-Resolution Mass Spectrometry (HRGC/HRMS)
sw-84 6 82804 Analysis of PCDDs and PCDFs bv HRGC/LRMS
sw-846 8330 Nitroaromatics and Nitramines by Hieh Performance Liquid Chromatosraphv ffiPLC)
sw-84 6 8332 Nitroglycerine by Hieh Performance Liquid Chromatography
sw-846 9040B pH Electrometric Measurement.
sw-84 6 9045C Soil and Waste pH
sw-846 90s6 Determination of Inorganic Anions by Ion Chromatography
sw-846 9095A Paint Filter Liquids Test
EPA 160.1 Total Dissolved Solids (TDS)'
EPA t60.2 Total Suspended Solids (TSS)'
EPA- 1668 Chlorinated Biphenyl Congeners in Water, Soil, Sediment, and Tissue bv HRGC/HRMS
TE-LOP-522 Laboratory Operating Procedure for Depot Area Air Monitoring Systems (DAAMS)
TE-LOP-524 Laboratory Operating Procedure for Automatic Continuous Air Monitoring System (ACAMS)
TE-LOP-s57 Analysis of Metals by Inductively Coupled Plasma-Mass Spectrometrv (ICP-MS)
TE-LOP-572 Extractions/Analyses Including: WCL Extraction of GB for the Metals Diluent Solution; DWS
Extraction of VX and HD; Extraction of GB, HD, and VX from Hydraulic Fluid; Analysis of GB,
HD, and VX in Lubricating Oils; Analysis of GB, HD, and VX in Organic Wastes; and
Extraction of GB, HD, and VX from Wood.
TE-LOP-S74 Special Analyses Including: Specific Gravity Measurements.
Attachm ent 2 - Page 56
TOCDF
Waste Analysis Plan
June 2009
OlTable 2-32
Analytical Method Descriptions
Method Description/Title
TE-LOP-s84 Neat Agent OPS/GC Including: GC-FID and GC-MSD Analyses of Agent Samples to Determine
Aeent Purity.
TE=LO.P-XXX Aeent GA and L Screen for ATLIC Solid Waste Matrices
TE-LOP-XXX Aeent GA and L Screen for ATLIC Liquid Waste Matrices
TE-LOP-XXX
Attachm ent 2 - Page 57
TOCDF
Waste Analysis Plan
June 2009
TOCDF may demonstrate compliance with organic constituents Universal Treatment Standards if
good-faith analytical efforts achieve detection limits for the regulated organic constituents that do
not exceed the treatment standards specified in the Table found in 40 CFR 268.40 by an order of
magnitude.
Table 2-4a
Metals (Universal Treatment Standards)
I Antimony 1.15 mg,fi TCLP
6 Chromium (Total)
0.6 mg/l TCLP
11 Silver 0.14 mgfl
TCLP
2 Arsenic 5 mell TCLP 7 Lead 0.7 5 ms,fi TCLP t2 Thallium 0.2 me/l TCLP
3 Barium 2l mell TCLP 8 Mercury 0.025 ms,ll TCLP t3 Vanadium 1.6 mg/l TCLP
4 Beryllium 1.22 ms,fi TCLP 9 Nickel ll mell TCLP t4 Zinc 4.3 ms,/l TCLP
5 Cadmium 0.1 I ms,ll TCLP t0 Selenium 5.7 me/l TCLP
Table 2-4br
Volatile Organic Compounds Universal Treatment Standards
I Acetone
(160 me/ke)
l5 1,2-Dibromoethane
(lSmelke)
29 1 , 1 , I ,2-Tetrachloroethane
(6mg/ls;
2 Benzene
(l0mg/kg)
t6 Dibromomethane
( l5mg/ke)
30 | ,l ,2,2-T etrachloroethane
(6mg/kg)
3 Bromodichloromethane
(15mg/kg)
t7 I ,l -Dichloroethane
(6me/ke)
3l Tetrachloroethylene
(6 melkg)
4 Bromomethane
(15me/kg)
18 1,2-Dtchloroethane
(6mg/kg)
32 Toluene
(l0mg/ke)
5 2-Butanone (Methyl ethyl ketone
36 me/ke)
t9 I ,1-Dichloroethylene
(6me/ke)
33 Tribromomethane
(Bromoform) (lSms,lke)
6 Carbon disulfide
(4.8mg/1 TCLP)
20 t r an s - 1,2 -D ichloro ethylene
(3Omg/l<e)
34 1 , 1 , 1 -Trichloroethane
(6mg/lqg;
7 Carbon tetrachloride
(6 mslke)
2t | ,2-Dichloropropane
(l8me/ke)
35 1,1,2 -Trichloroethane
(6mglkg)
8 Chlorobenzene
(6mg/kg)
22 cis -1, 3 -Dichloropropylene
(l8me/kg)
36 Trichloroethylene
(6mg/kg)
9 2-Chloro- 1,3 -butadiene
(0,z8melke)
23 tr an s -1, 3 -D ichloropropylene
( 18me/kg)
37 Trichloro fluoromethane
(30ms,lke)
10 Chlorodibromomethane
( l5me/ke)
24 1,4-Dioxane
( l70meike)
38 1,2,3-Trichloropropane (3 0
me/ke)
11 Chloroethane
(6melke)
25 Ethylbenzene
(lOmg/kg)
39 I ,l ,z-Trichlor o-l ,2,2-
trifluoroethane (30 mg/kg)
t2 Chloroform
(6mglkg)
26 Iodomethane
(65mg/ke)
40 Vinyl Chloride
(6 mglke)
l3 Z-Chloroethyl vinyl ether
(NA)
27 Methylene chloride
(30mg/kg)
4l Xylene (o-m-,p-)
(30 mg/ke)
t4 Chloromethane
(30me/ke)
28 Methyl isobutyl ketone
(33 me/ke)
Attachment2 - Page 58
TOCDF
Waste Analysis Plan
June 2009
TOCDF may demonstrate compliance with organic constituents Universal Treatment Standards if
good-faith analytical efforts achieve detection limits for the regulated organic constituents that do
not exceed the treatment standards specified in the Table found in 40 CFR 268.40 by an order of
magnitude.
Table 2-4cl
Semi-Volatile Organic Compounds (Universal Treatment Standards)
1 Acenaphthylene
(3.4mglkg)
23 p-Cresol
(5.6m9/ke)
45 Hexachloro cyc lop entadiene
(2.4mp,/ke)
2 Acenaphthene
(3.4melkg)
24 Dibenz( a,h) anthrac ene
(8.2mq,/ke)
46 Hexachloroethane
(30me/ke)
3 Acetophenone
(38me/ke)
25 m-Dichlorobenzene
(6mg/kg)
47 Indeno (1,2,3 -c,d) pyrene
(3.4mslkg)
4 Aniline
(l4ms/ke)
26 o-Dichlorobenzene
(6mglkg)
48 Naphthalene
(5.6mg/kg)
5 Anthracene
(3.4ms/kg)
27 p-Dichlorobenzene
(6me/ke)
49 2-Naphthylamine
(NA)
6 Beru(a)anthracene
(3.4 me/ke)
28 2,4-Dichlorophenol
(t4mslke)
50 2-Nitroaniline
(l4melkg)
7 Benzo(b)fluoranthene
(6.8mg/kg)
29 2,i-Dichlorophenol
(l4ms,fte)
51 4-Nitroaniline
(Z8mglke)
8 Benzo(k)fluoranthene
(6.8me/ke)
30 Diethyl phthalate
(28ms,fte)
52 Nitrob enzene
(14 me/ke)
9 Benzo(g,h,i)perylene
(1.8mg/kg)
31 2,4-Dimethyl phenol
(l4ms,lke)
53 2-Nitrophenol
(l3melke)
l0 Benzo(a)pyrene
(3.4m9,/ke)
32 Dimethyl phthalate
(28melke)
54 4-Nitrophenol
(29ms,lkg)
11 4-Bromophenyl phenyl
ether (llmelke)
33 Di-n-butyl phthalate
(28melkg)
55 Pentachlorob enzene
(l0mg/ke)
l2 Butyl benzylphthalate
(Z8ms,lke)
34 I ,4-Dinitrobenzene
(2.3me/ke)
56 Pentachloroethane
(6me/kg)
l3 p-Chloroaniline
(l6melkg)
35 4,6-Dinitro-o-cresol
(l60me/ke)
57 P entachl oronitrob en zene
(4.8 me/ke)
t4 B i s (2Chl oro e thoxy) me than
e (1.2me.kg)
36 2,4-Drnitrophenol
(160me/ke)
58 Pentachlorophenol
(7.4ms,/ke)
15 B i s (2 -Chloro ethyl) e ther
(6me/ke)
37 2,4-Dinitrotoluene
( l40me/ke)
59 Phenanthrene
(5.6mglkg)
t6 B i s (2 -Chloro i s opropyl)
ether (7.2mglkg)
, 3g 2,6- Dinitrotoluene
(28mglkg)
60 Phenol
(6.2 mg/kg)
l7 4-Chloro-3 -methylphenol
(r4mglke)
39 Di-n-octyl phthalate
(28mglkg)
6l Pyrene
(8.2mglke)
18 2-Chloronaphthalene
(5.6me/ke)
40 Diphenylamrne
(t3msfte)
62 1,2,4,S-Tetrachlorob enzene
(l4mglke)
r9 2-Chlorophenol
(5.7mslke)
4t Fluoranthene
(3.4mg,/ke)
63 2,3,4,6-Te trachloropheno I
(7 .4 melke)
20 Chrysene
(3.4me/ke)
42 Fluorene
(3.4ms/ke)
64 1,2,4 -Trichlorobenzene
(l9mp,lke)
2l o-Cresol
(5.6me/ke)
43 Hexachlorobenzene
(10me/ke)
6s 2,4,5 -Trichlorophenol
(7.4mp/ke)
22 m-Cresol
(5.6mg/ke)
44 Hexachlorobutadiene
(5.6me/kg)
66 2,4,6 -Trichlorophenol
(7.4mp,/ke)
Attachrnent2-Page59
TOCDF
Waste Analysis Plan
June 2009
Table 2-5 Agent Contaminated Waste That May Be Treated in The MPF'
Waste Stream and Quantity (if Applicable)Waste Code(s)
As sorted Parts/Material
Conveyors
Chains, Rollers, Links
Gears, Bearings, Bushings
Wheels, Idlers
Gearboxes
Gasket Materials (non-combustible)
S eals (non-cornbustible)
Pre-filters and HEPA filters
Carbon Adsorber Trays (from which carbon has been removed)
Collets
Drain Probes
Crimp Jaws and Pins
Bore Station Blades
Turntable Projectile Bushings
Projectile Pickup Heads
Shear Blades
Punches
Pusher Assemblies
Paper, Cloth, Pads, Pillows, Spill Adsorbents (Cellulose/pol)propylene)
(Maximum,28 lbs/charge for a single charge at 20,000 BTU/lb at 1450' F)
(Maximum 16 lbs/charge for consecutively charged trays containing paper, cloth,
pads, pillows and spill absorbents, at20,000 BTUllb at 1450" F)
Jaw Gripper Assemblies
Projectile Cans
Hoists
P999
Electrical Components
Motors
Conduit (Metal)
Solenoids
Switches (Safety, Limit, Light)
Light Fixtures, maximum of 20 units per furnace charge
P999
Attachrn ent 2 - Page 60
TOCDF
Waste Analysis Plan
June 2009
Plumbine Materials
Pumps
Piping/Fittings/Tubing (metal)
Chemical Seals
Hydraulic Motors
Hydraulic Cylinders
Hydraulic Tubing/Fittings (metal)
Hydraulic Hose/Fittings (metal)
Pressure Regulators
Flow Control Valves
Pneumatic Actuators
Accumulator Bladders
Filter Cartridges/Elements and associated residue/cleanup material
(includes AQS/ACS filter elements)
Spray Nozzles
Pipe Gaskets
Valves (Hand, Solenoid, Agent, Decon, Hydraulic)
P999
Instrumentation T est Equipment (Meters, Gauges, Etc.)
Sensors, Transmitters, and Transducers
Flow, Pressure, and Proximity Switches
Pressure Gauges
Cameras or Camera Parts
Load Cells
Speakers
Low Volume Agent Samplers
Thermocouples and Thermowells
P999
Attachrn ent 2 - Page 6l
TOCDF
Waste Analysis Plan
June 2009
Assorted Solids P999
Hand Tools
Grating
Metal Buckets, Pans, and Barrels
Metal Brackets, Stands, Fixtures, Etc
Escape Air Tank, Mask, and Regulators
Scrub Brushes
Banding Materral
Empty Overpacks/Drums (Non-Combustible)
Monitoring Sample Probes (DAAIVIS Tubes, etc.)
S ilicone materiaUparts
Glassware
Plaster
Paint Brushes, Rollers, and Pans
Empty Paint and Lubricant Spray Cans (Punched), maximum 25 units per
furnace charge
Personal Protective Equipment (non-combustible)
DPE Leather Over Garments, maximum 10 units per furnace charge
Plastic bags used to contain contaminated wastes, a maximum of 1.0 lb per
furnace charge
In addition to the P999 waste code, the above-mentioned waste streams may carry the following waste
codes: F999, D002, D004, D005, D006, D007, D008, D009, D010, and D011.
Attachm ent 2 - Page 62
aHt+*ri
l*o*+$r*a)FtZ,
rf
l
(,+*U)
r*x$t-*sdE+
r+t
c}I
ch
adodTq.$
$+ct
\s
s\o
chsct
\
rl
-
a*$
el
,
l*
s+o
$c{
t
tr
h+s
.o
.r
X
:!0,
.
.
.f
lTg${
.9
*a
ho
lLo*$
.
r+
aTIoEHoFL
H$t$
fl
$$f
l
$$$$
$H#$
IU{g(3*
$ct
\
pfr1$
f;
q-sU)fd
IoD
r{
-
,ect
\
lr
h+
at/
t
)
ch$
oO
tt
t
h
ef
t
ci
l+
.l
<+o
*et
t
t,
r
hqct
t
<D*oD
t
3g
m
f
i
I
(h-sU)dtd
9r+
ao+rArl
.+
qut
)
chsci
l
rF
ftcf
t+
chso
et
rt
tt
t+c+
t
I*
H
d*#c.t
$$cf
r
rIs
cl
l
di
at
r
chet
t
\o
T.9fi
$tr
t
t
oD*
fi
I*
Ifr
.$t'o
a
fi
t
{$us
$tr
t$
ma
FLdr*
cl
ild
*d\q$
\o++
t,
r
hsrl
-$
ch9
$
qc[
.GBqTt$
oDct
l+
$+
(U
.gq)
ofi
*,
ot
t
r{
-6o+
)l
(
F+*F*
ELo**
H1,dfr$
*o
.Gq)
,:
f
i
0x
fi
r+
a
il$*
b'Ifr
e
E$
I*
hrtt.$
$
t$
r*olY.gE#rl
J
fr
r+
^r*ol
\L
,t&$$
.+
I&+H$
[$
IE.
(U
ff
olx&-&cr
)d
r+
a
t*
sAch
-qfl
r
.*?f
)$.*
.*
_uE
$
a.9Eg-t
(B
.*
.$
cI
2
.9tE.Io.sri
lfoh
*+$$
g(B
{+
l
_t
(B
.gb$0L
tL

tr
O
\
,a

cd
o
ts
a
-
^
7\

A
\J
L.
/

H
rN
o
.2
-
d
F?
t
r
-3Eh
l<0)
(r
)d>
IIc!
ri
;
olobt$t+IT(B*tH8,J
alEIEIdlEIzlEI
JIEI
ililEI
6l
.:
l
alEI=l
JI
HE
I
EI

EI
-c
l

cl
ul

'a
l
"u

hl
co
l
UIal
*l5l
c{
l
cl
l
sl
e{
l
3
.+
l
('
)
l
:l
=l

Et
ql

E1
et

Et
+l
€
l
H
€l+l
€l
c.
r
l
9l
sl
eo
l
ot
-o
t
cl
lEIEI
cd
l
EI
tr
lol
zl
f-
lsl
o{
l
EI
elol
;lalol
=lolol
UI
Hf
,
o6du(
trooooO3oaE60o&
alEI
ilolat
OIOI
olnl
EI€lsl
fl
f
l
H
s
o-
l
ol
l
ol
ot
l=l
:c
l
nlUI
:I
\O
l
;I
9Inl
c{
l
-l
r-
l
rO
l
rc
l
"I
oo
l
f-
l
*l
f-
l
rr
lqIol
r\
l
f-
l
-.
1
oo
l
il
EI
IL
I
il
'E
l
fr
-
l
ol$l
f-
l
o,
l
FIEI
ol
.-
l-c
l
+J
lx
Fl

€l
5I

HI

L
El

ql

#l
6I

HH
(}
.
t\
,a
O.
oldotOrc..
)ol
!E
l
ta
IaU]
.+
l
\O
I
f-
l
st
l
-lor
l
oo
l
-.
1
c!
lql
ro
l
O.
l
nl
O,
l
f-
l
d.
!
l
*l
co
lol
;l
co
l
c{
l
$l$l
.+
l
OI
-lol
(\
r
l
FI
el
ro
l
EI=l
.E;l=l
5l
flEIol
5)
lbl
EI
ol
r-
l
cd
l
ol
br
€I:tcl
l
cl
EI
t-
lol^lOI
aJ
lCB
I
o)
l
EIOI
o.
l
0)
-ooao0)otro()
tJ
-
oc\
f-d()oOOEc!o\
,jEOa
'o
t-0)
(o>
Ll0)
I
-s
l
6lJOIHIolNI8l
fl€l.icl
cl
l
-q
l
5.
1olol5t
-c
l
()
I
cd
l
btOI
-r
l
UI
fi
'
ul
It
lUIulolCIol
5)
lot
()
I
6r
l
OI
ol$l
or
l
'o
l
'=
l
ot
;lBI
()
Ial
5l
EI
al
:l

Er
EI

EI

.i
l
'r
|
]
alc6l
:E
Idi
\O
l
5l
;lnl
f-
l
-.
1
$l
""
;
l
O\
l
nl
O,
l
r-
l
f-
l
rr
lol
;l
f-
lsl
O\
l
rr
lqlol
Gr
l
FI
rr
lql
co
l
OIOI
;I
afr
lsl
:l
-l
ZI
al
AB
€l

Hf
l
fl
H
l

fl
H
l
al
^loloo
l
:E
I
Lj
i
\O
l
;l
r-
lql
O,
l
nl
-r
l
.q
l
nl
o\
l
.q
l
O,
l
f-
l
€lnl
cr
r
l
er
l
$l
;lol
FI
or
l
nlql
co
l
OIOInl
oo
l
XI>l
OI
!)
lCU
I
EI
._
l€lolcl
$I

HH
H
*l

El

3l

EI
iI

g]

EI

HI
al
o-
lczl\o
fl=U!
c{
l
\O
l
ot
l
f-
l
"1
1
r-
l
ro
l
or
l
ol
l
o.
l
co
l
ql
er
l
rO
l
olel>lOIOI
ol
c{
l
f-
l
nl
eo
l
\O
l
OIOI
ol
il
oo
l
;l
i]
H
H
EI

H€
I
fi
E
l

fl
EIolEIol
cl
OI
tr
lol
zl
OI
cIol
zl
ol=l
!ioi
l-
.

I
cd
1a)Oi>lotat
*-
r
la\
0,
l
l
c0
l
al=l
<.
r
l
cg
l
-tcd
l
blclEI
.+
l
il
aor
ll-
laI
U,
I
\-
lEIUI
Bs
f
l
g
l
c.
Idl
f:
-
l
O1
EI
Lj
i
;l
or
l
qlol=l
\O
l
oq
l
\f
l
ra
l
\O
IqlEI
O\
l
el
\O
l
;l
qI
or
l
EIdICIEIrlolol
ol
oo
l
ot
l
-,
'
I
sl
g
El

€l

=r
il
E
l
B
$
g
l
eo
l
f-
l
oIOI
-'
l
ilEI
fl
OIEI
=l
cl
l
(J
lEI
5l
Gl
l
EI8lEI
(J
l
EI5l
fl?lEIzl>l
a
,r
'

9l
HH
$a
FIEI
'6
1HNIol
ri
l
l:
-
l
ol
*r
lcl
'5
1
o.
l
odEIol
c0
l
!)
l63
1Hl

s
fl
g
!t
r
l
FIEI?l
tr
I
!.
1cl
lAal
(.
)
l
Bl
f
l
'7
l
1

Al
-

|
gl

el

rl
bI
EIUI
br
'o
lol
a1OIEIalolelGl
l
(J
lOII
alolEIEI
o-
lel
=l
_o
t
€lal
ot
,lsl

q
HE
I
Il
f
l
EI

EI
olHI
elatEI
(J
I
'7
,
1
x-c
l
O-
l
o\OOe{O)F-
)
fi
r-
a
cdFl
|.
4gad
c!II
c\
l
fr
.
,
.
ooo
\odEot-a(d0)0)aoA.OUa)o3raoo)acdoaooa']Ecd
6F6aOo0
o
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2
CHEMICAL AGENT COMPOSITION
AGENT CHEMICAL CONSTITUENT MinimumValue
(wt%)
MaximumValue
(wt%)
GB Isopropyl methyl phosphonofluoridate (GB Aeent)37 97
N,N'-Diisopropylcarbodiimide (DICDI)0 1.9
Tributylamine (TBA)I 9.5
Methylphosphonofluoridic acid (MPA) I 0 8.35
Diisopropyl methylphosphonate (DIMP)0.9 27
Methylphosphonofluoridic acid (MPFA) t 2.6 13.6s
Diispropyl urea (DIU)0 2.4
Diethvl methyl phosphonate (DEMP)0.6 0.6
Isopropylmethylphosphonic acid (IMPA) t 0.05 25.8
Fluoride (F) t 0.1 2,8
Density (e/ml)I L,2
Metals Minimum (me/ke)Nlaximum (me/ke)
Aluminum 4,7 3205
Antimony 0.04 154
Arsenic 0.72 556
Barium 0.0094 40
Beryllium 0.002 1
Boron 1.1 4585
Cadmium 0.01 I 7.9
Chromium 0.72 54
Cobalt 0.07 10.9
Copper 0.25 120
Iron 18 4855
Lead 0.092 801
Manganese 0. 13 110
Mercury 0.0061 9.1
Nickel 0.72 415
Selenium <0.5 92
Silver 0.004 13
Thallium <.14 t54
Tin 0. l5 308
Vanadium 0.33 10
Note:
l. The parameter is analyzed if the mass balance of the initial agent organic analys s is fbund to be 80% or le )SS.
2-A-3
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2
CHEMICAL AGENT COMPOSITION
AGENT CHEMICAL CONSTITUENT MinimumValue
(wt%)
MaximumValue
(wt%)
vxr O-ethyl, S- [2-(diisopropylamino)ethyl]
methylphosphonthiolate (VX Aeent)
s9.6 96.7
Ethyl methylphosphonic acid (EMPA)2 0.460 5.42
N,N'-Dicyclohexylcarbodiimide (DCC or DCHCDI)0.02 4.15
bis(2-Diisopropylaminoethyl) disulfide (KM or EA 4lgils 0.60 2.3
N,N'-Diisopropylcarbodiimide (DICDI)ND 2.20
S - ( 2 -D iis opropyl amino ethyl)methylpho sp ono thio ic ac id
(EA 2tgD3
0.1 I 0.34
bis(2 -Diisopropylaminoethyl) sulfi de (I(K)0.2 0.4
Diethvl methylphosphonate (DEMP)0.02 0.18
Methylphosphonic acid (MPA)Z ND ND
Chlorine 0.306 0.s 14
Metals Minimum (me/ke)Maximum (me/ke)
Aluminum 1.5 1.8
Antimony ND
Arsenic ND 78
Barium ND 1.0
Beryllium ND
Boron ND
Cadmium ND
Chromium ND t2
Cobalt ND
Copper ND 6.7
Iron 6.9 53
Lead ND 6.5
Manganese ND
Mercury ND 0.78
Nickel ND
Selenium ND 44
Silver ND
Thallium ND
Tin ND
Vanadium 2.9 3.3
Zrnc 0.9 10.9
Notes:
I . Data are taken frorn the Bulk Agent Stockpile Survey Report and 2001 Agent VX Characterization.
2. The parameter is analyzed if the mass balance of the initial agent organic analysis is found to be less than 85%.
3. The parameter is analyzed during shakedown and trial burn sampling only.
ND = Not Detected
2-A-4
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2
HD-Filled Ton Containers, Liquid Contents, Baseline
CHEMICAL AGENT COMPOSITION1
AGENT CHEMICAL CONSTITUENT Average Value Maximum Value Minimum Value
HD Orsanic Compounds (Weieht Percent)
Bis (2-chloroethyl) sulfide (HD Agent)89.31 l0t 78.7
Thiodielycol 0.026 0.029 0.0218
1,Z-Dichloroethane 0.606 0.993 0.197
Tetrachloroethene 0.0502 0.0734 0.0127
1,1,2,2-Tetrachloroethane 0.0518 0.05 8 8 0.0472
bis l2-(2-chloroethylthio)ethyll ether (T)0.1 69 0.355 0.0409
1,2-bis (2-chloroethylthio) ethane (Q)3.24 5.66 0.448
Hexachloroethane 0.210 0.293 0,0245
Lewisitez (ms/ke)s.24 14.5 2.82
1,4-Dithiane 1 .10 5.6 0.028
1,4-Thioxane 0.26 0.97 0.083
2-Chloroethyl 4-chlorobutyl sulfide 0.51 3.0 0.079
b is (2-Chloropropyl) sulfi de 0. 19 1.0 0.043
Chloriner 41.61 48.08 NA
Metals (me/ke)
Aluminum 38 55 t2
Antimony 5.09 5.5 0.67
Arsenic 5.80 51.6 1.3
Barium 5.08 5.5 0.44
Beryllium 5. l9 5.5 4.8
Boron 9.34 1l 4.0
Cadmium s. 19 5.5 4,9
Chromium 4.81 29.9 1.4
Cobalt 1.03 1.1 0.33
Copper 37.9 84.8 4,5
Lead 4.7 r 5.5 0.47
Manganese 1.67 6.49 0.33
Mercury 0.3 5 0.55 0.054
Nickel 3.40 15.7 0.36
Selenium l0.l 11 1.2
Silver 5.15 5.5 t.72
Thallium 5. 19 5.5 4.8
Tin t0.4 1l 9.54
Vanadium 3.r2 5.5 1.06
Zinc 9.76 29.4 3.42
Notes:
I . The average, minimum and maximum concentration values shown in this table are based upon the results of the
Mustard Sample Validation Project for the 80 of 98 ton containers sampled that contained less than one ppm Hg in their
liquid contents. Data from the I 8 of 98 ton containers that had elevated mercury concentrations are not included in
these values.
2. The values for Lewisite are reported in mg/kg instead of "weight percent".
3. The values for chlorine were calculated as the total combined weight ofchlorine in all ofthe chlorine-bearing organic
compounds.
2-A-5
TOCDF
Waste Analysis Plan
June 2009
Baseline HD-Filted
CHEMICAL
Table 2-A-2
Ton Containers, Solid Contents
AGENT COMPOSITION1
AGENT CHEMICAL CONSTITUENT Average Value Maximum Value Minimum Value
HD Metals (me/ke)
Aluminum 36.2 r60 10.8
Antimony 2.05 30.3 0.t79
Arsenic 176 1 850 0.935
Barium t.42 14.2 0.0467
Beryllium 4.9 5.57 0.0572
Boron 9.7 1 1.1 3.99
Cadmium 0.888 5.34 0.0492
Chromium 47.7 397 9.28
Cobalt 7 .63 27 .t 2.00
Copper 151 2350 4.13
Lead 65. 1 625 6.61
Manganese 4tt 1 960 47
Mercury 1.s9 2s.6 0.0807
Nickel 82.6 96s 8.99
Selenium 24.1 27.8 1.09
Silver 4.41 5.55 0.0622
Thallium 5.04 5.57 0.4t2
Tin 9,39 52.6 0.966
Vanadium 3.55 5.57 0.98
Zinc 224 49s0 2.62
Notes:
1. The average, minimum and maximum concentration values shown in this table are based upon the results of the
Mustard Sample Validation Project for the 80 of 98 ton containers sampled that contained less than one ppm Hg in their
liquid contents. Data from the 1 8 of 98 ton containers that had elevated mercury concentrations are not included in
these values.
2-A-6
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2a
H-Filled 155-mm Projectiles, Liquid Contents
CHEMICAL AGENT COMPOSITION'
AGENT CHEMICAL CONSTITUENT Average Valuea Maximum
Values
Minimum
Value6
H Oreanic Compounds (Weieht I )ercent)
Agent)TBD TBD TBD
Thiodiglycol TBD TBD TBD
1,2-Dichloroethane TBD TBD TBD
Tetrachloroethene TBD TBD TBD
1,1,2,2-Tetrachloroethane TBD TBD TBD
bis l2-(2-chloroethylthio)ethvll ether (T)TBD TBD TBD
1,Z-bis (2-chloroethylthio) ethane (a)TBD TBD TBD
Hexachloroethane TBD TBD TBD
Lewisitez (mgikg)TBD TBD TBD
1,4-Dithiane TBD TBD TBD
I,4-Thioxane TBD TBD TBD
Z-Chloroethyl 4-chlorobutyl sulfi de TBD TBD TBD
bis (2-Chloropropyl) sulfide TBD TBD TBD
Chlorine3 TBD TBD TBD
Metals (me/ke)
Aluminum TBD TBD TBD
Antimony TBD TBD TBD
Arsenic TBD TBD TBI)
Barium TBD TBD TBD
Beryllium TBD TBD TBD
Boron TBD TBD TBD
Cadmium TBD TBD TBD
Chromium TBD TBD TBD
Cobalt TBD TBD TBD
Copper TBI)TBD TBD
Lead TBD TBD TBD
Manganese TBD TBD TBD
Mercury TBD TBD TBD
Nickel TBD TBD TBD
Selenium TBD TBD TBD
Silver TBD TBD TBD
Thallium TBD TBD TBI)
Tin TBD TBD TBD
Vanadium TBD TBD TBD
Zinc TBD TBD TBD
Notes:
l. The Initial characterization has not yet been performed, this table will be updated when data becomes available.
2. The values for Lewisite are reported in mg/kg instead of "weight percent".
3. The values for chlorine were calculated as the total combined weight ofchlorine in all ofthe chlorine-bearing organic
compounds.
2-A-7
TOCDF
Waste Analysis Plan
June 2009
Table 2-L-2t
H-Fitled 155-mm Projectiles, Solid Contents
CHEMICAL AGENT COMPOSITION1
AGENT CHEMICAL CONSTITUENT Average Valuea Maximum
Values
Minimum
Value6
H Orsanic Compounds (Weieht I ercent)
Aeent)TBD TBD TBD
Thiodiglycol TBD TBD TBD
1,2-Dtchloroethane TBD TBD TBD
Tetrachloroethene TBD TBD TBD
1,1,2,2-Tetrachloro ethane TBD TBD TBD
b is l2-(2 -chloroethylthio)ethyll ether (T)TBD TBD TBD
1,,2-bis (2-chloroethylthio) ethane (a)TBD TBD TBD
Hexachloroethane TBD TBD TBD
Lewisitez (mg/kg)TBD TBD TBD
1,4-Dithiane TBD TBD TBD
1,4-Thioxane TBD TBD TBD
2-Chloroethyl 4 -chlorobutyl sulfi de TBD TBD TBD
bis (2-Chloropropyl) sulfide TBD TBD TBD
Chloriner TBD TBD TBD
Metals (me/ke)
Aluminum TBD TBD TBD
Antimony TBD TBD TBD
Arsenic TBD TBD TBD
Barium TBD TBD TBD
Beryllium TBD TBD TBD
Boron TBD TBD TBD
Cadmium TBD TBD TBD
Chromium TBD TBD TBD
Cobalt TBD TBD TBD
Copper ..TBD TBD TBD
Lead TBD TBD TBD
Manganese TBD TBD TBD
Mercury TBD TBD TBD
Nickel TBD TBD TBD
Selenium TBD TBD TBD
Silver TBD TBD TBD
Thallium TBD TBD TBD
Tin TBD TBD TBD
Vanadium TBD TBD TBD
Ztnc TBD TBD TBD
Notes:
4. The Initial characterization has not yet been performed; this table will be updated when data becomes available.
5. The values for Lewisite are reported in mg&g instead of "weight percent".
6. The values for chlorine were calculated as the total cornbined weight ofchlorine in all ofthe chlorine-bearing organic
compounds.
2-A-8
TOCDF
Waste Analysis Plan
June 2009
. Table 2-A-2b
HT-Filled 4.2Inch Mortars, Liquid Contents
CHEMICAL AGENT COMPOSITION1
AGENT CHEMICAL CONSTITUENT Average Value Maximum Value Minimum Value
HT Orsanic Compounds (Weisht Percent)
Bis (2-chloroethyl) sulfide (HD)z TBD TBD TBD
bis l2-(2-chloroethylthio)ethyll ether (T)3 TBD TBD TBD
1,2-bis (2-chloroethylthio) ethane (Q)'TBD TBD TBD
2 -(2-chloroethyhio) ethyl 2 -chloroethyl
ether3
TBD TBD TBD
1,2-Drchloroethane'TBD TBD TBD
1,4-Dithiane'TBD TBD TBD
1,4-Thioxane'TBD TBD TBD
Chlorinea TBD TBD TBD
Metals (me/ke)
Aluminum TBD TBD TBD
Antimony TBD TBD TBD
Arsenic TBD TBD TBD
Barium TBD TBD TBD
Beryllium TBD TBD TBD
Boron TBD TBD TBD
Cadmium TBD TBD TBD
Chromium TBD TBD TBD
Cobalt TBD TBD TBD
Copppr .i TBD TBD TBD
Lead TBD TBD TBD
Manganese TBD TBD TBD
Mercury TBD TBD TBD
Nickel TBD TBD TBD
Selenium TBD TBD TBD
Silver TBD TBD TBD
Thallium T'BD TBD TBD
Tin TBD TBD TBD
Vanadium TBD TBD TBD
Zinc TBD TBD TBD
Notes:
1 . The Initial characte rizationhas not yet been performed. This table will be updated when data becomes available.
2. Quantitative analysis using calibration standard.
3. Reported as Tentatively Identified Compounds (TICs), a semi-quanti'tative analysis based on percent of area under the
chromatogram response curves.
4. The value for chlorine is determined frorn analysis.
2-A-9
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2b
HT 4.2Inch Mortars, Solid Contents
CHEMICAL AGENT COMPOSITION1
AGENT CHEMICAL CONSTITUENT Average
Value
Maximum
Value
Minimum
Value
HT Orsanic Compounds (Weieht Percent)
Chlorine2 TBD TBD TBD
Metals (mglkg)
Aluminum TBD TBD TBD
Antimony TBD TBD TBD
Arsenic TBD TBD TBD
Barium TBD TBD TBD
Beryllium TBD TBD TBD
Boron TBD TBD TBD
Cadmium TBD TBD TBD
Chromium TBD TBD TBD
Cobalt TBD TBD TBD
Copper TBD TBD TBD
Lead TBD TBD TBD
Manganese TBD TBD TBD
Mercury TBD TBD TBD
Nickel TBD TBD TBD
Selenium TBD TBD TBD
Silver TBD TBD TBD
Thallium TBD TBD TBD
Tin ai TBD TBD TBD
Vanadium TBD TBD TBD
Zrnc TBD TBD TBD
Notes:
1. The Initial characterization has not yet been performed. This table will be updated when data becomes available.
2. The value for chlorine is determined from analysis.
o
2-A- 10
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2c
GA Ton Containers Liquid Contents
CHEMICAL AGENT COMPOSITION'
Ton ContainENumber =D252s3 D29813 D35248 p5136s Average
Ag
CT
int GA
EMICAL CONSTITUENT
Ethvl N.N.-dimeth
ocyanidate (Wt'/o 3 8.8 2l.l 26.6 19.8 26.6
< 1.0 1.0 < 1.0 < 1.0 < 1.0
2.0 < 1.0 8.0 7,0 5,7
Dir rethyl dirqethldphosphoramidate (Afea 7o)< 1.0 < 1.0 1.0 1.0 < 1.0
l0 l0 20 20 15.0
0.5 6.0 8.0 9.0 5.9
Tekamethyl phosphoroiyanidic diamide (Area 7o)8.0 7.0 10.0 I 1.0 9.0
qh orobenzene (Wt7o)4.09 1 1.6 13. I 10.7 9.87
Metals
AT minum (me/ke)34.9 40.3 30.3 37.3 35.7
An limonv (mg/ke)0.52 0.23 334 316 162.7
tulenic (mCke)32.7 29.8 49.6 32.9 36.3
Ba kum (me t 1.06 0.62 0.39 0.36 0.6
Ber lvllium (me r < 0.05 0.05 0.0s 0.05 0.1
Bo lon (me/kp)109 tt2 l l3 95.6 107.4
Ca&mium (ms r < 0.05 0.05 0.05 0.05 0.1
Ch lomium (me )2.13 2.57 1,25 1.29 1.8
eq balt (me/ker < 0.05 0.05 0.05 0.05 0.1
Co boer (me/ker 21.6 10.3 0.82 1.72 8.6
rclo (me/ke)18.4 1 8.7 0.27 0.77 9.5
MJreanese (me/ke)1.25 1.32 0. 13 0.21 0.'7
M&curv (me/ke\4.1 0.49 10.4 l.8l 4,2
Ni lkel (ms/kel 0.68 0,7 0.09 0.t9 0.4
Selbnium (me/ke\< 0.05 0.05 0.07 0.09 0.1
sil lrer (me/ke)< 0.05 0.05 0.12 0.12 0.1
thhhum (me )< 0.05 0.05 0.05 0.0s 0.1
Tir [(me'kel 3.04 0.25 0.27 6.7 s 2.6
Va hadium (me/ke)9.58 I 1.5 13.9 1l I 1.5
Zit c (me/ke)62.1 43;l 28.3 36.7 42.7
tTLs t&lc obatains the analytical data for all four Aeoril GA Ton Containers stqred at DCD.
}-A-tl
TOCDF
Waste Analysis Plan
June 2009
l*.,.-Table 2-A-2d
Lewisite Ton Containers Liquid Contents
CHEMICAL AGENT COMPOSITION'
4r
gI
rent Lewisite
EMICAL CONSTITUENT (Area %)-
Average
Standard
Deviation
Maximum
Value
Minimum
Value
2-,rovin
ite Ll 7 6.9 2.1 80.4 74.3
&r
G,S
2-Ct 14.9 I*A 16.4 13.0
fi*2 -Qhlorovinyl)arsine (Lewisite L3 )0.73 0.14 0.99 ND
asE,1.3 0.34 1.9 ND
Metals
Ahlminum (ms/ke\34.3 4.25 44 29.8
Anlimonv (me/ke)313 16.0 338 292
Arlenic (Wt%)32.1 1.1 I 33.5 30.5
Balium (me/ker 0.376 0.1 I 0.59 0.16
Beh[ium (ms/ke)< 0.06 ND 0.10 < 0.05
Bolon (mq/kg)98. I Lto ll3 78.8
< 0.06 ND 0.10 < 0.05
'c*"***r*-rc,1,34 0. 15 1.59 l.l7
Cobalt (me1kg)< 0.05 ND < 0.05 < 0.05
Coboer (me/ke)0.94 0.95 2,35 0.26
Leld (me r 0.32 0.20 0.87 0.18
Mahreanese (me/ks)0.18 0.07 0.35 0.1 I
M&curv (ms1kg)w 136 58 48.4
Nidkel (mg1ke)0.22 0.23 0.84 0.06
Selbnium (ms/ke)< 0.68 2.00 6.36 0.05
Sillrer (me/ke)0.14 0.08 0.35 0.1
Thhlium (me/ke)< 0.05 ND < 0.05 < 0.05
Tirl (me/ke)< 0.39 0.26 0.95 < 0.25
Vahadium (me/ks)t4.t 1.6 16.9 1 1.8
Zirlc (me/ker 44.4 13.2 72 30.8
rTilis table includes data from samole collected from all l0 Lrwisite Ton Containers stored at DCD
o!
2-A-12
TOCDF
Waste Analysis Plan
June 2009
Table 2-A-2e
Lewisite Ton Coptainers Solid Contents
COMPOSITION'
Averase Maximum Minimum
Metals {mgJkq)
Aluminum 1_@ M 54.5
Antimonv 2.685 3.450 1.870
Arsenic 165.360 21 1.000 99.600
Barium 0.66 1.77 0.31
Bervllium 0.15 0.36 0.06
Boron W M w
Cadmium 0,30 0,73 0.1
Chromium 24.3 95.8 4.8
Cobalt 0.94 3.35 0.29
Cooner w 1.120 93.g
Iron I 1.290 39. I 00 3.020
Lead 519 2.600 25.3
MAneanese 47.7 186 12.7
Mercurv 335.299 493.000 13 1.000
Nickel 143 47.5 3.17
Selenium 6.57 10.2 3.29
Silver 0.14 0.35 0.08
Thallium 0.50 0.66 0.25
Tin 11.67 16.6 7.36
Vanadium 19.2 22.3 l6.l
Zinc ffi 1.194 ru
'This table inclqgles data from sample collected from al I 10 Lewisite Ton Containers stored at DCD
-
2-A-t3
to
t-
l
I-EoIadIo.-
t)cn
l)
.H
dxH.-
I]()+lcn
It
tr
E
.l
E
FE
I

Fr
rl
tE.
E
-a\-
c€
{Jc)
f-
laU)
tHo.-*.
)
.-dxI-
ft
lei-
.H
a-d€q)
l=
{a
-El
ff
i
ff
i
ff
i
&z
Ncao\OqO
&z
&z
\tooOqO
o\OOgO
E
EH
A
tr

o=

-g
g
€=

s
E
:'
E

E
E
d'
=

qP

c!
3
-=

EH
E

a
co

E€
E

gT
#
EH
S

":
E
T
.
.=
E
E

\F
E
(n

o
tr
=

\n
.
Y
.
c
u
H
=e
a

\o
E
F
E
EE
i
^

HE
;
3
sE
E

5E
E
grE
E€
3

EE
f
E
u=

a€

'l
=

E
E
t
rE
t

HT
€
H.

;€
;

.E
T
E
d
3
si

B
El
i
r

E
E
EE
E

'3
E
?
H=
EE
E

EE
g
E
EF
;
iG
EE
E

-E
f

E
e?H
EE
f

E€
[
tr

EH
E

iH
O
T
EH
€

EE
f
-oE
.E
.
H
I
;

q!

?2
ll

EE
H

;E
t
E
Ei
E

EE
E
ri
i

-q
E
E

*E
E
g
.i
,
B
A

:E
=
b
-O

9-
!

\-
/

E
^
3
tE

ta

g
Eg
g
'r
E
i
a
a

5
;
it
€
E
€
E
u
E
5
E
ct

1E

Ef

fE
E
E
'q

€
3
E
P
E
€
U
B
A
EE
E
P
!
E
,
E
-
=
€
-
E
EE
€
I
A
H
g
E
E
E
EI
i
E
i
E
j
E
E
'
EE
a
;
I
!
*
*
E
s
fr
E
E
E
:
O
S
r
,
i
5
E
EB
i
.
#
F
E
E
E
H
X
d#

zE
#

Es
#
t
r
E
+-
)

|
otZl
-

N
ca

:f
,

\n

\o
AI
&z
cao\OqO
&z
&z
\f
,
caooOqO
o\
f-OOqO
OI
l+
{
r{
r'
.
,z
\oooOOqO
&z
&z
fr
.
\nOOqO
o\NOOqO
sFr
?.
)
LU
&z
f-
.o\
ea
\nooc'
i
&z
6t
\o\f
,
eOoqC\
ca
\of-OqO
C\
ft
.qO
.f
f
i
f
f
i
ff
i
'r
.
.

t
iff
iAt-
.'
l
r
i
l*
r
ri
-

.
..
,
d
,E
.,
(
)
',
.
b
X
ft
,
::
i
:
:
:
i
:
t
\
ii
i
i
!
.
(
A
,
t
ii
i
i
H
'
ii
i
i
(
l
)
r
'.
l
.
d
:'
-
i
F
l
.
ii
i
F
l
l
ii
'
G
l
:r
.
{
i
f
'
A
,x
,r
,
o
'
.(
J
.t
'
t
1
.H
ui
,
i
l
,
.
'
o
,
.f
t
,'
O
'
i
..

f.
l
tr
!
{
iF
{
ii
i
:
,
O
r
:i
i
:
a
:
'
i'
G
l
FA
&z
oo
.f
,OOolO
&z
O\f
,
ooO
o\
f-f-Oq
o\
\noo
.OqO
EQ
&z
C\
ca
f-cac1O
&z
\nf-
.
ooNc'
)O
.f
,
ooOqO
\oOOqO
q)
tr
&z
o\No\OqO
&z
&z
$ooOqO
ooooOOqO
GIE
&z
f-N\o.f
,9O
&z
@f-f-
.
ca9O
cANooOqO
\oNOOqO
a
&z
ooO.f
,qO
&z
&z
O\f
,o\OqO
oo
\ocaqO
{t-,a
&z
N\o@OqO
&z
&z
t.
oNooOO
f-coOOqO
N
0
,1
cg
*-
)
()
|!
:
(a
rOE/LT-)0e
iOI]Fr
Fd
!reA)-F]
,qf-
iaFdFAFTaHJFcF
ard,4H-,)oI
t
aIFrF{
l-aA\
l-
{
f.
]acFdE13aFr
l
IzcZj3cF{
U)a{)0<()patr
{
)-
{ad0)
nf)t-
,
(
cd
o<t-
'
{aado
lF
{z
\,
l-
r
()b{
'O
)oJI<aodo\Jz
*O
0)
'd
a0)&)-
{
()o(
'O
oaa(noa
QE
F4HgaodB
ImIc\
+l00)Lq)
+Jtr
f-
{
t{
'
roOHcn+,o
mL
I(
I
)
NJ
=
7\

{.
J
EI
A
-t
V
ri

\,
6-
.
3?
ts
o
.I
l+.
)
.-dxI-F(aAx.-cr
)
Ficn
{.
)()
l.
{e
trN
lr
l
l+
{
lr
r
{!
)
i:Hq)AI
ff
i
':
l
i
.
\
,.
4
D
,
.l
i
l
'q
)
,t
,
ii
F
l
rF
l
.
ri
,
6
l
.
*r
,
;
,a
,H.o{lE,
,o
,
F{
r"
'
l
r
J
'-
',
H
.
at
r-
i
(D
t
ti
a
.f
i
!
in
"
::.
j
&z
ea
\o\nqO
&z
ilz
oo
(nqO
c\
coO.f
,qO
€H

a
.E
c

*
E.
t
r

.
()
.
E

H
El
o

a
JJ-:
O9
a
-c
\
:
fr

Et
8S

u,
E
"
\
EE

IE
F
JE

\o

Fr
'
-
EE

€E
E
ts
,
EEE

t
8€
H
8
?f

E
9o
oE;

€
H
H
*:

E$
E
5g
or
EEE

E*
E
E
E
H:
E
;
FE

.E
E
g
E:
'

rf

d
9E

-t
r
=

o.
#*

fr

y
r
v
J-
i
ro2

EH
c
=,
8

.;
E

E
?
I
9'
=
-
E
'E
*
;

'E
!

n
E
H
T
BI
8E

EE
E
tr

3
c6
E

Fc
s
3
7?
_

E
EE

.E
=

E
.O
"
r
-
l

tr

.
O
E
H
EE

I
d
S
.t
-
,

:z

y
,r
,

.
tr

t
E
i
i
EE

U:

E
E"
.
=
;E
E
i
g
E
E
f
S
3
fr
E
E
'
E
f

i'
tu
.
g
_
o
E
€
6
8
=
H
H:

6
9
E'
d

.E
EE
E
;
g
J
#
E
EE
I
E
E
E
E
H
EE
!
E
5
E
E
E
Pb
H
€
E
#
E
E
E
il
T
3
:
;E
P
E
g
E
s
t
E
JE

E
EE
E
{
:)ol-
{ol-
{
adaotcdoac)F,iC)
$-
.€(d
t<oa>{
)<O:)o()dF1F{
l-
,
{
qi
{-
)
(oq)Nl-
{o0.
,
CootsE(t
l-
.
(.
)HhEq)E0)
-ou
\J.d()X
l+
I
o-oc€C)L{
()T]o()C)
$<
cCc00)
'a
oHodtso63oHo
UI

F
0)
I
EIzl

-,
\f
,

\n
c\

cr
)
d-0
&z
.t
\noogO
&z
&z
raoo
\oqO
o\
\oOqO
tr
!,
(e
ilz
Ofr
.
\of-qO
ilz
&z
f-NOgO
o\o\
cA
f-qO
--U
&z
oo
\nooooqO
&z
&z
O\t
t-
{\oqO
oo
f-e\qO
oU
ilz
.f
,OcaOqO
&z
&z
f-\oOqO
f-
.
caOqO
m
&z
oooc
\oqO
&z
&z
ca
\nqO
t.
n
f-OqO
r'
,z
o\Ooo
\oO
&z
&z
f-
t.
n
\oqO
N\n\oOqO
ilz
\o\nOqO
&z
&z
rnO\nOqO
$\oOOqO
.-z
&z
cnO.
.
.f
,
e"
)O
&z
\n
f-@ct
lnO
(n(nOgO
r-
-
oo$i
q)a
&z
ooONi
&z
ilz
\ocf
t
,\
oqO
\.
)
.f
,wOO
f\
0Hst
+)c)
It
le
(n
rd?1--,)^IJo3aIE<ri
t3aaFr
lAt-A-FI
1
FAFTdri
jF-
{cE-
.
{
U)
7AYaH-JoaaIt-
{
FdHeRfr
laeriFI
l=
raF{IzozIt'
rot-
{
ao{=orC)
-oatr
{tra(doa,
*l-
{63Prtra(c()a
{-
)
l.
rH0)o0
'1
3
(,JHa63o
0)
'(
,
aC)&oo{oaU)
cdO
tJ
.

tr

O\
A
cB
O
l-
{

-r
t\
A
\
J
\J

ry

r\
l
O
.r

'o
i
F?
t
r
^F
t
iE

*1
oa(dB
*)Oq)L()
+Jtr
l-
l
th
{
oco
-{cn
*J()
-F
{
)e
tr
t
r
tON.
t
r
7\

+J
ll
A
-!
V
l-
{

\/
O'
.
.
3?
-o
.E{-
)
.-A-/-=a/x.-co
-i
GI
*)o13a
trN
dz
am-
&z
amF
amt-
{
E
HTE
EE
€
sq,q

ii
E
tr

€u
B
a
;q

o
g
iN

a
E
.E

2
E
E
e'
s

gH
+
'l
?
c
o

o.
o
B
E€

E
H,
H
i
En

E
tr

cU
d
r
-
!

c)
*
€t

uE
<u

tr

t'
{

cE
'

ti
N
-E
3

8E
H
A,
$
E
E,
E

E
H
S'
E
'
Z

E
J
E
E
Et
r
E
Eg
E
E
E-
q

=
(d
P
s:

A
E
E
Ut
r
o
)
o
Es
€
.
g
.
U
'5

Aq
i
l
E
.E

E
C
i
"-
{
j
i
X
t
r
d
E
$g
€
E
E
€:
E
;
6
EE
;
i
l
E
HE

EE
Xa
.
>
rE

6
U
a;
o
-E

?
6
:
fi

+E
i
'
F.
/
^
r
o
t
r
O
\J
r
v
\
/
r
D-
P
AE
:
fr

EE
Er
E
€
€

a
:
-E

(j

E-
:
g,
,
,
q
E
g
-
EE
E
.
=
E

I
Eg

i
EE
E
;E

gE
E
#
EE
E
Ef
i
.
l
€
i
E
=
F'
=

E
o
o
-
€
2
s
uJ

+E
E€
E
E
E
E
S
EE
5
;
U
3
E
fg
E
E
E
E
E
E.
E

r.
E

EE
E
fi
E
*
,
2
8
f
r
:
E
.
.l

.
.
8l

-
c\

cf
l
.
t

\n
+)
lol
zl
tra
&z
RFAF
&z
Rmt-
r
RFAF
tr
ooO9O
RmF
.f
,
-qN
omF
RmF.
t
i-U
f-oJO
amt-
,
'
Oo\
("
1O
omt-
,
(
omF
E
&z
omF
\oo\9
omF
RmF<
&z
amF{
&z
omFr
amt-
{
&z
RmF
&z
omF
omt-
r
.-Z
.tcA=qO
eFAF
\oo\9O
amF
emt-
r
q)a
r'
,
,z
amF
r'
.
,z
anaF
emF
t)o
a-
AIJt{Fr
rc$+ro-Gfr
t'
r
,1r-
{a-
r\

tr
0.
l+
,
{
Gl

FT
(
+i

+)
qJ
2
aa6)
r<
.iII()
a-
of(Fr
tLr>(
t4FH
l,
n
tn\-
{
ro
rdt1--t)oe]aJtsF.
l
t3aAF{AAF{
FA
llaf-
lFl3ct-
(
U)E?lHt-oe
rf
,U)
j3F{=aaf-
lAeri
FA
l!
'
{ard
!zczI]3oF
+(d
F-
{OcdO
lF
<z
t1
Oo{
-do'
JU)
cO()
t1
O
'd
ao&C)b{
rOoaacOO\3a
tq)
ir
r
(
I-rdotieIU)Axo
.F
i+,
cn
l)
.l
dts
t-
.l
r
(
jo+)
6g
9t
Fe

rd
.d
E
II
]

FE
.l
E
id
!
I.
.
H

'-
F.
f

a)
\-
6g+,q)
\3a\/Ot-o
.F
(+)
.H
tH--
tr
lza-
.l
adcn+Jq)
r-a
-Fr
amF
&z
amF
amF
8E
g
,l
r
cU
u
)€
EE
€
r
ET
E
E
€u
B
a
';
q

o
g
;c
\

a
E
.E

2
S
I
g'
x

gE
E
$g

E
B,
H
E
E3

ts
tr

cg
d
l
F
-
!

o
*
€t

uE
<l
)
t
r
i
-
{
c
g
t
r
N
-E
3

8E
H
A
r
+
E
EE

s
:
S
'E
'
r
,

E
:
E
=
Et
r
E
Eg
E
E
E-
c

=
cd
H
-q
:
E
E
E
Ut
r
O
J
o
Ee
€
.
9
b
'.
.
.
5

Aq
r
-
i
E
f;
:
E
E
Sg
S
E
E
€:
E
;
6
E€

Xi
l
,
E
FE

EE
xo
,"
E

6
6
a;
o
OE

2
6
:
fi
.
p
:
E
S
-d

oJ
}
E

o
g
Tf
r
E
E
t
as
t
I
F
!?
E
E

E
d=
=
OE

3
E
rv

.U

.H

.J

J
E
9
B
EI
E
6E
X
E
E
}
E
E
=E

H
E
I;
.
=
;

E#
:=
e

=€
;
E
E€
!
'
.
6
e
:
_8
T

I
U
E
rE
E
2E
E
E

E
S
E€
i
E
s
E
s
,t
r
s
E
H
:
H
E;
!
Hi

?E

E;
*
EE
z
z
f
i
n
:
E
..
18l

-
c\

ca

$
\n
6l
zl
AI
omt-
r
ilz
Rmt.
l
Rmt-
{
OI
l+
{
l.
J
.
l
am3
&z
RmF
omF
sFr
RmF-
{
<.nc\
RmF
omF
f.
)
trU
amF
Oo\
(t
)O
omt-
{
amt-
,
'
EU
RmF
\oo\9O
omF
amF
q)m
omt-
r
&z
amF
amF<
cgE
omF
\nct
)
omF
omF
O
emF
&z
amF
omF
rt-CN
amF
&z
omF
RmF
t\
ca-cg
+Jq)
!le
a-'(
L
dxt-e
<taFlFFd
l-
leArcaAFr
lEaFiIzczFl
Frot'
r
+60
o<acd
(.
)
l-
{z
rn
()a{
rdioFlacdo
l!
-
{z
f\
0)
'O
aO&C)OI
'd
oaacB()
\Je
qE
Al<fr
ts
+.aoLr€)
{.
Jtr
l-
{+{o0Fr
.
i
cn
+Jc)
nA
L
lG
)
N.
E
7\

+)
FE
i

A
-\

b/
f-
{

\/
C0

'-
_<
3
ts
o
.r
(
tf
.F
l
dts
l
a,)Haats
.-ct
)
-cn
{-
)
(.
)
\=
{a
trN
&z
amF
&z
amt-
{
amt-
{
oU
&z
RFA
t-
{
ilz
oFA
t-
r
amt-
'
{
-ts
ta
&z
cmF
&z
aFAF
amF
tr
ts
{a
caqc\
amF
&z
omt-
{
nmF
I-U
&z
omt-
r
&z
omt-
{
amF
na
ilz
omF
&z
oFA
t-
{
aaF
&z
oaF.
&z
omF-
{
RmF
ilz
RmH
/,z
omF.
(
oFA
t-
{
.-z
o\
v"
)
oo
RmF
NOqO
amt-
{
amF<
c)a
&z
amt-
{
&z
omF-
{
Rml-
,
(
0f{6d
{r
)
t<oHe\oo\
rHoGLFr
f\
=
Cr
)

!.
(
-
-
6d

tr
EL
:
-L-E
+j
t1
ts
aq)bI
,;
f(cn
{r
)froIt
{eeel
\f
,
0Edx,(-oe
iaF1E'
tHt3eaF4aari
!aEraf"
lJFloF.
l
ardd)i
(
t)oe
tf
,
OJt-
{F{
l:
{aardaAF]
FE
tcaF{IzczIFroF.
(
++)
tr(cPr
l-
(aCC0)a
t-
)
(.
)o{E5Jl-
{U)
(ooa
la
}
o3
'o
a()&Li()c{oaCd
0rOo.
l-
{
0<l'
<o63o
|<
-
{z
tq)
Fl--16ots
{aIU)Eo.-{-
,
6g
{.
4
.l
a-H
.'
r
lIc)
{.
)cg
rn

*,
IEmE
.{
E
F{

Fr
r
JT
l^
A

{r
H.
-
-u
)
L-
cg
{i0)
biact
)
d)ro
.l*.
J
.r
{
dH-l)
l=
,
(adx
'r
i
a-cg
*r0)=a
-3
#.
i
r
.
!:
i
i
:
i
;
*
iJ
i
)
ff
i
:.
.
d
,:
.
:

.i
ti
f
f
i
',
O
lrcr
3
{.
,
lr
,,
,
cErar':\oO\
-
.
*{o>6gLrHj-.
.d
.
-H
,,
i
.
.

'Fh(
,h
l
t
,i
i
5
l
'H
:
r.
F
l
.(
l
)
,
:i
.
,a
\
:u
,
Ii
r
.
o
,
c0
*Jfi
-
,-
iV
!=
{
,af::
i
'
.
:
:
1
1
1
1

"
Gr
l

,.
G.
;
,
,
'
'
Na
$4
&z
amt-
{
r'
,z
omt-
{
RmF
6FhH
€S
8
i
E3
t
o\
o
-
{
-'
!
-
\
/
-
-
v:
i
EU
i
,
H
€g
P
s
";
E
tr

b
tr
?
i
E
i6
c
d
U
Cd

.o

=
?,
q
h
.i

EE

e_
B
Es
s

f
E
iE
i

I
.E

sE

ai
E
EE
H
f
.N

_E
.
g

g
E
i
?E
€
E
s
*i
:

a
s
E
N5
"
*
{
;
:H=
6
F.
E
H
.
g
ts

EE
E
T
E
E
Si
J

E
E
i
E
u
E
;
to
g
O
Eg
€
q
:

H
q
E
H:

A€
E
*;

EE
E
-o

.t
r
(
EE
€
;.
p
;
,
r
;

E
g
EE

2E
,
€
E
uE
A
E
E
l+
!

6
o
OE

?.
q

S
'c

u,

.i
E

E
E
ge
.(
,

OJ
,
E
E

B
c)

I-
(

=
-Y

O
b
At
i

ts
E
o
E
H
8€
I
.
4
3
Fe
=
H
;
i
f
rE

i;
E

f
E.
g
E
.
=
E
r

F"
E:
l
a
E
f
o
J
0
6-
s
i
X
g
E
\
f
,
f
tr

o
T-
a

cd

cs

,\
EE
E
E
i
E
E
'
EE
€
E
*
E
E
-g
t

E
U
E
r'
i
-'

9f

^
B'
O

cg

i
El
E
g
#
E
g
EE

8.
E
S
E
E
.9
.
E

I
E
H
A,
.
o
3
EE
F
E
E
;
E
#E
f
,
z
#
f
r
9
..
r

O
8l

.O

r-

oo

O\

t-
'
i
EI
zl
al
&z
RmF
ilz
RmF
cmH
at
l+
{
ET
&z
Rmt-
,
'
&z
RmF
omF
E0r
&z
am-
\nc.
;
amF
RmF
?.
)
liU
o\
-t
:
.f
,
amF-
Ov"
)O
omF
RmF-
{
15U
N.f
,qO
RFAF
NOqO
amt-
<
omt-
'
r
q)
FE
&z
apaF
&z
RmF
amF"
c€
FA
&z
omF
rn\
omF-
omF
O
&z
t-
.
1mF-
.
t
/,z
aFA
t-
{
omF
A-a
&z
RFA
F.
<
&z
ecaF
RmF
6t
a-cn+)q)
EIe
a,tv/)<I,a^o.
fOr.
l3IE
t
Heafr
laaFd
tr
t3ardJFoFr
a
rr
{
vt<FI=o
!c
aIFrHl=
ieaHRaFdEFTeF{!zozF]-cFr
+tr630rU)
(oC)
ar
(.
)e[
'1
3
)ct
JU)
ct
d
()a
rr
-
)
()Eao&C)b{
()oGp<oot-
.
o.
,
(U)
(o()
tJ
.

tr

O\
n
od
o
lr
-
{

t-
7\

A
\J
\J

l*
r

r\
l
Q
.E
'
d
F?
t
r
.JE+
oadB
-t
ImIc\
|)U)Q)LIo
'+
,
a-t
F{+roadcq
:)q)
e=
Fa
L
r(
D
N.
t
r
7\

|)
l.
r
i
A
-!
V
f-
{

\/
CQ

-,
3?
ts
o
.-
{.
J.-Ax/-
l=
{adH.-O
t-
l
cgPq)
!te
trN
H
€E
E
d
E3
5
O\
o
-
{
-'
j
5
o
\
\
/
f-
-

Et

i'
tr

€r
F
i
'=
J

g
E
aE

IE
F
FE
E
B
8;E
EE
i

H
t
fl
i
u
E
ot
r
t
i
c
o
H
E
.X
g

I
E
e
;
E'
f
;
E
s
*i
:

a
s
E
tE
E
s
.
,
:
g'
E
.
9
r
j
E
E
-E
E
B
E
E
s'
i
EU
o
Eg
€
.
:

H
q
E
E:

A€
r
g{
E
g
=
E
'o
.
=

cs
-
-
'

-
g
HE

zE
E
.l

EE
*
E
E
o
O:
:
n;
,
E
E
E
F{

/-

()

tr
E

A
F
i;

Eg

H
bA
tE
E
€
I
E
I
;
iE

EE
F

I
EE
F
EE
A
E
€
O
J
U
;E

E
EE
E
S
i
E
E
E?
E
E
E
€
E
:t
s
g
;
f
e
=€

uE
€

=
I
EE
E
E
E
#
E
iE
s
r€
E
H
E
e
=
tr
.
E

r€

tr
E
P
-#
E
l
,
z
#
f
r
9
..
r
t
'
8l

.O

f-

@
o\

,-
{
6l
zl
oUttsatr--Utr.-zq)O
atr6n
+JL(or=
ra\oo\cqLH
N=
ai
-
-
cn

Fr
E;
+)
d)rq)bI
,;
fi6g+,L
.oraa(,
\
a\N++ro
QE
iHgadB
[a
IoIc{
t\ao)
--')EoEIrt
)
tro
.!
l{.
4GI
.l
.
f
.--tsEI
.-F]c)
{r
,GI
\l

tr
ts
l

lc
C{
I

E
r-
l
l

E
Jl

s
ca
l

.t
s
<l

'
fr
l

a
r
a-
cl
+,c)
tie\r
r
-a
tro
.I
l{r
,
.I
l
AI'l-lrztr
.-
l
a
-l
GI
*,c)
ts
(e
ra
l
t-
l
ti
r
q
l
<t?tEt
l
.0
1ddfr
lOIEI
rl
l
ci
l
IIEIOI
UIEIol
FI
+,
*
i
,
ilz
-{
lOIolql
O1
fl
ilz
OC)qO
&z
+-
)oatol-
.
(gao(ooF,iot<UCg
t-
.C)o>,
1
(.
)
5'c.
)o(€E
,E(goNt<oa,
(ooL{B€L{CgL0.
)
?a€O
'o€C)
,oH:a(.
)
'o(.
)x
lr
E
o-oo:)
'o
C)
L"0)
'1
,
aLao()
(.
)
l-
.
cg
cOoi"
'
ir
a
6
0Aalo*.LiFa{o+{
+-
)
tr
rf
a
Ba63
t)q)>.
F((.
)
F1
t-
lF
.
.l

.
rl
al

al
C)
l

a)
l
EI

EI
zl
z
l
ooA>aF{
cuaoal-
.c)
{-
'
idt-
ioUoF(,()
*r+)e4F'aC)
Eaol<€oaoA(,
)
l-
.
(.
)BC)
L<o:,Bok(.
))Ea()
r'
,
Fa0)OIEoa?1
.;cd+)
(.
)
74HL.
.o
.,
8
al
-l
cr
l

E
El

€
-
I'
F
a
=l

o
ul

E
>l

I
€l

'E
ql

co
EI

F
ol

=
-o
l

d
Ht
r
ts
a
l

.
-t
rr
.
l
lAI

E
zl
E
ol

tr
-q
l

o
=l

o
.E
t

s
'o
l

=
€l

E
!l

I
=l

=
NIIc\0)
I(cF?1T,O(oa
'.
O
60
:)oL{c,0Lro
.F
(
:)(nL{
IA:aO(J?1oUaCO
5)OEJ)gOI
A()
-o
rEl-
.
(l
)
ts
{
cdatool{o{-
,a)
l.
i
:)Ac)
?l
ra
t
B(,a€:r)o0OOq+.
.t
-
,
.F
(
BEo
t,
E
l-
.
(J
t4:t60
+-
)
tro()
?ao(€A:ao
.O
oa63m,r
;
osa,EOFc.
;
OJ
,oC€a>lEOEoLr
a4>rocd!r
l.
r
l-
.€Hoao(.
)o!o
'o
Oa)oI<C)>aOa0HFIat4F,
lxCd
at
<t
/z
FaOOoO
dz
ilz
OOqO
&z
al
HI
Hl
EI
F{OO
&z
Iz
OO
&t
zt
sl
ti
l
zl
(f
)
(f
l\noqc{
ilz
\o-f
,
co€(\
I
f-oo
;-
'
{oO]
&z
Fa
l
LlUI
dtzt
f-\oooO
&z
.f
,
ooO
\oc\OoO
ilz
EU
&t
zt
o\
00Nc'
lO
&z&z
€l€lNI
eo
l
dI
El
E
El

zr
€)
tr
&t
zt
&z
&t
zt
GI
na
2t
CAo\
c.
)9O
&z
--
]
€l
r-
l
ea
l
\o
t
l
dt
l
=F
a
zt
\ocaqO
2t
*
rnOO
zt
Ea
zt
ilz
&t
zt
&z
r+ee
)
(*
)O
&t
zt
rD
l
-l
si
l
*r
l
€)
t
>t
F4U,
I
EI
-lrlal
l
JIolol
\r
i
.'
l
.l
\lal
.l
l<t
t-
l
El
l
>tol
rd
l
alal
Er
l
mt=l
kl
l
JI<t
t'
(

I
ol
t-
l
,-
t
0E-lIrl-,otl
\,a-lErHfl
feardA-tA-Htrrtzrd
IzozF]FcF
\n
l
-[
l
alad
!lO.
lOI
-l€lal3l
f&
l
tr
l
.
-a
l
-l
F{
l
cd
l
r)
l
(l
)
t
=l
qtN:)t4Hcd
1
o'
.
1
.E
l
-l
Fa
l
cd
l
:)
lot
>t
t1-i
l+J
l
?a
l
Fa
i
(L
)
t
b{<l
'o
l
.
r<
l
!,
l
01
.H
l
'l
l
.-
4
1
ai
t

I
.d
l
-l
cg
l
!r
l0)
I
>l
.'
o
l
=l
EI
.i
l
alol
el
*r
ldc)
I
o{
<t
'd
l
.
-a
l
:l
ol
al
tr
l
.
r-
a
l
-l
cd
l
+J
l
'E

tr
O
\
n
cu
o
z\
A
\
/
\.
/

H'
r

(r
l
Q.
E
o
F?
t
r
^iE=
)
t<HO+)acd
\c
!mIN
f-
ImIN
+)0€)Lq)
:f
g
lr
i
t+
roa-d*r
,(u
"r

E
tQ
l

L
tt

€)
NI

E
r.
i
l

5
F{
l

r-
EQ
I
-
<t

3
E-
t
l

o
-
.E
l
t)
.
lr
lE_-Etr
.!
.
U)
-cl
*.c)
rl
ia
trN
tt
i
"
'
!

.i
!
:
'll
:
.
.
.
l
'.
.
.
1
'
!
i
l
i"
f
i
,
.
t
i
if
f
i
h
i
i
t
o
r
i
ff
i
i
f
f
i
dtzt
fr
.c\
l
\oqO
dz
ilz
f-
.N\oqO
&z
0isCB
rra
.F
(
;1
*a+.
,
l-
i€q)€F{
otr?1Ho:)c,F.L.€tr0)
t4
*.
4:)ooOo€o+-
,€0)a)()L{0)Bao-)COtr
ts
a
J>r
l-
rxCU
Eio:aq)
,o
t,
E
L{o?1Cd
:)Lao()
l-
ro(,
)
L<
+-
)
t-
]c)
*a!,
>aO(t
)Etr
,1ooOoOa
+.
{-
,>€o
tF
(rl
{
t-
.C)Al-
l(!
rrd>ao()
t4
O()
-c
d
(t
a
La
a
U)
>ao:)coq)
0.
)=COa(!
:)otr
€ao&?aF40)>oL{a>to:.C\
l
AHF'
lr
-oo?1
ts
l
EJ0)
l-
.oootr:,ot-
lFaI&z
.4
1
co
l
EI
;l
Fa
lcd
l
el
(l
)
l
>t€l
a)
l
'o
l
'o
l
a)
I
-o
lEIHtr
lol
zlC)
l
-c
l
EI
-u
l
0)
l
€l
!l()
I
tr
l
-l
.|
-
)oAtlBEtrCB
-)
t-
.0)Al-
{
a
'o
oEEos6
aL{oc4
:a3l'
-
'
F'oA
r-:,dL.
.
r-
a*.:,>ac,
:)OH0)F
'r
;
lOI
!)
lOI
zl
AIa
&z
oo
\oOqO
&z
il
tzt
oo
\oOqO
&z
tr
&z
OOO
&z
&z
OIqlOI
&z
-l-U
&z
FIc\qO
&z
&z
c\qO
dz
oU
&z
OOOO
dz
&z
OOOO
&z
tr
&z
c.
r
]
F{
iOI
&z
Iz
cnO]
zt
&z)
caO.f
,qO
dz
&z
ea
l
OI
.+
l
qlOI
&z
ilz
$qO
&z
&z
.f
,qO
2t
.-z
ilz
$o\c\
c?O
&t
zt
ooooc\
t
(t
)O
fr
.OoqO
&tzl
(l
)a
&tzl
El
l

zr
il
lzt
5tOIqlOI
&t
zt
a
-l
GI
+J(l
)E
,^
lalEI
-lIIrl-tol
OJ
\-
i
ct
)
l
il
F-
(
l
rd
l
EInl
Er
I
l
ntcl
fr
l
l
na
l
EIHI
''
'
l
-t<t
F{
l
olFI
tD
l
EI
tr
l=loleal
-I
l
<tH]
El
l=lol
fr
t
l
alal
rd
l
FA
I
=lHztctzl
il
tr
lCI
FI
3lal
bdEI
O.
l
a)
l
r<
l
-o
l
.
r{
lal
EI
tr
l
.l
l
-l
-a
l
cd
l
!)
l
+t
..
i
lEI
.
Fi
lCB
I
O.
l
tr
l
!lcd
l
6l=l
r)
l^i
l
!)
ltr
l
o)
l
od<l
'c
r
l
r
r{
l,lot
.d
l:l
.
Fa
lal
t-
.
.
t

I
(o
l
+)
l
^t
o
r
l
€l
.-
l
al0)
l
elEIG)
l
b0<t
'd
l
.-
l
-l
ol
al
tr
laC€
I
:)
l
()
l=l
qE
F4F,
igacd
O
I
(a
)
-lHo
.E
l
i.GI
l.
.I
l
-E
.I
l).
]q)
l
n&
ts
l

e
e.
i
l

E
r.
t
l

Fr
JI

E
ca
l

.E
<l

!
fr
l

a
L
!-
cl
t(u
ttz\,
-a
Eo
.-
l
{r
.E-l-tr
.-
l
a-di.c)
Ttz
-lH
#t
l
i
l
'
r
:\
'
.
f
,
,
:i
i
i
i
#
-
i
zt
*.
-
r

I
OIOIqlOI
r'
,
|
zt
&t
zt
-r
lOIolqlOI
ttzt
-)
lol
tr
Ial
cO
l
Bl
r,
l
t-
t
l
FI
ttclol
.
r<
l
+-
r
l
()
t
0.
)
l
:)
lc)
I
-1
lr
l
tr
lOI>t
c)BoA
rr
.
t
aEC)
:)o0)
:)(.
)
-o5'oFa
:tolic)>&z..
L
a
>EC)
J4Lc,
c4HL.aGI
:.O?a
ItLrtoL{
+JF4()OI€ag)-
l
}.
aacr
l
:)q)
t{otlEJ0.
)Eol{0L.o+Jcu
)-
.
Ht{€L.
.F
a
o?1
't
,
(.
)
5)Lo0oL{-
)ol-
.
I
?;
l

&
el
z
olzl
r
5)
lol
tr
lolLI
(B
l
al
a)
l
JI
cd
l
>l
()
I
?a
l
t-
a
lFI
.l
alotkt5l
9t
(o
l
klototr
l
Fa
l
(t
)
I
5r
lol
()
I
cg
1E]
,E
l
!)cg
l
c)NI
l.
{ooCd
:rotrBtt<CBLrotr
d€o€'o
q)
-o.1h(.
)E(.
)xtEO-oo€oli0)
'o
atdts
ao()Ol-
.
c\
l
CO
:)0)Hnat1Ho5)t<i{ta-
l
)<
lroF4-:)?1
Ita4-5)BaCt
,
!)a)>{
L.oFe.
i
'd
l
0)
l
EII
F'oat
Fa
l-
.L-o
(.
-
{
l-
i0)
-oct
3CgGI
()?1
*{:.?l
)tL{o
(.
H
0)
'o
CB
e4H}.
r
0.
)
p?aH(n()
)<A)tr
t{oL?1-o:,trc)
cu
(t
,x0)
+,
toL.o5.c,
(J
rE:,L.0)Ea{
()8()trg
,;
l

I
Fl
lsl

E
ol

)
*l

E
PI
Hol

-t
r
>l

:
EI

F
EI

E
ol

:=
-o
l

-H
EI

;
Ht
s
8E
zl

3
€l

I
EI

E
'o
l

.=
€l

E
=l

'1
,
()
l

o
=l
=
.
lc
o
e{IIc!osCI
,F?aF'
'1
,
o(o),ocl
:)ol-
.
(taL{o..
-
)cl
Li
:,
t<Hoots
ioUacl
+JOLr
azEi)c,bI
Lr0)
,.
o
tEl-
.otr
.F
a
c,
5)?ao()AHo0)k:ro?1
1-
)BCJ
+r
)
rl
DBa)JatA>ao0OOtr
)e!
(4
.a
-
)B
'o
o
r+
E
L{
()Lr
co
:)L.o()L.o5)(nAts
aoT,C)a(d
FA
\o
",

'l
:l
\lEIol
dt

.E
l
f,
!
l
ad

',
;
l
,H
l

sl
EI

EI
Ht
I
El

€l
HI

sI
EE
I
3J

.E
I
El

;l
?l
g
El

el
El
i
l
€l

El
El

€l
EI

EI
El

il
re
l

El
fl
E
l
$E
l
EI
H
I
#l

{l
sl

nl
t<o{-
rGI
liotrol-
.o?4
{-
.
1o!,Eao€
ol
il
tzt
O\
l
ololqlOI
&l
zt
dtzt
O'
l
OIOIqlol
dz
al
Fr
l
t-
t
l
&t
zt
c!
l
.,
.
)
l
-,
1
2t
dtzt
c\
l
eo
l
zt
EI
0r
l
dz
xi
l

zr
rn
l
eo
l
oe
l
el
l
c!
l
c\
l
otelol
&t
zt
r)
liU
ilz
Fl
lel
rc
l
-lol
il
lzt
=l
l

El
l

z,
II
IJU
&z
OO.c!
c'
)O
ilz
ooooc\
c'
)O
=l
l

z
q)E
d1zt
ceOoqO
dz
&z
ea
l
olOIqlol
&z
cl
tr
i
1r
'
t
r
t
;
.
:r

+l
'
I

'
OI
9l
.l
l
at
r-
l!l
{l
)
l
Ff
l
dEI
;f
i
1<lJal
lr
lolGI
.-
l
6l
3lEI
Iol
ulEI
1'
0
t{
l
ilz
ca
l
or
l
cn
l
rO
l
dl
&z
€fr
.ca9O
l.
n
F(OqO
il
tzt
OI
<l
/z
v?
l
r-
l
cn
l
€l
dz
&z
in[\
-
cn€
&t
zt
E]al
dz
ln
l
tloq
l
ol
dz
ilz
tr
)$ooO
EI
N
U)
al
c+.€)E
U)
,1
5
A-a--oa\,
?{0F]FETERfE
loafr
l
trFterd).
fFot'
{
aE-t-l-oa\,a-]Ff.
l
!renEr
loaf.
I
tr
fr
1
Izoz-IF(oF
+lal
ox,l
O{
l
ar
l
-r
l
,.
.
o
l
.
Fl
lal3l
fr
{
l
tr
l
r
ri
l-l
ct
l
elG)
l
>l
hlaJ
l
tr
l
.
-a
l
cd
l
o.
l
tr
l
'F
l
at
(!
l
a-
)

|
c)
I
>l
+)Hq)
oX<I
'o
l
.-
l
alol
.
r{
lJI
tr
l
.
ti
l-l
-l
c0
l
!r
lc)
l
>t
oto)
I3l
'o
l
.;
f

l
al
0)
l
dl
*.
1
tr
l
q)
I
b{
<t€l
.
ri
lol
al
tr
l
.
Fa
l-l
F{
l
cB
l
-)
l0.
)
l
>t
I,
L

tr

O.
,a

c0
0
-
Uo
.
X
o
.2
'
d
F?
t
r
-=E
'-
)
trC)ad
oo
!oIN
:)a(l
)Lq)
{j
tr-lr
i
oa-cl
+f
ol
g
-l

e
Cl

b
^l

f
F1
l

c
FI
I

-
El
-
r
r
*I

.E.-E
.-
l
-tr
.-a,
-cl
+,€)
Liz
flNI
i-
|
'
r
l
,

'i

:1

,
',
1
.

-
1.

d'
I,
f
C
r

l:
r
'x
,
i
}
;
,
r
f
i
i
j
,t
l
i
i
,
$
;
i
r
i
4
Wf
f
i
,
id
l
g
,
f
i
.o
t
II
.-
l
6t
rt
l}I
.3
1slE!
I
t.
'
S<Idf{
lol
:E
l
l
OI
Itl
9iEi
l
ol
ulE!
l
,F
l
&z
oo
t-
{O
&z
&z
€F{O
&1z)
:)oHoL{daot(noF,iol-
.):.Co
l<OoH0)
:)OocOE(t
r
:,Cu()NL{oo6d
rl
-
,otrB
rO
LrCo
troAt{
'd
(.
)
'o.O
0)s)-
'
0)Eox!E(.
)so*.
JEc)
l-
.o"O
.F
l
U)
L.o()0)
l<(g(l
,
!)oFl
l-
'H
na
?aF'o
'
tr
agtc4F{
:r
l()
rl
aar
ltr
.!
a
A
*a:,Bact
l
:)o>aLr
oo
l

q)
al
E
sl

H
olzl
;
:)otrU)
(€B:rH?1FaoOC)
5)(.
)€l-
(
(.
)
()Bod(.
)
+.
)oo:r0,
)€.l
-
)o?a()
t-
(c)>&z!,BEC)
J4l-
.
CdHaG,
+)C)HBoL.
.0)al
t.gJL.
.;G,6l-
.o
.i
l
t
cr
l

'u
?l

o)
sl

E
EI

E
>l

r
EI

.E
OI

t€
EI

E
-o
l

qY
EI

.E
rf
l
o
nl

tr
2l
r
d
'.
E
I

E
+-
r
l

O
.E
l

s
€l

=
€l

H
!l

I
ul

=
dl
a)
l
rE
l
.
r{
l
()
!
a)
lol
'l
\oL{
q,
)
trcd
:)tro(,Lro:
1.
.o:)C\
I
l-
.C)AHO?1Ho?1
r-
{5)o:)€e()p
EI
al
&z
C\OqO
ilz
dz
c!
lOIelOI
&z
tr
!(z
ctzt
o\OOqO
&z
&z
3l
l

z
--U
&t
zt
O\
l
rn
l
OIqlOI
&z
&z
O\
l
tf
r
lOqlOI
&z
oU
&tzt
r-
{

I
OIOIOIdl
dz
ilz
OOqO
ilz
tr
*t
(r
t
l
c{
l
oo
l
NI.t
OI
dz
zl
ln
l
c!
l
oo
l
o.
l
l
OI
&z
*l
OIOI
-r
l
-lOI
ilz
ilz
OOFtO
&z
dl
z)
$lqlOI
&z
dz
cac\
t
rf
,qO
lt
.!
tz
lt
O\
l
ol
co
l
c1
l
OI
ilz
oo
l
oo
l
c!
l
("
)
l
OI
t-
r

I
NIOIqlOI
2t
c)a
dtzt
O\
l
tn
l
EIOI
&z
*t
O\
l
ta
r
l
-<
lqlOI
EI
a-6l
+fo=a
^roEAI-l-oQ\,O'JErHEoHRRHm:r
{efE
l
Fl
Frct'
l
(,Etr=oOl
\r
taJHfr
tEleofr
loofr
l
trLr
i2r{
IZozFlFcFr
il\l
ala{3lEl
(l
)
I
-a
l
-o
l
.
Fa
l
-a
t
,l
Ir
{
l
tr
l
'-
l
Fa
l
CU
I
+-
)
l
(L
)
t
>l
clNl!)
ltr
I
.
r-
t
l
cr
l
0.
lH
.-
l
al
Fa
l
cd
l
:)
lol
>t
alNl+r
l
tr
l
c)
I
o{<l
€l
.
Fa
l
,I01
.
Fa
l
rl
tr
l
.
t-
.
1at
t-
a
l
cr
r
l
!)
l0)
t
>l
nl
\l

I
0)
I
JI
'o
l
.d
l
alol1tr
lol
ox<t
'd
l
.
-r
l
-lol
al
tr
l
.
F{
l-l
-l
cd
l
!)
l()
l
>t
QE
/L.gacdB
o\ImIc{
a*r{Z,
il
t
il
$
If
i
t
r
f
r
F'
?
i
l

t
H$
ri
l
ilo
ff
t
$
H**
I
ili7,Y^uc4.
,.
R
.
r
^
$HH$
_
n$
oDx
F+4.I-!
ri
l
Io**
$r
I
I
.!$E
!
ilr{
r+a*t
$r
+o
J*o
s*6orI*xr{
ta
h6F{
.
B'$
-!Hx
cNs
x
Fl
.z${
$n
CD
.d
oP
tt
f
i
r{
i
'*
o<DoD#
H*>1
.
r+
ot
F+t
s
oil
2Ih6r*e,*6
$r
q*
rl
.1s
ch
"5ch
<D+"
cn
IA
I+
t
i
l
o*
ZU$+
e*el
t
a\oeN
+!A
)
oD
tr*H*{r*o
$$
E
.r
h
lr
t
:+
t*d
dt
.
xs
ct
tx
$*
*
$+
i,oilHx
HHxJfr+
fi
$
&I
.
t+
a6
.a
a
)
rf
i
.$dFt
lJ
-

tr

O,
.i

co
o
l-
{

Ft
7\

A
\J
\J

H
,\
I
Q
.E
'
d
F?
t
r
-3EhoacB
fi

-t

*'
.?Fr
Izlr
l
tr
l

H
Ht

a
I|
E
zt
b
l.
{
l

\
rr

t(
l

A
tl

2l

xE
fi
I

EI

E]

E
nq
E
HI

5
il
l
rEt

gFr
l
HF.
i
I
HE
l
E
I
L.
l
0)
l
EI
or
l
EI
f,czlaHdI4
4i
l
gH
I
fr

Et
n]

$E
l
z
r
3l
E
I
oo
l
>I
!l
!t
!t
FzJJrdarofrEr
rl
s
!t
il
!l
!l
Ifr
1oolra
rl
!l
!I
!!
il
ldFail)E
Fl
s
$l
-.
:
l
ol
'+
l
pr
l
.q
l
oI
!l
hl
-laoJtrXrd
El
F{
l
olEt6l
FI
!t
!t
!l
Fl
rdootte
NI
>I
\o
l
>t
!I
!I
!l
FzH()
El
s
OI.l
\O
l
€l
r;
l
f-
l=l
OIol
rc
IJ
ololOIJ
OIol
,?
l
el
l
rdEF
oi
HI
lr
{
i
HI
HI
)+
{
l
EI
olEI
<Iol
Fl
l
azo-lazrd
Iz-a
Fl
s
f-
l
\o
1
a
$1e!
l
f-
l
-q
l
sf
l
ol
l
O\
l
od
l
or
l
OI
ol$l
a"
'
,
1
OIol
$l
.4
1
olol
,+
J
c.
r
l
;r
t
G
Fl

rd
UI

E
zl
a
ta
l
z
Jl

=
qlFI
oq
l
ro
l
ot
l
-lnl
oo
l
-lnl
oo
l
-r
l
;l
oo
l
HI
EI
I
EI

E
stol
-q
lol
tr
t
ql
.t
l
EI
.n
l
nl
'-
r

I
-.
:
l
ol
cn
l
-r
ldl
ea
r
l
-,
.
:
l
ol
en
l
-]
I

FI
t,
I
t
z
t
ol

h]
ol
e
l
>t
<
t
or
l
>I
=l
l

=l
$e
t
:l
lBl

<r
{l

or
HE
I
zlOI
:r
l
!HIBIEI
EIOI
>l€l
.E
l
dl
'+
l
FI

EI
EI

EI
alLI
0)
l
tr
l
.
=t
l
cr
l
l
5r
l
tr
l
EIelOI
FI
al
l-
.
1G)
l
.E
t
Gl
l
EIOI
UIrlFI
al
tr
!
c)
I
.E
l
cd
l
9ltr
tol
()
Iclol
FI
QE
t4Hgacd
ts
IUIc!
aZo-Flr
lz)=azt.
l
t]Hil
t-
lF
N
t-
l
F\

lr
l
-dF
Fr
U
F]&tE
(czo-r
i-
(
ts
l0oFr=aoU
Zol-tr
ts
laoei
tt
lzoU
oo
6
0)N
tJ
.
,
,
oh0)F
ooat-
iocdooo
o
'oE)ao
'5-.
o

'd
e{
tSH^3
r
oc
oHU5s
=OU
.r
;
E0
)
5E
aNXc
^-
C
d
E.
i

C)
ro
J8s
ca

ca
er
)
,

oo
iJ
I

N
EIxt=l=l
cd
lbl
5l
o€N
'o
cOOJ
dEoF
d
ho)F
Ualzzc\
l
\cUa'
loz0)
t-OC)o.ot-l-I
\o
6
=1
:
Nil
ut

t.
,
gl

6
Ol

f-
zl
;
FHlr
r()F.
l
l{B
aCd
tiuol
r.
)
\o
oo
[n
bI
[-
-
\n
boOf-
boOca
E-
rZF]zc0racU
.oO0al-oat-
rENN
0)bo
t<dU!oA.A.D
ob{
l-
r
CC
IU0)dEot-o
obo
t<CdUC)>J
Obo
l-UcdOc,
d
-o
()
c\
zo-Flizpl-a
l-
.
cdLooIN+c\
lz
tJ
.

tr

O\
A
C'
3
0
l-
{

r-
Uo
.
.
X
O.
2
o
Fp
t
r
-5EhOod
NI(,t
6l
t
)-J
FJEJ
g
A
o
o
o
TOCDF
Security Procedures
June 2009
ATTACHMENT 4
SECURITY PROCEDURES
Attachment4-Page I
TOCDF
Security Procedures
June 2009
TABLE OF CONTENTS
TABLE OF CONTENTS
LIST OF ACRONYMS
4.1
4.2
4.3
4,4
4.5
4.6
CFR
DCD
Code of Federal Regulations
Deseret Chemical Depot
SECURITY
GENERAL SECURITY PROCEDURES A}tD EQUIPMENT
TWENTY-FOUR HOUR SURVEILLANCE SYSTEM
BARRIER
MEANIS TO CONTROLENTRY
WARNING SIGNS
LIST OF ACRONYMS
ATLIC Area 10 Liquid lncinerator
GA . Tabun: dimethylphosphoramidocyanidic acid ethyl ester
L Lewisite; dichloro(.2-chlorovinyl)arsine
TOCDF Tooele Chemical Agent Disposal Facility
Attachment4 -Page}
TOCDF
Security Procedures
June 2009
4.1 SECURITY [R3 15-3-2.5ft)(4): R3 15-0-2.51
4.1.1 Security at the Deseret Chemical Denot (DCD) leeotC4eeele
shall meet the criteria and standards of the Department of Army
Regulation 190-59, "Chemical Agent Security Program." This regulation specifies criteria and
standards for the storage, handling, and movernent of chemical surety materiel. It specifically
describes the contents of physical security plans that are required for installations that have a
chemical storage mission, requirements for perimeter security and storage structure protection
systems, security procedures, requirements for security forces, and standards for physical security.
The stipulations of AR 190-59 are more stringent than the security requirements set forth in
R315-8-2.5.
4.1.2 4J1-In addition to the security procedures in effect at EG&G operated facilities at the DCD
@, the DCD installation provides overall security. The Chemical
Surety Restricted Area..t0C..drca1 . located adjacent to
the facility has a security system that complies with AR 190-59. All security systems are in full
effect during chemical demilitarization operations. The unclassified portion of the various security
systems is discussed below. A map depicting the location of fencing, gates, and warning signs for
the OCDF)andArea lO.andtheatheperimeterof
. the Deseret Chemical Depot (PCD) is shown in drawing TB-16-C-2,which is located in
. $ttachment 11 (General Facility Drawings) of this Permit. These systems will prevent
unknouA*ng entry into the facility and minimize the possibilityfor the unauthorized entry of
persons or livestock onto the facility by use of the following procedures and equipment: (1)
fencing around the entire facility perimeter; (2) 24-hours-per-day, seven-days-per-week
surveillance by armed patrols; (3) warning signs posted along perimeter fences to discourage
unknowing or unauthorized erfiry; (4) entry limited to one gate, staffed by armed security
personnel; (5) access limited to persons and vehicles displaying appropriate identification badges
and vehicle placards; (6) two-way radio communication; (7) telephone communications available
at selected facilities; and (8) security lighting provided at key locations. Drawine EG-22-G-8221
depicts a more daailed drawine of the ATLIC within Area 10.
lg is?roYidCbyD€D,ffd
4.2
4.2.t
GENERAL SECURTTY PROCEpURES AND EOUIPMENT tR3 15-3-2.5ftX4).
R315-8-2.5(a)l
The security provisions for the TOCDF are in addition to that of the Desmet€hmieal
Bepee(pcO) security provisions. The ATLIC is located within the DCD Area 10 and is
covered by the DdCD measures for securine site equipment and surety material. The
following procedures and equipment at the Tooele Chemical Agent Disposal Facility
(TOCDF) prevent unknowghg entry into the facility and minimize the possibility for
unauthorized entry of persons or livestock onto the facility: (1) fencing surrounding the
site; (2) 24-hours-per-day, seven-days-per-week surveillance by armed patrols; (3)
waming signs posted at the area perimeter; (4) routine entry to the facility limited to one
gate, staffed by armed security personnel; (5) routine access limited to persons displaying
appropriate identification badges and vehicle passes issued only by the Security Office; (6)
two-way radio communication; (7) security lighting to illuminate the entire facility. DCD
Attachment4-Page3
4.3
TOCDF
Security rrff:iffi.;
Area l0 Igloos 1631, 1632,{nd 1633. and 1639 are not located within the TOCDF proper,
but are managed by TOCDF. Igloo 1631 contains the Autoclave Subpart X Treatment
Unit. Igloo 1632 contains the Drum Ventilation System and Drum Ventilation Sorting
Room System Subpart X Treatment Units and is also permitted as a container storage unit.
Igloo 1633 is a permitted container storage unit. Am* Isloo 1639 contains the tabun (GA)
nerve aeent and Lewisite &) blister aee'nt incineration facility which is referred to as the
Area 10 Liquid tnqinerator (ATLIC).
TWENTY.FOT]R IIOUR SURVEILLAIICE SYSTEM IR3 1 5.8-2.5ft)(1)I
4.3.1 Continuoussurveillance@isaccomplishedbysecuritypatrols.
Overall administration of security personnel is performed by the Chief, DCD Security
Office.
4.3.2 Each patrol is radio equipped. Typical duties required of patrol members include:
4.3.2.1 Check for possible intrusion or security violations.
4.3.2.2 Check the security of the bulldings wi'thin the patrol area.
'
4.3.2.3 Check the physical integrity of perimeter barriers.
4.3.2.4 Challenge persons within the patrol area as appropriate.
4.3.2.5 Report all incidents and checkpoints.
4.3.2.6 Respond to contingency calls.
4.3.2.7 Perform specific duties as assigned.
4.3.3 Each patrol is equipped with required protective equipment. Limited first aid supplies,
fire extinguisher(s), and lights are available. All patrols are armed.
4.4 BARRTER tR3 I 5-8-2.5ft)(2)(il1
4.4.1 'Ihe TOCDF and Area 10 are slrrounded by chain-link security fences. The perimeterp
arEis completely lighted. The fenceg:Ig maintained in good repair.
4.5 NIEAI\S TO COTyTROL ENTRY.tR3l5-8-2.5ftX2Xiil1
4.5.1 Visitor access ithin the{r separate. fenced perimeter
perimeters. is controlled byatpamt+24-how guarded gateg. Visitors are accompanied at
all times during their visit to the facility and are subject to security checks.
4.5.2 For those individuals who routinely work in the-
operated facilities, picture idortity badges and other forms of identification are required at
the entry control point. These badges are.issued by the DCD to each individual.
Attachment4 -Page4
4.5,3
4.5.4
4.5.5
4.5.6
4.5.7
4.6
4.6.1
TOCDF
Security Procedurest
,. June 2oo9
A worker must be current itrmedical screeiring and training requirerneirts as well as
cleared through appropriate security progams.
Within thege secure facilitigsy, certain.areas have been designated as Exclusion Areas.
Access to Exclusion Areas is restricted to authorized personnel who have the appropriate
training. Personnel within Exclusion Areas will always work under the "Two-Person
Concept" or buddy system in which each worker remains in visual contact with his parhrer
at all times. Once personnel have entered the facility, access to Exclusion areas is
controlled.
Pedestrian access is controlled by a continuously
guarded tumstile system_at3agh_fagility. The individual maybe searched in his or her
person and effects as determined by the guards. Upon acceptance of identification, the
individual can pass through. All the gate guards are armed.
Vehicle access is controlled"by a continuously
guarded gate at€_9ach-al9a. When a vehicle requires entry@th€rfa€iliry, all
occupdits'except the driver must exit the vehicle and enter through the turnstile system.
The vehicle will be thoroughly searched by an armed guard.
Shortterm access can be authorized. An'authorized escort accompanies these personnel
during their time within the facilities.-either{aeiH*
WARNING SIGNS tR3 15-8-2.5(c)l
Signs warning that the areas areis restricted and dangerous, and that unauthorized entry is
illegal, are posted near all facility access gates and around the perimeter. These signs are
easily visible at a distance of 25 feet.
Attachment4-Page5
?+(.+
FDo)
H
CD)
tJt
TOCDF
Inspection Plan
June 2009
ATTACHMENT 5
INSPECTION PLAN
TOCDF
Inspection Plan
June 2009
TABLE OF CONTENTS
TABLE OF CONTENTS
LIST OF TABLES
LIST OF ACRONYMS
5.1 INSPECTIONPLAN/SCHEDULE
5.2 METHOD OF INSPECTION BASIS
5.3 INSPECTIONS
5.3.1 ContainerStorage
5.3.2 Incinerators
5.4 INCINERATORANCILLARYEQUIPMENT
5.4.1 Process ControllRCRA Compliance Instrumentation
5.4.2 DemilitarizationEquipment
5.4.3 lncineratorPollutionAbatement Systems
5.5 STORAGE/TREATMENTUNITS
5.6 LOADruNLOAD AREAS
5.7 AGENT MONITORS
5.8 24-HOUR IN'TERMITTENT COLLECTION I.INITS AND OTHER PERMITTED SUMPS
5,9 MDB VENTILATION CARBON FILTERS
5.10 EMERGENCY AND SA}'ETY EQUIPMENT
5.10.1 Emergency Power System[lnintemrptible Power Supply
5.10.2 Security System
5.10.3 Emergency Communication System
5.10.4 Fire Protection Systems
5.10.5 Hazmat Van and Decon Trailer
5.11 SPECIFIC INSPECTION PLANS AND LOG SHEETS
Attachrnent5 -Page2
o
TOCDF
lnspection Plan
June 2009
LIST OF TABLES
5-1 Hazardous Waste Management Unit Inspection Schedule & Methods of Inspection
5-Z TOCDF Support System Inspections
5-3 Automated Demilitarization lVlachines & Associated Equipment
5-4 Environmental Inspection for the iontainer Handling Building (CHB) & Secondary Containment
Systems (Overpacks)
5-5 Environmental Inspection for the TMA Container Storage
5-6 Environmental Inspection for TMA Airlock/Decon Area
5-7 Environmental Inspection for the Unpack Area (IPA) Container Storage Area
5-7(a) Additional Environmental Inspection for the Unpack Area (JPA) When Secondary Containment
Pallets Are Used
5-8 Environmental Inspection for the Explosive Containment Room Vestibule (ECV) Container
Storage Area
5-g Environmental Inspection for the Upstairs Munitions Corridor (UPMC) Container Storage Area
5-10 Environmental Inspection for the S-2 Warehouse Container Storage Area & Secondary
Containment Systems
I S-tt Environmental lnspection fortheTOCDF LIC 1 & LIC 2PimaryChambers
I S-tZ Environmental Inspection for the TOCDF LIC 1 & LIC 2 Secondary Chambers
5-13 Environmental Inspection for the Metal Parts Furnace
5-14 Environmental Inspection for the Deactivation Fumace System
I S-tS Environmental Inspection for the TOCDF LIC 1, LIC 2, MPF, & DFS Pollution Abatement
Systems
5-16 Environmental Inspection for the Load/Unload Areas & lncinerator Residue Discharge Areas
I S-tl Inspection for the TOCDF Agent Monitors
,f 1.!, .
Enyirbnmenlal Inspection For 24-hotx Intermittent Collection Units
5-19 Environmental Inspection forMDB RCRA Permitted Sumps
Attachrnent5-Page3
TOCDF
Inspection Plan
June 2009
LIST OF TABLES
(coNTrNrrED)
5-20 Environmental Inspection for the Munitions Demilitarization Building Demilitarization & Material
Handling Systems
5-21 Environmental Inspection for the Agent Collection Tanks ACS-TANK-101, ACS-TANK-l02 and
ACS Tank Secondary Containment System
5-22 Environmental Inspection for the Spent Decontamination Solution Tanks SDS-TANK-101, SDS-
TANK-102, SDS-TANK-IO3 and SDS Tank Secondary Containment System
5-23 Environmental Inspection for the Brine Reduction Area Surge Tanks BRA-TANK-I01, BRA-
TANK- 1 02, BRA-TANK-2O 1, BRA-TANK -202 & Secondary Containment System
5-24 Environmental Inspection for the Igloo 1632 and 1633 Container Storage Areas and Secondary
Containment Systems
5-25 Environmental Inspection for the Brine Reduction Area Pollution Abatement System
5-26 Environmental Inspection for the TOCDF Munitions Demilitarization Building Ventilation Carbon
Filter System
5-27 Safety and Emergency Equipment Inspection for Emergency Response Equipment-(For alLEG&G
QBerated Facilities)
5-28 Safety and Emergency Equipment lnspection for the TOCDF Emergency Generators, Security,
Hazard Communication, & Fire Protection Systems
5-29 Environmental Inspection for Igloo 1631 Autoclave and the Igloo Carbon Adsorption Filtration
System
5-30 Environmental lnspection for the Igloo 1632 Drum Ventilation System (DVS) and Drum
Ventilation System Sorting Room (DVSSR) and the Igloo Carbon Adsorption Filtration System
5-31 Environmental Inspection for the ATLIC Ton Container Glove-boxes
5-32 Environmental Inspection for the ATLIC LIC Primary and Secondary Chambers
5-33 Environmental lnspection for the ATLIC LIC Pollution Abaternent Systems
5-34 lnspection for the ATLIC Aeent Monitors
5-35 Environmental lnspection for the'ATLIC Ventilation Carbon Filter System
5-36 Safety and Emereency Equipment Inspection for the ATLIC Emereency Generators. Security.
Hazard Communication. & Fire Protection Systems
Attachrnent5-Page4
TOCDF
'"T#:;J#
5-37 Environmental lnspection forthe ATLIC TOX Area Tanls: NSF-Tank-8514" LtCS-Tank-8S16.
l,CS-Tank-851l. SDS-Taok-8523. LtCS-Tank-8S34 and the tank Secondary Containment Systgn
Attachment5-Page5
TOCDF
Inspection Plan
June 2009
ACA]\dS
ACS
LIST OF ACRONYMS
Automatic Continuous Air Monitoring System
Agent Collection System
ATLIC Area 10 Liquid Incinerator
Automatic Waste Feed Cut-Off
Bulk Drain Station
Brine Reduction Area
Continuous Emission Monitoring System
Code of Federal Regulations
Container Handling Building
Depot Area Air Monitoring System
Document Control Center
Deactivation Furnace System
Division of Solid and Hazardous Waste
Drum Ventilation System
Drum Ventilation System Sorting Room
Explosive Containment Room Vestibule
High Efficiency Particulate Air
Hazardous Waste Management Unit
Intermittent C ollection Unit
Liquid Incinerator
Munitions D emil rtanzation Building
Multiposition D emil rtanzation Machine
Multi-Munitions Handling Systern
Metal Parts Furnace
National Fire Protection Association
National Fire Code
On-Site Container
Pollution Abatement System
Process Data Acquisition and Recording System
Projectile Handling System
Prq ectileAvlortar Disass ernb ly Machine
Resource Conservation and Recovery Act
Residue Handling Area
Spent Decon Solution
Toxic Maintenance Area
Tooele Chemical Agent Disposal Facility
Unpack Area
Upper Munitions Corridor
Unintemrptible Power Supply
AWFCO
BDS
BRA
CEMS
CFR
CHB
DA."AMS
DCC
DFS
DSHW
DVS
DVSSR
ECV
HEPA
HWMU
ICU
LIC
MDB
MDM
MMS
MPF
NFPA
NFC
ONC
PAS
PDARS
PHS
PMD
RCRA
RHA
SDS
TMA
TOCDF
UPA
UPMC
UPS
Attachrnent5-Page6
5.1
5.1.1
5.1.2
TOCDF
"'oT:i"Jrto'#
INSPECTION PLAN/SCHEDULE tR315-8-2.6r R315-8-9.5: R315-8-10 t40 CFR
264. Subpart Jll R315-8-15.7: r315-3-5ftXfl1
The inspection required under R315-8-2.6 of permitted Hazardous Waste Management
Units (HWMUs) is intended to minimize and prevent releases of hazardous waste to the
environment and to protect human health. The frequency at which the inspections must
occur is specified by regulation and varies depending on the type of HWMU being
inspected.
Table 5-1 lists the HWMUs permitted under the Tooele Chemical Agent Disposal Facility
(TOCDF) Hazardous Waste Part B Permit, their regulation-based required inspection
frequency, and the method by which each HWMU is inspected.
TABLE 5-1
HAZARDOUS WASTE MANAGEMENT UNIT INSPECTION SCHEDULE &
METHODS OF INSPECTION
HAZARDOUS WASTE
MANAGEMENT UNIT
INSPECTION
FREQUENCY
REGULATION
LOCATION AGENT I FREQUENCY
VENTILATION I TNSPECTION
CATEGORY' I METHOD2
CONTAINER STORAGE
Container HandHir$ Building
(cHB)
Weekly
R3l5-8-9.s
Outside
Munitions
Dernilitarnzati
on Building
(MDB)
D Weekly - Physical Visual
Inspection of containers in
the S-2 Warchouse , Igloos
1632 & 1633, and TMA
Container Storage Area,
secondaly containment
pallets (S-2 Warehouse,
Igloos 1632 & 1633, and
UPA only) and storage
base(CHB and TMA
Container Storage Alea
only). In tl're CHB and
UPA: Autornatic
Continuous Air Monitoring
Syiteur/Depot Alea Air
Monitoring Systern
(ACAMS/DAAMS) used
to detennirre leaking
containers inside
ovetpacks that remain in
storage for longer than 7
days.
S-2 Warehouse Weekly
R3 t s-8-9.s
Outside MDB D
Igloo 1632 Weekly
R3l5-8-9.5
DCD Area l0 D
lgloo 1633 Weekly
R3l5-8-9.5
DCD Area l0 D
Unpack Area (UPA)Weekly
R3l5-8-9.5
Inside MDB C
Toxic Maintenance Area
(TMA) Container Storage
Weekly
R3l5-8-9.5
Inside MDB A
TMA Airlock Area Weekly
R3l5-8-9.5
Inside MDB C Weekly (wheu overpacks
are in storage) -Visual
Inspection perfonned using
closed circuit televisiou in
the A/B area and visual
irrspection through the
observation con'idor
window in the C area
TMA Decon Area Weekly
R3l5-8-9.5
Inside MDB NB
Explosive Containment Room
Vestibule
Weekly
R3 l5-8-9.5
Inside MDB fuB Weekly - Visual Inspection
pertbnned using closed
circuit television and
plocess data obseryed from
control screens.
Upstairs Munitions Conidor Weekly
R3 l5-8-9.s
Inside MDB A/B
Attachment5 -Page7
TOCDF
Inspection Plan
June 2009
TABLE 5-1
HAZARDOUS WASTE MANAGEMENT UNIT INSPECTION SCHEDULE &
METHODS OF INSPECTION
HAZARDOUS WASTE
MANAGEMENT UNIT
INSPECTION
FREQUENCY
REGULATION
LOCATION AGENT
VENTILATION
CATEGORY'
FREQUENCY
INSPECTION
METHOD2
INCINERATORS
Liquid Incinerator #l Daily
R3l5-8-
I 5.7(b), (c)
Inside MDB A/B Daily - Visual Inspection
perfonned using closed
circuit television and
process data observed from
control screens.
Monthly - Physical Visual
Inspection.
Liquid Incinemtor #2 A/B
Area t0 Liquid Incinerator
(ATLICIIC
ATLIC LIC
Room
A/B
Metal Pafts Fumace
Inside MDB
B
Deactivation Furnace System B
INCINERATOR ANCILLARY EQUI PMENT
Incinerator Process
ContrrcVRc RA Compliance
lnstrumentation
Based on
Frequency
stated in
Calibration
Plan
(Attachrnent
6)
Not Applicable Not Applicable Calibration - Calibration
Frequency based on
instrument type.
Dernil Machines/Conveyorc Daily
R3l5-8-
l s.7(b)
Inside MDB A, A/B Daily - Visual Inspection
perfonned using closed
circuit television and
plocess data observed from
control screens.
Pollution Abaternent Systerns Daily
R3l5-8-
l s.7(b)
Outside MDB D Daily - Physical Visual
Inspection.
lnside ATLIC
Environrnental
Control Systern
STORAGE/TREATM ENT UNITS
Agent Collection Systern
(ACS)
ACS-Tank- l0l
ACS-Tank- 102
Daily
R3 r 5-8-
r0[40 cFR
264.1 e5(a),
(b)l
Inside MDB A
Dailv - Phvsical visual
inspection or Visual
Insoection oerformed
using elosed eircuit
television and orocess
data observed from
control screens.
Weeklv - Phvsical Visual
Insoection.
NSF-Tank-8s14
LCS-Tank-85 l6
LCS-Tank-851 I
SDS-Tank-8523
LCS-Tank-8534
ATLIC TOX
fuea
Spent Decon Solution (SDS)
SDS-Tank-l0l
SDS-Tank- 102
SDS-Tank- 103
Inside Ivl DB
SDS Ancillary Tank Systerns
(24-Hour ICU and Secondary
Containrnent Surnps)
Inside MDB A, A/8, C Daily - Visual Inspection
perfonned by use of the
sump level indicators.
ATLIC TOX
Area for equip.
associated with
SDS-Tank-8523
Visual Inspection
oerformed bY use of
sump level indicators
Attachrnent5-Page8
TOCDF
Inspection Plan
June 2009
TABLE '1HAZARDOUS WASTE MANAGEMENT UNIT INSPECTION SCHEDULE &
METIIODS OF INSPECTION
HAZARDOUS WASTE
MANAGEMENT UNIT
INSPECTION
FREQUENCY
REGULATION
LOCATION AGENT
VENTILATION
CATEGORY'
FREQUENCY
INSPECTION
METHOD2
STORAGE/TREATMENT UNITS
Brine Reduction tu'ea (BRA)
BRA-Tank-101
BRA-Tank-102
BRA-Tank-2O1
BRA-Tar:/r.-202
Outside MDB D Daily - Physical Visual
Inspection
Cathodic Protection -
Annually - Confinn proper
operation.
Every Other Month -
Inspect/Test Sources of
Impressed Current
Autoclave & Igloo Carbon Adsorption
Filtration Systern
Daily & Weekly
R3l s-8-16 [40
cFR 264.602,
264.1s(bx4),
264.1033,
264.10871
DCD Area l0
Igloo 163 I
and Adjacent
Carbon
System
D
Daily - Physical Visual
Inspection
Weekly - Physical Visual
Inspection
ATLIC Ton Container Glove-box
Carbon Adsorption Filtration System
Daily & Weekly
R3l5-8-16 t40
cFR 264.602.
264.15(bX4).
264.t033.
264.10871
ATLIC
Processing
Esy
D
Daily - Physical Visual
Insoection
-..
Weekly - Physical Visual
Inspection
Drum Ventilation System:
DVS Enclosure DVS-l0l
DVS Enclosure DVS-102
DVSSR
Igloo Carbon Adsorption
Filtration Systern
Daily & Weekly
R3l5-8-16 [40
cFR 264.602,
264.1s(bx4),
264.1033,
264.10871
DCD Area l0
Igloo 1632
and Adjacent
Carbon Filter
Systern
D
Daily - Physical Visual
Inspection
Weekly - Physical Visual
Inspection
BRA ANCI LLARY EQUIPMENT
Pollution Abaternent Systern Daily
R3 t s-8-2.6
Outside MDB D Daily - Physical Visual
Inspection
' Agent Ventilation Categories are determined based on the probability ofagent contamination. The ranking system scales from A (highest
probability) to E (no prcbability). More ventilation air is required to be moved thlough areas as the prcbability of agent contarnination
increases. The level of personal pnctective equiprnent also increases as the prcbability of agent contaminatiou incrcases.
2 Inspections pedonned by the control room operators through the use ofclosed circuit television camems and process data acquisition
systems arc refemed to as "Visual Inspections". Inspections perfonned by pemonnel present at the actual location are refen'ed to as
"Physical Visual lnspections."
5.1.3 Table 5-2 includes additional inspections performed
hazardous waste at the TOCDF and ATLIC. These
minimtze releases of hazardous waste and to ensure
functional.
on systems supporting the treatment of
inspections are intended to prevent and
that emergency equipment is available and
Attachment5-Page9
Table 5-2_T€)CDILSUPPORT SYSTEM INSPECTIONS
TOCDF INSPECTIONS
SYSTEM/ITEM
INSPECTED
INSPECTIONFREQUENCY
REGULATION
METHOD OT
INSPECTION
Hazardous Waste Load/Unload Areas Daily (when in use)
R3l s-8-2.66X4)
Physical Visual Inspection
Agent Monitors Daily
R3l s-8-2.6GX4)
Challenge
MDB RCRA Permitted Sumps
(Cateeorv C)
Daily Physical Visual Inspection
MDB RCRA Permitted Sumps
(Category B and A/B)
Daily Visual Inspection performed by
use of sump level indicators
MDB Ventilation Carbon Filter System Daily Visual Inspection performed using
process data observed from control
Safetv/Emersencv Eq uipment Inspections
Emergency Generators Monthly
R3 ls-8-2.6(bxl)
Operational Test
Unintemrptible Power Supply Physical Visual Inspection
Security Physical Visual Inspection
Emergency Power System Annually
R3l s-8-2.6(b)fl)
Operational Test
Evacuation Notification System Weekly
R3 r s-8-2.6(bx1)
Operational Test
Fire Protection Systems Serni-annually & Annually
R3 I s-8-2.6ftX1)
Visual & Operational Tests
Hazrnat Van and Decon Trailer Monthly
R3l s-8-2.6(bxl)
Physical Visual Inspection
ATLIC INSPECTIONS
Agent Monitors Everv 4 hour to Daily
(See Table 5-34)
R3 I 5-g-2.6(b)(4)
Challenge
ATLIC RCRA Permitted Sumps
(LIC Room. Entry Airlock A. B and TOX
Area Room)
Daily Visual Inspection performed by
use of sump level indicators
ATLIC Veqtilation Carbon Filter System Daily Visual Inspection performed using
process data observed from control
screens.
Safetv/Emersencv Equipment Insnections
Emereency Generators Monthly
R3l s-8-2.6(bx l )
Operational Test
Uninterruptible Power Supply Monthly Physical Visual Inspection
Security ATLIC is within Securitv
Boundarv Provided by DCD
Area l0
ien
Performed bv DCD Securitv
Emergency Power System Annually
R3 l5-8-2.6(bX I )
Operational Test
Fire Protection Systems Semi-annually & Annually
R3 t 5-8-2.6(b)fl )
Visual & Operational Tests
TOCDF
Inspection Plan
June 2009
Attachment 5 - Page l0
5,2
5.2,7
5.2,2
5.2.3
5.3
5.3.1
TOCDF
Inspection Plan
June 2009
METHOD OF INSPECTION BASIS
The method of inspection is based on the location of the HWMU relative to the Munitions
Demilitarization Building (MDB). Due to the extreme toxicity of the chemical agent, the
TOCDF is designed to minimize the number of times workers have the potential of being
exposed to chemical agsnts. This is done primarily by the extensive application of
automated equipment, closed circuit television cameras, and distributed Process Data
Acquisition and Recording System (PDARS) in areas where the probability of chemical
agent contamination is high. This criteria is also used in determininq the inspection
methods for the ATLIC facility.
To lessen the potential of chemical agent exposure to workers, the inspections of HWMUs
located in areas having a high probability of chemical agent contamination (either airbome
or liquid) are performed by control room operators through the use of closed circuit
television cameras and the observations of critical process parameters displayed on the
control room monitors (i.e. "Visual Inspections," see last column of Table 5-l).
Areas where the probability of chemical agent contamination is low are inspected by
personnel present at the physical location (i.e. "Physical Inspections," see last column of
Table 5-1).
INSPECTIONS
The following describes the inspections to be performed at each HWMU and support
system by category. Inspections specific to each HWMU and support system listed in the
first column of Table 5-1 and Table 5-2 can be found in Tables 5-4 through 5-29r of this
plan. The inspection logs used to record the results of each inspection can be found in the
Inspection Log Sheet Attachment. Inspection log sheets shall be filled out completely and
accurately by inspectors.
Container Storaee [R315-8-9.51
Chemical munitions and bulk containers of chemical agents are stored in the CHB prior to
being transferred to the MDB to begin the demilitarization process. While stored in the
C[IB, munitions and bulk containers are kept in sealed overpacks. The type of munition
overpack used is an On-Site Container (ONC). Likewise, chemical munitions and bulk
containers of chemical agents are stored in the UPA, Explosive Containment Room
Vestibule (ECV), and the Upstairs Munitions Corridor (UPMC), and the TMA
Airlock/Decon Area. While stored in the UPA, non-leaking munitions and bulk
containers shall be placed on secondary containment pallets or kept in the overpacks,
described above, which provide secondary containment.
Containers with site-generated waste are stored in the S-2 Warehouse and DCD Igloos
1632 and 1633. While stored in the S-2 Warehouse and Igloos 1632 and 1633, the
containers shall remain closed except when adding or removing waste (includes
periodically mouitoring the vapor space within thei container).
'Tables 5-4 through 5-28 are located at the end of this plan.
5.3.1 .1
5.3.1 .1 . 1
s.3. | .l .2
o:
Attachment5-Pagell
TOCDF
Inspection Plan
June 2009
5.3.1.1.3 Containerized waste and agent-contaminated equipment and parts are stored in the TMA
Container Storage Area.
5.3.1.1.4 The overpacks provide a level of containment in addition to the CHB and UPA storage
area base because they are liquid tight; have the capacity to contain the entire volume of' the agent fill of the munitions and bulk containers stored inside them; and are not opened
while they are in the CHB.2 Overpacks used in the CIIB shall also be vapor tight.
5 .3 . I . 1 .5 The air inside all overpacks stored in the CHB and in the UPA for more than seven days is
" sampled and analyzed on the seventh day and every seventh day thereafter by an agent
monitor. The results of the sample analysis are available before the end of the eighth day
_ the overpack is in storage.
5.3.1.1.6 Overpacks found to be containing munitions or bulk containers that are leaking are
processed on a piiority basis or moved to a permitted storage area.
5.3.t.1.7 ONCs are subjected to an integrity test to determine their ability to contain vapors prior to
.. .. : beingplacedintoserviceandonanannualbasisthereafter. -....
5.3.1.1.8 The storage base for each storage area (CHB, ECV, and UPMC) and the storage base in
the Category A section of the TMA are inspected weekly for chips, cracks, and gaps in the
concrete or concrete sealant. When used for container storage, the storage base of the
TMA AirlocklDecon Area is inspected weekly for chips, cracks, and gaps in the concrete
or concrete sealant. The containers and secondary containment pallets in the S-2
Warehouse, Igloos 1632 and 1633 and UPA are inspected weekly for rupture, corrosion,
and released material.
5.3.1.2 IncineratorstR3l5-8-15.7ft):R315-8-15.7(c)l
5.3.1.2.1 The incinerators listed in Table 5-1 are located in individual rooms within the MDB rUrSl
the ATLIC LIC Room. Because the demilitarizationprocess occurring inside these areas
N{D}is operated remotely in order to lessen the potential exposure of workers to chemical
agent, the equipment inside the MDB and ATLIC LIC Room is provided with
instrumentation to allow the control room operators sufficient process information to
determine the performance of the equipment. By combining the visual observations made
through the remote control closed circuit television cameras and process data displayed on
the control screens, the control room operators can monitor the performance of the
incinerators to a sufficient degree to prevent releases of hazardous waste to the. ': envirclnment.
5.3.1.2.2 During incinerator operation, the possibility of agent contamination within the rooms
".;'j.: prevents unplanned access bypersonnel.
;r
5.3.1.2.3 Physical entry to the incinerator rooms does not occur on a regular predetermined basis
because shutdowns of the incinerators are planned on an as-needed basis (i.e. irregular
frequency). Process controUprocess parameter sensors and remote controlled closed
2Although the overpacks are not opened in the CHB, they are opened in the UPA located in the transition
area between the CHB and the MDB.
Attachrnent 5 -Page 12
5.3 .1 .2.4
5.3. r.2,5
5.3.1.2.6
5.3.1.2.7
s.3 .t .2.8
TOCDF
''oTlf;r'o'#
circuit television cameras throughout the MDB and ATLIC LIC Room are used to conduct
inspection in areas where trnplanned physical entry is prevented because of agent
contamination and/or high temperatures.
The daily visual inspections of LIC 1, LIC 2, MPF, and DFS and ATLIC UC primary
chambers, waste feed systems, combustion air blowers, and fuel systems are conducted
remotely using closed circuit television cameras and process data displayed on the control
room monitors.
The daily inspections conducted on the secondary chambers of LIC 1, on+LIC 2 ind
ATLIC LIC are performed as a physical visual inspection. The temperatures of the rooms
and the expected degree of agent contamination within the rooms housing the secondary
chambers of the LICs are low enough to allow forunscheduled entry. The combination of
the secondary chamber room temperature and the type of personal protective equipment
that can be used place a lower heat load on the operator than that of the rooms housing the
primary chambers.
Physical visual inspections of the components of each incinerator are conducted when
persorurel are in the rooms performing operational activities, maintenance activities, or
both. Physical visual environmental inspections are conducted, at a minimum, on a
monthly basis.
Physical visual inspections of the PAS are conducted on a daily basis.
Automatic Waste Feed Cut-Offs (AWFCO) shall be tested every 14 days. The method of
testing is described in the Attachment 6 (Calibration Plan). Waste feed cut-off test
documentation shall be included in the Operating Record.
INCINERATOR AI\CILLARY EOUIPMENT
Process ControURCRA Compliance Instrumentation
The process control instrumentation associated with specific permit conditions is listed in
the Calibration Plan (Attachment 6). The frequency of calibration is based on the type of
instrument (e. g. temperature transmitter, pressure transmitter, etc.).
A commercially available calibration system is used as a tool in performing calibration and
maintaining calibration records. The system consists of numerous hand-held
calibrators/data recorders and an associated database.
Calibration records of incinerator process control instrumentation that are not Continuous
Emission Monitoring System (CEMS) analyzers shall be maintained in the database
associated with the calibration system.
The technician calibrates each instrument and records sufficient information to
demonstrate the following: instrument Tag ID, name of person performing the calibration,
date calibration was performed, time calibration was performed, location of calibration
event (Manufacturer, Shop, or Field), %o enor as found in an instrument that can be
calibrated, Yo enor as left in an instrument that can be calibrated, and the calibrator values
fed to the instrument that were used to determine o/o enor.
5.4
5.4.1
s.4.1.1
5 .4.7. .2
5 .4.1 .3
5.4.1 .4
Attachment 5 - Page l3
TOCDF
Inspection Plan
June 2009
5.4.1.5 Data recorded on the hand held calibrator/data recorders is downloaded to the database.
The database is then used to generate various reports. If additional information is
reguired, custom reports are generated at the time the information is requested.
5.4.1.6 The calibration plan and examples of calibration log sheets associated with the CEMS are
included in thd TOCDF Continuous Emission Monitoring Plan. This Plan is on file at the
Utah Division of Solid and Hazardous Waste (DSHW) offices.
5.4.2 ry
5.4.2.1 Automated demilitarization equipmeirt and Material Handling Systems are used
throughout the MDB to prepare and feed chemical munitions and bulk containers of
chemical agent to the incinerators. The disassemblyprocess used at the TOCDF to
separate the explosive and agent components of chemical munitions uses automated
process equipment. Table 5-3 lists the automated demilitarization machines and material
handling equipment that function as ancillary equipment to the incinerators.
Attachment5 -Page14
TOCDF
Inspection Plan
June 2009
Table 5-3
AUTOMATED DEMILITARIZATION MACHINES & ASSOCIATED EQUIPMENT
ITEM DESCRIPTION
(quantity)
LOCATION METHOD OF OBSERVATION
Explosive Component Removal
Proj ecti le/M ortar Disassembly Machin e (2)Explosive
Containment
Rooms A & B
Control Room Operators using closed
circuit television cameras and data
presented on control room screens to
oversee processing of munitions
Material Transfer
Projectile Tilting Conveyor (2)Munitions
Corridor
Same as above
Multi-position Loader (2)Munitions
Corridor
Same as above
Agent Component Removal
Bulk Drain Station (2)Munitions
Processing Bay
Same as above
Multipurpose Demil Machine/Pick and Place Machine
(3)
Material Transfer
Associated Conveyors Throughout MDB Same as above
5.4.2.2 Automation is used to remove the operator from the explosive and chemical agent hazards;
force the steps in the disassernble/explosive separation/agent separation process to be
executed in the same sequence every time; prevent the disassembly process from
proceeding should a process step not be executed or interlocked components fail to
complete their preprogrammed sequence; and sequence the feeding of munitions to the
incinerators (i.e., the DFS).
5.4.2.3 Automating the disassembly explosive/agent separation process in no way relieves the
demilitarization machine operator from overseeing the process while it is in progress.
There is a dedicated operator for each tlpe of demilitarization machine. Through the use
of closed circuit television cameras and dedicated demilitarization machine process
screens in the control room, the operator can determine what step of demilitarization each
munition or bulk container is in.
5.4.2.4 Should a machine malfunction, the demil line supported by that machine stops until the
problem is corrected. The process step each demil machine is performing is displayed on
the control room screen so that the operator can determine which process sequence step
was not completed. The process line supported by the machine in malfunction cannot be
started again (i.e., the fail safe interloc$ until the problem is corrected. The demil
machine operator is required to observe the demil machines process munitions and bulk
containers while the machines are in automatic mode to ensure that any stops in the
programmed process sequence are corrected as soon as possible.
5.4.2.5 The munitions demilitarizationprocessing lines are inspected daily to ensure that the
equipment is functioning properly and the processing of a particular munition item has not
been overlooked because of misplacing of the item on the floor or in reject holding
locations. The operation of the demil machines is under observation by the demil control
room operators at all times.
Attachment 5 - Page 15
5.4,3
5.4.3.1
5.5
5.5. 1
5.5.2
5.5.3
5.5.4
" 5.5.5
TOCDF
'"T:i"Jr'J8;
Incinerator Pollution Abatement Svstems
Components of each incinerator's PAS undergo a dailyphysical visual inspection. PAS
sump 110 at TOCDF is inspected daily for the presence of liquids. Accumulated liquids,
in excess of three inches depth, are removed within 24 hours of detection and managed in
accordance with Attachment 2 (Waste Analysis Plan).
STORAGE/TREATMENT UNITS tR315-8-10 t40 CFR 264.195(a): 264.195ft)ll
Table 5-l lists the permitted TreatmenVStorage Units that are required to undergo a daily
environmental inspection. HWMUs ACS-TANK- 1 0 1, ACS-TANK- 1 02, SDS-TANK-
101, SDS-TANK-102, and SDS-TANK-IO3 are located inside the MDB. NSF-TANK-
85 I 4. LCS-TAITIK-8S 1 6. LCS-TANK-8S 1 1 . LCS-TANK-8534 and SDS-TANK-8523 are
located in the ATLIC TOX Area. these units +a*are under the same engineering controls
previously described. Because access is limited to the area where these tanks are located
by the high potential of chemical agent contamination, the daily environmental inspection
is performed by the control room operators using remote controlled closed circuit
television cameras and process data displayed on the control room monitors. The
associated secondary containment systems are inspected for the presence of liquids by
observing the status of the secondary containment systems sump liquid level indicators.
The presence of a level alann indicates liquid in the sump. A physical visual inspection
shall be performed on the permitted treatment/storage units located in the MDB and the
ATLIC TOX Area at a minimum on a weekly basis.
During the physical inspection, the secondary containment systems associated with the
tanks located in the Toxic Cubicle are inspected for cracks, gaps, and the deterioration of
concrete sealer. Ultrasonic thickness testing of the SDS tanks is also performed during the
physical inspection on an annual basis.
Storage/Treatment units and their associated secondary containment systems located
outside the MDB and inside the ATLIC TOX Area undergo a dailyphysical visual
inspection. ATLIC sumps are inspected dailv for accumulated liquids.
The Autoclave in Area 10 Igloo 1631 in conjunction with its shared filtration system, is a
"miscellaneous treatment unit" in accordance with R315-8-16 [40 CFR 264 Subpart X]
and is required to undergo environmental inspections by 40 CFR264.602.
The Drum Ventilation System (DVS) Enclosures and Sorting Room (DVSSR) in Area 10
Igloo 1632 in conjunction with their shared filtration system are "miscellaneous treatment
units" in accordance with R315-8-16 [40 CFR 264 Subpart X] and are required to undergo
environmental inspections by 40 CFP.264.602.
O
5.5.6 The ATLIC Ton Container Glove-box in Area 10 is considered a "miscellaneous
treatment unit" in accordance with R315-8-16 [40 CFR 264 Subpart X] and are required
to undergo environmental inspections by 40 CFR 264.602.
LOAD/I NLOAD AREAS tR315-8-2.6ft)(4)l5.6
Attachment 5 - Page 16
5.6. 1
5.6.2
5.7
5.7 ,l
5.7 .2
5.7 .3
5.7 .4
5.8
5.8. 1
5.8.2
5.8.3
TOCDF
*'oT:iTi.'a;
Areas located outside engineering controls that are used to load and unload hazardous
waste are: the CHB where overpacked bulk containers and munitions are received; outside
of the Residue Handling Area (RHA); and locations where incinerator solid residues are
discharged and the location in Area 10, outside Igloo 1631 where Autoclave treated waste
is loaded into roll-offs.
Load/Unload areas undergo a daily physical visual inspection (when in use) for discolored
and stained soil or concrete, spilled residues of hazardous waste, and if applicable, proper
container labeling, and usable incinerator residue container capacity.
AGENT MONITORS
Low-level agent monitors are used to determine the airborne concentration of chemical
agent in the workplace and exhaust stack gases. The lowJevel agent monitors used are the
Automatic Continuous Air Monitoring System (ACAMS), and the Depot Area Air
Monitoring System (DAAMS). The ACAMS and DAAMS are used throughout the
TOCDF site.
The inspection of and the need to calibrate each ACAMS are based on the results of agent
challenge tests. ACAMS are "challenged" by injecting a dilute solution of chemical agent
into the monitor and comparing the resulting spike and absorption column retention time
(as recorded on the unit's strip chart) to those that are expected.
The frequency at which ACAMS are challenged is based on the sampling location. The
frequencies are specified in Table 5-17.
The calibration methods used for ACAMS at the TOCDF are described in the Laboratory
Operating Procedure titled "Automatic Continuous Air Monitoring System" (TE-LOP-
524). Exanples of the agent challenge and calibration log sheets are included in TE-LOP-
524. Logbooks are kept at each ACAMS station and documentation of ACAMS
challenge tests, calibrations and repairs for all ACAMS are maintained on site in addition
to those listed above.
24.HOT'R INTERMITTENT COLLECTION T'NITS AND OTHER PERMITTED
St]MPS
All 24-Hour Intermittent Collection Units (ICUs) are equipped with pumps and level
indicators. Each 24-Hour ICU is "pumped down" every 24 hours until the sump's low-
level indicator deactivates (provided the low-level indicator was activated because of the
rising level of accumulating wastes).
Because the 24-Hour ICUs meet the definition of tanks, they shall be inspected daily.
The daily inspection of the ICU is conducted by an operator monitoring the liquid level frr
each ICU from the advisor screen located in the control room. Sumps containing liquid
are purpped down within 24 hours from the time the liquid first began to accumulate (as
indicated by the activation of the sump's level indicator). A PDARS report generated
daily is used to demonstrate the ICUs were inspected and managed properly.
Attachrnent 5 - Page l7
5.8.4
5.8.5
5.8.6
5.8.7
5.8.8
5.8.9
5.8. 1 0
. TOCDF
Inspection Plan
June 2009
Once per week, each ICU is inspected by personnel physically located at the ICU (i.e., a
physical visual inspection). This inspection consists of observing the level of liquid in the
ICU and communicating the observation to the control room to determine if the actual
level of liquid in the ICU corresponds with the correct alarm displayed on the advisor
screen.
Other sumps (e.9., those sumps not classified as ICUs, etc.) consist of the following: MDB
and ATLIC RCRA Permitted Sumps (CategoryAlB and B); MDB and ATLIC RCRA
Permitted Sumps (Category C); Disconnected Sumps; and Secondary Containment Sumps
(ACS, SDS, BRA Tanks, and Brine Loading Station sumps).
The MDB aE(ATLIC Permitted Sumps (Category A/B and B) are connected to the SDS
hazardous waste management unit and shall be inspected using ICU procedures. The
daily inspection of these sumps is conducted by an operator monitoring the liquid level in
each sump from the advisor screen located in the control room. Sumps containing liquid
shall be pumped down within 24 hours from the time the liquid first began to accumulate
(as indicated by the activation of the sump's level indicator). A PDARS report generated
daily is used to demonstrate the sumps were inspected and are managed properly. The
transfer of each sump's contents is complete when the sump's low level indicator alarm is
deactivated.
rl..
Once per week, each MDB Permitted Sump (Category A/B and B), with the exception of
sumps SDS-PUMP-I57 and -188, shall be inspected bypersonnel physically located at the
sump (i.e., a physical visual inspection). Since sumps SDS-PUMP-IS7 and -188 are
located in high temperature areas near the LICs and a cool down is required before a
physical visual inspection can occur, the physical visual inspections for these sumps shall
be done monthly. These inspections consist of the inspector observing the level of liquid
in the sump and communicating the observation to the control room to veri$ the actual
level of liquid in the sump coresponds with the correct alarm displayed on the advisor
screen.
The MDB and ATLIC Permitted Sumps (Category C), which are connected to the SDS
hazardous waste management unit, shall be inspected daily by physical visual inspections
and shall be pumped down within 24 hours of detection. The transfer of each sump's
contents is complete when the sump's low-level indicator alarm is deactivated.
The Disconnected Sumps mehtioned above are not connected to the SDS hazardous waste
managernent unit. Any hazardous waste coll€cted in these sumps shall be managed
according to the standards applicable to generators of hazardous waste (R315-5). The
inspection requirements for the secondary containment sumps mentioned above are
described in Tables 5-21 through 5-24.
During agent change over (i.e., the time period over which activities are conducted to
prepare the TOCDF to treat a different tlpe of chemical agent), each ICU.:\TLIQ and
MDB Permitted Sump (Categories A/fl, B, and C) shall be:
Triple rinsed with appropriate decontamination solution to decontaminate the sump and
provide a basis for regulatory partial closure. At the time the sumps are triple rinsed, the
function of each sump level switch will be checked. Each sump will be filled
5.8.10.1
Attachrnent 5 - Page 18
5.8 .10.2
5.8. 1 1
5.8.11.1
5.8 .ll .2
5.9
5.9.1
5.9.2
5.9.3
5.10
5.10.1
TOCDF
t*Ti',,"Jrt#;
incrementally so that each of the level switches will be activated in sequence. The control
room will verifu the activation of each switch.
Completely emptied so the metal sump can be inspected for corrosion and integrity of the
surface coating.
For ICUs, the following activities shall be performed annually and be documented:
Interstitial leak detection sensor will be removed and tested for proper function. The
control room will verify activation of the leak detection sensor.
Interstitial space betwee,n the metal sump and the concrete liner will be checked for the
presence of liquid.
I4DBIIVAC CARBON F'ILTERS
The MDB and ATLIC HVAC carbon filters shall be inspected daily to snsure proper
operation and sufficient absorption media capacity.
The TOCDF has Nnine exhaust filter units that are available, with any seven running at
the same time. The ATLIC has 3 filter units that are available. with any 2 running at the
same time. Each of the nine TOCDF filter units contains a pre-filter, a High Efficiency
Particulate Air (HEPA) filter, six individual banks of carbon filters, followed by a HEPA
filter. The ATLIC filters are confizured similar to those at TOCDF except each A,T[,G[
ATLIC filter system contains three banks of carbon. Differential pressure sensors (used
to determine plugging) are located across the pre-filter, the initial HEPA filter, the final
HEPA filter, and one to measure the overall differential pressure across each filter unit.
Agent monitoring (ACAMS and DAAMS tubes, used to determine saturation of the
carbon bank) occurs in accordance with Attachment 22 (AgerttMonitoring Plan). A flow
sensor is placed in each filter's exhaust blower inlet to enable the control room operator to
determine if any loss of performance has occurred in the filter unit's blower.
The inspection of the MDB and the ATLIC carbon filter system shall be done daily and
shall be performed by a control room operator observing the status of agent alarms, the
differential pressure across the filter unit, and the exhaust blower flow rate of each
operating exhaust filter unit.
EMERGENCY AND SAFETY EOUIPMENT tR3 15-8-2.6ft): R3 15-8-2.6(c)l
The design of the TOCDF and ATLIC includes emergency equipment to be used in the
event of a fre or hazardous waste release. Additional inventories of supplies are set aside
to be used in an emergency situation. Emergency equipment is inspected to ensure that it
is available and functional in the event it has to be used. Included in this category are the
emergency power generators, the security system, the site evacuation siren, the fire
protection systems, and the Hazmat Van and Decon Trailer including the inventory of spill
response equipment maintained on the vehicles.
Emersencv Power Svstem./Uninterruntible Power Sunplvs.10.2
Attachment 5 - Page l9
5.10 .2.1
5. 10 .2.2
5.10.2.3
5.10.3
5.10.3.1
5.10.4
5.10.4.1
5. l0 .4.1
5.10.5
5. 10.5.1
5.10 .5 .2
,rrO".,I:;?:
June 2009
Each emergency generator shall be tested monthly to ensure the emergency generators
function properly, and equipment and systems designated as essential loads continue to
function if utilitypower is intemrpted.
The emergency generators shall be tested by operatrng one emergency generator in either a
loaded or unloaded configuration. This test format results in the performance of each
emergency generator being evaluated on a monthly basis. The filter generator shall also
be tested monthly by operating the generator in either a loaded or unloaded configuration.
The Unintemrptible Power Supply (UPS) shall be inspected monthly by checking the
battery voltage. Annually, the Emergency Power System (e.g., both emergency
generators, switchgear, etc.) and UPS shall be tested by performing power loss tests. The
annual power loss tests may be scheduled events or may be unscheduled or naturally
oocurring events (e.g., power loss due to inclement weather, etc.).
Securitv Svstem
The ernphasis of the inspection of the security system is placed on the fence surrounding
the TOCDF site, which is used to keep unauthorized personnel out. Waming signs are
posted at approximately 100-foot intervals around the facility perimeter. The inspection is
performed to ensure the integrity of the fencing system and determine if any warning signs
are missing. Security lighting shall be inspected to ensure that all lights are working.
Emersencv Communication Svstem
The emphasis of the inspection of the TOCDF site communication system is placed upon
the site evacuation siren. The siren shall be tested weekly to ensure proper operation.
Although other methods of communication are available on the site (i.e., phones, radios,
public address system) there is no plan to inspect communication equipment because it is
used daily as part of the methods of maiiaging/operating the TOCDF.
Fire Protection Svstems
Four types of fire suppressants are used in the TOCDF fire protection systems; Halon
1301, FM-20088-227, dry-chemical, and water. The ATLIC uses a wet sprinkler system
in Ieloo 1639 and a FM200 System in the ATLIC Control Center Equipment Enclosure.
All system inspections conform to procedures and frequencies specified in the National
Fire Protection Association (NFPA) - National Fire Code (l.tFC) l2A, 13, 17, ard 2001.
Fire protection systems using Halon as a fire suppressant shall be inspected every six
months to ensure a full charge of Halon is present in the Halon storage tanks. Fire
protection systems using FM-200lpE-227 as a fire supp.ressant shall be inspected every six
months to ensure a full charge of extinguishing agent is present in the FM-200|FE-227
storage tanks.
Fire protection systems using a dry chemical fire suppressant shall be inspected every six
months to ensure that there is a sufficient compressed gas (nitrogen) to propel the dry
chemical through the system.
5.10.5,3
Attachrnent5-Page20
5.10.5.4
5. 10.6
5.10.6.1
TOCDF
Inspection Plan
June 2009
Fire protection systems using water as a fire suppressant shall be tested annually to ensure
that the water flow rate through the pipes feeding the system is sufficient.
Hrzmat Van and Decon Trailer
The Hazmat Van shall be stocked with PPE and all equipment and supplies necessary for
hazardous material spills, including shovels, brooms, bags, absorbents, etc. The Hazmat
Van also carries equipment and supplies necessary to perform emergency
decontamination. The Decon Trailer contains PPE and all equipment and supplies
necessary to perform personnel decontamination. The trailer has one fixed rinse shower
and one portable decontamination shower. A TOCDF truck is used to move the Decon
Trailer to the scene. The Hazrnat Van shall be inspected monthly to ensure that sufficient
inventory of emergency response equipment is on hand, and that the equipment is
functional.
SPECIFIC INSPECTION PLAI\S AND LOG SIMETS
Tables 5-4 through 5-28 contain the individual inspection plans for each of the HWMU
and support systems previously discussed. Included in each plan are the items to be
inspected, types of expected problems, and the inspection frequency.
The Inspection Log Sheet Attachment to Attachment 5 contains the inspection logs used to
document that the inspections occurred and to communicate the corrective actions (if any)
that are required. All log sheets documenting the occurrence of required inspections and
problems identified during each inspection shall be maintained in the Operating Record
and shall be kept at the facility for a minimum of three years. The inspection log sheets
shall be filled out completely and accurately by inspectors.
5.11
5.1 1 .1
5.11 .2
TABLE 5-4
ENVIRONMENTAL INSPECTION
FOR THE
CONTAINER HANDLING BUILDING (CHB) &
SECONDARY CONTAINMENT SYSTEMS (OVERPACKS)
rTEM 264.15(bX1)TYPES OF PROBLEMS 264.15(bX3)
FREQUENCY
264.1s(bx4)
Overpack Time in Storage Review the CHB operating record to determine which
overpacks will, or have been in storage for 7 days or more.
Daily
Deteriorating Containers
(inside ovemacks)
Monitor the interior air of all overpacks that have been in the
CHB for 7 days.
(Every 7 days)
Containment System
(Ovemacks)
Conduct non-destructive integrity tests on overpacks.Annually
CnnfoirlPre in Sfnr^oc Fncrrre fhqt fhe nrrrnhcr nf firll nrrernqr.lrs in cfnrqoc rlnec nnf Daily
W..kty
W..kty
W..kty
W..kly
v vv^ wE
ffi
M"t.t@
Equipment
Storage Base
M
exceed 48.
storage to .t t
labeled
Observe material handling equipment during operation to
determine any loss of performance.
Inspect floors, trenches, and sumps for cracks, gaps in the
concrete or the concrete coating.
Inspect the ONC storage area for apparent spills or leaks
Attachment 5 - PageZl
TOCDF
Inspection Plan
June 2009
TABLE 5-4
ENVIRONMENTAL INSPECTION
FORTHE
CONTAINER HAI\DLING BUILDING (CHB) &
SECONDARY CONTAINMENT SYSTEMS (OVERPACKS)
rTEM 264.15(bX1)TYPES OF PROBLEMS 264.15(bX3)
FREQUENCY
264.15(bX4)
from the overpacks.
Notes: Physical visual inspection perforrred throughout the week by CHB Operator(s).
Attachrnent 5 -PageZ2
TOCDF
Inspection Plan
June 2009
TABLE 5.5
ENVIRONMENTAL INSPECTION
FOR
TMA CONTAINER STORAGE
ITEM
264.1s(bX1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
Deteriorating
Containers
Inspect the containers for deterioration (i.e., rupture,
corrosion, released material, etc.).
Weekly
Closed Containers Ensure that all containers'covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3 15-8-
22 140 CFR 264.1086(c)(3)l identifies allowable exceptions
to this requirement.
Weekly
Storage Base Inspect the floor and sumps for cracks and gaps in the
concrete or the concrete coating.
Weekly
Containers in Storage Ensure that the total volume of containers in storage does not
exceed 2,200 gallons.
Weekly
Container Labels Inspect all containers in storage to ensure they are correctly
labeled.
Weekly
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perfonnance.
Weekly
General Area Inspect the TMA area for apparent spills or leaks from the
containers.
Weekly
Notes: Physical visual inspection performed throughout the week by TMA operator(s).
Attachrnent 5 -Page23
TOCDF
Inspection Plan
June 2009
TABLE 5-6
ENVIRONMENTAL INSPECTION
FOR
TMAAIRLOCK/DECON AREA
rrEM 264.15(b)(1)TYPES OF PROBLEMS 264.15(b)(3)
FREQUENCY
264.15(bX4)
Storage Base Inspect the floor and sumps for cracks and gaps in the concrete
or the concrete coating.
Weekly
Containers in Storage
(Permitted CapaciM
Ensure that the number of overpacks in storage does not exceed
2.
Weekly
Closed Containers Ensure that all container covers/closure devices are secured in a
closed position so that there are no visible holes, gaps or other
open spaces into the interior of the container. R3 I 5-8-22 L40
CFR 264.1086(c)(3)l identifies allowable exceptions to this
requirement.
Weekly
Container Labels Inspect all containers in storage to ensure they are correctly
labeled.
Weekly
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perfofinance.
Weekly
General Area Inspect the TMA Airlock/Decon Areas for apparent spills or
leaks from the containers.
Weekly
Notes: When overpacl,s are in storage, visual inspection performed throughout the week by operator(s).
Attachrnent5 -Page24
TOCDF
Inspection Plan
June 2009
TABLE, S-7
ENVIRONMENTAL INSPECTION
FOR THE
UNPACKAREA (UPA) CONTAINER STORAGE AREA
ITEM
264.1s(bx1)
TYPES OF PROBLEMS
264.15(b)(3)
FREQUENCY
264.15(bX4)
Overpack Time in Storage Review the UPA operating record to determine which
ovenlacks have been in storape for more than 7 days.
Daily
D eterio r atingl Le aking
Containers (inside
overpacks)
Monitor the interior air of all overpacks that have been in the
UPA for more than 7 days.
Every seven days
Closed Containers (not in
ONCs)
Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3 15-8-
22 140 CFR 264.1086(cx3)l identifies allowable exceptions
to this requirement.
Weekly
Permitted Cap actty Ensure that the number of closed (full) overpacks in storage
does not exceed 9 ONCs.
Daily
Overpack Labels Inspect all overpacks in storage to ensure they are correctly
labeled.
Weekly
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perforrnance.
Weekly
Storage Base Inspect floors, trenches, and sumps for cracks, gaps in the
concrete or the concrete coating.
Weekly when
storing leaking
containers
General Area Inspect the storage area for apparent spills or leaks from the
overp acks/c ontainers .
Weekly
Notes: Physical visual inspection performed by MDB/UPA Operator(s).
Attachrnent 5 - Page25
TOCDF
Inspection Plan
June 2009
TABLE 5-7 (a)
ADDITIONAL ENVIRONMENTAL INSPECTION
FORTHE
T]NPACKAREA (UPA) WHEN SECONDARY CONTAINMENT PALLETS ARE USED
ITEM
264.15(b)(1)
TYPES OF PROBLEMS
264.15(b)(3)
FREQUENCY
264.15(bX4)
Deteriorating Containers
and Secondary
Containment Pallets
Inspect the containers and the secondary containment pallets
for deterioration (i.e., rupture, corrosion, released material,
etc.).
Weekly
Closed Containers (not in
ONCs)
Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3l5-8-
22 140 CFR 264.1086(cX3)l identifies allowable exceptions
to this requirement.
Weekly
Containers per Pallet Ensure that the number of containers stored per pallet does
not exceed the quantities specified in the Inspection Log.
Weekly
Storage Configuration Ensure that the munition(s) or pallet(s) of munitions do not
extend over the edge of the secondary containment pallet.
Weekly
Permitted Cap acity Ensure that the total number of overpacks and secondary
containment pallets used to store containers does not exceed
the limits specified in the Inspection Log.
Weekly
General Area Inspect the storage area for apparent spills or leaks from the
containers or secondary containment pallets.
Weekly
Notes: Physical visual inspection performed by operator(s).
Attachrnent5 -Page26
TOCDF
Inspection Plan
June 2009
TABLE 5.8
ENVIRONMENTAL INSPECTION
FORTHE
EXPLOSTVE CONTATNMENT ROOM VESTTBULE (ECV)
CONTAINER STORAGE AREA
ITEM
264.15(b)(1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
D e teri o r atingl Le aking
Containers
Inspect the containers for deterioration (i.e., rupture,
corrosion, released material, etc.).
Weekly
Closed Containers Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3 15-8-
22 140 CFR 264.1086(c)(3)l identifies allowable exceptions
to this requirement.
Weekly
Containers in Storage
(Permitted Capacity)
Ensure that the number of containers in storage does not
exceed the limits specified in Module IIL
Weekly
Storage Base Inspect floors for cracks or gaps in the concrete or the
concrete coating.
Weekly
General Area Inspect the storage area for apparent spills or leaks from the
containers.
Weekly
Notes: Visual inspection performed remotely by Control Room Operator(s).
Mustard l55mm projectiles that have been rejected from the PMD back into the ECV solely due to a stuck burster
do not have nose closures and4.2" Mortars that have been rejected from the PMD back into the ECV soley due to
the inability to remove the fuze. In these cases, the burster well continues to function as the container closure device
that contains the agent inside. Verification will consist of 1) the lack of visible leakage, and 2) the lack of an ECV
ACAMS reading.
TABLE 5-9
ENVIRONMENTAL INSPECTION
FOR THE
UPSTAIRS MUNITIONS CORRIDOR (UPMC)
CONTAINER STORAGE AREA
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264.1s(b)(3)
FREQUENCY
264.15(bX4)
Inspect the containers for deterioration (i.e., rupture,
corrosion, released material, etc.).
D e teri o r atrngl Le aking
Containers
Weekly
Closed Containers Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3 l5-8-
22 140 CFR 264.1086(cX3)l identifies allowable exceptions
to this requirement.
Weekly
Ensure that the number of containers in storage does not
exceed the limits soecified in Module III.
Containers in Storage
Permitted Capacity)
Storage Base Inspect floors for cracks and gaps in the concrete or the
concrete coatin
Weekly
Inspect the storage area for apparent spills or leaks from the
containers.
General Area
Notes: Visual inspection performed remotely by Control Room Operator(s).
Attachrnent 5 - Page27
TOCDF
Inspection Plan
June 2009
TABLE 5-10
ENVIRONMENTAL INSPECTION
FORTHE
S-2 WAREHOUSE CONTAINER STORAGE AREA &
SECONDARY CONTAINMENT SYSTEMS
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264.150X3)
FREQUENCY
264.15ftX4)
Deteriorating Containers
and Secondary
Containment Pallets
Inspect the containers and the secondary containment pallets
for deterioration (i.e., opfure, corrosion, released material,
etc.).
Weekly
Closed Containers Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3 15-8-
22 140 CFR 264.1086(c)(3)l identifies allowable exceptions
to this requirement.
Weekly
Containers in Storage Ensure that the total volume of containers in storage does not
exceed 38,720 gallons. Ensure that the volume of
containers per secondary containment pallet does not exceed
600 gallons per pallet and the volume of the largest container
on a secondary containment pallet does not exceed 60
gallonsl.
Weekly
Segregation of
Incompatible Wastes
Ensure that incompatible waste is not placed on a secondary
containment pallet at the same tihe.
Weekly
Container Labels Inspect all containers in storage to ensure they are correctly
labeled.
Weekly
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perfoffnance.
Weekly
General Area Inspect S-2 Warehouse area for apparent spills or leaks from
the containers or secondary containment pallets.
Weekly
Notes: I Attachment 12 describes circumstances where a larger container may be stored on a pallet in the S-2
Warehouse.
Physical visual inspection performed throughout the week by S-2 Warehouse operator(s).
Attachment5-Page28
TOCDF
Inspection Plan
June 2009
o . TABLE 5-11
ENVIRONMENTAL INSPECTION
FOR
TOCDF LIC 1 & LIC 2 PRIMARY CHAMBERS
ITEM
264.1s(b)(1)
TYPES OF PROBLEMS
264.15(bX3)
TREQUENCY
264.15(bX4)
Primary Chamber
Waste Handline/Pipine
Inspect for leaks in the agent feed line at threaded and
flanged pipe connections.
Daily
Primary Chamber Inspect for fugitive emissions and hot spots on the outer
shell of the primary chamber, which would indic ate a
breakdown of the chamber's refracto(y.
Daily
Primary Chamber
Combustion Air Blower
Evaluate combustion air blower performance through
Control Room advisor screen observations.
Daily
LIC Primary Chamber
Room Floor
Inspect for residues of lubricant andlor wastes beneath the
components of the LIC agent feed system and the LIC
exhaust gas ductwork.
Daily
Waste Feed Cut-Off
Mechanism
Test control circuit and document that waste feed is
stopped.
Every 14 days
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by the incinerator
operator in the Control Room.
Physical visual inspections are performed at a minimum on a monthly basis.
TABLE 5-I2' ENVIRONMENTAL INSPECTION
FOR
TOCDF LIC 1 & LIC 2 SECONDARY CHAMBERS
ITEM
264.1s(bx1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.1s(b)(4)
Secondary Chamber
Waste Handline/Pipine
Inspect for releases of wastes from the spent decon solution
feed line at welded and flanged pipe connections.
Daily
Secondary Chamber Inspect for fugitive emissions, and hot spots on the outer
shell of the secondary chamber, which would indicate a
breakdown of the chamber's refractory. Inspect interior of
second ary chamber through the view port to ensure the slag
level has not reached the top of the view port.
Daily
Secondary Chamber
Combustion Air Blower
Inspect for loss of lubrication and vibration. Check for
broken or missing anchor bolts.
Daily
Secondary Chamber Room
Floor
Inspect for residues of lubricant andlor wastes beneath the
components of the spent decon feed system and the LIC
secondary chamber ductwork having a potential to cause a
release of wastes or fugitive emissions.
Daily
Notes: Physical visual inspections are performed daily by Operator(s)
Attachrnent 5 -Page29
TOCDF
Inspection Plan
June 2009
TABLE 5-13
ENVIRONMENTAL INSPECTION
FORTHE
METAL PARTS FURNACE
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264,15(bX3)
FREQUENCY
264.15(bX4)
Waste Handling System Inspect for movement of internal conveyor system from the
control panel by ensuring conveyor drive chains are in
motion.
Daily
Combustion Air Blowers Evaluate combustion air blower perforrnance through
Control Room advisor screen obseryations.
Daily
Primary Chamber Inspect for hot spots on the prirnary chamber outer shell,
which would indicate a breakdown of the incinerator's
refractory.
Daily
Afterburner Inspect afterburner shell for hot spots, which would indicate
a breakdown of the afterburner's refractory. Inspect
ductwork between primary chamber and afterburner for
fugitive emissions.
Daily
Waste Feed Cut-off
Mechanism
Test control circuit and document that waste feed is stopped.Every 14 days
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by the incinerator
operator in the Control Room.
Physical visual inspections are performed at a minimum on a monthly basis.
I
Attachment5-Page30
TOCDF
Inspection Plan
June 2009
TABLE 5-14
ENVIRONMENTAL INSPECTION
FORTHE
DEACTIVATION FURNACE SYSTEM
ITEM
264.1s(bx1)
TYPES OF PROBLEMS
264.1s(b)(3)
FREQUENCY
264.15(bX4)
Waste Handling System Inspect the Projectile/Mortar Disassembly Machines within
ECR 1 and ECR 2 to ensure that no explosive residues or
explosive munitions components are collecting on the
associated material handling equipment. Inspect for leaking
hydraulic hoses/connections and accumulated residues of
chemical agent.
Daily
Combustion Air Blower Evaluate combustion air blower perfofinance through Control
Room advisor screen observations.
Daily
Rotary Kiln
(Primary Chamber)
Inspect the rotary kiln for fugitive emissions.Daily
Rotary Kiln Drive Inspect the Rotary kiln trunnion rollers for smooth motion.Daily
Rotary Kiln Drive
Lubrication System
Inspect the Rotary kiln trunnion bearing lubrication system for
leaks and spills.
Daily
Heated Discharge
Conveyor
Inspect the Heated Discharge Conveyor motion indicator plate
for smooth even operation.
Daily
*Heated Discharge
Conveyor
Inspect the floor beneath the Heated Discharge Conveyor for
residues of accumulated wastes.
Monthly
Automatrc Waste Feed
Cut-offs
Test control circuit and document that waste feed is stopped.Every 14 days
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by the incinerator
operator in the Control Room.
Physical visual inspections are performed at a minimum on a monthly basis.
*Inspection performed monthly during physical visual inspection.
Attachrnent 5 - Page 31
TOCDF
Inspection Plan
June 2009
TABLE 5.15
ENVIRONMENTAL INSPECTION
FOR
TOCDF LIC 1, LIC 2, MPF, & DFS
POLLUTION ABATBMENT SYSTEMS
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
DFS Afterburner
Combustion Blower
Inspect blower for excessive noise, vibration, loss of
lubricant, and missing or broken anchor bolts.
Daily
DFS Afterburner Inspect afterburner shell for hot spot, which would indicate a
breakdown of refractory.
Daily
Mechanical Locks for DFS
Isolation and Air Intake
Valves
During normal operations, XV-862 will be locked in the
open position and HV-863 will be locked in the closed
position. Inspect XV-8 62.and HV-863 to ensure mechanical
locks are in place and secure.
Daily
Exhaust Gas (PAS)
Ductwork
Inspect for fugitive emissions or residues at flanged duct
connections and duct expansion joints. Inspect expansion
ioints for breaks that would result in leakage to the system.
Daily
Quench Tower Inspect for brine residues at manway covers and released
liquids from piping or pumps.
Daily
Venturi Scrubber Check venturi plug valve and ensure that it operates freely.
Inspect for releases of scrubber liquid from associated pumps
and pipine.
Daily
Packed Bed Scrubber Inspect for scrubber liquid residues at manway cover.
Inspect for release of scrubber liquid from associated pumps
and piping.
Daily
Demister Inspect for fugitive emissions or residues of scrubber liquid
at the manway cover.
Daily
TOCDF PAS-SI.TMP-I IO Inspect for the presence of material and liquids in excess of
three inches (3"). Check for oil sheen.
Daily
Bleed Air Darnper Ensure cover on bleed air damper is in place and secure.Daily
PAS Blorver Inspect for excessive vibrations and loss of lubricant.Daily
Scrubber Effluent
Handling System
Inspect brine transfer line and associated punrps for leaks at
pump seals and flanged pipefittings. Inspect for swaying
pipe system during operation.
Daily
Notes: Physical visual inspection performed daily by Pollution Abatement System Operator(s).
Attachrnent 5 -Page32
TOCDF
Inspection Plan
June 2009
TABLE 5-16
ENVIRONMENTAL INSPECTION
FORLOAD/UNLOAD AREAS &
INCINERATOR RESIDUE DISCHARGE AREAS
ITEM
264.1s(bx1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
CHB LoadlUnload Area Visually inspect for discolored and stained soil/concrete and
hazardous waste residues.
Daily
RHA LoadUnload Area
(outside buildine)
same as above Daily
MPF Metal Residue
Discharge Area
Inspect for ash residues on cohcrete base underneath
conveyor system.
Daily
DFS Cyclone Ash
Discharge Area
Inspect for ash residue around receiving container. Ensure
that the container is labeled as hazardous waste and that there
is sufficient space in the container to receive ash that will be
generated during operational period.
Daily
DFS Heated Discharge
Conveyor Residue
Discharge Area
Same as above Daily
Notes: Physical visual inspections are performed daily (when in use).
TABLE 5-17
INSPECTION
FOR
TOCDF AGENT MONITORS
ITEMS
264.1s(bx1)
TYPES OF PROBLEMS
264.1s(b)(3)
FREQUENCY
264.1s(bx4)
TOCDF Common Stack
(PAS 701 and -PAS 706)
Perform agent challenge test IAW Attachment22 to
determine the need to calibrate monitor, calibrate if agent
test results in failure. Replace monitor if it can't be
calibrated to specification.
Agent Challenge
(Every 4 hrs.)
LIC 2 PAS Blower
(PAS702\
Same as above Agent Challenge
(Every 4 hrs.)
LIC 1 PAS Blower
(PAS703)
Same as above Agent Challenge
(Every 4 hrs.)
MPF PAS Blower
(PAS704)
Same as above Agent Challenge
(Every 4 hrs. for VX
and Daily for GB)
DFS PAS Blower
(PAS70s)
Same as above Agent Challenge
(Every 4 hrs. for VX
and Daily for GB)
MDB Filter Stack
(FrL601)
Perform agent challenge test IAW Attachment 22 to
determine the need to calibrate monitor, calibrate if agent
test results in failure. Replace monitor if it can't be
calibrated to specification.
Agent Challenge
(Daily)
Notes: The (TAG ID's) used are those that appear on the Control Room advisor screens and the Process Data
Acquisition and Reporting System (PDARS) generated reports.
Attachment5-Page33
TOCDF
Inspection Plan
June 2009
TABLE 5-18
ENVIRONMENTAL INSPECTION
FOR }4-HOUR INTERMITTENT COLLECTION UNITS
ITEM
264.15(bX1)
TYPE OF PROBLEMS
264.15(bX3)
TREQUENCY
264.15(bX4)
Waste Accumulation Time Review Daily PDARS Sump Report to veriff that no primary
containment sump accumulated liquids for longer than 24
hours.
Daily
Sump Liquid Level
Indicator
Visually inspect each primary containment sump to
determine if sump's liquid level coffesponds to level alarm
displayed on control room advisor screen. Inspect for cracks
and deterioration of protective coatings, rusting and any
signs of leaks.
Weekly
Sump Liquid Level
Indicators
Demonstrate function of Sump liquid level detectors by
filling sump (can be done during agent change-over
decontamination step).
Agent campaign
change-over
Metal Sump Completely empty sump and inspect metal sump for
deteriorating surface coating, corrosion, and cracks.
Agent campaign
change-over
Sump Interstitial Leak
Detector
Remove interstitial leak detection probe and test function.Annually
Sump Interstitial Space Swath interstitial space through opening provided by
removed interstitial leak detection probe to determine if
space is dry.
Annually
TABLE 5-19
ENVIRONMENTAL INSPECTION
FOR MDB RCRA PERMITTED SUMPS
ITEM
264.1s(bx1)
TYPB OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
For Category A/B and B Sumps
Material in Sump Review Daily PDARS Sump Report to veriff that no sump
accumulated liquids for longer than 24 hours.
Daily
Sump Liquid Level
Indicator
Physical visual inspection of each sump to determine if
sump's liquid level coffesponds to level alarm displayed on
control room advisor screen. Inspect for cracks and
deterioration of protective coatings, rusting and any signs of
leaks.
Weekly
For Category C Sumps
Material in Sump Physical visual inspection to determine the presence of
material in the sumps.
Daily
For Category A/8, B, and C Sumps
Sump Liquid Level
Indicators
Demonstrate function of sump liquid level detectors by
filling sump (can be done during agent change-over
decontamination step).
Agent campaign
change-over
Metal Sump Completely empty sump and inspect metal sump for
deteriorating surface coating, corrosion, and cracks.
Agent campaign
change-over
* Since sumps SDS-PUMP-I57, and 188 are located in high temperature areas near the LICs and a cool down is
required before a physical visual inspection can occur, the physical visual inspections for these sumps is done on a
monthly frequency.
Attachment5-Page34
TOCDF
Inspection Plan
June 2009
TABLE 5-20
EIWIRONMENTAL INSPEC TION
FORTHE
MUNITIONS DEMILITARI ZATION BUILDING
DEMILITARIZATION & MATERIAL HANDLING SYSTEMS
ITBM
264.1s(bx1)
TYPES OF PROBLEMS
264.1s(bx3)
TREQUENCY
264.15(bX4)
Munitions/Bulk Container Demil Machines
PHS-PMD-101 Observe the operation of the machines. Note the
number of times each machine has to be put into
manual mode because an interlock on the machine
prevented further processing (in order to evaluate any
deterioration in the machine's performance).
Daily
PHS-PMD-IO2
MMS.BDS.IOI
MMS-BDS-IO2
PHS-MDM-101
PHS-MDM.IO2
PHS.MDM.l03
Material Handline Conveyor Systems
Explosive Containment
Vestibule
Visually inspect for munitions and/or munitions
components not being transferred by conveyors due to
hung up or falling on the floor. Ensure that all
containers are able to be moved by material handling
system. Record the number of rejects in the ECV and
Munitions Processing Bay.
Daily
Explosive Containment
Room(s)
By-Pass Convoyor
Projectile Tilting
Conveyors
Multiposition
Loader(s)/Pick and Place
Machines
Buffer Storage Area
(supporting Munitions
Processing Bay)
Munitions Corridor
Munitions Processing Bay
(including Pick and Place
Machines)
Buffer Storage Area
(supporting MPF)
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by an
operator in the Control Room.
Attachrnent5-Page35
TOCDF
Inspection Plan
June 2009
TABLE 5-2I
ENVIRONMENTAL INSPECTION
FOR THE
AGENT COLLECTION TANKS
ACS-TANK- I 0 1, ACS-TANK- 1 02
AND
ACS TANK SECONDARY CONTAINMENT SYSTEM
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264.1s (bX3)
TREQUENCY
264.15 (bX4)
Level Indicators and
Transmitters
Check level indicator transmitters for proper operation at
control panel.
Daily
Tank Structure Visually inspect for major corroded areas, discolored, or
blistered surface coatirg, buckles or bulges in tank,
corrosion around foundation, and evidence of overtopping.
Daily
Fixed Roof and Closure
Devices
Visually inspect to check for defects that could result in air
pollutant emissions. Defects include, but are not limited to,
visible cracks, holes or gaps in the roof sections or between
the roof and the tank wall; broken, cracked, or otherwise
damaged seals or gaskets on closure devices; and broken or
missing hatches, access covers, caps, or other closure
devices.
Annually
Tank Area Visually inspect for evidence of waste residue on floor.Daily
Tank Supports Visually inspect for discolored or blistered surface coating
and corroded areas.
Daily
Pipe System, Valves, and
Pumps
Visually inspect for leaks, vibration or swaying of pipe
systems, missing pump anchor bolts.
Daily
Secondary Containment
SystemSDS-PLIMP- l5 1
Visually inspect for the presence of liquid in secondary
containment sump by observing the status of sump's liquid
level indicator.
Daily
Secondary Containment
System (including Toxic
Cubicle Floor)
During physical visual inspection, inspect for cracks and
deterioration of protective coating of secondary containment
system and Toxic Cubicle floor. Also inspect all items as
listed above.
Weekly
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by an operator in the
Control Room.
Physical visual inspections are performed at a minimum on a weekly basis.
Attachment5-Page36
TOCDF
Inspection Plan
June 2009
TABLE 5-22
ENVIRONMENTAL INSPECTION
FORTHE
SPENT DECONTAMINATION SOLUTION TANKS
SDS-TANK-101, SDS-TANK-102, SDS-TANK-IO3
AND
SDS.TANK SECONDARY CONTAINMENT SYSTEM
ITEM
264.15(b)(1)
TYPES OF PROBLEMS
264.15 (bX3)
FREQUENCY
264.15 (bX4)
Level Indicators and
Transmitters
Check level indicator transmitters for proper operation at
control panel
Daily
Tank Structure Visually inspect for major corroded areas, discolored, or
blistered surface coatirg, buckles or bulges in tank, corrosion
around foundation, and evidence of overtopping.
Daily
Tank Area Visually inspect for evidence of waste residue on floor.Daily
Tank Supports Visually inspect for discolored or blistered surface coating and
corroded areas.
Daily
Pipe System, Valves, and
Pumps
Inspect for leaks, vibration or swaying of pipe systems, missing
pump anchor bolts.
Daily
Secondary Containment
SystemSDS-PUMP-150
Visually inspect for the presence of liquid in secondary
containment sump by observing the status of sump's liquid level
indicator.
Daily
Ultrasonic Thickness
Testing
Inspect for corrosion (i.e., loss of shell thickness). If the
measured wall thickness is less than or equal to 0.25 inches,
then the affected tank is taken out of service until the TOCDF
and DSHW agree upon an appropriate course of action.
Annual
Secondary Containment
System (including Toxic
Cubicle Floor)
During physical visual inspection, inspect for cracks and
deterioration of protective coating of secondary containment
system and Toxic Cubicle floor. Also inspect all items as listed
above.
Weekly
Notes: Visual inspections are performed remotely through the use of Closed Circuit Television by an operator in the
Control Room.
Physical visual inspections are performed at a minimum on a weekly basis.
Attachrnent 5 -Page37
TOCDF
Inspection Plan
June 2009
TABLE 5.23
EIWIRONMENTAL INSPECTION
FORTHE
BRINE REDUCTION AREA STJRGE TAIIKS
BRA-TANK-101, BRA-TANK-102, BRA-TANK-201, BRA-TANK-202, BRrNE LOADING STATTON, PIPE
TRENCH
& SECONDARY CONTAINMENT SYSTEM
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
Level Indicators and
Transmitters
Check level indicator and transmitter for proper operation at the
tank.
Daily
Tank Structure Visually inspect for major coroded areas, bulging or buckles in
tank, waste residue stains on the sides of tanks and evidence of
overtopping.
Daily
Pipe System, Valves, and
Pumps
Visually inspect for leaks, vibration or swaying of operating pipe
systems, missing pump anchor bolts, leaking pump seals.
Daily
Pipe Trench Visually inspect for presence of liquids in secondary containment
system. Ensure that there are no cracks or gaps in the coatino
used to seal the secondary containment trench.
Annually
Secondary Containment
System (includes sump
and Brine Loading
Station)
Visually inspect for presence of liquids in secondary containment
system and associated sump. Ensure that there are no cracks or
gaps in the coating used to seal the secondary containment
berms, floor, and sump.
Daily
Cathodic Protection Confirm proper operation of the cathodic protection systems.Annually
Inspect/test sources of impressed current.Every other
month
Notes: Physical visual inspection performed daily by Operator(s).
Attachment 5 - Page 38
TOCDF
Inspection Plan
June 2009
TABLE 5-24
ENVIRONMENTAL INSPECTION
F'OR THE
IGLOO 1632 AND 1633 CONTAINER STORAGE AREAS AND
SECONDARY CONTAINMENT SYSTEMS
TYPES OF PROBLEMS
264.1s(B)(3)
ITEM
264.1s(BX1)
TREQUENCY
164.15(BX4)
Deteriorating Containers
and Secondary
Containment Pallets
Inspect the containers and the secondary containment pallets
for deterioration (i.e., rupture, colrosion, released material,
etc.).
Ensure that all container covers/closure devices are secured
in a closed position so that there are no visible holes, gaps or
other open spaces into the interior of the container. R3l5-8-
22 140 CFR 264.108(cX3)l identifies allowable exceptions
to this requirement.
Closed Containers
Containers in Storage Ensure that the total volume of containers in storage does not
exceed 14,520 gallons.
Ensure that the combined liquid volumer within the
containers on a single secondary containment (SC) pallet
does not exceed l0-times the SC pallet's rated capacity.
Ensure that the liquid volu*e' of the single largest container
on a secondary containment pallet does not exceed the SC
allet's rated caoaci
Segregation of
Incompatible Wastes
Ensure that incompatible waste is not placed on a secondary
containment pallet as the same time.
Container Labels Inspect all containers in storage to ensure they are correctly
labeled.
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perforrnance.
General Area Inspect Igloo 1632 and 1633 areas for apparent spills or
leaks from the containers or secondary containment pallets,
and for the accumulation of orecioitation.
Physical visual inspection performed throughout the week by TOCDF personnel.
lFor the purposes of determining required secondary containment capacity, only the volume of an overpacked container
needs to be considered, not the volume of the overpack itself as long as the overpack contains only the leaking container (e.g.
a 55-gallon drum of liquid waste overpacked in an S5-gallon overpack contributes only 55-gallons to the required SC
capacity).
Attachment5-Page39
TOCDF
Inspection Plan
June 2009
TABLE 5-25
ENVIRONMENTAL INSPECTION
FORTHE
BRINE REDUCTION AREA POLLUTION ABATEMENT SYSTEM
ITEM
264.15(bX1)
TYPES OF PROBLEMS
264,15(bX3)
FREQUENCY
264.15(bX4)
Process Parameters Record differential pressure reading for each baghouse and
compare the value with the previous day to determine if
baghouse perfortnance consistent.
Daily
Process Equipment
Knockout Box
Inspect flanged joints joining ductwork to Knockout Box,
Knockout Box manway cover, Knockout Box hopper knife
gate, rotary valve, and Knockout Box flashing for salt
residue buildup.
Daily
Process Equipment
BRA PAS Ductwork
Inspect flanged fittings in ductwork for buildup of salt
residues.
Daily
Process Equipment
BRA Baghouses
Inspect hopper knife gates, rotary valves, and access doors
for buildup of salt residues.
Daily
Knockout Box Discharge
Container & Transfer hose
Inspect container for the presence of hazardous waste label
and ensure label is dated and that the label date does not
exceed 90 days. Inspect transfer hose for crack or tears.
Inspect outside of container and area around container for
salt residue.
Daily
Baghouse Discharge
Containers & Transfer
Hoses
Inspect containers for the presence of hazardous waste labels
and ensure the label is dated and that the label date does not
exceed 90 days. Inspect transfer hoses for cracks or tears.
Inspect outside of containers and area around each container
for salt residue.
Daily
Baghouse Pad Sump Inspect sump to ensure no liquids are present in the sump. If
liquids are present sample for pH and oil sheen.
Daily
Exhaust Stack Plume Observe exhaust stack plume to ensure BRA PAS is
functioning properly.
Daily
Emergency Equipment Inspect for the presence of a charged fire extinguisher, and
the presence of portable or fixed eyewash station.
Weekly
Compliance Process
P arameter Instrumentation
Inspect calibration label on temperature sensing element TI-
l72and Differential Pressure Transducers PDI- 143, PDI-
144, PDI-l45,and PDI-l86to ensure that the certified
calibration seal has not been broken or tampered with.
Daily
Notes: Physical visual inspection performed daily by Pollution Abatement System Operator(s).
Attachment5-Page40
TOCDF
Inspection Plan
June 2009
TABLE 5-26
ENVIRONMENTAL INSPECTION
TOCDF MUNITIONS
VENTILATION
FORTHE
DEMILITARI ZATION BUILD IN G
CARBON FILTER SYSTEM
ITEM
264.1s(bx1)
TYPES OF PROBLEMS 264.15(bX3)FREQUENCY
264.15(bX4)
Agent Monitors Observe the values reported from the ACAMS monitoring
the MDB ventilation carbon filter banks (to determine if
breakthrough of any carbon bank has occurred).
Daily
Differential Pressures Observe the values reported from the differential pressure
transmitters (to determine if plugging of any carbon filter
bank has occurred).
Daily
Filter System Blowers Observe the flow rates reported by the filter system blowers
(to determine if blower perfofinance has deteriorated).
Daily
Notes: Visual inspections are performed remotely by Control Room Operator(s) through use of the data acquisition
system.
TABLE 5-27
SAFETY AND EMERGENCY EQUIPMENT INSPECTION
FOR
EMERGENCY RESPONSE EQUIPMENT
(For all EG&G Operated Facilities)
ITEM(quantity)
264.1s(bx1)
TYPES OF PROBLEMS
264.1s(bx3)
FREQUENCY
264.1s(bx4)
HAZMAT Truck with Decon
Trailer
Parked in proper location, gas tank is more than half
full, engine starts.
Monthly
Ton Container
Repair Kit (l)
Inspect kit seal to ensure that the contents of the kit are
complete. If the seal is broken inspect contents of kit.
Monthly
85 Gallon Overpacks (3)Inspect for sufficient quantity.Monthly
*OSHA Level A Response
Suits (12)
Inspect for sufficient quantity and functionality Monthly
OSHA Saranex Suits (6)Inspect for sufficient quantity and functionality Monthly
OSHA Level
C Response Suits (6)
Inspect for sufficient quantity and functionality Monthly
SCBA Packs with
Bottles (6)
Inspect for sufficient quantity and functionality Monthly
Spare Air Pack Bottles (6)Inspect for sufficient quantity and functionality Monthly
Respirats{g with
particulatel or ganic vapor
cartridges (6)
Inspect for sufficient quantity and functionality Monthly
Non-'sparking Tool Kit (l Inspect for completeness of kit Monthly
Portable Eyewash Station ( I Inspect for functionality Monthly
Caustic Neutralizer
( 10 eallons)
Inspect for sufficient quantity Monthly
Acid Neutrahzer
( l0 eallons)
Inspect for sufficient quantity Monthly
Shovels (5)Inspect for sufficient quantity Monthly
Brooms (5)Inspect for sufficient quantity Monthly
Attachment 5 - Page 4l
TOCDF
Inspection Plan
June 2009
TABLE 5-27
SAFETY AND EMERGENCY EQUIPMENT II{SPECTION
FOR
EMERGENCY RESPONSE EQUIPMENT
(For all EG&G Ooerated Facilities)
ITEM(quantity)
264.15(bX1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.15(bX4)
Absorbent (100 lbs.)Inspect for sufficient quantity Monthly
Foot Baths (4)Inspect for sufficient quantity Monthly
:&:rTAP Butyl M3 Coveralls or
OSHA A Response Suits (6)
Inspect for sufficient quantity and functionality Monthly
TAP Butyl Hood (6)Inspect for sufficient quantity and functionality Monthly
TAP BuM M2 Gloves (6 pair)Inspect for sufficient quantity and functionality Monthly
OSHA Overboots
(6 Pair)
Inspect for suflicient quantity and functionality Monthly
TAP Butyl M2Al Boots (6
Pair)
Inspect for sufficient quantity and functionality Monthly
TAP Butyl M2 Aprons or
OSHA Level C Coveralls (6)
Inspect for sufficient quantity and functionality Monthly
Agent Antidote Kits (6)Inspect for sufficient quantity Monthly
Water for Decon (25 gallons)Inspect for sufficient quantity Monthly
Notes:
* There are at least 12 OSHA Level A Response Suits that are stored in the PMB TAP Room.
** There are at least 6 TAP Butyl M# Coveralls or OSHA Lrvel A Response Suits stored on the HAZMAT Truck.
Attachment5 -Page42
TOCDF
Inspection Plan
June 2009
. TABLE 5.28
SAFETY AND EMERGENCY EQUIPMENT INSPECTION. FoR rHE-!reDE
EMERGENCY"GENEBATORS, SECURITY, HAZARD COMMUNICATION, &
FIRE PROTECTION SYSTEMS
ITEM
264.1,5(bX1)
TYPES OF PROBLEMS
264.15(bX3)
FREQUENCY
264.1s(b)(4)
Emergency Generators Test each Emergency Generator by operating in either a
loaded or unloaded configuration.
Monthly
Filter Generator Test the Filter Generator by operating in either a loaded or
unloaded configuration.
Monthly
Unintemrptible Power
Supply
Check for Adequate Voltage.Monthly
Emergency Power
S ystem/Unintemrptib 1e
Power Supply
Test Emergency Generators and Unintemrptible Power
Supply by performing a power outage exercise. Ensure
sufficient power is provided to equipment and systems
designated as critical and essential loads.
Annually
Security
Fencing Visually inspect the fences and gates surrounding TOCDF
for integrity, sight obstructions caused by vegetation, and
gaps at the fence base.
Weekly
Warning Signs Visually inspect for the presence of all signs. Sign must be
leeible from a distance of 50 feet.
Weekly
Outside Security Liehtine Visually inspect the liehts for proper operation.Weekly
Site Evacuation Siren Verify operability of evacuation siren.Weekly
Fire Protection Systems
Halon Veriff sufficient pressure in halon storage tanks.Six months
Control Room
UPS/B attery Enclosures
and FM-200|FE-227
Verify sufficient pressure in FM-200/FE -227 storage tanks.Six months
Dry Chemical Verify sufficient pressure in nitrogen propellant tanks.Six months
Common PAS
Toxic Chemical
Automatic Sprinkler Veriff sufficient flow rate of water at inspector's test
connection.
Annually
CHB
UPA
Fire Hydrants Verifu sufficient flow Annually
Attachrnent5 -Page43
TOCDF
Inspection Plan
June 2009
TABLE 5-29
ENVIRQNMENTAL INSPECTION
F'ORTHE
IGLOO 163l AUTOCLAVE'
SUPPORTING CARBON FILTER SYSTEM, AND HAZAROUDS WASTE LOAD AREA
ITEM
264.1sftX1)
TYPES OF PROBLEMS
264.15ftX3)
FREQUENCY
264.15ftX4)
Autoclave and Ancillary
Equipment
Autoclave Door
Inspect Locking Ring and Hinges. and Rollers for proger
operation.
Inspect O-Ring for cracks or gaps.
IuspestDaorand Vessel ioint for sisns oJsteam leaks
Weekly
Autoclave Exterior
Insoect for siqns of rust Weekly
Process Steam Piping
Insoect for leaks audlor drips
Daily
(when in use)
Cooling Tower and Condensate Transfer Pumps
Inspect fur leaks, unbroisal noise and vibrations
Daily
(when in use)
Condensate Transfer Lines
Inspect for rust and leaks andlor drips
Daily
(when in use)
Material Handling
Equipment
Observe material handling equipment during operation to
determine any loss of perforrnance including hydraulic or oil
leaks, frayed cablcs, jrrky movement. Review the Site Work
Order database for newly-generated maintenance requests.
Weekly
Autoclave Carbon
Adsorption Filtration
System
Inspect ductwork for fugitive emissions or residues at
flanged duct connections.Weekly
Inspect joints for breaks that would result in in-leakage to the
system.Weekly
Observe pressure on Carbon Filter System Pressure Gauge to
ensure system is operated under negative pressure relative to
atmospheric (i.e., negative pressure in excess of 0.25 in-
w.c.).
Daily
(when in use)
Igloo 163l Floor
Inspect floor area traversed by the condensate transfer piping
and Autoclave load/unload area for condensate and/or wet
spots.
Daily
(when in use)
Igloo 1631 Waste
Load/Unload Area
Ensure Roll-Off is closed except when waste is being added
to it
Inspect for debris or waste that fell from the roll-off during
transfer
Daily
(when in use)
Attachrnent 5 -Page44
TOCDF
Inspection Plan
June 2009
TABLE 5-30
ENVIRONMENTAL INSPECTION
FORTHE
rGLOO 1632 DRUM VENTILATTON SYSTEM (DVS) ENCLOSURES, SORTTNGROOM (DVSSR) Ar[D THE
IGLOO CARBON ADSORPTION FILTRATION SYSTEM
ITEM
264.15(B)(1)
TYPES OF PROBLEMS' 264.15(BX3)
FREQUENCY
164.15(BX4)
DVS Enclosures 101I 102
and DVSSR
Inspect secondary containment floors and sumps for
presence of standing liquids (sumps must be emptied of
liquid within 24 honrs of collection), inspect sumps for signs
of deteriorations, cracks, gaps or evidence of leakage.
Ensure the DVS and DVSSR doors are closed if un-
containenzedwaste is within the unit.
Daily
(when in use)
DVS Enclosure 101
Miscellaneous Treatment
Unit
Inspect the enclosure, including observation windows,
gloves, penetration seals, vent ducting for signs of
deterioration, cracks, gaps or evidence of leakage. Ensure
that the enclosure sump is emptied and that the main feed
door and at least one of the airlock doors are fully closed
(unless waste is currently being put in or taken out) Visually
inspect the enclosure floors and sump for the presence of
standing liquid, signs of deterioration, cracks, gaps, or signs
of leakase
DVS Enclosure 102
Miscellaneous Treatment
Unit
Inspect the enclosure, including observation windows,
gloves, penetration seals, vent ducting for signs of
deterioration, cracks, gaps or evidence of leakage. Ensure
that the enclosure sump is emptied and that the main feed
door and at least one of the airlock doors are fully closed
(unless waste is currently being put in or taken out) Visually
inspect the enclosure floors and sump for the presence of
standing liquid, signs of deterioration, cracks, gaps, or signs
of leakase
DVS Sorting Room
(DVSSR) Miscellaneous
Treatment Unit
Inspect the sorting room, including doors, walls, observation
windows, penetration seals, vent ducting for signs of
deterioration, cracks, gaps or evidence of leakage. Ensure
that the interior floor and sump is dry and that the doors are
closed (unless personnel are currentiy entering or exiting).
Visually inspect the eirclosure floors and sump for the
presence of standing liquid, signs of deterioration, cracks,
aps. or sisns of leakase
Igloo Carbon Adsorption
Filtration System
Inspect main and backup filter housings and ducting for
Signs qf deterioration, cracks, gaps, evidence of gas leakage.
'Inspect induction fans for signs of degradation or failure.
Ensure DVS Enclosures and DVSSR are operating in excess
of 0.25 in-w.c. nesative Dressure.
Weekly
Material Handling
Equipment
Observe material handling equipment (i.e., forklift and
hoists) during operation to determine any loss of
performance, including hydraulic or oil leaks, frayed cables,
jerky movement. Review the Site Work Order database for
newlv- senerated maintenance reouests.
Physical visual inspection performed throughout the week by TOCDF personnel.
Attachrnent5-Page45
TOCDF
Inspection PIan
June 2009
TABLE 5.31
ENVIRONMENTAL INSPECTION
FOR TIIE
ATLIC TON CONTAINER GLOVF-BOXES
ITEM
26/,.15(bX1)
TYPES OF PROBLEMS
26/,.15(bX3)
FREQUENCY
zffi.15(bX4)
Glove-box Gloves
Inspect gloves and their penetration seals/gaskets for
cracks. holes or tears. Ensure labeled service life of the
elove has not expired
Dailv
Glove-box Pressure
Observe and record Glove-box pressure reading to ensure
negative pressure is maintained within the glove-box
whenever a ton container or waste is Dresent
Dailv
Glove-box Interior
Observe interior of elove-box through the observatlon
windows to determine if connections to ton container.
valves and piping are not leaking. Observe for presence of
Dailv
liouids
Phvsical visual insnection performed bv local operator.
Attachment5 -Page46
TOCDF
Inspection Plan
June 2009
TABLE 5.32
ENVIRONMENTAL INSPECTION
FOR
ATLIC LIC PRIMARY AND SECONDARY CHAMBERS
ITEM
264.1sftX1)
TYPES OF PROBLEMS
264.150X3)
FREOUENCY
264.150X4)
Primary Chamber
Waste Handline/Pipine
Inspect for leaks in the agent feed line at threaded and
flansed pipe connections.
Daily
Secondary Chamber
Waste Handling/Pipine
Inspect for releases of wastes from the spent decon solution
feed line at welded and flanged pipe connections.
Daily
Primary Chamber Inspect for fugitive emissions and hot spots on the outer
shell of the primary chamber. which would indicate a
breakdown of the chamber's refractorv.
Daily
Secondary Chamber
Inspect for fugitive emissions. and hot spots on the outer
shell of the secondary chamber. which would indicate a
breakdown of the c,hamber's refractory.
Daily
Combustion Air Blower Evaluate combustion air blower performance through
Control Room advisor screen observations.
Daily
ATLIC Room Floor
Inspect for residues of lubricant and/or wastes beneath the
components of the LIC agent feed system and the LIC
exhaust gas ductwork.
Daily
Waste Feed Cut-Off
Mechanism
Test control circuit and document that te feed is
stopped.
Every 3e 14 days
or prior to
orocessing waste
if waste feed is
suspended for
lonser than 14
davs
Notes: Visual inspections are oerformed remotely throueh the use of Closed Circuit Television by the incinerator
ooerator in the Control Room.
Physical visual inspections are oerformed at a minimum on a monthly basis.
Attachrnent 5 -Page47
TOCDF
lnspection Plan
June 2009
TABLE 5-33
ENVIRONMENTAL INSPECTION
FOR
ATLIC LIC
POLLUTION ABATEMENT SYSTEMS
ITEM
264.1sft)(1)
TYPES OF PROBLEMS
264.15ftX3)
FREOUENCY
264.15(bX4)
Exhaust Gps (PAS)
Ductwork
Inspect for fugitive emissions or residues at flaneed duct
connections and duct expansion joints. Inspect expansion
ioints for breaks that would result in leakase to the system.
Daily
Ouench Tower Inspect for brine residues at manway covers and released
liquids fronn pipine or pumps.
Daily
Packed Bed Scrubber Inspect for scrubber liquid residues at manway cover.
Inspect for release of scrubber liquid from associated pumps
Daily
and pipine.
Venturi Scrubber Check venturi plug valve and ensure that it operates freely.
Inspect for releases of scrubber liquid from associated pumps
Daily
and pioine.
Moisture Separator Inspect for fugitive emissions or residues of scrubber liquid
at the inlet and outlet flanges connections.
Daily
Baghouse Inspect inside Baghouse residue enclosure for integritv of
the waste residue container's connection to the Baghouse
hopper at discharge gate and for waste residues.
Daily
PAS Blower Inspect for excessive vibrations and loss of lubricant.Dailv
Scrubber Eflluent
Handling System
Inspect brine transfer line and associated pumps for leaks at
pump seals and flanged pipefittings. Inspect for swaying
pipe system during operation.
Daily
Notes: Phvsical visual insoection perfiormed daily by Pollution Abatement System OperatorG).
Attachrnent5-Page48
TOCDF
Inspection Plan
June 2009
!
TABLE 5-34
INSPECTION
FOR
ATLIC AGENT MONITORS
ITEMS
264.1sftX1)
TYPES OF PROBLEMS
264.15ft)(3)
FREOUENCY
264.15ftX4)
ATLIC Exhaust Stack
TEN-709 and TEN-710
Perform agent challenge test IAW Attachment 22A to
determine the need to calibrate monitor. calibrate if aeent
Aeent Challenge
(Every 4 hrs.)
test results in failure. Replace monitor if it can't be
calibrated to soecification.
ATLIC Filter Stack
(TEN-7s0)
Perform agent challenge test IAW Attachment 22A to
determine the need to calibrate monitor. calibrate if aeent
Agent Challenee
(Daily)
test results in failure. Replace monitor if it can't be
calibrated to specification.
Notes: The (TAG ID's) used are those that appear on the Control Room advisor screens and the Process Data
Acquisition and Reoorting System generated reports.
TABLE 5-35
ENVIRONMENTAL INSPECTION
FORTHE
ATLIC VENTILATION CARBON FILTER SYSTEM
TYPES OF PROBLEMS 264.15ftX3)
Observe the values reported from the ACAMS monitoring
the ATLIC ventilation carbon filter banks (to determine if
breakthroueh of any carbon bank has occurred) and
vestibules to determine if corrective action is required.
Record alarm status
Differential Pressures Observe and record the values reported from the
differential pressure transmitters (.to determine if plugging of
anv carbon filter bank has occurred
Filter System Blowers Observe and record the flow rates reported by the filter
system blowers (.to determine if blower performance has
deteriorated).
Notes: Visual inspections are performed remotely by Control Center Equioment Enclosure Operator(s) throueh use
of the data acouisition system.
Attachment5 -Page49
TOCDF
Inspection Plan
June 2009
TABLE 5.36
SATETY AND EMERGENCY EQUIPI\4ENT INSPECTION
FOR TIIE ATLIC
EMERGENCY GENERATORS. SECURITY. HAZARD COMMUNICATION. &
FIRE PROTECTION SYSTEMS
ITEM
264.15(bX1)
TYPBS OF PROBLEMS
264.15(bX3)
FREQI'ENCY
264.15(bX4)
Emgrgpncv Generators Test e.ach Emergencv Generator bv operating in either a
loaded or unloaded configuration.
Monthlv
Unintemrptible Power
Supply
Check for Monthlv
Emerggncv Power
S v stem/ Uninte rruptib le
Pqwqr Supplv
Test Emergencv Generators and Uninterruptible Power
Suqplv bv performing a power outage exercise. Ensure
sufficient.power is provided to equipment and svstems
designated as critical and essential loads.
Annuallv
Fire kotection Svstems
ATLIC Control Room Fire
Suppression Svstem
Vs:rifv suf,ficient pressure in storage tanks.Six months
Automatic Sprinkler
System
Verifv sufficient flow rate of water at inspector's test
connection.
Annuallv
Attachment5-Page50
TOCDF
Inspection Plan
June 2009
TABLE 5-37
ENVIRONMENTAL INSPECTION
FORTHE ATLIC TOX AREATANKS
ITEM
264.1s(bx1)
TYPES OF PROBLEMS
264.15 (bX3)
FREOUENCY
264.15 ftX4)
Level Indicators and
Transmitters
Check level indicator transmitters for proper operation at
control panel.
Daily
Tank Structure Visually inspect for major corroded areas. discolored. or
blistered surface coatine. buckles or bulges in tank.
corrosion around foundation. and evidence of overtooping.
Daily
Fixed Roof and Closure
Devices
Visually inspect to check for defects that could result in air
pollutant emissions. Defects include, but are not limited to
Annually
visible cracks. holes or gaps in the roof sections or between
the roof and the tank wall: broken. cracked. or otherwise
damased saals olgasl<qts ou closure devices; and broken or
missing hatches. access covers. caps. or other closure
devices.
Tank Area Visuallv inspect for evidence of waste residue on floor.Dailv
Tank Supports Visually inspect for discolored or blistered surface coating
and corroded areas.
Daily
Pipe System. Valves. and
Pumps
Visually inspect for leaks. vibration or swaying of pipe
svstems. missinq oumo anchor bolts.
Daily
Secondary Containment Visu.ally inspect for the presence of liquid in Toxic Area
sumD by observins the status of sump's liquid level indicator.
Daily
Secondary Containment
System (includine Toxic
During physical visual inspection. inspect for cracks and
deterioration of protective coatins of secondary containment
Weekly
Area Floor)system and Toxic Cubicle floor. Also inspect all items as
listed above.
Notes: Visual inspections are oerf,ormed remotely through the use of Closed Circuit Television by an ooerator in the
Control Room.
Physical visual insoections are oerformed at a minimum on a weekly basis.
Attachrnent5-Page5l
o
o
o
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009.'
ATTACHMENT 6
INSTRI'MENT CALIBRATION PLAN
&
INCINERATOR WASTE FEED INTERLOCK FT]NCTION TEST
l
l
l
l
I
I
I
I
l
I
l
I
I
I
I
I
I
I
I
I
1
l
I
I
I
l
l
l
Attachment6-Pagel
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
Table of Contents
Scope
InstrumenVAlarm Tag ID Nomenclature
Instrument Calibration and Preventative Maintenance Methods
Overview
Instrument Preventative Maintenance/ Calibration Methods
Analyzer Indicator, Transmitter (XX-AIT-XXX)
Continuous Emission Monitoring System
pH Anallzers
Density Indicator, Transmitter (XX-DIT-XXX)
Flow Indicator, Transmitter (XX-FIT-XXX)
Mass Flow Meters
Electro-Magnetic Flow Meters
Differential Pressure Indicator, Transmitters (XX-PDIT-XXX)
Level Indicator, Transmitter (XX-LIT-XXX)
Differential Pressure Transmitters
Ultrasonic and Radar-Level Transmitters
Level Switches (XX-LSHH-XXX)
Temperature Indicator, Transmitter (XX.TIT-XXX)
Current Switches (XX-TSLL-XXX)
Temperature Switches (XX-TSHH-XXX)
Pressure Indicator, Transmitters (XX-PIT-XXX)
Pressure Switches (XX-PSHH-XXX)
Weight Indicator, Transmitters (XX-WIT-XXX)
Chemical Agent Monitors (PAS 7XXA, B, C)
lncinerator Waste Feed Interlock Function Test
Process Data Instrumentation Calibration and Waste Feed lnterlock Tables
Attachment 6 - Page2
6-4'-1
6-A-2
6-B
6-C
6-D
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
LIST Of TABLES
Liquid Incinerator #1 Process Data and Waste Feed Interlock Instrumentation Calibration
Liquid Incinerator #2 P.rocess Data and Waste Feed Interlock Instrumentation Calibration
Metal Parts Fumace Process Data and Waste Feed Interlock Instrumentation Calibration
Deactivation Fumace System Process Data and Waste Feed Interlock Instrumsntation
Calibration
TankHazardous Waste Management Unit Process Data and Tank Overtop Protection
Inskumentation Calibration.
ATLIC Incinerator Process Data and Wastg Fe
ATLIC TankHazardous Waste Management Unit Process Data and Tank Overtop
Protection Instrumentation Calibration.
6-E
6-F
Attachment6-Page3
ACA]VIS
ACS
AQS
ATLIC
BDS
BRA
CEMS
DFS
GA
Instrument Calibration Plan & Incinerator Waste Feed Interlock arr.,l:??rI
June 2009
List of Acronyms
Automatic Continuous Air Monitoring Systern
Agent Collection System
Agent Quantification System
Area 10 Liquid Incinerator
Bulk Drain Station
Brine ReductionArea
Continuous Emission Monitoring System
Deactivation Fumace System
Nei:r're Aee,nt GA Tabun
Hazardous Waste Management UnitsHWMU
L Lewisite
LIC
MDM
MINICA]\dS
MPF
PAS
PDAR
PLC
RCRA
SDS
TOCDF
Liquid Incinerator System
Multipu{po s e D emil ttanzation Machines
Miniature Continuous Air Monitoring System
Metal Part Furnace System
Pollution Abatement System
Process Data Acquisition and Recording
Programmable Logic Controller
Resource Conservation Recovery Act
Spent Decontamination System
i- Tooele Chemical Agent Disposal Facility
Attachment6 -Page4
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
6.1 SCOPE
6.1.1 This Calibration Plan:
6. 1 .1 .1 Describes the basis for assigning TAG IDs to the various instruments and alarms
associated with components of the process control systems for Subpart X treatment units,
tanks, and incinerators.
6.1.1.2 Identifies components of the process control system associated with an incinerator
requiring proper operation to ensure proper waste treatment, to stop/prevent the feeding of
hazardous waste to an incinerator should the magnitude of permit regulated operating
parameters exceed limits imposed by permit condition, and to demonstrate compliance
with the conditions of this Permit.
6.1.1.3 Identifies components of the process control system associated with permitted tank
requiring proper operation to determine accurate volumes of liquid wastes stored in tanks,
to prevent the overtopping of tanks, and to demonstrate compliance with Permit conditions
limiting the volume of hazardous waste stored in tanks.
6.1.1.4 Identifies components of the process control system associated with permitted Subpart X
treatment unit requiring proper operation to ensure proper waste treatment, to stop/prevent
the feeding of hazardous waste to Subpart X treatment unit, should the magnitude of
permit regulated operating parameters exceed limits imposed by permit condition, and to
demonstrate compliance with the conditions of this Permit.
6.1.1.5 Differentiates between instrumentation calibrated by the user and instrumentation
calibrated by the manufacturer.
6.1.1 .6 Differentiates between instrumentation that is calibrated and function tested, and
instrumentation that is function tested only.
6.1.1.7 Describes the methods used to veri$ operational accuracy (i.e., function test) and calibrate
different types of process control instrumentation associated with the demonstration of
compliance with the conditions of this Permit.
6. 1 .1 .8 Describes the methods used to function test the waste feed interlock system associated
' with each incinerator and the overtop protection system associated with each tank.
6.2 INSTRUMENT/ALARM TAG ID NOMENCLATURE
6.2.1 A unique TAG ID is used to identiff each instrument and alarm. An instrument's TAG
ID is stamped on a tag physically attached to (or in close proximity to) the instrument.
Each instrument TAG ID is comprised of a two-digit or three-digit prefix "system
identifier," followed by a three or four-letter "instrument tlpe identifier," followed by a
one to three-digit suffix "instrument number."
6.2.2 The two-digit/three-digit prefix "system identifier" and the corresponding systems are
presented below:
Attachrnent6-Page5
SYSTEM
IDENTTFIER
CORRESPONDING SYSTEM
1I-XXX-XXX Toxic Cubicle (TOX)
Includes Agent Collection System associated with ACS-
TANK-101 & ACS-TANK-L}} and Spent Decontamination
System associated with SDS-TANK-I0I, SDS-TANK-L}} &
SDS-TANIK-I03
1 a \z\z\z \7\z\z Y :---:l T-^ . l-^^-^^t^-^ Ct---L. -- -- lT r^ 1 O- T Trt ^\I J -.ar..aL-ar, -.{\-a|.-/\.L/IqUr(l UIUUItiIatUI Dylitt IIrU (IJIU I, OC IJL\/ L)
14-XXX-XXX Metal Part Furnace System (MPF)
16-XXX-XXX Deactivation Furnace System (DFS)
23-X)(X-XXX Brine Reduction Area System including: BRA-TANIK-101,
BRA-TANIK -102, BRA-TA}TK -20I, BRA-TANK -202,
BRA-EVAP-I O 1, BRA-EVAP -20I, BRA-DDYR-I O 1, BRA-
DDYR -102, and BRA-DDYR- 201
24-XXX-XXX Incinerator Pollution Abatement Systems: LIC 1 PAS, LIC 2
PAS, MPF PAS, & DFS PAS
27-XXX-XXX Brine Reduction Area Pollution Abatement System including
BRA PAS Baghouse Modules: BRA-SEPA-101, BRA-
SEPA -1A2, BRA-SEPA-I 03, and BRA-SEPA -104
49-XXX-XXX Bulk Drain Station (BDS)
Agent Quantification System associated with the Bulk Drain
Stations (i.e., load cells): BDS-I01, & BDS-I02
51-XXX-XXX Agent Collection System (ACS)
Agent Quantification Systems associated with the Rocket
Shear Machines: RSM-I01, & RSM-102, and the
Multipu{pose Demil Machines: MDM-101, MDM-102, &
MDM.I03
81s-XXX-XXX ATLIC Incinerator
81g-XXX-XXX ATLIC Incinerator Pollution Abatement System
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2409
Attachment6-Page6
6.2.3
6.2.4
6.2.5
6.2.6
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
The following three or four-letter codes are used to identift different types of instruments:
The three-digit numeric suffix is used to differentiate between individual instruments of
the same t1pe.
Even though instruments of the same type share the same three or four-letter "instrument
type identifier" code, and some instruments share the same one to three-digit suffix, a
unique TAG ID exists for each instrument since the complete TAG ID is composed of 1)
the System ID Code, 2) the three or four-letter instrument tlpe identifier and 3) the one to
three-digit suffix instrument number.
TAG IDs describing alarm and switch waste feed interlocks are derived from the
instrument TAG IDs by replacing the last two letters in the instrument type identifier code
with one of the following combinations of letters:
3-4 LETTER CODES INSTRUMENT TYPE
xx-AIT-XXX Analyzer Indicator Transmitters includes Continuous
Emission Monitors for oxygen, carbon monoxide , & carbon
dioxide, and pH analyzers
Density Indicator Transmitters
xx-FIT-XXX Flow Indicator Transmitters
Level Indicator Transmitters
Pressure Indicator Transmitters
xx-PDIT-XXX Pressure Differential Indicator Transmitters
XX-PDT-XXX Pres sure Differential Transmitters
xx-TIT-XXX Temperature Indicator Transmitters
Weight Indicator Transmitters
PAS.XXX Chemical Agent Monitors
ATLIC Chemical Agent Monitors
Attachrnent6 -Page7
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
The "A" and "S" letters in the waste feed interlock TAG ID are used to differentiate
between waste feed interlocks activated by switches located in the field and waste feed
interlocks activated by monitored process values exceeding setpoints established in the
Programmable Logic Controller (PLC) software.
"A" designates a waste feed interlock that is activated when the magnitude of the four to
20 milliamp control signal output from a specific transmitter exceeds a setpoint
established in the PLC software. The transmitter sending the control signal causing the
waste feed interlock can be determined by associating the first letter in the waste feed
interlock TAG ID with the three-digit suffix. As an example, l3-TAHH-610
(Temperature Alarm High High) is generated when the control signal output from
temperature transmitter 13-TIT-610 which monitors the exhaust gas temperature of the
LIC 1 primary chamber exceeds the setpoint established in the PLC software.
6.2.7
6.2.7.1
6.2.7.2
6.2.7.3
6.3
6.3.1
The instrument causing the waste feed
signal, referring to the above example,
TAHH-610 does not exist.
interlock is the transmitter sending the control
13-TIT-610. An instrument with the TAG ID 13-
"S" designates a change in state of a switch (which can be identified in the field by the
TAG ID stamped on the tag attached to the instrument) causes the waste feed interlock.
As an example, a pressure above atmospheric in the LIC I primary chamber causes 13-
PSHH-233 (LIC 1 Pressure Switch #233Hidh High) to open. When this switch is open,
waste feed is stopped/prevented.
INSTRT]MENT CALIBRATION & PREVENTATTVE MAINTENANCE
METHODS'
Overview
I In this plan, the tolerance or accuracyto which an instrument is calibrated is expressed as "percent of span."
Span is defined as the arithmetic difference between an instrument's lower and upper range.
TAG II)ALARM & SWITCHFEED INTERLOCK
xx-xAL-xxx Alarm Low
xx-xALL-xxx Alarm Low Low
xx-xDALL-XXX Differential Alarm Low Low
xx-xsLL-xxx Switch Low Low
xx-xAH-xxx Alarm High
xx-xAlIH-xxx Alarm High High
xx-xDAH-xxx Differential Alarm High
xx-xsHH-xxx Switch High High
Attachrnent6-Page8
6.3.1 .1
6.3.1 .2
6.3,1 .3
6.3.1 .4
6.3.1 .5
6.3.1 .6
6.3 .l .7
6.3.1 .8
6.4
6.4.r
6.4.1 .1
6.4.1 . 1 .1
Instrument Calibration Plan & Incinerator Waste Feed Interlock arr"rl:?:r1
- June 2009
Preventative maintenance performed on components of the TOCDF incinerators and tank
process control systems consists of function/accuracy tests and/or re-calibration.
Preventative maintenance on user-calibrated instrumentation consists of function/accuracy
tests and re-calibration if necessary.
A commercially available process instrumentation calibration system is used at the
TOCDF. The calibration system allows the user to download data specific to each
instrument to be calibrated. The downloaded calibrator is then taken to the field and used
to input (or used to enable the input of1 artificial process values into the instrument being
calibrated. As the artificial process values are being input, the calibrator compares and
records the instruments output. Depending on the output, the instrument is either left as
is, or adjusted so that the output is within the pre-established percentage of the expected
value.
The "as found" and "as left" outputs of the instrument are recorded by the calibrator.
Calibration results are then downloaded from the calibrator to a database and both an
electronic and hard copy record of each calibration event is maintained.
For instrumentation calibrated by the manufacturer, preventative maintenance performed
by the user consists of periodic accuracy/function tests only.
The results of function tests are not recorded in the instrument calibration system database
for instruments calibrated by the manufacfurer. Proper calibration of manufacturer-
calibrated instruments is demonstrated by the certificate of calibration provided by the
manufacturer and the completed preventative maintenance procedure log sheet.
At the conclusion of each function/accuracy test (and re-calibration if necessary) the
validity of the data being sent by the transmitter to the control room advisor screen is
tested by a procedure referred to as a "loop check".
Loop checks are accomplished through coordination between the instrument technician
performing the calibration and control room operators. The instrument technician injects
various artificial control signal values into the instrument and informs the control room
operator of the magnitude of the injected value. The control room operator then
determines (by knowing the strength of the signal being injected and the span over which
the transmitter is calibrated to) the accuracy of the entire control loop. The results of loop
checks are recorded on log sheets that are kept on file and attached to the hard copy of
each function/accuracy test result and/or calibration event.
INSTRT]MENT PREVENTATIVE MAINTENANCE/CALIBRATION METHODS
Analyzer Indicator. Transmitters (XX-AIT-XXX)
Continuous Emission Monitoring Systems
The certification and calibration of hazardous waste incinerator exhaust gas CO and Oz
Continuous Emission Monitoring Systems (CEMS) are regulated by Federal Regulations
found in 40 CFR 266, Appendix IX.
Attachrnent6-Page9
6,4.1 .1.2
6.4.1.1.3
6.4.1.2
6.4.1 .2.1
6.4,1 .2.2
6.4.1 .2.3
6.4.t.2.4
6,4.2
6.4.2.r
6.4.2.2
6.4.2.3
Instrument Calibration Plan & Incinerator Waste Feed Interlock trr;:??l
June 2009
These regulations speciry required methods, frequencies, and accuracies to which the
CEMS must be certified, calibrated, and audited. These include daily Calibration Drift
(CD) tests, quarterly Calibration Error (CE) tests, and annual performance specification
tests @STs).
CO, 02, and NO* CEMS will be managed (i.e., certified, calibrated and audited) as
specified in 40 CFR 266, Appendix IX and outlined in the TOCDF CEMS Monitoring
Plan (CDRL 06).
pH Anallzers
pH analyzers are used to control the capability of PAS scrubber solutions to absorb acid
gases exhausted by the incinerators. The PAS process control system of each incinerator
is equipped with tr'no anallzers monitoring scrubber brine pH. Both analyzers sample the
same location in the process stream. Only one analyzer is active at any one time. The
active analyzer is used to control pH. The analyzer designated to be active is alternated at
equal intervals.
pH analyzers are calibrated by immersing the sensing element in certified buffer solutions
at a pH of 4,7 , and 10 and observing the pH analyzer transmitter's output. The transmitter
is determined to be properly calibrated if the output of the transmitter is within +2.0o/o of
the expected value. pH analyzer transmitters are calibrated at least once every seven days.
As the calibration history on each pH analyzers develops, the users will be able to
determine the stability of the analyzer (i.e., the tendency of the analyzer's transmitter to
drift out of calibration).
If waste feed to an incinerator is discontinued for a period longer than seven days,
calibration of the pH analyzerltransmitter associated with the incinerator is suspended but
will be done prior to the resumption of waste feed.
Density Indicator" Transmitters (XX-DIT-XXX)
The density of Pollution Abatement System scrubber brine solutions for each incinerator is
measured by a vibrating tube type primary sensing element and paired transmitter.
The accuracy of the primary sensing element is established by the manufacturer through
the design. The calibration of the associated transmitter is done by the manufacturer and
is valid over the operational lifetime of the primary sensing element/transmitter pair. The
manufacturer provides the user with a certificate of calibration for each density primary
sensing element/transmitter pair. The user progftlms the transmitter per manufacturer
instructions.
The function and accuracy of the sensing element/transmitter pair is checked by taking a
sample of the scrubber brine and determining the samples density by weighing the sample
or using a hydrometer.
If the density of the sample is within r2.0% of the value reported by the sensing
element/transmitter pair, the instrument is determined to be functioning properly.
6.4.2.4
Attachrxent6-Pagel0
6.4.2.5
6.4.3
6.4.3,1
6,4.3.2
6.4.3.2.1
6.4.3.2.2
6.4.3.2.3
6.4.3.3
6.4.3.3. 1
Instrument Calibration Plan & Incinerator Waste Feed Interlock Orr#??l
June 2009
Proper operation of each density primary sensing elemenVtransmitter pair is tested at least
once every 180 days.
Flow Indicator. Transmitters (XX-FIT-XXX)
Flow rates of incinerator liquid waste feeds, incinerator PAS solutions, and incinerator
exhaust gases are determined using mass flow meters, magnetic flow meters, and
differential pressure sensors respectively.
Mass Flow Meters
Mass Flow Meters are used to measure the feed rate of chemical agent and spent
decontamination solution to the primary and secondary chambers of the Liquid
Incinerators. Each mass flow meter consists of a vibrating tube type primary sensing
element and a transmitter, which are calibrated by the manufacturer. Mass flow meters are
not calibrated by the user; rather the manufacturer provides the user with a certificate of
calibration for each flow meter. The manufacturer's calibration is valid over the life of the
instrument. For mass flow meters, the instrument error increases as the flow rate
decreases. The instrument calibration will be maintained such that the accuracy is within
+0.4% at all flow rates above 10% of the maximum design flow rate.
The TOCDF uses two mass flow meters in series to measure the feed rate of chemical
agent to the primary chamber of each Liquid Incinerator. This ensures accurate
measurements of agent feed rates and the ability to determine proper operation of the mass
flow meters. If the agent feed rates reported by each flow meter are within 5olo of each
other, the flow meters are determined to be functioning properly. If the flow rate values
from each flow meter differ by greater than 5o/o, the flow meter causing the error will be
repaired or replaced with a new factory calibrated one. The mass flow meter causing the
error is determined by physical inspection and/or component continuity checks as
described in literature provided by the manufacturer.
Since mass flow meters are calibrated by the manufacturer, preventative maintenance
performed by the user is limited to checking the "zero value" of each flowmeter (i.e., at
flow rates of 0.0 lbs/hr transmitter output should be 4.0 milliamps) and resetting the "zero
value" if necessary. The "zero value" of each mass flow meter is checked at least once
every 180 days.
Electro-Magnetic Flow Meters
Electro-Magnetic Flow Meters are comprised of a primary sensing element and a
transmitter. The primary sensing element is located in a section of piping of known cross
sectional area. The accuracy of the primary sensing element is established by the
manufacturer through the design.
The transmitter associated with each magnetic flow meter is calibrated by the user. A
frequency generator integrated within the transmitter as part of the flow meter's self-
diagnostic system simulates the flow of liquids through the meter. Frequencies equivalent
to zero and 100 percent of span are injected into the transmitter and the resulting milliamp
output of the transmitter is evaluated and adjusted if necessary.
6.4.3.3.2
Attachment6-Pagell
6.4.3.3.3
6.4.4
6.4.4.1
6.4.4.2
6.4.4.3
6.4.5
6.4.5 .1
6.4.5.2
6.4.5.2.1
6.4.s.2.2
6.4.5.3
6.4.s.3.1
Instrument Calibration Plan & Incinerator Waste Feed Interlock arr;:??rl
June 2009
Electro-Magnetic flow metertransmitters are determined to be properly calibrated if the
output of the transmitter is the expected value *1.0% of the transmitter's span. Maguetic
flow meters are calibrated at least once every 180 days.
Differential Pressure Indicator. Transmitters (XX-PDIT-XXX)
Differential pressure measurements are used to determine flow rates of exhaust gases
through each incinerator. A differential pressure measurement requires a transmitter
capable of receiving and measuring the difference between a low and a high-pressure
input.
Differential pressure indicating transmitters are calibrated by removing the low and high-
pressure inputs to the transmitters. The low-pressure leg of the transmitter is then exposed
to atmospheric pressure. The high-pressure leg of the transmitter is exposed to five
successive increasing pressures using either a hand pump or compressed gas.
The transmitter is determined to be properly calibrated if the four to 20 milliamp output of
the transmitter (when exposed to each of the five successive pressures) is the expected
value +1.0% of the transmitter's span. Differential pressure transmitters are calibrated at
least once every 360 days.
Level Indicator. Transmitters (XX-LIT-XXX)
Levels of liquids stored in permitted hazardous waste tanks and small vessels associated
with the Agent Quantification System are determined using either differential pressure
transmitters, or ultrasonic or radar level sensors.
Differential Pressure Transmitters
Differential pressure transmitters are designated in the TAG ID alpha code with the letters
LIT when used in liquid level measurement applications. The low-pressure leg of the
transmitter is exposed to atmospheric pressure, while the high pressure leg is exposed to
the pressure head created by the column of liquid stored in the tank.
Differential pressure transmitters used in tank liquid level applications are calibrated in the
same manner and at the same frequency as those used to determine incinerator exhaust gas
flow rates (i.e., XX-PDIT-XXX).
Ultrasonic and Radar Level Transmitters
Ultrasonic level sensors determine the distance between the liquid level surface and the
face of the level sensor by measuring the time required for a sound pulse sent out from the
sensor to be reflected offthe liquid surface and retum to the sensor. Radar level indicators
make this strme measurement using a radio frequency pulse.
The function/accuracy of ultra sonic level detector is tested using features included in the
sensor/transmitter pair. The sensor generates artificial inputs to the transmitter at a
frequency equivalent to that which the transmitter would receive if the tank were empty.
6.4.5.3.2
Attachrnent6 -Page12
Instrument Calibration Plan & Incinerator Waste Feed Interlock O"r.rl:?"r1
June 2009
The sensor then repeats the process, generating inputs to the transmitter at a frequency
equivalent to that which the transmitter would receive if the tank were full.
6.4.5.3.3 The output from the transmitter should be four ard20 milliamps respectively +1.0% of the
transmitter's span. Ultrasonic and radar transmitters are calibrated at least once every 180
days or 360 days as specified in the tables at the end of this Attachment.
6.4.6 Level Switches (XX-LSHH-XXX)
6.4.6.1 Sonic level switches are used in permitted tank control systems to prevent the tanks from
being filled beyond their capacities. Level switches are function checked to ensure proper
operation by removing the switch and immersing it in liquid. The function of each level
switch is tested at least once every 360 days.
6.4.7 Temperature Lrdicator. Transmitters (XX-TIT-XXX. XX-TT-XXX)
6.4.7.1 Temperature transmitters are calibrated using a hand-held calibrations instrument, which
simulates the thermocouple millivolt, output that is input to the transmitter by the
thermocouple.2 Five calibration points are injected into the transmitter and the resulting
milliamp outputs are evaluated.
6.4.7.2 The transmitter is determined to be properly calibrated if the four to 20 milliamp output of
the transmitter is the expected value *1.0olo of the instrument's span. Temperature
transmitters are calibrated at least once every 90 days or 180 days as specified in the
Tables at the end of this Attachment.
6.4.8 Current Switches (XX-TSLL-XXX and XX-PSHH-XXX)
6.4.8.1 Current switches are used in some temperature and pressure control loops to activate waste
feed interlocks. The current switch is placed in series after the temperature or pressure
transrnitter. The current switch is adjusted so that it opens/closes at a threshold milliamp
value (i.e., the setpoint). Current switches are calibrated using a hand-held calibrator,
which simulates the input normally provided by a temperature or pressure transmitter.
6.4.8.2 Each current switch is determined to be in calibration when it activates at a milliamp value
equivalent to the setpoint +1.0% instrument's span. Current switches are calibrated at least
once every 360 days.
6.4.9 Temperature Switches (XX-TSHH-XXX)
6.4.9.1 Filled-system-type temperature switches are used on each incinerator to stop or prevent
waste feed if an incinerator's PAS quench tower exhaust gas temperature exceeds the limit
established through Permit conditions. Filled-system-type temperature switches are
calibrated by exposing the sensing element of the switch to a region of known
temperature.
' Thermocouples are not calibrated. The accuracy of a thermocouple over a specific temperature range is
determined by the materials of construction and design.
Attachrnent 6 - Page l3
6.4.9.2
6.4.10
6.4.10. I
6.4.10.2
6.4. 10.3
6.4.11
6.4.11.1
6.4.11.2
6.4.1 1 .3
6.4.t2
6.4.12.1
6.4.12.2
Instrument Calibration Plan & Incinerator Waste Feed Interlock a"";:?:rl
June 2009
Each temperature switch is determined to be properly calibrated if the switch activates at
temperatures equivalent to the setpoint+|.0%o of the transmitter's span. Filled-system-type
temperature switches are calibrated at least once every 360 days.
Pressure Indicator. Transmitters (XX-PIT-XXX)
Diaphragm-type pressure sensors are used to measure and/or control process operating
parameters associated with each incinerator's primary chamber pressure, quench brine
delivery pressure to venturi scrubbers, and clean liquor delivery pressure to scrubber tower
spray bars.
The transmitter associated with diaphragm-tlpe pressure sensors are calibrated using a
hand air pump or compressed gas to pressurize the diaphragn. The diaphragm is
subjected to five different pressures ranging from 0 to 100% of the pressures the
transmitter is set to span. The resulting output of the transmitter is then evaluated.
Pressure transmitters are determined to be properly calibrated if the transmitter's four to 20
milliamp output is the expected value *1.0o/o of the instrument's span. Pressure
transmitters are calibrated at least once every 180 days.
Pressure Switches (XX-PSHH-XXX. XX-PSL-XXX. XX-PSLL-XXX)
Pressure Switches are used to stop or prevent waste feed to each incinerator when primary
chamber pressures exceed limits imposed by this Permit. Pressure switches are calibrated
by injecting a pressure into the switch equivalent to the switch's setpoint.
Pressure switches (PSHH) are determined to be properly calibrated if the switch activates
at pressures equivalent to the setpoint+3.0%o of the instrument's span. Pressure switches
are calibrated at least once every 180 days.
Pressure switches (PSL and PSLL) are determined to be properly calibrated if the switch
activates at pressures equivalent to the setpoint+\.0%o of the instrument's span. Pressure
switches are calibrated at least once every 180 days.
Weight Indicator. (Transmitters XX-WIT-XXX)
Load Cells are used in the determination of the heel of chemical agent remaining in bulk
containers drained at the Bulk Drain Stations and control the feed rate of chemical agent to
the Metal Parts Fumace. The load cells may be used to weigh the miscellaneous wastes to
the MPF to verifr that permit feed rates are not exceeded. They may also be used to
quantiff the amount of miscellaneous agent contaminated liquids (hydraulic fluid, fuel oil,
lubricating oil, etc.) that will be transferred to the ACS tanks.
The transmitters associated with load cells convert and scale the millivolt output of the
load cell to a four to 20 milliamp control signal. A calibrator is used to simulate the
millivolt output of the load cell to the transmitter. The resulting output of the transmitter
is then evaluated. Load cell transmitters are determined to be properly calibrated if the
output of the transmitter resulting from a known input is that which is expected +0.2%o of
the instrument's span. Transmitters associated with the load cells are calibrated at least
once every 90 days.
Attachment 6 - Page l4
6.4.12.3.
6.4.13
6.4.13.1
6.4.13.2
6.5
6.5. 1
6.5.2
6.5.2.1
6.5.3
Instrument Calibration Plan & Incinerator Waste Feed Interlock a"";:??rl
June 2009
A scale in the TMA may also be used to quantifu the amount of miscellaneous waste and
miscellaneous agent contaminated liquids (hydraulic fluid, fuel oil, lubricating oil, etc.)
that will be transferred to the ACS tanks. This scale will be calibrated once every 360
tlays by placing a known weight on the scale and adjusting the scale as necessary to obtain
an accnracy of +2%o of the scales range. A record of this yearly calibration date, with
results, shall be kept at the facility until the next calibration has been completed.
Automatic Continuous AirMonitoring Systems (ACAMS) and Miniature Continuous Air
Monitorine Systems (MINICAMS) are used to detect concsntration of agent in exhaust
gases.
The calibration and challenging of ACAMS/II4INIQAMS is described in Attachments 3
(Sampling, Analytical, and QA/QC Procedures) ard22 (Agent Monitoring Plan).
R315-8-15.7(c) INCINERATOR WASTE FEED INTERLOCK FUNCTION TEST
The process control system of each incinerator is designed to stop or prevent waste feed
when operating parameters exceed the limits specified in this Permit. This feature of the
control system is referred to as the automatic waste feed cut-off (or waste feed interlock)
system. Hazardous Waste regulations require owners and operators of an incinerator to
periodically test this system.
The TOCDF procedure titled "Waste Feed Interlock Testing" (Document Number TE-
SOP-301) specifies the interlock that must be tested, the methods used to test the
interlocks, and the frequencies at which the tests are to be conducted. The procedure
includes examples of the forms used to document the test results.3
The ATLIC procedure titled "GA/L FACILITY OPERATIONS" (Document Nurnber TE-
SOP-702) specifies the same information as listed in paragraph 6.5.2 except that it is
specific to the ATLIC incinerator. The ATLIC incinerator waste feed interlocks are tested
using the manual method described in paragraphs 6.5.3.1 through 6.5.3.4.
The TOCDF waste feed interlocks are tested using one of two methods: (1) an automated
method using PLC software that allows inputs of simulated signals into the logic of the
field PLCs; or (2) a manual method that is used as a backup if the automated method is not
functional. The Permittee shall document in the Operating Record the reason(s) why the
automated method was not used and the action(s) taken to correct anyproblems with the
automated method. Waste shall not be fed to the affected furnace(s) during the waste feed
interlock test. The manual backup method for testing the waste feed interlocks is as
follows:
3 The procedure to test the overtop protection systems associated with tanks as required by R31 5-8-10 [40 CFR
26al95(a)l are included in this procedure.
Attachment 6 - Page l5
6.5.3. 1
6.s.3.2
6.5.3.3
6.5.3.4
6.5.4
6.5 .4.1
6.5.4.2
6.5.5
6.5.5. 1
6.5.5.2
Instrument Calibration Plan & Incinerator Waste Feed Interlock ar";:?:.I
June 2009
Waste feed interlocks arc either activated when the four to 20 milliamp control signal
output from a transmitter exceeds a setpoint residing in the process control software or
when the value of a process parameter exceeds the setpoint of a switch and causes the
switch to open.
For waste feed interlocks activated when the magnitude of operating parameters cause the
analog value of the four to 20 milliamp control signal output from a transmitter to exceed
a setpoint residing in the process control software, the instrument technician injects an
artificial control signal into the process control system that is greater or less than the value
equivalent to the setpoint. The artificial control signal is injected at the location where the
transmitter's output leads connect to the programmable logic controller.
For waste feed interlocks activated by a change in state of a switch (i.e., contacts closed to
contacts opm), the instrume,nt technician will cause a change in state of the control loop
associated with the interlock being tested by opening (or removing) the fuse to the loop.a
The TOCDF ACAMS associated with the waste feed interlocks are tested either
automatically or manually as described in Section 6.5.3. Each ACAMS is tested for a
malfunction alarm. ATLIC incinerator ACAMSA{INICAMS are tested manually. The
ACAMSA{IMCAMS associated with the TOCDF Common Stack and ATLIC incinerator
exhaust stack are additionally tested for a "non-staggered" alarm.
The automated testing method produces a report documenting the testing of the waste feed
interlocks that is prepared using a feature included with the waste feed interlock function
test software. The alarms associated with the interlock function test shall be observed and
verified by the Control Room Operator of the affected furnace. The observed time of each
interlock alarm shall be included with the report. When using the manual backup testing
methods, the control room operator observes the activation of each waste feed interlock on
the incinerator-specific "Alarm Summary Screen" and records the time of its activation.
The reports of the interlock function tests and alarm verifications for each fumace system
and tank system shall be included in the Operating Record.
The interlock function test report shall veriff that all appropriate interlocks occur (e.g., the
TOCDF Common Stack ACAMS alarm causes an interlock to automatically prevent the
waste feed to all of the fumaces.)
Proper function of the entire waste feed interlock system is demonstrated by:
The proper operation of instrumentation causing waste feed interlocks is ensured and
demonstrated by compliance with the calibration methods and frequencies established in
the calibration plan,
Successful completion of the waste feed interlock function test demonstrates the absence
of hardwire jumpers, software jumpers, or both within the portion of the process control
logic (i.e., software) that stops and prevents waste feed.
a The Level Switch High High (LSHH), which when activated, prevents continued liquid feed to tank HWMU are
tested the same way as incinerator waste feed interlocks that are activated by switches.
Attachrnent 6 - Page l6
o
Inskument Calibration Plan & Incinerator Waste Feed Interlock arr.,l??:l
June 2009
6.5.5.3 Successful completion of the waste feed interlock function test demonstrates the proper
function of the PLC, the PLC code associated with stopping or preventing waste feed, and
the values of the setpoints used to stop or prevent waste feed.
6.5.5.4 The design of the control system includes continual control loop self diagnostic checks.
The process control system components are designed to fail safe (e.g., a failed
thermocouple causes the associated transmitter to ramp to its high range, which in turn
activates a waste feed interlock).
6.5.6 The waste feed interlocks required to be tested are those associated with operating
parameters which have a corresponding Permit Condition limitation.
6.5.7 The frequency at which the testing of the waste feed interlock system of each TOCDF
incinerator occurs is at least once every 14 days unless the incineration system has been
shut down. If the ihcineration system has been shut down, the waste feed interlock system
will be tested before waste feed is introduced. The interlock system shall be tested every
14 days when the fumace is idling or processing waste. Waste feed shall not occur to the
effected incinerator during the waste feed interlock test.
6.5.7.1 The frequency at which the testing of the waste feed interlock system of the ATLIC
incinerator occurs is at least once every!!3e days (unless the incinerator is ldlg-g4gllb
not nrocess waste for longer than 14 davs or shut down) or at the beginning of each
agent campaign, which ever is shorter
ine
l) the e*terded length ef tirne and aCditienal eeerdinatien required te perferm the
ag€n*€€ffipeif
6.5.8 The frequency of testing of the overtop protection system of each TOCDF tank is at least
once every 14 days.
6.5.8.1 The frequency of tqsting of the overtop protection system of each ATLIC tank is at least
once every![3e days
6.5 .g The frequency of testing of the BRA waste feed interlock system is at least once every 1 4
days.
6.5.10 Although minor modifications to the procedures rnay occur, portions of the procedure that
shall not be changed without prior approval by the Executive Secretary are:
6.5.10.1 The methods used to test waste feed interlocks.
6.5.10.2 The interlocks required to be tested.
. 6.5.10.3 The frequency at which the function test occurs which is specified as once every 14 days
or€sdalls, as indicated in Section 6.5.7.o
Attachment 6 -Page 17
6,6
6.6.1
6.6.2
6,6.3
6.6.4
6.6.5
6.6.6
6.6.7
6.6.9
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
June 2009
PROCESS DATA INSTRT]MENTATION CALIBRATION & WASTE FEED
INTERLOCK TABLES
The following tables list (by incinerator, Subpart X, and tank) the TAG IDs of process
instrumentation whose proper function is required to demonstrate compliance with Permit
conditions and stop or prevent waste feed when operating parameters exceed the limits
established through the Conditions of this Permit.
Under the column heading "Process Data Instrument TAG ID," transmitters are referenced
rather than control loops because it is the transmitters that physically exist as instruments.
It is the transmitters that must be calibrated properly to ensure precise process control and
accurate data generation.
Process data generated from the output of these transmitters is electronically recorded by
the Process Data Acquisition & Recording System (PDARS). The outputs of the
fransmitters listed are continuously monitored by the Programmable Logic Controllers
(PLC), however process variables residing in the registers of the PLC are recorded by
PDARS.
The activation and duration of waste feed interlocks (listed in the following tables by
alarm/switch TAG IDs) are recorded by PDARS also.
PDARS reports are formatted to present the hourly maximum and minimum values of
each parameter listed.
The tables for all incinerators list two scrubber brine pH analyzer transmitter TAG IDs (A
and B). The value appearing on the PDARS report associated with each incinerator is the
"process variable" (a value that exists in a register of the controller which is the actual pH
of the scrubber brine that is compared by the PLC to the setpoint). Each scrubber brine
pH analyzer is a complete separate system. Only one of the pH analyzer systems is active
at any one time and the system that is active is rotated on equal time intervals. It is the
active system that provides the process variable to the controller and it is the process
variable that appears on the PDARS reports.
Each exhaust gas carbon monoxide (CO) 60-minute rolling average is composed of the
previous 60 one-minute averages. Each one-minute average is composed of four
instantaneous CO readings taken 15 seconds apart.
Tables 6-8 and 6-C include control loop temperature TAG IDs appearing in bold print;
signiffing two thermocouple/transmitter pairs are used to measure the temperature.
Controllers receiving inputs from two thermocouples/transmitter pairs activate combustion
chamber high and low temperature AWFCOs based on the most conservative temperature
measured. The PLC is programmed to activate high and low temperature combustion
charnber AWFCOs based on the thermocouple/transmitter pair measuring the highest
temperature when the high temperature limit is approached, and the pair measuring the
lowest temperature when the low temperature limit is approached.
Attachment6-Page l8
',;1k
'I"t'6ffi
'=fid.
:.
I Agent Feed Rate to Prirnary
Charnber
l3-FIT-127 A
l3-FIT- 127H-
Mass Flowmeter
Vibrating U-Tube
TYPe
0 - 1,500
lbs/hr
t 0.4% of
Flow
I 80 days 6.4.3 .2
2 Agent Feed Atornizing Air
Pressure
I 3-PIT- 128 Diaphragrn 0 - 200 psig t 1.0% of
Span
I 80 days 6.4.t0
3 Agent Gun Nozzle Pressure I 3-PIT- I l2 Diaphragrn 0 - 25 psig t 1.0% of
Span
I 80 days 6.4.10
4 Reserved
5 Prirnary Charnber Exhaust
Gas Ternperafure
t 3-TIT-610 Thennocouple 212 - 3,0000 F t 1.0% of
Span
I 80 days 6.4.7
6 Secondary Chamber Spent
Decon/Process Water Feed
Rate
1 3-FIT- 102 Mass Flowmeter
Vibrating U-Tube
Twe
0 - 2,250
lbs/hr'
t 0.4o/o of
Flow
I 80 days 6.4.3.2
7 Secondary Chamber Spent
Decon/Process Atornizing Air
Pressure Waste Feed Interlock
l3-PSL-058 Diaphragrn 12 - 100 psig t l.0o/o of
Span
I 80 days 6.4.n
8 Secondary Charnber Slag
Gate Open Waste Feed
lnterlock
l3-zs-3678 Lirnit Switch Not
Applicable
Not
Applicable
Not Applicable Not Applicable
9 Secondary Charnber Exhaust
Gas Temperature
I 3-TrT- 129 Thennocouple 32 - 2,4000 F t 1.0% of
Sparr
I 80 days 6.4.7
9.a S econdary Charnber Exhaust
Gas Ternpemture [,ow Gas
Temperature Waste Feed
Interlock
l 3-TSLL- 129 Cument Switch 4-20lm4 t 1.0% of
Span
360 days 6.4.8
7to Slag Removal Systern Shell t3-TtT-37 4
l3-TIT-375
l3-TIT-376
t3-TtT-377
Thennocouples 0 - 1000" F t 1.0% of
Span
I 80 days 6.4.7
ll V-Cone pressure to con'ect to
standard conditions
24-PtT-9431 Diaphragrn 8- I 3 psia t 1.0% of
Span
I 80 days 6.4.1
lla V-Uone ternperafure to
correct to stdndard conditions
').4-tn-943t I lrennocouple 100-200" F + 1.0% of
Span
UU days 6.4. t
llb V-Cone flow rate /.+-ilt-94JtA
24-FtT-9431 B
DIP Cell U- 14, /6U clm + 1.0% of'
Soan
UU days 6.4.4
t2 Quench Tower Exhaust Gas
Tempemture
24-TtT-397 Thennocouple 0-300'F t 1.0% of
Span
90 days 6.4.7
12.a Quench Tower Exhaust Gas
Temperature High Waste
Feed Interlock
24-TSHH-089 Filled Systern t75 - 360" F t 1.0% of
Span
360 days 6.4.9
r3 Quench Brine Delivery
Pressure
24-PtT- 100 Diaphragrn 0 - 150 psig t 1.0% of
Span
I 80 days 6.4.10
t4 Quench Brine to Venturi
Scrubber
24-FrT-08 8 Electro-M agnetrc
Flowmeter
0 - 150 gprn t 1.0% of
Span
I 80 days 6.4.3 .3
l5 Venturi Scrubber A Pressure 24-PDtT-090 D/P Cell -0-70in. w.c.t 1.0% of
Span
360 days 6.4.4
l6 Clearr Liquor to Scrubber
Tower Sprays
z4-FtT-t 12 Electr o-Magnetrc
Flowmeter
0 - 1,000 gpm t 1.0% of
Span
I 80 days 6.4.3 .3
t7 Clean Liquor Delivery
Pressure
24-Prr-129 Diaphragrn 0 - 100 psig t 1.0% of
Sparr
I 80 days 6.4.10
l8 Scrubber Liquid Effluent pH 24-ArT-091A
24-Atr-091 B
Electrodes 0- 14pH
Units
! 2.0o/o of
Span
7 days 6.4.t .2
l9 Scrubber Liquid
Specific Gravity
24-DIT-O83 Magnetically Vibrated
Tube
0.6 - r.4 sGU t 2.0o/o of
Span
180 days 6.4.2IBlower Exhaust Gas CO 24-AtT-018 Infi'ared Cell Analyzer 0-200&0-
5,000 ppm
CD: daily
CE: quarterly
PST: annually
6.4.1.1
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
Attachrnent 6 - Page l9
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
ii:iilt:liiiffi
ffin
l;.i:,1:11F,118flfi 6ffi'ffi Yr{{,,11#
2t Blower Exhaust Gas CO t 3-Arr-083 Infiared Cell Analyzer 0-200&0-
5,000 ppm
t 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.1.t
22 Blower Exhaust Gas Oz 24-AtT-210 Zirconiurn Oxide Cell
Analyzer
0 -25%t 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.1
23 Blower Exhaust Gas Oz t3-Arr-229 Zirconium Oxide Cell
Analyzer
0 -2s%t 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.1
24 Blower Exhaust Gas Agent PAS 7O4AH
PAS 7O4BH
ACAMS 0 - 512 sEL +25o/o of
Response
Challenge daily,
calibrate if it fails
the challense
6.4.t3
25 Common Stack Exhaust Gas
Agent
PAS TOIAG
PAS TOIBG
PAS TOICG
PAS 7O6AV
PAS 7O6BV
PAS 7O6CV
PAS 707 AH
PAS 7O7BH
PAS 7O7YH
ACAMS 0 - 512 sEL +25"/o ot
Response
Challenge every
4 hoursicalibrite
if it fails the
challenge
6.4. l3
26 HVAC t,X.$ftrhaust Gas T.IL 6UICH
FIL 6OIDH
ACAMS U . 5I2 VSL +25o/o of
Response
Challenge evely
24 hours',
calibrate if it fails
the challenge
6.4. l3
T.IL 6U I EC.'
FIL 60 I FG3
FIL 60IAV3
FIL 60 I BV3
VSL +4U"h oI
Response
Lrne Challenge
every 60 days *
3 days
I
2
3
The HVAC ACAMS causes a staged shutdown as described in Module X.
The ACAMS shall be challenged every 24 hours with a I -hour grace period before or after the 24-hour deadline.
The GB and VX are historicaftnonitois
Attachrnent 6 - Page20
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
ffi ffi
I Agent Feed Rate to Prirnary
Chamber
13-FrT-73 1A
13-FrT-73 I B
Mass Flowrneter
Vibrating U-Tube
Type
0 - 1,500 lbs/hr'.0.4% of
Flow
1 80 days 6.4.3.2
2 Agent Feed Atornizing Air
Pressure
t 3-PrT-736 Diaphragrn 0 - 200 psig + 1.0% of
Span
I 80 days 6.4. l0
3 Agent Gun Nozzle Pressure l3-PIT-760 Diaphragm 0 - 25 psig + 1.0% of
Span
180 days 6.4.10
4 Reserved
5 Primary Chamber Exhaust
Gas Temperature
l3-TrT-710 Thermocouple 212 - 3,0000 F + 1.0% of
Span
I 80 days 6.4.7
6 Secondary Chamber Spent
Decon/Process Water Feed
Rate
13-FIT-763 Mass Flowmeter
Vibrating U-Tube
Type
0 - 2,250lbs/hr + 0.4Yo of
Flow
I 80 days 6.4.3.2
7 Secondary Chamber Spent
DeconlProcess Atomizing
Air Pressure Waste Feed
Interlock
13-PSL-809 Diaphragm 12 - 100 psig t 1.0% of
Span
I 80 days 6.4.rr
8 Secondary Chamber Slag
Gate Open Waste Feed
Interlock
13-zs-567B Lirnit Switch Not Applicable Not
Applicable
Not Applicable Not
Applicable
9 Secondary Chamber Exhaust
Gas Tempemture
t3-TtT-782 Thennocouple 32 - 2,400" F + 1.0% of
Span
I 80 days 6.4.7
9.a Secondary Chamber Exhaust
Gas Temperafure [.ow Gas
Temperature Waste Feed
Interlock
13-TSLL-782 Cument Switch 4-20mA t 1.0% of
Span
360 days 6.4.8
l0 Slag Removal Systern Shell l3-TrT-574
l3-TIT-575
13-TIT-576
13-TrT-577
Thennocouples 0 - 1000'F t 1.0% of
Span
I 80 days 6.4.7
ll V-Cone Pressurc Production
Rate
24-PU-9902 Diaphagrn 8-13 psia + 1.0% of
Span
I 8Odays 6.4.10
1la V-Cone 'I'emperafure 24- ilt -99u',2 I hennocouple 100-200"F + 1.0% of
Soan
I UU days 6.4.'t
rlb V-Cone flow rate 24-FtT-9902/t
24-FYt-99028
DiP Cell U- 14,'/6U ctm + 1.0% of
Soan
I UU clays 6.4.4
t2 Quench Tower Exhaust Gas
Temperature
24-TIT-816 Thermocouple 0-300"F t 1.0% of
Span
90 days 6.4.7
12.a Quench Tower Exhaust Gas
Temperature High Waste
Feed Interlock
24-TSHH-800 Filled Systern 175 - 360' F t 1.0% of
Span
360 days 6.4.9
l3 Quench Brine Delivery
Pressure
24-PrT-838 Diaplrragrn 0 -150 psig t 1.0% of
Span
I 80 days 6.4. l0
t4 Quench Brine to Venturi
Scrubber
24-FIT-828 Electro-Magnetic
Flowmeter
0 - 150 gprn t 1.0% of
Span
180 days 6.4.3 .3
15 Venturi Scrubberd Pressure 24-PDIT-814 DiP Cell -0-70in. w.c.t 1.0% of
Span
360 days 6.4.4
t6 Clean Liquor to Scrubber
Tower Sprays
24-FrT-825 Electro-Magnetic
Flowmeter
0 - 1,000 gpm + 1.0% of
Span
I 80 days 6.4.3.3
t7 Clean Liquor Delivery
Pressure
24-PrT-839 Diaphragrn 0 - 100 psig t 1.0% of
Span
180 days 6.4.t0
l8 Scrubber Liquid Effluent pH 24-AIT-83 I A
24-AtT-831B
Electrodes 0 - 14 pH Units t 2.0 of
Span
7 days 6.4.1.2
)
19 Scrubber Liquid Effluent
Specific Gravity
24-DIT-835 Magnetically Vibrated
Tube
0.6 - 1.40 sGU t2.0% of
Span
I 80 days 6.4.2
Attachment 6 - Page2l
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
|.yr,l#"p ffi
20 Blower Exhaust Gas CO 24-An-716 lnfiared Cell Analyzer 0-200&0-
5,000 ppm
t 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.t.t
2l Blower Exhaust Gas CO 13-AtT-778 Infiared Cell Analyzer 0-200&0-
5,000 ppm
+ 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.1.1
22 Blower Exhaust Gas Oz 24-An-7fi Zirconium Oxide Cell
Analyzer
0 -25%+ 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.1
23 Blower Exhaust Gas Oz l3-Am-798 Zirconium Oxide Cell
Analyzer
0 -2s%+ 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.1
24 Blower Exhaust Gas Agent PAS 7O5AH
PAS 7O5BH
ACAMS 0 - 512 sEL +25o/o of
Response
Challenge daily,
calibrate if it fails
the challense
6.4.t3
Z5 Common Stack Exhaust Gas
Agent
PAS TOIAO
PAS TOIBG
PAS TOICG
PAS 7O6AV
PAS 7O6BV
PAS 7O6CV
PAS 107 AH
PAS 7O7BH
PAS 7O7CH
ACAMS U - 5I2 SBL t25"/o ot
Response
Challenge every
4 hours,"calibrite
if it fails the
challenge
6.4. l3
26 HVAC Stack Exhaust Gas
Agentr
FIL 60I CH
FIL 60I DH
ACAMS 0-512 vsl-t25o/o of
Response
Challenge every
24 hourc2,
calibrate if it fails
the challenge
6.4.13
FIL 60I EGJ
FIL 60I FG3
FIL 60 I AV3
FIL 60I BV3
DA\AI\4S VSL t40% of
Response
Line Challenge
evely 60 + 3
days
l. The HVAC ACAMS causes a staged shutdown as described in Module X.
2. The ACAMS shall be challenged every 24 hours with a l-hour grace period before or after the 24-hour deadline.
3. The GB and VX are historical monitors
Attachment6 -Page22
ffi ffi ,,ffi
iiiiilii.n
liiiiiliE
iilliriii;tit"t iiiii
I MPF Prirnary Charnber
Temperafure Zone I
l4-TrT-152 Thennocouple 0 - 2,000" F t 1.0% of
Span
I 80 days 6.4.7
2 MPF Prirnary Charnber
Temperature Zone 2
t4-TIT-l4l Thennocouple 0 - 2,000" F t 1.0% of
Span
I 80 days 6.4.7
3 MPF Prirnary Charnber
Tempemture Zone 3
l4-TrT- I 53 Thennocouple 0 - 2,000' F t 1.0% of
Span
I 80 days 6.4.7
4 MPF Primary Chamber Exhaust
Gas Ternpemfure
l4-TIT-010 Thermocouple 32 - 27000 F t 1.0% of
Span
I 80 days 6.4.7
5 MPF Prirnary Charnber Pressure l4-PIT-070 DIP Cell -10.0 - 0.0 in.
w.c.
t 1.0% of
Span
I 80 days 6.4.10
5.a.MPF Prirnary Chamber Pressure
Hieh Waste Feed lnterlock
l4-PSHH-034 Cument Switch 19.85 rnA t 1.0% of
Setpoint
360 days 6.4.8
6 MPF Afterbumer Temperature 14-TIT-065
l4-TIT-069
Thennocouple 32 - 2,,7000 F t 1.0% of
Span
I 80 days 6.4.7
7 V-Cone Pressure 24-PrT-9661 Diaphrarn 8-15 psia t 1.0% of
Span
I 80 days 6.4. l0
la V-Uone I ernperature '24-tn-966 t I lrennocouple t UU-ZUU "+ 1.0% of
Span
I UU days 6,4. I
7b V-Cone flow mte
'/4-il 1 -966 /A
24-FtT-9667B,
DIY Cell 0- l6,990ctrn + 1.0% of'
Soan
I UU clays 6.4.4
8 Quench Tower Exhaust Gas
Temperature
24-TIT-509 Thennocouple 0-300"F t 1.0% of
Span
90 days 6.4.7
8.a Quench Tower Exhaust Gas
Tempemture High Waste Feed
Interlock
24-TSHH-223 Filled Systern 175 - 360'F t 1.0% of
Span
360 days 6.4.9
le Venturi Scrubber Difl'erential
Pressure
z4-PDtr-222 D/P Cell 0 - 50 in. w.c.t 1.0% of
Span
360 days 6.4.4
l0 Querrch Brine to Ventuti
Scrubber
24-FtT-218 Electro-Maguetic
Flowmeter
0 - 150 gprn + 1.0% of
Span
I 80 days 6.4.3 .3
il Quench Brirre Pressure 24-PtT-233 D/P Cell 0 - 150 psig t 1.0% of
Span
I 80 days 6.4.10
t2 Clearr Liquor to Scrubber Tower
Sprays
24-FtT-248 Electr o-Magnetrc
Flowmeter
0 - 1,000 gprn t 1.0% of
Span
I 80 days 6.4.3 .3
l3 Clean Liquor Delivery Pressure 24-PtT-258 D/P Cell 0 - 100 psig t 1.0% of
Span
I 80 days 6.4.10
t4 Scrubber Liquid Effluent
Specific Gravity
24-DtT-2t6 Magnetically
Vibrated Tube
0.6 - 1.4 sGU t2.0o/o of
Span
I 80 days 6.4.2
l5 Scrubber Liquid Effluent pH 24-ArT-224A
24-AtT-2248
Electrodes 0 - 14 pH Units t 2.0 pH
Span
7 days 6.4.t.2
l6 Blower Exhaust Gas CO l4-AIT - 384 Inf}ared Cell
Analyzer
0-200&0-
5,000 pprn
t3%of
Span
CD: daily
CE: quarterly
PST: annually
6.4.1.1
t7 Blower Exhaust Gas CO 24-Atr-669 Infrared Cell
Analyzer
0-200&0-
5,000 ppm
t 3o/o of
Span
CD: daily
CE: quarterly
PST: annually
6.4.1.t
r8 Blower Exhaust Gas Oz r4-ArT-082 Zirconiurn Oxide
Cell Analyzer
0 -25%+ 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.t.l
l9 Blower Exhaust Gas Oz 24-AtT-670 Zirconiurn Oxide
Cell Analyzer
0 -2s%+ 0.5% of
Oz
CD: daily
CE: quarterly
PST: arrnually
6.4.t.1
)
20 Blower Exhaust Gas Agent PAS 7O3AH
PAS 7O3BH
PAS 103 C
PAS 703 D
ACAMS 0 - st2 sEL t 25o/, of
Response
Challenge evely
4 hours fbr VX
or daily fbr CB
or mustard
calibrate if it
fails the
challense
6.4.13
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
Attachrnent 6 - Page23
March 2009
2t Common Stack Exhaust Gas
Agent
PAS TOIAG
PAS TOIBG
PAS TOICG
PAS 7O6AV
PAS 7O6BV
PAS 7O6CV
PAS 707 AH
PAS 7O7BH
PAS 7O7CH
ACAMS 0 - 512 sEL t 25% of
Response
Challenge every
4 hourc,
calibrate if it
fails the
challenge
6.4.t3
22 L,oad Cell, BDS-101 49-WrT-152 L,oad Cell 0 -10,000 lbs + 0.20o/o of
Span
Every 90 days 6.4.12
23 L.oad Cell, BDS-102 49-WrT-252 I-,oad Cell 0 -10,000 lbs !.0.2% of
Span
Every 90 days 6.4.t2
24 Agent Quantification System
MDM-IOI
5l -LIT-073 DP Irvel Indicating
Tmnsmitter
0-25 in. w.c.t 1.0% of
Span
360 days 6.4.5.2
25 Agent Quantification Systern
MDM-I02
5l -LIT-083 DP Level Indicating
Tmnsmitter
0-25 in. w.c.t 1.0% of
Span
360 days 6.4.s.2
26 Agent Quantification Systern
MDM.I03
5l -Lrr-093 DP I-evel Indicating
Tmnsmitter
0-25 in. w.c.t 1.0% of
Span
360 days 6.4.5.2
27 HVAC Stack Exhaust Gas
Agentr
FIL 60ICH
FIL 60 I DH
ACAMS 0-5 12 vsL t25% of
Response
Challenge every
24 hours2,
calibrate if it
fails the
challenge
6.4.13
FIL 60 I EG'
FIL 60 I FG3
FIL 60I AV3
FIL 60 I BV3
DAAMS VSL t40% of
Response
Line challenge
evely 60 + 3
days
l. The HVAC ACAMS causes a staged shutdown as described in Module X.
2. The ACAMS shall be challengd every 24 hours with a I -hour grace period before or after the 24-hour deadline.
3. The GB and VX arc historical monitors
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
Attachrnent 6-Page24
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
ffi ffi
r,l iii'irffi
.ll
iiix iiie'*fiffi-fHtiff "r
,i;ffie,1iill -+',
,
Illaintenance'i.#dEft$ fu
I Jammed Chute Line A Waste
Feed lnterlock
l6-xs-207 Radioactive Pr oxirnity
Switch
On-Off Non
Applicable
Not Applicable Not Applicable
2 Jarmned Chute Line B Waste
Feed h-rterlock
l6-xs-209 Radioactive Pr oxirnity
Switch
On-Off Non
Applicable
Not Applicable Not Applicable
3 Reseryed
4 Reserued
5 Kiln Rotational Speed
Calculated fiom:
t6-zx-602 Proxirnity Switch Not Applicable Not
Applicable
Not Applicable Not Applicable
7 Kiln Pressure l6-PIT-01 8 Diaphragm -2.0 to 1.0 in.
w.c.
+ 1.0% of
Span
I 80 days 6.4. l0
7.a Kiln Pressure High Waste
Feed Interlock
l6-PSHH -204 Diaphragrn -0.5 to 0.5 in.
w.c.
+ 3.0% of
Setpoint
I 80 days 6.4.11
8 Kiln Exhaust Ternp Pre
Quench
6-TIT-182
6-TrT-244
Thennocouple 0 - 2,3000 F + 1.0% of
Span
I 80 days 6.4.7
9 Kiln Exhaust Ternp.Post
Quench
6-Trr-008
6-TIT- 169
Thennocouple 0 - 2,300' F + 1.0% of
Span
I 80 days 6.4.7
l0 Discl-rarge Conveyor
Temperature (lower)
t6-TtT-042 Thennocouple 0 - 1,6000 F + 1.0% of
Span
I 80 days 6.4.7
ll Discharge Conveyor
Tempemture (upper)
l6-TIT-184 Thennocouple 0 - 1,6000 F + 1.0% of
Span
I 80 days 6.4.7
t2 Discharge Conveyor Tip Gate
Jarn Waste Feed Interlock
l6-xs-0s8 Radioact
Sw
ve Lirnit
tch
Not Applicable Not
Applicable
Not Applicable Not Applicable
l3 Discharge Conveyor Slide
Gate Jarn Waste Feed
Interlock
l6-xs-821 Radioactive Lirnit
Switch
Not Applicable Not
Applicable
Not Applicable Not Applicable
,t4 Discharge Conveyor Speed
[.ow Waste Feed Interlock
r6-ssL-057 Speed ( Proximity)
Switch
On-Off Not
Applicable
Not Applicable Not Applicable
l5 Exhaust Gas Aftet'bunrer l6-TrT-092
l6-TIT-003
Thernocouple 0 - 2,400' F + 1.0% of
Span
I 80 days 6.4.7
l6 V-Corre Pressure 24-PtT-9430 Diaphrarn 8- I 3 psia t 1.0% of
Span
I 80 days 6.4.t0
l6a V-Cone I emperature '24- | il -94JU lrennocouple I UU-ZUU "+ 1.0% ot
Soan
I 80 days 6.4. I
r6b V-Cone flow rate z4-t t't'-9430A
24-FtT-9430B
D/P Cell 0-38,126 acfln + 1.0% of
Soan
I 80 days 6.4.4
l7 Quench Tower Exhaust Gas
Temperafure
24-TlT-374 Thennocouple 0-300'F + 1.0% of
Span
90 days 6.4.1
ll .a Quench Tower Exhaust Gas
High Ternp Waste Feed
Interlock
24-TSHH-001 Filled Systern t75 - 360'F t 1.0% of
Span
360 days 6.4.9
l8 Scrubber Liquid Effluent
Specific Gravity
24-DIT-033 Magnetically Vibrated
Tube
0.6 - 1.40 sGU t 2.0% of
span
I 80 days 6.4.2
l9 Scrubber Liquid Ef}luent pH 24-AIT-007A
24-AtT-0078
Electrode 0 - l4 pH Units + 2.0%
Span
7 days 6.4.1 .2
20 Quench Brine Pressure 24-PIT-01 I Diaphragrn 0 - 200 psig + 1.0% of
Spau
180 days 6.4.10
2l Quench Brine to Venturi
Scrubber
24-FIT-006 Electro-rnagnetrc
Flowrneter
0 - 400 GPM + 1.0% of
Span
I 80 days 6.4.3 .3
22 Venturi S crubber Differential
Pressure
24-PDIT-008 D/P Cell 0 - 50 in. w.c.+ 1.0% of
Span
360 days 6.4.4
23 Clean Liquor to Scrubber
Tower Sprays
24-FIT-030 Electro-tnagnetrc
Flowmeter
0 - 3,000 GPM + 1.0% of
Span
I 80 days 6.4.3.3
24 Clean Liquor Pressure 24-PtT-036 Diaphragm 0 - 100 psig t 1.0% of
Spatt
I 80 days 6.4.10
25 Blower Exhaust Gas Oz 24-AtT-206 Zirconium Oxide Cell
Analyzer
0 -2s%+ 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.1
426 Blower Exhaust Gas O,l6-AIT- l7s Zirconiurn Oxide Cell 0 -2s%+ 0.5% of CD: daily 6.4.t.1
Attachrnent 6 - Page25
March 2009
hi#"
Analyzer Oz CE: quarterly
PST: annually
27 Blower Exhaust Gas CO 24-ArT-207 Infrared Cell Analyzer 0-200&0-
5,000 ppm
+ 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.t.t
28 Blower Exhaust Gas CO l6-AIT-059 Infiarrd Cell Analyzer 0-200&0-
5,000 ppm
+ 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.t.t
3l Blower Exhaust Gas Agent PAS 7O2AH
PAS 7O2BHG
PAS 7O2C
PAS 7O2D
ACAMS 0 - 512 sEL + 25% of
Response
Challenge every
4 hours for VX
or daily for GB,
mustard,
calibrate if it
fails the
challenge
6.4.13
32 Common Stack Exhaust Gas
Agent
PAS TOIAG
PAS TOIBG
PAS TOICG
PAS 7O6AV
PAS 7O6BV
PAS 7O6CV
PAS 707 AH
PAS 7O7BH
PAS 7O7CH
ACAMS 0 - 512 sEL + 25% of
Response
Challenge evely
4 hours,
calibrate if it
fails the
challenge
6.4,13
33 HVAC Stack Exhaust Gas
Agentl
FIL 60ICH
FIL 60I DT{
ACAMS 0-512 vsL tZl"/o oI
Response
ChallenRe evely
24 hou#, '
calibrate if it
fails the
challenge
6.4.t3
F
F
F
F
L 601 EC',
L 60I FG3
L 601A\/3
L 6OIBV:.
DAAMS VSL +40Yo of
Response
Lrne Challense
every 60 + Y
days
1. The HVAC ACAMS causes a staged shutdown as descdbed in Module X.
2. The ACAMS shall be challenged every 24 hours with a I -hour grace period before or after the 24-hour deadline.
3. The GB and VX are historical monitors
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
Attachrnent 6 -Page26
March 2009
1 Agent Collection System
ACS-TANK-I0I kvel
Indicator
I I -LIT-093 Radar kvel [ndicating
Tmnsmitter
6-90in.t 1.0% of
Span
I 80 days 6.4.5.3
2 Agent Collection Systern
ACS-TANK-I 0l High-High
I-evel Interlock
I I-LSHH-
091
Sonic lrvel Switch Interlock
setpoint 7t 6tt
above tangent2
See NOTE
3
360 days 6.4.6
3 Agent Collection System
ACS-TANK-I02 I-evel
Indicator
I l -LIT-I09 Radar kvel Indicating
Tmnsmitter
6 - 105 in.t 1.0% of
Span
I 80 days 6.4.5.3
4 Agent Collection System
ACS-TANK-I 02 High-High
I-evel lnterlock
I I-LSHH-
111
Sonic Irvel Switch lnterlock
setpoint 81 9r'
above tangent2
See NOTE
3
360 days 6.4.6
5 Spent Decon Systern SDS-
TANK-I 0l Irevel Indicator
I l -LrT-020 Ultrasonic kvel
Indicating Transmitter
0 - 107 in.*1.0% of
Span
I 80 days 6.4.5.3
6 Spent Decon Systern SDS-
TANK-IOI High-High
I-evel Interlock
I I-LSHH-
018
Sonic kvel Switch lnterlock
setpoint 91 srt
above tangent2
See NOTE
3
360 days 6.4.6
7 Spent Decon Systern SDS-
TANK- 102 Level lndicator
I I -LIT-030 Ultrasonic l-evel
Indicating Tmnsrnitter
0 - 107 in.t 1.0% of
Span
I 80 days 6.4.5.3
8 Spent Decon System SDS-
TANK-102 High-High
lrvel Interlock
I I.LSHH-
028
Sonic Irvel Switch Interlock
setpoint 91 5rr
above tangent2
See NOTE
3
360 days 6.4.6
9 Spent Decon Systern SDS-
TANK-103 kvel lndicator
I l -LIT-064 Ultra Sonic Level
Indicating Tmnsrnitter
0 - 107 in.t 1.0% of
Span
I 80 days 6.4.5.3
l0 Spent Decon System SDS-
TANK- 103 High-High
Level Interlock
I I-LSHH.
062
Sonic lrvel Switch Interlock
setpoint 9'5"
above tangent2
See NOTE
3
360 days 6.4.6
ll Brine Reduction Area BRA-
TANK- l0l l-rvel Indicator
23-LIT-003 Ultra-Sorric Level
Indicating/transrn itter
0 - 210 in.t 1.0% of
Span
360 days 6.4.5.3
t2 Brine Reduction Area BRA-
TANK-IOI High-High
lrvel Interlock
23-LSHH.
002
Sonic Level Switch Interlock
setpoint l8'3"
See NOTE
3
360 days 6.4.6
l3 Brine Reduction Area BRA-
TANK- l 02 Level Indicator
23-LtT-007 Ultra-Sonic Level
I ndi c ati n g/transrn itter
0 - 210 in.t 1.0% of
Span
360 days 6.4.5 .3
t4 Brine Reduction Area BRA-
TANK-102 High-High
kvel Interlock
23-LSHH-
006
Sonic lrvel Switch Interlock
setpoint l8' 3"
See NOTE
3
360 days 6.4.6
l5 Brine Reduction Area BRA-
TANK-2O1 Level Indicator
23-LtT-703 Ultra-Sonic Level
Indicating/trans rnitter
0 - 210 in.t 1.0% of
Span
360 days 6.4.s .3
t6 Brine Reduction Area BRA-
TANK-201 High-High
Level Interlock
23-LSHH-
702
Sorric Level Switch Interlock
setpoint l8' 3
See NOTE
"tJ
360 days 6.4.6
t7 Brine Reduction Area BRA-
TANK-202 Level Indicator
23-LtT-707 Ultra-Sonic Level
I ndi cati ngltransrn itter
0 - 210 in.t 1.0% of
Span
360 days 6.4.s.3
t8 Brine Reduction Alea BRA-
TANK-202 High-High
Level Interlock
23-LSHH-
706
Sonic lrvel Switch Irrterlock
setpoint l8' 3"
See NOTE
3
360 days 6.4.6
NOTES:
I Resewed
2 The tank tangent is the geornetric tmnsition where the cylindrical side meets the ellipsoidal bottom, apprcximately two inches below the head-to-shell weld.
3 lrvel switches are not.calibrated, they are function tested. The level at which they activate is not adjustable since each switch is positioned in the tank
though a flanged opening in the side ofthe tank.
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
Attachrnent6 -Page27
March 2009
I Agent Feed Rate to Primary
Chamber
807-FT-8430 Mas's Flowmeter
Vibrating U-Tube
Twe
0 - 1500 lbs/trr (t 0.4%)
of Flow
I 80 days 6.4.3.2
2 Agent Atornizing Air Press.822-PT-8410 Diaphragm 0 - 200 psig t 1.0% of
Span
I 80 days 6.4. t0
3 Primary Chamber' Exhaust
Gas Temperature
815-TT-8471 Thermocouple 212 - 3,000" F t 1.0% of
Span
I 80 days 6.4.7
4 Secondary Charnber Spent
Decon/Process Water Feed
Rate
815-FT-8521 Rheotherm Flow
Meter
100 - 1000
lbs/hr
t 0.4% of
Flow
I 80 days 6.4.3.2
5 Spent Decon Atomizing Air
Press.
822-PT-8s l I Diaphragm 12 - lffi psig t 1.0% of
Span
I 80 days 6.4. l0
6 Secondary Chamber Exhaust
Gas Temperature
815-TIT-8571 Thennocouple 32 - 2400" F t 1.0% of
Span
I 80 days 6.4.7
7 Stack Exhaust Gas Flow Rate 819-FIT-8932 D/P Cell 0-3.25 b
\ry.c.
t 1.0% of
Span
I 80 days 6.4.4
7a Stack Exhaust Cas Pressure 819-PrT-8932 Diaphram 8-13 psia + l.0o/o of
Span
I 80 days 6.4. t0
7b Stack Exhaust Gas
Temperature
819-TIT-8932 Thermocouple 100-200 'F + 1.0% of
Span
I 80 days 6.4.7
8 Scrubber Brine Pressure 8 l9-PT-8982 Diaphragm 0 - 100 psig t 1.0% of
Span
I 80 days 6.4. l0
9 Venturi Brine Pressure I l e-PT-8e56 Diaphragm 0 - 100 psig t 1.0% of
Span
I 80 days 6.4.10
l0 Scrubber Tower Flow 819-FT-8924 Electro-Magnetic
Flowmeter
0 - 150 gpm t 1.0% of
Span
I 80 days 6.4.3.3
il Venturi Scrubber A Pressure 8 l9-PDT-8915 D/P Cell 0-70 in. W.C..t 1.0% of
Span
360 days
t2 Scrubber Tower Flow 8 l9-FT-892t
8l e-FT-8922
8 t 9-FT-8923
Electro-Magnetic
Flowmeter
0 - 150 gpm t 1.0% of
Span
I 80 days 6.4.3.3
l3 Scrubber A Pressure 819-PDT-891 I
8 lg-PDT-8912
8 l9-PDT-8913
D/P Cell 0-70 in. W.C.t 1.0% of
Span
360 days 6.4.4
t4 Venturi Specific Cravity 819-AT-8927 Magnetically Vibrated
Tube
0.6 - 1.40
SGU
+ 2.0% of
sDan
I 80 days 6.4.2
l5 Venturi Liquid Effiuent pH 8 l9-AlT-8917
A,B&C
Electrodes 0- 14pH
Units
! 2.0o/o of
Span
7 days 6.4.1.2
16 Scrubber Brine Specific
Cravity
8 r 9-AT-8983 Magnetically Vibrated
Tube
0.6 - 1.40
SGU
+ 2.0o/o of
span
I 80 days 6.4.2
l7 Scrubber Lrqurd Ettluent pH E I9.AI I -8952A,B&C Electrodes U- 14oH
Units r ! 2.O"/o of
Span
b.4.t:/
l8 Uarbon lnlectron Feed FI-E933 Load Cell TBD 0-75 lbs.TBE)=O.ZO"/o oIidffiEE)90 davs +BD 6.4.I2TBD
l9 Uarbon lnlectron Arr Flow H-E940 UECdl +BD 0-100 sclm
TEDr
t 1.07o of
Spru:t[D
lEO davs TBD 6.4,mD
20 Bag House A Pressure u l9-PLt,,t -uyJo D/P Cell 0-70 rn. W.C.t 1.0% of
Span
36U days 6.4.4
2t Carbon Filter A Pressure 8 Ig-PDIT.
894U8942
DIP Cell 0-70 in. W.C.t 1.0% of
Span
360 days 6.4.4
22 Carbon Filter Inlet
Temperature
819-TIT-893e Thennocouple 0- 300" F t 1.0% of
Span
I 80 days 6.4.7
23 Stack Exhaust Gas CO 819-Arr-8302
A/B
Infrared Cell Analyzer 0-200&0-
5,000 ppm
t 3.0% of
Span
CD: daily
CE: quarterly
PST: annually
6.4.1.1
24 Stack Exhaust Gas Oz 819-AIT-8301
A/B
Zirconium Oxide Cell
Analyzer
0 -2s%t 0.5% of
Oz
CD: daily
CE: quarterly
PST: annually
6.4.1.t
25 Stack Exhaust Gas Agent
(GA)
TEN 7O8AK
TEN 7O8BK
TEN 7O8CK
ACAMS 0 - 512 sEL !25Yo of
Response
Challenge every
4 hours, calibrate
if it fails the
challenge
6.4.13
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
Attachrnent6-Page28
26
)
Stack Exhaust Gas Agent
(trwisite)
I EN -IUgAL
TEN 7O9BL
TEN 7O9CL
TEN 7O9DL
TEN 7O9TIL
TIIN 7O9FL
MINICAMS 0 - s12 sEL +25Yo of
Response
Challenge every
4 houis, calibrate
if it fails the
challenge
6.4.13
27 HVAC Stack Exhaust Gas
Agentr(GA)
I L,N /)UAK
TEN 75OBK
ACAMS 0 - 512 vsl t25%o of
Response
Challenge every
24 hours2,
calibrate if it fails
the challenge
6.4.13
28 HVAC Stack Exhaust Gas
Agent'(GA)
I I,N /)UAK.'
TEN 75OBK]
DAAMS VSL +40o/o of
Response
Line Challenge
every 60 days +
3 days
6.4.t3
29 HVAC Stack Exhaust Gas
Agentr (Lewisite)
I EN -ISUAL
TEN 75OBL
TEN 750eL
TEN 75ODL
MINICAMS 0 - 512 vsl +25o/o of
Response
Challenge every
24 hours2,
calibrate if it fails
the challense
6.4.13
30 HVAC Stack Exhaust Gas
Agentr(kwisite)
I EN 75UAL'
TEN 75OBL3
DAAMS VSL +40%o of
Response
Line Challenge
every 60 days +
3 days
6.4.13
l. The HVAC ACAMSA,IINICAMS causes a staged shutdown as described in Module X.
2. The ACAMS/IvIINICAMS shall be challeneed wery 24 hours with a l-hour erace oeriod before or after the 24-hour deadline.
TBD-These valnes will be ireereratC orier'te the fiit'al aublie aere*
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
Attachment 6 -Page?9
TOCDF
Instrument Calibration Plan & Incinerator Waste Feed Interlock Function Test
March 2009
.:1.
Initrurnint
Teg ID
I lewisite Agent Holding
Tank LCS-TANK-851 I
Level Indicator
812-LIT-
8540
Radar Lrvel Indicating
Transmitter
0-65in.t 1.0% of
Span
I 80 days 6.4.5 .3
2 lrwisite Agent Holding
Tank LCS-TANK-851 I
High-High trvel Interlock
8I2.LSHH.
8539
Ultra Sonic lrvel
Switch
lnterlock
setpoint 65"
above tangent2
See NOTE
3
360 days 6.4.6
3 Major Spill Collection
Tank I-CS-TANK-8534
kvel Indicator
8 l2-LIT-
8590
Radar lrvel lndicating
Transmitter
0-65in.t 1.0% of
Span
I 80 days 6.4.5.3
4 Major Spill Collection
Tank LCS-TANK-8534
High-High Lrvel Interlock
8 I2-LSHH.
8589
Ultra Sonic [-evel
Switch
Ihterlock
setpoint 65"
above tangent2
See NOTE
3
360 days 6.4.6
5 Spent Decon Holding
Tank SDS-TANK-8523
Level lndicator
829-LIT-
8567
Radar Level Indicating
Transmitter
0-65in.+ 1.0% of
Span
I 80 days 6.4.5.3
6 Spent Decon Holding
Tank SDS-TANK-8523
High-High level [nterlock
829-LSHH-
8566
Ultra Sonic lrvel
Switch
Interlock
setpoint 65"
above tangent2
See NOTE
3
360 days 6.4.6
7 Nitric Acid Holding Tank
NSF-TANK-8514 Level
lndicator
842-LIT-
8547
Radar [rvel Indicating
Transmitter
0-65in.t 1.0% of
Span
I 80 days 6.4.5.3
8 Nitric Acid Holding Tank
NSF-TANK-8514 High-
High lrvel Interlock
842.LSHH.
8546
Ultra Sonic level
Switch
Interlock
setpoint 65"
above tangent2
See NOTE
3
360 days 6.4.6
9 Nitric Acid Holding Tank
LCS-TANK-8516 Lrvel
Indicator
842-LtT-
8555
Radar level Indicating
Transmitter
0-65in.+ 1.0% of
Span
I 80 days 6.4.s.3
l0 Nitric Acid Holding Tank
LCS-TANK-8516 High-
High lrvel lnterlock
842.LSHH.
8554
Ultra Sonic Level
Switch
Interlock
setpoint 65"
above tangent2
See NOTE
3
360 days 6.4.6
NOTES:
t Reserved
2 The tank tangent is the geometric transition where the cylindrical side mees the ellipsoidal bottom, approximately two inches below the head+o-shell
weld.
3' l.evel switches are not calibrated, they are function tested. The level at which they activate is not adjustable since each switch is positioned in the tank
though a flanged opening in the side ofthe tank
Attachment6-Page30
(.+(+
FD
C))r+)l{P)(D)(.+{
ATTACHMENT 7
TRAININGPLAN
TOCDF
Training Plan
TABLE OF CONTENTS
TABLE OF CONTENTS
LIST OF ACRONYMS
LIST OF TABLES
7.1 PERSONNEL TRAINING
7.2 OUTLINE OF TRAINING PROGRAIvI
7.2.1 Programmatic Training
7.2.2 Job Titles and Duties
7.2.3 Training Content, Frequency, and Techniques
7.2.4 Chemical DemilitarizationTraining Facility
7.2.5 TOCDF Site Training
7.2.6 Annual Review and Other Training
7.2.7 Training Manager
7.2.8 Training for Emergency Response
7.3 IMPLEMENTATION OF TRAINING PROGRAI\4
7.4 DETAILED COURSE DESCRIPTIONS
Attachm ent 7 - Page I
TOCDF
Training Plan
I
LIST OF ACRONYMS
CAIVIDS Chemical Agent Munition Disposal System
CDTF Chemical Demihtanzation Training Facility
CFR Code of Federal Regulations
CMA Chemical Materials Agency
JACADS Johnston Atgll Chemical Agent Disposal System
PAS Pollution Abatement System
PDAR Process Data Acquisition and Recording
RCRA Resource Conservation and Recovery Act
TOCDF
-Tooele
Chemical Agent Disposal Facility
ATLIC Area 10 Liquid Incinerator
LIST OF TABLES
*. .,:
TABLE 7-1 INITIAL TRAINING REQUIREMENTS
TABLET-Z ANNUALREVIEWPROCESSCHANGEREQUIREMENTS
Attachm ent 7 - Page 2
7.1
7 .l,l
7 .1.2
7 .1.3
7 .1.4
7.2
7.2.1
7 .2.1 .1
7 .2.r.2
TOCDF
Training Plan
@
PERS Or\NEL TRAINING tR3 1 5-3-5ft X12). Ri I 5-8-2.7t
This training plan has been developed in accordance with R315-3-5(b)(12) and R315-8-2.7
as an integral part of the facility's Hazardous Waste Permit for hazardous waste treatment
and storage. It has besn impleme,nted to ensure that the facility is operated in a manner that
protects human health and the environment, both on and off the facility.
The training program trains facility personnel to perform their duties by providing classroom
instruction, hands-on Computer Based Training equipmeirt, and supervised on-the-job
training. The program provides for both initial and annual review kaining, relevant to an
employee's position, for the facility personnel that manage hazardous waste. This includes,
but is not limited to, personnel that handle, move, perform maintenance on, or operate
hazardous waste management equipment. The program provides facility personnel with
training relevant to their positions to respond effectively to emergencies and familiarization
with emergencyprocedures, emergency equipment, emergsncy systems and implementation
of the contingency plan. Relevant to the employees' duties, instruction is given which
teaches hazardous waste management procedures to ensure compliance with this Permit.
Included in the training are assessments of each individual's skill and knowledge to
determine that the training program objectives have been met.
This training plan provides for the recording and documentation of training which meet
hazardous waste requirements. This training plan is reviewed and updated periodically to
maintain compliance with permit and regulatory requirements. This training plan is
maintained and available at the Tooele Chemical Agent Disposal Facility (TOCDF).
Section 7.2 provides an outline of the training program, while Section 7.3 describes
implernentation of the training program.
OUTLINE oF TRAINING PROGRAM IR315-3-5ft)(12). R315-8-2.7(a)(1). R315-8-
2.7(a\Q\t
Pro grarnmatic Trainine
The Chemical Materials Agency (CMA) has been tasked with carrying out the Army's
responsibility for disposing of the United States stockpile of chemical warfare munitions
pursuant to Public Law 99-145. There are eight disposal sites in the continental United
States where chemical disposal facilities are or may be constructed, with the TOCDF
being one of the eight. A programmatic training facility was planned to provide systems
training. The programmatic demilitarizationtraining facility is located in the Edgewood
Area of the Aberdeen Proving Ground, Maryland, known as the Chemical
Demilitarization Training Facility (CDTF).
Thistrainingprovidestheskillandknowledgethatiscommontotheeightchemical
disposal facilities. The training is provided by using actual process equipment and lines,
simulated toxic work areas, a control room, and a non-agent laboratory.
Attachm ent 7 - Page 3
7 .2.1.3
7 .2.1 .4
7 .2.1.5
'7.2,2
7.2.2.1
7.2,2.2
7.2.2.3
;
7.2.3
7 .2.3. 1
7.2.4
7.2.4.1
TOCDF
-r*rr**#[i'S#fl
!
The training progra:ir was developed from a job/task analysis that defined the technical
tasks which are performed by the facility personnel. Skill and knowledge profiles were
developed to indicate the items that must be known to perform a particular task. The skill
and knowledge profiles were then used to develop the course objectives and supporting
training materials.
The TOCDF course materials are validated by technical review performed by Government
and/or contractor subject matter experts. Any required changes are incorporated prior to
using the course material.
Not all facilitypersonnel receive advanced training at CDTF; initial training and annual
review training are conducted at TOCDF. Tables 7-l andT-2listthe courses for initial,
advanced, and.annual review training. The courses listed in the tables and described in
Section 7.4 are taught at either CDTF or TOCDF.
Job Titles and Duties IR315-8-2.7(dX1)l
The original job titles and duties for job positions related to hazardous waste management
were determined as part of the training program development process. Each job position
.. ., shall have a written job description, which lists the requisite skill, education or other
' ' qualifications, and the duties for that position. The TOCDF job description and employee
name filling that position shall be maintained at TOCDF.
Facility personnel *" t ir"a usirig critgria for each job classification, which includes
minimum standards for education and previous training or experience.
Personnel expected to have access to agent will enter the Army's Chemical Personnel
Reliability Program.
' Trainine Content. Frequencv. and Techniques R315-8-2.7(dX3). R3l5-8-2.7(c)l
The classroom lectures, hands-on Computer Based Training, and self-paced study courses
that are required by an employee's job position are listed in Table 7-I,Table7-2 andin
the Training Records database. The descriptions of these courses, and the training
frequency and techniques, are included in Section 7.4.
Chemical Demilitarization Trainine Facilitv (CDTF) Training
The CDTF located at Aberdeen Proving Ground, Maryland, is used to provide classroom
and hands-on training for those personnel who will benefit from practicing with the
unique demilitarization equipment and monitoring support equipment. The CDTF
includes actual demilitarization process lines as training equipment, a control room,
simulated toxic operations area, maintenance craft laboratories for electrical, instrument,
and mechanical training, simulated toxic maintenance area, and a non-agent laboratory.
' . This equipment allows plant operators, maintenance personnel, and analytical and
monitoring personnel to have hands-on experience in a nontoxic environment.
Attachm ent 7 - Page 4
7.2.4.2
7.2.4.3
7.2.5
7 .2.5.1
7 .2.5.2
7.2.6
7 .2.6.1
TOCDF
,*ruJffi'S"t:il
Major pieces of demilitarization equipment installed at the CDTF are the Rocket Shear
Machine/Burster Size Reduction kit, Mine Machine, Projectile/l\dortar Disassernbly
Machine, Multipurpose DemilitarizationMachine, Bulk Drain Station, conveyors,
airlocks, fumace equipment and the Pick and Place Machine. The equipment is
sequenced to follow the demilitarizationprocess from the Unpack Area, through the
Explosive Containment Room Vestibule, and through the demilitarization operations.
Operation and control of other process equipment not included at the CDTF is simulated
using a simulation computer and trainer's console. The non-agent laboratory provides
training in monitoring and analytical techniques in the areas of occupational exposure and
environmental emission criteria.
The personnel who do not require advanced technical training at the CDTF (administrative
personnel, support staff, etc.) receive their training at the TOCDF. Personnel attend
training at the CDTF in accordance with the requirements of their job position. The
detailed course descriptions shown in Section 7.4 maybe taught by either TOCDF or
CDTF instructors. Personnel in operations and maintenance are only required to train in
those sections of the technical courses in Section 7.4 that are needed to operate/maintain
the system(s) on which they will work. For example, a Control Room Operator attends
applicable modules of Plant Operator training as required by their job position, while a
Pollution Abatement System (PAS) Operator attends only those modules, which are
relevant to the PAS. Also, a Control Room Operator who operates fumace systems is only
trained in the sections applicable to those systems in each technical course.
TOCDF Site Trainine
During training, the employee gains plant knowledge and experience. Department
managers and/or supervisors may conduct job specific training or performance
demonstrations needed for employees to demonstrate job competency or to complete
experience requirements.
Employees shall not work unsupervised in the plant until the training requirements for
their respective job titles are complete. This includes completing initial and advanced
training courses and the satisfactory completion of any on-the-job training.
Annual Review and Other Training
Continuing training takes place at the TOCDF and/or CDTF. The job titles, which receive
continuing training, are shown in Table 7-2. DPE suit training is only provided to those
individuals with the specified job titles who actually make DPE entries. Additional
training requirements of specific personnel are based on observation and critique by safety
and supervisory personnel. Remedial training is conducted whenever necessary. When
job specific requirements warrant change to either training or training material, such as a
change in munition processing or agent campaign, retraining shall take place for the
relevant job titles without modification to this Permit. lntegrated plant exercises are held
that may involve small groups or.the entire facility in order to evaluate personnel
emergency responses and provide team training. These exercise scenarios are also used to
evaluate the emergency responses and the contingency procedures.
Attachrn ent 7 - Page 5
'7.2.6.2
7.2.6.3
7.2.6.4
7.2.7
7.2.7.1
7 .2.7 .l .l
7 .2.7 .l .2
7 .z.i .r.3
7 .2:7 .1 .4
7 .2.7 .1 .5
7 .2.J .l .6
7 .2.7 .l .7
TOCDF
Training Plan
. @
When munition processing or an agent campaign is changed, the facility personnel shall
receive specific training before the new campaign begins. The training courses for process
change are listed in Table 7-2. Only the training necessary for the process change will be
taught. 'Annual review training provides a review ofagent characteristics, hazards and
symptoms, emergency response, and waste management. Some of the presentation
techniques for annual review training may be changed from formal classroom activities to
self-paced study. The self-paced study is directed and monitored by the Training Staff.
The employee is given sufficient time to study the material for the course. The same
material is reviewed in self-paced study as in formal classroom activities. The detailed
course descriptions in Section 7.4 state the applicability of annual review training for each
course. Included in the annual refresher training is a review of the agent characteristics
and associated hazards/symptoms.
In addition to completing required courses, all employees must understand the basic
operation of the facility and know and abide by Army regulations applicable to chemical
agent facilities, such as surety, security, and safety.
Some of the presentation techniques may be changed to self-paced study from formal
classroom activities, for individuals hired to fill a job position after the initial work force
has been trained. The self-paced training is directed and monitored by the Training Staff
and any on-the-job training is directed by the individual's supervisor. The employee is
given sufficient time to study the material and take the written test(s) for the course. The
new hires develop the same skill and knowledge as if they had attended formal classroom
activities. New hires complete required training before working unsupervised in the plant.
They shall complete initial training requirements within six months of the date of their
employment or assignment to a new position. They shall complete advanced training
requirements for their respective job titles prior to working unsupervised in the plant.
Trainine Manaser [R3 1 5-8-2.7(ax2)l
The Training Manager at the TOCDF is responsible for ensuring that employees have
completed the training requirements and performance demonstrations, if any, for their
specified job. Included in the requirements and responsibilities of the Training Manager
are the following:
Schedule training
Coordinate training with the CDTF.
Supervise the training of persormel in proper operation. of the facility in accordance with
federal, state, and local environmental regulations, and the facility's Permit.
Perform and evaluate classroom instruction.
Document performance demonstrations, if any, for each job position.
Administer the personnel training records in accordance with this Permit.
Ensure the quality of the training progam.
Attachm ent 7 - Page 6
7 .2.7 .l .8
7 .2.7 .l .9
7.2.7.2
7.2.7,2.1
7.2.7.2.2
7.2.7,2.3
7.2,7.3
7.2.8
7 .2.8.1
7.2.8.2
7.2.8.3
7.3
7 .3.1
TOCDF
*rrt*=r,ffiffi
Identiff training documents.'
Direct and coordinate training docurnent development.
The experience and qualifications of the Training Manager are:
Trained in hazardous waste management.
Knowledge of plant operations.
Prior teaching experience including training plan development experie,nce.
The Training Manager is required to become thoroughly familiar with hazardous waste
management requirements and facility operations prior to exercising control over this
training program.
Facility personnel are trained to respond properly, as outlined in Attachment 9
(Contingency Plan), to emergency situations based on their job responsibilities. Training
includes agent characteristics/symptoms and first aid, response to alarms and evacuation
response to fire alarms, and personal protective equipment. Employees receive training
appropriate to their job description that includes emergency response for agent related
emergencies. Practical exercises and participation in exercise scenarios provide onthe-job
experience. Based on job duties, employees receive training on emergency monitoring
equipment operation and maintenance, key parameters for waste feed cut-offs, and ground
water contamination.
Site hazardous material response training is provided to selected individuals from the site
who acts as responders to hazardous material incidents. The site specific training is
provided by an instructor whose qualifications meet the regulatory requirements as
determined by the Training Manager.
Annual review training is provided by TOCDF instructors. Training records for annual
review training shall be maintained at the TOCDF.
IMPLEMENTATION OF TRAINING PROGRAM tR315-8-2.7ft). R3 15-8-
2.7(d(4). R315-8-2.7(e)l
Facility personnel that manage hazardous waste shall successfully complete their initial
training within six months after their date of employment, assignment to the facility, or
assignment to a new position at the facility. Prior to completing the advanced training,
personnel that manage hazardous waste shall be supervised while performing hazardous
waste duties.
Attachm ent 7 - Page 7
7 .3.2
.7.1.3
7 ,3.4
7 .3.s
7 .3.5.1
7 .3.5.2
7 .3.5.3
7 .3.5.4
7 .3.6
7.4
7.4-.1
TOCDF
Training Plan
@
Training operations began prior to systemization, continue through plant operations, and
end when closure is complete. The training program includes initial, advanced, and
annual review training. Personnel in operations and maintenance are only required to
completd the sections of the technical courses described in Section 7.4, which are relevant
to the system(s), which the individual will operate or maintain.
Employees are assigned to training courses that meet the needs of the facility and ensure
compliance with regulatory requirements. Each course has its own unique set of
objectives for skill and knowledge that must be mastered before the employee passes the
course. The instructor records attendance and performance for each employee. The
Training Department tracks the training given to and completed by each employee.
Employees who cannot complete the training requirements for their job position will have
their training records and performance evaluated. The evaluation will be conducted by the
Training Manager and the individual's manager or department head. Recommendations
on the employee's suitability to the job or the project will be made to the Human
Resources Department.
The following information and documents shall be maintained and available at the
TOCDF:
Job title for each position at the facility related to hazardous waste management, and the
name of the employee(s) filling each job.
A written job description for each job title.
A written description of the tlpe and amount of initial, advanced, and annual review
training given to each person named.
Records that document the successful completion of the training and any experience
required for each person named.
The training records and documents shall be kept at least until closure of the facility.
Training records on former employees shall be kept at least three years from the date the
employee last worked at the facility. The Training Plan shall be maintained and available
at the TOCDF.
Detailed Curriculum Descriptions tR315-b-2.7(dX3)l
The following curriculum categories consist of one or more training courses. Employees
are required to successfully complete at least one training course in any category required
for their job position. Employees receive training in the courses which are necessary for
their job position. These courses may be applicable for initial, advanced, annual review,
or process change training. lnitial training shall be completed within six months.
Advanced training shall be completed following the initial training period but prior to the
employee working unsupervised in the plant. Annual review training shall be
accomplished within the same calendar month (anniversary month) plus or minus 30 days
of initial training and may consist of self-paced study. Employees hired prior to the
effective date of this Permit may use their last refresher date as the date of initial training.
Attachm ent 7 - Page 8
7.4.2
7.4.3
7.4.4
7.4.5
TOCDF
Training Plan
@
For a change in munition processing or agent campaign, only the training necessary for the
change is provided. Courses may be conducted by either CDTF or TOCDF personnel at
either facility. Topics covered in the General Employee and Safety and Health categories
meet the OSHA requiremsnts for Hazardous Waste Operations (HAZWOPER) for a
TSDF facility.
General Employee: This curriculum provides employees with general information about
the TOCDF. This curriculum is an initial training requirement. Annual review training is
applicable. Process change training is not applicable. Topics covered in this curriculum
include: Chemical Stockpile Disposal Program Overview; Chemical Ageirt Description,
Response to Alarms, Description of Munitions/Agent Inventory Process Flow Overview,
Personal Protective Equipment for Site E try, Quality Control Overview, Federal and
State Regulatory Authority, Emergency Response Plan and Organization, Safety Program
Plan, Accident Prevention Plan, Industrial Hygiene Plan, Medical Plan, Training Plan,
Qualrty Assurance Plan, Security and Safety.
Safety and Health: This curriculum provides training that meets applicable OSHA and
Army regulatory requirements for Operations and Emergency Response. This curriculum
is an initial training requirement. Annual review training is applicable. Process change
training is not applicable. Employees receive training in the courses which are necessary
for their job positions. Topics covered in this curriculum include: Hazard
Communication, CPR, First Aid, Confined Space, LockouVTagout. Advanced Safety and
Health courses are provided to selected employees who act as part of the TOCDF
Emergency Response Organization (ERO).
Systems Descriptions: This curriculum describes the operation and control of the plant
systems and is broken into training courses and taught at the block diagram, piping and
instrumentation drawing level, as appropriate for the job position. Employees receive only
the courses necessary forjob performance. These course are intended for employees who
operate or maintain plant equipment and their managers/supervisors. This curriculum is
an initial training requirement. Annual review and process change training are not
applicable. Topics covered in this curriculum include: Major ComponentslEquipment and
Construction; System Operation; System Flow; System Key Parameters; System
lnterlocks; System Alarms; and System Waste Feed Cut-off.
Toxic Area Personal Protective Equipment: This curriculum is an initial training
requirement. Annual review training is applicable. Employees receive training in the
courses which are necessary for their job positions. Topics covered in this curriculum
include: Supplied Air PPE Levels of Dress (DPE or OSHA-A), Air Puriffing PPE Levels
of Dress (Levels C and D), and Toxic Area EntrylExit protocol. This curriculum provides
a description of all levels of protective clothing, toxic area entry reciuirements and
procedures, decontamination techniques, toxic area entry monitoring activities, and
personnel emergencies in toxic areas. Practical exercises are included for suit-up activities
and decontamination.
Plant Operations: This curriculum is intended for plant operators, their supervisors, and
plant shift managers. Courses build on previous training for operators and supervisors
who handle agent/munitions, control or handle waste streams associated with the
demilitarization processes. Employees receive training in the courses which are necessary
7.4.6
Attachrn ent 7 - Page 9
7,4.7
7.4.8
J.4.9
7 .4.t0
l,
t .'
TOCDF
Training Plan
@
for their job positions. Hands-on training is provided for operators to develop the skills
necessaryto operate plant equipment during normal and emergency conditions. This
curriculum is an advanced training requirement. Arurual review training is not applicable.
Process change training is applicable. Topics covered in this curriculum include: Control
Description and Response; Interpretation of System Indication and Response; System
Operation; System Safety, Chemical Surety, and Environmental Requirements;Normal
System Operating Procedures; Abnormal,/Emergency Proeess System Procedures; Data
Loggrng; Procedure Compliance and Process Control System Overview.
.Plant Maintenance: This curriculum provides maintsnance craftsmen and supervisors
with the skills and knowledge to maintain various pieces of plant equipment. This
curriculum is an advariced training requirement. Annual review training is not applicable.
Process change training is applicable. Topics covered in this curriculum include: Normal
Operation; Troubleshooting; Maintenance Techniques and Methods; Safety and
Environmental Requirements; and Data Logging.
Monitoring: This curriculum provides monitoring personnel and supervisors with a
description of monitoring activities and equipment. It provides skills and knowledge on
the agent and industrial pollutant monitoring equipment used at the facility. This
curriculum is an advanced training requirement. Annual review training is not applicable.
Process change training is applicable. Topics covered in this curriculum include:
Operation and Maintenance of Agent Monitors; Operation and Maintenance of Non-Agent
Monitors; Troubleshooting Equipment Faults; Response to Agent and Non-Age,nt Monitor
Alarms; Laboratory Monitoring Procedures; and Sample Collection Requirements and
Methods.
Laboratory: This curriculum is designed to introduce laboratory personnel to the plans,
procedures and equipment necessary to perform the laboratory mission in a safe and
environmentally responsible manner in accordance with applicable regulations. This
curriculum is an advanced training requirement. Annual review training is not applicable.
Process change training is applicable. Topics covered in this curriculum include:
Laboratory Analytical Procedures; Laboratory Safety; Chemical Hygiene; Hazardous
Waste Procedures; Contingency Procedures; Component Fault Isolation Techniques;
Equipment Maintenance Safety; and Component Replacement.
Process Control System: This course is intended for Controls Engineers and Process Data
Acquisition and Recording (PDAR) Engineers. It provides a detailed explanation of the
specific components of the process control system. This course is an advanced training
requirement. Annual review and process change training are not applicable. Topics
covered in this course include: Equipment Operation; Troubleshooting; and Programming.
Attachmentl- Page l0
TOCDF
Training Plan
Table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number 1 2 3 4 5 6 7 8 9
CURRICULUM TITLE
(l)q)
o-g---rd
I.6lL
C)E(r)I
--!-c,(u
HI
EE6l
Te€la
rititr
6
C)L
I
a-notr
O--o.I
I
EL
.LL
e)qtoa
EA-E
C)!a,
a
a--c
.I)!6tL
C)oo
I--C-tr
€)
C.)-I6E(9
9
EI
a-6tsla
TEC-er
a0
EI.-LoI
atleolr2
to:aLo€6
FI
a2-oL!eo(J
acn
G)9oLtrJOB TITLE
TOCDF Personnel
General Manager x x x
Deputy General Manager - Technical Support/Risk
Manager x X x
Deputy General Manager - Closure Integration X x x x
Permitting Supervisor x X x
Environmental Manager x X X
Environmental Shift Inspector x X
Environmental I n spector/Auditor x'x
Comp li ance/Audi t S upervi sor X x X
Permitting Techni ci anlSpeci al i st X X X
Environmental Test Specialist x X X
Closure Electrical Engineer x'x x
Closure Environmental Engineer Technologist X X X
Closure Mechanical Engineer x X x
Closure Manager X X x
Secondary Waste Manager X X x
Environrnental Technician X X x
Project Manager - Mustard x X X
Trial Burns Project Manager X X X
Area lO/Secondary Waste Operations Manager x x X x
Operator/Secondary Waste X x
Operations Supervisor - Iv{ustard X x x x X
Environmental Leader x X x
Changeover Manager x x x x x
Facility Modifi cation Specialist x X X X X
Surety & Security Manager X x X
Perfonnance and Quality Assurance Manager X x x
Quality Manager X x x
Attachment7- Page 1 1
TOCDF
Training Plan
Table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number 1 2 3 4 5 6 7 8 9
CURRICULUM TITLE
o
C)
o-a-Lh
frl
E.6f.
C)E
C)(J
-rIt,l
c,(u-f*i
EEqt
I
,g6a
r{trtr
6lIL
.9xoti
a
-l-o
al!a
.I LIU,oa
aET()I0
a
U'--o.Il
I6Loao
IEt-tr
€J9E6-to
IE.rl
6'
TEC-Er
AD-Ia-
LoI.al
Eo
E
Lo
IdLoE
6l
Fl
a-ot
I-IoU
rA
?A
C'UoL
erJOB TITLE
Quality Support Specialist X X x
Quality Technician x x x
Quality Oversight Specialist x x x
Quality Support Supervisor x x X
Quality Management Support Technician x X x
Safety Manager X x x
Deputy Safety Manager x X X
Shift Safety Specialist X X X
S afety En gi neer/Technol ogi st x X X
Industrial Hygienist x x X
Agent Munitions/Saf-ety Specialist x X x
Security Specialist X x X
Emergency Preparedness Administrator r x X x
Training Manager X x X
Training Instructor /Simulator Specialist x x X
Training Special i st/lnstructor x X x
Instructional Technologist X X x
Operations and Maintenance Manager x X X
Deputy Operations and Maintenance Manager X x X
Assistant Operations Manager x X X x
Plant Shift Manager X X X X
Maintenance Manager X x X
Systems Engineer X X X
Controls Engineer X x X x
:
Controls Engineer Supervisor x x x x
Operations Supervisor X X X X x
Control Room Supervisor x'x x X X x x
Hazmat/ H ot I i n e/ D S A/ S upervi sor X X x x x
Control Room Operator X X X X X
PAS Operator x x X X X
BRA/RHA Operator X X X X
Attachrnent 7- Page 12
TOCDF
Training Plan
Table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number I 2 3 4 5 6 7 8 9
CURRICULUM TITLE
(9
C)
o
-aEL-hL
frl-6L
C)EoU
E3-6t
€)
Hir
E
EI6
I
,g
6to
f-Itr
Cr
qt
(lJlr
I.rlxoF
TA--o.!a:a
.I L(,a
€)a
?A
-l-h(,
I0
0
et-Io
a-3qt
L(,
A-o
Tg
a-n{
q)I
EI
6te
€)
IE.-a
6t
E
!EC-o.
a0--.I LoI.ra
EIots2
LoT
6!Lo€
6!:1
a-otr
I--o
Q
qh
?t()
I6litrJOB TITLE
Utilities Operator x x x x
DSA Operator x x x x x
CHB/UPA Operator x x x x x
Operations Munition Coordinator x x x X x x
Maintenance Supervisor x x x x
Maintenance Engineer x x x
Calibration Coordinator x x
Planner X x
Electrical Technician x x x x x
Instrument Installer x x
I&C Technician x X x X x
Mechanical Technician X X X x X
PM/CM Technrcran X X
Preventative Maintenance Coordi nator x X X
Modifi cation Maintenance Supervisor x X X
Warehouse Supervisor x X
Hazardous Waste M anager X X x x X
Hazardous Waste Coordinator x X x x X
Senior Hazardous Waste Technician x x x X x
Hazardous Waste Technician X X X X x
Hazardous Waste Tracking Support Specialist X X
Laboratory Manager/Battelle Senior Site Manager X X X X x
Project Manager-Secondary Waste and Closure x x x X
Laboratory QC Manager x x X X x
QC Analytical Inspector x x x x X
QC Analytical Inspector Supervisor / QC Specialist X X X x x
Quality Engineer x x x X X
Special Projects Chemist x x X x x
QC Monitoring Inspector Supervisor / QC Specialist x X X X x
QC Monitoring Inspector X X x X X
Laboratory Monitoring Manager x X x X
AttachmentT- Page l3
O
TOCDF
Training Plan
Table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number 1 2 3 4 5 6 7 8 9
",.
CURRICULUM TITLE
€Je)
o-g-ts
If.l
-a6L()
Eo(J
--IE.
ctc)
Hr*r-U-Iqt
UeCct)
Htr
Cr
6le)L
I.-*otr
a-Io.!a
Ia.-L
?)0(ua
CA--T(uTa
U2
U,--oo-.la
6tL
€)aoT
EI6t-t{
(l')IE6t
taIo
IE.ra
6tEz
IEilt-tr
a0-ts.taLofa--Io!{a
Lo
IctLoEC
Fl
a
-loL3
-lIoU
u)al)IoLtr.IAN TITLE
CEMS Specialist x x X x
Monito.irg Operations Manager x x x x X
Monitoring Coordinating Manager x x x x x
Master Technician x x x x
Monitoring Foreman x x x X
Senior Instrument TechlLead X x x x x
Senior M onitoring Technician x X x X x
M onitoring' Techni ci an I x x x x X
Monitoring Technician II x X x x x
Senior Laboratory Support Technician X x x x x
Monitoring Scientist X x X X x
Operations Analytical Support Manager x X X X X X
Instrument Technician x x x X X
Laboratory Analytical Manager X X X x
Laboratory Shift Supervisor X x X X
DAAMS Team Lead X x X x
Senior GC Operator x X X X
GC Operator x x X X
Logistician X X x X
Solutions Chemistry Lead X X x X X
Agent Solutions Chernist x x X x X
Metals Chernist X X X x x
Mercury Metals Chemist X X X x
Laboratory Data Analyst Demil Tech I x x X X
Laboratory Data Ap'alyst Demil Tech II x X X X
Plant Systems Engineering Manager X X X
Proj ect Engineering Supervtsor x X X
Engineering Manager X x X
Engineering Supervi sor X X X
Electrical Engineer Design x X X X
Electrical Engineer x X X xo
Attachm ent 7 - Page 14
TOCDF
Table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number I 2 3 4 5 6 7 8 9
CURRICULUM TITLE
(,)
c)
o-CL-LH
rd-€LoEoI
--t
-lql
e)
Hr{
EE
6t
!e€0
frltrtr
6t
C)L
Iaraxot-
qa
EIo.Il3
AI.IlLq)
ehq)a
a-bI{)Ta
cA
0Eo
a-I6
li(uao
!EC
I.tr
€)I
EI
6t-I(9IE.-l
C
E
IEC-nr
a0EaraLo
I.L
Eots2
Lo€6Lo4
C
11
U'
-aoLIEoU
e,,Y'
C)IoLarJOB TITLE
Mechanical Engineer - Design X x x
Engineering Technologist - Design x x x
Engineering/Technol ogi st x x x
Engineering Technician x x x
PDAR Engineer x x x
PDAR Technician X x x
Environmental Engineer/Technol ogi st X x x
Project Specialist x X x
ATLICWPersonnr )l
Analytical Supervisor x x x x x
Area lO/Secondary Waste Operations Manager x X X x
ATLIC Operations Manager x x X X x
Battelle/CAM DS Monitoring Manager X X X X x
CAMDS/DCD Analytical Manaeer x x x x
CD Instrument Technician X X x x x X
x x x x x x
CD Master Technician x x x X x x
CD Monitoring Foreman x x x x x x
CD Monitoring Technician I x X x x
CD Monitorine Technician II X X X x x x
CD Principal Research Scientist X x x X x
x x x x x
ieian x x x x x x
Closure Laboratory and Monitoring Manager X X X X X
Control Center Operator x x x x x x
Controls / I&C/ Electrical Technician x X x x X
GA/Lewisite Analytical Supervisor X X x
GNlewisite Mechanical Technician X X X x x
Gfu Lewisite Monitoring Manager x X x x x
ICP Chemist X X x x X
Junior Chemist X X x x X
AttachrnentT-Page
o
TOCDF
Training Planll' @
table 7-1
InitiaUAdvanced Training Requirements
Initial Training x x x x
Advanced Training x x x x x
Curriculum Number I 2 3 4 5 6 7 8 9
CURRICULUM TITLE
(9
c)
o-g
-lIt
tr1-6L(l)
E(r)(,
a-I
-lqt
C)-r{
EE
6t
Ie
q30
Htr
er
6tq)L
I.rlxoF
qr,
Eo.rlya.IlL9a
C)a
1a
-l-I
C)
I o
U)
?,,-Io.lT6lLoao
flE{-ti
(u9E
6t
-lIo!E.-
6lE2
3-5
6t-tr
a0-taItLo3.-
EIc
E
Lo€6troE{
Fl
a-oLI-IoU
0|t)(,IoLt(JOB TITLE
Junior GC Operator x X x x x
Junior M onitorin g Operator x X x x x
Junior Shift Chernist x x x
Monitoring Supervisor x x x X x
Operations Supervisor - Secondary Waste x X X X
PAS Operator GA/LEW x X X
Senior Chemist x X x x x
Senior GC Operator x x x X x
Senior Monitorin g Operator x x x x x
Senior Shift Chemist x X x
Shift Lead - Monitoring x x x X X
Shift Leader - Laboratory x X x X x
Uti lities Operptor GA/LEW x x X
Attachm ent 7 - Page 16
TOCDF
Training Plan
Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number I 2 3 4 -5 6 7 8 9
CURRICULUM TITLE
q)
q)
oraa-HIH-6lLq)-Io()
--+)-6lq)
Ht*r
EEcl
*.l
€J
fH
GIa
frlni
nr
GIo
li
.9xo
Fr
aE
.92E
F.-Io(l)-+JY-tD rAa8
atro.l+,clLoao
+JA
-acl-!r
oI--tc€-I
€)+,
-lHo-
GIttz
{r)t
I
cl
-lnr
a0a
I.-Lo:,
a-
Eo
Lo+,
6ltio!cl
t]
a-o
li+fa-ao
U
oaOooLilJOB TITLE
TOCDF Personnel
General Manager x x
Deputy General Manager - Technical Support/Risk
Manager x x
Deputy General Manager - Closure lntegration x x X
Permitting Supervisor x x
Environmental Manager x X
Environmental Shift Inspector X x
Environmental In spector/Audi tor X x
Compl i ance/Audi t S upervi sor X X
Permitting Techni ci anlSpeci ali st X X
Environmental Test Specialist X x
Closure Electrical Engineer X X
Closure Environmental Engineer Technologist x x
Closure Mechanical Engineer X X
Closure Manager X X
Secondary Waste Manager X x
Environmental Technici an x X
Proj ect M anager-M ustard X X
Trial Burns Project Manager X x
Area 10/Secondary Waste Operations Manager x X x
Operator/S econdary Waste x X
Operations Supervisor - Mustard X x x
Environmental Leader x X
Changeover Manager X X X X
Facility Modification Specialist x x X X
Surety & Security Manager X X
Perflonnance and Quality Assurance Manager x X
Attachrnent Page 17
TOCDF
Training Plan
Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number 1 2 3 4 5 6 7 8 9
CURRICULUM TITLE
€)(t)
o-a
aa
L
Frl-GI
liotrq)I
t-+)
-tclq)llt{
Er<
-ad
{.,
,9)rFt
cga
rd
0r!i
cl(u
L
o.-xotr
a
tH0.-2E
F.-Ia
AcJir) V)
AE
aslxo.-+)
GILoao
+,
aIcl-tr
q)
CJ
dI
ct
dIq)+,-I.-
cltlz
+,-I
GI-0(
boAts.lLo+J.l
dIoIIz
L0+)6l
liosclj
rA-,oL*Ja
IoU
ratoq)
CJo
linrJOB TITLE
Quality Manager x x
Quality Support Specialist x x
Quality Technician x x
Quality Oversight Specialist x X
Quality Support Supervisor x X
Quality Management Support Technician x X
Safety Manager x x
Deputy Safety Manager x x
Shift Safety Specialist x x
S afety En gi neer/Tech n ol ogi st x x
Industrial Hygienist X X
Agent Munitions/Safety Specialist x x
Security Specialist X X
Emergency Preparedness Admini strator x X
Training Manager x X
Training Instructor /Sirnulator Specialist X x
Training Specialist Instructor X X
Instructional Technologi st X x
Operations and Maintenance Manager X X
Deputy Operations and Maintenance Manager X x
Assistant Operations Manager x x
Plant Shift Manager x x
Maintenance Manager x X
Systerns Engineer X x
Controls Engineer x x
Controls Engineer Supervisor x X
Operations Supervisor X X X
Control Room Supervisor X X X X x
Hazmat/ H ot I i n e/D S fu S upervr s or X x x X
Control Room Operator X x X
Attachrnent 7- Page l8
TOCDF
Training Plan
Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number I 2 3 4 -5 6 7 8 9
CURRICULUM TITLE
q)o
o-aa-Lri-6lLo--o()
AtI.{-)-6lq)
Htrt
roAI
GI
+)€)(+r
GIa
rd
nr
nr
(t
€)L
CJ.-xotr
u,tIo
2Ets|ri-ai(l):l5Y'a ra
AA
ra;taoo-+,
c{Loao
+)trcl-I
(l)
It
IclaIq)
l,
E.-
6l
+,trcl-tr
b0
E.!a
lio{-,.!l
Eo
lro+,cl
lio!
6l
t]
(a-o
LItIo
U
tt2
u2o
CJo
li
erJOB TITLE
PAS Operator X x X x
BRA/RHA Operator X x x
Utilities Operator x x x
DSA Operator x X x x
CHB/UPA Operator x x x x
Operations Munition Coordinator x x x x
Maintenance Supervisor x X X
Maintenance Engineer x x
Calibration Coordi nator X X
Planner x X
Electrical Technician x x X X
Instrument Installer x x
I&C Technician X x X x
Mechanical Technician X X X X
PM/CM Technicran x x
Preventative Maintenance Coordinator X x
Modifi cation Maintenance Supervisor X x
Warehouse Supervisor X X
Hazardous Waste Manager X X X X
Hazardous Waste Coordinator X X X X
Senior Hazardous Waste Technician x X x X
Hazardous Waste Technician X X X X
Hazardous Waste Tracking Support Specialist X X
Laboratory Manager/Battelle Senior Site Manager x x X x
Project Manager-Secondary Waste and Closure x X x
Laboratory QC Manager x X x x
QC Analytical Inspector X X X x
QC Analytical Inspector Supervisor / QC Specialist X X X X
Quality Engineer x x X
QC Monitoring Inspector Supervisor / QC Specialist X x x X
Attachrnent 7-Page t9
TOCDF
Training Plan
Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number I 2 3 4 5 6 7 8 9
CURRICULUM TITLE
oo
o-aaEI
rd
E
clL
€)-Hq)()
--+r)-GIo
F?(r*r
,!tr-tl
c{
t)
-€)rts
GIa
rd
er!r
cloL
CJ.-xoF
(aaIo.-2E-.-I i:(l)ngv0V1
AE
(a
-lIo
a-+)
c!
lioao
+,tI
cg-ti
Q)(J
aa
cl
aI
(r)+)-I.-
cl
=a
+)-I
en-!i
o0
-lht.-Lo+).l
Eo=2
Lo+)cl
lio€
ctj
u2-oL+,AIo
U
0
U,oIoL!iJOB TITLE
QC Monitoring Inspector X x x x
Special Projects Chemist x x X
Laboratory Monitoring M anager X x x
CEMS Specialist x x X
Monitoring Operations Manager x x x X
Monitoring Coordinating Manager X x x X
Master Technician x x x
Monitoring Foreman X x X
Senior Instrument TechlLead X x X x
Senior Monitoring Technicran X X X X
Instrument Technician X X X x
Monitoring Technician I x x X X
Monitoring Technician II x X X X
Senior Laboratory Support Technician X x x x
Monitoring Scientist x X X X
Operations Analytical Support Manager x X X X X
Laboratory Analytical Manager x X X
Laboratory Shift Supervisor X X X
DAAMS Team Lead X X X
Senior GC Operator X X x
GC Operator X X X
Logistician X X x
Solutions Chemistry Lead x X x X
Agent Solutions Chemist x x x x
Metals Chernist x X x X
Mercury Metals Chemist X x x
Laboratory Data Analyst Dernil Tech I x x X
Laboratory Data Analyst Demil Tech II x x X
Plant Systerns Engineering Manager X x
Project Engineering Supervrsor x X
Attachrn ent 7 - Page 20
TOCDF
Training Plan
, Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number I 2 3 4 t 6 7 8 9
CURRICULUM TITLE
q)o
o
EIa-LLH-clL
o)slEq)
(J
AtI{-)-GIq)
Ht
E
aI
cl
t,
€)
IH
cto
rd
Or
er
clo
li
(.)
o-xoF
a
-lHo
aL2EF.rIa -.:U'rr, A
AA
U,
-lIo
a-+)
c,
lioao
+)Ed-tr
q)
(J
IL
6lAIq)
{.)
aI.-
GItie
+fAa
ctl
-l0r
a0-IaLLo+f.-
Eotlz
Lo+)cltro!clJ
co
-aoL+,
dao
U
a
u2o
CJoL
0{JOB TITLE
Engineering Manager X x
Engineering Supervisor X x
Electrical Engineer - Design X x
Electrical Engineer X x
Mechanical Engineer - Design X x
Engineering Technologist - Design X X
Engineeri n g/Technol ogi st X x
Engineering Techni ci an x x
PDAR Engineer x x
PDAR Technicran X X
Environmental Engineer'fechnologist x x
Project Specialist X X
ffiATLICPersonnel
Analytical Supervisor x x
Area l0/Secondary Waste Operations Manager X x
ATLIC Operations Manager x x
Battel lelCAM DS M onitori n&M anaeer x x
CAMDS/DCD Analytical Manager x X
CD Instrunent Technician X X
€Drl{rstrument Teeh n iei ffr x x
CD Master Technician x X
CD Monitoring Forcman X x
CD Monitoring Technician I X X
CD Monitoring Teghnician II X X
CD Principal Research Scientist x x
x X
i€ian x x x
Closure Laboratory and Monitoring.Manager X X
Co.ntrol Center Operator X X X
Controls / I&C/ Electrical Technician x X x
Attachment Page 2l
TOCDF
Training Plan
Table 7-2
Annual Review/Process Change Requirements
Annual Review Training x x x
Process Change Training x x x x
Curriculum Number 1 2 3 4 -5 6 7 8 9
CURRICULUM TITLE
q)o
o-attsI
rd-cllrq)
-lIo()
-!l+)-€€oIti:rr€--acn
t)€)IH
ctla
rdti
nr
c{oL
C).-xoti
raa-o.-
a:TEE.-ta(l):l€\,ir, a
AA
a-Io.-l*-)
€gLq)ao
t)t
c{-Rr
Q)UtHcl-tq)+,
dI.Il
cltslz
+)Ecl-tr
a0tr.l
lio+,.-
Eo
tro+rctLoE
qn
l]
U2-0L+J
aIo
U
u,
u2o(JoLtrJOB TITLE
GA/Lewisite Analytical Supervisor x x
GA/Lewisite Mechanical Technician x x x
GA/Lewisite Monitoring Manager x x
ICP Chernist X X
Junior Chemist x x
Junior GC Operatoi 'x x
Juhior Monitorin g Operator X x
Junior Shift Chemist x x
Monitorin&Supervisor X x
PAS Operator GA/LEW X x x x x x
Operations Supervisor - Secondary Waste x x
Senior Chemist x X
Senior GC Operator x x
Senior Monitoring OBerator x x
Senior Shift Chemist x x
Shift Lead - Monitoring x X
Shift Leader - Laboratory x X
Utilities Operator GA/LEW x x x x x x
Attachm ent 7 - Page 22
TOCDF
Training Plan
Table 7-l and Table 7-z
Initial and Continuing Training Requirements
ACRONYM LIST FOR JOB TITLES
CD CAMDS/DCD: a designatqr for some of the ATLIC oersonnel
iob titles
DSA Operator Demilitarization Protective Ensemble Support Area Operator
CHBruPA Operator Container Handling BuildingAJnpack Area Operator
BRA/RHA Operator Brine Reduction Area/Residue Handling Area Operator
PAS Operator Pollution Abatement System Operator
I&C Technician Instrumentation and Control Technician Operator
DAAMS Process Supervisor Depot Area Air Monitoring System Process Supervisor
GC Operator
Senior GC Operator
PDAR Engineer
Gas Chromatograph Operator
Senior Gas Chromatograph Operator
Process Data Acquisition and Recording Engineer
Attachrn ent 7 - Page 23
TOCDF
Preparedness and Prevention Plan
July 2008
ATTACHMBNT 8
PREPAREDNESS AND PREVENTION
Attachment8-Pagel
8.1
TOCDF
Preparedness and Prevention Plan
July 2008
TABLE OF CONTENTS
DOCUMENTATION OF PREPAREDNESS AND PREVENTION REQT'IREMENTS
8.1.1 Equipment Requirements
8.I.2 Aisle Space Requirements
PREVENTATIVE PROCEDURES, STRUCTURES, AND EQUIPMENT
8.2.1 LoadingAJnloading of Hazardous Waste
8.2.2 Runoff
8.2.3 Water Supplies
8.2.4 Equipment and Power Failure
8.2.4.1 Equipment Failure Conkol
8.2.4.2 Incinerator Upset Control
8.2.4.3 Emergency Power
8.2.5 Personnel ProtectionEquipment
8.2.6 Spent Decontamination Collection System
8.2.7 Agent Monitoring Equipment
PREVENTION OF IGMTION OR REACTION OF IGNITABLE, REACTIVE, OR
INCOMPATIBLE WASTE
8.3.1 Precautions to Prevent Ignition or Reaction of Ignitable or Reactive Waste
8.3.2 General Precautions for Handling Ignitable or Reactive Wastes or Accidentally Mixing
Incompatible Wastes
8.3.3 Management of Ignitable or Reactive Wastes in Containers
8.3.4 Management of Incompatible Wastes in Containers
8.3.5 Management of Ignitable or Reactive Wastes in Tanks
8.3.6 Management of Incompatible Waste in Tanks
8,2
8.3
Attachrnent 8 -Page2
t.
'{.r i
TOCDF
Preparedness and Prevention Plan
July 2008
ACAI\{S
ACRONYMS
Automatic Continuous Air Monitoring System
ATLIC Area 10 Liquid Incinerator
BDS Bulk Drain Station
BMS Burner Management System
Brine Reduction Area
Burster Removal Station
First Floor Buffer Storage Area
Burster Size Reduction Machine
Chemical Accident/Incident Response and Assistance Plan
Chemical Assessment Laboratory
Chemical Agent Munitions Disposal System
BRA
BRS
BSA
BSRM
CAIRAP
CAL
CAI\{DS
CCEE Control Center Equipment Enclosure
CFR
CDS
Code of Federal Regulations
Central Decon Svstem
Container Handling Building
Carbon monoxide
Carbon dioxide
Water
Distilled mustard, bis (2-chloroethyl) sulfide
Human Machine Interfaces
Munitions D emi litanzation Building
Metal Parts Furnace
Multipurpose D emil ttarrzation Machine
Nitrogen
National Fire Protection Association
DAu{MS
DCD
DFS
ECR
ECV
CHB
CO
COz
HzO
HD
HMIs
Composition B 60% RDX, 39.5% TNT, 0.5o Calcium Silicate
CON-OP Control Room Operator
Depot Area Air Monitoring System
Deseret Chemical Depot or'
Deactivation Furnace System
Explosive Containment Room
Explosive Containment Room Vestibule
E-stop Emereencv Stop
FCS Facility Control Systern
FSSS Flame Safety Shutdown Systan
GA Tabun (Ethvl N. N-dimethylphosphoramide-cyanidate)
GB S arin, Isopropyl methylpho sphonofluoridate
H Levinstein mustard, bis (2-chloroethyl) sulfide
HOA Hand-Off Auto
HS Hand Station
HT Mustard, 60% HD and 40%T
VO ' lnpui/Output .
LCS ,'Local Control System
Lewisite Dichloro-(2chlorovi$yl) arsine
Liquid'lncinerator
Loc'al-Off Remote
LIC
LOR
MDB
MPF
MDM
Nz
NFPA
AttachmentS-Page3
TOCDF
Preparedness and Prevention Plan
July 2008
NO
NOz
Nitrogen oxide
Nitrogen dioxide
Tooele Army Depot
Toxic Maintenance Area
Tooele Chemical Agent Disposal Facility
Toxic Cubicle
Unpack Area
Upper Munitions Corridor
OWS Operator Workstation
Pollution Abatement System
Programmable Logic Controller
Proj ectile/Jvlortar Di sas s embly M achine
Personal Protective Equipment
C ycl otrimethyl enetrinitramine
Residue Handling Area
Spent Decontamination Solution; Spent Decontamination System
PAS
PLC
PMD
PPE
RDX
RHA
SDS
T Bis[2(2-chloroethylthioethyl)] ether
TC Ton Container
TEAD
TMA
TOCDF
TOX
UPA
UPMC
\IX O-ethyl-S(2-diisopropylaminoethyl) methyl phosphonothiolate
Attachrnent 8 -Page 4
8.1
8.1.1
9.1 .1.1
8.1 .t .2
TOCDF
Preparedness and Prevention Plan
July 2008
DOCT]MENTATION OF PREPAREDNESS AI\D PREVENTION
REOUIREMENTS IR3 15-8-3.3 : R3 15-8-3.61
Equipment Requirements
The Tooele Chemical Agent Disposal Facility (TOCDF) and Arba l0 Liquid Incinerator
(ATLIC) maintains an extensive inventory of emergency equipment. Telephone and
public address loudspeakers are available throughout the facility and in all work areas for
use in case of emergencies. The telephone system is available for intemal as well as
external communications. Portable fire extinguishers, a sprinkler systern, a halon system,
and a FM-200|FE-227 system are all built into the facility to minimize the threat of fire.
Attachment 5 (Inspection Plan) contains lists of emergsncy equipment that are inventoried
on a regular basis. Attachment 9 (Contingency Plan) contains a list of additional
emergency equipment available from Deseret Chemical Depot (DCD) and Tooele Army
Depot (TEAD).
Pumps are installed at the existing wells to produce the anticipated 616,000 gallons per
day required at Deseret Chemical Depot (DCD). The well pumps supply water to two
reservbits (with a combined capacity of one million gallons). These reservoirs supply the
water distribution system at DCD. These reservoirs provide sufficient water for operations
at the TOCDF and ATLIC. and the fire water requirement of 330,000 gallons. All water
storage tank system components are designed to meet National Fire Protection Association
(I.[FPA) standards.
ry
Areas that will be used by TOCDF for container storage include tThe Container Handling
Building, (CHB), Unpack Area (JPA), Explosive Containment Room Vestibule (ECV),
the Upper Munitions Corridor CJPMC), the S-2 warehouse, the Toxic Maintenance Area
(TMA), and Igloog 1632 and 1633 . The storage areas
are arranged to provide efficiency in container storage; to provide adequate access for fire-
fighting and proper maneuvering of a forklift (except in the ECV and UPMC); to meet
minimum fire code requirements; and to allow easy access for personnel and equipment,
which is needed for inspections and emergency operations.
The CHB stores the munitions before demilitarization processing. There is a minimum of
2.5 feet of aisle space associated with the containers stored in the TMA Container Storage
Area, the S-2 warehouse, and Igloos 1632 and 1 633. An aisle space will be available for
fork lift operation in the S-2 warehouse and Igloos 1632 ard 1633. There is a minimum of
six feet of aisle space between overpacks (On-site Containers (ONCs) stored in the CHB.
There are no aisle space requirements for the containers stored within an overpack. Aisle
space within an overpack is not relevant or needed since the overpacks are monitored and,
if a release is detected, the overpacks and leaking munitions are managed as described in
Attachment 1 2 (Containers).
PREVENTIVE PROCEDT]RES. STRUCTT]RES. AIID EOUIPMENT tR3 1 5-3.
2.sftx8)t
8.1 .2
8.1.2.1
8.1 .2.2
8.2
AttachmentS-Page5
8.2.1.2.1 Ton containers (TCs) that will be processed at the ATLIC will be broueht directly from
storage in Area 10 to the processins area. which is in close Broximity. The TC is then
placed on the transfer table. From the transfer table. the TC is placed in the elovebox.
where the agent GA or Lewisite is drained and orocessins begins.
Reserved
The incinerator ash and residue at TOCDF are
@ischarged directlyto containers. The spent charcoal from
the ventilation system a1!_TOCDF is removed from the ventilation system bypersonnel in
Personal Protective Equipment (PPE) clothing. The charcoal is placed in containers that
are compatible with the material to be stored and meet or exceed the requirements stated
in R315-8-9.3 and R315-7-16.3.
8.2.1
8.2.1.1
8.2.1 .2
8.2.1 .3
8.2,1 .4
8.2. 1 .5
g .2.1 .5. 1
8.2.1 ,5.2
i
TOCDF
Preparedness and Prevention Plan
July 2008
Loadine/,Unloadihs of Hazardous Waste [R31 5-3-2.5ft)(8Xil1
The wastes managed at th+TOCDF and ATUC are described in Attachment 2 (Waste
Analysis Plan). The scrubber brines are pumped from the incinerator scrubber towers to
the brine tanks. The Spent Decon Solution (SDS) is collected in sumps, pumped to the
spent decontamination tanks, and then transferred to the Liquid Incinerator (LIC). The
@ent decontamination solutiongmaybe shipped off site if
the requirements in the Attachment 2 (Waste Analysis Plan) are met.
The munitions and bulk containers are delivered to the TOCDF CHB in overpacks via
transport tnrck. They are unloaded from the transport truck and placed in the CHB. From
the CHB, the munitions are transported by a conveyor to a lift system and then on a
conveyor to the Munitions DemilitarizationBuilding (I\{DB). There they are unloaded in
the Unpack Area (UPA) where processing begins.
particulate removal device. and expen4ed PAS carbon filters and HEPA filters used in the
PAS will be tl
{,'h*sampled and analyzed for asent content per the requirernents in the Attachmsnt 2
(Waste Analysis Planlaremet. Operators handling waste will wear the aoprooriate level
of PPE. All waste is placed in containers that meet or exceeds the requirernents stated in
R315-8-9.3 and R31 5-7-1 6.3.
The following procedures will be followed when transferring residue from the TOCDF
Deactivation Fumace System (DFS) cyclone to the associated receiving container to
minimize fugitive emissions and ensure proper management:
The transfer funnel that is used to connect the cyclone discharge pipe to the receiving
container will be sealed (e.g., via duct tape, etc.) to the receiving container and the cyclone
discharge pipe.
The building that encompasses the DFS cyclone discharge will be kept closed except
when inspecting the receiving container and discharge are\ entering and exiting the
building for operation and maintenance, and moving containers into and out of the
building.
8.2.1.4.1 Waste at the ATLIC such as residue from the Pollution Abatem€nt System OAS)
AttachmentS-Page6
8.2.1 .5.3
8.2.1.5.4
8.2.1 .5.5
8,2.2
8.2.2.1
8.2.4
8,2,4.1
8.2.4.1 .7
TOCDF
Preparedness and Prevention Plan
July 2008
The interior of the building will be monitored for the pressnce of agent prior to opening.
The building shall be ventilated to the MDB ventilation system when the DFS is
operational or when waste is present in the cyclone discharge building.
Unless the Permittee demonstrates that the agent concentration of a sample of the residue
generated from the operation of the DFS Cyclone is below 200 ppb for IIIHDAIT, the
residue must be placed into permitted storage.
Runoff tR3 15-3-2.5ft )(8)fiilI
At TOCDF. rRunofffrom all hazardous waste handling areas to other areas of the facility
or the e,nvironment is prevented by facility design features. Waste handling in the CHB,
MDB, and RHA takes place in enclosed buildings. These measures should minimize the
pote,ntial for precipitation runoff to reach these areas. The waste handling areas of the
CHB and MDB have sumps for collection of spilled hazardous waste. The floor sumps
for all toxic management areas of the MDB have provisions for transferring sump contents
.to spent decontamination tanks (see Section 8.2.6). The other areas have passive sumps,
which are pumped dry when liquids accumulate in them.
8.2.2.1.2 Runoff from all hazardous waste handling areas to other areas of the ATLIC or the
8.2.3
environment is also prevented by facilit), desien features. The handling and transfer of
hazardous waste in the Central Decon System (CDS) and Soerrt Decon System (SDS)
takes place in a secure enclosure. which eliminates storm water exposure. The area where
the Central Decon Systern (CDS) is located is bermed and the floor slopes to a collection
sump that will collect any spills. The collection sump has a sump oumo to remove any
snilled decon from this area. Spent Decon Systern (SDS) sumps are located in the rooms
where equipment and personnel are to be deconned. The floors in these areas are also
sloped to collect spills. The sumps are concrete with a steel pan and protective liner. Leak
detection has been placed between the concrete sump and the steel pan.
Water Supplies [R315-3-2.5ftX8Xiii)l
The processing and storage of all hazardous waste at the TOCDF and ATLIC takes place
in enclosed structures with concrete bases that prevent the downward percolation of
wastes or liquids.
Eouipment and Power Failure [R315-3-2.5ftX8'l(Ml
TOCDF Equinment Failure Control
The process control system at TOCDF is designed and operated to perform shutdown of
the entire facility or a portion of the facility should an equipment failure (or other
emergency) occur. The control room'has a positive-pressure, filtered supply air system
providing protection against toxic fumes that could be emitted during an ernergency. A
detailed description of the centralized control system is provided below.
8.2.3.1
Attachment 8 -Page7
8.2,4.1.2
9.2.4.1 ,3
8,2.4.1.4
8.2.4.1 .5
9.2.4.1 .6
8.2.4.1 .7
TOCDF
Preparedness and Prevention Plan
July 2008
The centralized process control system uses process controllers with functional keyboard
or keyboards for operator interface and control ofthe system as required, control screens
for displays, a printer to print out alarms and messages, and an event recorder or data
logger. This equipment is installed in the Control Room and is defi:red as the Master
Control Station. Contained in the process controller are the programs for each type of
munition demilitarization machine throughout the facility and process-supporting
facilities, such as utilities. An operator can remove a unit or piece of equipment from
automatic control and control it manuallythrcugh the keyboard on the console. The
control system is designed as a fail-safe system. All local controllers communicate with
the central control on a real-time basis. Should this communication link become inactive
(presumably from a failure in the central control), the local controls automatically shut
down to a safe mode. The communication system described previously is a redtrndant
system to reduce the likelihood of this occtrring as a result of a failure in the
communications link.
Initialization of the control system is necessary before munitions processing can begin.
The initialization procedure resides within the process controller; the actual initialization is
a semiautomatic operation. When the initialization has been successfully completed, the
operator is notified via the control screen, which indicates that all permissives have been
received and the system is now ready to process that type of munition. Any problems that
may arise during the initialization are displayed on the control screen of the appropriate
control room work station.
Before processing munitions, each system is pre-checked by a test program from within
the process controller.
After initializationand performance verification, a second level of perforrnance
verification is conducted by the process controller; this verifies the presence ofany
shutdowns and any permissive interlocks. Having met all performance verification
checks, a message appears on the control scresrl and printer that the munitions processing
equipment, as viewed by the process controller, is ready for operation.
After start of the system has been initiated, automatic operation follows, as long as all
individual steps occur within their predetermined parameters and no shutdown signals
occur. If a step or function does not occur within its predetermined parameters, a message
appears on the control screen and on the printer; the operator shall take corrective action.
Shutdown requests and interlocks are monitored. Where possible, applicable pre-alarms
or indications that a shutdown condition is imminent are used. This gives the operator
time to prevent a shutdown or to be prepared for it. Interlocks are developed to respond to
various conditions in a manner applicable to the condition and equipment. As an
example, some shutdowns are immediate, others are orderly. The system logs conditions,
such as starting and stopping of equipment.
In addition to the process control system, equipment such as furnaces, boilers, and airlock
doors in the UPA and each load station have a local control panel that offers limited
control. Local control panels offer the capability of operating in conjunction with the
Master Control System or independently for maintenance purposes. Areas such as the
UPA or incinerator require a semiautomatic operation, either during normal operation or
8.2.4.1 .8
Attachment8-Page8
h. TOCDF
Preparedness and Prevention Plan
July 2008
startup. In the semiautomatic mode of operation, the Master Control Slatem rnay start a
unit and wait for the next step to be initiated and controlled by an operator before
proceeding to the next logic control step.
8.2.4.1.9 ATLIC Equioment Failure Control
8.2.4.1.9.1 The Facility Control Systan (FCS) at ATLIC is desiened to safely and gfficiently monitor
and control the process systems. process support systems. and control systsms that are
located within the facility. The FCS is composed of microprocessor-based electronic
controllers and Human Machine Interfaces (fIMIs) with the orimary function of assistine
operations oersonnel in the safe startuo. monitoring. control. data logging, alarming. and
planned shutdown of the fasility.
8.2.4.1.9.2 The FCS is configured to orovide system graohic een€ration. control confisuration. data
collection. data storage. report gsneration. and prosranuninq. The FCS has grinters for
alarm and reoorting pumoses. These printers,are connected to the FCS control network
directly or via print servers or computers: they are located in the Control Center
Equioment Enclosure (CCEE). The FCS has a firewall to Brotect the integrity of the FCS
network.
8.2.4.1.9.3 Olreration of the FCS is conducted from a CCEE in proximity to the ATLIC. There are
three individual control consoles for Ooerations nersonnel. Each console houses a FCS
operator workstation (OWS) consisting of two (2) LCD screens and any other equipment
necessary to oerform automatic or manual control and monitorinq tasks.
8.2.4.1.9.4 The Burner Manage,nrent System (BMS) has a flame safety shutdown s],stem GSSS). The
BMS interfaces with the furnace control PLC to ensure the safety of all furnace purge.
burner light-off. and bumer operations. Control is maintained through fuel and waste feed
block valves. nilot valves. and the burner igniters. The BMS provides control signals to
the-Prograrnmable Logic Controller OLC).for operation of the fuel control valves and
monitors the combustion air blower operation fuel and combustion air control valves. and
combustion air flow to veriffthey are operational for safe combustion. The BMS locks
out the bumers and signals the PLC to stop related equipment if any safety interlock is
violated. Activation of a reset by an op€rator is required to restore burner oneration
followinga BMS lock-out of the burners.
8.2.4.1.9.5 A purge blpass switch is orovided that allows the ooerator to b)ryass the purge cycle for
relight of a burner when the temperature of the specific chamber is above 1400'F. It also
allows blDass of the flame suoervision system for a burner located in a chamber where the
temperature input to the purge blpass switch.
,' i'
8.2.4.1.9.6 Control of all LIC eouioment is orovided throush the local control s$!em (LCS). All
motors have a Hand-Off-Auto (HOA) or Local-Off-Remote (.LOR) Hand Station (HS) and
emergency stoo (E-stoo) pushbutton located near the motor. Each HS station is connected
to a microprocessor-based motor controller that monitors motor current. controls starting
and stopping of the motor it is connected to. and relays all hand station activity and motor
status (jncludins motor ourrent) to the plant control system.
Attachment8-Page9
TOCDF
Preparedness and Prevention Plan
July 2008
8.2.4.1.9.7 All safety-related lnLuVOutput (UO) connects directly to the BMS. The BMS has
complete control over the flame safety systerns of the LIC. Flame safety data isi' ' ' ' communicated from the BMS to the control room operator (CON-OP). Control
commands from the CON-OP and stop-feed commands are communicated to the BMS. A
waste feed interlock is also hard-wired from the LCS directly to the BMS panel. An E-
stop on the CON-OP console is hard-wired directly to the BMS.
8.2.4.2 Incineration Unset Control
At TOCDF. a A control systemprovides continuous automatic control of the incineration
process. System interaction by the operator is limited to startup or shutdown of process
systems or waste feed and reaction to abnormal conditions. In monitoring critical
functions, the process control system gives advanced waming of alarms where possible,
indicating that a critical or hazardous condition is developing and warning operators in
time to take action. Interlocks are provided to respond to various conditions. Shutdown
can be immediate or staged.
All incineratorsjncludins the ATLIC. have automatic waste feed cutoff systems as
specified in Attachment 19 (Instrumentation and Waste Feed Cut-Off Tables).
8.2.4.2.1
8J+l-38.2.4.2.2.1.2 At the ATLIC. waste feed to the primary chamber may be stopped by the CON-
OP as either a "normal" ramped secgssion of feed or an anersencv shutdown of the LIC
s],stem by actuating the ernergencv stoo (E-stop) button in the control room (CON E-stop).
The CON E-stop shuts down the primary and secondary chamber bumers. stops the
combustion air blower. drives all valves to their safe position. stops primary waste feed.
and stops SDS feed. The Wench brine pump and ID fan remain running. An outside
operator can initiate an emereency shutdown of the LIC system by acfuatingthe E-stop on
the BMS panel. The BMS E-stop shuts down the orimary and secondary chamber
bumers. stops primary waste feed. stops SDS feed. and shuts down the fuel gas supply to
the fumace.
8.2.4.2,2.1 .l
8.2.4.3
8.2.4.3.1
8.2.5
8.2.s.1
Emersency Power
The emergency power systems are described in Attachment 9 (Contingency Plan).
Personnel Protection Eouipment [R315-3-2.5(bX8Xv)l
Various levels of protective clothing are required at the faeilit#aqililier to protect workers
from the effects of the agent in the work environment. The type of protective clothing
wom by the workers is based on the level of protection required by the location, the
process, and the tlpe of agent. Selection of proper PPE is addressed in Attachment 9
(Contingency Plan).
Spent Decontamination Collection Svstem [R315-3-2.5(b'l(8Xiii)l8.2.6
Attachment 8 - Page l0
8.2.6.1
8,2.6.2
8.2.7.2
*
TOCDF
Preparedness and Prevention Plan
July 2008
At TOCDF. Ipall category A and B areas, as well as in some category C areas, spent
decontamination surrps and pumps are designated and provided to collect any liquid from
that area and pump it to one of the SDS storage tanks in the Toxic Cubicle (TOX).
AII primary sumps *" "o.rrt*"ted of steel and surrounded by an epoxy coated external
concrete liner. Secondary sumps are consiructed of epoxy-coated concrete. The
compatibility of materials has been considered when designing these sumps. There are no
incompatibility problems with the selected materials and anticipated decontamination
solutions or other such wastes. Attachment 16 (Tank Systems) contains a detailed
description of the TOCDF sump system.
8.2.6.3 At ATLIC. the SDS system starts at the collection points. There are sumps and oumos in
the Entry Airlock "A". Entry Airlock "B". LIC Room. TOX Room. and a sump pan in
each glovebox. Each area's floor is sloped. and SDS is collected in a below-srade sump.
The sumps are constructed of concrete and have a steel pan placed within the concrete
sump. The steel pan is lined with a protective liner compatible with the materials that are
in the area. Leak detection is provided between the concrete sump and the steel pan.
Information from the detector is sent to the control room to noti$ operators of any
problems. If liquid is detected. the CON-OP will have the ability to activate and direct the
sump content to the SDS collection tank. The collection points in the gloveboxes have
collection pans: these pans are an integral part ofthe gloveboxes and are oiped and
drained to the SDS collection tank. In the case of the TOX sump. the contents can be
directed to the SDS collection tank or to the Major Spill tank. both located in the TOX.
8.2.6.4 The Major Spill tank is provided as a storage point should a major spill occur. The tank is
desiened to handle a "worst case" spill of the largest tank within the TOX (1000 eallons).
This tank allows soilled liouids to be removed from the room in an efficient
dgcreasing the likelihood of saturating the filters under a Major Spill condition.
8.2.6.5 The SDS collection tank has a recirculation and sampline pipine loop that allows for
continuous recirculation of the contents within the tanks as well as providine for a
sampline point to remove SDS sample for testing. The Major Spill tank can be sampled
and directed via a manually installed hose to any of the storage svstems within the TOX
room utilizine that system's recirculation and samoling oiping loop.
8.2.6.6 The area around the eloveboxes in the Processing Area is surrounded by a berm to provide
containment if a leak occurs.
8.2.7 Aeent Monitorine Equipment [R315-3-2.5ftX8Xvi)l
Chemical agents are routinely managed at TOCDF and ATLIC. The safe operation of
these faciliti$y requires that personnel be protected from accidental or inadvertent
exposure to these agents. The ventilation systems -minimizes worker exposure to agents.
To supplement the ventilation system, an agent monitoring system is provided to alert
facility personnel to the presence of agents.
The agent monitoring equipment at TOCDF includes the Automatic Continuous Air
Monitoring System (ACAMS) and the Depot Area Air Monitoring System (DAAMS). In
addition to ACAMS and DAAMS. monitoring equipment at the ATLIC includes
8.2.7.1
Attachment8-Pagell
8.2.7.3
8.3
8.3.1
8.3.1.1
8.3.1.2
9.3. 1 .3
8.3.1 .4
8.3. 1 .5
TOCDF
Preparedness and Prevention Plan
July 2008
MIMCAMS. Attachmentg 22 and2ZA(Agent Monitoring Plan) provides more
information on each system, including a general description of the system, its theory of
operation, and its sensitivity and response time.
In addition to the agent monitoring equipment, detector paper may be used as a
confirmatory test for identifying G series, VX, and H series agents in suspect liquids. This
paper does not detect vapors or extremely small droplets of $!!fuggjgg, VX, or mustard
agents and may change color in the presence of other chernicals.r
PREYENTION OF IGNITION OR REACTION OF IGNITABLE. REACTTVE. OR
INCOMPATIBLE WASTE
Precautions to Prevent Ienition or Reaction of Ienitable or Reactive Waste [R315-3-
2.5ft)(9) and R3 15-8-2.8(a)-(c)l
Ignitable waste at the facility includes waste generated at the Chemical Assessment
Laboratory (CAL) and subsequently stored in the S-2 warehouse and Igloos 1632 and
1633. No sources of ignition will be allowed in the S-2 warehouse and Igloos 1632 and
1633 when ignitable items are stored. Potential sources of ignition to be prohibited
include: open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks
(static, electrical, or mechanical), spontaneous ignition (e.g., from heat producing
chemical reactions), and radiant heat. "No Smoking" signs will be placed at the entrances
to the S-2 warehouse and Igloos 1632 ard1633.
No treatment of wastes within the containers in the S-2 warehouse and Igloos 1632 ard
1633 will occur (i.e., S-2 warehouse and the igloos will be used for storage only). This
fact, coupled with the procedures identified in paragraph 8.3.4 regarding managernent of
incompatible waste and the procedures identified above regarding the management of
ignitable, will prevent the types of reactions described in R315-8-2.8(b).
Reactive wastes at the TOCDF facility include chernical agents by EPA characterization,
explosives, propellants, and certain active ingredients in the fuzes. No precautions are
taken by the facility to protect reactive wastes from contact with the water from the
automatic sprinkler system. The explosives, propellants, and fuze components were
originally produced in a water solution, are compatible with water, and dissolution in
water reduces the reactivityhazard of these components, so no special precautions are
necessary to prevent contact with water.
The demilitarizationprocess and operations in the MDB are designed to prevent
accidental ignition or reaction of agent, explosives, and propellants. The entire building is
a designated non-smoking area. During munition processing, all equipment is grounded to
prevent the transfer of electrostatic charges to the munitions.
Handling procedures have been incorporated into the transportation and plant operation
procedures to apprise personnel of the importance of handling the munitions and bulk
tArmy Regulation 50-6, Nuclear and Chemical Weapons and Material, "Chemical Surety
Program," Headquarters, Department of the Army, Washington, D.C., 15 January 1984.
Attachment 8 -Page 12
8.3. I .6,
8.3. 1 .7
8.3. 1 .8
8.3. 1 .9
8.3. 1 . 10
TOCDF
Preparedness and Prevention Plan
July 2008
containe?s. Conveyors and charge cars are used totransport munitions and their
components witlin the MDB. The conveyor incorporates stops, interlocks, and guard rails
that prevent the munitions and components from falling.
The facility is protected from fires and explosions potentially caused by functioning
munitions, electrical shorts, fuel leaks, overheated equipment, or miscellaneous equipment
and operator failures by a fire protection system designed to meet the special needs of the
plant areas. The fire protection system for the MDB includes: (1) automatic fire detectors
throughout the building (smokq, thermal, and photoelectric tlpes); (2) manual fire alarm
pull stations at exit points from the various hazard areas of the building; (3) fire protection
water; (4) an automatic sprinkler system for the IJPA; (5) automatic total flooding Halon
systems to protect the Control Room, Control Room Support Area, and Power Room; (6)
automatic total-flooding FM-200/FE-227 for the UPS and Battery Enclosures; and (7)
portable fire extinguishers located throughout the building (except in category A and B
areas). A detailed description of the building fire protection system is provided in
Attachment 9 (Contingency Plan).
The explosive components of munitions are removed by the projectile/mortar disassembly
machine in the Explosive Containment Rooms (ECRs). There is also a burster size
reduction machine in the containment room when projectiles are being processed. The
containment rooms feature reinforced concrete enclosures designed to totally contain the
effects of an accidental explosion. These areas are unmanned during normal operations.
The probability of an explosion occurring in the DFS is low. The system is designed,
however, so that the effects of an explosion within the incinerator are minimized, and the
system's barrier (room) is designed to contain the explosive effects of an explosion in the
system (similar to the ECRs). Material entrance to the retort is accomplished via the blast
gate valve, which isolates the retort in case of an explosion. Again, this normally is an
unmanned area.
The agent in the munitions is removed by the Multipurpose Demilitarization Machine
(MDM) or the Bulk Drain Station (BDS). These areas are protective clothing areas and
normally are unmanned during processing operations. The probability of reaction of the
agents is low because of the contained design of the drain stations and the compatibility of
the materials in the plant. If a reaction of agents occurs, the system has been designed to
contain all gases.
An incident or accident involving an explosion is regarded as a serious event. If such an
event should occur, processing of munitions will be safely halted and the plant will be shut
down at a point where the munitions are secured. Startup shall not occur until the cause of
the explosion is determined, a corrective action is implemented as necessary, and
Executive Secretary approval is received.
Detonations are not a planned technique for chemical demilitarization. A detonation will
be handled by preplanned response in the contingency plan and the installation's Chemical
Accident/lncident Response and Assistance Plan (CAIRA Plan).
The definition of major detonation includes personnel injuries. The TOCDF regards any
incident that results in any personnel injury from handling munitions as unacceptable,
8.3.1.1I
8.3. r.12
Attachment 8 - Page 13
8.3.1.13
8.3. | .14
8.3. 1 .l 5
8.3.1.16
8.3. | .17
8.3.1 .18
8.3.1.19
TOCDF
Preparedness and Prevention Plan
July 2008
requiring coffective action. The occurrence of any detonation in the course of
denrilitarization of chemical munitions is unacceptable and requires corrective action.
The possibility of a death from a detonation is included in the definition of a rnajor
detonation, and operating procedures are designed to minimize this possibility.
Both fire fighting and evacuation are possible options in an emergency situation. If the
fire involves explosive materials or is supplying heat to explosives, or if the fire is so large
that it cannot be extinguished with the equipment at hand, the personnel involved shall
evacuate and seek safety.
The fire protection system does provide protection against and immediate response for a
situation involving fire inside the building. The fire protection system will provide
protection by extinguishing a Class A fire involving dururage in the UPA. The fire
protection system will provide protection against the spread of a fire to a pallet of
munitions in the UPA and allow time for operators in the UPA to evacuate the area. The
fire protection system will provide cooling and a degree of protection to munitions in the
ECV and ECR from a fire that gets started away from the munitions. While the fire
protection system does not provide a primary defense against a detonation of a munition,
the system in connection with the blast resistant structure of the ECR and the
compartmentalization of the ECV, UPA, Control Room, and incinerators does provide
protection against the spread of fire from an explosive accident.
By design, the only fires allowed inside of the MDB are to be contained within the
fumaces. A fre in any other part of the plant is regarded as a serious event requiring
immediate attention and corrective action. Because a fire that exposes energetic materials
in the munitions can cause an explosion and/or rapid spreading of the frre, no distinction is
to be made between "small" fires, "smoldering" fires, "large" fires, "dunnage" fires, or
"explosives" fires. All fires inside the building are to be reported immediately and
corrective action instituted immediately.
Since any fire inside the building will consume oxygen and generate gases that cannot
support life within a given enclosed space, it is imperative that the presence of a fire be
communicated rapidly and traffic into an affected area be restricted to only those
personnel prepared to fight a fire safely. Again, no distinction is to be made between
"small" or "large" fires, or the tlpe of fire. Immediate response to communicate the
presence of a fire and immediate corrective action is mandatory.
The ECR and the associated equipment are designed to be operated remotely, unattended
by operators. In the normal course of events, there will be no personnel inside the ECR
while munitions are present.
When repairs must be performed near explosively configured munitions or munition jam-
ups, the demilitarization process will be stopped and adequately protected personnel may
manually remove the munition(s) from the work area. The munitions can be moved to the
UPA, ECV, or the First Floor Buffer Storage Area (BSA) until startup procedures can be
initiated. With the explosively configured munitions removed from the work area,
maintenance personnel can work on process equipment without the possibility of
accidental munition detonation.
Attachment 8 - Page l4
8.3.1.20
8.3. | .21
8.3. L22
9.3.1.23
8.3. r .24
8.3. | .2s
8.3.1.26
TOCDF
Preparedness and Prevention Plan
July 2008
If an explosion occurs in a containment roorn, it is expected that a portion of the agent will
be combusted while the remainder will exist in a vapor or liquid form. In the ECR, the
agent vapors will be contained in the room because both the blast valves and the leak-tight
dampers will be closed. The blast valves will remain closed until the pressure decays to
the point where the spring force is greater than the room pressure (0.5 psi). At this
pressure, the blast valve will open, but the leak-tight damper will continue to contain the
gases. The leak tight dampers will not be opened until the room gas pressure has decayed
to approximately atmospheric pressure
High gas pressure in the DFS kiln will be vented through an attenuation duct, then through
the afterbumer and @AS). The attenuation duct will reduce
the gas pressures resulting from shocks so that an explosion will not violate the structural
integrity of the afterburner or the PAS.
The ECRs were designed to have a leakage rate of no greater than 300 cubic feet per
minute. The ECR is completely surrounded by rooms that are ventilated to the filter
system. Therefore, any leakage out of the ECR as a result of a blast will be vented to the
filter system
Liquid agent in the ECR resulting from an explosion will be collected in the ECR sump.
Because of the limited number of munitions that will be in the ECR at any one time, the
amount of liquid agent released by an explosion is not expected to be greater than about
two gallons. Once ventilation has been reestablished in the ECR (by reopening the gas
tight valves), Demilitarization Protective Ensernble (DPE) entries will be made and the
area will be hosed down with decontamination solutions. Sufficient decontamination
solution will be used to ensure complete neutralization of the agent. The resulting waste
liquids will then be pumped to the spent decontamination holding tank system for later
incineration in one of the two LICs. The GB sodium hydroxide-based spent
decontamination solution may be shipped off site if the requirements of Attachment 2
(Waste Analysis Plan) are met.
There is a remote possibility of a detonation in the DFS. This possibility is minimized by
conholling the DFS retort temperature below a point where the explosive components
would be expected to detonate. The possibility of a detonation is further reduced by
spacing energetics on the feed conveyors and separating materials inside the retort by
spiral flights, so that a detonation on one flight cannot propagate to other flights and cause
a sympathetic detonation.
The possibility of a detonation is further minimized by shearing bursters into pieces, open
at both ends, so that combustion initiates at both ends of a cylindrically shaped burster and
there is no net force to cause acceleration of a work piece in any axial direction. Bursters
from large projectiles (155-mm) are sheared into pieces to increase the surface area
available for combustion and to reduce the size of the pieces so that combustion does not
auto accelerate to a detonation (i.e., the fuel burns itself out before a supersonic pressure
wave in the burning fuel can be established).
The energetic materials, because of their chernical composition, are expected to generate
heat (2,000 to 4,000 Btdlb) and evolve gases (CO, CO2, H2O, NO, NO2, N2) rapidly, ao
Attachment 8 - Page l5
9.3. I .27
8.3.1.28
8.3. | .29
8.3.1.30
8.3.1 .3 I
8.3.1.32
TOCDF
Preparedness and Prevention Plan
July 2008
process generally described as deflagration. This rate is designed into the size of the
retort, ductwork, and induced draft fan so that it can be controlled safely and effectively.
This design concept has been proven effective in fumaces buming explosives and
propellants from conventional munitions in several places across the country.
If a detonation should occur in the DFS, the operation of the afterburner will be protected
by the Blast Attenuation Duct in the ductwork between the retort and the cyclone, and
secondarily by the cyclone separator. Discharge of combustion gases from the heated
discharge conveyor is prevented by two blast gates in series at the discharge end of the
heated conveyor. Fugitive emissions from the retort seals will be controlled by capturing
the emissions inside a shroud srurounding the retort and recycling the emitted gases back
into the retort or exhausting the gases to the ventilation filter system before they are
discharged to the atmosphere. The room surrounding the DFS retort is a blast resistant
structure and is separately vented to the ventilation filter system to control any vapors from
inside of the building.
These controls of feed rate, feed preparation, operating parameter controls, and design to
control fugitive emissions from the DFS are adequate to safely manage chemical
munitions in the TOCDF.
If the DFS should shut down, the interlocking system managed by the computer control
system will simultaneously stop the processing of munitions in the ECR. Feed to the ECR
will stop, and the transfer of munitions to the ECV and UPA will stop until the furnace
can be restarted. This will preclude a buildup of munitions components at the retort entry.
The feed chutes will continue to be monitored for a high temperature and water will be
sprayed into the feed chute to cool the chute and any pieces that are present in the feed
chute to prevent an explosion.
The ECR area ventilation category will remain at Category A once the blast valves and the
leak t1,pe valves are opened after a detonation. The area surrounding the ECR will also
rernain at category A. Before any entries are allowed in the ECR after a detonation occurs,
the room air will be monitored to determine the agent concentration.
The DFS ventilation category will remain at category B because no agent will be present
other than what is expected. The room air will be monitored to determine the agent
concentration before any entries will be allowed in the DFS after a detonation occurs.
The Burster Size Reduction Machine (BSRM) receives projectile bu.rt"r, from the
Burster Removal Station (BRS) of the ProjectileilVlortar Disassembly Machine (PMD).
The burster is conveyed by the BRS gripper to the BSRM feed chute. Bursters are fed
into a special die that is designed to hold the burster in place during the shear blade cycle.
Except for bursters from 4.2-inch mortars, which are open on one end, the burster is
sheared to preclude an explosion during buming and drops into the DFS feed chute. The
machines for burster shearing are limited in the amount of force that can be applied and
the speed at which they move to preclude application of a shock load of sufficient energy
to initiate the energetic materials in the burster. The operation is conducted within an area
of the plant designed to contain the explosive effects of a detonation if this remote
possibility occurs.
Attachment8-Page16
/
9.3.1.33
9.3. I .34
8.3.1 .35
8.3. r .36
8.3.1 .36. 1
8.3. I .36.2
8.3. r .37
TOCDF
Preparedness and Prevention Plan
July 2008
The blast loads that must be contained are shock waves, quasistatic gas pressure and
primary and secondary fragments. The shock waves are short duration, high pressures that
range up to approximately 900 psig. The quasistatic gas pressure caused by the heating of
the gas as a result of combustion will reach as high as 26 psig. The fragments will be
generated by the munition casing. The ECR is designed with blast shields used to cover
and protect the piping and electrical penetrations. If exposed agent piping is in the direct
line of sight of the blast, the piping could be damaged by either the shock or the
fragments. But, if the agent piping is behind the blast shield, it will be protected from
damage. This shock pressure does not translate directly into hydraulic pressure because of
its duration. Also, the shock pressure indicated above does not take into account the
equipment and structure in the ECR. The equipment and structure will absorb part of the
energy from this detonation, resulting in greatly reduced shock pressures. It is expected
that the hydraulic pressure in the agent pipe will not exceed the design pressure for that
pipe. The quasistatic pressure does translate into hydraulic pressure, but the hydraulic
pressure will not exceed the design pressure of the pipe. Fragments will have no effect on
agent piping outside of the ECR. To provide additional assurance that explosions will not
damage the agent lines outside of the ECR, quick response valves were installed in the
agent lines after the lines exit the ECR. The response time of these valves is between 50
ard75 milliseconds. Based on this discussion, rupture of the agent piping outside of the
ECR is not expected. Also, it should be noted that all agent piping outside of the ECR
that carries agent runs only through ventilation category A areas where the facility was
designed to handle spilled agent.
The lower blast gates in the feed chutes to the DFS retort are driven by double acting
pneumatic cylinders. Proximity switches that sense the position of the cylinder in the open
or closed positions are located at each end of travel of the cylinders. These are labeled
ZS-01A, ZS-018, ZS-02A, afiZS-028. If a blast gate is to be closed but the position
switches do not confirm that the blast gate is closed, the interlock will open and an alarm
will be given to the operators that the blast gate did not close. This would be the first
indication that a piece is caught in the blast gate guides. Confirmation of this is available
with the jam sensors XS-207, XS-208, XS-209, or XS-210.
There are two temperature sensors located in each feed chute TE-150, TE-202, TE-154,
and TE-203 that will alarm if a high temperature condition is reached in this area between
the blast gates. A high temperature would cause water to be sprayed into this area to cool
the chute and work pieces in the chute.
The safety features built into this system are:
The blast gates move slowly so that should the gate impact a fize or burster piece there is
not enough kinetic energy transferred to cause detonation.
The high temperature switches are set below the temperature at'which the energetic
materials would start to deflagrate. Tlpically this temperature is above 200' C (392" F).
Since the operational steps of the blast gates are event driven, the program will not allow
the operation to advance to the next step until the current step has been completed. In the
case of the blast gates, before each cycle step can proceed, feedback from the limit
switches on the gates must be received at the Programmable Logic Controller @LC). The
Attachment 8 -Page 17
9.3. I .3 8
8.3.1.39
8.3. | .40
8.3.l.4l
8.3. | .42
8.3. | .43
8.3.1.44
8.3.1.45
8.3. I .46
TOCDF
Preparedness and Prevention Plan
July 2008
PLC not only looks at the current state of the limit switch, it also verifies that the
switching takes place in the proper sequence. If this signal is not receivd, m alarm is
received in the control room and the ECR operations are halted.
The blast gates that feed the DFS from the ECR are designed to prevent the propagation of
the blast effects from the area where any blast occurred by ensuring that at least one blast
gate between these areas is closed at any time. At certain times during explosive feed to
the DFS, theie may be a burster and small amounts of agent between two gates that are
closed. Effects bf a detonation during this time are expected to be minimal because both
gates are designed to withstand a blast of this magnitude.
Agent vapors evolving in the ECR are removed to the filter systern and vapors evolving in
the DFS will be incinerated in the furnace or will be removed by the room filter system.
When the blast gates in the ECR do not close completely, operations within the ECR are
automatically halted.
A detonation in the retort would be sensed by pressure sensors/transmitters at the
discharge end of the retort, PIT-I8, and in the exhaust duct, PIT-I68. The retort is
fabricated with a spiral flight which separates the solid materials into discrete segments. If
a detonation should occur in one segment, the flight will inhibit propagation to adjacent
segments, limiting the amount of material that explosively combusts. If a detonation
should occur that causes a severe overpressure, feed to the retort would be stopped
immediately, munitions processing upstream of the DFS would be stopped, the retort
burner would be shut down, and the retort oscillated to allow the inventory of material in
the retort to burn out. Any vented air is treated in the carbon filters to control vapor
emissions from the plant before being released to the atmosphere.
The DFS barrier and ducts exiting the barriers have been designed to withstand
detonations. In the unlikely event that there is an explosion, that detonation will have very
little effect on the afterburner. The shock wave from the rotary kiln would have to travel
through ducting that will dissipate the energy to prevent stress until it exits the building.
Once the duct leaves the building, it enters an attenuation duct that will significantly lower
the shock pressure. From the attenuation duct, the duct runs to the cyclone, then to the
afterburner. At this point, the blast pressures have decayed to barely noticeable levels that
would not affect the afterburner operation or cause afterburner flameout.
If a blast is detected, the Deactivation Furnace System afterbumer will be shut down in an
orderly manner and the room air will be diverted to the filter system. The hazard analysis
addressed the concem of reaching an explosive level as a result of combustibles in the
Deactivation Fumace System barrier and it was concluded that this level would not be
reached with the designed air flows in that room.
Reserved
Reserved
Reserved
AttachmentS-Page 18
8.3.1.47
8.3. 1 .48
8.3. I .49
8.3. 1 .50
9.3. 1 .5 1
8.3. I .s2
TOCDF
Preparedness and Prevention Plan
July 2008
The burster well in projectiles is a metal tube that contains the burster. When the
projectiles are being demilitarized, the fuze, booster, and burster are removed from the
projectiles remotely in the ECR. The burster is removed from the burster well by applylng
air pressure to the back of the burster and pneumatically forcing the burster out of the
well. A clamp, specially designed to limit clamping pressure, grabs one end of the burster
and withdraws it from the well. Bursters are conveyed to the BSRM feed chute by the
BRS gripper. At no time at this step of the process is the burster well clamped or held
from the outside, so there is no possibility of crimping the burster well with the burster
inside of the well. If, for some reason, the burster cannot be removed from the well, the
projectile is not processed further, but is rejected and loaded onto a tray specifically
designated for rejected projectiles and is set aside for special handling.
After the explosive components are removed from the projectile, the empty burster well is
removed from the projectile, crimped, and placed back in the projectile. The crimping
machine has been designed to deform an empty, thin wall cylinder that requires a low
hydraulic pressure.
If an accident should occur during the course of demilitarizing projectiles, the size of the
event is strictly limited to the number of projectiles inside the ECR at any time. If an
accident should occur, the event will be contained within the ECR and cleanup would be
implemented as described previously.
The force used to remove trzes f.om irojectiles is insufficient to cause an explosion. The
fuze removal operaiion is used for the M8 fuze on 4.2 mortars. This operation is done
under undue force conditions which, by definition, are less than a force required to deform
the explosives either in the fuze or in the bursters. The burster material of the mortars is
tetryl.
There is a finite, albeit small, probability that the burster well may have been thoroughly
corroded by the combined action of chemical agent on the outside of the burster well and
the cast solid explosive on the inside of the burster well. In the course of storing and
managing chemical weapons over the past 60 years and demilitarizing projectiles at the
Chemical Agent Munitions Disposal System (CAMDS) plant since l979,the Army has
not had any indication that the possibility of burster well corrosion is a significant concem.
If a corroded burster well is uncovered by fuze and burster removal, 1 1 .7 lb of mustard
agent from a 155mm projectile or 6.0 lb of agent HD/HT from the 4.2 inch mortar
projectile is possible inside of the ECR. The leak would be contained within the ECR.
Any evolved vapor would be carried by the ventilation air to the carbon filters where the
vapor would be absorbed onto carbon. The ventilation filter system has been designed to
safely treat the air swept over a spill covering 96 square meters continuously for 449
hours. The filter system can safely lrandle the evolved vapors until the ECR can be
emptied of munitions and the spill treated with decontamination solution.
:
After the burster is removed from a leaking projectile or the burster and propellant are
removed from a leaking mortar cartridge, the burster well is removed, the agent is
. removed by pumping out the cavity of the projectile, the burster well is crimped to prevent
a tight reseal, and the projectile body and burster well are loaded onto a tray to be treated
in the Metal Parts Fumace (MPF). The agent is pumped to the agent storage tanks in the
8.3. 1 .53
Attachrnent 8 - Page 19
8.3.1.54
8.3. 1 .55
8.3.2
8.3.2,1
8.3.3
8.3.3. 1
8.3.4
8.3.4. I
8.3.2.2 Durine Lewisite operations at the ATLIC. the Nitric Acid Feed System (NFS) provides
the facility with safe and effrcient required storage and distribution of nitric acid. The acid
storaee enclosure houses the nitric acid supply barrels. The area will bermed and adequate
ventilation will be orovided for the enclosure.
TOCDF
Preparedness and Prevention Plan
July 2008
TOX and is incinerated in one of the two LICs. After treatment in the MPF at a
temperature and time sufficient to destroy any remaining agent contamination, the metal
that remains will be managed in accordance with Attachment 2 (Waste Analysis Plan).
Reserved
It is the basic requirement that the M8 fuzes have two independent interlocks that are
always tumed to a safe position and the fuze train is intemrpted. Either of these interlocks
is capable of preventing an unintended detonation before the ammunition is projected. An
explosive train develops a detonation by progression of the reaction from an explosive of
greater sensitivity but minimal quantity, to the explosives of least sensitivity (bursters).
Without this train of explosives, a high yield detonation cannot be achieved. The interlock
devices intemrpt the explosive train so that should an explosive function occur on the side
of the device (i.e., thermal initiation in a furnace), the explosives on the other side of the
device will not be affected.
General Precautions for Handlins Ignitable or Reactive Wastes or Accidentlv
Mixins Incomnatible Wastes tR315-3-2.5ftX9) and Ri15-8-2.8ft)
General precautions for handling ignitable and reactive waste are discussed above. With
the exception of the wastes stored in the S-2 warehouse and Igloos 1632 and 1633, none
of the hazardous wastes are ignitable or potentially incompatible. Procedures which
preVent mixing of incompatible wastes in the S-2 warehouse and Igloos 1632 ard 1633 are
provided in section 8.3.4.
Manasement of Ienitable or Reactive Wastes in Containers [R315-3-2.6(c) and
R315-8-9.71
The containers of agent, explosives, and propellants are not ignitable and are managed so
that water contact is minimized. This same practice is adhered to if other wastes, such as
the incinerator ash or residue, are found to be reactive because ofthe presence ofsulfides
or inorganic fluorides. All containers holding reactive or ignitable wastes will be located at
least 50 feet from the facility property line.
Manasement of Incompatible Wastes in Containers [R315-3-2.6(d) and R315-8-
9.8(a)(2)l
No incompatible hazbrdous waste at TOCDF shall be managed at the CHB. Munitions
and bulk coritainers with only one agent tlpe may be processed at one time.
8.3.4.1.1 GA and Lewisite will not be processed simultaneously by the ATLIC.
AttachmentS-Page20
8.3.4.2
TOCDF
Preparedness and Prevention Plan
July 2008
Containers with incompatible site-generated wastes shall not be placed on a secondary
contafument pallet in the S-2 warehouse at TOCDF or Igloos 1632 and 1633 at the same
time. Therefore, incompatible wastes, or incompatible wastes and materials shall not be
placed in the same container or on the same secondary containment pallet.
The acid storase enclosure at ATLIC will house the nitric acid suoolv barrels. The area
will bermed and adequate ventilation will be provided for the enclosure.
8.3.5
8.3.5. 1
8.3.6
8.3.6. 1
Manaeement of Isnitable or Reactive Wastes in Tanks [R315-3-2.7 [40 CFR
270.16(fl1 and RI15-8-10 1264.198(a)(2)ll
Agent, brine, and spent decontamination solutions have flash points that classiff them as
Class IIIB liquids in accordance with the National Fire Protection Association. These are
not unstable, ignitable or reactive liquids, as defined by the National Fire Protection
Association (I.[FPA). The storage tanks are in fuIl compliance with the NFPA
requirements. The agent collection and spent decontamination tanks are located in the
TOX and Spent Decontamination System Room, respectively. These areas are provided
with trenches and sumps that provide containment in excess of the largest tank capacity.
The spacing between tanks is in excess of three feet.
Manaeement of Incomnatible Waste in Tanks [R315-3-2.7 [40 CFR 270.16(fl1 and
RI15-8-10 t264.199ft)lt
The design of thclIOCpF allows for brines from the PAS to go to the brine surge tanks
in the BRA, spent decontamination solutions and miscellaneous liquid wastes from the
sumps to go to the spent decontamination tanks, and agent from the process machines and
miscellaneous liquids to go to the agent collection tanks. All pollution abatement system
brines from all of the furnaces, whether processing GB, VX, or mustard, are compatible.
Different agents are not processed together in the ACS tanks and when changing from one
agent to another, the agent collection tanks are thoroughly decontaminated to less than 20
ppb.
8.3.6.2 The Scrubber Liquor Blowdown at the ATLIC will be directed to three 90-dav storage
Receivinq Tanks. These storage tanks are sized to allow suffici€'nt storage for continuous
processine operations. SBent d€contamination solutions and miscellaneous liquid wastes
from the sumos eo to the spent decontamination tanks iq the Toxic Area. Different aeents
are not processed together in the LCS tank. The GA aeent will be drained and fed directly
to the LIC. Asent front Lewisite tons will be drained and collected in the Lewisite
collection tank located in the Toxic Area.
Attachment 8 -Page?l
(+r+
FDo
;J
F)
CD
iJ
\o
TOCDF
Contingency Plan
June 2009
ATTACHMENT 9
CONTINGENCY PLAN
This Contingency Plan is designed to minimize hazards to human health or the environment from fires,
explosions, or any unplanned sudden or non-sudden release ofhazardous waste or hazardous
waste constituent to the air, soil, or surface water.
The provisions for carrying out emergeircy responses described in this plan are contained within
emergency response procedures, available on site.
Deseret Chemical Depot CAIRA Plan incorporated by reference, current plan available on site.
o
Attachment9-Pagel
9.1
9.0
9.2
li:, ;
TOCDF
Contingency Plan
June 2009
ABL[' OF CONTENTS
coN-rnlaiNcY PLAN
EI\{ERGENCY EQUIPMENT AND SYSTEMS
9. 1 .1 Electrical Distribution and lmergency Power (EP) System Overview
9.1.1.2 TOCDF Primary Power System (PPS)
9.1.1.3 TOCDF SecondaryPower System (SPS)
9.1.1.4 TOCDF Unintemrptible Power Supply (UPS) System
9.1.1.5 TOCDF Emergency Ge,nerator (GEI.I) System
9.1 .1 .6 CAMDS Electrical and Emergency Power System
9.t.2 Fuel Gas System (Natural Gas and Liquefied Petrolzum Gas)
9.1.3 Fuel Oil System
9.1.4 Fire Detection and Protection Overview
9.1.4.2 TOCDF Detection and Alarm
9.1.4.3 TOCDF Automatic Sprinkler System
9.1.4.4 TOCDF Halon (HAL) FM-200/F'E-227 Systems
9.1.4.5 Reserved
9.1.4.6 TOCDF and Area 10 Igloos Portable Fire Extinguishers
9.1.4.7 TOCDF Dry-Chemical System
9.1.4.8 CAMDS Fire Detection and Protection
9.1.4.9 ATLIC Fire Detection apd Protection
:"
EMERGENCY RESPONSE ORGANZATION
9.2.1 Overview
9.2.2 Scene Responders ' '
9.2.2.2 Incident Commander (IC)/Emergency Coordinator
9.2.2.3 Scene Control Officer (SCO)
9.2.2.4 SafetyAdvisor
9.2.2.5 Environmental Advisor
9.2.2.6 Maintenance Superintendent
9.2.2.7 HAZMAT Team Leader (HTL)
9.2.2.8 Decon Team Leader (DTL)
9.2.2.9 Paramedic Team l,eader (PTL)
9.2.2.10 Medical Clinician In Charge (MCIC)
9.2.2.11 Rescue Team Leader (RTL)
9.2.2.12 CMA Shift Engineer
9.2.3 Control Room
. 9.2.3.2 Assistant lncident Commander (AlC)/Altemate Emergency Coordinator
9.2.3.3 Accountability Coordinator
9.2.3.4 Sweepers
9.2.4 Contractor Management Advisory Team (CMAT)
9.2.4.2 General Manager
9.2.4.3 CMA Project Manager
9.2.4.4 Deputy General Managers
9.2.4.5 Government Shift Representative (GSR
9.2.5 CAMDS-Specific Emergency Notification
Attachment 9 - Page2
o
TOCDF
Contingency Plan
June 2009
9.3
9.2.6 ATLIC-Specific Emergency Notification
IMPLEMENTATTOX
9.3.2 Fire or Explosion Incident
9.3.3 Agent or Non-Agent Release
9.3.4 Decision Process
EMERGENCY RESPONSE PROCEDURE S
9.4.1 Notification
9.4.1.l Notification and Mobihzation Overview
9.4.1 .2 Persorurel Notification
9.4.1.2.2 Site Personnel
9.4.1 .2.3 Public Address System
9.4.1.2.4 Offsite Personnel
9.4.1.2.5 DCD Installation
9.4.1 .2.6 EG&G Management
9.4.1 .3 Emergency Responder Notification
9 .4,1 .3. I Scene Response Teams
9.4.1.3.2 DCD Primary Response Organizations
9.4.1.3.3 ContractorManagement AdvisoryTeam
9.4.1.4 HAZMAT Release Reporting
9.4.2 Identification of Hazardous Materials
9.4.2.1 Identification of Hazardous Materials Overview
9.4.2.2 Hazardous Materials at TOCDF and TOCDF Operated Facilities
" 9.4.2.3 GB (Sarin): Physical, Chemical, and Toxib Properties
9.4.2.1.2 Effects of GB
9.4
': ".' 9.4.2.3.3 Hazard Symbol forGB
9.4.2.4 VX: Physical, Chemical, and Toxic Properties
9.4.2.4.2 Effects of VX' 9.4.2.4.3 Hazard Symbol forVX
9.4.2.5 Mustard: Physical, Chemical, and Toxic Properties
9.4.2.5.2 Effects of Mustard
9.4.2.5.3 HazardSymbol forMustard
9.4.2.6 GA: Physical. Chemical and Toxic Properties
9.4.2.6.2' -' EffectsofGA
Hazard Svmbol for GA
9.4.2.7 Lewisite: Physical. Chemical and Toxic Properties
9.4.2.7.2 Effects of Lewisite
9.4.2.7.3 Hazard Svmbol for Lewisite
9.4.3 HazardAssessment
9.4.3.1 Hazard Assessment Overview
9.4.3.2 Event Detection
9.4.3.3 Event Information Gathering
9.4.3.4 Information Sources
9.4.3.4.2 Information from Emergency Response Teams
9.4.3.4.3 Information from SCO,IC, and Advisors
9.4.3.4.4 Information from TOCDF Control Room
9.4.3.4,5 Information from Monitoring and Sampling Teams
9.4.3.5 Event Assessment
9.4.3.6 Determination of Event HazardZone
Attachment9-Page3
TOCDF
Contingency Plan
June 2009
9.4.4 ControlProcedures
9.4.5 Prevention of Recurrence or Spread of Fires, Explosions, or Releases
9.4.5.1 Fire
9.4.5.2 Fire Reporting and Evacuation
9.4.5.2.1
9.4.5.2.2
9.5.4.2.1
9.5.4.2.2
9,5.4.2.3
9.5.4.2.4
9 .5 .4.8. 1
9.5.4.8.2
Immediate Actions
Subsequent Actions
9.5
9.6
9.4.5.3 Fire and Agent Releases
9.4.5.3.5 Prevention of Recurrence, Spread of Fires, Explosions, or
Releases
9.4.5.4 Explosive Hazards
9.4.6 Storage and Treatment of Released Material
9.4.7 IncompatibleWaste
9.4.8 Post-Emergency Equipment Maintenance
9.4.9 Container Spills and Leakage
9.4.10 Tank Spills and Leakage
9.4.11 Spills and Leakage from Other Regulated Units
EMERGENCY EQUIPMENT
9.5.1 Reserved
9.5.2 Communication and Alarm Systems
9.5.2.2 SystemDesign
9.5.2.3 Control Room
9.5.3 Spill Control and Decontamination Equipment
9.5.4 EmergencyEquipment
9.5.4.1 Fire Extinguishing Equipment
9.5.4.2 Emergency Personal Protective Equipment
Emergency Personal Protective Equipment Overview
Chemical Agent Ventilatio n/Hazard C ategories
TOCDF Descriptions of Personal Protective Equipment
Ensernbles
Selection of PPE
9.5.4.2.4.1 Chemical Agent Release
9.5.4,2.4.2 Industrial Chemical Release
9.5.4.3 Medical Emergency Equipment
9.5.4.4 Showers and Eyewash Facilities
9.5.4.5 Agent Detection Equipment
9.5.4.6 Decontamination Solution
9.5.4.'l Confined Spaces if Entry
9 .5 .4.8 Offsite Equipment
Firefighting Equipment
Heavy Equipment
COORDINATION AGREEMENTS AND SUPPORT ORGANZATIONS
9.6.1 CoordinationAgreements Overview
9.6.2 DCD Support
9.6.2.1 General '' '.
9.6.2.2 DCD Security :
9.6.2.3 Real Time Analysis Pldtforms (RTAPs)
9 .6.2.4 DCD Meteorological/Detection Teams (Met/Det)
9.6.2.5 DCD Hotline Crew
Attachrnent9 -Page4
TOCDF
Contingency Plan
June 2009
9.6.2.6 DCD Decontamination Teams
9.6.2.7 Emergency Operations Center (EOC)
9.6.2.8 DCD Fire Station
9.6,3 Reserved
9.6.4 TEAD Support
9.6.4.I General
9.6.4.2 TEAD Fire Station
9.6.4.3 TEAD Public Works
9.6.4.4 Support Center
9.6.5 Medical Support
9.6.5.1 General
9.6.5.2 Aid Station (DCD)
9.6.5.3 Reserved
9.6.5.4 U.S. ArmyHealth Clinic (TEAD)
9.6.5.5 Dugway Proving Ground
9.6.5.6 Air Ambulance Services
9.6.5.7 Intermountain Medical Center
9.6.5.8 University Hospital
9.6.5.9 Mountain West Medical Center
9.6.5.10 Utah Valley Regional Medical Center
9.6.5.11 Salt Lake Valley Regional Medical Center
9.6.6 62nd Explosive Ordnance Disposal (EOD) Detachment
9.6.7 Community Fire Support
9.6.7.1 Tooele City Fire Department
9.6.7.2 Stockton Fire Department
9.6.7 .3 Grantsville Fire Department
9.6.7.4 Tooele County Fire Department
9.6.7 .5 Volunteer Fire Departments
9.6.8 Other Emergency Services
9.6.9 Department of Army (DA)
9.7 PROTECTTVE ACTIONS AND EVACUATION PLAN
9.7.1 Protective Actions Overview
9.7.2 ProtectiveActionDecision-Making
9.7.3 ProtectiveActionlmplementation
9.7.3.1 Protective Masks and Agent Antidotes
9.7 .3.2 Access and Traffic Control
9.7.3.3 In-Place Sheltering
9.7.3.4 Evacuation
9.8 REQUTRED REPORTS
Attachment9-Page5
TOCDF
Contingency Plan
June 2009
LIST OT'TABLES
9-1-1 Emergency Power Load Summary
9-2-l Incident Commanders (Emergency Coordinators)
9-2-2 Assistant Incident Comrnanders (Altemate Emergency Coordinators)
9-3-1 Agent Exposure Limits and Agent Stack Limits (-g/-')
9-4-l Munitions and Bulk Item Characteristics
9-4-2 Chemical and Physical Properties of Agent
9-5-1 TOCDF Emergency Communications
9-5-2 Emergency Decon Stations and Personnel Decontamination Equipment
9-5-3 Deseret Chemical Depot (DCD) and TEAD Emergency Equipment
9-7-l Protective Action Communication
Attachment9-Page6
9-1-1
9-r-2
9-3-l
9-5-1
9-s-2
9-5-3
9-5-4
9-5-5
9-5-6
9-s-7
9-7 -l
9-7 -2
9-7 -3
9-7 -4
9-7 -s
9-7 -6
9-7 -7
9-7 -8
9-7 -9
9-7 -10
9-7 -ll
9-7 -12
9-7 -t3
9-7 -14
LIST OF FIGI]RES
TOCDF Emergency Response Organ rzatron
DCD Emergency Response Organrzatron (Chemical Event)
Initial Response Activities
MDB l't Floor Eye Wash and Decon Stations
MDB l't Floor Mezzantnes Eye Wash and Decon Stations
MDB 2"d Floor Eye Wash and Decon Stations
MDB 2nd Floor Mezzantnes Eye Wash and Decon Stations
PUB l't Floor Eye Wash Stations
PAS 100 Ft Level (Ground Floor) Eye Wash Stations
CHB l't Floor Eye Wash Stations
MDB 1st Floor
MDB lst Floor MezzaruLnes
MDB ZndFloor
MDB 2nd Floor Mezzanines
PUB lst Floor
PAS 100 Ft Level (Ground Floor)
PAS 16 Ft Level
PAS ll4-129 Ft Levels
PAS 128-l4l Ft Levels
PAS 147 -150-Ft Levels
PAS 159-170 Ft Levels
CHB
PSB
MSB Plan
TOCDF
Contingency Plan
June 2049
Attachment 9 - PageT
TOCDF
Contingency Plan
June 2009
9-7 -t5
9-7 -16
9-7 -17
9-7 -18
9-7 -19
9-7 -20
9-7 -21
9-7 -22
9-7 -23
9-7 -24
9-7 -25
9-7 -26
9-7 -21
9-7 -28
9-7 -29
9-7 -30
9-7 -31
9-7 -32
9-7 -33
9-7 -34
9-7 -35
EG-16-C-0004
9-7 -36
LIST OF FIGT'RES
ECF Plan
PMB Plan
S-l Plan
S-2 Plan
S-3 Plan
S-4 Plan
S-5 Plan
5-6 Plan
s-7
Qu alit y lBnvironment a 1
ETC
T-25
T-26
T-21
T-28
Area l0Igloos 1631,1632 and 1633
CAMDS Buildings 3309, 3311, and 3314
CAMDS Buildings 3308, 3310, and 3315
CAMDS Personnel Support Complex (PSC) and Command Post (CP)
CAMDS Site Anal tical Facility (SAF), Building 7085 and Command Module
(cMo)
DCD Site Evacuation Map
Evacuation & Rally Points Plan (TOCDF)
CAMDS General Layout and Muster Areas
Attachrnent9-Page8
TOCDF
Contingency Plan
June 2009
O ls-7-37
ATLIC"
Attachment9-Page9
TOCDF
Contingency Plan
June 2009
ACRONYMS
For purposes of this Contingency Plan, the following acronyms are used:
ACAMS AutomaticContinuousAirMonitoringSystem
ACS Agent Collection System
AFSC ArmyField Support Command
AIC Assistant Incident Comrnander
APR AirPuriffing Respirator
Area 10 Chemical Surety Materiel Storage Area
ATLIC Area 10 Liquid Incinerator
BP BatteryPack
BSRM Burster Size Reduction Machine
BRA BrineReductionArea
CA Combustion Air
CAIRA Plan Chemical Accident/Incide,nt Response and Assistance Plan
CAL Chemical Assessment Laboratory
CAMDS Chemical Agent Munitions Disposal System
CBR Chemical, Biological, and Radiological
CCEE Control Center Equipment Enclosure (ATLIC)
CFR Code of Federal Regulations
CHB Container Handling Building
CHE Cholinesterase
CMA Chemical Materials Agency
CMAT Contractor Management Advisory Team
CMO Command Module (CAMDS)
CON Control Room..(IOCpE)
CON-OP Control Room Operator (for ATLIC)
CSEPP Chemical Stockpile Emergency Preparedness Plan
DA Department of the Army
DAAMS Depot Area Air Monitoring System
DCD Deseret Chemical Depot
Decon Decontamination
DFS Deactivation Furnace System
DOSC Deputy On-Scene Coordinator
DPE Demilitarization Protective Ensemble
DVS Drum Ventilation System
DVSSR Drum Ventilation System Sorting Room
ECF Entry Control Facility
ECR Explosive Containment Room
EMT EmergencyMedical Technician
EOC Emergency Operations Center
EOD Explosive Ordnance Disposal
EP EmergencyPower
ERO EmergencyResponse Organization
ERP Emergency Response Plan
GA Tabun (Ethyl N. N-dimethylphosphoramidecyanidate)
GB Sarin,Isopropyl methylphosphonofluoridate
GC Gas Chromatograph
GEN Emergency Generator Supply
Attachment 9 - Page l0
TOCDF
Contingency Plan
June 2009
-e. I GSR Government Shift Representative
O
'
, bis (2-clioroethyl) sulfide
HD Distilled mustard, bis (2-chloroethyl) sulfide
hr Hour
HT Mustard,600/o HD and 40%T
ACRONYMS
HTL HAZMAT Teamleader
HVAC Heating, Ventilation, and Air Conditioning
IC Incident Commander
ICU Intermittent Collection Unit
IDLH Immediately Dangerous to Life and Health
IR Infrared Retro-Reflective
IRF Initial Response Force
lb/hr pounds per hour
LIC Liquid Incinerator
LPG Liquefied Petroleum Gas
MCE Maximum Credible Event
MCIC Medical Clinician In Charge
MDB Munitions Demilrtanzation Building
MDM Multi-pu{pose Demihtanzation Machine
MET/DET MeteorologicallDetection Teams
MOU
MPF
MSDS
NaOCI
NaOH
NIOSH
OSC
PAS
PDS
PMB
PMD
POC
POV
PPE
PPS
PTL
PUB
QRU
RTAP
RTL
SCBA
SCO
SDS
SPORT
Memoranda of Understanding
Metal Parts Furnace
Material Safety Data Sheets
Sodium Hlpochlorite
Sodium Hydroxide
National Institute for Occupational Safety and Health
On-Scene Coordinator
Pollution Abatement System
Personnel Decontamination Station
Personnel Maintenance Building
Proj ectileAVlortar Disas semb ly Machine
Point of Contact
Privately Owned Vehicles
Personal Protective Equipment
Primary Power Supply
Paramedic Team Leader
Process and Utility Building
Qr\S^S eMr\ Shi$Quality r\ssuanee Speeialist and l "rurnurdtien Strrveillanee
Quick Response Unit
Real Time Analysis Platform
Rescue Team Leader
Self Contained Breathing Apparatus
Scene Control Officer
Spent Decontamination System
Single Pallet Only Rocket Transporter
Spent Decon Spent Decontamination Solution
SPS Secondary Power Supply
Attachrnent9-Pagell
TOCDF
Contingency Plan
June 2009
SSCC
SEL
STEL
T
TAP
TCB
TEAD
TOCDF
TOX
UPS
UV
VSL
VX
xxx
xxxxx
Site Security Control Center
Source Emission Limit
Short-Term Exposure Limit
B i s [2 (2 -chloro ethylthio) ethyl] ether
Toxicological Agent Protective
Treaty Compliance Building
ACRONYMS
Tooele Army Depot (North Area)
Tooele Chemical Agent Disposal Facility
Toxic Cubicle
Un-intemrptible Power Supply
UltravioletAnfrared
Vapor Screening Level
O - ethyl - S (2 -dii sopropylamino ethyl) methyl pho sphonothio late
3X; surface decontamination
5X; thermaltreatment at 1000 oF for a minimum of 15 minutes
Attachment9 -Page12
9.0
9.0.1
9.L
i
9.L.1
9.1 .l .1
9.1 .1 .1 .1
TOCDF
Contingency Plan
June 2009
CONTINGENCY PLAI\ 1R315.3.2.5. R315-8.4I
This Contingency Plan provides for hazardous waste ilumagement and describes the
actions facility persorurel will take in response to fires, explosions, or any unplanned
sudden or nonsudden release of hazardous waste or hazardous waste constituents from
their containment systems. This plan encompasses TOCDF and TOCDF operated
facflities including the Chemical Agent Munitions Disposal System (CAMDS) rortLlthe
Area 10 Liquid lncinerator (ATLIC).
EMERGENiY EOTIIPMENT AIID SYSTEMS
Electrical Distribution and Emergency Power @P) System Overview
The TOCDF and ATLIC electrical system consists of primary and secondary systems.
The primary system consists of substation, switchgears, and diesel engine generators. The
secondary system consists of 480-V switchgears, Motor Control Centers, distribution
transformers, panelboards, and Uninte.rruptible Power Supply (UPS) systems. The
electrical loads are divided into three categories: critical, essential, and utility:
Critical Loads are those required imr4ediately following a power intemrption. These
loads are fed from UPS and battery packs (BPs). Those requiring AC power are supplied
from a solid-state UPS consisting of a batteryiinverter system. Those requiring DC power
are fed froin a battery charger and storage battery or a special purpose pack furnished as an
integral part ofthe load device.
Essential Loads are those that are essential for health and safety but can tolerate
intemrption for a few seconds or more. Essential loads may be supplied from a standby
generator system that can be started and fully loaded within 90 seconds.
Utility Loads are those not falling into the first two categories. The loss of these loads
may result in a shutdown of the facilities and loss of production, but will not endanger
health or safety.
TOCDF PrimaryPower System (PPS)
Two 5-MVA transformers in the main substation, located near the TOCDF, receive
primary power from the local electrical utility. This substation steps down line voltage
from 46kV to 4.16kV and provides power to the TOCDF Primary Power System (PPS).
Each transformer in the substation can carry 100% of the essential loads. Primary power
to the ATLIC is provided by tying onto an existing 12.470 VAC overhead line from the
Silverado substation that runs to TOCDF.
TOCDF SecondaryPower System (SPS)
The Secondary Power System (SPS) consists ofdouble-ended 480-V load center and
switchgear, motor control centers, and other equipment necessary to control and distribute
power to TOCDF equipment. The SPS drops the voltage received from the PPS from
4,160-V to 480-V through a series of transformers. These transformers supply power to
9.1.1.1.2
9.1.1.1.3
9.1.1.2
9.1 .1 .2.1
9.1.1.3
9.1.1.3.,1
Attachment 9 - Page l3
TOCDF
Contingency Plan
June 2009
the switchgear and load centers. The switchgear and load centers contain circuit breakers
that control power to the SPS motor control.centers, transformers, and UPS systems.
9.1.1.3.2 The TOCDF line has been extended thrcugh an undersound lin-e into Arca 10 to a new
transformerpad at the ATLIC (approx. 1800 feet). A 2.0 MVA transformerBrovides 480
VAC 3O secondary power for the ATLIC.
TOCDF Unintemrptible Power Supply (UPS) System
The Unintemrptible Power Supply (tlPS) at TOCDF provides power to electrical loads
that cannot be intemrpted for any length of time, such as instrument control systerns,
Control Room advisor screens, closed-circuit television, DPE radio system, waming lights
(flashing), fire alarms, exit and emergency lights, and agent monitoring systems. The UPS
system for the TOCDF MDB uses offset battery racks in a separate room to facilitate
access for maintenance and to accommodate cable connections to each battery. Positive
room air circulation is utilized to avoid hazardous concentrations of hydrogen gas. If the
utility and emergencypower systems are not available, the critical loads will be powered
by two UPS batteries that provide power for no less than 45 minutes.
9,1,1,4
9.1 .1.4.1
9.1.1.4.2 lso provi tin criti
with battery supply at full load for a period of 45 minutes in the event of power system
failure. The UPS systern batteries are desiened to carry these loads with no interruption
for that 45 minute period or until the ernereency generator syst€, n has started and
automatically takes over the load. The UPS systems can be operated ind€pend€ntly as
either UPS is caoable of carrying the entire UPS load should one UPS fail or require
maintenance. Additionally. each UPS can be manually b)?assed if either UPS should
require a blpass at anytime for any reason. A listing of the major systems and major
equipment that remains operational under emergencypower at TOCDF and ATLIC is
provided in Table 9-1-1.
Table 9-1-1
IOCDF EMERGENCY POWER LOAD ST]MMARY
Power Load
Recommended
Tvpe of Supply
Load
Classification
Agent annunciation system BP,Critical
Fire alarm BP Critical
DPE radio base station BP,Critical
ACAMS agent monitors UPS Critical
Emergency liehting in non-toxic areas BP Critical
Emergency liehtine in toxrc areas BPJ Critical
Load center and electrical switchgear controls (SPS-
LCTR-l0l and -102)
UPS andlor
Station Batteries Critical
DA\r{\4S Monitoring EP Essential
Rotary retort DFS drive EP Essential
DFS retort lube oil pump EP Essential
CCTV (selected areas)UPS Critical
Public address system UPS or BP Critical
Instrumentation (CON, PLCs, microprocessors)UPS Critical
Control room ventilation (at handline)EP Essential
UPS (power to)EP Essential
Attachment 9 - Page 14
TOCDF
Contingency Plan
June 2009
Table 9-1-L
TOCDF EMERGENCY POWER LOAD ST]MMARY
Power Load
Recommended
Type of Supply
Load
Classification
Life support system and compressor EP Essential
CAL building. hood and filter units EP Essential
Air filtration system (includes air handline units)EP Essential
Instrument air compressor EP Essential
Area 10 Igloos 1631,1632, and 1633 and the Igloo
Carbon Adsorption Filtration System EP Essential
Battery room exhaust(HVC-FANX- 1 02)UPS Critical
LPG transfer pump air compressor, vaporrzer EP Essential
Facility heating EP Essential
Decon supply purnp and spare EP Essential
Stack liehtine EP Essential
MPF/ DFS/ECR feed and exit, conveyors/doors EP Essential
DFS secondary combustion air blowers EP Essential
MPF combustion air blower EP Essential
DFS/MPF emergency exhaust blowers EP Essential
DFS/MPF afterburners EP Essential
Quench brine pumps EP Essential
MPF/DFS Clean Liquor Pumps EP Essential
Control room air conditionine EP Essential
Process Water Supply EP Essential
Primarf Cooling water EP Essential
Elevators/doors EP Essential
Notes:
I BP = self-contained battery pack, EP = emergency power, UPS = solid-state unintemrptible power
supply.
2 8-hour battery.
3 Battery packs are located in non-toxic areas.
ATTIC EMERGENCY POWER LOAD SUMMARY
Power Load
Recommended
Tvne of Supnlv
Load
Classification
FTB#I MCC RM-8OOI UPS Critical
54-52- 120 Switch Gear Breaker open/close UPS Critical
54-52-l2l Switch Gear Breaker open/close UPS Critical
54-52- 122 Switch Gear Breaker ooen/close UPS Critical
54-52- 123 Switch Gear Breaker oper/close UPS Critical
54-52- 124 Switch Gear Breaker ooerr/close UPS Critical
54-52-125 Switch Gear Breaker open/close UPS Critical
54-52-126 Switch Gear Breaker open/close UPS Critical
54-52- 127 Switch Gear Breaker open/close UPS Critical
Fire Alarm Svstem UPS Critical
Sound svstem (PA)UPS Critical
Radio Svstems UPS Critical
Intrusion Detection Svstem UPS Critical
Control room CCTV
MON-8101.8102
swcH-8101. 8102
UPS Critical
Attachrnent 9 - Page l5
TOCDF
Contingency Plan
June 2009
ATLIC EMERGENCY POWER LOAD ST]MMARY
Power Load Power Load Power Load
OPCW ROOM CCTV
MON-8103.8104
swcH-8103.8104
UPS Critical
Seimens PLC
# s-7-3 l9 UPS Critical
Server FCS-SRVR-2 I 1. 2 12 UPS Critical
ContrqlConsol #l UPS Critical
Control Consol #2 UPS Critical
PLC Panel #l UPS Critical
PLC Panel #2 UPS Critical
PLC Panel E UPS Critical
PLC Panel tl4 UPS Critical
19 iru RackCCTVIqQMM UPS Critical
24 in Rack UPS Critical
Seimens Power Supplv #l UPS Critical
Seimens- Power Supplv42 UPS Critical
MON-DAAIVIS 671 UPS Critical
MON-DAAIVIS 672 UPS Critical
Phone Bgard UPS Critical
Ensineerine Work Station UPS Critical
Aeent Alarms UPS Cdtiaal
MON-DA,AIVIS.672 UPS Critical
UPS Critical
MON-ACAIvIS-S21 UPS Critical
MON-ACAIvIS-675 UPS Critical
MON-MCAI\{S-I24 UPS Critical
MON-MCAIVIS-I25 UPS Critical
MON-DAAIVIS.676 UPS ftrliaal
MON-ACAIVIS-523 UPS Critical
MON-DAu{lvIS-677 UPS Critical
MQN-MCAI\4S-I26 qPS Critical
MON-MCAIUS-127 UBS Critiaal
MON-DAAtvIS-678 UPS Critical
MON-ACAIVIS-529 UPS Critical
MON-DA\AIVIS-679 UPS Critical
MON-MCAN{S-I30 UPS Critical
MON-MCAMS.I3I UPS Critical
MON-DAAIVIS.68O UPS Critical
MON-ACAI\{S-53 I UPS Critical
MON-MCAN{S-I32 UPS Critical
MON-ACAI\{S.532 UPS Critical
MON-W UPS Critical
AGB-GLBX-8502 UPS Critical
AGB-GLBX-85OI UPS Critical
FTB-MON#6 RM.l 13 FTB.8OO6 UPS Critical
MON.ACAMS.s19 UPS Critical
MON-MCAMS-122 UPS Critical
MON-ACAIVIS-520 UPS Critical
MON-MCAMS-123 UPS Critieal
Attachment 9 - Page l6
TOCDF
Contingency Plan
June 2009
ATLIC EMERGENC\.POWER LOAD SM
Power Load Power Load Power Load
MON-ACAIVIS-52I UPS Critical
MON.W UPS Critical
MON.ACAI\4S-525 UPS Critical
MON-MCAI\{S.I29 UPS Critical
MON-ACAI\4S-527 UPS Critical
MON-MCAN4S-134 UPS Critical
MON-ACAN4S-533 UPS Critical
MON.DAAIVIS.6SI UPS Critical
MQN-ACAN{S-535 UPS Critical
MON-MCAN{S-136 UPS Critical
MON-MCAI\{S-I35 UPS Critical
MON-MCAIVIS-I37 UPS Critical
MON-DAuU\4S-682 UPS Critical
MON-ACAIVIS-s39 UPS Critical
MON-ACANdS.537 UPS Critical
MON.MCAMLL3S UPS Critical
MON-DA\AIVIS-683 UPS Critical
MON-DAAIVIS-684 UPS Critical
MON-MCAIVIS-139 UPS Critical
815-fSU=8102 UPS Critical
835- PSU-8 101 UPS Critiaal
FTB #3 MON RM 113 FTB-8003 UPS Critical
FTB #4 MON RM 110 FTB-8004 UPS Critical
FTB #5 Isloo RM I 13 FTB-8005 UPS Critical
PAS PANEL l GACQMM)UPS Critical
MON-ACAIv[S-543 UPS Critical
MON-DAAIVIS-687 UPS Critical
MON-ACAN{S-544 UPS Critical
MQN-DAAMS.688 UPS Critical
MON-ACANdS-545 UPS Critical
MON-MCAI\4S.I42 UPS Critical
MQN-MCAIVIS-143 UPS Critical
MON-MCAIVIS-144 UPS Critical
MON-MCAIVIS-145 UPS Critical
MON-MCAIVIS-146 UPS Critical
MON-MCAIVIS-I37 UPS Critical
MON.DAAMS-685 UPS Critical
MON-DAAI\{S.686 UPS Critical
MON-DAAIVIS-689 UPS Critical
MON-DAv{l\dS-690 UPS Critical
FTB #?IMON RM 1I3 FTB-8002 UPS Critical
MON-ACAIVIS-549 UPS Critical
MON-DAu{IvIS-7415 UPS Critical
MON-DA\AIVIS.7O5 UPS Critical
MON-MCAIVIS-148 UPS Critical
MON-MCAMS-I49 UPS Critical
MON.ACAIVIS.S5I UPS Critical
MON-DAAIVIS-693 UPS Critical
MON-DAu{IvIS-717 5 UPS Critical
Attachment 9 -Page 17
TOCDF
Contingency Plan
June 2009
ATLIC EMERGENCY POWER LOAD SIJMMARY
Power Load Power Load Power Load
MON-DAAMS-707 UPS Critical
MON-MCAMS-150 UPS Critical
MON-MCAMS.I5I UPS Critical
MON.ACAMS-s59 UPS Critical
MON-DA.AMS.713 UPS Critical
MON-DA\AMS-7195 UPS Critical
MON-DA,AMS.7II UPS Critical
MON-MCAMS-152 UPS Critical
MON-MCAMS-I53 UPS Critical
MON.ACAMS.553 UPS Critical
MON-DA\AI\4S-695 UPS Critical
MON-ACAMS-s54 UPS Critical
MON-DAAMS-696 UPS Critical
MON-MCAMS-I54 UPS Critical
MON.MCAMS-I55 UPS Critical
MON.MCAMS.l56 UPS Critical
MON-MCAMS-I75 UPS Critical
Air Handline Unit LIC EP Essential
Plant Air Svstem Air Compressor (PLA-COMP-8354)EP Essential
LIC Combustion Air Blower EP Essential
PAS Venturi Brine Pump EP Essential
PAS Packed Bed Liquor Pump #1 EP Essential
PAS Electric Reheater EP Essential
Filter Bank A EP Essential
Filter8anLc (Spare)EP Essential
PUMP ChiIIEr UNit, LIC [HVC.PUMP.84OD EP Essential
Pump Chiller Unit. Ieloo (HVC-PUMP-8327)EP Essential
Air Handline Unit" Chiller. Isloo EP Essential
PAS Air Cooled Liquid Cooler Fan #3 EP Essential
Proeess lMater Supplv fump EP Essential
WTS Loading Pump EP Essential
480V Power Distribution Panel (SPS-PANL-8008)EP Essential
480V Power Distribution Transfonner (SPS-TRSF-8006)EP Essential
Critical Power UPS I/TRSF 8002 EP Essential
GA/Lewisite Supply Pump #l NE Non-Essential
Nitric Reiect Supplv Pump #l NE Non-Essential
SDSiuppLy Pump #1 NE Non-Essential
Chiller Air Cooled Condenser (PAS-COND-8975 A&B)NE Non-Essential
PAS Carbon Tansport Blower NE Non-Essential
PAS Liquid Chilter (PAS-CHL-8976 A&C)NE Non-Essential
Swamp Cooler Blower Fan NE Non-Essential
480V Power Distribution Panel (SPS-PANL-8004)NE Non-Essential
480V Power Distribution Transformer (SPS-TRSF-8002)NE Non-Essential
Air Handline Unit Ieloo EP Essential
Plant Air Svstem Air Compressor (PLA-COMP-8357)EP Essential
ID Fan ryFD)EP Essential
PAS Air Cooled Liquid Cooler (PAS-COOL-8972 A&B)EP Essential
Filter Bank B EP Essential
Emergency Ouench Supply Pump EP Essential
Attachrnent 9 - Page l8
ol
I
TOCDF
Contingency Plan
June 2009
TOCDF Emerge,ncy Generator (GEN) System
The Emergency Generator (GEN) system at TOCDF consists of diesel-driven electrical
generation systems capable of providing backup power to all of the critical and essential
loads in case of a power outage. Diesel-driven auxiliary electrical generation systems are
provided to supply essential power to the MDB and associated facilities for a safe and
orderly shutdown. This includes power for emergency lighting, instrumentation and
control system, building ventilation system, and key process equipment such as pumps and
blowers where a power loss could either create a safety hazard or major damage to
equipment. An additional diesel-driven filter generator is tied to all nine filter units in the
MDB HVAC filtering system to provide power for any two of the filter units during an
outage as needed. Plant security lighting is supplied from the Entry Control Facility
generator.
Area l0Igloos 1631 (Autoclave operations), 1632 (DVS/DVSSR operations & storage),
1633 (storage) and monitoring, including the Igloo Carbon Adsorption Filtration System,
are provided emergency power by a dedicated natural gas-powered emergency generator.
ACAMS monitoring at the carbon filtration system stack is initially powered by UPS.
9. I . 1 .5.3 The ATLIC Generator system consists of two diesel-powered gen€rators and associated
support equioment. includine a fuel-oil day tank. The GeNrerator equipment is located east
of Igloo 1639 in the erners€,ncy eenerator buildine. The g€nerators are used to enerqize
the Essential and Critical loads only. The Primary Generator will supply these loads by
opening and clo$ine a combination of tie breakers. main non-essential breakers and utility
source breakersto ensure there is never a chance of back feedine the utility line from a
f one of the qenerators should fail to start or fail durins oDeratio
throueh the use of the PLC and qronitored bv the control room operators. a manual Tie
breaker can be closed. At the same time SPS-MCC-8439 BKR #1 or BKR #2 can be
9.1.1 .5
9 .t .1 .s.1
9.1.1.5.2
ATLIC EMERGENCY POWER LOAD SI,]MMARY
Power Load Power Load Power Load
Pump Chiller unit. LIC (HVC-PUMP-8400)EP Essential
Pump Chiller Unit. Isloo (HVC-PUMP-8414)EP Essential
PAS Pump EP Essential
Air Handline Unit. Chiller LIC EP Essential
Process Water Supolv Pump EP Essential
PAS Packed Bed Liquor Pump #2 EP Essential
4 8 0V Power Distribution Panel SP S-PAI.IL-8 007 EP Essential
4 8 0V Power Distribution Transformer SP S-TRSF-8 005 EP Essential
Critical Powet EP Essential
Gdlewisite Suonlv Pumn #2 NE Non-Essential
Nitric Reiect Supplv Pump #2 NE Non-Essential
SDS Supplv Pump #2 NE Non-Essential
PAS Liquid Chiller (PAS-CHL-8976 B)NE Non-Essential
Swamn Cooler Blower Fan NE Non-Essential
Chiller Air Cooled Condenser (PAS=COND-8975 C&D)NE Non-Essential
CDS Unloadine oump NE Non-Essential
4 8 0V Power Distribution Panel SP S-PAII{L-8 003 NE Non-Essential
4 8 0V Power Distribution Transforrrer SP S-TRSF-8 00 I NEr Non-Essential
Attachment 9 - Page l9
9.1 .l .6
9.1.2
9.1 .2.1
9.1 .2.2
9.1 .2.3
9.1 .2.4
9.L.3
9.1 .3.1
a"rrrrr"rl?;?:
June 2009
locked in their open positions until the failed generator can be brought back on line or
normal utilitypower restored. Should either generator fail to start automatically after 4
attempts. the generators will reouire a manual start seque, rce. If both gendrators fail to
start. the UPS maintains anergency liehtine. control systern ooeration. and
communication while the plant is in a fail-safe condition.
The CAMDS electrical power system consists of primary and secondary systems. The
primary system consists of substation, switchgears, and diesel engme generators. The
secondary system consists of 480-V switchgears, Motor Control Centers, distribution
transformers, panelboards, and Unintemrptible Power Supply (UPS) systems. The
CAMDS emergency power system consists of diesel-engine-driven emergency standby
generators. These systems are capable of carrying the entire CAMDS emergency load and
providing backup power to all of the critical and esseirtial loads in case of a power outage.
Failure of commercial power is sensed by automatic transfer switches that start each
generator and switch critical loads to standby power within ten seconds after a power
failure. The CAMDS emergencypower is provided to all critical functions, e.g., the
control system, agent monitors, emergency lighting, ventilation filter units, communication
systems, Closed Circuit Television (CCTV) systems, guardhouse, and perimeter lighting.
Fuel Gas System (Natural Gas)
The furnaces at TOCDF are designed to bum natural gas as theirprimary fuel source. The
natural gas is fed to the facility from the local utility company main supply line at a
nominal pressure of 70 psig. The TOCDF regulates this pressure down to a header
pressure of35 psig.
The TOCDF fuel gas system consists of commercially supplied natural gas, associated
controls, indicators, and flare stack and fuel gas distribution system. A seismic-activated
gas cutoff valve is provided to shut the gas supply to the equipment in the event of an
earthquake.
The DCD Area 10 Igloo natural gas-powered emergency generator is supplied by the
DCD natural gas supply system.
The CAMDS fuel gas system consists of commercially supplied natural gas, associated
controls, indicators and distribution system. The use of fuel gas at the CAMDS site is
limited to various building heating systems.
9.1.2.5 At ATLIC. natural gas is supplied to the primary and secondary chamber burners as fuel.
The fuel is suop-lied through the fuel supply skid located outside the buildine. Apressure
regulator reduces the fuel supply pressure to the burners. The fuel flow rate is measured
by an orifice plate and regulated by a flow-control valve and controller.
Fuel Oil System
The Fuel oil storage at TOCDF is provided to supply fuel to the emergancy diesel-driven
electrical generation system. The fuel oil system consists of a belowground storage tank
with level sensor, switch panel, drop tube, and 30-inch manway. The tank is double
walled with a rustproof fiberglass reservoir. A monitoring system provides for leak
detection.
Attachment 9 -PageZ0
adjacent to each emergency diesel generator. The fuel oil tanks are subject to 4-hour
periodic fire-watch inspections.
9.1.3.3 The ATLIC has a fuel-oil day tank. In the event of a projected utility loss. orovisions will
be made to provide fuel delivery as required or incorporate the addition of a larser fuel
tank into the system design. An alternative to this course of action will be to oerform a
prosrammed shut down of the Primary Generator and brins the Secondary Generator on
line. This action would allow for additional operation before refueling would be required.
9,1.3.2
9.1,4
9.1 .4.1
9.1 .4.2
9.1 .4.2.1
9.1 .4.2.2
9.t.4.2.3
TOCDF
Contingency Plan
June 2009
The CAMDS emergencypower system fuel oil supply is provided by fuel oil tanks located
Fire Detection and Protection Overview
TOCDF is equipped with smoke and fire alarm sensors, control panels, and alarms to alert
personnel that a fire has been detected. Manual pull stations are located at exit points
throughout the site to allow personnel to report visual sighting of a fire. Pull stations,
alarms, and hydrants are located throughout the site near the fuel storage area for the
emergency generator, the LPG tank, the PMB filters, the fuel and bulk chemical unloading
area, the MDB filter and stack area, the CON filter, the CHB loading dock, and the
backup generator area. To extinguish fres, sprinkler systems using water are used in the
UPA, ECR, and CHB; Halon 1301 total-flooding systems are used in the CON and UPS
rooms, FM-200iFE-227 total-flooding suppression systems are used in the UPS and
Battery Enclosures; and dry chemical systems are used in the TOX; and the induced-draft
fan oil-lube systems located east of the PAS building. Wet-pipe sprinkler systems are
used in the PMB. Smoke detectors are used in the PSB, certain areas of the PMB, and the
Treaty Compliance Building (TCB). Portable fre extinguishers are provided for rapid
response to small fres. In addition, a looped water distribution system services the site's
fire hydrants.
TOCDF Detection and Alarm
Fire detectors used in the various fire detection systems are one of the following tlpes:
photoelectric, combination Ultraviolet/Infrared ([JV/IR), and thermal. Detectors in the
furnace rooms and in areas subject to decon solution spray are hightemperature, rate-of-
rise, and thermal types. Combination LIV/IR detectors are provided for the ID fan oil-lube
systems. All other areas are provided with photoelectric detectors.
If smoke or heat is sensed, an alarm is generated at the local panel and a signal go'es to the
main supervisory control panel in the CON. That panel passes the alarm to the ECF
control panel. The ECF control panel reports the alarm to the DCD fire department
through the radio communication system.
Rooms with Halon 1301 and FM-200/FE227 protection use cross-zoned anti-falsing
photoelectric smoke/heat detectors. Rooms with dry-chemical extinguishing systern
protection use cross-zoned protection with thermal and photoelectric detectors in the TOX.
When these detectors sense smoke or heat, they simultaneously activate an alarm
throughout the MDB using local alarm homs and strobe lights and visual and audio alarms
in the CON.
Attachment9 -PageZl
g.l .4.2.4
9.1 .4.3
9 .l ,4.3.1
9,1 .4,3,2
9,1 .4,4
9.1 .4.4.1
9.1 .4.4.2
9.t.4.5
TOCDF
Contingency?lan
Ifa worker observes a fre and no alann has sounded, that person should pull the nearest
manual pull station. Whsn a fire occurs inside of the double fence, the Plant Shift
Manager must decide whether the fire can be extinguished without peril to personnel or
equipment. Using existing resources and personnel can stop a small fire that has no
chance of spreading further if promptly extinguished.
TOCDF Automatic Sprinkler System
Dry-type, hydraulically designed automatic sprinkler systems are located in the CHB and
the UPA. Thermal fire detectors in these areas automatically trigger the systems.
In the event of a fire, the sprinkler system dry pipes are charged with water by the
activation of a deluge valve triggered by thermal detectors in the area. Sprinkler heads
over the fire are then thermally activated by melting a fusible linkr. Water is released
through open sprinkler heads to extinguish the fire. If the fire is very small and remotely
located from explosives, it could be fought effectively with a hand-held extinguisher. In
the event of a large fire or if the fire is detected in the UPA, the sprinkler systern
automatically activates. If it fails to start automatically, operators in the UPA and CHB
UPA must manually activate the sprinkler deluge valve.
TOCDF Halon (HAL) and FM-200 EE-227 Systems
Automatic total-flooding Halon 1301 (HAL) and FM-200/FE227 systems protect the CON
and MDB UPS enclosures. Halon is used to extinguish fires in these rooms since it does
not cause damage to electrjcal equipment. The CON rooms have raised computer-room
floors, so these under floor spaces are also protected by Halon discharge nozzles. The
systems are actuated by cross-zoned, photoelectric smoke/heat detectors in two stages; if a
detector in only one stage is activated, a waming signal is generated. The automatic
control leading to the HAL discharge is actuated only when detectors in two different
zones are activated; the second alarm sets the system into a 30-second time delay mode
with horns and strobes indicating imminent release. The time delay allows operators to
push an abort switch, which inhibits the HAL and FM-20088-227 discharge as long as
the button is held down. This allows personnel to determine the seriousness of the fire or
if it is a false alarm, and it allows evacuation of affected personnel from the fire area if
necessary.
If the fire is small and can be fought safely, operators may abort the automatic release and
use the manual Halon 72ll ftre extinguishers located in the CON and MDB UPS rooms to
extinguish the fire. If the fre is large, and the operator does not choose to abort the
discharge, the second alarm sounds and the HAL or FM-200/FE-227 f:re suppression
system is discharged thirty seconds after the abort button is released. If the automatic
discharge fails, the manual discharge switch may be used. The manual discharge switch
overrides the time delay and abort switches in the system.
Reserved
rThe sprinkler system uses sprinklers with fusible alloy sealed into a bronze center strut by a stainless steel ball.
When heat from a fire causes the alloy to melt, the ball is forced upward into the center strut allowing a release of the
pressurized firewater.
Attachment9 -Page22
9,1 .4.6
9.1 .4.6.1
9,1 ,4.6,2
9.1 .4.6.3
9.1 .4.7
9.1 .4.7 .l
9.r.4.8
a""rirrJ?;il:
June 2009
TOCDF and Area 10 Igloo Portable Fire Extinguishers
Portable fire extinguishers are wall mounted throughout the TOCDF (except for A and B
air categories in the MDB) and TOCDF-operated igloos, and are used in the event of a
small fire that has been determined to be one that can be handled safely and kept under
control. Two types of portable fire extinguishers are available depending on the type of
fire expected in the immediate area: Halon l2ll andmultipurpose dry chemical. Both
types are compatible with chemical agent and decontamination fluids. All personnel are
authorized to use portable fire extinguishers to extinguish small fires and are familiar with
extinguisher locations.
Halon L2Ll fte extinguishers are rated 2A:60B:C and placed in areas where electrical
fires or electrical hazards are expected. The contents ofthese extinguishers are stored as a
. liquid under pressure and expelled as a liquid.
ln areas where electrical'fires or electrical hazards are not expected, multipurpose dry-
chemical fire extinguishers are sufficient. Multipurpose dry-chemical extinguishers for
Class'A, B, and C, and rated20A:120B:C are mounted in such areas.
TOCDF-Dry-Chemical System
-'*: Fiyg dry-chemical type fire suppression systems protect specific process zones. Four
systems are.located on the east side of the PAS platform east of the PAS building and
provide protection to the four lube-oil systems of the four PAS induced-draft fans. A fifth
system provides protection to the upper and lower levels of the TOX.
CAMDS Fire Detection and Protection consists of hand-held portable fire extinguishers,
fire hydrants, and four dry-chemical type fire suppression systems that protect the CMO,
the SAF Lab, the SAF chemical storage room, and the CUB. The portable hand-held
extinguishers are distributed throughout the buildings that remain standing (e.g., have not
been decommissioned, demolished and closed yet). All personnel are authorized to use
portable fire extinguishers to extinguish small fires and are familiar with extinguisher
locations. Additional fire detection is provided by 4-hour periodic fire watch inspections.
9.1.4.9 The ATLIC Fire Detection and Protection consists of a Fire Alarm Control Panel (FACP)
located in the Area l0 Control Point facility ATLIC CCEE. The FACP reports to the
TOCDF CON and the DCD Fire Department. The fire detection. intemal alarm and
central reporting systems are confizured in accordance with NFPA. Drawine EG-22-K-
8201. Sheet l. provides a comolete descriotion and list of ancillary equipment to the Fire
Protection Svstem.
9. I .4. 10 An addressable Fire Detection Annunciation and Alarm system incorporates photoelectric
smoke detectors as well as Combination fixed-temperature and rate-of-rise thermal
detectors. This system is caoable of beins activated by local fire detectors or manual oull
stations.
9.1.4.1 1 This system interfaces with the Main Suoervisory Fire Alarm Panel (MSFAP) and
forwards this information to the TOCDF Control Room (CON) Fire Alarm Panel.
Attachment 9 -Page23
TOCDF
Contingency Plan
June 2009
9.1.4.12 Fire dampers are not allowed in a hazardous exhaust duct. Duct detectors have been
incomorated in the two monitoringrooms located inside the Environmental Control
System (ECS) to ensure adequate detection and control.
9. I .4. 1 3 Portable fire extinzuishers are olaced throughout the facility in comoliance with NFPA 10.
9.1.4.14 Most areas contain a temp€rature sensor only while other areas will contain combination
photo and heat detectors. Each zone or area is adequately covered bv a combination
Hom/Strobe alarm lieht designed with the ambient noise theshold in mind. A strobe sync
module is installed within the FACP.
9.1.4.15 The Ieloo. ECS. monitoring €nclosures. and the electrical room are protectd with a ore-
action wet sprinkler system. In addition. an FM200 systemorotects the Prosrarn Logic
Controller OLC) area inside the Control Center Equipment Enclosure (CCEE).
9.2
9.2.1
9.2.1 .1
9.2.1 .2
9.2.1 .3
9.2.t.4
EMERGENCY RESPONSE ORGAITIIZATION tRi 15-8-4.3(c). R3 15-8-4.6: 29 CFR
1e10.120t
Overview
TOCDF and TOCDF-operated facility response efforts are comfiranded and controlled by
the Incident Comrnander (IC)2. The IC is an employee of EG&G, the operator of TOCDF
and TOCDF-operated facilities. Oversight of emergency response efforts is provided by
the TOCDF General Manager, also an EG&G employee. For the purposes of emergency
response, *EG&G'includes all EG&G subcontractors such as Battelle. In an emergency
that is declared a Chemical Accident/ftrcident Response and Assistance (CAIRA) event,
response command and control is ceded to the DCD Commander operating from the
installation Emergency Operations Center (EOC). During CAIRA events, the On-Scene
Coordinator (OSC) has been designated by the DCD Commander to direct emergency
operations. ln a CAIRA event, the EG&G IC will fulfrll this function under the direction
of the OSC.
EG&G's Emergency Response Organization (ERO) is composed of three distinct but
coordinated groups of emergency personnel: Scene Responders, the Control Room, and
the Contractor Management Advisory Team (CMAT). Each group has its own response
role and focus, each complementing the other. Group composition and relationships are
illustrated in Figure 9-l -1. The basic responsibilities of each of these three groups are
discussed below.
The DCD Emergency Response Organization for a chemical event is shown in Figure 9-1-
2. During chemical events, TOCDF emergency response efforts are under the direction of
the DCD Commander at the DCD EOC. Direct interface is provided through the DCD
OSC at the EOC.
CAMDS EmergencyNotification-As describedin9.2.5, Theprescribed communication
path for reporting CAMDS emergencies to the TOCDF Control Room is via the CAMDS
2 To be consistent with the EG&G Emergency Response Plan, the title of Incident Commander (IC) is used instead
of Emergency Coordinator.
Attachrnent 9 -Page24
TOCDF
Contingency Plan
June 2009
CMO. CAMDS personnel have been trained to report all incidents directly to the
CAMDS CMO, who then is responsible for notiffing the TOCDF Control Room in order
to activate the ERO.
9.2.1.5 ATLIC EmergencyNotification - As described in. 9.2.6. the orescribed communication
path for reporting ATLIC emereencies to the TOCDF Control Room is via the ATLIC
CON-OP. ATLIC oersonnel have bean trained to report all incidents directly to the
ATLIC CON-OP. who then is responsible for notiryins the TOCDF Control Room in
order to activate the ERO.
9.2.2
9,2.2.7
9.2.2.2
9.2.2.2.1
9.2.2.2.2
9.2.2.2.2.1
9.2.2.2.2.2
9.2.2.2.2.3
9.2.2.2'.2.4
Scene Responders
The Scene Responders are comprised of EG&G and EG&G-contracted (e.g._-,Battelle)
employees with the expertise to quickly respond to the scene of an event, assess the
situation, and promptly implement corrective and protective measures. This group is
modular in composition; therefore, responders can be mobilized based on need. The
organizational structure of Scene Responders is pattemed after the unified command and
control concepts of the Incident Comrnand System as specified in OSHA Regulation 29
CFR 1910.120. Scene Responders are led by the IC who directs and controls emergency
response activities at TOCDF and TOCDF-operated facilities, including CAMDS and
ATLIC. Res_ponse teams are activated by the IC, and the IC will establish the response
objectives. In a chemical agent event, the DCD OSC will establish rcsponse objectives
and inform the IC. The responsibilities of each scene response leader and advisor are as
follows:
Incident Commander (IC)lEmergency Coordinator
The Incident Commander (IC)/Emergency Coordinator during an emergency at TOCDF
and all TOCDF-operated facilities (including CAMDS) is the TOCDF Plant Shift
Manager. The alternate designee IC is the TOCDF Operations Shift Supervisor or
personnel certified as either the TOCDF Plant Shift Manager or the TOCDF Operations
Shift Supervisor. The IC is responsible for directing EG&G emergency response
operations. The IC will receive notification of an event in the Control Room. The IC will
determine whether the event is an incidental event or an emergency. If the event is an
emergency, the IC will decide personnel protective actions and determine which elements
of the Emergency Response Organization (ERO) to activate. The IC will then turn over
operation of the plant to the Operations Shift Supervisor and assume the role of IC for the
duration of the embrgency.
The IC will:
Ensure prompt notification of an emergency to pre-specified organizations.
Ensure effective mobilization of EG&G, EG&G-contractors, and outside responders and
resources.
Ensure the safety ofsite personnel and responders.
Ensure personn'el and responder accountability is maintained.
Attachment 9 - Page.Z5
9.2.2.2.2,9.r
9.2.2,2.2.9.2
9.2.2.2.2.t0
9.2.2'.2.2.1,0.r
9.2.2.2.2.70.2
9.2.2.2.2.11
contin-#;',J
June 2009
Establish response strategies, obj ectives, and priorities.
If appropriate, evacuate the facility (see Section 9.10.3.4).
Make the necessary notifications (see Section 9.7.1).
Mobilize personnel and ensures the proper PPE is provided.
Stop flow into the tank system and inspect to determine the cause of the release (see R315-
8-10 [40 CFR 264.196(a)], Sections 9.4.9 through 9.4.11, and Attachment 16 (Tank
Systems) of this Permit regarding spills and leakage from TOCDF_aOd Al'Uc-permitted
tanks, containers, and other regulated units (or Attachment 13 (Tank Systems) of the
CAMDS Permit (incorporated into this Permit as Attachment 28) regarding spills and
leakage from CAMDS-permitted tanks and containers).
Shut off pumps and closes inlet valves as appropriate.
If a valve, pipe, hose, or pump is leaking or spilling, isolate this equipment by closing the
appropriate valves.
Removes sufficient waste from the tank system within 24 hours after detection of leak to
reach a level where further release is prevented and tank inspection and repair can be
performed (see R315-8-10 [40 CFR 264.196(b)], Sections 9.4.9 through 9.4.11, alrLd
Attachment 16 (Tanks Systems) of this Permit (Attachment 13 (Tank Systems) of the
CAMDS Permit(incorporated into this Permit as Attachment 28) regarding spills and
leakage from tanks, containers, and other regulated units).
Transfers the contents to other tank(s), container(s), or an appropriate treatment process.
As appropriate, removes the tank or component in question from service until permanent
repairs can be made.
Conducts a visual inspection of the release and prevents further migration and removes
and properly disposes of any visible contamination (see R315-8-10 [40 CFR 264.196(c)),
Sections 9.4.9 through 9.4.11, and Attachment 16 (Tank Systems) of this Permit
(Attachment 13 (Tank Systems) of the CAMDS Peflmi(PenUq(incorporated into this
Permit as Attachment 28) regarding spills and leakage from tanks, containers, and other
regulated units).
9.2.2.2.2.11.1 Assemble the appropriate response equipment (i.e., absorbent material, empty drums,
overpacks. shovels, brooms, pumps, vacuum trucks, etc.)
9.2.2.2.2.11.2 Determine the most appropriate containment and clean-up methods; implements
appropriate containment procedures (i.e., earthen dikes, etc.).
g.2.2.2.2.11.3 Initiate clean-up and, directly or through communidation with spill response persorurel,
monitors the clean-up of the released material. Clean-up will be performed as soon as
possible, following detection of the release, to minimize any associated affects on human
health or the environment. Rele4pes to secondary containment systems will be cleaned-up
within 24 hours of detection. The released material will be transferred (e.g., via shovel,
Attachrnent 9 -Page26
TOCDF
ontingency Plan
pump, vacuum truck, absorbent, earth moving equipment, etc.) to a container(s) or other
tank(s) in good condition or to an appropriate treatment process.
g .2.2.2.2.11 .4 If the origin (and therefore the identity) of the released material is unknown, ensure that a
sample of the released material and/or the clean-up residues/solutions are obtained and
iuranges laboratory analysis.
9.2.2.2.2.11.5 Ensure that the released material, that is treated or has been placed into a container(s) or
tank(s) is managed in accordance with this Permit (e.g., stored in permitted container
storage area(s), stored in permitted tank(s), shipped offsite, thermally treated, etc.).
9.2.2.2.2.11.6 Fr.I" that, after clean-up is complete, the secondary containment system and all
equipment and PPE used during clean-up is decontaminated as necessary and PPE and
absorbent materials are restocked as appropriate.
9 .2.2.2.2.12 Develop and submit the appropriate reports required by R3 15-8-10 [40 CFR 264.196(d)]
and Section 9.8 of this Contingency Plan.
9.2.2.2.2.13 Ensure, tank systems are repaired or closed as appropriate (see R315-8-10 [40 CFR
26a.196(e)l). The repair methodology specified in the appropriate tank system
desigdfabrication standards (i.e., ASME Section VIII Division I, API 650, etc.) will be
followed. Attachment 10 (Closure Plan) of this Permit contains details regarding tank
system closure. See Sections 9.4.9 through 9.4.11, and Attachment 16 (Tank Systems) of
this Permit (Attachment 13 (Tank Systems) of the CAMDS Permit (incorporated into this
Permit as Attachment 28) regarding spills and leakage from tanks, containers, and other
regulated units.
9 .2.2.2.2.13 .l If the tank system is repaired and the repair was extensive, obtain and submit a
certification by an independent, qualified registered professional engineer that the repaired
system is capable of handling hazardous waste for the intended life of the system (see
R3ls-8-10 [40 CFR 26a.t96(e)]).
9.2.2.2.3 With advice and input from ERO members, the IC will:
9.2.2.2.3.1 Assess the emergency and its consequences.
g.2.2.2.3.2 Establish ahazardzone andprotectirre actions.
g.2.2.2.3.3 Develop a corrective action plan.
9.2.2.2.4 The IC will integrate non-EG&G responders such as firefighting and security services and
ensure that all parties are fully informed of events and actions occurring at the scene.
Upon termination of an emergency, the IC will make reentry and recovery
recommendations and assist with recovery operations.
9.2.2.2.5 The IC has the authority to commit all EG&G resources necessary to adequately
. implement any.response actions.
9.2.2.2.6 Table 9-2-1 identifies the ICs and Table 9-2-2 idertifres the AICs for TOCDF and
TocDF-operated facilities, including CAMDS and ATLIC.Or
Attachment 9 - Page27
TOCDF
Contingency Plan
June 2009
Table 9-2-l
EMERGBNCY C OORDINATORS
Incident Commanders
Position Name and Address Work Phone Home Phone
PLANT SHIFT MANAGER JAMES BREWER
167 McMichael Street
Grantsville, Utah 84029
(43s) 833-7700 (43s) 8 84-67 68
BURKLEATHAM
566 Walden Drive
Tooele, Utah 84074
(43s) 833 7700 (43s) 882-1 e1I
JAY TVEY
2692 West Ridgeline Road
Stocktoo, UT 84071
(43s) 833-7700 (43s) 830-s2s0
ROBERT PETERSEN
619 East 180 North
Tooele, Utah 8407 4
(43s) 833-7700 (43s) 833 -e7 s4
GARY C. SMITH
865 East 980 North
Tooele, Utah 84074
(43s) 83 3-7700 (43s) 843-01 8 1
SCOTT SORENSON
169 Millcreek Way
Tooele, Utah 84074
(43s) 833-7700 (43s) 882-4347
TROYH. WORTHEN
273 West Sky Court
Saratoga Springs, Utah
84045
(43s) 833-6722 (801) 33t-67t6
Table 9-2-2
ALTERNATE EMERGENCY COORDINATORS
Position Name and Address Work Phone Home Phone
CONTROLROOM
SUPERVISOR/
OPERATIONS
SUPERVISOR
ROBERT ANDERSON
10540 South Columbia Way
Sandy, Utah 84094
(43s) 8 33-7700 (801) s4s -8e73
DANIEL CURREY
4I9 South Bevan Way ;
Tooele, Utah 8407 4
(43s) 8 33-77 t6 (43s) 8 82-3840
MATTELWELL
103 East Main
Grantsville, Utah 84029
(43s) 8 33-7700 (43s) 8 84-60e3
KEITH EYRE
8441 Barnstable Road
West Jordan, Utah 84088
(43s) 833-6722 (8o r) 282-1 68s
JASON LARSEN
183 South Quirk
Grantsville, Utah 84029
(43s) 833-7700 (43s) 884-s 046
Attachment9-Page28
9.2.2.3
9,2,2.3,7.
9.2.2.4
9.2.2.4.1
9.2.2.5
9.2.2.5.7
TOCDF
Contingency Plan
June 2009
Scene Control Officer (SCO)
Immediately upon activation of any scene responder, the Scene Control Officer (SCO) will
report directly to the scene, take control of the activities of fnst responders, and then
coordinate the actions of all response teams upon their arrival. The SCO will conduct
evacuation ofall personnel from the hazard zone; coordinate first responder efforts;
control the spread of contamination; establish hazard zone perimeter control; determine
the appropriate level of PPE for response teams; establish a staging area for response
teams; designate the Personnel Decontamination Station (PDS) location; inform response
team leaders of the mission objectives and priorities; assess person el and equipment
requirements; ensure responder accountability is maintained; and coordinate the
evacuation of emergency responders from the site if necessary. The SCO will keep the IC
fully informed of scene events and actions, and ensure the safety and effective
coordination of assembled response teams. The SCO will take direction from and report
to the IC.
Safety Advisor
The Safety Advisor is responsible for identiffing and evaluating hazards, and ensuring the
safety of emergency operations. The Safety Advisor position is filled by the shift Safety
Representative. Immediately upon activation of any scene responder, the Safety Advisor
will report directly to the scene to provide safety assessment and advice. When activities
are judged by the Safety Advisor to be an IDLH condition and/or to involve an imminent
danger condition, the Safety Advisor has the authority to alter, suspend, or terminate those
activities and will inform the SCO andlor IC of any actions needed to correct these hazards
at the emergency scene. The Safety Advisor will ensure the appropriate level of PPE is
worn by responders; ensure pre-entrysafety checks are performed; ensure proper
surveillance of responders inside the hazard zone; and assess the adequacy of the hazard
zone perimeter and protective actions implemented.
Environmental Advisor
The Environmental Advispr is responsible for assessing the environmental consequences
of a hazardous material event; providing guidance to the SCO and/or IC on contamination
control, spill survey, and clean-up measures; and arranging for environmental sampling
and analysis. The Environmental Advisor position is filled by the shift Environmental
Table 9-2-2
ALTERNATE EMERGENCY COORDINATORS
Position Name and Address Work Phone Home Phone
DEVINLEMMON
3886 Sun Valley Drive
Grantsville, Utah 84029
(43s) 833-7700 (435) 8 84-1s23
RALPH MAESTAS
484 South 100 West
Tooele, Utah 84074
(43s) 8 33-7738 (43s) 8 82-63s0
ROBERT RALSTON
202 West 1900 North
Tooele, Utah 84074
(43s) 833-7sse (43s) 843 -07 4s
Attachrnent 9 -Page29
9,2.2.6
9.2.2.6.1
9.2.2,7
9.2.2.7 .l
9.2.2.8
9.2.2.8.7
9.2.2.9
9.2.2.9.1
TOCDF
Contingencyllan
Representative. Immediately upon notification of any hazardous material release, the
Environmental Advisor will report directly to the scene to assess environmental impacts
and provide advice on environmental matters. The Environmental Advisor will provide
advice and methods for keeping a spill and decontamination activities confined to initially
affected areas (under engineering controls, inside a building, etc.) to the extent reasonable.
The Environme,ntal Advisor will provide technical advice in the areas of spill cleanup,
property decontamination, and hazardous waste disposal.
Maintenance Superintendent
The Maintenance Superintendent will perform duties as directed in an ernergsncy.
HAZMAT Team Leader (HTL)
The HAZMAT Team Leader (HTL) is responsible for directing activities of the
HAZMAT Team. The HTL will obtain mission objectives from the SCO; assess the risks;
develop a HAZMAT entry plan; prescribe safety measures to be taken; ensure proper
equipment is used; brief en!ry and backup teams on the mission; perform entry readiness
checks; dispatch the entry teams; provide constant surveillance and guidance during entry
operations; direct portable air sampling for oxygen, combustible gas, and toxic vapor
levels as required; ensure contamination control and personnel decontamination
procedures are followed;maintain accountability of HAZMAT personnel; and obtain any
needed support for entry teams. The HTL will take direction from and report to the SCO.
Decon Team Leader (DTL)
The Decon Team Leader (DTL) is responsible for directing activities of the Decon Team
deployed to the scene. The DTL manages the setup and operation of the Personnel
Decontamination Station (PDS) at the scene. The Medical Clinician in Charge manages
the setup and operation of the PDS at the Medical Clinic. The DTL will obtain the PDS
location from the SCO; determine the extent of PDS setup needed; ensure the proper
decon solution and equipment are available; assign personnel and perform readiness
checks; direct the processing of contaminated personnel through the decon line; ensure the
PDS remains outside the hazard zone; minimize secondary contamination; monitor
personnel at the PDS for signs of illness/exposure; maintain accountability of Decon Team
personnel; obtain any needed support for decon activities; direct PDS shutdown and
cleanup; and ensure proper PDS waste disposal. The DTL will take direction from and
.,ePon to the SCO.
Paramedic Team Leader (PTL)
The Paramedic Team Leader (PTL) is responsible for directing activities of the Paramedic
Team and all outside medical teams at the scene. The PTL will obtain mission objectives
from the SCO; ensure proper PPE for medical personnel; assess the medical needs of the
event; establish a triage and treatriibnt area at the scene as required; advise other team
leaders on medical care and patient processing administered by their personnel (HAZMAT
entrants, deconners, etc.); ensure patients have been at least gross decontaminated prior to
transport; administer medical treatment; assess the need for further medical assistance and
transportation; ensure medical support for responders at the scene; and obtain medical
support through the Medical Clinician In Charge (MCIC) as needed. The PTL will take
Attachrnent9-Page30
9.2.2.10
9.2.2.10.7
9.2.2.1\
9.2.2.t1.1
9.2.2.12
9.2.2.12.r
TOCDF
Contingency?lan
direction from and report to the SCO for scene control matters and report to the MCIC for
medical treatrnent matters.
Medical Clinician In Charge (MCIC)
The Medical Clinician In Charge (MCIC) has overall responsibility for emergency
medical response. The MCIC is the most highly-trained medical person at the TOCDF
Medical Clinic at the time of an emergency. TOCDF is the primary medical care facility
forpetmtiel-agent related events at DCD
@. The MCIC is responsible for dispatching medical transport
vehicles and paramedics to the scene; authorizing administration of additional nerve agent
antidote irf ections as required (may also be authorized by paramedics); providing casualty
triage and treaknent instructions to paramedics on the scene; assuring the Clinic is staffed
and prepared to receive casualties; ensuring casualties have been adequately
decontaminated prior to treatment in the Clinic; managing personnel decontamination at
the Clinic; performing and directing emergency triage and treatment of casualties arriving
at the Clinic; requesting outside medical support directly from the DCD EOC via the
TOCDF Control Room and keeping the DCD EOC updated on casualty status and
medical response; directing activities of all outside medical teams at the Clinic; and
recording and tracking treatment provided to casualties at the scene, at the Clinic, and in
support facilities.
Rescue Team Leader (RTL)
The Rescue Team Leader is'responsible for directing activities of the Rescue Team in
performing confined space/technical rescue. The RTL and Rescue Team personnel are
also members of the HAZMAT Team. If the event involves HAZMAT response and
either confined space or technical rescue, the RTL will defer to the HAZMAT Team
Leader for matters involving HAZMAT operations (PPE, contamination control,
personnel decontamination, etc.). The RTL will obtain mission objectives from the SCO;
assess the risks; develop a rescue plan; prescribe safety measures to be taken; veriff that
no explosive atmosphere exits prior to any confined space entry; ensure proper PPE and
rigging systems for the rescue; brief rescue and backup teams on the mission; perform
rescue readiness checks; dispatch the rescue teams; provide constant surveillance and
guidance during the extraction; maintain accountability of rescue personnel; and obtain
any needed support for rescue teams. The RTL will take direction from and report to the
SCO.
CMA Shift Engineer
The CMA Shift Engineer will provide technical advice and guidance to the IC and Control
Room personnel, and perform CMA notifications. During an off-hours emergency
involving Contractor Management Advisory Team (CMAT) mobilization, the CMA Shift
Engineer will dispatch the CMA Shift Quality Assurance Specialist and Ammunition
Surveillance to the DCD EOC to act as a EG&G liaison and technical advisor pending
CMAT arrival.
Control Room9.2.3
Attachment 9 - Page 3l
9,2.3.1
9.2.3.2
9.2.3.2.1
9.2.3.2.2
9.2.3.2.3
TOCDF
t-t"'rn?iJ8;
The Control Room for TOCDF plant operations is located in the MDB. The Control
Room is desigued with engineering controls to isolate it from the effects of potential
hazards. It contains centralized monitoring capability and emergency communications
systems including the 911 emergency reporting line, the site-wide public address system
for broadcast of emergency notification and instructions, and base radio stations for
emergency communications. It also provides centralized control and monitoring of critical
plant systems and equipment. The Control Room is staffed on a 24-hour basis. The
Control Roorn, comprised of shift Control Room Operators, is directed by the Plant Shift
Manager during normal shift operations. The Plant Shift Manager will delegate direction
of the Control Room to the Control Room Supervisor in an emergency event. The Control
Room Supervisor will then be the Control Room group leader and be responsible for all.
. TOCDF and TOCDF-operated facility (including CAMDS and ATLIC) emergency
notification; protective action instructions; activation of the Emergency Response
Organization; emergency communications; and monitoring and controlling plant
processes, systerns, and equipmeirt to ensure personnel safety and to mitigate damage to
facilities and equipment. The role of the CAMDS CMO and the ATLIC CON-OP during
the incident is primarily notification of the €,44'{D$incident to the TOCDF Control
Room.
Assistant Incident Commander (AlC)/Alternate Emergency Coordinatot'
The Operations Shift Supervisor is the Assistant IC (AIC). The Operations Shift
Supervisor may be designated the IC in any event by the Plant Shift Manager or will
automatically assume the role of IC in the Plant Shift Manager's absence. If the
Operations Shift Supervisor is designated the IC, he will then assume command of all
EG&G emergency response operations and report to the EOC for the duration of the
emergency. If the Operations Shift Supervisor assumes the role of IC, he will assign a
certified Operator to assume the Operations Shift Supervisor's duties.
The Operations Shift Supervisor is responsible for monitoring emergency alarms and
communication devices; providing initial emergency instructions and guidance to first
responders at the scene; rapidly notiffing required emergency services such as firefighting,
medical, and security; alerting and notifring affected personnel of the emergency and
protective actions; deploying responders to the scene and emergency facilities such as the
Clinic and DCD EOC; promptly notiffing DCD and EG&G management; establishing a
Control Room communications and information center for EG&G emergency response;
initiating rapid entry and exit procedures for areas under surety controls; tracking
accountability ofsite personnel and responders; acquiring resources to support scene
operations; and documenting and tracking emergency events and actions. The above
Operations Shift Supervisor responsibilities are carried out by the Control Room
Operators, who are pre-assigned to certain emergency tasks at the start of their shift in
order to maximize response effectiveness.
ln addition, the Operations Shift Supervisor will assess any malfunction or damage to
plant systems, equipment, or facilities; initiate remedial actions such as shutdown, reroute,
or repair; identifo hazardous locations; anticipate emergency impact on associated systems
3 To be consistent with the TOCDF/EG&G Emergency Response Plan, the title of Altemate Incident Commander
(AIC) is used instead of Alternate Emergency Coordinator.
Attachrnent 9 -Page32
9.2,3.2.4
9.2.3.3
9 .2.3.3. 1
9.2.3.4
9.2.3.4.1
9.2.4
9.2.4.1
9.2.4.2
9.2.4.2.t
TOCDF
a*rtrt.*?i#;
or equipment; take action to mitigate damage; and provide technical advice and cautions
for response teams working on plant systems.
During an Emergency, the AIC in consultation with the CMA Shift Engineer, if available,
has the authority to commit all EG&G resources necessary to adequately implement any
response actions.
Accountability Coordinator
The Accountability Coordinator is responsible for managing muster area operations during
an emergency requiring site-wide evacuation and coordinating personnel accountability
during an emergency involving site-wide, in-place sheltering. Responder accountability
such as HAZMAT, decon, and medical personnel is coordinated by the SCO at the event
sce,ne. During site-wide evacuation, the Accountability Coordinator will manage muster
area operations; report building sweep and personnel accountability results to the Control
Room; maintain evacuee control and personnel accountability; transmit emergency
information between the Control Room and evacuees; and ensure the safety of assernbled
evacuees. During site-wide in-place sheltering, the Accountability Coordinator will report
persormel accountability results to Control Room. The Accountability Coordinator will
take direction from and report to the IC.
Sweepers
Sweepers are responsible for assuring that all buildings and areas under an evacuation
directive are clear ofpersonnel and reporting results to the appropriate accountability 1ead.
Sweepers are designated by building. Sweepers will perform their duties at the time of
evacuation. Sweepers are the last persons out of their assigned building and will ensure
the building is clear of personnel. The Sweeper will not enter an area of danger. If there
is a hazardous condition, the Sweeper will report the area of the building that could not be
swept. The IC may arange for the search and rescue of personnel thought to be in the
area of danger. The Sweeper will normally report building sweep results to the
Accountability Coordinator or Building Custodian.
Contractor Management Advisory Team (CMAT)
Pre-designated responsibilities have been assigned to each member of the Contractor
Management Advisory Team (CMAT). The responsibilities for each MAT position are as
follows:
General Manager
During an emergency, the EG&G General Manager is responsible for the health and safety
of all personnel at TOCDF and TOCDF-operated facilities and for the overall direction of
the EG&G emergency response effort. The General Manager or designee will ensure
prompt, appropriate, and effective implementation of this plan in order to minimize the
consequences of an emergency. The General Manager will review emergency response
strategies, objectives, and priorities for appropriateness; notiff EG&G and their
subcontractors (e.g., Battelle) corporate headquarters after DCD Commander concurrence;
track casualty status and care; ensure proper notification to families of EG&G and
subcontractor casualties after DCD Commander concurence; support DCD public affairs
Attachment9-Page33
9.2.4.3
9.2.4.3.1
9.2.4.4
9.2.4.4.1
TOCDF
Contingency?lan
activities; ensure EG&G and subcontractor families are kept informed of personnel status;
review news media reports for accuracy; monitor ongoing EG&G response actions;
determine the need for additional personnel to support the CMAT; terminate EG&G
emergency operations when appropriate; initiate an immediate critique of response
effectiveness; and initiate coordinated recovery planning and operations. The General
Manager will also work with and advise the DCD EOC Director of Operations on TOCDF
and TOCDF-operated facility issues.
CMA TOCDF Site Project Manager
The CMA TOCDF Site Project Manager is responsible for monitoring overall EG&G
response efflectiveness, ensuring coordinated interface between EG&G and outside
organizations, and providing technical and facility design basis information. The CMA
TOCDF Site Project Manager will ensure CMA is notified and ke,pt informed of
emergency events and activities; confirm notification of offsite agencies required by
regulation or administrative agreement; ensure effective coordination between EG&G and
outside organizations; ensure emergency terms of TOCDF Memoranda of Understanding
(MOUs) are upheld; assist in developing solutions to response problems; mobilize CMA,
SAIC, and other government resources as needed to support CMAT activities; ensure
proper notification to families of any government casualties after DCD Commander
concrurence; coordinate EG&G public affairs activities and ensure integration with DCD
efforts; ensure govemment families are kept informed of persorurel status; review and
approve TOCDF and TOCDF-operated facility-related press releases and briefing sheets;
and review news media reports for accuracy. The CMA Project Manager will also work
with and advise the DCD EOC Director of Operations on TOCDF and TOCDF-operated
facility issues.
EG&G Deputy General Managers or Designee
The EG&G Deputy General Managers are responsible for providing CMAT support to
TOCDF and DCD, facilitating information flow and resource support between EG&G and
DCD, and advising DCD EOC staff on plant operations and technical matters. The
Deputy General Managers will assist with CMAT mobilization and operations; represent
EG&G operational needs and interests at the EOC; advise EOC staff on plant systems and
other technical matters; track casualty status and care; closely monitor ongoing EG&G
response activities including responder actions and personnel protective actions; assist the
Control Room in developing solutions to response problems; identiff and coordinate
delivery of CMAT support; mobilize additional resources to support the CMAT as
required; arrange support for extended response operations such as food and relief; assist
the EG&G General Manager in determining emergency operations termination; and assist
the EG&G General Manager in implementing recovery operations. The EG&G Deputy
General Managers will work with and advise the DCD OSC on TOCDF and TOCDF-
operated facility issues.
The EG&G Deputy General M*ug"., delegate reviews and amendments to the
Contingency Plan, if necessary, whenever: (a) The facility RCRA permit is revised; (b)
The Contingency Plan fails in an emergency in any way; (c) The facility changes in its
design, construction, operation, maintenance, or other circumstances in such a way that
materially increases the potential for fires, explosions, or releases of hazardous waste or
9.2.4.4.2
Attachment 9 -Page34
9.2,4.5
9.2,4.5.1
9.2.4.6
9.2.4.7
9.2.4.8
TOCDF
Contingency PLan
hazardous waste constituents, or changes the response necessary in an emergency; (d) The
list of Incident Commanders changes; or (e) The list of emergency equipment changes.
CMA Government Shift Representative (GSR)
During an off-hours emergency involving Contractor Management Advisory Team
(CMAT) mobilization, the CMA Government Shift Representative (GSR) will report to
the DCD EOC to serve as liaison between DCD and EG&G and a technical advisor to
EOC staff until the CMAT arrives at the EOC. The GSR will facilitate information flow
and resource support between EG&G and DCD; represent EG&G response needs and
interests at the EOC; and advise EOC staff on plant systems and other technical matters.
The GSR will work with and advise the DCD OSC (or altemate) on TOCDF and TOCDF-
operated facility issues until the CMAT arrives. The GSR will then tum over his
responsibilities to the EG&G General Manager and take direction from the CMA Project
Manager.
The CMAT is comprised of the EG&G General Manager, the EG&G DeputyGeneral
Manager for Plant Operations, the EG&G Deputy General Manager for Risk Management,
and the CMA TOCDF Site Project Manager (or their alternates). The EG&G General
Manager is ultimately responsible for the overall EG&G emergency response effort and
serves as the head of the CMAT. The CMA TOCDF Site Project Manager provides a
government oversight function. The Deputy General Managers provide technical
expertise to DCD EOC personnel relative to TOCDF and TOCDF-operated facility
operations. In a CAIRA event in which the DCD Commander assumes responsibility for
the overall response, CMAT members will serve as liaisons and technical advisors to DCD
EOC staff and coordinate closely with the EOC Director of Operations and the OSC as
necessary.
The CMAT serves as an information and advisory group to DCD EOC staff and represents
TOCDF needs and interests at the EOC. The CMAT will confirm completion of required
notifications; ensure effective information flow between EG&G emergency facilities and
the EOC; advise EOC staff on plant technical matters; review emergency response
strategies, objectives, and priorities; monitor EG&G response and provide
recommendations as appropriate; ensure adequate resource support to EG&G; track
casualty status and care; complete corporate and family notifications; assist the Control
Room in solving operational problems; support DCD public affairs activities; arange
support for extended operations such as food and relief; terminate EG&G emergency
operations; and initiate coordinated recovery planning and operations. The CMAT will
not direct actions at the scene or at any emergency facilities but will ensure the overall
plan of action is appropriate and that primary objectives are kept in focus.
The IC makes the decision to activate the CMAT. The IC will automatically mobilizethe
CMAT whenever DCD activates its EOC due to an event et TOCDF or TOCDF-operated
facility. For EG&G-response pu{poses, the EOC is considered activated whenever the
OSC is directing CAIRA operations fiom it. The IC, at his discretion, may mobilize the
CMAT to the EOC or another location based on other considerations. During nbrmal
working hours, CMAT members are mobilized from work locations near the EOC. Off-
hours, CMAT members are mobilized from home locations some distance away, in which
case the onsite CMA Government Shift Representative are dispatched to the EOC to
provide plant technical information and represent EG&G needs until the CMAT arrives.
Attachrnent9-Page35
9.2.4.9
9 .2.4.10
9.2.5
9 ,2.5.1
9.2.5.2
9.2.s.3
9 .2.s.s
TOCDF
Contingency Plan
June 2009
Upon arrival, the CMAT will augment and integrate into EOC staffing as required. As the
event develops, additional EG&G expertise may be required at the EOC or some other
location, e.g., plant systems specialists or special working groups may be needed to
analyze specific problems and recommend solutions. The activation of additional EG&G
personnel in support of the CMAT is at the discretion of the General Manager.
During an emergency, the CMAT will continue to administer normal work functions not
impacted by the emergency.
CAMDS-Specific Emergency Notification
Initial reports of CAMDS emergency events will be from the discovering CAMDS
personnel to the CMO, who will then notifr the TOCDF Control Room for ERO
activation. CAMDS emergency communications are performed by standard telephone,
cellular phone, radio, and face-to-face contact. Upon discovery of an emergency event at
CAMDS, site personnel are instructed to call4400 from a site phone that will connect
them to the CAMDS CMO.
The CAMDS Plant Shift Manager will receive event notification from the CMO. He will
determine whether the event is an incidental event or an emergency. If the event is an
emergency, he will decide immediate personnel protective actions for CAMDS site
personnel, and then notif,i the TOCDF Control Room of the situation. The CAMDS Plant
Shift Manager will request resources from the TOCDF Control Room to support
emergency response actions at the CAMDS facility. The CAMDS Plant Shift Manager
will then delegate operation of the CAMDS site to the CMO Operator for the duration of
the emergency and assume responsibilities as assigned by the IC (e.g., advisor to the
sco).
Upon a declared emergency at CAMDS, the CAMDS Plant Shift Manager will select a
POC from the CAMDS staff to meet the EG&G Emergency Response Organization at the
CAMDS Command Post to ensure a safe entry route and advise a set-up location.
The CAMDS Plant Shift Manager will ensure prompt notification of an emergency to pre-
specified organizations; ensure effective mobilization of EG&G and outside responders
and resources; ensure the safety ofsite personnel and responders; ensure personnel and
responder accountability is maintained; and aid the SCO in establishing response
strategies, objectives, and priorities. Upon termination of an emergency, the CAMDS
Plant Shift N{anager will make re-entry and recovery recommendations to the IC and assist
with recovery operations.
ln the event of an emergency, CAMDS will receive support from EG&G Emergency
Response Teams. CAMDS site employees are trained to OSHA 'awareness level' to
recognize and report emergency conditions. Additionally all CAMDS site personnel are
trained in CPR and use of an AED.
9.2.5.4
9.2.6 ATLIC-Soecific EmereencyNotification
9.2.6.1 lnitial reports of ATLIC ernergenc), events will be from the discovering ATLIC personnel
to the CON-OP. who will then notifu the TOCDF Control Room for ERO activation.
Attachment9-Page36
TOCDF
Contingency Plan
June 2009
ATLIC smersencv communications are performed by standard telephone. cellular phone.
radio. and face-to-face contact. Upon discovery of an emergency event at ATLIC. site
personnel are instructed to call the ATLIC CON-OP from a site phone.
9.2.6.2 The ATLIC Shift Supervisor will receive event notification from the CON-OP. He will
determine whether the event is an incidental event or an emerEency. If the event is an
emergency. he will decide immediate personnel protective actions for ATLIC site
personnel. and then noti$ the TOCDF Control Room of the situation. The ATLIC Shift
Supervisor will request resources from the TOCDF Control Room to support emergency
response actions at the ATLIC.
9.2.6.3 Upon a declared emereency at ATLIC. the ATLIC Shift Supervisor will select a POC
from the ATLIC staffto meet the EG&G Emergency Response Organization at the ATLIC
Designated Entry Point to ensure a safe entry route and advise a set-up location.
9.2.6.4 The ATLIC Shift Supervisor will ensure Eompt notification of an emergency to pre-
specified organizations: ensure effective mobilization of EG&G and outside responders
and resources: ensure the safe8 ofsite personnel and responders: ensure personnel and
resoonder accountability is maintained: and aid the SCO in establishins response
strateeies. objectives. and priorities. Uoon termination of an emergency. the ATLIC Shift
Suoervisor will make re-entry and recovery recommendations to the IC and assist with
recovery operations.
9.2.6.5 In the event of an emeree,ncy. ATLIC will receive support from EG&G Emereenc],
Resnonse Teams. ATLIC site employees are trained to OSIIA 'awareness level' to
recognize and report ernergency conditions. Additionally aII ATLIC site personnel are
trained in CPR and use of an AED
9.3
9.3.1
9,3,2
9.3.2.1
9.3.2.2
9.3.2.2.1
TMPLEMENTATTON [R3 1s-8-4.2(b)l
The purpose of this section is to establish guidelines for the orderly reporting and handling
of emergency situations, which occur or could foreseeably develop at the TOCDF site or
TOCDF-operated facilities. Due to the nature of materials handled at TOCDF and
TOCDF-operated facilities, this plan may be implemented as a precautionary measure
during routine operations. This Contingency Plan is implemented immediately in the
event that a fire, explosion, or agent or non-agent release occurs which could threaten
human health or the environment.
Fire or Explosion Incident
For the pupose of this section, fire means a fire in a chemical agent, oil, or hazardous
material/waste storage, transportation, treatment, or work area. Explosion means an
explosion in a chemical agent, oil, or hazardous material/waste storage, transportation,
treatment, or work area.
The Contingency Plan is implemented due to fire or explosion if:
The event causes the release of toxic fumes.
Attachment9 -Page37
9.3.2.2.2
9,3.2.2.3
9.3.2.2.4
9.3.2.2.5
9.3.2.2.5.1
9,3.2.2.5.2
9.3.2,2.5.3
9,3.2.2.6
9.3,2.3
9.3.3
9.3.3. 1
TOCDF
Contingency Plan
The fire spreads and could possibly ignite materials at other locations on site, or could
cause heat-induced leaks or explosions.
The fire could possibly spread to offsite locations.
The use of fire suppressant, either chemicals or water, could result in contaminated runoff.
The explosion has or could:
Result in danger from flying fragments or shock waves,
Ignite other materials at the facility,
Release toxic matErials.
The fire or explosion endangers human health or the environment for any other reason.
In the event that a fre and/or explosio:r has occurred, follow Section 9.4.1.
Agent or Non-Agent Release
For the purpose of this plan, agent release means the release of chemical agent to the
environment outside of closed systems, facilities, or devices (e.g., lab hoods, glove-box,
munitions and bulk containers) exceeding or predicted to exceed the agent exposure limits
listed in Table 9-3-1. This includes release of any nature resulting in personnel exhibiting
clinical signs or symptoms of agent exposure. Any potential release exceeding the agent
exposure limits from a stack, which cannot be confirmed or non-confirmed withn24
hours, is also agent release. Non-agent release means release of oil, hazardous
material/waste or hazardous waste constituents. Release means any unplanned sudden or
non-sudden release to air, soil, or surface water at the facility.
The Contingency Plan is implemented due to a spill or material release if:
t
-'
Attachment9-Page38
Table 9-3-1
AGENT EXPOSTIRE LIMITS AND AGENT STACK LIMITS (me/m3)
GA GB Lewisite VX H/IIDIIJT
12 hour W?LI 0.00002 0.00002 0.003 0.0000006 0.00027
24-hr GPLz 0.000001 0.000001 0.003 0.0000006 12 hour GPL
0.00002
SELJ 0.0003 0.0003 0.003 0.0003 0.03
STEL (fifteen
minute TWA)
0.0001 0.0001 0.003 0.00001 0.003
VSL (single-cycle)0.0001 0.0001 0.003 0.00001 0.003
' Unmasked agent worker l2-hour Worker Population Limit.
2 Non-agent worker/General Population (GP L) lz-hour time weighted average.
3 Sorr.e Emission Limit.
9.3.3.2
9.3.3.2.1
9.3.3.2.2
9.3.3.2.3
9.3.3.2.4
9.3.3.3
9 .3 .3.3. 1
9.3.3.3.2
9.3.3.3.3
9.3.3.4
9.3.4
9 .3 .4.1
9.4
9.4.1
9.4.1 .1
9.4.1 .1 .1
TOCDF
Contingency?lan
The spill could release toxic or flamrnable liquids or vapors outside of engineering
controls or could cause a fire or gas explosionhazard.
The spill could result in offsite or onsite soil, groundwater, or surface water
contamination.
The spili constitutes a release of a Reportable Quantity (RQ) of a hazardous substance
under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA).
The spill endangers human health or the environment for any other reasons.
The Contingency Plan is implemented due to an agent spill or release if:
Observation of an age,nt spill, leaking vapor, or mustard (garlic) odor outside of
engineering controls.
Agent signs and/or symptoms in personnel are observed.
Agent is released to the environment, exceeding source emissions limits.
ln the event that a spill or material release has occurred, follow section 9.4.1.
Decision Process
A logic diagram of typical initial response activities leading to implementation of the
Contingency Plan is shown in Figure 9-6-1. Should the incident be of a minor or
controllable nature (i.e., it presents no potential hazard to human health or the
environment), the IC will not implement the Contingency Plan but will complete the
necessary reporting per section 9.8.
EMERGENCY RESPONSE PROCEDT RES [R315-8-4.7]
Notifi cation [R3 15-8-4.7(a)l
Notification and Mobilization Overview
The ability to quickly alert and notifu personnel during an emergency event is critical.
Site personnel and emergency responders must be informed in a timely manner to be able
to initiate emergency response actions and implement protective actions. Twenty-four
hour reporting will be adhered to as required by Condition I.U. EG&G will also send all
other required reports, notifications, and submissions as required by Condition I.AA.2. to
the Executive Secretary and the EPA Region VIII as required by Condition I.AA.3.
At TOCDF and TOCDF-operated facilities, emergency notifications are performed by the
TOCDF Control Room. Emergency conditions at TOCDF or TOCDF-operated facilities
are most commonly indicated by system alarms sounding in the Control Room oi by first
responders at the event scene calling information into the Control Room (e.g., from the
CAMDS CMO. ATLIC CEE or Area l0 Igloo
Control Point). AIl TOCDF alarms as well as the TOCDF-operated igloo ACAMS are
9.4.1 .1 .2
Attachment9-Page39
9 .4.1 .l .3
9.4.1 .l .4
9 .4.1 .1 .5
9.4.1.1.6
9.4.1 .2
9.4.1 .2.1
TOCDF
Contingency Plan
June 2009
centrally monitored in the Control Room; therefore, Control Room operators will often be
alvare of abnormal or emergency events as they occur. For the MDB, the Conkol Room
has visual monitors as well as agent and other alarms. The Control Room also monitors
TOCDF plant systems and are therefore aware of which elements of a system may not be
functioning properly. Because of their monitoring capability, the Control Room is most
likely to notiff personnel of an emergency or abnormal event based on direct and
immediate input. First responder reports are the second most frequent means of event
notification. All TOCDF personnel have been trained to call the Control Room when they
recognize an emergency situation. No CAMDS or ATLIC alarms alert the control room
directly; CAMDS persorurel have been trained to call the CMO when theyrecognize an
emergency situation at CAMDS, who will then notiff the TOCDF CON. Likewise.
ATLIC personnel have besn trained to call the CON-OP wh€n they recosdze an
emersency situation at ATLIC. who will then notift the TOCDF CON. The Control
Room can be reached by telephone or by hand-held radio at the following numbers:
o Emergency (non-cellular) Telephone - Call 911.
. Telephone-[phone].
Control Room C.ellular Telephone - [phone].
For reporting CAMDS site emergencies to the CMO, extension 4400 form a site
phone or [phone] from a cellular phone will be used. The CMO will
notifu the TOCDF Control Room for possible ERO activation.
For reoortin 11 the CON-OP. ext
ite nhone or (4 llular ohone will
will noti& the TOCDF Control Room for possible ERO activation.
The Control Room, which is staffed and operational24 hours a day,7 days a week,
provides TOCDF and TOCDF-operated facilities with a 24-hotr notification capability.
They receive alarms and first responder reports and perform all further notifications
required.
Control Room personnel record information provided by the caller on an Event Report
form. The Control Room questions the caller to ensure all essential event information is
obtained. The Control Room uses the Event Report form as the basis for all notifications.
Emergency event notifications are made to alert site personnel and mobilize emergency
responders, including DCD support. Emergency notifications to off-post authorities are
made via the DCD Emergency Operations Center (EOC). It is the responsibility of DCD
to notifr the public, as appropriate.
Notifications will serve to alert personnel that an emergency situation exists and provide
specific instructions on required protective actions to be implemented.
Personnel Notification
The ability to quickly direct personnel from a danger area to a safe area and prevent offsite
personnel from traveling into a danger area is vitally important. EG&G has a system in
Attachment9-Page40
9.4.1.2.2
9.4.1 .2.2.7
9.4.r.2.2.2
9.4.r.2.2.3
o
9.4.1 .2.2.4
9.4.1 .2.3
9.4.1 .2.3.1
TOCDF
Contingency?lan
place for promptly notifuing both onsite and offsite personnel of an emergency at TOCDF
or any of the TOCDF-operated facilities.
Site Personnel
The TOCDF site-wide public address system is used to notiff TOCDF personnel of an
emergency. The system simultaneously reaches personnel inside TOCDF buildings, as
well as those outdoors. The system is capable of providing both an alert signal and an
emergency message throughout the site. CAMDS also possesses a CAMDS-wide public
address system for notification of CAMDS personnel. ATLIC also possess an ATLIC-
wide public address system for notification of ATLIC personnel.
The alert signal varies according to the type of event and action necessary. A warbler tone
alerts persorurel to immediate$ mask and await emergency instructions. A steady tone
alerts personnel to evacuate to the muster area and mask if directed by the TOCDFControl
Room.ATLIC CCEE or CAMDS CMO. A repetitive yelping tone alerts personnel in the
TOCDF MDB to mask and evacuate; Whenever an agent alarm is activated, lights
installed in the MDB begin flashing to alert personnel in high-noise areas of an emergency
event. For a non-agent emergency, the phrase "Attention, all site personnel" is broadcast
as the alert signal, which prompts personnel to listen for an important follow-on message.
An emergency message will quickly follow the alert signal to notifr personnel of
emergency events and, if necessary, provide protective action instructions. Instructional
messages are clear and concise. They will contain the information necessary for personnel
to protect themselves. Sheltering messages will include instructions on how to maximize
protection when sheltering. Evacuation instructions will include, at a minimum:
Hazard t1pe.
Hazard location.
Danger areas to avoid.
Muster area.
Best path of travel.
Evacuation instructions will contain familiar terms and landmarks and be broadcast
initially at least two times, then periodically repeated.
Public Address System
The TOCDF;\TUQ and CAMDS public address systern consists of a signal generator,
microphone, power amplifiers, and numerous loudspeakers installed throughout occupied
buildings and outdoor areas across the site. The TOCDFTIsLIILIC system is on twin-
diesel generator backup power and a UPS system. The CAMDS system is on diesel
generator backup power. Emergency use and activation of the TOCDF PA system is
controlled by Control Room operators. the ATLIC PA system is contrc
OP and the CAMDS PA system is controlled by CMO operators. The agent alarm and
Attachrnent 9 - Page 4l
9.4.t.2.3.2
9.4.1 .2.3.3
9.4.1 .2.4
9.4.1 .2.4.1
9.4.1 .2.4.2
TOCDFt-t*'r"*?i#;
evacuation alarm switches and the emergency microphone are also located there. When
switched on, alarm signal and microphone messages override any other PA use.
In the event of microphone failure, a standard telephone can be used to make TOCDF site-
wide or CAMDS site emergency announcements. Proper PA system functioning can be
verified inside the Control Room and CMO by monitoring messages over Control Room
and CMO loudspeakers. If the PA system fails during an emergency, radios and standard
phones are used to dispatch nrnners to affected areas to make emergency announcements.
Emergency components of the TOCDF-AIIIC and CAMDS PA system are tested
weekly. During each test, the agent alarm and evacuation alarm are sounded, along with a
test message.
Offsiie Personnel
Offsite TOCDF-operated facility (e.g., CAMDS, ATLIC. Area 10, etc.) personnel will be
notified ofan event on site in order to provide any off-site protective actions required and
prevent offsite persorurel from inadvertently traveling into a danger area prior to access
control being established. The TOCDF Control Room will notiff DCD EOC, who will
activate the warning lights along the roads leading to TOCDF, CAMDS-+ndATUCe4d
Area l0 as necessary. When the flashing lights are on, no personnel mayproceed past the
lights without their masks donned. Prompt notification to nearby offsite locations will also
prevent outside personnel from adding to the problem. Offsite locations to be notified of
all emergencies involving site-wide protective action include:
o DCDEOC
Chemical Assessment Laboratory (CAL)
Receiving Warehouse and Transfer Yard
Stark Road Office
Area 2 Warehouses
Area 10 Secondary Waste Facility
CAMDS
ATLIC
Notification of DCD personnel is performed bythe EOC. EG&G notification of the EOC
is described below. The CAL, Receiving, and the Stark Road Office will be notified of an
emergency on site by standard phone. The Control Room will inform these locations of
the emergency and any offsite protective actions required. The Control Room will also
advise the sites to keep offsite personriel away from the TOCDF or TOCDF-operated
facility; and, if site-wide sheltering is in effect, to instruct site personnel visiting their
o
Attachment9 -Page42
facility to phone their supervisor for accountability pu{poses.
Area 2 carry a cellular phone and will be notified by phone.
If an emergency occurs at any of the aboveJisted offsite locations, notification to the
TOCDF Control Room may be accomplished using the same methods described above. In
this situation, the CAL, Receiving, StarkRoad Office, Area 10, ATLIC and CAMDS will
promptly notiff the TOCDF Control Room of an emergency at their location. ln the event
of an emergency at Area2,TOCDF personnel working there will report it to the Control
Roomusingacellularphoneorhandheldradio. Asdiscussedlrl.9.2.5,anemergency
event at the CAMDS location is initially reported to the CMO by site phone extension
4400 or cellular telephone using [phone]. An emergency evbnt at the ATLIC
location is initially reportd lp.Itre CON-OP by site phone extension rc or cellular
teleohone usins (T35) 833-m.
DCD Installation
The Control Room will notifr the EOC of all TOCDF and TOCDF-operated facility
emergedcies and chemical events using the EOC hotline phone, with standard phone and
DCD radio as backup methods. Chemical events are defined in detail in Section 4,
Definitions, of the DCD CAIRA Plan (current plan maintained on site). It is understood
that within 10 minutes from initial confirmed detection of an actual or likely chemical
agent release at the DCD installation, the DCD Commander or designee must report the
event to the Tooele County Sheriff Dispatch Center. The Control Room shall therefore
report all events immediately upon discovery to the EOC.
EG&G Management
EG&G senior management has an interest in any emergency event occurring in an area
under EG&G control. The Control Room will promptly notifu EG&G senior management
of an emergency. At a minimum, the following managers or designees will be notified of
all emergencies at TOCDF or TOCDF-operated facilities:
General Manager
Deputy General Manager for Risk Management and Technical Support
Operations and Maintenance Manager
CMA $hift Engineer
CAMDS Closure Manager
o Operations Manager for ATLIC
TOCDF
Contingency Plan
June 2009
EG&G personnel visiting
9.4.r.2.4.3
9.4.1 .2.5
9.4.1 .2.5.1
9.4.1 .2.6
9.4.1 .2.6.1
9.4.1 .2.6.2
9.4.1 .3
9 .4.1 .3. 1
If the IC decides to mobilize the Contractor Management Advisory Team, the Control
Room will notifu CMAT members.
Emergency Responder Notification
Scene Response Teams
Attachment9 -Page43
9.4.1.3.1.1
9.4.1 .3.2
9.4,1.3.2.1
9,4.1 .3 .2.2
9.4.1 .3.2.3
9 .4. 1 .3.3
9 .4. 1 .3.3. 1
9.4.1 .4
9 .4.t .4.1
9.4,2
9.4.2.1
9.4.2.t.1
TOCDF
Contingency Plan
June 2009
EG&G scene response tealns comprised of TocDF-stationed employees will be notified
of an onsite or offsite emergencyvia the TOCDF's site PA system. HAZMAT, Decon,
and Paramedic T-eams are on site24 hours a day,7 days a week. A verbal PA
announcement is made to EG&G response personnel to mobilize or stand by. If the
HAZMAT and Decon Teams are mobilized, the HAZMAT Team Leader and Decon
Team Leader will contact the Control Room for information and response confirmation.
The Clinic is notified using the Clinic hotline phone.
DCD Primary Response Organizations
DCD Fire Station on the DCD installation will be notified of a TOCDF or TOCDF-
operated facility emergency by the Control Room using a standard phone. The backup
means of notification to the DCD Fire Station is by cellular telephone.
The Control Room will notifythe DCD Site Security Control Center (SSCC) using a
standard phone. The backup means of notification to the SSCC is by DCD radio.
TOCDF Entry Control Facility (ECF) personnel will be alerted to an emergency event
when site personnel are notified over the site PA system. ECF personnel will be
mobilized by the SSCC.
For all TOCDF and TOCDF-operated facility emergency events, the Control Room will
contact the DCD Emergency Operations Center (EOC) via hotline telephone, with
standard phone as backup, to provide initial alert and request assistance as necessary.
Contractor Management Advisory Team
During normal working hours for members of the Contractor Management Advisory Team
(CMAT), the CMAT will be alerted by the Control Room via the public address system
and standard telephones. Off-hours, standard telephone will be the primary means of
notifying the CMAT with cellular phone as the backup.
HAZMAT Release Reporting
For any emergency event requiring HAZMAT release reporting, the Control Room will
notiff the DCD Emergency Operations Center and the CMA Shift Engineer, and provide a
copy of the Event Report. All reporting to Army, local, State, and Federal agencies will
be handled by DCD and the Environmental Department.
Identification of Hazardous Materials [R3 15-8-4.7(b)]
Identification of Hazardous Materials Overview
As soon as possible, the IC will determine the character, source, and extent of any released
materials by visual inspection and with reference to available information such as
manifests, sample analyses, waste profile sheets, Material Safety Data Sheets (MSDS),
and other available sources of information.
lnitial identification includes the following parameters:9.4.2.1 .2
Attachment9 -Page44
9.4.2.1 .2.1
9.4.2.1 .2.2
9.4.2.2
9.4.2.2.1
9.4.2.2.2
9.4.2.2.3
9.4.2.2.4
TOCDFt*t*'ra?#3;
Origm of the release
Condition of the source (e.g., repairable leak, uncontrollable leak, easily moved,
unmovable, etc.)
Physical state of the spill (e.g., granular, liquid, gas)
Odor, if noticed
Color of material and
Noticeable reactions (e.g., fuming, flaming, or gas evolution).
After the materials have been identified to the fullest extent possible, the IC assesses the
possible hazards to human health and the environment in accordance with Section 9.4.3 of
the Contingency Plan.
Hazardous Materials at TOCDF and TOCDF-operated Facilities
Hazardous materials stored and used at TOCDF and TOCDF-operated facilities that may
be involved in an emergency fall into two major categories: Industrial Chemicals and
Chemical Agents.
Industrial chemicals are handled through inventory control. The control room has access
to information on all chemicals through Material Safety Data Sheet (MSDS) records kept
on-site. Control room personnel will inform the IC of any chemicals involved in a spill or
release. Bulk chemicals stored onsite include sodium hydroxide (caustic).
The chemical agents stored in Area 10 comprise the blistering mustard agents (H, HD,
HT). The mustard agents H, HD, and HT all refer to various blends of the same basic
chemical compounda.
Chemical agents are stored in three types of containers and/or munitions: artillery and
mortar shells, and bulk containers. Munition and bulk item characteristics are shown in
Table 9-4-1.
a H is mustard made by the Levinstein process. It contains tp to 25Yo by weight of impurities, chiefly sulfur,
organosulfur, and polysulfides. HD (distilled mustard) is mustard purified by washing and vacuum distillation,
which reduces the impurities to about 5%. HT is a 60:40 mixture by weight of HD and T. T is an abbreviation for
bis 2 (chloroethylthioethyl) ether.
Table g-4-{
MUNITIONS AND BULK ITEM CHARACTERISTICS
Fuzes Bursters
4.2-inch mortar shell
155-mm projectiles
Attachrnent9-Page45
9.4.2.2.5
9.4.2.2.6
9.4.2.2.7
TOCDF
Contingency Plan
June 2009
MT]NITIONS AI\D
Table g-4-lr
BT]LK ITEM CHARACTERISTICS
Item Aeent Fuzes Bursters
Ton containers GAI{D,
HD.
Lewisite
NO NO
Notes:
I Fro*: "Disposal of Chemical Munitions and Agents," National Research Council
Washington, D.C. 1984.
Bulk containers are standard one-ton tanks in which GAltB.EDeOOlQfUiSb-is stored.
Mortars and some projectiles contain mustard agent.
As mentioned, the f,r+Sgyen major agents slated for demilitarization are the three types of
mustard, C+HaChS; Tabun (GA). C:HuNaOzP. Sarin (GB), C+IIroFOzP; Lewisite.
CzHaAsClr and VX, C1H2NO2PS. The chemical and physical properties of the agents
are summarizedinTable9-4-2 and are discussed in more detail in the following
paragraphs.
Attachment9 -Page46
9.4.2.3
9.4.2.3.7
9.4.2.3.2
9.4.2.3.2.t
9.4.2.3.2.2
9.4.2.3.2.3
TOCDF
Contingency Plan
June 2009
Table g-4-2r
CHEMICAL AI\D PTTYSICAL PROPERTIES OF AGENTS
Agent Chemical
Formula
Molecular
Weieht
Boiling
Point(oC)
Melting
Point(oC)
Vapor Pressure
(mmHe)
H CaHnClrS t75 225 5to14 0.059 (20"c)
HD c4H8cl2s 1s9 217 t4 0.069 (20'c)
HT c4H8cl2s
c3H16c12os2
(HD - lse)
(T: 263\
228 0 0.079 (20"c)
GA C.HrrNrOzP 162.13 248 -50 0.057 (25'C)
GB CaHroFOzP 140 158 -56 2.9 Q50C)
Lewisite ezHzAseli 207.3?t96 -ffi 34.6 Q5 "Cl
VX CrrHxNO?PS 267 298 -50 0.00063 (25"c\
Notes:I H, HD, HT, GB, vx data (U.S. ARMY, 1996, 1999, and 2001). GA and Lewisite data (MSDS
GB (Sarin): Physical, Chemical, and Toxic Properties
GB, also known as Sarin, is the most volatile of the nerve agents in the stockpile and, for
this reason, is mainly an inhalation hazard. This nerve agent will not, however, dissipate
immediately if spilled. GB is clear to amber in coloi;'with no odor. GB is readily
hydrolyzed by either acid or base to relatively nontoxic products. The hydrolysis products,
hydrofluoric acid and isopropyl methylphosphonic acid, can readily attack metal, which
may explain degradation of some weapons. GB is miscible with water, but under neutral
conditions (pH 7), the halflife for hydrolysis is several days.
Efficts of GB
GB is an extremely active inhibitor of cholinesterase (ChE). By forcing the buildup of
acetylcholine at the synapsis of cholinergic nerve fibers, GB causes victims to experience
pinpoint pupils (miosis), increased salivation, abnormal tearing of the eyes, urination,
diarrhea, convulsions, respiratory collapse, and death. A lethal dosage of GB is 100 mg
rnir/m3. Early treatment with oxime derivatives, such as pralidoximine, can accelerate
regeneration of cholinesterase, especially in the peripheral nervous system. Treatment
with atropine, an inhibitor of acetylcholine release, can also mitigate the toxicity of GB.
Victims surviving the acute cholinergic effects of GB may suffer delayed neuropathy
syndrome characteized by degeneration of peripheral nerves and permanent paralysis. In
addition, like similar compounds, GB may cause abnormal fetal development. For this
reason, pregnant women are restricted from areas containing the agent.
Absorption of enough nerve agent by any route results in the following generalized effects
upon the body system:
Pupils become pinpoint, sometimes unequal (miosis)
Frontal headache, eye pain, and slight dimness of vision occur
Occasional nausea and vomiting
Attachment9 -Page47
9.4.2.3.2.4
9.4.2.3.3
9.4.2.3.3.1
9.4.2.4
9.4.2.4.1
TOCDF
Contingency Plan
June 2009
Tightness in chest, wheezing or coughing
Giddiness
Tension
Anxiety
Restlessness
Slowness of recall
Confusion
Slurred speech
Generalized weakness
Drooling
Runny nose
The extent of the symptoms depends on the amount of the agent received. A severe
exposure causes:
Convulsions (twitchirg, j erking, staggering)
Collapse
Paralysis
Death, without immediate treatment, usually within 15 minutes.
Hazard Symbolfor GB
The hazard symbol for GB is a yellow circle, 24 inches in diameter, with a black letter "G"
in the middle.
VX: Physical, Chemical, and Toxic Properties
VX is a clear to straw colored, oily liquid. It is both an inhalation and a skin contact
hazard. Despite its low vapor pressure, VX still poses a significant vapor hazard. A lethal
dosage for VX is 35 mg min/m3. VX is a nerve agent. Nerve agents are
organophosphorus compounds, chemically related to pesticides. All nerve agents bind to
cholinesterase, an snz)me of the human body that is essential for functioning of the
nervous system.
Effects of VX
Attachrnent9-Page48
9.4.2.4.2
9.4.2.4,2.1
9.4.2.4.2.2
9.4.2.4.3
9 .4 .2.4.3 . 1
TOCDF
Contingency Plan
June 2009
The acute toxic effects of VX are like those of GB, and its mode of action is similar.
Absorption of VX results in symptoms identical to those produced by GB. Absorption of
enough nerve agent by any route results in the following generalized effects upon the body
system:
. Pupils become pinpoint, sometimes unequal (miosis)
Frontal headache, eye pain, and slight dimness of vision occur
Occasional nausea and vomiting
Tightness in chest, wheezing or coughing
Giddiness
Tension
Anxiety
Restlessness
Slowness of recall
Confusion
Slurred speech
Generahzed weakness
Drooling
Runny nose
The extent of the symptoms depends on the amount of the agent received. A severe
exposure causes:
Convulsions (twitchirg, j erking, staggering)
Collapse
Paralysis
Death, without immediate treatment, usually within 15 minutes.
Hazard Symbolfor VX
The hazard symbol for VX is a yellow circle, 24 inches in diameter, with black letters
"VX't in the middle.
Attachment9 -Page49
9.4.2,5
9.4.2.5.1
9,4.2.5.2
9.4.2.5.2,1
9.4.2.5.2.2
9 .4.2.5.3
9.4.2,5.3.1
TOCDF
Contingency Plan
June 2009
Mustard: Physical, Chemical, and Toxic Properties
Mustard agent comes in three varieties that differ mainly in purity. H is the crude agent
made by the Levinstein process. Distillation of the crude material yields HD. A mixture
of HD (60 percent) with a similar compound, T (CIC2II4SC2H4)2O), is termed HT. T is
also known as bis 2 (chlorethylthioethyl)ether. HT has the advantage of a lower melting
point than pure HD, which freezes at 15oC and, therefore, cannot be poured at low
ambient temperature. Mustard belongs to a family of toxicants, the N-, S-, and O-
mustards. Mustard is a colorless, oily liquid with a garlic odor. It quickly numbs the
olfactory nerves, after which the odor is no longer detected. Although the boiling point is
relatively btdh(225"C for H), it has a significant vapor pressure at ambient temperatures.
Even in the solid state at 0oC, the vaporpressure is 0.025 mm of Hg, which is 28% of the
vapor pressure at 30oC. Mustard is virtually insoluble in water, but, because of its high
lipid solubility, it rapidly pe,netrates the skin. Mustard is considered to be a 'lersiste,nt"
chemical age,nt.
Effects of Mustard
Although inhalation of mustard produces pulmonary edema, it is classified as a vesicant.
As such, it acts on the eyes, lungs, and skin, and bums and blisters the skin or any part of
the body that comes in contact with it. Mustard has also been ide'ntified as carcinogenic,
teratogenic, and mutagenic.
The eye is the most vulnerable part of the body to mustard. Long exposures to low
concerrtrations or short exposure to high concentrations can result in permanent eye
damage. The initial effect after skin contact is a reddening of the skin. Depending on the
severity of exposure, the reddening may progress to blistering and tissue destruction. The
initial exposure is not accompanied by a sensation, but, as the symptoms develop, there
may be an itching or burning sensation, which develops to reddening and then to
blistering. lnhalation of mustard vapor or aerosol causes damage to the mucous
membranes of the upper respiratory tract. Damage from mustard exposrre develops
slowly and may not reach maximum severity for several days.
Hazqrd Symbol for Mustard
The hazard symbol for mustard is a yellow circle, 24 inches in diameter, with a black letter
rrHrr in the center.
9.4.2.6 GA (Tabun): Physical. Chemical. and Toxic Properties
9.4.2.6.1 GA. also known as Tabun is a colorless to brown liquid: eenerally odorless. thoueh
possibly frnity. GA was manufactured as a warfare agent and is a lethal cholinesterase
inhibitor. It has the same mechanism of toxicity as organophosphate insecticides but is
much more potent. GA is considered to have moderately low persistence as it is less
volatile than GB (sarin). but it is much more volatile than persistent aeents. such as VX or
HD. If released into water. GA would likelv desrade from evaporation and hydrolysis.
and be further broken down bv dissolution and treatment orocesses such as chlorination.
Attachrnent9-Page50
".rorr#;ohlJune 2009
Environmental and hydrolytic degradation products of GA are not significant toxic
concerns. However. liquid aeent GA reaction with hieh-pH decon solutions (e.e..
household bleach) may produce toxic intermediate products (e.e.. claanide eas).
9.4.2.6.2 Elfects of GA
9.4.2.6.2.1 Sisns/symptoms of exposure to GA will occur within minutes or hours dependins on the
dose. Even relatively low dose exoosure to GA can be fatal. though immediate
administration of an antidote can be lifesavine. Symotoms are dose d€p€Nrd€'nt and may
occur within seconds after exposure to vapors and within minutes or hours from exlpsure
to liquid form. Mild: Runny nose. reduction in pupil size (.miosis). dimness of vision.
tiehtness of chest. diflicult breathing. Mod€rate: Increased miosis (to level of oinoointine
of pupils). headaches. confusion. drowsiness. nasal coneestion. tishtness of chest. nausea
vomitine diarrhea. cramos. generalized weakness. twitchine of larse muscle erouos.
Severe: Involuntary defecation and urinaJion. drooline. twitchine. staeg€ring. convulsions.
cessation of breathine.lo$s gf consciousness. coma. and death.
9.4.2.6.3 Hazard $tmboUor GA
9.4.2.6.3.1 The hazard symbol for GA is a yellpw circle. 24 inches in diameter. with a black letter
"G" in the middle.
9.4.2.7 Lewisite: Physical- Chemical. and Toxic Prope4ies
9.4.2.7.1 Lewisite is oily. colorless and odorless (if oure) to yeltow brown (if imBure) liquid with
strone oenetratine goranium odor for impure com[,ounds. It was develoned as a warfare
as€nt that can cause severe injuries to the skin. eyes. and respiratory tract. Unlike the
sulfur mustard blister aeents. L is volatile and not oersistent. Because of its volatility. it
has been manufactured in mixtures (e.e.. with sulfur mustard) to provide low freezing
ooint for use in cold weather operations or as a hieh altitude soray aeent. If released h air
as small aerosolized droplets or as a vaoor. pwe L misht last minutes to hours dep€ndine
on weather conditions. Heat and moisture increase ags,rrt breakdownl vaporsldroplets will
likely settle in coolerllow-lyinq areas since L is heavier than air. L brgals down inhours to
two toxic products. lewisite o{ide and arsenic. which can oersist for days or more. The
effects caused by L are not tupicallv fatal. but hieh enough conc€ntration exoosures (e.e..
direct liquid contact. high vapor concentrations) can cause immediate we pain and
eye,/skin/respiratorytract irritation with lesions forming hours later (this is unlike HD
which has delayed effects). Low airborne concentrations may cause onlytemporary eye
irritation. L can penetrate normal clothine. Dimercaprol (a.k.a. British Anti-Lewisite. 2.3-
dimercaptopropanol) applied topically is an antidote for L exposure to skin. Persistence:
vcpor: hours-day: /laill'd: hours-day. dependins on amount. Elevated temperatures.' rain/other weather conditions will exoedite desradation.
9.4.2.7.2 Wcts of Lqrvisite
9.4.2.7.2.1 Irnmediate bumine pain (.eye and skin). skin redness within 15-30 min: then blister
formation (approx. 12 hours oost exposure) and deep skin bums. Time of onset and
severity of effects de,pend on dose. duration. and route of exoosure. Not all
signs/symptoms may develoo. Inhalation: Immediate burnine pain. bloody nose. violent
sneezinq. couqh. lung edema frothins mucous. sinus pain. shortness of breath: lung tissue
Attachment 9 - Page 5l
TOCDF
Contingency Plan
June 2009
damaee at higher concentrations and exoosure durations. Skin: Immediate stinsins pain
and redness within 30 minutes. blisters within 12 hours (dependingon dose). deep skin
burns. Ingestion ftare): Diarrhea. nausea. vomiting. Eves: Instant pain. tearine. irritation.
and swelling of the eyelids. Corneal scaning. iritis. oermanent damaee and blindness
within one minute.
9.4.2.7.3 Hazard Svmbol.for Lewisite
9.4.2.7.3.1 The hazard symbol for Lewisite is a yellow circle. 24 inches in diameter. with a black
letter "L" in the middle.
9.4.3 Hazard Assessment [R315-84.7(c)l
9.4.3.1, HazardAssessment Overview
9.4.3.1.1 Hazard assessment involves determining the type and nature of an emergency situation
and its potential or actual impact. This leads to the determination of ahazard zone around
the accident area, in which an unacceptable level of personnelhazard exits. Hazard
assessment results serve as the basis for determining appropriate emergency response
actions (e.g., hazard containment and control, selection and implementation of protective
actions, mobilization of response personnel and equipment, etc.).
9.4.3.1.2 Hazardassessment will be performed continually during the response phase of an event.
The initial assessment will involve determining, as soon as possible, the emergency hazard
type, source, amount, severity, and scope. Event hazard assessment will be performed by
the first responders, Scene Control Officer (SCO), response teams, Control Room
personnel, and the Incident Commander (IC) with assistance from DCD during events
involving the release of chemical agent. Subsequent assessments will support redefining
the event hazard zone and redirecting response and protective actions as necessary.
9 .4.3.1 .3 The hazard assessment process involves the following primary activities: event detection;
event information gathering; event assessment; determination of event hazard zone; and
on-going verification of event hazardzore.
9.4.3.1.4 If a chemical agent release extends off-post, civilian authorities will become involved in
extended or long-term assessment. This assessment will be primarily concemed with
evaluating the impact of the event on the population and monitoring conditions to
determine appropriate protective measures. On-going assessment will include identiffing
long-term adverse effects on air, soil, water, wildlife, etc.
9.4.3.1.5 In the event of a DCD emergency, which affects TOCDF or TOCDF-operated facilities,
DCD performs hazard assessment and provides the appropriate protective actions.
9.4.3.2 Event Detection
9.4.3.2.1 Emergency event assessment and response activities begin with the detection of an event.
Emergency events are identified primarily through the following means:
Site persorurel in the vicinity (who become event first responders)
Attachrnent9 -Page52
9,4.3.2.2
' 9.4.3.3
9 .4.3.3. 1
9.4.3.3.2
TOCDF
Contingency Plan
June 2009
Control Room (via plant data monitorirg)
o Detection equipment (for chemical agent)
Personnel working in the vicinity of the event area will be the individuals most likely to
witness or discover an emergency situation. AIl EG&G personnel have been trained to the
OSHA Hazardous Materials Awareness Level. This provides a strong site-wide
emergency detection capability. Awareness level personnel are trained to initiate the
emergency response process by performing an initial assessment of event conditions and
contacting the Control Room. The awareness training course covers the following basic
concepts: Identification of emergency situations; Hazardous substances and their dangers
and risks; Recognition of the presence of hazardous substances in an emergency;
Identification of hazardous substances; and the Role of the first responder in the
emergency response process, including use of the US DOT Emerge,lrcy Response
Guidebook.
Event lnformation Gathering
It is important to gather as much information about an emergency event as soon as
'possible after detection. Accurate and timely event information results in a more
comprehensive assessmsnt, which leads to implementation of the most appropriate
response actions.
The first information likely to be available during an emergency will be from the first
responders on the scene. Except ATLIC and CAMDS personnel, all site personnel are
taught to repofi emergency situations to the TOCDF Control Room. The TOCDF Control
Room and/or the CAMDS CMO can be reached by telephone or by hand-held radio at the
is described in the 5tr'bulla).
Emergency (non-cellular) Telephone - Call 911.
Telephone - [phone].
Control Room (on cellular phone) - [phone].
For initial reporting of CAMDS site emergencies lfo the CMO, extension 4400 on
a site phone or [phone] from a cellular phone will be used.
9 .4.3.3.3
For initial rsDortins of ATLIC site em cies to the CCEE. extelrsion
site pone or (435) 833-ffi from a cellular phone will be used.
The information provided by first responders will allow for an initial assessment of
TOCDF events to be performed by the TOCDF Control Roonr;\T!!C ,CCEL -or
CAMDS @CMO. However, to support the complete
emergency event assessment process, the following information must be known or
projected:
Nature of release;9 .4.3.3.3. 1
Attachrnent9-Page53
TOCDF
June 2009
!.'
: ir:illH:*,, (small, moderate, or large)
: d,[:+lT$,'f"ffi]1tffiflfi*.rl'"1?.:**ii#* a, s.urce,.ca,i.n
and atmospheric inversion)
e'4'3'3'3'2 3*""tiT;1Xf#::I azard? (should be assumed until monitoring data indicates
otherwise)
r Potential water hazard?
o Potential subsurfacehazard? (adsorbed into the soil)
9.4.3.3.3.3 Anticipated duration of hazard; and
9.4.3.3.3.4 Extent of the area impacted by dispersion of hazard.
9.4.3.3.3.5 Event information is recorded by Control Room Operators on an Event Report. Event
information beyond that usually available from first responders is obtained from many
dif ferent sources, including :
: ,:","#'::::,:*'
Control Room
. Monitoring and sampling teams
DCD Emergency Operations Center
9.4.3.4 lnformation Sources
9.4.3.4.1 The following describes the tlpe of event information provided by each of these groups.
9.4.3.4.2 lryfbrmationfromEmergency ResponseTeams
9.4.3.4.2.1 Emergency response teams include the HAZMAT Team, Paramedic Team, and Decon
Team. The HAZMAT Team will provide information about the type, quantity, source,
and behavior of the hazardous substance. HAZMAT members may also provide air
sampling support. The Paramedic Team will provide information about number of
casualties and the tlpe of injuries to the Control Room. The Clinic will provide patient
condition, treatment, and transport status periodically to the Control Room. The Decon
Team will provide the number of people processed ttrough thq Personnel
Decontamination Station (PDS), and the capability of the PDS to handle additional
personnel. By working close to the hazard, response teams have a unique perspective on
the event and can provide specific information on the hazard and its immediate impacts.
Attachrnent9-Page54
9.4.3.4.3
9 .4.3.4.3.1
9.4.3.4.4
9.4.3,4.4.1
9.4.3.4.5
9.4.3.4.5.1
9.4.3.4.s.2
9 .4 .3 .4.5 .3
9.4.3.4.s.4
9.4.3.4.5.4.1
9.4.3.4.5.4.2
9.4.3.4.s.4.3
TOCDF
Contingency?lan
Informationfrom SCO, IC, and Advisors
The SCO and IC gather event information through direct observation and input from
advisors. The SCO, who is typically the first outside responder on the scene, provides
event information to the IC, Control Room, and response teams.
Information from TOCDF Control Room
The Control Room serves as the technical center for TOCDF plant system information as
well as a reference for TOCDF technical information. Control Room personnel monitor
the status of TOCDF plant systems and activities via monitoring systems, which feed
directly to computer terminals. The CAMDS CMO and the ATLIC CCEE servos a
similar purpose for the CAMDS site. However, the TOCDF Control Room acts as a
central point for collecting, assessing, and distributing event information from responders
for events at all TOCDF-operated facilities. The Control Room also assists scene
responders in obtaining required resources and forwards DCD MeteorologicallDetection
Teams (Met/DeQ results, provided by the EOC, to the SCO.
Information fro m Monito ring and Sampling Teams
For emergency events involving the release of chemical agent or industrial chemicals,
monitoring and sampling will be performed to confirm the release plume location and
levels. Monitoring and sampling activities will be initiated as soon as possible after
emergency event detection. Initial monitoring will focus on broadly defining the hazard
and its impacts. Subsequent monitoring (and sampling) will provide more detailedhazard
release characteristics.
The HAZMAT Team will perform airborne monitoring as necessary during events
involving the release of industrial chemicals. The TIAZMAT team will use an air pump
instrument and associated detector tubes for the chemical(s) involved to perform air
monitoring. Monitoring personnel will perform environmental sampling (e.g. surface,
soil, water) as directed by the IC.
For events involving the release of chemical agent, DCD will dispatch Met/Det Teams.
Chemical agent samples will be taken to a lab located at DCD.
DCD agent monitoring and sampling will be accomplished using the following equipment:
Real Time Analysis Platform 6fAf1: Combines gas chromatograph with an automatic
continuous environmental monitoring system in a self-contained mobile platform;
provides low-level chemical agent monitoring capability. RTAPs required by an event at
TOCDF or a TOCDF-operated facility will be provided by DCD.
Depot Area Air Monitoring System (DAAMS)
:Air sampling unit designed to provide lowJevel detection capability for GA. GB, H,
Lewisite and VX agents requires lab analysis.
In the event off-post monitoring and sampling are required, DCD, via the EOC, may
provide resources and assistance to local off-post agencies requesting support.
9 .4.3 .4.5.5
Attachrnent9-Page55
9 .4.3.5
9 .4.3.5.1
9.4.3.5.2
9 .4,3.5.3
9.4.3.5.4
9 .4.3.5.5
9 .4.3.5.6
TOCDF
Contingency Plan
June 2009
Event Assessment
Initial event assessment will often be done by first responders at the scene or by the
Control Room. This initial assessment involves a quick analysis of immediate hazard area
dangers. Subsequent assessments will involve more integrated and complex analysis of
event information. Hazard assessment is a process, which will continue throughout the
event as additional event information becomes available.
The hazard assessment process will involve analysis of threats, direct and indirect, to both
human health and the environment. Direct threats are those posed by the immediate
hazard and are generally obvious. The dangers of indirect effects are less obvious and can
be caused by, for example, the generation of toxic, irritating, or asphyxiating gases from
the event hazard; the run-off of water or chemicals used to control fire and heat-induced
explosions; and the use of large amounts of decontaminants.
The event hazard assessment process involves projection of affected areas and
contamination levels using computer modeling based on event information and
comparison of model predictions versus actual field data from MetlDet Teams (for agent
only). For chemical agent releases, the DCD Emergency Operations Center (EOC) directs
plume plotting and monitoring and sampling activities. The EOC initially performs plume
projection based on the MCE (Maximum Credible Event) for a CAIRA event. The EOC
later uses actual field data received from DCD MetiDet Teams to refine the initial
projections. In the event of a DCD emergency, which affects TOCDF or any TOCDF-
operated facility, DCD performs hazard assessment and develops and provides protective
action recommendations.
Hazard assessment will also be performed after the event response phase and prior to
entering the recovery phase. This assessment will focus primarily on identiffing and
analyzing long-term hazards and impacts and will support the setting of recovery
priorities.
Event assessment results will be used by the IC in directing response activities and
developing TOCDF and TOCDF-operated facility protective actions. This information
will also be provided to DCD via the EOC for use in developing depot protective actions.
DCD will supply the information to offsite authorities for use in developing protective
actions for the public. The timeliness and accuracy of the event hazard assessment affects
the ability to protect site and post personnel as well as the public
Hazardassessment will result, at a minimum, in the following key information:
Tlpe and nature of hazard
Quantity of hazardous substance and form of release
Direction and speed of release
Definition of the hazard zone
Expected effects on personnel in the hazard zone O
Attachrnent9-Page56
9,4.3.6
9.4.3.6.1
9 .4.3.6.2
9.4.3.6.3
9.4.3.6.4
9.4.4
9 .4.4.1
9.4.5
9.4.5.1
9.4.s.1 .1
TOCDF
Contingency Plan
June 2009
Determination of Event HazardZone
Based on the emergency event characteization, ahazard zone will be determined. The
hazard zone is the area around thehazard source in which an unacceptable level of
personnel hazards exist.
For industrial chemical releases, the hazard zone will be determined by comparing hazard
exposure projections to the Short Term Exposure Limit (STEL) for the specific hazardous
substance involved. The STEL is the average concentration to which unprotected
chemical workers may be exposed for up to 15 minutes continuously. A STEL level of
greater than 1.0 is considered to be an unacceptable personnel risk. The use of STELs to
define the hazard zone represents a conseryative approach to protecting personnel.
For releases of chemical agent, DCD EOC staff determines the hazard zone by defining
the "no effects" distance for the specific chemical agent involved. For chemical munitions
in an explosivelyhazardous condition, EOC staff use the munitions fragment distance as
the minimum hazard zone. Initial definition of the hazard zone will be based on the
Maximum Credible Event (MCE) developed for TOCDF. The hazard zone will be refined
as appropriate as actual event information becomes available.
The hazard zone will be verified by results from monitoring and sampling activities.
Changes in monitoring and sampling results, as well as changes in event conditions, will
result in re-definition of the event hazard z.one.
Control Procedures I R315-8-4.7(a)]
EG&G emergency response personnel will comply with R3 1 5 -8 -4.2 by evaluating
emergency situations with regards to the criteria specified in Section 9.3 and, if the
emergency situation meets the criteria specified in Section 9.3 (i.e., the situation could
threaten human health or the environment), immediately implementing the Contingency
Plan (e.g., taking the appropriate response actions specified in Section 9.4, etc.). By
implementing the appropriate portions of the Contingency Plan, the requirements of R315-
8-4.7 will be addressed as required by R315-8-4.3(a).
Prevention of Recurrence or Spread of tr'ires, Explosions, or Releases [R315-8-a.7(e)
& (01
Fire
Fires or explosions occurring on the facility grounds are handled by the Emergency
Response Team and the Deseret Chemical Depot Installation Fire Department unless they
are beyond the capabilities of the two units. In that case, the Tooele County, Tooele City,
Grantsville, and/or Stockton Fire Departments are called in to supplement onsite
capabilities.
If a fire involves explosive materials or is supplying heat to it, or if the fire is so large that
it cannot be extinguished with the equipment at hand, the personnel involved shall
evacuate and seek safety.
9.4.5.1 .2
Attachrnent9 -Page57
9 .4.5.1 .3
9,4.5.1 .4
9 .4.5.1 .5
9 .4.s.1 .6
9.4.5.2
9.4.5.2.r
9.4.5.2. 1.1
TOCDFt*ttt"*?#3;
The TOCDF is equipped with both smoke and heat detectors in designated areas that
alarm in the Control Room. The fire suppression system is designed to extinguish a fire
before the fire increases the amount of agent available for release to the environment. In
addition, the fire suppression system reduces the temperature produced by a fire to prevent
rupturing of agent storage tanks/containers and piping, and the detonation of explosively
configured munitions.
All fire response personnel are provided with the appropriate protective clothing and ,
safety equipment. Care must be taken to contain and recover any runoff of waste and
water, foams, or chemicals applied to the fire. If possible, the area should be diked and/or
any runoff drains blocked prior to using liquids to put out the fire. Once extinguished, the
materials involved in the fire and surrounding area are decontaminated, if necessary,
recwered, and placed in containers for proper disposal.
In the event of a fire, the major effort is placed on preventing the fire from spreading to
nearby areas. The following actions are taken in indoor areas affected by a fire or
explosion:
Fire doors in buildings are closed.
Hazardous work in all areas are terminated immediately.
All feed lines to fumaces and additional equipment are shut down, as necessary
and practical.
The IC is contacted.
The area is cleared of all personnel not actively involved in fighting the fire. Non-
emergency personnel are to report to the designated assembly point for a head
count.
All injured persons are removed, and medical treatment is administered by
qualified personnel.
The IC is responsible for all firefighting efforts until help from outside the facility arrives.
Supervisors of unaffected areas will stay with their personnel and will be ready to
evacuate and account for the persons under their supervision.
Fire Reporting and Evacuation
Immediate Actions
As soon as any fire of any size is found at any TOCDF-operated facility, the Control
Room must be notified as described in this plan. If the fire is observed visually and no
automatic alarms are activated, the individual noticing the fire pulls the nearest manual
alarm in the area. If the sprinkler, dry chemical, Halon or FM-200/F8227 systerns are
activated, ample time should be given for them to operate. When the fire is extinguished,
the alarms should be deactivated. After the size and location of the fire is determined, he
announces "Fire in the (speciS room, building, atea, etc.), stand by for instructions," on
the TOCDF. CAMDS oTATLIC public address system@
Attachrnent9-Page58
TOCDF
Contingency Plan
June 2009
E6tffi{s-appreeriote. The CAMDS,#TOCDF and ATLIC public address systems are
operated from the CMO*-an+CON and CCEE only, respectively; the systems are entirely
independent from one another. If the public address system is not functional, operators are
used to pass instructions. Anyone in immediate danger must be assisted, if safe to do so.
At TOCDF, all unpacking and munitions processing will stop until further evaluation of
the event has been completed.
9.4.5.2.1.2 The Control Room Operator and/or the CAMDS PSM notifies the IC and gives the
information as noted below. The following information is also relayed to other
appropriate personnel :
(a) Location of fire
O) Type of fire (if known)
(c) Hazardous material involved
(d) Number of known casualties
(e) Type of injuries (if known)
9.4.5.2.t.3 The IC determines the course of action based on the seriousness of the situation. The
seriousness or size of a fire is a subjective decision that must be made as quickly as
possible. If there is ever any doubt on the course of action to be taken, a large fire is
assumed.
9.4.5.2.2 Subsequent Actions
9.4.5.2.2.1 Subsequent actions depend on the magnitude of the fire and, more importantly, the
location. Procedures will be followed during firefighting activities at TOCDF or any
TOCDF-operated facility.
9.4.5.2.2.2 The DCD Fire Department is responsible for fighting the fire at TOCDF or TOCDF-
operated facility. The IC directs the appropriate person to remain with the DCD Fire
Department during firefighting for assistance with technical advice.
9.4.5.2.2.3 An Emergency Response Team dressed in appropriate protective clothing enters the
building to conduct reentry monitoring only after receiving approval from the IC, DCD
Fire Department Chief, and Safety Representative.
g.4.5.2.2.4 The IC, Safety Representativp and any other applicable personnel assess the damage and
determine any further course of action to be taken.
9.4.5.3 Fires and Agent Releases
9.4.5.3.1 If an agent release occurs during or as a result of a fre, the offgases from the fire may
contain toxic chemicals. As a precaution, all personnel fighting fires are in appropriate
protective clothing at all times. The potentially toxic offgases cannot be controlled, but
every effort is made to quickly extinguish the fire with the fire suppression system and
douse any agent leaks with decontaminant when the scene is rendered safe.
g.4.5.3.2 After a fire involving chemical agents has been controlled ,rrd
"*iirrgrrished,
the
Emergency Response Team closely monitors the affected area to determine that all tfaces
of chemical agents have been thoroughly decontaminated. For events outside the TOCDF
Attachment9-Page59
9.4.5.3.3
9.4.5,3.4
9 .4.5.3.5
9 ,4.5.3.5.1
9 .4.5.3.6
9,4.5.4
9 .4.5 .4.1
9,4.6
9.4.6.1
TOCDF
Contingency?lan
MDB, the workers initially use standard detection kits to clear an area. More sensitive
analyses are conducted in the facility laboratory if necessary. Inside the MDB building,
standard lowJevel monitors of the facility are used to clear an area. This involves
ensuring that all monitors are retumed to a normal level and that no detectable chemical
agent rernains above the Alarm Set Point level.
Runoff from fires inside the MDB are collected in sumps that drain to the SDS tanks.
From there, these runoffs are fed to one of the two LICs. For an event at the facility, such
as a transportation accident involving fire, runoff is contained as much as practical,
absorbed on pads and managed appropriately.
Any remaining materials in the fire area that may have been exposed to agent are
decontaminated with decontamination solution and managed appropriately.
Prevention of Recurrence, Spread of Fires, Explosions, or Releases [R315-8-4.7(e) &. fl]
Fire and spill response actions discussed previously, and explosions in the following
section, are the primary means of preventing releases of hazardous waste resulting from
the recurrence or spread of fires and explosions. Other actions include collecting and
containing the released waste and recovering or isolating containers.
If the facility stops operations in response to a fire, explosion, or release, the Emergency
Coordinator must monitor for leaks, pressure buildup, gas generation, or ruptures in
valves, pipes, or other equipment, wherever this is appropriate.
Explosive Hazards
In general, two tlpes of explosive hazards are of concem in the TOCDF facility: (1)
explosives in the presence of agent, and (2) explosives alone. Many of the munitions to be
processed in the facility contain explosives (bursters, supplemental charges, and fuzes). A
detonation of an explosively configured munition presents not only ahazardto personnel
and property from the blast effects, but also ahazard from the spread of chemical agent
throughout the local work areas. Once the explosively configured munition has been.
disassembled in the Explosive Containment Room, the explosive components will be
separated from the agent and agent exposure from a detonation is not a concem. After
separation, the explosives are incinerated in the TOCDF Deactivation Fumace System
where all energetic material is destroyed. CAMDS no longer treats or manages
explosives.
Storaee and Treatment of Released Material [R315-8-4.7(e)l
Once the emergency situation has ended, the IC will ensure that recovered waste,
contaminated soil, or any other material (e.g., decontamination solution, etc.) that results
from a release, fire, or explosion at the facility is immediately stored (i.e., placed in
containers or tanks in good condition), treated, or shipped offsite. When determining the
appropriate destination for this released material, the IC will address the compatibility
considerations described below in Section 9.4.7. Information regarding the management
of material that results from a release is provided below in Sections 9 .4.9 , 9 .4 .10, md
9.4.tt.
Attachment9-Page60
TOCDF
Contingency?lan
9.4.6.2 Any agent-contaminated spilled liquids and any solid materials (rags, clothing, etc.) will
be managed in accordance with this Permit. Waste that is not agent-contaminated will be
managed onsite in accordance with this Permit or applicable regulations. The IC will
ensure that, after clean-up is complete, all equipment and PPE used during clean-up is
decontaminated as necessary (refer to Section 9.7.8 below) and first aid supplies and
absorbent materials are restocked as appropriate.
g.4.7 Incompatible Waste tR315-8-4.7(hx1)l
g.4.7.1 The IC will ensure that, in the affected areas of the facility, the storage and treatment of
wastes that may be incompatible with the released materials will be prevented until clean-
up procedures are comple*ed.
g.4.7.2 The TOCDF operating approach (i.e., onlyprocessing munitions and bulk containers
containing one tlpe of agent at a time) minimizes the potential of released material being
incompatible with other wastes in the area. Also, the design of the TOCDF plant
minimizes the chlances of incompatible material contact. For instance, the brine, spent' decontamination solutions, and agent each have a separate and unique destination (e.g.,
BRA storage tanks, spent decontamination tanks, agent collection tanks). Additionally,
this Permit mandates that containers, which share a cornmon secondary containment
system, only be used for the storage and treatment of compatible waste streams. Likewise,
this Permit requires that tanks, which share a cornmon secondary containment system,
only be used for the storage and treatment of compatible waste streams. Therefore, the
TOCDF plant design, this Permit, and normal operating procedures in use at any of the
TOCDF-operated facilities will generally prevent management of an incompatible waste in
afl area where a release has occurred.
9.4.7.3 However, to ensure segregation of incompatible waste and materials, the IC will assure
that the released material is characterizedby the appropriate means (e.g. analysis, checking
facility records if origin of the release is known, etc.) and will use this information to
ensure that no incompatible materials or wastes are brought into the affected area. The IC
will also compare the characterizationof the released material to the characteristics of the
waste and material already stored in the affected area. If, based upon this comparison, any
transportable incompatible materials are determined to be in the area and available storage
capacity exists elsewhere at the DCD or TOCDF-operated facility, the IC will have these
materials moved to another available area (e.g., a different container storage area or tank
system, etc.) where segregation of incompatible wastes/materials can be assured.
Potentially incompatible waste or material that cannot be removed from the affected area
will be segregated from the released material by using any appropriate means (e.g., earthen
berms, overpacks, etc.) until the clean-up procedures are completed.
9.4.8 Post-Emergency Equipment Maintenance [R315-8-4.7(hX2)l
9.4.8.1 After an emergency event, all emergency equipment used during the emergency
response/clean-up, including PPE, will be either: (l) discarded and replaced with new
emergency equipmentiPPE; or (2) cleaned with the proper decontamination solution,
repaired as necessary, and reused. Also, as necessary, absorbent material and first aid
supplies will be restocked and fire extinguishers recharged. Before operations resume, an
inspection of the affected emergency equipment listed in Section 9.5 will be conducted by
the IC or his designee to ensure that the equipment is clean and fit for future use. Once
Attachrnent 9 - Page 6l
9.4,9
9.4.9,1
9.4.9.2
9.4.9.3
9.4.10
9.4. 10.1
9.4.10.2
9.4.11
TOCDFt*t*tffi#;;
this inspection is complete and the appropriate notifications have bee,n made, operations
may resume in the affected area.
Container Spills and Leakage [R315-8-4.3, R315-8-9.21
If there is a spill, leak, or release from a container, which could threaten human health or
the environment, the EG&G Emergency Response Plan (ERP) will be implemented. If
this release involves a chemical agent and/or munitions, then the Chemical
Accident/Incident Response and Assistance (CAIRA) Plan (Appendix A of the ERP) will
also be implemented. These plans provide detailed procedures, which encompass the
various aspects of emergency response, including: notification, mobilization, PPE
requirements, hazard assessment, emergency response, recovery, etc.
If the spill, leak, or release from a container could threaten human health or the
environment, then this section of the Contingency Plan will also be implemented. This
section of the Contingency Plan augments the procedures provided in the ERP and the
CAIRA Plan by focusing on procedures for responding to releases from containers.
If an agent release is involved, the first individual to observe the release will mask and
notiff the TOCDF Control Room (or CAMDS CMO or ATLIC CCEE as described
herein). The procedures described in the ERP and CAIRA as well as the procedures
identified below will then be followed. If a non-agent release is encountered, then the first
individual to observe the release will do the following:
Alert other nearby workers and, if outside, move upwind of the release.
Contact the Control Room (or CAMDS CMO or ATLIC CCEE) who will contact
the Control Room), which will then notiff the Emergency Coordinator; report the
release, location, nature of material spilled (if known); and report the estimated
amount involved.
Prevent access to the area by vehicles or other personnel.
Follow instructions offered by the Emergency Coordinator or the Control Room.
Tank Spills and Leakage [R315-8-10 [40 CFR 264.194.c=ll
If there is a spill, leak, or release from a tank system, which could threaten human health
or the environment, the EG&G Emergency Response Plan (ERP) will be implemented. If
this release involves a chemical agent, then the Chemical AccidenVlncident Response and
Assistance (CAIRA) Plan (Appendix A of the ERP) will also be implemented. These
plans provide detailed procedures, which encompass the various aspects of emergency
response, including: notification, mobilization, PPE requirements, hazard assessment,
emergency response, recovery, etc.
If the spill, leak, or release from a tank system could threaten human health or the
environment, then this section of the Contingency Plan will also be implemented.
Spills and Leakage from Other Regulated Units
Attachrnent9 -Page62
9.4.1 1.1
9.4,11 .2
9.4.1 I .3
9.5
9.5. 1
9.5,2
9.5,2.1
TOCDFt*tt'rHiJa;
Spills and leakage from other units at the TOCDF or TOCDF-operated facilities are
possible. These TOCDF units include the incineration systems (LIC1, LIC2, DFS, MPF),
the associated pollution abatement systems, the Subpart X units (BDS, PMD, MDM, Area
l0 Autoclave, DVS/DVSSR), and Slag Removal System (SRS). CAMDS units include
various permitted HWMUs that support CAMDS closure such as tanks, sumps and
container storage areas specified in this Permit. The ATLIC units includes the LIC.
associated PAS system and various permitted HWMUs that support ATLIC operations
such as tanks and sumps snecified in this Permit.
If there is a spill, lealg or release from a unit identified above, which could threaten human
health or the environment, the EG&G Emergency Response Plan (ERP) will be
implemented. If this release involves a chemical agent and/or munitions, then the
Chemical Accident/Incident Response and Assistance (CAIRA) Plan (Attachment A of
the ERP) will also be implemented. These plans provide detailed procedures, which
encompass the various aspects of emergency response, including: notification,
mobilization, PPE requirements, hazard assessment, emergency response, recovery, etc.
If an agent release is involved, the first individual to observe the release will mask and
notiff the Control Room (or the CAMDS CMO or the ATLIC CCEE). The procedures
described in the ERP and CAIRA as well as the procedures identified below will then be
followed. If a non-agent release is encountered, then the first individual to observe the
release will do the following:
Alert other nearby workers and, if outside, move upwind of the release.
Contact the Control Room (orthe CAMDS CMO who will contact the Control
Room), which will then notiff the Emergency Coordinator, report the release,
location, nature of material spilled (if known), and the estimated amount involved.
Prevent access to the area by vehicles or other personnel.
Follow instructions offered by the Emergency Coordinator or the Control Room.
EMERGENCY EQUTPMENT [R3 1s-8-4.3(d)]
Reserved.
Communication and Alarm Systems
Communications inside the TOCDF will be achieved through a telephone system and the
TOCDF public address (PA) system. Telephones are located so that each employee has
access to one from his workstation. An employee can call the Control Room or any other
telephone in the TOCDF and can be connected to an outside phone line from site
telephones. Employees can access the PA system for paging by using or by contacting
designated telephones throughout the site or by contacting the Control Room. The paging
system will be broadcast through a series ofloudspeakers to provide coverage throughout
the active portion of the facility. Two-way radios are also available for onsite
communication. The TOCDF is connected to the local telephone system to enable
extemal communications. Alarms will be broadcast over the PA system loudspeakers.
The agent and evacuation alarms will be initiated by the Control Room. The alarm to
Attachrnent9-Page63
9.5,2.1 .1
9.5.2.2
9.5.2.2.1
9.s.2.2.2
9.5.2.2.3
9.s.2.2.4
TOCDF
ContirrrHrtrS;
mask and await further instructions will consist of a warble tone (oscillating whine)
broadcast. The alarm for site evacuation and masking, if directed bythe Control Room
will consist of a steady-tone broadcast. The alarm to mask and evacuate personnel within
the MDB will consist of a repetitive yelping tone. Generally, the alarms will be
accompanied by instructions from the Control Room, which include event-specific
instructions. Area 10 Igloo communications with the main TOCDF Control Room will be
via the TOCDF-staffed Igloo operations control point by telephone or two-way radio.
Although the TOCDF CON is the communications center for emergencies at any TOCDF-
operated facility, communications within the CAMDS facility can be achieved through the
telephone system and the CAMDS PA system. CAMDS employees can call the CMO or
any other telephone at the CAMDS or TOCDF, and can be connected to an outside phone
line. CAMDS employees can request PA announcement by contacting the CMO. The
message will be broadcast through a series of loudspeakers to provide coverage
throughout the CAMDS site. Alarms specific to the CAMDS site will be broadcast over
the CAMDS loudspeakers. Agent and evacuation alarms at CAMDS will be initiated by
the CMO. The alarm to mask and await further instructions will consist of a warble tone
(oscillation whine) broadcast. CAMDS alarms will be accompanied by instructions from
the CMO, which include event-specific instructions. Emereency communication at the
ATLIC is the same as the CAMDS facilitv with the exceotion of relrortine to the CMO.
ATLIC ernployees need to call the CCEE.
System Design
TOCDF and TOCDF-ooerated facilities emergency communications are performed by
standard telephone, hotline telephone, cellular phone, radio, and face-to-face contact.
All Emergency Response Organization members have received training in emergency
communications. Common terminology has been developed to ensure clear
communications. All personnel assigned radios have been trained in the use of those
radios, Entry teams have been trained to remain in visual contact with their buddy.
All communications links are backed up. A minimum of two charmels will be available
on all radios. Within the areas with the highest probability of erirergency incidents (MDB,
unpack) emergency phones have been strategically located. If required, the public address
system, which is on an unintemrpted power source, could be utilized for one-way
emergency communications on site. The system can be addressed to site-wide or specific
locations. The system can be accessed through several identified facility standard
telephones.
The attached Emergency Communications table (Table 9-5-l) provides detailed
infbrmation regarding the tlpes of equipment used for emergency communication. Links
beyond the DCD Emergency Operations Center (DCD EOC) to Army, local, State, and
Federal agencies are covered in the DCD CAIRA Plan.
Table 9-5-1
TOCDF and TOCDF-Operated Facility Emergency Communications
Phone Systems
Standard Phones Lines into the site and on the site are buried. The phone system is on an
Attachrnent9 -Page64
TOCDF
Contingency Plan
June 2009
Table 9-5-1
TOCDF and TOCDF-Operated Facility Emergency Communications
trnintemrpted power supply. The backup power supply provides six hours of
margin. If there is a loss of offsite (outside of TOCDF) power the system will
continue to provide communications on the site, but will not provide
communications offsite.
Hotline Phones There are four hotline phones on site, all of which connect with the Control
Room. These phones are located in the Entry Control Facility, Clinic, DSA,
and DCD EOC. These phones, which are independent of the standard phone
system, have an unintemrpted power supply that provides six hours of margin.
Radio Network
Wiens
te l5l,955MHz, Fer daily epqatiens eeelr ef the fellewkrg greups are essigrCffi
@Wine
@geeratiens-++S
@geemtiens++i.'lities
Emergency Operations For emergency operations, the following response personnel will be assigned a
specific radio channel (1 through 6).
Emergency Responder
Control Room Operators
IC
SCO
Safety Advisor
Environmental Advisor
HAZMAT Team
Decon Team Leader
Rescue Team Leader
Paramedic Team Leader
TOCDF Clinic
Fumaces (PAS)
utilities
CAL
Appropriate radios are distributed to emergency response teams. DCD utilizes
a Motorola Saber 16-channel radio system with 12 assigned frequencies ranging
from 1 39.035 MHz to | 48.97 5 MHz. There are four portable radios with DCD
frequencies assigned to TOCDF. In an emergency they will be used by the IC
and Clinic. In addition, the Control Room maintains a DCD radio base station
with 12 assigned frequencies.
Attachrnent9-Page65
9,5,2.2,5
9.5.2.3
9.5.2.3.1
9.s.2.3.2
9.5.2.3.3
9.5.3
9.5.3. 1
9.s.3 .2
TOCDFt*t*'rn?#a;
During drills and exercises, communications are typically prefaced by and ended with
"This is a test exercise message".
Control Room
The TOCDF Control Room is the communications center for emergency response
involving TOCDF and all TOCDF-operated facilities. The Control Room has engineering
controls, which isolate it in the event of an emerge,ncy. It is manned 24 hours a day,7
days a week, and has backup emergency power. The Control Room contains the
following communications equipment: standard phones, hotline phones, a cellular phone,
radio base stations each covering all TOCDF channels, a radio base station covering all
DCD channels, and a fax machine.
In an emergency at TOCDF or a TOCDF-operated facility, specific Control Room
Operators are assigned to act as phone contacts with specific response teams. Specific
operators are assigned to each of the following groups: IC if he is in a field location, SCO,
Clinic, CMAT, and EOC. The operatprs who are not assigned to one of these specific
response teams will handle all other communications. These remaining groups will
normally have limited communications requirements. If for any reason the
communications needs of a group expand, a specific operator will be assigned.
The TOCDF Control Room communicates with the TOCDF-operated Igloo personnel by
telephone or two-way radio via the Igloo control point, which is staffed at all times during
hazardous waste operations within the igloos.
Spill Control and Decontamination Equipment
TOCDF has trained personnel and a variety of equipment and supplies available onsite for
responding to spills and decontamination at TOCDF-operated facilities. The HAZMAT
and Decontamination Teams are staffed by trained on-shift personnel around the TOCDF
site and are primarily composed of Maintenance and Operations personnel. The
HAZMAT Team performs victim rescue, containment, mitigation, and clean-up activities
during TOCDF and TOCDF-operated Igloos emergency events involving the release of
chemical agent or industrial chemicals. The Decon Team performs associated personnel
decontamination.
HAZMAT and Decon Response Teams' resources include a Decon Trailer, HAZMAT
Van,'Emergency Decon Station, Buildings S-1 and S-5, and the DPE Support Area
(DSA). The HAZMAT Van and Decon Trailer are stationed inside Building S-1. All
HAZMAT response equipment and supplies located in the HAZMAT Van and Decon
Trailer are inspected on a regular basis as specified in Attachment 5 (lnspection Plan).
Lists of equipment that must be maintained on the HAZMAT Van and Decon Trailer can
be found in the Inspection Log section of Attachment 5 (Inspection Plan).
The Decon Trailer contains PPE and all equipment and supplies necessary to perform
personnel decontamination. The Decon Trailer inspection log identifies equipment and
supplies available on the Decon Trailer. The Decon Trailer has one fixed rinse shower
and one portable decon shower. A TOCDF truck is used to move the Decon Trailer to the
scene.
9.s.3.3
Attachment9 -Page66
TOCDF
Contingency?lan
9.5.3.4 The HAZMAT Van is stocked with PPE and all equipment and supplies necessaryto
respond to hazardous spills and emergency decontamination. The TIAZMAT Van
inventory inspection log identifies equipment and supplies available on the HAZMAT
Van.
9.5.3.5 At TOCDF, Emergency Decon Stations house additional gear and are located along the
most probable routes of egress in an emergency. Each Emergency Decon Station contains
the equipment as listed in Table 9-5-2.
9.5.3.6 CAMDS Additional Equipment
9.5.3.6.1 As described previously, if a large spill were to occur, the CAMDS facility would be
supported by TOCDF Emergency Response teams. CAMDS has additional spill response
and decontamination equipment and resources located in the immediate vicinity. There
are two tanks for storage of the decontamination solution for agents GB and VX. Truck
Table 9-5-2
EMERGBNCY DECON STATIONS AI\D PERSONNEL
DECONTAMINATION EQUIPMENT
ITEM QUANTITY
Coveralls 10 pair
Socksr l0 pair
Tee-shirtsr 10 pair
Underw ear (merVwomen) I 10 pair
Towels 10
DPE Booties 10 pair
Blankets 10
Butyl Gloves 10 pair
Scissors 2 patr
Belt Cutter 1
Decon Solution 2 6 gallons
Step Pans3 1 water, 1 decon
Chemical Casualty Kits4 2
Spill Control Kit 1
NOTE: The HAZMAT Van and Decon Trailer respond to all chemical spills or incidents at TOCDF or TOCDF-
operated facilities. Some of the items referenced above are stored on the HAZMAT Van and/or Decon Trailer.
I Personnel will not receive these items until they have been evaluated at the TOCDF Clinic. The PMB will
supply these items as necessary.
2 Liquid soap and water are readily available for decontamination. Decontamination solution is always available
on the HAZMAT Van or Decon Trailer that responds to chemical spills or incidents.
3 Step Pans are always available on the Decon Trailer. Additional step pans are available from S-1.
a Each individual has a chemical casualty kit with them at all times. Additional chemical casualty kits are
available on the HAZMAT Van and at the TOCDF Clinic.
5 Spill control kits are stored on the HAZMAT Van. Additional spill control kits are available from S-1.
Attachrnent9 -Page67
TOCDF
Contingorcy Plan
June 2009
mounted decontamination units with decontaminants for GB, VX, and mustard agent are
available at Area 10 to support CAMDS. These are maintained by Deseret Chemical
Depot Ammunition Storage Division for CAMDS and munition storage missions.
9.5.3.7 ATLIC Additional Equinment
9.5.3.7.1 The ATLIC would also be supported by the TOCDF Emersency Response teams should a
laree spill occur. ATLIC has additional spill response and decontamination equipment
and resources located in the immediate vicinity. There aretrvo{anlts is one tank for
storage of the decontamination solution (18% NaOH solution@
Truck mounted decontamination units with decontaminants for €BrlA(ff(Lnrrstac
aeents are available at Area 10 to supoort ATLIC. These are maintahed by Des€ret
Chemical Dspot Arrmunition Storaee Division for ATLIC and munition storase missions.
Emergency Equipment
Fire Extinguishing Equipment
Sprinklers Halon and FM-20088-227 systems are capable of operating automatically to
extinguish fres in the TOCDF areas in which they have been placed. These areas include
the UPA (sprinklers) and areas where electronic equipment is in use (Halon). Chemical
tlpe fire suppression systems protect the ATLIC. CAMDS CMO, SAF Lab, SAF
chemical storage room, and the CUB. Portable fire extinguishers are available throughout
the facilities and are capable of extinguishing small fires. The facility structures are
generally designed to be fire-resistive. An automatic detection and alarm system is placed
throughout the TOCDF facility. Fire response forces have available portable
extinguishers, a complete site firewater distribution system, and emergency response
equipment similar to that of a municipal fire department.
Emergency Personal Protective Equipment
Eruergency Personal Protective Equipment Overview
This plan section presents an overview of how the PPE available to EG&G will be utilized
by personnel responding to a release event of chemical agent or industrial chemicals at a
TOCDF-operated facility. Response to an agent release will require use of agent approved
PPE by responders entering toxic or contaminated areas. The general work force is
required to don Army air purifying respirators (masks) immediately upon notification by
the Control Room-ATLIC-CCEE or CAMDS CMO of any unusual event that could result
in a release of agent impacting the TOCDF-operated facility work site. All personnel who
enter the vicinity of TOCDF, CAMDS. ATLIC or DCD Area 10 sites are trained in the
use of, have issued to them, and are required to be prepared to use an Army protective
mask. The use of the Army mask is for eggess only in the event of an agent release.
Response to industrial chemical releases and spills require the wearing of OSHA PPE.
The TOCDF facility was designed and constructed with the overriding consideration that
"The use of personal protective equipment (PPE) is the least desirable method of exposure
control." Based on hazard analyses, the reduction of dependence upon PPE was designed
into all areas and operations of the TOCDF.
9.5.4
9.5.4.1
9.5.4.1 .l
9,5.4.2
9.5.4.2,1
9.5.4.2.1 .1
9.5,4.2.r,2
Attachrnent9-Page68
TOCDF
Contineency?lan
9.5.4.2.L.3 The TOCDF and TocDF-operated facilities conduct operations in areas where no amount
of design and engineering can alleviate the requirements to wear PPE. These
requirements for wearing PPE are dependent on a number of factors that include the type
of operations performed in an area and the likelihood of the presence of agent during
normal or abnormal conditions. Selection of the appropriate level of protection is
determined by the potential level of exposure/contamination that exists in the specific
environment and the task to be performed.
9.5.4.2.2 ChemicalAgentVentilation/HazardCategories
I O.S.+.Z.Z.| Each room and/or building at TOCDFJTUC and CAMDS has a designated category
rating of A, B, C, D, or E based upon the potential for agent contamination dtring normal
munitions and support operations. Categories may be temporarily upgraded to correspond
with increas ed hazar d potential.
9.5.4.2.2.1.1 Rooms assigned a Category A rating have probable agent liquid and likely vapor
contamination.
9.5.4.2.2.1.2 Rooms assigned a Category A/B are evaluated for contamination probability depending on
the operations being performed and the materials present.
9.5.4.2.2.1.3 Rooms with a Category B rating have possible vapor contamination only resulting from
routine operations.
9.5.4.2.2.1.4 Rooms with a Category C rating have a low probability of agent vapor contamination.
9.5.4.2.2.1.5 Rooms with a Category D rating have a very low probability of ever being contaminated
by agent.
9 .5 .4 .2.2.1 .6 Rooms and areas with a category E rating are maintained from being contaminated by
agent at all times barring the possibility of a catastrophic event.
9.5.4.2.3 Descriptions of Personal Protective Equipment Ensembles
9.5.4.2.3.1 Level A (A1-A2) clothing is used for entry into agent toxic areas with agent vapor and
liquid present based on the OSHA and Army criteria for chemical agent activity. Level A
provides positive pressure, full-face, self-contained breathing apparatus (SCBA), or
positive pressure supplied air line respirator with self-contained escape air supply,
approved byNIOSH, and totally encapsulating, vapor-tight, chemical protective suit. The
Demilitarization Protective Ensemble (DPE) suit (Level ,A.1) is normally used within the
agent areas of the Munitions Demilitarization Building. ln any of these areas where an
emergency occurs, the DPE suit is wom unless the emergency conditions themselves
preclude the use of the suit. ln those circumstances, M3 B (81) (formerly known as
Modified Level A) or OSHA Level A protective clothing is used. This equipment is
available at the Demilitarization Protective Ensemble Support Area (DSA) in the TOCDF
Personnel Maintenance Building. (PMB)
9.5.4.2.3.2 M3 B (Bl) (formerly known as Modified Level A) or OSHA A clothing is the highest
level of protection available at the site, excluding the DPE suit. OSHA A or M3 B (B1)
may be used in the presence of liquid when conditions prohibit DPE, when needed to
Attachment9-Page69
TOCDF
"*,,rtffi#3;
restore the plant to normal conditions, or as the primary PPE for DPE backup. It will be
used for munitions handling or other tasks based on OSHA and Army criteria for chemical
agent activity.
9.5.4.2.3.3 Level B Protective Clothing-Level B (B1-B5) provides positive pressure, full-face Self-
Contained Breathing Apparatus (SCBA), or positive pressure supplied air line respirator
with self-contained escape air supply, approved byNIOSH, and non-encapsulating
chemical protective clothing. It will be used for munitions handling or other tasks based
on OSHA and Army criteria for chemical agent activity.
9.5.4.2.3.4 Level C Protective Clothing - Level C (Cl-C6) provides an air purirying full-face
respirator or protective mask and non-encapsulating chemical protective clothing. It will
be used for entry into agent toxic areas with agent vapor only (no liquid) based on OSHA
and Army criteria for chemical agent activity.
9.5.4.2.3.5 Level D - Level D provides mask or respirator slung or readily available and employer
provided clothing. It will be used for entry into agent toxic areas where no vapor is
present oi anticipated based on OSHA and Army criteria for chemical agent activity.
9.5.4.2.3.6 Street Clothes (SC) - This level consists of personal clothing with Mask Available and is
for areas at TOCDF and TOCDF-operated facilities where no respiratoryprotection or
chemical protective clothing is needed.
9.5.4.2.4 Selection of PPE
9.5.4.2.4.1 ChemicalAgentRelease
9.5.4.2.4.1.1 When responding to a chemical agent release, the level of protection required will be
determined for each operation. Conditions under which the various levels of protection
are required are described along with the PPE descriptions in the section above.
9.5.4.2.4.2 IndustrialChemicalRelease
9.5.4.2.4.2.I When responding to an industrial chemical release, the correct level of PPE is selected by
the Scene Control Officer (SCO) with approval of the Safety Advisor. MSDS sheets for
the chemical involved, the NIOSH "Personal Protective Equipment for lndustrial
Chemicals Incidents: A Selection Guide", and the DOT Emergency Response Guidebook
are references used in determining this selection. The PPE selection made by the SCO
will also consider the work requirements of the entry to ensure the durability of the PPE is
appropriate to that work.
9.5.4.3 Medical Emergency Equipment
9.5.4.3.1 The following emergency medical equipment is to be available at the TOCDF medical
clinic. The clinic is responsible for ensuring that the following equipment is available and
operational.
o Ambulance bags (Jump Kits)
o Oxygen Cylinders
Attachment9-Page70
9.5.4.4
9,5,4,4.7
9 .5 .4.5
9.5.4.5.1
9.5.4.6
9.5.4.6.1
9 .5 .4.7
9 .s .4.7 .l
9.5 .4.8
9 .5 .4.8. 1
9.5.4.8.1.1
9.5.4.8.2
TOCDF
Contingency Plan
June 2009
Defibrillator
Litters
Mark 1 Auto Injectors (Nerye Agent Antidote Kit)
Protective Clothing
Protective Masks
Ambulance/V ehicl e for transp orting casualti es
Showers and Eyewash Facilities
Safety showers, decontamination showers, and eyewash stations are located in appropriate
areas of the MDB (Figures 9-5-1 through 9-5-4), the PUB (Figure 9-5-5), the PAS (Figure
9-5-6), the CHB (Figure 9-5-7), and the CAMDS SAF @igure 9-7-34). All figures are
located at the end of the Contingency Plan.
Agent Detection Equipment
Agent munitions and alarms are present in each agent work area. The tlpe of monitors
used varies based on.the agent being processed. The alarms/indicators consist of visual
(rotating beacons or panel lamps) and audible alerts (homs). Instructions are given from
the Control Room via the public address system to inform personnel as to what actions to
take following an agent alarm.
Decontamination Solution
Decontamination solutions are available within the TOCDF facility to address liquid agent
spills. The appropriate solution is available throughout the facility based on chemical
agent being processed. The location is specific to each appropriate area of the facility.
Confined Spaces Entry Equipment
The equipment required for Confined Space Entry will be available and maintained at the
TOCDF PMB, Building 5-6, or in the response vehicle. This includes a combustible gas
indicator, an oxygen-sensing device, and self-contained breathing apparatus.
Offsite Equipment
Firefighting Equipment
Fire protection, emergency equipment, and DCD support organizations are detailed in
Section 9.6
Heavy Equipment
Attachrnent9 -PageTl
9.5.4.8.2.1
TOCDF
"**rrffi#;;
Supplemental heavy equipment and supplies will be available, if needed, from offsite
sources including Tooele Army Depot (TEAD) and DCD. Table 9-5-3 lists the
emergency equipment available at the DCD and TEAD.
u A minimum of one shovel and one broom are kept at each container storage building.
Table 9-5-3
DESERET CIIEMICAL DEPOT (DCD) AI\D TEAD EMERGENCY EQUIPMENT
NOMENCLATT]RE CAPABILITY QUANTITY LOCATION
Fire Trucks 1,000 gpm pumper 1 DCD Fire Station
(Bldg s010)
Brush truck, 1,000-
gallon capacity, 200 gpm
pump
1 DCD Fire Station
(Bldg s0l0)
Equipment truck, [-]-ton
pickup
1 DCD Fire Station
(Bldg s010)
Crash truck for
helicopter crash
response; with foam, dry
chemical water
capabilities (NOTE:
This .vehicle doubles as
1,0O0-gallon pumper
truck listed above.)
DCD Fire Station
(Bldg s010)
Ambulances Emergency personnel
evacuation and medical
support
4 TOCDF (r) DCD
Area 10 (1) Bldg
s010 (1)
Bulldozer Caterpillar tlpe for
brushfire, control, spill
cleanup, general grading
1 Behind Building
t34 (rEAD)
Loader, Scoop Ito2-yd' capacity, front-
end tlpe; for spill
cleanup, etc.
I Behind Building
r34 (rEAD)
Backhoe Wheeled type tractor-
mounted; for ditch
digging and excavation
I Behind Building
r34 (TEAD)
Hand Tools (shovels,
brooms, etc.)6
Small spill cleanup as available Container storage
buildings Building
s 16 (rEAD)
Distributor, Water
Tank
1,000 gallon with pump I Building 516
(rEAD)
Auger, Earth Boring up to 24-tnch
holes
I Building 516
(rEAD)
Excavator,Backhoe type excavation I Building 516
Attachment 9 -Page72
TOCDF
Contingency Plan
June 2009
9,6 C OORDINATION AGREEMENTS A}{D SUPPORT ORGAI\IZATIONS [R3 1 5-8-
4.3(b), R315-8-3.71
9.6.1 Coordination Agreements Overview
9.6.1.1 TOCDF, through DCD, has made contact with the local and regional entities and
authorities, which may be involved, in an emergency situation at a TOCDF-operated
facility. Each of these authorities have been provided with a copy of the current EG&G
Emergency Response Plan (ERP) and relevant background information. A copy of this
updated EG&G Contingency Plan, along with the DCD CAIRA Plan is provided to each
of these authorities upon approval.
9 .6.1 .2 Discussions regarding their specific involvement and coordination have been held.
9.6.1.3 The US Army, as owner and co-operator of TOCDF has contacted the following local
authorities to obtain emergency response and/or mutual assistance and support agreements
for the DCD, TOCDF, and TOCDF-operated facilities.
9.6.1.4 The following agreernents are in place and on file at the TOCDF.7
7 Copies of the agreements are found at the back of this section.
. Table 9-5-3
DESERET CIIEMICAL DEPOT (DCD) AND TEAD EMERGENCY EQTIIPMENT
NOMENCLATT]RE CAPABILITY QUANTITY LOCATION
Multipurpose (rEAD)
Tractor Caterpillar-type for ditch
digging, backhoe
capabilities, etc.
10 Building 516
(rEAD)
Grader, Road Road grading, ditch
cleaniflg, etc., with 12-
foot blade
5 Building 516
(rEAD)
Loader, Scoop Ito2-yard3 cap acrty,
front-end tlpe
2 Building 516
(rEAD)
Crane, Shovel 1-yardt
"upucity
for
loading sand and gravel
1 Crusher area
(rEAD)
Crane, Hydraulic 25-ton for major item
material handling
1 Building 516
(rEAD)
Truck, Dump S-yardt
"upucity
for
handling and dumping
7 Building 516
(rEAD)
Truck/Pickup For general purpose
transportation
2 Building 516
(rEAD)
Crane, Clamshell and
Dragline
13-ton capacity 1 Building 516
(rEAD)
Attachrnent 9 - Page73
9.6.1 .5
9.6.1 .6
9,6.2
9 .6.2.1
9.6.2.1 .l
TOCDF
Contingency Plan
June 2009
Tooele County Sheriffs Office (27 May 1997)
North Tooele County Fire District (1 I August 1998)
City of Stockton Fire Department (1 1 August 1998)
City of Tooele Fire Department (1 1 August 1998)
City of Grantsville Fire Department (1 1 August 1998)
Mountain West Medical Center (14 March 2003)
Evans Army Community Hospital (17 July 2003)
Utah Valley Regional Medical Center (26 June 2003)
Intermountain Medical Center (29 Febru da, 2008)
University of lJtah Medical Center AirM ed (26 June 2003)
Intermountain Health Care (IHC) Life Flight (23 July 2003)
University of Utah Hospital (26 June 2003)
EG&G is the main provider of emergency response resources at TOCDF-operated
facilities including TOCDF, CAMDS, and the DCD Area l0 SecondaryWaste facility.
EG&G utilizes a number of emergency support services located on the DCD installation.
For most accident scenarios, installation resources are the only support required, with the
exception of advanced medical treatment. TOCDF provides frst-level emergency medical
care, but regional hospital support is required for casualties in need ofadvanced life
support.
Non-EG&G resources are requested through the DCD Emergency Operations Center
(EOC) located at DCD Building 5108, except for urgent DCD Security and DCD Fire
Station resources, which may be requested directly by the Control Room. Additional
local, State, and Federal resoruces are available in the event of a major disaster. All local,
State, and Federal notifications and resource requests will be made by DCD. The OSC
identifies and recommends the outside resources needed to the DCD Commander, who in
turn, establishes liaison with the provider to obtain them.
DCD Support
General
DCD maintains its own response force to handle chemical accidents/incidents involving
DCD operations. EG&G response teams may also be called upon to support an
emergency on the installation. The DCD resources available to support EG&G emergency
response are described below. DCD resources are under the command and control of the
EOC on a daily basis. In the event EG&G requires DCD resources, the Control Room
Attachrnent 9 - Page74
9.6.2.2
9.6.2.2.1
9.6.2.2.2
9.6.2.3
9.6.2.3 .l
9.6.2.3.2
9.6.2.4
9 .6.2.4.t
9.6.2.5
9.6.2.5.1
TOCDF
Contingency?lan
will request them directly from the EOC, with the possible exception of initial DCD
Security response.
DCD Security
The DCD Law Enforcement and Security Division (Security) is the sole provider of
security services to TOCDF and TOCDF-operated facilities on a daily basis. In the event
of an emergency at TOCDF or TOCDF-operated facility, Security will:
ensure the safeguarding of chemical surety materiel and property
provide perimeter control assistance and limit access to authorized personnel
capture intruders
. implement rapid entry/exit procedures for responders and evacuating personnel.
Security personnel are under the command and control of the Site Security Control Center
(sscc).
Real Time Analysis Platforms (RTAPs)
TOCDF monitoring personnel conduct agent monitoring at the facilityusing fixed
ACAMS and DAAMS stations located primarily inside the CHB, MDB, CAL, and
associated exhaust stacks. In the event of a chemical agent release outside a normally
monitored area, TOCDF has the necessary portable equipment to perform airborne
monitoring in these TOCDF-operated facility areas.
DCD maintains Real Time Analysis Platform (RTAP) capability to support its daily
chemical storage operations. The RTAP is a self-contained mobile platform, which can be
moved from location to location to perform low-level, near real-time agent monitoring.
Each RTAP includes a monitoring technician, a van with an ACAMSA4INICAMS, and a
portable radio. RTAPs maybe deployed individually or in support of DCD response
teams, such as a Met/Det Team or the Hotline Crew.
DCD Meteorological/Detection Teams (MetlDet)
DCD has MeteorologicallDetection Teams (MetlDet) available to perform initial entry,
wind measurement, and agent detection activities. Each Met/Det Team includes at least
two persons each with Army Level A and B protective clothing, available SCBA
respiratory protection, a truck, portable radio, chemical casualty kit, decontamination
solution, and a wind measuring instrument. Upon deployment of a Met/Det Team, a
RTAP accompanies the team to perform lowlevel agent monitoring.
DCD Hotline Crew
DCD has a Hotline Crew available to perform personnel decontamination at the event
scene. The Hotline Crew includes personnel and a mobile Persorurel Decontamination
Station (PDS) consisting of a tractor and a decon-ready trailer. The mobile PDS is a
Attachrnent9 -Page75
9.6.2.6
9,6.2.6.1
9,6.2.7
9.6.2,7 .l
9.6.2.7 .2
9.6.2.7 .3
9.6.2.7 .4
TOCDF
a*,r"rrffirr#;
totally self-contained, environmentally controlled, runoff-capturing hotline in a trailer,
which can be moved from location to location to perform personnel decontamination.
DCD Decontamination Teams
DCD has De,contamination Teams available to perform decontamination of personnel and
agent-contaminated surfaces such as property and equipment. Each Decontamination
Team includes DCD personnel each with Army Level A and B protective clothing, a
flatbed truck with a generator and decontamination tank, portable radio, and
decontamination tools. DCD pre-assigns one Decontamination Team for rapid
deployment to an event scene to perform emergency actions such as personnel
decontamination, spill confinement, and surface decontamination.
Emergency Operations Center (EOC)
The Emerge,ncy Operations Center (EOC) is a fully equipped emergency facility
maintained by DCD and located at DCD Building 5108. The EOC is staffed 24 hours a
day,7 days a week, and is the primary point of contact for performing off-post
notifications and obtaining resource support, including DCD, TEAD, and outside support.
The DCD Commander is the Initial Response Force (IRF) Commander during a chemical
accident/incident response and operates from the EOC. The OSC also operates from the
EOC and maintains direct contact with the DOSC in the field.
After the initial confirmed detection of an actual or likely chemical agent release at the
DCD installation, the DCD Commander or designee must classifu the event; determine the
protective action recommendation for off-post populations; and report the aforementioned
items to the Tooele County Sheriff Dispatch Center. The DCD Commander or designee
will notiff local, State, and Federal organizations required by regulation, mutual
agreement, or response requirements; obtain emergency medical support, as required; and
execute public affairs activities related to the event.
TOCDF has two buses available for personnel evacuation. In the event of a site-wide
evacuation of TOCDF and TOCDF-operated facility persorurel, up to five busloads of
evacuees may require transportation from a TOCDF-operated facility muster area to a
DCD assembly area. DCD will provide the additional buses needed to fill the
transportation shortfall. During a chemical accident/incident, all buses on the DCD
installation are under the control of the OSC, who will plan and direct any evacuation to
DCD assembly areas. The Control Room requests transportation support from the EOC
for any TOCDF-operated facility.
In the event the primary EOC facility is within the down-wind hazard area, DCD
command staff will activate and operate from their Mobile Command Post. Upon EOC
activation due to an event at TOCDF or a TOCDF-operated facility, the Contractor
Management Advisory Team (CMAT) will deploy to the EOC to provide technical
assistance to EOC staff. EG&G will maintain and provide to DCD a current roster of
CMAT members authorized to access the EOC.
DCD Fire Station9.6.2.8
Attachrnent 9 - Page76
9.6.2.8.1
9.6.2.8.2
9.6,2.8.3
9.6.3
9.6.4
9.6.4.1
9 .6.4.t .l
9 .6.4,2
9 .6.4.2.1
9 .6.4.3
9.6.4.3.1
TOCDF
"*'*t}?lo'3;
The DCD Fire Station, located on the DCD installation, is the primary provider of fire-
frghting services and the backup provider of rescue and HAZMAT response services to
TOCDF and TOCDF-operated facilities. The DCD Fire Station is a fully-equipped fire
fighting station staffed 24 hours aday,7 days a week. The DCD Fire Station is located
approximately 3.5 miles from TOCDF and 5.2 miles from CAMDS in DCD Building
5010 and has an expected arrival time of 8 - 1 0 minutes. In the event of a fire emergency,
the TOCDF Control Room will contact the DCD Fire Station directly for fire fighting
services. Once the DCD EOC is activated, the Control Room will request fire-fighting
services through the EOC.
Upon receipt of a fire alarm at TOCDF, the DCD Fire Station receives only a general
alarm for the TOCDF site. The Control Room then informs the DCD Fire Station of the
particular zone(s) in alarm and confirms the alarm prior to fire fighter deployment. Once
deployed, EG&G will guide fire personnel to the scene and brief them on the event,
structure layout, and hazards present. The senior DCD fire officer on scene will direct all
fire fighting activities at TOCDF and TOCDF-operated facilities.
In addition to fire fighting skills, DCD fire personnel are trained and certified in rescue
operations and as Hazardous Material Technicians in accordance with OSHA 29 CFR
1910.120. In an event involving hazardous industrial chemicals, DCD fire personnel will
supplement EG&G HAZMAT resources as required. A fully-staffed and equipped EG&G
HAZMAT Team is on site 24 hours a day,7 days a week. The Control Room requests
DCD HAZMAT support through the DCD Emergency Operations Center.
Reserved
TEAD Support
General
Tooele Army Depot (TEAD), under the Army Field Support Command (AFSC), is located
approximately 15 miles north of DCD and 2 miles southwest of the City of Tooele.
TEAD maintains resources to support a chemical accidenVincident response at the DCD
installation. The TEAD resources available to support EG&G emergency response are
described below. In the event EG&G requires TEAD support, the TOCDF Control Room
will request it through the EOC, with the possible exception of initial TEAD Fire
Department response.
TEAD Fire Station
The TEAD Fire Station, located on the TEAD installation, is the backup provider of fire
fighting services to TOCDF and TOCDF-operated facilities. It is a fully equipped fire
fighting station staffed 24 hours a day,7 days a week. The TEAD Fire Station is located
approximately 15 miles north of DCD and has an expected arrival time of 30 minutes.
The TEAD Fire Station will supplement the DCD Fire Station resources.
TEAD Public Works
TEAD Public Works dispatches a representative to the Support Center to coordinate
TEAD equipment support to the DCD installation.
Attachrnent9 -Page77
TOCDF
Contingency Plan
June 2009
9.6.4.4 Support Center
9.6.4.4.I The Support Center is a fully equlpped emergency support facility maintained by TEAD.
The Support Center is the primary point of contact for coordinating all TEAD resource
support to DCD during a chemical accident/incident. The TEAD Commander is the
Support Center Commander and operates from the Support Center. The TEAD
Comrnander or designee will provide all aspects of logistical support to DCD, including
transportation, equipment, and facility support.
9.6.5 Medical Support
9.6.5.1 General
9.6.5.1.1 Medical services at both the DCD and TEAD installations, with the exception of TOCDF
and TOCDF-operated facilities, are provided and managed by Evans Army Community
Hospital based at Fort Carson, Colorado. Evans Army Community Hospital staffs and
equips the TEAD Health Clinic, and DCD Aid Station. Resources from these facilities are
available to support a TOCDF or TOCDF-operated facility medical response, if necessary.
9.6.5.1.2 In the event of multiple casualties requiring ground or air transport to definitive care
facilities, medical resources other than Army support will be needed. Medical support,
including Army resources, will be requested through the EOC to ensure there are no
logistical impairments. The Medical Clinician In Charge (MCIC) of the TOCDF Clinic
will make the initial request to the EOC through the Control Room, and once
arrangements are made, will discuss the ETA and medical details directly with the medical
support provider. Likewise, requests by DCD for TOCDF medical support on the DCD
installation will be made through the EOC.
9.6.5.2 Aid Station (DCD)
9.6.5.2.1 The Aid Station, located on the DCD installation, is the first backup provider of
emergency medical services to EG&G. It is a fully-equipped emergency medical station
maintained by Evans Army Community Hospital. The Aid Station is located
approximately 3.5 miles from TOCDF in DCD Building 5010 and has an expected arrival
time of 8 - l0 minutes. Aid Station resources include two ambulances with advanced life
support equipment and a minimum of two Emergency Medical Technicians (EMTs) on
duty Monday - Thursday, 0630 - 1700.
9.6.5.3 Reserved
9.6.5.4 U.S. Army Health Clinic (TEAD)
9.6.5.4.1 The Health Clinic, located on the TEAD installation, is the third backup provider of
emergency medical services to EG&G. It is a fully-equipped emergency medical station
maintained by Evans Army Community Hospital. The Health Clinic is located
approximately 15 miles from DCD and has an expected arrival time of 30 minutes. Health
Clinic resources include one physician, one ambulance with advanced life support
equipment and a minimum of two EMTs (Monday-Thursday, 0630-1700 hours only).
Attachment9-Page78
TOCDF
ContingencyPlan
9.6.5.5 Dugway Proving Ground
9.6.5.5.1 Dugway will supply one ambulance with a physician and two EMS personnel if requested,
with an expected arrival time of 50 minutes.
9.6.5.6 Air Ambulance Services
9.6.5.6.1 Air ambulances will provide air evacuation for casualties, when this can be done without
endangering their personnel. Air ambulances will be requested directly by the MCIC
through the EOC. The Control Room will be notified of this action immediately. Air
ambulance services, which may be used, include: Life Flight (LDS Hospital) and AirMed
(University Hospital).
9.6.5.1 Intermountain Medical Center
9.6.5.7.1 Severely ill or injured patients may be transported by air or ground ambulance to
Intermountain Medical Center. Intermountain Medical Center should be utilized for
general trauma, shock trauma, closed head injury and maybe used for chemical casualties.
9.6.5.8 University Hospital
9.6.5.8.1 Severely ill or injured patients may be transported by air or ground ambulance to
University Hospital. University Hospital is the hospital of choice for chemical casualties
and bum trauma. University Hospital should also be utilized for general trauma, closed
ead or spine injuries, and as a backup for shock trauma.
9.6.5.9 Mountain West Medical Center
9.6.5.9.1 Patients who are ill or injured to a lesser degree may be transported by ground ambulance
to Mountain West Medical Center.
9.6.5.10 Utah Valley Regional Medical Center
9.6.5.10.1 Patients who are ill or injured to a lesser degree may be transported to Utah Valley
Regional Medical Center in Provo.
9.6.6 Explosive Ordnance Disposal (EOD) Detachment
9.6.6.1 In an emergency event involving unexploded ordnance or other potential explosion
situations at TOCDF or TOCDF-operated facility, the EOD Detachment will be required
to respond. The U.S. Army EOD Detachment is the primary response group for events
that require Render Safe Procedures. The EOD Detachment is only dispatched via the
EOC.
9.6.7 Community Fire Support
9.6.7.1 Tooele City Fire Department
9.6.7.1.1 In the event the TEAD Fire Department needs assistance, the Tooele City Fire Department
will provide fire-fighting support. Estimated arrival time from Tooele is 45 minutes.
Attachment9 -Page79
TOCDF
Contingency Plan
June 2009
9.6.7.2 Stockton Fire Department
9.6.7.2.1 The Stockton Fire Department is the closest off-post responder. Stockton Fire Department
is an all-volunteer fire fighting service. Anticipated mobilization time is approximately 30
minutes.
9.6.7.3 Grantsville Fire Department
9.6.7.3.1 The Grantsville Fire Department will provide a fourth level of fire fighting backup, if
needed.
9.6.7,4 Tooele County Fire Department
9.6.7.4.1 In the event the TEAD Fire Department needs assistance, the Tooele County Fire
Department will provide fire-frghting support. Estimated arrival time from Tooele is 45
minutes.
9.6.7.5 Volunteer Fire Departments
9.6.7.5.1 The following Fire Departments may respond to any fire emergency to the best of their
ability. Due to the volunteer nature of their agency and the departments' limited
capability, no written agreement can be entered into.
o Town of Rush Valley Volunteer Fire Department and Ambulance Quick
Response Unit (QRU).
. Town of Vemon Volunteer Fire Department
o Town of Ophir Volunteer Fire Department
9.6.8 Other Emergency Services
9.6.8.1 Coordination with other emergency services in Tooele, Utah and Salt Lake Counties,
along with federal emergency response groups, is handled through the Chemical Stockpile
Emergency Preparedness Plan (CSEPP), which is coordinated by DCD.
9.6.9 Department of the Army (DA)
9.6.9.1 Additional Department of the Army (DA) resources are available to respond to a chemical
accident/incident at the DCD installation. These DAlevel resources are deployed by DA
Headquarters, based on information and requests made by the DCD Commander. DA
resources available to support a CAIRA response are detailed in the DCD CAIRA Plan.
EG&G, through DCD, has made contact with the local and regional entities and
authorities, which may be involved, in an emergency situation at the facility.
9,7 PROTECTIVE ACTIONS AND EVACUATION PLAN [R315-8-43(e)]
9.7 .l Protective Actions Overview
o
Attachrnent9-Page80
9.7.1.1
TOCDFt*""rn?iJ8;
Protective actions are emergency measures intended to avoid or reduce personnel exposure
to hazards. The two primary protective actions are evacuation, which involves moving
personnel away from ahazard, and in-place sheltering, which involves personnel
remaining indoors to avoid ahazard. Evacuation is the preferred protective action when
conditions allow it to be safely completed prior to personnel hazardexposure. In-place
sheltering is the preferred protective action when conditions do not permit a safe
evacuation. Other protective actions include access control and the use of protective
equipment. Protective equipment, such as respirators, suits, gloves, boots, etc., is wom
primarily by emergency response personnel. All EG&G personnel in the vicinity of
TOCDF, CAMDS or Area 10 have Army protective masks and Mark I nerve agent
antidote kits required by DA PAM 385-61.
Protective actions may be required for both on-post personnel and the off-post general
public. The selection and implementation of protective actions for the public are the
responsibility of civilian authorities and are addressed in the DCD CAIRA Plan.
Protective actions may be implemented for either an actual or a potential danger. An
example of a protective action based on an actual threat is an evacuation of the site due to
DCD reporting a release of agent from Area 10. When protective actions are implemented
prior to an actual danger existing they are called precautionary. An example of a
precautionary protective action is evacuatin[ the site due to'the activation of the Depot
Terrorist Alarm following a direct terrorist threat or actual terrorist attack in the United
States. There is no health danger to the site, but depot procedures would require a
precautionary site evacuation.
Determination of the appropriate protective actions for an emergency event is made
through the protective action decision-making process. The process involves an
assessment of event conditions and available data, use of contingency plans based on the
plant hazards assessment, and selection of the protective action that best protects
personnel from hazard exposure and minimizes event impacts.
The initial protective actions for an emergency event will be issued as soon as possible
upon completion of the event assessment and protective action decision-making process.
Subsequent protective actions will be developed and implemented as needed when
changes in event conditions warrant upgrading or downgrading the existing protective
actions. Examples of situations, which could result in the issuance of subsequent
protective actions, include a shift in wind direction, obtaining results from monitoring
teams, and successful containment of the hazard.
Protective Action Decision-Making
lnitial hazard assessment and protective action decision-making are performed in the
Control Room or CAMDS CMO. An upset condition is identified in the TOCDF Control
Room either by notification from site personnel (including the CAMDS CMO) or via
alarms or abnormal system readings. Control Room personnel in conjunction with the
CAMDS CMO persorurel, if applicable, perform an initial assessment of event conditions
to determine the appropriate immediate response actions. These actions may involve
providing guidance to first responders on how to properly confine thehazard and establish
perimeter control, and/or may be requests for support from organizations such as Medical,
TEAD Fire Department, or the HAZMAT Team.
9.7 .1.2
9.7.1 .3
9.7 .t.4
9.7.1 .5
9.7.2
9.7 .2.7
Attachrnent 9 - Page 8l
9.7 .2.2
9.J .2.3
9.7 .2.4
9.',l ,2.5
9.7 .2.5.r
9.7 .2.s.2
9.7 .2.5.3
9.J .2.6
9.7 .2.7
TOCDF
Contingency Plan
June 2009
Following the determination of required immediate response actions, the IC will begin the
protective action decision-making process. The process involves an analysis of the
following event conditions and factors: type of actual or potentiallnzard; anticipated
hazard duration; time of hazard occurrence; meteorological conditions; projected or actual
event impacts; and projected or actual populations affected byhazard.
The selection ofprotective actions is based on the goal ofreducing personnel exposure to
the hazard and reducing overall event impacts. For many smaller events, no protective
actions may be required. For events with a slightly larger potential for personnel danger,
the donning of protective masks, such as would be appropriate in a Chemical
Accident/Incident, may be ordered as a precautionary protective action. For events that
pose a more serious and imminent danger to personnel, a determination must be made
between in-place sheltering and evacuation.
The protective action of evacuation will be implemented primarily for events involving the
sustained release or continued presence of chemical agent or other hazardous materials.
The protective action of in-place sheltering will be implemented primarily for the
following situations:
Events involving a short hazard duration in which personnel could avoid hazard exposure
by staying indoors until any released materials can pass through the area
Events where time or protective equipment is not available to avoid significant exposure to
personnel
ln lieu of evacuation when weather or other conditions do not permit a safe evacuation
Immediate protective actions may be implemented by personnel in the hazard area upon
identification of an emergency event. Subsequent protective actions, however, are
determined and issued by the IC. Since the IC position is filled by the TOCDF Plant Shift
Manager, who is always available on site, TOCDF has 24-hour, protective-action,
decision-making capability. In a Chemical Accident/lncident, the CAICO in the DCD
(DCD EOC) will determine the appropriate protective actions for the entire installation,
including TOCDF and TOCDF-operated facilities. The EOC also provides protective
actions to EG&G personnel for post emergencies, which affect TOCDF-operated facilities.
When protective actions have been determined and affected areas and populations defined,
the information is relayed to the following groups by the method shown in Table 9-7-1.
Table 9-7 -l
Protective Action Communication
Group Method of Contact
TOCDF Site Personnel Public Address System
On-Scene Responders Public Address System, Telephone, & Radio
CAL Telephone
Stark Road Offices Telephone
Attachrnent9-Page82
TOCDF
Contingency Plan
June 2009
Table 9-7-l
Protective Action Communication
Group Method of Contact
DCD (via EOC)Telephone
CA]\4DS Public Address System & Telephone
ATLIC Public Address System & Telephone
9.7.2.8 It is important that all affected personnel and groups immediately carry out protective
_ actions.
9.7 .2.9 DCD is responsible for providing protective action recommendations to off-post
authorities. DCD bases their recommendations in part on information received from
EG&G. The TOCDF Control Room provides DCD's Emergency Operations Center with
the identical information used to develop the site protective actions. Final determination
of off-post protective actions is the responsibility of off-post elected officials.
9.7.2.10 The IC periodically assesses event conditions and evaluates the appropriateness of existing
protective actions (in coordination with the CAICO in Chemical Accident/Incidents).
Only the IC (CAICO in Chemical AccidenVlncidents) has the authority to upgrade or
downgrade protective actions as appropriate.
9,7,3 Protective Action Implementation
O 9.7.3.1 Protective Masks and Agent Antidotes
9.7.3.1.1 All personnel in the vicinity of TOCDF, CAMDS and Area 10 are issued military
protective masks. Included in the issuing process is performance of a fit test and training
on mask use and upkeep. The masks are examined annually at a minimum by the issuing
branch, and each individual is responsible for performing a visual inspection of their mask
monthly.
9.7.3.1.2 The protective masks are designed to prevent inhalation of chemical agent vapors by
personnel. The masks are not designed or intended to be used to limit exposure to any
substances other than chemical agent. If the IC determines that the donning of protective
masks is an appropriate protective action, affected persoru:el will be notified via the
mpthods discussed in Section 9.7.2 of this Contingency Plan.
9 .7 .3.1 .3 In addition to military protective masks, all TOCDF, CAMDS and Area 1 0 persorurel have
been issued three Mark I nerve agent antidote kits. Each kit contains two injectors:
, : Atropine (2 mg) and Pralidoxime Chloride (600 mg). The injectors will be used whenever
,.-- two or more signs or symptoms of mild/moderate nerve agent exposure are being
exhibited or whenever one or more signs or symptoms of severe nerve agent exposure are
being exhibited. The injectors will be applied to either the outer thigh muscle or the
upper, outer-quarter of the buttocks. Site persorurel have been trained in identiSring agent
exposure symptoms and in the use of antidote injectors when they are issued the Mark I
kits.
O g.7 .3.2 Access and Traffic Control
Attachrnent9-Page83
9.'7 ,3,2,1
9.7 .3.3
9 .7.3.3.1
9.7 .3.3.2
9 .1.3.3.3
9.7 .3.3.4
9.7 .3.4
9 .7 .3 .4.1
TOCDF
Contingency Plan
June 2009
Access control will be established to prevent access to the site or specific site buildings
and areas. Depending on the severity and scope of the emergency event, access may be
controlled at the DCD installation main gate, TOCDF Entry Control Facility (ECF),
Control Room, and Clinic, in addition to the hazard-affected buildings and areas at
TOCDF and TOCDF-operated facilities. Access control at the main gate and the TOCDF
ECF will be performed by DCD security personnel. Additional TOCDF access control
capability exists by closi.g the site gates, which are at the northeast and south sides of the
site. Traffic control is intended to facilitate the smooth flow of vehicles during an
evacuation.
In-Place Sheltering
In-place sheltering involves personnel remaining indoors to avoid exposure to the hazard
outside. Most buildings can provide significant protection against industrial chemical
plumes, particularly in releases of short duration. Most non-pressurized buildings,
however, are not air-tight. After a period of approximately two to three hours, the inside
hazardous concentration becomes equal to the outside concentration, and the structure no
longer provides exposure protection. In-place sheltering, therefore, is only effective as a
short-term measure.
In the event in-place sheltering is ordered, personnel will complete the following actions
to ensure the maximum possible exposure protection:
Close windows and doors
Shut off ventilation systems that draw air from the outside
Note: Only applies to ventilation systems NOT specifically designed for agent filtration
(e.g., office air conditioners).
Move away from windows and doors (as appropriate)
Move away from exterior walls facing the hazard (as appropriate)
Individuals outdoors will be permitted to enter a building where personnel are sheltering,
but the time that doors are open must be minimized. Personnel will be prevented from
exiting the shelter, by verbal instruction, until the sheltering protective action is canceled
or changed.
At the discretion of the PSM, personnel accountability may be performed during in-place
sheltering. The designated Point of Contact (POC) for each work group will use their
respective Accountability Roster to perform an accountability of their personnel, then
report the results to the Accountability Coordinator.
Evacuation
Evacuation involves the moving of personnel away from a hazardand to a safe area. An
evacuation protective action may be declared for the entire TOCDF and TOCDF-operated
facilities or a portion of the TOCDF and TOCDF-operated facilities, depending on the
Attachrxent9-Page84
9,7 .3.4.2
9.7 .3.4.3
9.7 .3.4.4
9 .7 .3 .4.s
TOCDF
"-tt'rt*?i#;
event severity and magnitude. A TOCDF-wide evacuation involves all non-essential
personnel at TOCDF-operated facilities leaving the site to a safe location a significant
distance away from the plant.s Essential personnel may be evacuated at a later time as
conditions permit. A partial evacuation involves the movement of personnel from a
specific TOCDF-operated facility, building or area to a safe area at another TOCDF-
operated facility. The Incident Commander (IC) determines which buildings, areas, and
populations are affected by an evacuation.
If a partial evacuation is determined as the appropriate action, all affected personnel will
be notified by the TOCDF Control Room or CAMDS CMO. Personnel in the affected
area will be instructed to evacuate to a specified upwind location. All other persorurel will
be told to stay clear of the affected area. The notification also requests that any personnel
who normally work in the evacuated area but who are presently at other site locations
report their whereabouts to the TOCDF Control Room or CAMDS CMO.
Figures 9-7-1 through 9-7-34 show escape plans, which are posted in each building as
applicable. These figures show the best routes out of that specific building. All site
personnel have received training on evacuation procedures. Since CAMDS is currently in
the Closure phase of operations, only CAMDS buildings that are occupied on a regular
basis are included in the figures.
Sweeps of evacuated buildings will be performed to ensure that all personnel have left,
and Points of Contact (POCs) will perform personnel accountability. Based on sweep and
accountability results, the IC will dispatch search and rescue teams as appropriate. The IC
will determine when it is safe to return to the evacuated building or area.
If it is determined that a site-wide evacuation is appropriate, all TOCDF and TOCDF-
operated facilities will be notified by the TOCDF Control Room or CAMDS CMO. All
non-essential personnel will be told to report to the designated muster area. The
evacuation muster sites are indicated on Drawing EG-16-C-0004. There are two
designated TOCDF muster areas:
immediately south of the PSB
immediately north of warehouse S-7
Lr addition, there are two designated CAMDS muster areas, as indicated on Figure 9-7-33:
the CAMDS north access gate
the CAMDS south access gate
9.7 .3.4.6 Signs are posted at the TOCDF and CAMDS muster areas to help persorurel assemble
with their co-workers. The Accountability Coordinator reports to the muster area to
manage muster operations. Visitors to the TOCDF or TOCDF-operated facilities will
t "Non-essential" personnel are those not required to stay during an emergency and perform critical plant operations
or response activities. Persons who must stay and perform task even though the site is evacuating are termed
"essential" personnel.
Attachment9-Page85
9.7 ,3.4.7
9.7.3.4.8
9.',l ,3.4.9
9.8
9.8.1
9.8.2
TOCDF
Contingency?lan
follow the directions of their escort. Escorts will take visitors to the appropriate muster
area, where they will turn over custody of the visitor to the POC for visitors.
Upon completion of muster area operations, the Accountability Coordinator, in
coordination with the IC, will instruct personnel to either evacuate or return to their
normal work locations. If transportation resources are required to support further
evacuation, the IC will request resources from DCD.
In some cases, Privately Owned Vehicles (POVs) will be used for evacuation. When
evacuating in POVs, personnel will follow one of the DCD-designated routes used for
evacuation from TOCDF. Figure 9-7-3I is a DCD site map depicting the possible
evacuation routes from the TOCDF.
The TOCDF Control Room and TOCDF Clinic are intended to be occupied by response
personnel during most emergencies, even when the rest of the TOCDF is evacuated. Self-
contained ventilation systems, filtered air systems, and positive pressure are among the
engineered features of these buildings, which allow them to provide exposure protection to
occupants. These buildings are locked during emergency events to control access.
REQUIRED REPORTS [R31s-8-4.7(i) and (ilI
Required reports are made in accordance with R315-8-4.7(i) & (i) and TOCDF Part B
Permit Conditions.
The operator must note in the operating record the time, date, and details of any inciderrt
that requires implementing the Contingency Plan. For any emergency event requiring
HAZMAT release reporting, the control room will notiffthe DCD EOC and the CMA
Shift Engineer and provide a copy of the event report. All reporting to the Army, local,
State, and Federal agencies will be handled by DCD.
Attachrnent9-Page86
TOCDF
Contingency Plan
June 2009
I----!ir--;;----] t----;;-*l l-- *"----l i
i l Gr)rRATlBNs MANAcr"R firurtaAL MANAcr.fi l ii!--- '*f - i
Figure 9-L-1
TOCDF Emergency Response Organization
MANAGI}'TNT AilVI $GRY I[AM
nf'l*SCil'ffl
I NC I n[NT C0l'lil4ANt][fi
rt)8sc )
{ [Mf TiGENCY CG0Ril lf,lATilR i
t"r*'ffiF*l
1.""itne*t,wx:";.. I
I
i'},tRAtnli:D it -
|
Tr*,tht Lt:AtjtR " I
till'rTl?GL fi0ilh{
I]i.. FRATilR5
ti. il ll3/ tJP,l ii r::pr, nA T'JFis i*-*
i,)Sir
upLHATiltiS
l,A.S,rUT 11.. I TY
ilr,IHA ItjftS
I RR',l,/R,LA I
I li,ltiA I ciis i
p,gir 1$ttH*r
t'l,1Zt-lAT
IiAl,{ i-EArtfi
Attachrnent9-Page87
TOCDF
Contingency Plan
June 2009
TOCDF Contractor
Management Advisory
Team
Director of Operation
(DCD EOC)
TOCDF IC
(TOCDF Control Room)
DCD DOSC
(FTELD)
TOCDF
RESPONDERS
Figure 9-l-2
DCD Emergency Response Organization (Chemical Event)
Attachment9-Page88
TOCDF
Contingency Plan
June 2009
Figure 9-3-1
Initial Response Activities
Attachment9-Page89
TOCDF
Contingency Plan
June 2009
LE5ETID:
o cuSINEc ErEurSH &Axl)- 0'dEErEAIl SHUilER STrt toN
u EE[0N SHUffiF
O C$EINE0 E'E[t}{ ANE
UTILITI STATI DI
01 301 I H0, 1 03
Figure 9-5-1
MDB l't Floor Eye Wash & Decon Stations
Attachrnent9-Page90
TOCDF
Contingency Plan
June 2009
ttIB
I
LEGEND:
- MEZZANINE LEVEL
COMEINED DECON AND UTIIITY STATION
DECOH $HOI',UER
t r:t lrtIr
1:El[1it'!
r:
lml:
tllJll!lq, [._._
Itr rlr
s.rr1 Fq':lD
l'
Hr" *'
UIll I
rtt a:.Itrr '.Il((
uLr,ir Id\z rA
q+Tr
.F....tlrr.X,
IEE
,:1 rErlSFl l!(.
ia.lfl
Figure 9-5-2
MDB l't Floor Mezzanines Eye Wash & Decon Stations
f:t tr[}:tltf
IJEI IJII
il.4.d
'Itm
Attachrnent 9 - Page 9l
TOCDF
Contingency Plan
June 2009
{yI-,6
II
r-carrun.
1$ cohrBru=D EvEv,/ASH &ANB ovERHEAD sHov'/ER srATloH
+ co[.tBtNED DECoN nND unlrry srAT oN
af tr 'tB.,il,TD
:-.r-l{
Figure 9-5-3
MDB 2nd Floor Eye Wash & Decon Stations
Attachrnent9 -Page92
TOCDF
Contingency PIan
June 2009
o
LEGEl.ID:
ffi h'lEZZANlhlE LEVELi .- ....r.-.,";
tr DEcoH sHowER
Figure 9-5-4
MDB 2nd Floor Mezzilnines Eye Wash and Decon Stations
Attachrnent9-Page93
TOCDF
Contingency Plan
June 2009
t)
/
ZND FLOOill
LFSFHD:
A COTEINED EYETASH AHD-" OI/ERHEAD SHDTER STATIOI{
Figure 9-5-5
PUB I't Floor Eye Wash Stations
I{II#
=w--
E,;'; '! -:6 n"=LiifiL
\.-/-.n=.sy
=N.;4, E%
Attachrnent9 -Page94
TOCDF
Contingency Plan
June 2009
ril'
ttI
F
.LEGEFID:
0 corlrBrlrEu EvF,'.IASH &ANB o,,ERHEAD gHDtvER srATIoN
Figure 9-5-6
PAS 100 FT Level (Ground Floor) Eye Wash Stations
Attachrnent9-Page95
TOCDF
Contingency Plan
June 2409
r iltil[ ]
rf l'
::lt
I J':
Ar.-'-,J'[,, _ .,. .,.FErfllji11,.,il __i*r,*A__-j-i
. t iillll' , l
I
ffilllillf#iililrr r t,i :t:
l''.
.l
r lrlliili
llilll
l.:[llI i,tll
'r___llfililil
t_. . ...
f,1: : ;l
.-. - ,*-fl
e COhIBINED EYEWASH &AND OVERHEAD SHOU\IER STATION
Figure 9-5-7
CHB l't Floor Eye Wash Stations
Attachment9-Page96
TOCDF
Contingency Plan
June 2009
tt
{
LECEN0:
^A
A8C IYPE EXT I NGU t SHER
(HAN[) HELOI
EE
m
reil
FIRE ALARM CONIROL PAI'IEI.
flITH PANEL NUMSER
F IRE SYTE}I AN}IUNC I AI(]R
II tTH PANEL NUMER
HALSI CONIROL PANEL
'N I TH PANEL NUi€ER
Figur e 9-7 -l
MDB l't Floor
Attachrnentg -Page97
<rExlT
ttI
P
TOCDF
Contingency Plan
June 2009
L EGEN0.;
A TU.OH TYPE TXTINGUISH:R
( HAN[) HILD )
- - EX I I iOUTE UNOER U€Z ZAI{ I EilE!
<r E}(tI N0TE: Fffi TOxlc
,.fiEAS EXII VIA THE
REYERSE PATH OF
EHT1Y AS AI.TERHAIT
ROUTE5 TILL BE LOCKEI}.
Figur e 9-7 -2
MDB I't Floor Mezzanines
Attachrnent9-Page98
TOCDF
Contingency Plan
June 2009
t
/
r*l
lflq-*(J
L'--t.li5
EE
Htrl
tFF
'{EE!t t
I-ffit
["F
L-rE*cYcHuTE
-
LEfiEuo i
A A8C TYPE EXTTNGUI5I{ER
(HAt$ HELO I
IffiI FIRE ALARU COIIT8Or:r ,1IH PAIIEL t{tl€gfl
IffiI FIRE SYIEil AIffiI}TCrt J'rr rlTH Ptf{EL HITEER
<rExlI
-,--E; EXtr nruTE YIA sIAlf,s
TO I sT FLG]R
Figure 9-7 -3
MDB 2nd Floor
Attachrnentg-Page99
TOCDF
Contingency Plan
June 2009
,YI
P
I .r-{..- _ Lt Sillfl:--_-
l -l-
-
A +!i.3H. llIrtrtulsHEnL{ .. r
--
tHi.,IO!+ILDI
{-Ertr
=,ru.- ixlf HrI'TE TI.{ SIllP.S
fE lrt F'-tIIft
J{UTE: Fln TOT:C
.{NEIs EI IT U IT IHE
R:VEi5E PITH tr
ErrRr 15 *L r[.+{rIE
HHJIE5 IILL ET I[EI(E[}.
Figur e 9-7 -4
MDB 2nd Floor Mezzanines
Attachrnent 9 - Page 100
TOCDF
Contingency Plan
June 2009
#I
P
ZND TLOOR
.H-\
-r{I
I
!!LJ
b
l----:tr
l--E--L _ . ='.'Jt
t
!
t
-l=.i
I
I
;
.lItI
=l
m
l.[
lr tri -r
: tr
!
trtr
trtr
Figur e 9-7 -5
PUB I't Floor
L tEEts;
4 ,rBrl TIPE EXI tnfi U t$En
{ III}ID HELO ]
A HTLIil ITPT ETIttIIUIsIIER
I HTIf, HELO ]
{-EIIT
#+-G
r
Attachrnent 9 - Page l0l
TOCDF
Contingency Plan
June 2009
I
I
i
I
ttIf H
3
H
tr,
Eh
Figur e 9-7 -6
PAS 100 Ft Level (Ground Floor)
-:]t
,l
{
I
Itri
L EGENQ:
6 l8C TYPE EXTINGUTSHER
(HANO HELO I
A HALON TYPT EXT INGU t SHER
(HANO HEL[}}
<iExlT
Attachrnent 9 - Page 102
TOCDF
Contingency Plan
June 2009
ttI
P
f
!
I
I
I
I
-{
I
I
li
=
I r--$ir't[ ;
#38-H I to' LSIEL
A ,tEC rPt E:(T Io{tII | s.rE B
T HND TITL D I
{rExlr
rrr EX:I R0JT[ LHDER
PLI TFflftIJ
Figur e 9-7 -7
PAS 16 Ft Level
Attachrnent 9 - Page 103
TOCDF
Contingency Plan
June 2009
o
tE
f,
/
. 'rEIEttr:
ffiSrlq'IE\EL
ffi,qFEtlg'tEtr-L
trffi llE'fflHtTof, HtusE
tr-- t tet' LEUSL
Wr1:filIE' LEvEL
Ef".?TTt l2g' LEI/EL
A TEI T'TIE ETT IFIOI'T SHEH
I Ht,rln ffiL I :
llfLtF :n: it lfru IEHIRIIL P tIE:r lt:{ f ttf,.:- I'tulJSEE
{-ExtT
rrd- EX,I P[U-E UIII]EH.
FL[T;EFI/
Figure 9-7-8
PAS ll4-129 Ft Levels
Attachrnent 9 - Page 104
TOCDF
Contingency Plan
June 2009
.fI
P
' iESEh0:
i;.:[ltE tlE' LE'fi1
f{Tfirqffi I l.r' LEvEL
tffiliEit I ts' LE'JEL
FnZa l{l' LEUEL
a rEc IrrE E rT t HGU t Silil!
tHillII l{Elll I
{-EnI
dr= EJ(:T flUJT: UIIIER
Fr-tTttHll
Figure 9-7-9
PAS 128-141 Ft Levels
Attachrnent 9 - Page 105
TOCDF
Contingency Plan
June 2009
+I
P {
T;i:l;l:-
'.'i-r-
I
L
niiil
d
I
I
l
a
tu
nlr,\J,
,^.
I
\-/'
C.
i.
-\:!*\-/
TEfiEIItr:
Effi:50', Ltuut
H*=,,F-.tr= r(?'.LEYEL
a ,tEc TrPE Err lil0u t SHEH
THAHD HTLD)
{rEIIT
E!(tI RI]UTE UHllEfl
fLTIFTRI
Figur e 9-7 -10
PAS 147-150 Ft Levels
Attachrnent 9 - Page 106
TOCDF
Contingency Plan
June 2009
tt
{
LEGENO:
F'ffi'f'''-q I 59' LEYEL
ffillo'LEvEL
a, ABC TYPE EXT I NcU I SHER
( HANO HELO I
<rExlT
-,E-- ExlT RoUTE UNoER
PL AIF ORM
Figure 9-7 -ll
PAS 159-170 Ft Levels
Attachrnent 9 - Page 107
TOCDF
Contingency Plan
June 2009
tt
/
IIL -^:J LEGENO:
A ABC TYPE EXTINGUISHEfl
(HANO I{EL[) }
<iExlT
Figure 9-7-12
CHB
Attachrnent 9 - Page 108
TOCDF
Contingency Plan
June 2009
+
{
F
r Fn4!r}:
a rEc rrPE ErrlNCU isHEH
tr.rAr{u HEL 0 r
Figur e 9-7 -13
PSB
Attachrnent 9 - Page 109
TOCDF
Contingency Plan
ruY00e
t{
/
l.EGEN0-:
a A8C fiPE ExTINGUtSHER
( HAilO HEL[) I
<E
Figur e 9-7 -14
MSB Plan
Attachrnent 9 - Page 110
TOCDF
Contingency Plan
June 2009
fI
F
I EGEI{TI:
A rEf, ITFE ETIIIIEU lslf,H
t H TITJ HELO I
+E!(ir
Figur e 9-7 -15
ECF Plan
Attachment9-Pagelll
TOCDF
Contingency Plan
June 2009
ltI
f,
I
I
I
l
t
$,eflft
s rEC TTPE ExTlt{CUl${Eil
{ HAI''|0 }iELo )
A H[TI}+ I'fPt EXT IHGIJ TSHEE
(Hltt0 HILD )
{-ExlT
Figur e 9-7 -16
PMB PIan
I
EI
IEI
-;-1-,,1'i-
Ilr
Attachrnent 9 -Pagell2
TOCDF
Contingency Plan
June 2009
*S
-1
I
I
I
{
I
ij
I
I
I
i
I
Il
I
I
I
I
I
I
&L->
?NQ FLQQR
PARTIAL PLAN
MAIN FLOOR
Figure 9-7-17
S-1 Plan
LEGEND:
A ABC TYPE EXTINGUISHEH
(HANO HEL[)I
<*Extr
Attachrnent 9 - Page I l3
TOCDF
Contingency Plan
June 2009
--+(5_
A ABC TYPE EXTINGUISHER
( HAND HELD )
<-ExlT
Figure 9-7-18
S-2 Plan
Attachrnent 9 - Page I 14
TOCDF
Contingency Plan,T 200e
:l-t
I
-l
--4.
-
[,,IAIN TLCCIT
I ETEilT:
+ iE{ T[2E EHT I t{HJ t SHEI
(H,I}r:. HELII }
{-ill'
Figur e 9-7 -19
S-3 Plan
SiCOND ILOCR
Attachrnent 9 - Page I l5
TOCDF
Contingency Plan
June 2009
r-flh---
PARIIAL PLAN
$TIXHO FL{TH .IIIHIH
lt
--
ffi
',FFF ffi- 1----l\l
\___ r
MAIN TLOOR
Figur e 9-7 -20
S-4 Plan
O
I
i
Tt
f
l
It'i
+
I
+
I
;.
t
i
I O
PARTIA-L. PLAN
sEc(fiil FLMfl sOU IH
LECEYE:
A AE{ TYFE EXTTIISUISTEE
f HrllD ,-ti t.u ,
{iL(rr
o
Attachrnent 9 - Page I l6
TOCDF
Contingency Plan
June 2009
R!*!- Il.
I
'li[.!l
-EA
\unEr
I
t
l
l
I
tlt-l AI
-Tr^
-^[-+,.- -fR
0L0(
T
00
STTOND FI
E.{5-
.
a
i
i
\ rrng t
-{,n-
T
I!1AIN TL
F
IF]---j ELJ=' E
TL,_lt}r-
*-14!--
STCOND TLOOR
IEs I
$ttltt':
t qiC IlPl EI(TIHGU tSHEl
I ir,llD ]l-LL0 :
+;xir
Figur e 9-7 -21
S-5 Plan
Attachment 9 - Page I l7
*,-T+-
FLOCR
rT I rmi,i
{--== I - -=='tI
Figure 9-7-22
5-6 Plan
Attachmentg-PagellS
TOCDF
Contingency Plan
June 2009
M:ZZAIIJNE
L FEEIJD:' 5 i.B[ ;TPi Ei{I l}lfrr,silE,q
I H,tl#l HEL'.I1
{ii{rr
Attachrnent 9 - Page I l9
TOCDF
Contingency Plan
June 2009
lt
{
F
LrfiElfr
A .lflC -IFE iXTIHGJ:STIEI
I HAtlu HE-[) i
{riI:-
Figur e 9-7 -24
Q u ality/E nviro nm enta I
Attachrnent 9 - Page 120
TOCDF
Contingency Plan
June 2009
T-?.J
LtrjEl*10 t
a AEI TTPE EX; tf{,}J I SHE t
(Hixrl HEt.tl l
{iETIT
T-20 IftT t LEf, I{UI,{IEf,
E I[ E]tG : I'tt tt I ]lt TEA IL tx' i0l#L Ex
Figur e 9-7 -25
ETC
Attachment9 -Pagel2l
TOCDF
Contingency Plan
June 2009
--*#-
A THC TIP E EXT IHGU l S|{ER
.
!HIhD }TEIDI
+ExtT
Figur e 9-7 -26
T-2s
Attachrnent9 -Pagel22
ilItrI
O
O
LIITilU
{iHrrT
Figur e 9-7 -27
T-26
o
Attachment9-pagel23
TOCDF
Contingency Plan
June 2009
,trI
P
L F(E tl0 :
A ilEC TIPE :If :ltiul5H:H
t H,tJl0 HEL.I I
{-ExrT
Figur e 9-7 -28
T-27
Attachrnent9 -Page124
TOCDF
Contingency Plan
June 2009
,fI
P
LE fiEIS:
A ATC IYFE E:( T IXU ishEft
( l{liill . EI,D :
-#=IlI
Figure 9-7 -29
T-28
Attachrnent9 -Page125
TOCDF
Contingency Plan
June 2009
CARBO}I ADSORPTIOil
FILTRATP}I SYETET
A
LEGE]tID
a ABC TYPE EXTTilGUTSITER
(HANO HELOI
+EXIT
Figure 9-7-30
Igloos 1631, 1632 and 1633 Plan
Attachment9 -Page126
TOCDF
Contingency Plan
June 2009
BLBG 3311 gf, HRE Emrffi.nsHffi
d> RRE ESCAPE nCA,JIE
@ mrnurL THP RRE flr,Rm
Figur e 9-7 -31
CAMDS Buildings 3309, 3311 and 3314 Plans
Attachment9 -Pagel27
TOCDF
Contingency Plan
June 2009
tr-g
FNE EXIilGT.IS}GR
FNE ESCAPE Rd'TE
Figur e 9-7 -32
CAMDS Buildings 3308, 3310 and 3315 Plans
Attachment 9 - Page 128
TOCDF
Contingency Plan
June 2009
PSC SECOND FLOOR
CoMMAND POST (CP)
A FRE Exrilqfl3lcR
4 FFEESCAPEROUTE
o ffit**
Figure 9-7-33
CAMDS Personnel Support Complex (PSC) and Command Post (CP) Plans
Attachrnent9 -Pagel29
TOCDF
Contingency Plan
June 2009
BLDG 7085
A, t a Em*flrsl*n
-}-
FmE ErcAPE notm
@ umur rnP FnE rtril
@rrmaarcY EYrw J{ rrAnoil
coNTRoL iilODULE (clr[O]
Figur e 9-7 -34
CAMDS Site Analytical Facility (SAF), Building 7085 and the Command Module (CMO) Plans
slrE AilALYnCAL FACTUTY (SAFI
Attachrnent 9 - Page 130
TOCDF
Contingency Plan
June 2009
+--E--.
Figure 9-7-35
DCD Site Evacuation Map
o
t II
i f,oI'
L
Attachrnent9-Pagel3l
I,
L

tr

O\
/\

co
o
F(
7\

A
\J
\J

t+
i

l\
l
I
bg
LF
(
Iot
s
bo
'

.
o(J
C.
l
coobo
CO
F-
'
.
Io\oocd
Ax6€
-lFrU2+)
tH.-
to=A
qJ
r-
-
9c
s
tt
Y
\o

-r
i€L)
E
ld
o
.-+Jcg
-l-CJ6{
FE
I
qE
Flts
r5ALroU
CA
caobodA!OtoOco
cnq)
lrLq)
+JaI-EIe-tJ
\o
t
r
mc
n
I\EO\
O
.-
Hb
Y
r,

-'
l
-F
{O0
-
.-
.
-
r-

L\
.
HL
q)
dHq)
rlvV)aE(ZU
o
EH
=
is
s
gf
f
i
r$
frt
TOCDF
Contingency Plan
June 2009
Figure 9-7-37
ATLIC
IGLOO 1639
/' ni err ']
, r:-l'.t, -!f*. _lX
LEGEND
{- EXIT
{:_)(_7
@
a (:7
I ;*4e ^?l !I Sri'q& , tir i
Attachment9 -Pagel34
()
(D
TOCDF
General Facility Drawings
June 2009
ATTACHMENT 11
GENERAL FACILITY DRAWINGS
ARCHITECTURAL 1t'A" series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-7-A-8 CHB - Areas 7 -l through 7-8 NORTH
ELEVATION
3 06128191 Y
TE-7-A-9 CHB - Area 7 -2 through 7-9 SOUTH
ELEVATION
2 06128191 Y
TE-7-A-10 CHB - Unloading/Storage Area EAST &
WEST EXTERIOR ELEV
3 06128191 Y
TE-7-A-11 CHB - Center Area EAST & WEST
EXTERIOR ELEV
2 0612819r Y
TE-7 -A-12 CHB - Transition Area EAST & WEST
EXTERIOR ELEV
3C 02124193 Y
TE-7-A-13 CHB - Transition Area NORTH & SOUTH
EXTERIOR ELEV
3C 02124193 Y
TE-7-A-14 CHB _BUILDING SECTION A 3 07lt8l9t Y
TE-7-A-20 CHB - ROOF PLAN IC 02124193 Y
CML (?rC, series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-16-C-2 Site Work - OVERALL SITE PLAN &
VICINITYMAP
t4 U3U97 Y
TE- l6-C-3 Site Work - Topographic Map (restricted
access - protected record)
17 0U0sl09 Y
TE-16-C-4 Site Work - Area 1 PLOT PLAN 13 I13U97 Y
TE- 16-C-s Site Work - Area 2 PLOT PLAN 13 07 lt8l06 Y
TE-16-C-6 Site Work - Area 3 PLOT PLAN 10 10124194 Y
Attachment I l, Page I
TOCDF
General Facility Drawings
June 2009
MECHANICAL PROCESS (,Drr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-00-D-901 General Symbols and Legend PIPING &
INSTRUMENT DIAGRAM
18 02124109 Y
TE-1-D-9 MDB - Spent Decon Collection PIPING &
INSTRUMENT DIAGRAM
31 09127107 Y
TE-l-D-10 MDB - Spent Decontamination Collection
System PIPING & INSTRUMENT
DIAGRAM
18 0s124106 Y
TE-1-D-501 MDB - Rocket Processing System (A)
PIPING & INSTRUMENT DIAGRAM
33 06117108 Y
TE-1-D-502 MDB - Rocket Processing System (B)
PIPING & INSTRUMENT DIAGRAM
33 0912s108 Y
TE-1-D-503 MDB - Mine Processing System PIPING &
INSTRUMENT DIAGRAM
l4 0s120199 N
TE-1-D-505 MDB - Proj/Mortar & Bulk Item Processing
System (A) PIPING & INSTRUMENT
DIAGRAM
t4 09109196 Y
TE-1-D-506 MDB - Proj/Mortar & Bulk Item Processing
System (B) PIPING & INSTRUMENT
DIAGRAM
t4 09109196 Y
TE-l-D-507 MDB - TraylDunnage Processing System
(A) PIPING & INSTRUMENT DIAGRAM
t2 0y30196 N
TE-1-D-508 MDB - Tray Processing System (B) PIPING
& INSTRUMENT DIAGRAM
13 0U30196 Y
TE-1-D-509
I of 2
MDB - Projectile/M ortar Disassembly &
Output (A) PIPING & INSTRUMENT
DIAGRAM
t6 09130/08 Y
TE-1-D-509
2 of 2
MDB - Projectile/Mortar Disassembly &
Output (A) PIPING & INSTRUMENT
DIAGRAM
l5 08/r sl96 Y
TE-t-D-510
I of 2
MDB - Projectile/Mortar Disassembly &
Output (B) PIPING & INSTRUMENT
DIAGRAM
16 09130/08 Y
TE-1-D-510
2 of 2
MDB - Projectile/Mortar Disassembly &
Output (B) PIPING & INSTRUMENT
DIAGRAM
t4 08/l s196 Y
TE-l-D-51I
I of 2
MDB * Multiposition Loader (A) PIPING &
INSTRUMENT DIAGRAM
t2 0s109196 Y
TE-1-D-51 1
2 of 2
MDB - Multiposition Loader (B) PIPING &
INSTRUMENT DIAGRAM
lt r2lt319s Y
TE-t-D-512 MDB - Buffer StoragelCharge Car (Znd
Floor) PIPING & INSTRUMENT
DIAGRAM
t4 06104108 Y
L
Attachrnent 11, Page 2
TOCDF
General Facility Drawings
June 2009
MECHANICAL PROCESS (rrDrr series drawings)
DRAWINGNUMBER DRAWINGTITLE
REV.
#
REV.
DATB
APPROVEI)
RCRA
BASELINE
TE-1-D-513
I of 2
MDB - Buffer Storage PIPING &
INSTRUMENT DIAGRAI\{
t1 t2l0719s Y
TE-1-D-513
2 of 2
MDB - Buffer Storage PIPING &
INSTRUMENT DIAGRAM
l4 06104108 Y
TE-1-D-514 MDB - Multipurpose Demil & Bulk Drain
System (B) PIPING & INSTRUMENT
DIAGRAI\{
24 08/1 1/08 Y
EG-O1-D-514 MDB - Multipurpose Demil & Bulk Drain
System (B) PIPING & INSTRUMENT
DIAGRAM
33 031t7109 Y
TE-1-D-515 MDB - Multipurpose Demil & Bulk Drain
System (A) PIPING & INSTRUMENT
DIAGRAM
18 tUt3l0t Y
EG-01-D-515 MDB - Multipurpose Demil & Bulk Drain
System (A) PIPING & INSTRUMENT
DIAGRAM
39 03117 109 Y
TE-1-D-516 MDB - Multipurpose Demil & Bulk Drain
System (A) PIPING & INSTRUMENT
DIAGRAM
13 03117109 Y
TE-t-D-517 MDB - Multipurpose Demil & Bulk Drain
System (B) PIPING & INSTRUMENT
DIAGRAM
l3 03117 109 Y
TE-t-D-521 MDB - Agent Collection System PHS-
MDM-101 PIPING & INSTRUMENT
DIAGRAM
29 03lrt 109 Y
EG-01-D-521
I of 2
MDB - Agent Collection System PHS-
MDM-IOZ PIPING & INSTRUMENT
DIAGRAM
26 0910s107 Y
EG-O1-D-521
2 of 2
MDB - Agent Collection System PIPING &
INSTRUMENT DIAGRAM
29 09124107 Y
TE-t-D-526 MDB - LIC Furnace No. I - Primary
Chamber PIPING & INSTRUMENT
DIAGRAM
56 01/08/09 Y
TE-l-D-527
l of 2
MDB - LIC Furnace No. 1 - Secondary
Chamber PIPING & INSTRUMENT
DIAGRAM
27 0s13y06 Y
TE- t-D-527
2 of 2
MDB - LIC Furnace No. I - Secondary
Chamber PIPING & INSTRUMENT
DIAGRAM
15 10/08/98 Y
TE-1-D-528 MDB - Metal Parts Furnace PIPING &
INSTRUMENT DIAGRAM
4t 02103109 Y
EG-1-D-528 MDB - Metal Parts Furnace PIPING &
INSTRUMENT DIAGRAM
24 07 129108 Y
TE-r-D-529 MDB - MPF Burners PIPING &
INSTRUMENT DIAGRAM
2t 03120107 Y
Attachment 1 l, Page 3
TOCDF
General Facility Drawings
June 2009
MECHANICAL PROCESS (rrDrr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-1-D-530
I of 2
MDB - MPF Details PIPING &
INSTRUMENT DIAGRAM
t7 0410610s Y
TE-1-D-530
2 of 2
MDB - MPF Details PIPING &
INSTRUMENT DIAGRAM
t9 a9Dsl08 Y
TE-1-D-531
I of 2
MDB - DFS Retort PIPING &
INSTRUMENT DIAGRAM
33 07 lr4l08 Y
TE-1-D-531
2 of 2
MDB - DFS Heated Scrap Discharge
Conveyor PIPING & INSTRUMENT
DIAGRAM
t7 09103198 Y
EG-01-D-531 DFS Retort PIPING & INSTRUMENT
DIAGRAIVI
31 081091a7 Y
TE-1-D-533 MDB - DFS Air Blower/Retort Lube Oil
System PIPING & INSTRUMENT
DIAGRAM
t7 09/30/08 Y
TE-1-D-534 MDB - Toxic Cubicle - Spent Decon
PIPING & INSTRUMENT DIAGRAM
40 04104108 Y
EG-O1-D-534 MDB - Toxic Cubicle - Spent Decon
PIPING & INSTRUMENT DIAGRAM
38 04104108 Y
TE-1-D-535 MDB - Toxic Cubicle - Spent Decon
PIPING & INSTRUMENT DIAGRAM
40 04104108 Y
TE-1-D-536 MDB - Toxic Cubicle - Agent PIPING &
INSTRUMENT DIAGRA]\{
45 tU07 107 Y
TE-l-D-546 MDB - LIC Furnace No. 2 - Prrmary
Chamber PIPING & INSTRUMENT
DIAGRAM
53 612512008 Y
TE- t-D-547
I of 2
MDB - LIC Furnace No . 2 - Secondary
Chamber PIPING & INSTRUMENT
DIAGRAM
32 0U29109 Y
TE- t-D-547
2 of 2
MDB - LIC Furnace No. 2 - Secondary
Chamber PIPING & INSTRUMENT
DIAGRAM
13 r 0/08/98 Y
TE-1-D-551 MDB - Rocket Shear Machine Feed (A)
PIPING & INSTRUMENT DIAGRAM
t2 0U27 196 Y
TE-l-D-552 MDB - Rocket Shear Machine (A) PIPING
& INSTRUMENT DIAGRAM
13 0s/17196 Y
TE-1-D-s53 MDB - Rocket Shear Machine Feed (B)
PIPING & INSTRUMENT DIAGRAM
t2 0U27 196 Y
TE-1-D-554 MDB - Rocket Shear Machine (B) PIPING
& INSTRUMENT DIAGRAM
2t 0912s108 Y
EG-O1-D-3501 TOX-Remote Agent Sampling System
(RASS) PIPING & INSTRUMENT
DIAGRAM
13 04104108 Y
Attachment I l, Page 4
TOCDF
General Facility Drawings
June 2009
MECHANICAL PROCESS (rrDrr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
EG-O1-D-4902 Multipurpose Demil & bulk Drain system
(Mercury Tons) PIPING & INSTRUMENT
DIAGRAM
10 08/l 1/08 Y
EG-01-D-8801 MPB - Heel Transfer System PIPING &
INSTRUMENT DIAGRAM
4 0U2U09
TE-2-D-501 PUB - Brine Surge Tanks and Pumps - Line
1 PIPING & INSTRUMENT DIAGRAM
27 08l2sl0s Y
TE-}-D-502 PUB - BRA Evaporator - Line I PIPING &
INSTRUMENT DIAGRAM
20 08l2sl0s Y
TE-2-D-503 PUB - BRA Drum Dryer - Line I PIPING &
INSTRUMENT DIAGRA]\4
2t 12120105 Y
TE-2-D-504 PUB - BRA Drum Dryer - Line 1 PIPING &
INSTRUMENT DIAGRA]\{
2t l2l20l0s Y
TE-2-D-505 PUB - BRA PAS Burner & Manifold
PIPING & INSTRUMENT DIAGRAM
20 12120105 Y
TE-2-D-51 I PUB - Brine Surge Tanks and Pumps - Line
2 PIPING & INSTRUMENT DIAGRAM
26 08lzsl0s Y
TE-2-D-512 PUB - BRA Evaporator - Line 2 PIPING &
INSTRUMENT DIAGRAM
l9 0812410s Y
TE-2-D-513 PUB - BRA Drum Dryer - Line 2 PIPING &
INSTRUMENT DIAGRAM
22 tzl20l0s Y
TE-6-D-501 PAS - LIC No. 1 - PAS Quench and Venturi
PIPING & INSTRUMENT DIAGRAM
40 09118/08 Y
EG-06-D-501 PAS - LIC No. I - PAS Scrubber Tower
PIPING & INSTRUMENTATION
DIAGRAM
37 03112109 Y
TE-6-D-502 PAS - LIC No. 1 - PAS Demisters PIPING
& INSTRUMENT DIAGRAM
21 07 l18/06 Y
TE-6-D-503 PAS - Demister Acid Waste System PIPING
& INSTRUMENT DIAGRAM
19 07 lt8la6 Y
TE-6-D-504 PAS - MPF PAS Quench and Venturi
PIPING & INSTRUMENT DIAGRAM
44 09118/08 Y
EG-O6-D-s04 PAS - MPF PAS Scrubber Tower PIPING &
INSTRUMENT DIAGRAM
43 031r2109 Y
TE-6-D-505 PAS - MPF PAS Demister PIPING &
INSTRUMENT DIAGRAM
28 07 lt8/06 Y
EG-06-D-505 PAS - MPF PAS Exhaust Blowers PIPING
& INSTRUMENTATION DIAGRAM
40 03126109 Y
EG-O6-D-s06 PAS - DFS PAS Scrubber Tower
PIPING & INSTRUMENT DIAGRAM
41 02124109 Y
TE-6-D-506 PAS - DFS PAS Quench and Venturi
PIPING & INSTRUMENT DIAGRAM
43 02124109 Y
TE-6-D-507 PAS - DFS Exhaust Blowers & Stack
PIPING & INSTRUMENT DIAGRAM
28 tzla3l08 Y
Attachment Page 5
TOCDF
General Facility Drawings
June 2009
MECHANICAL PROCESS (rrDrr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVEI)
RCRA
BASELINE
EG-06-D-s07
I of 2
PAS - DFS Exhaust Blowers & Stack
PIPING & INSTRUMENT DIAGRA]VT
16 0s109196 Y
EG-06-D-507
2 of 2
PAS - DFS Exhaust Blowers & Stack
PIPING & INSTRUMENT DIAGRAM
29 07103108 Y
TE-6-D-508 PAS - DFS PAS Demister PIPING &
INSTRUMENT DIAGRAN4
28 04121/08 Y
TE-6-D-509 PAS - DFS Afterburner PIPING &
INSTRUMENT DIAGRAM
23 07114108 Y
TE-6-D-510 PAS - Recovered Water System PIPING &
INSTRUMENT DIAGRA]\4
24 0912s1087 Y
TE-6-D-51 I PAS - LIC No. 2 -PAS Quench and Venturi
PIPING & INSTRUMENT DIAGRA]VI
4t t213012008 Y
EG-06-D-51 I PAS - LIC No. 2 -PAS Scrubber Tower
PIPING & INSTRUMENT DIAGRAM
40 03112109 Y
TE-6-D-512 PAS - LIC NO. 2 -PAS Demister PIPING &
INSTRUMENT DIAGRAM
2l 07 lt8l06 Y
TE-6-D -517
l of 2
PAS - LIC No. I Exhaust Blower PIPING &
INSTRUMENT DIAGRAM
30 0U20109 Y
TE-6-D -517
2 of 2
PAS - LIC No. 2 Exhaust Blower PIPING &
INSTRUMENT DIAGRAM
3l 0U20109 Y
EG-06-D-891 I PAS Filter System Building LIC No. l,
No.2, MPF PFS Monitoring Ports P&ID
l0 0U20109 Y
EG-06-D-8912 PAS Filter System Building LIC No. 1 PFS
Filter Module P&ID
l0 0U20109 Y
EG-06-D-8913 PAS Filter System Building LIC No. 2 PFS
Filter Module P&ID
10 0y20109 Y
EG-06-D-8914 PAS Filter System Building MPF PFS Filter
Module P&ID
10 0y20109 Y
TE-7-D-503 CHB - CHB Sump and Details PIPING &
INSTRUMENT DIAGRAM
15 r2lt7 199 Y
TE- 16-D-3
2of5
Site Work - Utilities Distribution PIPING &
INSTRUMENT DIAGRAM
43 0912s108 Y
TE-27 -D-501
I of 2
PUB - BRA PAS Baghouses PIPING &
INSTRUMENT DIAGRAM
13 02104198 Y
TE-27 -D-501
2 of 2
PUB - BRA PAS Baghouses PIPING &
INSTRUMENT DIAGRAM
t2 12103197 Y
TE-27 -D-502 PUB - BRA PAS Blower & Stack PIPING &
INSTRUMENT DIAGRAM
16 02119198 Y
Attachrnent I l, Page 6
TOCDF
General Facility Drawings
June 2009
Process Flow Diagrams (ttptt series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATB
APPROVED
RCRA
BASELINE
TE-1-F-s01 MDB - Deactivation Furnace System (DFS)
PROCESS FLOW DIAGRAM
l0 0910s196 Y
TE-l-F-s02 MDB - Liquid Incinerator System (LIC) No.
I PROCESS FLOW DIAGRAM
l0 03103194 Y
TE- 1-F-503 MDB - Metal Parts Furnace System (MPF)
PROCESS FLOW DIAGRAM
5 04l0sl0s Y
TE-l-F-505 MDB - Toxic Liquid Storage (TOX)
PROCESS FLOW DIAGRAM
t4 04101/08 Y
TE-2-F-501 PUB - Brine Reduction Area (BRA) First
Train PROCESS FLOW DIAGRAM
13 0812s105 Y
TE-2-F-502 PUB - Brine Reduction Area (BRA) Second
Train PROCESS FLOW DIAGRAM
13 08l2sl0s Y
TE-6-F-501 PAS - Pollution Abatement System (PAS)
for DFS PROCESS FLOW DIAGRAM
1t 02123198 Y
TE-6-F-502 PAS - Pollution Abatement System (PAS)
for LIC #l PROCESS FLOW DIAGRAM
t2 t2lt7 197 Y
TE-6-F-503 PAS - Pollution Abatement System (PAS)
for MPF PROCESS FLOW DIAGRAM
il y06199 Y
TE-6-F-504 PAS - MPF/DFS Demister Vessel Spare
PROCESS FLOW DIAGRAM
2 t2lt7 197 Y
TE-6-F-506 PAS - Pollution Abatement System (PAS)
for LIC #2 PROCESS FLOW DIAGRAM
t2 08124198 Y
Attachrnent I l, Page 7
TOCDF
General Facility Drawings
June 2009
General Arrangement (ttc" series drawings)
DRAWINGNUMBER DRAWINGTITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-1-G-501 MDB - Major Equipment Legend-l
GENERAL ARRANGEMENT
33 t0lzsl06 Y
TE-1-G-502 MDB - Major Equipment Legend-2
GENERAL AIUJ{{GEMENT
t9 08/0s/08 Y
TE-1-G-503 MDB - Major Equipment Legend-3
GENERAL AIUI{{GEMENT
23 08/0s/08 Y
TE-1-G-504 MDB - First Floor Plan-North GENERAL
ARRANGEMENT
22 07124106 Y
TE-1-G-505 MDB - First Floor Plan-South GENERAL
AITRJ{{GEMENT
30 t2104107 Y
TE-1-G-506 MDB - lst FLR Platform Plan-North
GENERAL AITRANIGEMENT
10 07 124106 Y
TE-1-G-507 MDB - lst FLR Platform Plan-South
GENERAL AITRJ{{GEMENT
13 03107196 Y
TE-l-G-508 MDB - Second Floor Plan-North GENERAL
AI(RJ{]{GEMENT.
33 r0102107 Y
TE-l-G-509 MDB - Second Floor Plan-South GENERAL
AI{RJ{]{GEMENT
19 08/0s/08 Y
TE-1-G-510 MDB - 2nd FLR Platform Plan-North
GENERAL AIUANIGEMENT
t2 r0102106 Y
TE-t-G-51 I MDB - 2nd FLR Platform Plan-South
GENERAL AITRJ{{GEMENT
15 rt lt6l00 Y
TE-1-G-512 MDB - Building Section A GENERAL
AI(RANIGEMENT
1t 10i 1 y9s Y
TE-l-G-s 13 MDB - Building Sections B, C & D
GENERAL AIIRANGEMENT
t2 04l0sl0s Y
TE-6-G-501 PAS - Major Equipment Legend GENERAL
AI(RANGEMENT
25 04109107 Y
TE-6-G-502 PAS - Ground Floor Plan GENERAL
AIIRANGEMENT
10 04109107 Y
TE-6-G-s06 PAS - Building Section A GENERAL
AI(RANIGEMENT
3 0612819r Y
TE-6-G-507 PAS - Building Section B GENERAL
AI{RANGEMENT
3 06128191 Y
TE-7-G-501 CHB - Major Equipment Legend GENERAL
AITRANGEMENT
t4 10104107 Y
TE-7-G-502 CHB - Plan-East, Unloading/Storage
GENERAL AIUJ{{GEMENT
t4 08102196 Y
TE-7-G-503 CHB - Plan-West, Unloading/Storage
GENERAL AILzu{{GEMENT
13 rU t6l00 Y
TE-7-G-504 CHB - Plan-Center Area GENERAL
AITRANGEMENT
l1 10104107 Y
Attachment I l, Page 8
TOCDF
General Facility Drawings
June 2009
General Arrangement (ttctt series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-7-G-505 CHB - First Floor Plan. Transition
GENERAL AIUL{{GEMENT
l0 0s/l s196 Y
TE-7-G-506 CHB - Second Floor Plan, Transition
GENERAL AITRANIGEMENT
t2 tUt6l00 Y
TE-27-G-501 BRA PAS - Major Equipment Legend &
Floor Plan GENERAL AIIRANIGEMENT
ll t2lt319s Y
HVAC ("H" series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-00-H-902 General - Plumbing and Fire Protection
SYMBOLS AND ABBREVIATIONS
2 05/18/90 Y
TE-7-H-8 CHB - Mechanical Equipment Room
(Area 7 -ll) PLAN
10 05/1 6196 Y
TE-7-H-11 CHB - Mustard Thaw Container (Area 7 -4)
UTILITY PLA}I
10 0s/1 6196 Y
TE-7-H-15 CHB - DETAILS AND UTILITY
ISOMETRIC
t0 0s109196 Y
Fire Protection (*Kr? series drawings)
DRAWINGNUMBER DRAWING TITLE
APPROVED
RCRA
BASELINE
MDB - Fire Protection TOX CUBICLE
DRY CHEMICAL SYSTEM
05/10196
MDB - Fire Protection DUN LIFT PLAN,
SECTION & DIAGRAMS
07125194
o
Attachrnent 1 l, Page 9
TOCDF
General Facility Drawings
June 2009
PLUMBING (rr[,r? series drawings)
DRAWINGNUMBER DRAWINGTITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-7-L-l CHB - Unloading and Storage Area - East
PLUMBING PLANI
l0 0s/1s196 Y
TE-7-L-2 CHB - Unloading and Storage Area - West
PLUMBING PLANI
10 05/10196 Y
TE-7-L-3 CHB - MER and Conveyor Corridor
PLUMBING PLANI
l0 0s109196 Y
TE-7-L-4 CHB - PLUMBING SCHEDULES AND
DETAILS
3 0612819t Y
MECHANICAL (rrMrr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
EG-01-M-140r
I of 2
MDB MPF Sparge Air Mods & Camera
Location Layout
2 03128107 Y
Attachrnent 11, Page l0
TOCDF
General Facility Drawings
June 2009
Piping (rrPrr series drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-00-P-901 General -MISCELLANEOUS PIPING
DETAILS
l2 05/10196 Y
TE-l-P-54 MDB - Furnace Ducts & Pipeway Area l-10
UPPER PIPING PLAN
l3 06l2U0t Y
TE-1-P-501 MDB - TOX and SDS First Floor EL 100'-0"
ENLARGED PIPING PLAN
10 04l2sl0s Y
TE-l-P-502 MDB - TOX and SDS First Floor EL 108'-2"
ENLARGED PIPING PLAN
1l 04107103 Y
TE-l-P-503 MDB - TOX and SDS Area l-4
ENLARGED PIPING SECTIONS
t2 04107103 Y
EG-01-P- 1402
I of 5
MPF Back-Up Combustion Air Blower
Addition Pipe Modification Assembly
1 0410s105 Y
TE-2-P-7 PUB - EL 122'-0" Boiler Room Area2-5
PIPING PLAN
2 t0lt6192 Y
TE-2-P-501 PUB - EL 100'-0" Brine Reduction Area2-4
PIPING PLAN
9 08/30/05 N
TE-2-P-503 PUB - Brine Reduction Area 2-4 PIPING
SECTIONS
7 08/30/0s N
EG-O6-P-8904 PFS Building PAS Filter System Flue Gas &
Vent Piping Plan & Sections
1l 03126109 Y
TE-6-P-501 PAS - EL 100'-0" Area 6-1 PIPING PLAN 1l 0s/1 s196 Y
TE-6-P-503 PAS - EL 100'-0" Area 6-3 PIPING PLAN 7 0212319s Y
TE-6-P-505 PAS - EL 100'-0" Area 6-5 PIPING PLAN 6 02127 19s Y
TE-6-P -507 PAS - EL I l1'-0" Area 6-l PIPING PLAN 1t 05/1s196 Y
TE-6-P-509 PAS - EL 111'-0" Area 6-3 PIPING PLAN 10 02120196 Y
TE-6-P-51 I PAS - El I l1'-0" Area 6-5 PIPING PLAN 4I 07 13U92 Y
TE-7-P-1 CHB - Second Floor EL 122'-0" Area 7-14
PIPING PLAN
1t 02lts196 Y
TE- t6-P-2 Site Work - Pipeway Are a 16-3 & 16- 1 1
PIPING PLAN
t2 07 l02l0t Y
TE- l6-P-4 Site Work - Truck Unload Area 16-10
PIPING PLAN
8 04127 100 Y
TE- 16-P- 10 Site Work - Pipeway Area 16-12 & 16-13
PIPING PLAN
t4 07 l02l0t Y
TE- 16-P-504 Site Work - Brine Surge Tanks Area 16-12
PIPING PLAN
15 07 l02l0t Y
TE- 16-P-505 Site Work - Brine Surge Tanks Area 16- 13
PIPING PLAN
15 07 l02l0t Y
Attachrnent I l, Page
TOCDF
General Facility Drawings
June 2009
STRUCTURAL 1tt 5 tt series .drawings)
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
TE-00-s-901 General - GENERAL NOTES 3 06128191 Y
TE-00-s-908 General - TYPICAL CONCRETE DETAILS 1 08107 189 Y
TE-00-s-909 General - TYPICAL CONCRETE DETAILS 5 0s13U06 Y
TE-00-s-910 General - TYPICAL CONCRETE DETAILS 1 08107189 Y
TE-t-S-l MDB - Area 1-1 through l-9 IST FLOOR
PLAN (COMP)
6 r2lt8l92 Y
TE-1-S-2 MDB - Area l-1 lST FLOOR PLAN 10 osi 14197 Y
EG-O1-S-2 MDB - Area l-1 ACCESS PLATFORM
PLAN & ELEV.
10 0s/14197 Y
TE- I -S-3 MDB - Area l-2 IST FLOOR PLAN 3 06128191 Y
TE- 1-S-4 MDB - Area 1-3 lST FLOOR PLAN 2 0s/18/90 Y
TE-l-S-5 MDB - Area l-4 IST FLOOR PLAN 5 03120192 Y
TE-1-5-6 MDB - Area 1-5 1ST FLOOR PLAN l0 05/l 6196 Y
TE-1-S-7 MDB - Area 1-6 IST FLOOR PLAN l0 0s/13196 Y
TE- l -S-8 MDB - Area l-7 IST FLOOR PLAN 11 04104108 Y
TE- 1-S-9 MDB - Area 1-8 1ST FLOOR PLAN 2 05/18/90 Y
TE- 1-S-10 MDB - Area l-9 1ST FLOOR PLAN I 08107 189 Y
TE- 1-5-60 MDB -FOUNDATIONS 2 0s/18/e0 Y
TE- l -5-63 MDB - MISC CONC PLATFORMS 4 0612819r Y
TE- I -5-69 MDB - FOUNDATION PLAN 10 0s/13196 Y
TE- t-S-72 MDB - WALL SCHEDULE & DETAILS 3 12lt2l9l Y
TE-2-S-5 PUB - All Areas FLOOR SLAB PLAN 1l 08/30/0s Y
TE-7-S-1 CHB - Areas 7 -l through 7 -15 FLOOR
PLAN & GENERALNOTES
5 r2lt8l92 Y
TE-7-S-2 CHB - Areas 7 -1, 7 -2, 7 -4 FOLTNDATION
AND FLOOR PLAN
5 12lt8l92 Y
TE-7-S-3 CHB - Areas 7-5,7-7,7-8,7-9
FOUNDATION AND FLOOR PLAN
10 05/17196 Y
TE-7-S-4 CHB - Areas 7 -10 through 7 -13
FOUNDATION AND FI,OOR PLAN
10 0s/17196 Y
TE-7-S-6 CHB - Areas 7 -l through 7 -13
FOUNDATION AND FLOOR DETAILS
10 0U28197 Y
TE-7-S-7 CHB - Area 7-14 FOUNDATION PLAN 10 0s/16196 Y
TE-7-S-8 CHB - Area 7 -14 FIRST FLOOR PLAN 10 0slt7 196 Y
TE-7-S-9 CHB - Area 7-14 SECOND FLOOR PLAN 10 0s/16196 Y
TE- 16-5- 16 Site Work - BRA TANK FOUNDATIONS 2 06128191 Y
Attachrnent I 1, Page 12
TOCDF
General Facility Drawings
June 2009
Vendor Drawings
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
4-RHA-L47 A-C-002 General Arrangement/Outline Dimensions
Assernbly Drawing/Shop Details Salt
Containers
3 0U25193 Y
4-RHA-147 A-C-003 General Arrangement/Outline Dimensions
Assembly Drawing/Shop Details Salt
Container Covers
3 0U25193 Y
4-RHA-L47 A-C-004 General Arrangement/Outline Dimensions
Assembly Drawings/Shop Details DFS
Cyclone Disch arge Shroud
3 03115193 Y
t7 -14 -167 -C Primary Chamb er 2 Fuel, Burner Injector
Assembly (LV-14) QA Class II
t8 12104107 Y
06-02-3710-D Assembly Prim ary Chamber
(LrC-FURN-101)
11 U3U97 Y
06-a2-3713-D Assembly Secondary Chamber
(LrC-FURN-t02)
1l 09109197 Y
06-02-3731-D Exhaust Duct Assembly 11 02104198 Y
06-02-3927 -D Assembly Primary Chamber (LIC-FURN-
201)
l3 0U28198 Y
06-02-3928-D Assembly Secondary Chamber (LIC-FURN-
202)
11 09109191 Y
22-406-713-40r DFS Slagging Afterburner GENERAL
AI(RANGEMENT
t2 09124107 Y
22-406-721-401 DFS Cyclone and Slide Gate GENERAL
AI(RANGEMENT
9 08109107 Y
22-s04-856-s01 Shell Assembly 13 09112197 Y
22-504-859-401 Rotary Kiln GENERAL AITRJ{{GEMENT 13 0s/1 6196 Y
22-504-947 -801 Duct from DFS-BLOW-l0l to DFS-FURN-
1 O I GENERAL AITRANGEMENT
l0 0s/r 6196 Y
DA-30- t 6l0- 1-6- 100 Primary Charnber Blower 1l 0810s197 Y
DA-3 lRB t2t6-t0t Combustion Air Blower 5 0810s197 Y
DA-3 2-1806-5- 106 Secondary Chamber Blower 7 0810s197 Y
42-524-777 DFS Duct from DFS Kiln to Blast
Attenuation Duct GENERAL
AITRANGEMENT
t5 03,r6193 Y
42-s24-778 DFS Duct from Blast Attenuation Duct to
Cyclone GENERAL AITRANGEMENT
13 04112196 Y
42-524-779 DFS Duct from Cyclone to Slaging
Afterburner GENERAL AITRANGEMENT
13 08109107 Y
878- I 00 MPF Venturi Scrubber G 08/14197 Y
878-l0l DFS Venturi Scrubber G 08/14197 Y
878- t02 LIC Venturi Scrubber 11 0s/12108 Y
89-305-RH Side Elevation MPF System 8 r0102108 Y
Attachrnent 11, Page l3
TOCDF
General Facility Drawings
June 2009
Vendor Drawings
DRAWINGNUMBER DRAWING TITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
90-8890-A
I of 6
LIC I Quench Tower 10 05/0 U97 Y
90-8890-B
I of 6
LIC #2 Quench Tower l2 07116198 Y
90-8890-C
I of 8
LIC 1 Scrubber Tower 6 0li 1 u98 Y
90-8890-E
I of 7
DFS Quench Tower 6 02123198 Y
90-8890-F
1 of 8
DFS Scrubber Tower 8 02113198 Y
90-8890-H
I of 6
MPF Quench Tower 5 02106198 Y
90-8890-J
I of 8
MPF Scrubber Tower 8 0U27 198 Y
c-440441 RB 453 Pressure Blower Arrangement 4
CCW-UB from Drive End
6 08129197 Y
D-90s7 06-M101 PT- 12-I 4-I 6 GENERAL ARRANGEMENT 10 0s/1s196 Y
HM-1028
l of ll
LIC Demister Vessel 04-PAS-DMIS-101
GENERA,L AITzu{NGEMENT
6 0826197 Y
HM-1028
4ofll
N{PF Demister Vessel 04-PAS-DMIS-l 03
GENERAL AITRANGEMENT
5 0412U93 Y
HM-1028
5 of ll
DFS Demister Vessel 04-PAS-DMIS- I 04
GENERAL AITRANGEIVI ENT
5 0610619s Y
RD- 13549-3
5 of 15
Refractory Lining for Cross-Over Duct of
Liquid Incinerator System GENERAL
ARRANGEMENT & DETAILS
4 04lrsl97 Y
ATLIC DRAWINGS
DRAWINGNUMBER DRAWINGTITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
EG-22-A-8211 Sht I of ll Process Building Architectural Floor Plan 2 02taufi Y
EG-22-A-8212 Sht I of 3 Igloo Architectural Floor Plan !07 t07 tr0 Y
EG-22-C-8213 Site Paving and Grading Plan -5 05/06/10 Y
EG-22-D-8210 Sht I of 2 LIC Primary P&ID 0 07t2ut0 Y
EG-22-D-8210 Sht 2 of 2 LIC Secondary P&ID 6 07 t21l10 Y
EG-22-D-821I Sht l-4 PAS P&ID 7.08t26tr0 Y
EG-22-D-82t2 Glovebox 8501 P&ID -5 05t26n0 Y
EG-22-D-8213 Glovebox 8502 P&lD -5 05t26n0 Y
EG-22-D-8214 Lewisite Collection System P&ID I 08/31/10 Y
Attachrnent I l, Page l4
TOCDF
General Facility Drawings
June 2009
ATLIC DRAWINGS
DRAWINGNUMBER DRAWINGTITLE
REV.
#
REV.
DATE
APPROVED
RCRA
BASELINE
EG-22-D-8215 Nitric Reject Collection System P&ID !08/31/10 Y
EG-22-D-8216 Nitric Acid Collection System P&ID )5-09/08/10 Y
EG-22-D-8217 Spent Decon Collection System P&ID 3 08/3Uro Y
EG-22-D-8219 Major Spill Collection System P&ID I 0s/06/10 Y
EG-22-D-8222 SDS Feed System P&ID 6 09/01/10 Y
EG-22-D-8223 Waste Feed System P&ID 0 09/01/10 Y
EG-22-D-8227 PAS Blowdown Storage P&ID g 06/01/10 Y
EG-22-D-8228 PAS Blowdown Unloading/Decon Loading
P&ID
3 05/06/10 Y
EG-22-F-8210 Sht r-2 GA TC Glovebox Processing 2 02t0ut0 Y
EG-22-F-821I Sht t-2 Lewisite TC Glovebox Processing 2 02t0ut0 Y
EG-22-G-8204 General Arrangement Plan -5 08/31/10 Y
EG-22-H-8202 Sht l-3 HVAC P&ID Z tu02n0 Y
Attachment I l, Page l5
F./op
p
(D
h)
A
ATTACHMENT 14
Miscellaneous Treatment Units
Demilit anzation Mi scellaneous TreatmJ:t53l
June 2009
Table of Contents
l4.l Description of Miscellaneous Units
14.2 Reserved
14.3 Bulk Drain Station
14.3.1 Physical Characteristics
14.3.2 Operations and Maintenance
14.3.3 Monitoring Procedures
14.3.4 Inspection
14.3.5 Closure
14.3.6 Mitigative Design and Operating Standards
14.3.7 Environmental Performance Standards for Miscellaneous Units
14.4 Projectile/Ir4ortar Disassernbly Machine
14.4.1 Physical Characteristics
14.4.2 Operations and Maintenance
L4.4.3 Monitoring Procedures
14.4.4 Inspection
14.4.5 Closure
14.4.6 Mitigative Design and Operating Standards
1,4.4.7 EnvironmentalPerformanceStandardsforMiscellaneousUnits
14.5 Multipurpose Dernilitarization and Pick and Place Machines
14.5.1 Physical Characteristics
14.5.2 Operations and Maintenance
14.5.3 Monitoring Procedures
14.5.4 Inspection
14.5.5 Closure
14.5.6 Mitigative Design and Operating Standards
14.5.7 Environmental Performance Standards for Miscellaneous Units
14.6 Reserved
14.7 Air Operated Remote Ordnance Access System (Cutter Machine)
14.7.1 Physical Characteristics
14.7.2 Operations and Maintenance
14.7.3 Inspection
14.7.4 Closure
14.7.5 Mitigative Design and Operating Standards
14.8 DVS - Drum Ventilation System Enclosures and Sorting Room
14.2.1 Physical Characteristics
14.2.2 Operations and Maintenance
14.2.3 Inspection
14.2.4 Closure
14.2.5 Mitigative Design and Operating Standards
14.9 Autoclave
14.9.1 Physical Characteristics
14.9.2 General System and Operation
14.9.3 System Startup
14.9.4 Feed
14.9.5 Interlocks
14.9.6 System Shutdown (normal)
14.9.7 Emergency Shutdown
14.9.8 Monitoring Procedures
I
I
Attachrnent -14 - Page I
TOCDF
Dernilitarization Miscellaneous Treatment Units
June 2009
Waste Identification
Waste Throughput
Inspection
Closure
Mitigative Design and Operating Standards
14.l0 ATLIC Ton Container Rinse and Drain Glovebox
14.10.1.Equioment Installations
14.10.2. Physical Characteristics
14.10.3. Dimensions and Location
14. 10.4. Conveyors
14. 10.5. Gates
14.10.6. Pumps and Transfer Lines
14.10.7. Sump Pump
14.10.8. Tanks and Containers
14.10.9. Feed System
14.10.10.lnstrumentation
14.10.11. Electrical System
14.10.12. Heating Ventilation and Air Conditioning (HVAC) System
14.10.13.Fire Protection
14.10.14. Alarm and Communication System
14.10.15. General System Operations
14.10.16.Svstem Startup
14.10.17.Interlocks
14.10.18. System Shutdown
14.10.19. Agent Monitoring Procedures
t4.r0.20.Waste Identification
14.10.21 . Waste Throughput
14.10.22. lnspection
14. 10.23. Closure
14.10.24. Mitigative Design and Operating Standards
14.g.g
14.9.10
14.g.ll
14.9.12
14.9.13
t4-2-l
t4-3-l
I4-4-l
t4-4-2
t4-s-l
t4-5-2
t4-6-l
List of Tables
Reserved
List of Bulk Drain Station Sensors and Critical Interlocks
Maximum Explosive Weight in Explosive Containment Room
Brojectile/Ivlortar Disassembly Machine Sensors
Summary of Multipurpose DemilitarizationMachine and Pick and Place Sensors
Multipurpose DemilitarizationMachine, Pick and Place Critical Sensors and Interlocks
Reserved
Attachment - 14 - Page 2
ACAMS
ACS
AQS
BDS
BRS
BSRM
CCTV
CHB
CON
CWC
DCD
DFS
DS
DSHW
DTS
DVS
DVSSR
ECR
ECV
FCC
HTS
HVAC
IS
LIC
MDB
MDM
MPB
MPF
MPRS
NAAQS
NCRS
NO*
O3
ONC
PHS
PLC
PMro
PMD
PPE
PPM
RCRA
RDS
SDS
Soz
TOCDF
TSP
UPA
DemilitarizationMiscellaneo..r.""*"]ro,i,l,,l
June 2009
List of Acronvms
Automatic Continuous Air Monitoring System
Agent Collection System
Agent Quantification System
Bulk Drain Station
Burster Removal Station
Burster Size Reduction Machine
Closed Circuit Television
Container Handling Building
Control Room
Chemical Weapons Convention
Deseret Chemical Depot
Deactivation Furnace System
Discharge/Output Station
Division of Solid and Hazardous Waste
Drain Tube System
Drum Ventilation System
Drum Ventilation System Sorting Room
Explosive Containment Room
Explosive Containment Room Vestibule
Facility Construction Certifi cation
Heel Transfer System
Heating, Ventilation, and Air Conditioning System
Infeed/Transfer Station
Liquid Lrcinerator
Munitions Demilitarization Building
Multipurpose D emilitari zation M achine
Munitions Processing Bay
Metal Parts Furnace
Miscellaneous Pdrts Removal Station
National Ambient Air Quality Standards
Nose Closure Removal Station
Nitrogen Oxides
Ozone
Onsite Container
Proj ectile/Tvlortar Handling System
Programmable Logic Controller
Particles Less Than 10 Microns in Aerodynamic Diameter
Proj ectileil\dortar Disassembly Machine
Personal Protective Equipment
Pick and Place Machine
Resource Conservation and Recovery Act
Rinse and Drain Station
Spent Decontamination System
Sulfur Dioxide
Tooele Chemical Agent Disposal Facility
Total Suspended Particles
Unpack Area
Attachment -14 - Page 3
O
TOCDF
Demi I i t anzation M i scel I aneous Treatment Units
June 2009
14.l Description of Miscellaneous Units
14.1.1 The miscellaneous units addressed in this attachment are:
14.1.1.1 Reserved
14.1.1.2 BulkDrain Station (BDS)
14.1.1.3 Projectile/IMortar Disassembly Machine (PMD), including the Multi-position Loader.
14.1.1.4 Multipurpose Demilitarization Machine (MDM), including the Pick and Place Machine.
14.1.1.5 Reserved
14.1.1.6 Air Operated Remote Ordnance Access System (Cutter Machine)
14.1.1,.7 DVS (DVS Enclosure 101, DVS Enclosure 102 and the DVSSR)
14.1.1.8 Autoclave
14.1.2 These units do not fit the definition of a container, tank, surface impoundment, waste pile,
land treatment unit, landfill, incinerator, boiler, industrial furnace, or underground
injection well. Therefore, these units are categorized as miscellaneous units. The
miscellaneous treatment units listed above will be used to treat the following items:
14.1.2.1 Reserved
14.1.2.2 Explosive components from munitions
14.1.2.3 Reserved
14.1.2.4 Reserved
14.1.2.5 Ton containers (BDS)
14.1.2.6 Reserved
14.1.2.7 M104, Mll0projectiles, 155mm(PMD andMDM)
14.1.2.8 M2 and M2Al mortar cartridges, 4.2-nch(PMD and MDM).
14.1.2.9 TOCDF-Generated Secondary Waste (DVS and Autoclave)
14.1.3 Reserved
14.1.4 The treatment objective for the BDS is to separft'e the liquid agent from its container and
send the agent to the ACS and the bulk item casing containing a solid and liquid residue '
heel to the Metal Parts Fumace (MPF) for further treatment.
I4.1.5 The treatment objective for the PMD is to separate, as applicable, explosive and
miscellaneous components and bursters from the munitions and send the burster to the
BSRM for further treatment. All miscellaneous and explosive components and bursters
are sent to the DFS for further treatment.
I4.1.6 The treatment objective for the MDM is to separate the liquid agent from the munition and' send the agent to the ACS and the casing to the MPF for further treatment. For mustard
155mm projectiles, the treatment objective for the MDM is only to breach the agent cavity
by collapsing the burster well downward into the projectile body. No agent will be
removed from these projectiles.
14.1.7 Reserved
14.1.8 The treatment objective for the Cutter Machine is to gain access to the interior components
of overpacked/reject munitions or other cylindrical items so that the liquid agent can be
sent to the ACS or SDS for further processing, and the metal components to the MPF or
DFS (if energetically configured) for further treatment.
Attachment - 14 - Page 4
14.1 .9
14.1 .10
14,2
14,3.
14.3.1
14.3. I . I
14.3.1 .2
14.3.1 .2.1
t4.3. 1 .3
14.3.1 .4
14.3 .I .4.1
DemilitarizationMiscellaneo..r.".*r1ro,?3r,1
June 2009
The treatment objective for the DVS (i.e., the Enclosures and the DVSSR) is to treat agent
contamination that exists on secondary waste by decontamination with an approved
decontaminant (NaOH or Bleach) for the applicable agent type (e.g., GB, VX, Mustard)
for reducing the level of PPE necessary for further treatment activities in the Autoclave.
Treatment applicable to waste codes other than P999 is NOT with the objective of the
DVS.
The treatment objective for the Autoclave is the removal and destruction of the agent
contaminating secondary waste through the application of pressurized steam.
Reserved
BI]LK DRAIN STATION
The TOCDF bulk item processing system, which includes two BDSs, is designed to safely
remove liquid agent, including liquefied solid agent heel, from ton containers. Following
rernoval of the liquid agent, the ton container is sent to the MPF for further treatment. The
liquid chernical agent is collected by the ACS, a separate system that includes the agent
holding tanks, associated pumps, valves, piping, and other ancillary equipment. The
drained agent is then incinerated in the LICs. Solid agent heel that has been liquefied at
the HTS is transferred to a separate container and incinerated in the MPF.
The BDS processes munitions that are not configured with explosives, propellants, or
other energetics, so the processing system is only concemed with separating the chernical
agent from the munition or bulk item. The BDSs are designed to 1) punch a hole in
munitions or bulk items, 2) dranthe liquid chemical agent from them, and 3) liquefu a
portion ofthe solid agent heel and transfer the liquefied agent heel to a separate container.
The following munitions and bulk items are processed on the BDS:
Ton containers.
The BDS begins at the munitions demilitaizationgates, where the munitions are
transferred from the Upper Munitions Corridor into the MPB onto the BDS Indexing
Hydraulic Conveyor. It ends where the BDS Hydraulic Conveyor transfers the bulk item
to a series of three MDM Indexing Hydraulic Conveyors that leads through two other
indexing conveyors to the Lift Car Assembly at the far end of the MPB. Eventually, the
bulk items are transferred to the MPF for thermal treatment.
Equipment Installation
The equipment that constitutes the bulk item processing system has already been installed,
and the installation of these machines and their support equipment has been verified
through the Facility Construction Certification documentation required by Permit
Condition LS. This Certification attests that the bulk item processing system equipment
has been installed in accordance with the equipment's design specification and drawings,
as stated in the permit.
Dimensions and Location14.3. 1.5
Attachment - 14 - Page 5
14.3. 1 .5. I
r4.3.1.6
14.3.1 .6.1
14.3.1 .7
14.3.1 .'7 .l
14.3.1 .8
14 .3. 1 .9. 1
14.3 .r .8.2
14.3.1 .9
14.3. 1 .9.1
14.3. 1.10
14.3. 1.10.1
14.3.1 .1 0.2
DemilitarizationMiscellaneourrr""*"].o,!,1,,1
June 2009
Each BDS is approximately 17 feet long, eight feet wide and 10 feet high. The
approximate nominal weight of each BDS is 16,500 pounds. The conveyors and HTS,
which are an integral part of each BDS, are 17 feet long, five feet wide, and three feet
high. They weigh approximately 3,000 pounds each. The BDSs are located on the second
floor of the MDB in the MPB.
Conveyors
The BDS consists of a Munitions Transfer Conveyor, Main Frame Assembly, a Punch and
Drain Station, and an HTS Rinse and Drain Station (RDS). The munitions and bulk items
are transferred to the BDS in specially designed cradles that are mounted on MPF trays.
Gates
The cradles/trays are transferred automatically from the MDM Feed Conveyor in the
Upper Munitions Corridor into the MPB through one of two MPB gates. The gates are
opened to receive bulk items and they will not close until the bulk item is transferred
completely into the MPB (see Section 14.3.2.9 on interlocks).
Pump and Transfer Lines
Each BDS's ACS is equipped with pumps to remove agent from the bulk items. The
agent is transferred from the BDS through lines connecting the pumps to the ACS and to
the agent holding tanks.
The two BDS RDSs share a common transfer line that enables the transfer of liquefied
heel material from one BDS's RDS to the other BDS's RDS. The fluid transfer is
performed through the use of a transfer pump located at the sending RDS (e.g., the RDS at
the Parent TC).
Tanks and Containers
There are no tanks or containers directly associated with the BDSs. Liquid agent from the
BDS DTS is pumped directly to the ACS Tanks. Liquefied heel material from the BDS
RDS is pumped directly to a container staged at the opposite BDS RDS.
Feed System
The BDS Main Frame Assembly, which is constructed of steel, supports the conveyors,
sensors, hydraulic apparatus, punch, drain tube apparatus, and other ancillary equipment
associated with the BDS.
The bulk items (including the cradle and tray) are weighed before and after the agent
draining process to obtain the initial fulI weight and final drained weight of the items. A
set of load cells, mounted on hydraulic cylinders in the Munitions Transfer Conveyor, are
designed to accomplish this.
The Punch Station consists of a hydraulic cylinder eqlipped with a punch and hold-down
clamp. The hydraulic cylinder is mounted vertically on the upper front of the BDS
column assembly, which stands next to the conveyor (toward the center of the MPB) so
that the Punch is suspended over the center line of the conveyor. When extended, the
t4.3.1 .10.3
Attachrnent - 14 - Page 6
DemilitarizationMiscellaneou.rr""*"lP,tl,,:
June 2009
cylinder punches a hole through the top of the munition or bulk item. The punch is
mounted at the top of the column when processing ton containers. Two position switches
on the cylinder sense the position ofthe punch (retracted or extended).
14.3.1.10.4 The BDS hold-down clamp is mounted on the hold-down support assembly, below the
punch cylinder. It consists of two small hydraulic cylinders, one on each side of the
punch, that extend a hold-down clamp near the surface of the bulk item. The hold-down
clamp prevents excessive lifting or rolling of the munition or bulk item in place when the
punch is retracted. The hold-down clamp cylinders are actuated by hydraulic fluid from
the same control valve as the conveyor lift cylinders.
14.3.1.10.5 The Drain Station consists of an agent drain tube that is lowered into the bulk item
through the hole made by the ptrnch. A position switch provides indication of an "on-
bottom" condition when a solid layer is encountered. The amount of agent removed is
quantified at the Drain Station by the use of before and after agent drain weights. A
bubbler provides verification of the liquid level in the bulk container.
14.3.1.10.6 Reserved
14.3.1.10.7 The draining of mustard ton containers at the DTS is performed using qualitative
information gained through the approximate measurement of the solid residue heel that
took place prior to TOCDF receipt of the ton containers and from historical tare weights
and final weights.
14.3.1.10.8 The transfer of liquefied heel material from one TC to another container staged at the
opposite BDS RDS is performed using quantitative information regarding the weight of
TC contents necessary to be removed from the TC in order to render the Parent TC
treatable in the MPF. In addition, the Child Container (i.e., the container staged at the
opposite BDS RDS that receives the liquefied heel material) net weight is ensured to be
less than the maximum allowable to the MPF. The target weights for both the Child
Container and the Parent TC are, in part, based on the most efficient use of the MPF and
are subject to adjustment in order to respond to changing plant conditions.
14.3.1.11 Instrumentation
14.3.1 .1 1. 1 Instrumentation associated with the BDSs is remotely monitored in the TOCDF CON.
The instruments are primarily associated with the hydraulic and pneumatic systems,
electronic position sensors, load cells, drain verification system, and interlocks. Table 14-
3-11 summarizes the various sensors for the BDS and their function. Details of the
instruments and sensors are shown on drawings contained in Attachment 11 (General
Facility Drawings).
14.3.1,12 Electricalsystem
14.3.1.12.1 The electrical power supply and distribution network for the process systems are provided
by the local utility and by the installation. Electrical power has been extended to the MDB
complex as part of the site development. Additionally, there are two backup power
systems: essential and unintemrptible. Attachment 9 (Contingency Plan) provides detailed
information regarding the backup power systems..
' All tables are located at the end of this Attachment.
Attachment - 14 - Page 7
14.3.1.13
14.3.1.13.1
14.3.1 .1 3.2
14.3.1.13.3
14.3.1 .1 3.4
r4.3. 1.13.s
DernilitarizationMiscellaneor.r..r*Jr0;r|r,:
June 2009
Heating. Ventilation. and Air Conditioning System (IIVAC)
The HVAC system for the MDB consists of a once-through cascade system servicing the
MDB process areas, a stand-alone HVAC system servicing the MDB CON, and
miscellaneous HVAC systems servicing the Category D areas. The primary means of
preventing the release or spread of contamination is through the use of cascaded pressure
control. The CON is maintained at a positive pressure with respect to the atmosphere,
while toxic areas are maintained at a negative pressure with respect to the atmosphere.
This ensures a flow of air from the cleanest areas to areas with ascending potential for
higher contamination.
Each room in the MDB has a designated category rating of A, A./fl, B, C, D, or E based
upon the potential for agent contamination. Rooms assigned a Category A rating
(negative pressure), like the ECRs, are routinely contaminated by either agent liquid or
vapor. Rooms with a Category B rating (negative pressure) have a high probability of
agent vapor contamination resulting from routine operations. Rooms with a Category C
rating (negative pressure) have a low probability of agent vapor contamination. Rooms
with a Category D rating (atmospheric pressure) have a very remote probability of ever
being contaminated by agent. Rooms with a Category E rating (positive pressure) are
maintained from being contaminated by agent at all times.
The control of pressure for the incinerator rooms is accomplished by the control system.
The pressure for the other rooms is balanced manually before facility start. The airflow
and pressure differentials are regulated manually by fixed balancing dampers to maintain
the desired negative environment in the MDB. Isolation dampers are located between
Category A, A./8, or B rooms and Category C rooms to prevent possible migration of
chemical agent to a lower contamination category area in case of an agent spill and a
power failure. These isolation dampers are designed to fail closed.
Three air handling units supply air to all Category A, A./8, B, and C rooms in the MDB.
During normal processing, two air-handling units are online, with the third air-handling
unit serving as a spare. Conditioned air is supplied to the air supply-handling units. The
filters on the inlet of the air-handling unit are used to remove dust contained in the air.
The units have heating coils that are supplied by hot water for use in the winter and l
cooling coils supplied by chilled water for use in the summer. Outside air flowing across
the coils is either heated or cooled. A blower on the unit is used to pull air from outside
and deliver the air to the building rooms.
Air rernoved from the MPB is exhausted to air filtration units. The MPB is maintained at
a negative pressure of approximately 1.8 inches of water column. The exhaust air
filtration units contain filter media (carbon adsorption units) used to ensure that agent is
not released to the environment.
Air removed from the ECRsis eihausted to air filtration units. The ECRs are maintained
at a negative pressure of approximately 2.0 inches of water column. The exhaust air
filtration units contain filter media (carbon adsorption units) used to ensure that agent is
not released to the environment.
t4.3.1.1 3.6
Attachment - l4 - Page 8
14.3.1.13.7
14.3.1 .13.8
14,3.1 .r4
14.3.I.14.1
14.3.1.1 4.2
14.3.1 .15
14.3.1 .l 5.1
14.3.2
14.3.2.1
14.3.2.2
14.3.2.3
14.3.2.4
14.3.2.5
14.3.2.5.1
DernilitarizationMiscellaneou.r.".*.LO;3r:
June 2009
Each exhaust filtration unit has ACAMS ports to detect agent breakthrough *d send an
alarm to the CON for the current agent campaign. The ACAMS sample as described in
Attachment 22 (Agent Monitoring Plan).
Each exhaust filter unit is provided with a centrifugal fan that discharges the air to the
atmosphere through an exhaust stack. Air flows through each exhaust filtration unit with
a range of 12,200 to 16,000 cubic feet per minute. Air exhausted through the stack is
monitored for the presence of GB, VX, and mustard chemical agent.
Fire Protection System
The fire protection system in the MPB consists of thermal (heat) detectors and fire
dampers. There are 28 thermal (heat) detectors mounted on the ceiling and 10 on the
trnderside of the platform of the MPB. There are five manual pull fire alarms in the MPB.
As mentioned above, fire dampers are provided in ducts passing through fire-rated walls
and ducts serving the MDB. The fire dampers restrict fire propagation in the building
through the ventilation air ducts.
Alarm and Communication Systems
The MDB is equipped with telephones for TOCDF-wide communication. Personnel will
be able to use this system to summon assistance in an emergency. The MPB is equipped
with hom speakers and CCTV so that the CON operator can visually observe the
operations in the MPB and notifu facility personnel in the event of an emergency. Fire
alarms, initiated by the automatic heat detection system or the manual pull stations, are
described above. Also, instrumentation alarms will send signals to the CON.
Operations and Maintenance
Munitions and bulk items to be processed at the BDS are received from the Upper
Munitions Corridor, and transferred to the MPB. As the conveyor moves the bulk item(s)
to the correct position under each station, the BDS punches and drains the bulk item.
Mustard TCs that are to have their contents transferred to another container staged at the
opposite BDS are transferred to the BDS RDS. For bulk items previously verified as
drained prior to arrival at the BDS, the BDS drain and RDS sequence may be bypassed.
As mentioned previously, all munitions are received and processed in cradles that are
mounted on MPF trays. Ton containers are received one at a time. The following section
further describes the operating sequence for bulk items processing at the BDS.
The BDS is designed to receive bulk items and treat and forward the drained bulk
containers to the MPF. The MPF maximum feed rates are specified in this Permit. Upon
reaching the BDS, each bulk item waste will have been identified. Physical and chemical
characteristics of each waste are summarized in Attachment 2 (Waste Analysis Plan).
Reserved
General System Operation
Reserved
Attachrnent - l4 - Page 9
14.3.2.5.2
14.3.2.5.2.1
14.3.2.5.2.2
14.3.2.5.2.3
14.3.2.5.2.4
14.3.2.6
14.3.2.6.1
DernilitarizationMiscellaneourrr""*JL?,l,rl
June 2009
Operating Description: Ton Container
At the BDS, ton containers are punched, drained of liquid agent, and punched again at
least once. The ton containers are moved to the punch position by the indexing hydraulic
conveyor. Proximity switches detect flags located on the side of the cradles which
position the cradle for punching and draining. When the bulk item is stopped at the punch
position, the indexing conveyor lowers allowing the cradle/tray to rest on the main frame
anvils. Simultaneously, the hold-down cylinders extend to prevent excessive lifting or
rolling of the bulk item. The Punch then extends, creating a hole in the bulk item. When
punching is complete, the punch cylinder retracts, the transfer conveyor raises, the hold-
down cylinders retract, and the bulk item moves to the drain position. For bulk items
previously verified as drained prior to arrival at the BDS, the BDS drain sequence may be
bypassed.
Prior to draining (and after ptrnching), the indexing hydraulic conveyor, tray, cradle, and
munition/bulk item are raised hydraulically off the anvil and weighed by a set of four Load
Cells. These cells are located under each corner of the conveyor and are mounted on the
hydraulic cylinders that raise the conveyor. Weighing is accomplished electronically by
actuating the Load Cells (conveyor in raised position). The weight is recorded by the
PLC.
A drain tube is lowered into the punched hole on the bulk item at the Drain Station. The
tube then extends until it reaches an operator-entered depth inside the interior of the bulk
item or until the solid is detected. Draining starts after the bubbler system verifies the
presence of liquid chemical agent. The bulk item is drained to ensure all but residual
chemical agent and solid residue have been removed. After the drain tube retracts, the
bulk item is re-weighed by the Load Cells. By comparing the full and drained weights, the
amount of chemical agent removed is obtained. The indexing conveyor then moves the
bulk item to the correct position for punching at least once more vent hole, the conveyor
and hold-down clamp lower, a vent hole is punched (the same size as the drain hole), and
the conveyor and hold-down clamp raise. If the bulk item is considered sufficiently
drained the bulk item (with cradle/tray) is then transferred to the MDM Indexing
Hydraulic Conveyors that deliver the cradle to the opposite end of the MPB.
If the bulk item is a Mustard TC to have additional heel material removed from it using
the HTS, the "Parent TC" is moved to the correct position at the RDS for the water spray
sequence. The high-pressure water spray wand is inserted into the TC and actuated to
inject a predetermined amount of hot water. After a soaking period, the spray wand is
retracted from the bulk item and the TC is moved to the correct position for the heel
transfer sequence. After staging a "Child Container" at the opposite BDS RDS as a
receiving vessel, both the Child Container drain tube and the Parent TC drain tube are
inserted into their respective containers. Liquefied heel material is transferred from the
Parent TC to the Child Container by the Parent TC's HTS pump.
Setup Procedures
The BDS is initialized before being placed in service. A1l major system components are
remotely activated from the CON, and the PLCs verify the proper operation of the system.
The indicators in the CON are observed to veriff the status of the BDS. The BDS major
Attachment - 14 - Page l0
DemilitarizationMiscellaneou.r.""*"],o,!,lnl
June 2009
system components are tumed off, and the initialization procedure is completed. At this
point, the BDS is ready to receive a start command from the CON.
14.3.2.7 System Startup
14.3.2.7.1 The procedures for BDS startup are contained in the appropriate BDS system standard
operating procedures document. In summary, the systems are started byplacing Line A
and B BDSs in automatic mode, selecting the type of agent and bulk item to be processed,
and then pressing the initialization start icon. This is accomplished remotely in the control
room. When the control room display system start/stop icon changes from flashing to
steady green, the processing lines are ready to accept bulk items.
14.3.2.8 Feed
14.3.2.8.1 Waste quantification requirements are met when the weighing operation is performed at
the BDS. These various activities are recorded either manually, or by the PDARS, and
such records will be available at the plant in the facility Operating Record.
1,4.3.2.8.2 Altematively, during baseline ton container processing, waste quantification may be met
using the programmed levels associated with the BDS Drain Tube System (DTS) and the
systems integrated bubbler provided the Executive Secretary approves the heel
weight/heel depth correlation developed during the Mustard Baseline Shakedown Period
as allowed per Permit Condition VI.C.1.a.v.
14.3.2.9 Interlock Processes
14.3.2.9.1 The BDS is operated in either the manual or automatic mode using a system of interlocks.
The goal ofthe various interlocks is to ensure that the procedures executed by the various
components of the BDS do not interfere with each other or operate in a manner that is
unsafe to human life or harmful to the environment. The interlocks remain in place during
manual operations.
14.3.2.9.2 Should the BDS machine malfunction, the demilitarization line will stop until the problem
is corrected. The process step being performed by the BDS is displayed on the CON
screen so that the operator can determine which process sequence step was not completed.
The BDS cannot be started again until the problem is corrected because the system is
interlocked (in a fail safe mode). The demilitarizationmachine operators are required to
observe the machines during automatic operations to ensure that any stops in the
programmed process sequence are corrected as soon as possible.
14.3.2.9.3 There are two interlocks associated with the BDS operations that are activated by sensors
P2 and P5 (see Table 14-3-1 for a description of these sensors). When a munition and
cradleltray are being transferred from the Munitions Corridor to the MPB through the
munitions demilitarization gates, the gate will remain open and interlocked until the
cradle/tray arrives at the BDS Punch Station. Sensor P2 detects the presence of the
cradle/tray at the Punch Station and allows the gate to close.
14.3.2.9.4 After a munition has been processed at the BDS, it passes sensor P5, a retroreflective
sensor, whlqb signals that the cradle/tray is be.ing transferred to the next conveyor. If
another munition is waiting in the Munitions Corridor at the munitions demilitarization
Attachment -14 - Page l l
DemilitarizationMiscellaneou.r*"*"Lo,!,l,rl
June 2009
gates, and no BDS (or MDM) processing is being conducted, the gate(s) will open to
allow the next cradle/tray into the MPB.
14.3.2.10 SystemShutdown(Normal)
14.3.2.I0.I After the stop command has been issued, the BDS is "parked." When the BDS is parked,
it is configured so that the conveyor lift table, hold-down cylinders, and punch cylinder are
extended; this is the fail-safe mode.
14.3.2.10.2 After the bomb and bulk item demilitarization campaigns have been completed, the BDS
will no longer be needed except to transfer projectiles and mortars from the Munitions
Corridor to the MDMs, which are also located in the MPB.
14.3.2.11 Emersency Shutdown
I4.3.2.11.1 In the event of an abnormal or upset condition associated with the BDS, the processing
operations are modified in order to mitigate the condition. Abnormal or upset conditions
are any conditions that cause an emergency termination in processing, nonconformance to
a specified procedure, a safety hazard, equipment damage, or injury to personnel. These
conditions are identified by plant personnel or indicated by the process sensors (which
send signals to the CON through the PLCs). After conditions are identified, the CON
issues an emergency stop command to the BDS. When this command is issued, the BDS
machine components are stopped.
14.3.2.12 Extended Shutdown
14.3.2.12.1 The BDS operating procedures do not include specific steps to shut down the systern for
extended periods. Instead, normal shutdown procedures are followed when the BDS
machines are not being used. Shutdown procedures are implemented after the BDS is
parked as explained earlier.
14.3.2.13 Maintenance
14.3.2.13.1 Maintenance of the BDS machine includes preventive maintenance procedures and
corrective maintenance procedures. Preventive maintenance procedures generally involve
inspections, cleaning (as required), and lubricating (as required) for the BDS machine.
14.3.3 Monitoring Procedures
14.3.3.1 Each BDS is equipped with sensors to detect the presence, position, and weight of
munitions and bulk items during operations. The sensors, which are corurected through
PLCs, ensure that the munitions and bulk items will be processed safely by relaying
information to the CON.
14.3.3.2 The CON monitors the operations of the BDS through the dernilitarization operator. consoles and CCTV. The demilitarization operator consoles can display information from
the PLCs and sensors. The PDARS provide operational data for analysis and historical
records. lnformation obtained by the PDARS can be used to meet environmental
monitoring and reporting requirements. ln addition, the CON operators and outside
operators are required to log the events that occur during their shift into logbooks.
Attachment -14 - Page 12
14.3.3.3
14.3.3.4
14.3.3.4.1
14.3.3.5
14.3.3.5.1
14.3.4
14.3.4.1
14.3.4.2
14.3.5
14.3.5.1
t4.3.s. 1 . 1
14.3.5.2
14.3.5.2.1
14.3.6
TOCDF
Derni litari zation Miscellaneous Treatment Units
June 2009
The MPB is a Category A room, and it is expected that this area will be contaminated by
agent (liquid or vapor) as part of normal operations. ACAMS are used to detect the
presence of agent vapors in the MPB.
Waste Identification
As mentioned previously, bulk iterns are fully identified prior to entering the BDS. The
quantity of bulk items processed by the BDS is recorded by the PDARS and maintained in
a logbook by CON operators.
Waste Throughput
The waste entering the BDS is a bulk item. During treatment by the BDS, the liquid agent
is separated from the item and handled through the ACS. The metal casing is then
transported away from the BDS for thermal treatment later in the MPF. In each case,
quantification of waste occurs: the agent is quantified as a result of weightings that occur
before and after the agent drain process, with the weights and their difference recorded on
the PDARS and in the manual record; and the metal casing is quantified through the
PDARS record and by the manual record created by the CON operator who observes the
BDS in operation.
Inspection
A TOCDF Inspection Plan is contained in Attachment 5 (Inspection Plan) of this Permit
and describes inspection requirements.
The BDS, PMD, and MDM inspections prevent equipment deterioration and possible
equipment malfunctions that would cause abnormal or upset conditions. The inspections
are designed to reduce the potential impacts of operations on human health and the
environment. In addition to daily inspections, the BDS, PMD, and MDM will be
monitored remotely by CCTV throughout operations.
Closure
Partial Closure
At the conclusion of each agent campaign or the beginning of a new munition campaign,
the BDSs will be thoroughly decontaminated, as necessary; all decontamination films shall
be removed using an appropriate rinse; all clouded observation windows that compromise
the ability to view operations shall be cleaned or replaced; and maintenance and repair will
be performed, as necessary, on the machines and other room components. The TOCDF
will submit in writing to the Executive Secretary, a request for partial closure of the room,
since either the agent or the munition type is being changed. Upon approval for partial
closure from Executive Secretary, the next campaign will commence when authorized and
when it is appropriate to do so.
Final Closure
Final closure is addressed in Attachment 10 (Closure Plan).
Mitigative Design and Operating Standards
Attachment - 14 - Page l3
14.3.6.1
14.3.6.2
14.3.6.3
14.3.7
14.3.7 .L
14.3.7 .2
14.3.7 .2.1
r4.3.7 .2.2
t4.3.7 .2.3
t4.3.7 .3
14.3.7 .3.1
DemilitarizationMiscellaneou.r.""*rTrorilnl
June 2009
The BDS machines are designed for demilitarizationpurposes and do not contain inherent
components to mitigate the potential for waste migration to the environment. However,
the MPB was designed for this purpose. The MPB will be operated in a manner to reduce
the risk of waste constituent migration to the environment.
The floor of the MPB is impervious and sloped to drain any spills to sumps located in the
floor. Protective clothing is mandatory during cleanup of spilled agent in the room, and
care is taken to reduce the potential for spills.
The MPB will not contain explosively configured munitions. Therefore, the room is not
designed for, nor expected to incur, an explosion during munitions demilitarization.
However, if an accident occurs, air from the MPB would be captured by the MDB
ventilation filter system and not escape to the atmosphere.
Environmental Performance Standards for Miscellaneous Units
The BDS has been designed, installed, and will be operated in a manner to preclude the
release of hazardous chemical constituents that may have adverse effects on human health
or the environment. The following section describes the potential for waste constituent
releases to the environment (air, soil, and water), the potential impact of such releases, and
the location features of the TOCDF that will mitigate these releases.
Miscellaneous Unit Wastes
The volume and the physical and chemical characteristics of the wastes to be treated at the
BDS are associated with bulk item storage containers (such as ton containers). These
wastes have been fully identified, and information about their physical and chemical
characteristics may be found in Attachment 2 (Waste Analysis Plan).
The maximum number of bulk items in the MPB atarry time is equal to the number of
munitions in eight cradles/trays (one cradle/tray per conveyor section). Therefore, up to
eight ton containers could be in the MPB at one time.
The maximum volume of agent processed in the MPB is equivalent to the number of
munitions in each cradleltray at the BDS. For example, only one ton container may be
processed at the BDS at a time. Therefore, during ton container processing, the maximum
volume of waste at the BDS is equivalent to the agent in the ton container and the ton
container itself. The maximum number of munitions and/or bulk items in the MPB that
contain agent is equivalent to two cradle/trays (one per processing line). Therefore, up to
two ton containers containing agent could be at the BDS at one time.
Containment System
The seven sumps located in the MPB are primary containment sumps. Some of the sumps
have trenches that aid in collecting spills. The dimensions of three of the seven sumps are
approximately 2.33 by 2.33 by 2.25 feet with a capacity of about 89 gallons each. Three
of the remaining sumps are approximately 233 by 2.33 by 1.71 feet with a capacity of
about 69 gallons and one is 2.33 by 2.33 by 1.46 feet with a capacity of 59 gallons (a total
combined capacity of approximately 533 gallons not including the trench volume). The
outer portion of each sump is constructed of cast-in-place, epoxy-coated reinforced
Attachment -14 - Page 14
14.3.7 .3.2
14.3.7 .3.3
14.3 .7 .3.3.1
14.3.J .3.4
14.3.7 .3.5
14.3.7 .3.6
t4.3.7 .4
14.3.7 .4.1
14.3 .7 .5
14.3.7 .5.7
14. 3.J .6
14. 3 .7 .6.1
Demi litarizati on Mi scellaneour r."r*J:;3,:
concrete. The sumps are constructed with a metal internal liner and an interstitia, $:::"'
that is monitored for the presence of liquid. The concrete is designed to be free from
cracks or gaps.
Each sump metal internal liner is equipped with a level sensor probe to detect liquid. The
level seirsor is screwed into a coupling that is welded into the mounting flange of the metal
liner. The presence of material in the interstitial space will be an indication of leakage
from the metal sump. The bottom of the liner is sloped to the level sensor. The liner will
normally be empty. The level sensor will activate low, high, and high-high alarms, as
appropriate, in the CON. This will provide for liquid detection within 24 hours of
occtuTence.
As mentioned previously, the maximum number of munitions filled with agent in the
MPB at anytime is:
Two ton containers.
Additional quantities of the above munitions or bulk items can be in the MPB at any given
time; however, the maximum number of agent-containing bulk items is limited to those
being processed at the BDSs. The maximum quantity of agent in munitions being
processed is associated with the ton containers (two ton containers hold up to
approximately 380 gallons of agent). In the eve,nt both ton containers leak or both are
ruptured and all the agent spills onto the floor of the MPB, the sumps will be able to hold
all the spilled liquid.
Material in the sumps will be removed within 24 hours of detection. The liner will then be
decontaminated, as necessary, and rinsed. All rinsing materials will be collected and
transferred to the SDS.
In addition to the sumps, the MPB contains curbed walls so that liquid spills and
decontamination solution will not leak under doors and gates. The floors and walls are
painted with epoxy chemical-agent resistant paints to aid in decontamination.
Site Air Conditions
The following paragraphs describe the potential impacts of air emissions due to operation
of the BDSs, PMDs, and the MDMs. A brief description of topographic and meteorologic
characteristics of the Tooele area are presented as well as a sunmary of potential impacts
on existing air quality in the Tooele region.
Topography
The DCD is located in Tooele County in the northwest portion of the State of Utah. The
DCD spreads out over 19,364 acres in the middle of Rush Valley. Attachment 1 (Facility
Description) provides detailed information regarding topography.
Meteorologic and Atmospheric Conditions
The climate around TOCDF is characteristic of semi-arid continental regions. Attachment
1 (Facility Description) provides additional information regarding meterologic and
atmospheric conditions.
Attachrnent -14 - Page 15
14.3.',l .7
14.3.7 .7 .l
14.3.7 .7 .2
14.3.7 .7 .3
14.3.7 .8
r4.3.7 .8.1
r4.3.7 .8.2
r4.3.7 .8.3
t4.3 .7 .8.4
14.3.7.8.5
14.3 .7 .9
14.3.7 .9.1
Demilitarization Miscellaneour r.**J:frT
June 2009
Air Ouality
The TOCDF is located south of the Great Salt Lake Air Basin in the area designated by
the EPA as the Wasatch Front Intrastate Air Quality Control Region [Title 40, Code of
Federal Regulations (CFR) Part 81.521. This region has been designated by the EPA as
meeting all regulated pollutant National Ambient Air Quality Standards (NAAQS).
Historically, ambient monitoring at DCD has been conducted for sulfur dioxide (SOz),
nitrogen oxides (NO*), ozone (O3), total suspended particulates (TSP), and particulates
less than 10 microns in aerodynamic diameter (PMro). No exceedance of existing state
and Federal NAAQS has been observed at DCD. The DCD also has a network of agent
monitors around the TOCDF.
Any air emissions from the demilitarization machines located in the ECRs or MPB are
captured by the MDB ventilation system and processed through the MDB carbon filter
system before being exhausted to the HVAC stack.
Prevention of Air Emissions
The BDSs, PMDs, and MDMs/PPMs, are not sources of air emissions in and of
themselves, but they are associated with treatment operations that could potentially emit
air pollutants. For example, the BDS or MDM agent draining process could potentially
release small quantities of agent due to evaporation. For the purposes of analyzing
potential air emissions from these machines, it is assumed that the machines and ancillary
equipment associated with the machines (e.g., piping and sumps), are the sources of
pollutants. These air emissions will occur as part of normal TOCDF operations.
When the munitions are brought to the ECRs or the MPB, the munitions have already
been identified, so the tlpe of propellant, explosive, miscellaneous materials and agent
being drained from the munitions and bulk items is known. Physical and chemical
characteristics of each waste are summarized in Attachment 2 (Waste Analysis Plan), and
are not reproduced here.
Potential sources of air emissions from the BDSs, PMDs, and MDMs, include agent,
decontamination solution, and possibly metal particulates (from the shearing and cutting
processes). Emissions of agent are predicted to occur due to vaporization.
Emissions of decontamination solution, which is a water-based cleaning solution, are
predicted to result from evaporative processes. However, the vapor pressure of this
solution (containing mostly water) at the conditions within the ECR or MPB is low;
therefore, evaporative emissions are expected to be negligible.
Emissions of metal particulates in the MPB are also expected to be negligible because the
bulk munitions are poretrated with a metal punch and no fragmenting is anticipated.
Operating Standards
The MPB is a Category A area and is under engineering controls at all times, as previously
discussed. Liquid wastes are captured and controlled in the containment system, air
emissions are controlled by the HVAC system and cleaned through filters, and the BDS
Attachment -14 - Page l6
14.3.7 .10
14.3.',7 .10.1
14.3.7 .ll
14.3.7 .ll.l
14.4
14.4.1
14.4.1 .l
t4.4.r.2
14.4.1 .3
14.4.1 .3.1
DemilitarizationMiscellaneou.r.."*r1rO,9rT
June 2009
operations are continuously monitored by the CON and PDARS. As a result, there is
virtually no opporhrnity for the waste constituents to be released in such a way as to have
adverse effects on human health or the environment due to migration into the outdoor
environment. The liquids are placed in tanks or, if spilled, are contained in sumps and
from there placed in tanks. Volatilized agent is captured by the HVAC system, primarily
in carbon beds. The BDS itself is operated in a systematic and safe manner whether in
automatic or manual mode, thereby reducing the potential for agent to be released and
migrate into the air.
Site Hydroloeic Conditions
A summary of site hydrologic conditions is given in Attachment I (Facility Description).
Migration of Waste Constituents
Migration of munition or bulk item wastes into the environment from BDS, PMD, or
MDM operations is not expected to occur. Therefore, no impacts on human health and the
environment fromthe BDSs, PMDs, orMDMs are expected.
PROJECTILE/}IORTAR DISASSEMBLY MACHINE
Physical Characteristics
The PMD is part of the Projectile/I\dortar Handling System (PHS). The PHS is designed
to safely separate explosives and miscellaneous parts (fuze well cups, supplementary
charges, and cardboard spacers) from 155mm projectiles and 4.2-inch mortars. The PHS
includes conveyors that transport the projectiles/mortars from the MDB UPA, through the
ECV, to the ECRs where the PMDs are used to remove the explosive components from
the projectiles/mortars. Next, the explosive and miscellaneous components are fed into
the DFS for thermal destruction, and the projectile/mortar bodies are transferred to the
MDM for chemical agent removal. After the chemical agent is removed, the
projectile/mortar bodies are thermally treated in the MPF. Finally, the drained chemical
agent is incinerated in one of the two LICs. The process differs for the mustard 155mm
projectiles, the projectiles will only have their burster wells crushed down into the
projectile at the MDM and then will be thermallytreated in the MPF.
The PHS consists of two identical process lines designed to operate simultaneously. Both
projectile/mortar processing lines (A and B) are located on the second floor of the MDB.
Each line consists of several conveyors and a PMD. The Projectile Feed Conveyors and
Projectile Discharge Conveyors for process lines A and B will be included with the
discussion of the PMD. These conveyors are not considered part of the PMD, but they are
included because they represent the beginning and end of the PMD treatment process.
Equipment Installation
The equipment that constitutes the PMD-I01 and PMD-I02 has already been installed,
and the installation of these machines and their support equipment has been Verified
through the Facility Construction Certification documentation required by Permit
Condition LS. This Certification attests that the PMD equipment has been installed in
accordance with the equipment's design specifications and drawings, as stated in this
Permit.
Attachment - 14 - Page 17
14.4.1 .4
14.4.1 .4.1
14.4.1 .4.2
14.4.1 .5
14.4.1 .5.1
r4.4.t.s.2
t4.4.1 .6
14.4.1 .6.1
t4.4.t.7
14.4.1 .7 .l
14.4. 1.8
14.4. 1 .8. I
DemilitanzationMiscellaneousTreatmJl;r',1
June 2009
Dimensions and Location
The approximate size of the PMD is 13 feet long by 11 feet wide by seven feet high. Most
of the machine components are nickel-plated, and others are coated with a corrosion
resistant epoxy paint to protect against the corrosive action of the decontamination
solutions used at the facility.
The PMDs are located inside ECRs A and B. To provide effective containment in the
event of any spills, leaks, or explosions, the ECRs have been equipped with blast doors
and blast gates that remain closed while operations are taking place. Furthermore, each
ECR is provided with a containment sump, and the air from the rooms is cycled through a
closed ventilation system equipped with carbon filters in order to control emissions. With
the blast gates and blast doors closed, each ECR is designed to contain a maximum
explosion equivalent to 15 pounds of trinitrotoluene. To ensure that this design limit is
not exceeded, the number of munitions in the ECR is limited. See Table I44-f for the
maximum number of munitions allowed into the ECR.
Conveyors
The projectile feed conveyors are made of steel and have dimensions of approximately
4.75 feet long and 1.33 feet wide. The projectile discharge conveyors are also made of
steel and have dimensions of approximately 1 1.13 feet long and 1.33 feet wide.
For process line A, the projectile feed conveyor and the projectile discharge conveyor are
located inside ECR A. For process line B, the projectile feed conveyor and the projectile
discharge conveyor are located inside ECR B.
Gates
The projectiles/mortars are transferred automatically from the ECV into ECR A or B
through munition access blast gates. After the projectiles/mortars are processed by the
PMDs, they are transfeffed out of ECR A or B through a discharge blast gate. These gates
will not close until a projectile/mortar is transferred completely into or out of the ECRs.
Pumos and Transfer Lines
PMDs do not drain the chemical agent out of the projectiles/mortars, thus there are no
pumps or chemical agent transfer lines associated with the PMDs.
Sump Pump
Each of the two ECRs is provided with a containment sump. Each sump is serviced by a
sump pump located in the Munitions Corridor. Sump pump operation is controlled by a
local-off-remote switch and must be designated by the toxic area entrant for either local
(local manual) or remote (level-controlled) operation. When a sump level alarm is sent to
the CON, the liquids collected in the sump are pumped to a spent decontamination
holding tank.
All tables are located at the end of this Attachment.
Attachment-14-Page I8
14.4.1 .9
14.4.1.9.1
14.4.1 .10
14.4.1 .10.1
14.4.1 .10.2
14.4.1 .10.3
Demi I i t anzation M i scel I aneous Treatm Jtot!3tl
June 2009
Tanks and Containers
There are no tanks or containers directly associated with the PMDs as they are being
addressed in this Permit. Chemical agent is drained in the MDM and then pumped
directly to the ACS, except for the mustard 155mm projectiles which will not be drained
prior to thermal treatrnent in the MPF. Only minor amounts of froth will enter the ACS
from the processing ofthese projectiles
Feed System
This section covers the feed system of one PHS; operation of the second system is
identical. The feed rate of projectiles/mortars to the ECR varies according to the type and
the amount of explosive fed to the DFS. One projectile/mortar system is coordinated with
the other to ensure that the explosive limit of the DFS is not exceeded.
After confirmation of correct lot number and quantrty of munitions, a signal is given to the
UPA operator to load projectiles/mortars onto the UPA Projectile/IVlortar Feed Conveyor.
When this operation is complete, the operator signals the CON system and CON operator
that loading is complete. The CON operator then initiates the start of processing the
projectile/mortar.
The following conditions must be met before commencement of operation:
14.4.1 .10.3.1 Feed conveyors are continuously running
14.4.1 .1 0.3.2 Stops on the conveyors are retracted
14.4.1 .10.3.3 ECR munition access blast gate is open.
14.4.1 .1 0.4
14.4. 1.11
14.4. 1.11.1
14.4.1 .11.2
When these have been confirmed, the orientation of the projectile/mortar is checked. If it
is found that the projectile/mortar was loaded backwards, the LIPA operator will reload the
projectile/mortar in the correct orientation. The projectile/mortar is conveyed onto the
feeder in the ECR. The feeder loads the projectile/mortar onto the Index Table, and the
table is rotated. At this time a second projectile/mortar, if properly oriented, is loaded
onto the conveyor system and is conveyed into the ECR to be loaded onto the Index Table.
At this point, the munition access blast gate closes and the first operation of the explosive
removal process coillmences.
Instrumentation
The PMD is operated by PLCs. The PLCs contain the controls and instruments for the
PMD but are not a part of the machine. All the instrumentation installed on the machine
is designed to relay information to the PLC. Also, the machine can be operated locally by
setting the machines in the local mode from the PLC.
There is a variety of sensors installed to support the operation of the PMDs. The sensors
are used to track process flow through the machine and cqntinually update the PLC with
new information. Those types of sensors include inductive proximity sensors (used to
track munition movernent throughout the process and to indicate the switches) and fiber-
optic switches. The sensors are used to track movement throughout the process and to
indicate cylinder or actuator position. A list of those sensors, their t1pe, and a brief
description of their function is provided in Table 14-4-2.
Attachment -14 - Page 19
14.4.r.12
14.4.1 .12.1
14.4.1 .13
14.4.1 .13.1
14.4.1 .14
t4.4.t.14.1
14.4.1.15
14.4.1.15.1
t4.4.2
t4.4.2.1
14.4.2.2
t4.4.2.2.1
t4.4.2.2.2
DemilitarizationMiscellaneourrr""*"1:;:r,:
June 2009
Electrical System
See Section 14.3.1.12.
Heating. Ventilation. and Air Conditioning System (HVAC)
See Section 14.3.1.13.
Fire Protection System
The ECR High-Speed Deluge Systems are located in the ECRs and installed above the
miscellaneous parts conveyors of the PMDs. Each system consists of three UV flame
detectors, three Rapid-Response deluge valves, and a manual pull station located in each
ECR. When a flame is detected on the miscellaneous parts conveyor, the UV sensor sends
a signal to the Rapid-Response deluge control panel, which in tum actuates the High-
Speed Deluge Solenoid Valve and sends an alarm to the control panel. The detection of a
flam will operate the High-Speed Solenoid in approximately 49 miliseconds. The systern
is activated and ready to respond during projectile campaigns that result in explosive
debris on the miscellaneous parts conveyors (i.e. 105mm M604d360 projectile campaign
when fuze booster-cups were punched above the miscellaneous parts conveyor).
Alarm and Communication Systerns
See Section 14.3.1.15.
Operations and Maintenance
There are two systems that process non-leaking projectiles/mortars prior to the
incineration. These systems operate in parallel, each in its own ECR. This description
covers the operation of one processing system. Operation of the second system is
identical. Both line is capable of meeting the maximum feed rate of the DFS, and the two
lines are coordinated with each other. Pallets containing leaking projectiles/mortars are
handled similarly to pallets without leakers, except that for sealed3 ONCs determined, via
ACAMS monitoring, to have agent levels greater than 40 VSL, munition unpacking
occurs in the TMA. The process description for leaking munitions can be found in
Attachment 9 (Contingency Plan).
General System Operation
The PMD is located in the ECR and is comprised of five major work stations: the
Infeed/Transfer Station (IS), Nose Closure Removal Station (NCRS), Miscellaneous Parts
Removal Station (MPRS), Burster Removal Station (BRS), and Discharge/Output Station
(DS).
The feed of projectiles/mortars to the PMD is described in Section 14.4.1.10, "Feed
System." After a projectile/mortar is successfully transferred into the ECR, the projectile
feed conveyor transfers the projectile/mortar to the PMD's infeed conveyor for
disassembly. The PMD infeed conveyor then transfers the projectile/mortar to the IS on
the PMD Index Table and the table is rotated to the NCRS. The NCRS removes the nose
3The requirements for overpacks that fail the seal test are described in Permit Condition III.G.4.
Attachrnent - 14 - Page 20
14.4.2.2.2.1
14.4.2.2.2.2
14.4.2.2.3
1,4.4.2.2.4
14.4.2.2.5
t4.4.2.3
14.4.2.3.1
Derni I i tari zati on M i scel I an eour r.."*"]:firr:
June 2009
closure or fuze and burster when processing mortars. Then, the lndex Table rotates the
projectile/mortar to the MPRS where the supplementary charge and miscellaneous parts (if
any) are removed and the burster is rotated. After the operation at the MPRS is
completed, the Index Table rotates to the BRS where the burster of the projectile is
rernoved by differential air pressure. If the burster is successfully removed using
differential air pressure, the Index Table then rotates again to the DS where the
projectile/mortar is removed from the PMD by the projectile discharge conveyor.
If the burster cannot be successfully removed using differential air pressure, the Index
Table rotates back to the PMD's infeed conveyor and the projectile is transported back
into the ECV for storage. Only after the burster has been removed, the Index Table rotates
to the DS where the projectile is removed from the PMD by the projectile discharge
conveyor.
The burster-less projectile/mortar is transported from the PMD to the discharge blast gate
and stop. The munition discharge blast gate opens and the stops holding the munition are
retracted, allowing the projectile without explosives to transfer out of the ECR and the
next projectile/mortar to travel inside the ECR.
The nose closure or fuze, miscellaneous parts, and the supplementary charge are deposited
onto the miscellaneous parts conveyor which transfers them to the DFS feed gate for
thermal destruction. The bursters are conveyed to the Burster Size Reduction machine
(BSR).
The BSR may be adapted to receive each of the various sizes of bursters from the mustard
155mm projectiles. When configured for burster shearing, water-cooled shear blades cut
the burster into pieces that fall into the DFS feed gates. Since the bursters on the 155mm
Ml044d110 and 4.2-nch mortars are relatively small in comparison to other munitions,
and since it is open at one end, it does not require this reduction operation. Mustard
I 55mm bursters may be sheared in order to reduce potential jamming of the DFS heated
discharge conveyor.
Mustard 155mm projectiles that have not been configured with energetics (i.e., non-
explosive) may bypass the ECR and the PMD entirely. ln this case, in lieu of using the
PMD to remove the nose closures, the nose closures may be removed manually by facility
personnel before transferring the projectiles to the MDM.
Setup Procedures
Automatic operation is the preferred mode for the startup, shutdown, and emergency
shutdown of the PMDs and is to be used when possible for all operations. When the
system is in automatic and remote manual from the Control Room mode, all system
interlocks are automatic, causing the system to fail safe should an abnormal or upset
condition occur. Both A and B lines have the same startup, shutdown, and emergency
shutdown procedures. Before the startup procedures can begin, the operator must ensure
the following systems are operable and online: DFS, DFS PAS, Decontamination System,
SDS, Process Water System, Cooling Water System,Instrument Air System,
Unintemrptible Power Supply System, Plant Air System, Secondary Power System,
Primary Power System, Emergency Generator System, MDB HVAC System, ACS, and
CON Console Operations.
Attachrnent - 14 - Page 2l
14.4.2.4
t4.4.2.4.1
14.4.2.5
14.4.2.5. I
14.4.2.6
t4.4.2.6.t
DernilitarizationMiscellaneourr.""*J,O;lr,:
June 2009
System Startup
The procedures for PMDs startup are contained in the appropriate PMD system standard
operating procedures document. In summary, the systems are started by selecting the type
of agent and the type of munition to be processed and placing the PMD stations in
automatic mode. This is done remotely by the CON operators. Before operations are
commenced, a receiving tray is staged in the Upper Munitions Corridor on the Bypass
Conveyor (this is where the munitions are sent after treatment at the PMD). Once these
steps are perfomied, the PMDs are ready to begin treating munitions.
Feed
Prior to the projectiles/mortars arriving at the blast gate (located between the ECV and
ECR and leading to the projectile input conveyor), the projectiles/mortars are identified in
the storage igloo, placed in an Onsite Container (ONC) along with their pallet, transported
to the Container Handling Building (CHB), and moved to the UPA where the ONC is
monitored for chemical agent. If chemical agent is detected, via ACAMS monitoring,
inside the ONC, at levels less than or equal to 40VSL, the ONC is opened; the pallet is
moved out into the UPA and unpacked. For non-burstered projectiles, the nose plug is
either: (1) removed manually in the Upper Munitions Corridor after the munitions are
loaded onto trays and the trays are transferred to the blpass conveyor and moved to the
Upper Munitions Corridor. Trays are delivered to the MPB for further processing through
the MDM following nose plug removal; (2) removed at the PMD; (3) removed at the
MDM. For burstered projectiles and mortars, the UPA operator loads the
projectile/mortar onto the UPA Projectile/IMortar Feed Conveyor. If the projectile/mortar
is correctly oriented, it is then transported to the blast gate leading to the PMD. During
that process, appropriate inspections and paperwork are completed to satisff the various
requirements associated with the Army Surety Program, the CWC, and hazardous waste
identification and tracking requirements. Waste quantification requirements are met when
the chemical agent is drained from the projectileimortar at the MDM and pumped to the
AQS. These various activities are recorded either manually, or by the PDARS, and such
records will be available for scrutiny in the facility operating record.
Interlock Processes
The PMDs are operated in either the manual or automatic mode using a system of
interlocks. The goal of the various interlocks is to ensure that the procedures executed by
the various components of the PMDs neither interfere with each other, nor operate in a
manner that is unsafe to human life and health or harmful to the environment. The
interlocks areZS-1391239,l-Pt,Z-Pl, ardzs-1471247. Interlocks 23-1391239 are
described in this section, 1-P1 and 2-P7 are described in Sectionl4.4.2.7, andZS-1471247
are described in Section 14.4.2.11. The interlocks remain in place during manual
operation and also prevent operator error that could result in the machine being operated
in an unsafe or unprotective manner. The demilitaizationmachine operators are required
to observe the machines during automatic operations to ensure that any stops in the
programmed process sequence are corrected as soon.as possible.
When a projectile/mortar stops jusf befor'e it enters the ECR, the munition access blast
gate will open and the projectile/mortar will be conveyed into the ECR. An infrared retro-
reflector sensor (ZS-139 andZS-239, for lines A and B, respectively) detects the
projectile/mortar while it is passing through the blast gate. The sensor is interlocked with
t4.4.2.6.2
Attachment - 14 - Page 22
14.4.2.6.3
14.4.2.J
14.4.2.7.1
14.4.2.8
14.4.2.8.1
14.4.2.8.2
14.4.2.9
14.4.2.9.1
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
the munition access blast gate so that the gate remains open until the entire
projectile/mortar has successfully passed through the munition access blast gate and enters
the ECR.
Once the projectile/mortar enters the ECR, it is processed by the PMD. The
projectile/mortar entering from the blast gate is transferred to the projectile feed conveyor.
The projectile feed conveyor moves the projectile/mortar to the PMD Infeed/Transfer
Station.
Infeed/Transfer Station
Asensorontheinfeedconveyor(1-Pl and2-Pl,for linesAandB,respectively)detects
the presence of the projectile/mortar. This sensor is interlocked with the munition access
blast gate. The munition access blast gate will close when the sensor detects the
projectile/mortar on the infeed conveyor. The infeed conveyor moves the
projectile/mortar near the saddle on the Index Table. From this position, the Transfer
Conveyor Pusher contacts the projectile/mortar and pushes it onto the saddle. The Index
Table then rotates clockwise to bring the projectile/mortar to the NCRS.
Nose Closure Removal Station (NCRS)
The NCRS is the number 2 processing station on the PMD. The NCRS is used to remove
the nose closure or fuze from projectiles and fuzes and bursters from mortars. When a
projectile/mortar is detected in the NCRS by sensor P2, the projectile is clamped. A
hydraulic chuck engages and unscrews the components. The components are removed
from each type of projectile/mortar as follows:
All components from the NCRS are dropped onto the miscellaneous parts removal station
conveyor. After the operation in the NCRS is completed, the station signals to the PLC
that it is ready to index. The Index Table is then rotated clockwise to bring the
projectile/mortar to the MPRS.
Miscellaneous Parts Removal Station (MPRS)
The MPRS removes the fuze well cup or supplemental charges from the projectiles. Not
all projectiles have components that require removal at the MPRS station. Munitions that
do not require any disassernbly at this station [such as some 155mm projectiles and all4.2-
inch (M2A1) mortarsl will blpass it. When sensor P3 detects a projectile is present at the
MPRS, the projectile hold-down cylinder and positioning cylinder extend. Then, the
MPRS carriage moves forward to remove the components from the following types of
projectiles:
Proi ectile/lVlortar Removal Process
155mm The nose closure is unscrewed and removed.
Mortars The fuze and burster are unscrewed and removed as one unit since they
are screwed together; therefore, the hydraulic chuck is needed to
separate the firze from the burster.
Proiectile Removal Process
The screw tlpe fitze well cups from Ml04 and Ml10 projectiles are
removed.
Attachment - 14 - Page 23
14.4.2.9.2
14.4.2.9.3
14.4.2.9.4
14.4.2.10
14.4.2. 10. 1
14.4.2.I0.2 Reserved
14.4.2.11
14.4.2.11 .l
14.4.2.11.2
DernilitarizationMiscellaneourr.""*r1rO,?XUl
June 2009
Components that have been removed are deposited on the MPRS conveyor. The MPRS
conveyor discharges all parts onto the DFS feed gate, from which they are sequenced into
the DFS.
Reserved
When processing 155mm Ml044d110 projectiles, following fuze well cup removal, the
Burster Rotating Adapter Device (BRAD) extends to contact the burster. The BRAD then
rotates the burster, in preparation for burster removal at the Burster Removal Station
(BRs).
Burster Removal Station (BRS)
The BRS is the next station to process the projectiles after the MPRS. The BRS is used to
rsmove btrsters from projectiles with the use of high pressure air. The 4.2-nch mortars
are not processed by the station. The operation begins when a projectile is sensed by the
P4 sensor. The projectile positioning cylinder extends. Then the BRS carriage moves
forward and a delta-P head assembly contacts the projectile. High pressure air
(approximately 100 - 300 pounds per square inch) is applied to the head of the projectile.
The differential pressure causes the burster to separate from the projectile, and the BRS
carriage retracts with the burster. A gripper transfers the burster to a conveyor which in
tum transfers the burster to the BSR. The BSR shears the burster into sections and feeds
them to the DFS.
Discharge/Output Station (D S)
The projectile will be rotated to the DS after its burster is removed at the BRS. T\e 4.2-
inch mortars blpass the MPRS and BRS enroute to the DS. The DS transfers the
projectile/mortar to the projectile discharge conveyor. This is accomplished using the
PMD transfer conveyor pusher. The projectile discharge conveyor transfers the
projectile/mortar to the discharge blast gate. Sensor ZS-147 or ZS-247, for line A or line
B, respectively, is interlocked with the discharge blast gate. The sensor allows the
discharge blast gate to open and keeps it open until the projectile/mortar has successfully
passed out of the ECR.
After the projectile/mortar exits the ECR a burster detection system, located at the
Projectile Output Conveyor discharge stop in the Upper Munition Corridor, checks the
projectile to verifu that the burster has been removed. After verifying burster removal
status, the mortar is tilted to the upright position. If a burster is detected in the projectile,
the Multi-position Loader (MPL) will not transfer the projectile to the munitions tray. The
projectile with the detected burster will be loaded onto the reject table by the MPL. The
reject tables are located next to the Projectile Output Conveyor discharge stop. They can
each hold a maximum of four projectiles or six 4.2 inch HT mortars. Any rejected
projectiles will be removed manually by an operator in appropriate PPE. The projectiles
are then loaded onto an empty munitions tray by the MPL. The loaded tray will be
transported into the MPB, and the projectiles/mortars will be processed by the MDM.
System Shutdown (Normal)14.4.2.12
Attachrnent - 14 - Page 24
14.4.2.12.1
14.4.2.13
14.4.2.13.1
14.4.2.14
14.4.2.14.1
14.4.2.15
14.4.2.15.1
14.4.3
14.4.3. I
14.4.3.2
14.4.3.3
14.4.3.4
Demi I itari zati on M i scel I an eou. r.""*"]:;:r.:
June 2009
Normal shutdown of the PMDs is done in accordance with standard operating procedures.
The system must be first clear of all munitions. The CON operators then issue "stop" and
'opark" commands to the system. The equipment is placed in home position at this time.
Emergency Shutdown
In the event of an abnormal or upset condition, an emergency stop is initiated. This is
initiated remotely by the CON operator and is done by activating an emergency stop. An
abnormal or upset condition may include any condition that causes an emergency
termination in processing, nonconfornance to a specified procedure, a safety hazard,
equipment damage, or injury to personnel. The CON operator will record any abnormal or
upset conditions in a logbook.
Extended Shutdown
The extended shutdown will be utilized to protect personnel and equipment during a
shutdown period. This operation, or parts thereof, can be applied at the discretion of the
Shift Manager or his/her designee. Extended shutdown procedures are initiated after the
PMD systems have been parked. The extended shutdown procedures are implemented
during agent campaign changeover.
Maintenance
To ensure that the PMDs are in operational condition at all times, and to discover and
correct any defects before they result in serious damage or failure, the PMDs will be
systematically subjected to preventive maintenance inspections.
Monitoring Procedures
Each PMD is equipped with several types of sensors to detect the presence and position of
projectiles/mortars during operation. These sensors ensure that the projectiles/mortars will
be processed safely by relaying information to the PLC. The functions of these sensors are
described in Section t4.4.1.1l, "Instrumentation", and summarizedrnTable |4-4-2.
The CON operators monitor the operations of the PMDs through the demilitaization
operator consoles and CCTVs. The demilitaization operator consoles can display
information from the PLCs and sensors. The PDARS provides operational data for
analysis and historical records. Information obtained by the PDARS can be used to meet
environmental monitoring and reporting requirements.
In addition, the CON operators and outside operators are required to log the events that
occur during their shift into their respective logbooks.
Chemical agent released in the ECRs will be contained by the sumps or controlled by the
HVAC system. ACAMS are used to monitor for the presence of agent in the ECRs and
the ECV.
Fire Protection14.4.3.5
Attachrnent -l4 - Page25
14.4.3.5.1 .The ECR High-Speed Deluge Systems are located in the ECRs and installed above the
miscellaneous parts conveyors of the PMDs. Each system consists of three UV flame
detectors, three Rapid-Response deluge valves, and a manual pull station located in each
ECR. When a flame is detected on the miscellaneous parts conveyor, the UV sensor sends
a signal to the Rapid-Response deluge control panel, which in tum actuates the High-
Speed Deluge Solenoid Valve and sends an alarm to the control panel. The detection of a
flam will operate the High-Speed Solenoid in approximately 49 miliseconds. The system
is activated and ready to respond during projectile campaigns that result in explosive
debris on the miscellaneous parts conveyors (i.e. 105mm M60A{360 projectile campaign
when fuze booster-cups were punched above the miscellaneous parts conveyor).
Waste Identification
Demi I it anzation M i scel I aneous TreatmJ:;#I
June 2009
By the time a projectile/mortar reaches the PMD, it will have been fully identified per
Attachment 2 (Waste Analysis Plan).
Waste Throughput
When a projectile/mortar arrives at the PMD, its nose closure or fuze is removed. Then
the supplementary charge or miscellaneous parts (if any) are removed. The next station
removes the burster by differential air pressure or direct force for mortars. The
projectiles/mortars are quantified by the PDARS and by the manual record created by the
CON operator who observes the PMD in operation.
Inspection
See Section 14.3.4.
Closure
Partial Closure
At the conclusion of each agent campaign or the beginning of a new munition campaign,
the ECRs will be thoroughly decontaminated, as necessary; all decontamination films shall
be removed using an appropriate rinse; and maintenance and repair will be performed on
the machines and other room components as necessary. The TOCDF will submit in
writing to the Executive Secretary, a request for partial closure of the room, since either
the agent or the munition tlpe is being changed. Upon approval for partial closure from
the Executive Secretary, the next campaign will commence when authorized and when it
is appropriate to do so.
Final Closure
Closure of the site is addressed in Attachment 10 (Closure Plan).
Mitisative Design and Operating Standards
The ECR is a room where explosives or propellants could potentially be ignited. The
design and operating plans for the ECR have been carefully prepared to anticipate this
tlpe of mishap. For example, as a worst-case situation, the operating plan limits the total
14.4.3.6
14.4.3.6.1
14.4.3.J
14.4.3.7 .l
14.4.4
14.4.4.1
t4.4.s
t4.4.5. 1
14.4.5. 1 . 1
14.4.5.2
14.4.5.2.1
t4.4.6
14.4.6.1
Attachrnent - 14 - Page 26
14.4.6.2
14.4.6.3
t4.4.6.4
14.4.6.5
14.4.6.6
14.4.7
t4.4.7.1
DernilitarizationMiscellaneourr.""*J:;X,,:
June 2009
amount of explosives or propellants that are present in the room at afiy one time so that in
the event of an accidental ignition, the ECR could contain the reaction.
Protective systems in the ECR include an industrial-type, automatically activated fire
sprinkler system. Also, water and decontamination solution outlets are available within
the room for final manual wash-down and area cleanup. The floor of the room is sloped to
drain to a sump, and the sump de-watering system transfers the collected liquid to the SDS
for disposal in one of the two LICs. Protective clothing is mandatory during cleanup of
explosive and propellant residues in the room, and care is taken to reduce the potential for
residues.
If an explosion occurs in a containment room, it is expected that a portion of the agent will
be combusted while the remainder will exist in a vapor or liquid form. In the ECR, the
agent vapors will be contained in the room because both the blast valves and the leak-tight
dampers will be closed. The blast valves will remain closed until the pressure decays to
the point where the spring force is greater than the room pressure (0.5 pounds per square
inch). At this pressure, the blast valve will open, but the leak-tight damper will continue
to contain the gases. The leak-tight dampers will not be opened until the room gas
pressure has decayed to approximately atmospheric pressure.
The ECR is completely surrounded by rooms that are ventilated to the filter system.
Therefore, any leakage out of the ECR as a result of a blast will be vented to the filter
system.
Liquid agent in the ECR resulting from an explosion or leaking munition will be collected
in the ECR sump. Because of the limited number of munitions that will be in the ECR at
any one time and the maximum agent capacity of individual muntions in the event of a
leak, the amount of liquid agent released by an explosion is not expected to be greater than
about two gallons. Once ventilation has been reestablished in the ECR (by reopening the
gastight valves), DPE entries will be made, and the area will be hosed down with
decontamination solutions. Sufficient decontamination solution will be used to ensure
complete neutralization of the agent. The resulting solution will then be pumped to the
SDS for later disposal in the LICs.
If entry to the ECR is required after processing projectiles/mortars and explosives may be
presant, the Entry Team shall thoroughly wet each other's PPE and the ECR floor (where
they will be working) immediately prior to entering the ECR, to preclude the possibility of
static discharge. A water hose is available at the decontamination station by the access
door to each ECR.
Environmental Performance Standards for Miscellaneous Units
The PMDs have been designed, installed, and will be operated in a manner to preclude the
release of hazardous chemical constituents that may have adverse effects on human health
or the environment. Section 14.4.7.2 describes the potential for waste constituent releases
to the environment (air, soil, and water), the potential impact of such releases, and the
location features of the TOCDF that will mitigate these releases.
Miscellaneous Unit Wastes14.4.7.2
Attachrnent -14 - Page27
14.4.7.2.1
14.4.7.2.2
14.4.7.3
14.4.7 .3.1
14.4.7.4
14.4.7.4.1
14.4.7.5
14.4.7 .5.1
14.4.7.6
r4.4.7 .6.1
14.4.7.7
14.4.7 .J .l
14.4.7.8
14.4.7.8.1
14.4.7.9
14.4.7 .9.1
t4.4.7 .9.2
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
The volume and the physical and chemical characteristics of the wastes to be treated at the
PMDs include 155mm projectiles and 4.2-inch mortars. These wastes have been fully
identified and information about their physical and chemical characteristics may be found
in Attachment 2 (Waste Analysis Plan). The maximum volumes of wastes that will be
allowed into the ECR at one time are listed in Table 14-4-1.
The energetics and chemical agent wastes will be incinerated. The nose closure or fuze
and burster removed from the projectiles/mortars will be incinerated in the DFS. The
chemical agent will be drained by the MDMs and then incinerated in the LICs. The
projectile nose plugs and drained projectiles/mortars will be sent to the MPF.
Containment System
See Section 14.3.7.3.
Site Air Conditions
See Section 14.3.7.4.
Topography
See Section 14.3.7.5.
Meteorologic and Atmospheric Conditions
See Section 14.3.7.6.
Air Oualit),
See Section 14.3.7.7.
Prevention of Air Emissions
See Section 14.3.7.8.
Qperating Standards
Based on the above, chemical agent is assumed to be the pollutant of concem from the
PMDs with respect to air emissions.
Chemical agent emissions from the PMDs will be captured by the MDB HVAC systern
and controlled by the MDB carbon filter system. Emissions from the MDB are discharged
to the 120-foot HVAC stack.
The PMDs are located in the ECRs within the MDB. The ECRs are maintained at
approximately -2 inches of water column. These two rooms are maintained at the lowest
pressures within the MDB so that all air emissions from the PMDs during normal
operations will be captured by the ventilation system rather than migrating to another part
of the building.
14.4.7 .9.3
Attachrnent - 14 - Page 28
14.4.7 .9.4
14.4.',|. 10
14.4.7 .10.1
14.4.7.11
14.4.7 .11 .l
14.5.
14.5.1
14.5. 1 . I
TOCDF
Demilitarization Mi scellaneous Treatment Units
June 2009
Attachment 5 (Inspection Plan) covers the MDB ventilation and carbon filter systems. In
summary, the ventilation and carbon filter systems will be inspected daily by plant
personnel to ensure proper operations of these systems. In addition, sensors have been
installed in the carbon filter system to determine automatically if plugging occurs, to
detect chemical agent, and to determine loss of blower performance.
Site Hydrologic Conditions
A summary of site hydrologic conditions is given in Attachment 1 (FacilityDescription).
Migration of Waste Constituents
See Section 14.3.7.11.
MULTIPTTRPOSE DEMILITARIZATION AI\D PICK AI\D PLACE MACIIINES
14.5.T.2
I4 .5. 1 .3
14.5.1 .4
Phvsical Characteristics
The TOCDF MDMs are designed to either 1) remove burster wells and drain chemical
agent from 4.2-nch mortar cartridges or 2) collapse mustard 155mm projectile burster
wells down into the projectile body. The processed munitions and pdectile nose plugs
are sent to the MPF for thermal treatment. Chemical agent is collected by the ACS, a
separate system that includes the AQS, agent holding tanks, associated pumps, valves,
piping, and other ancillary equipment. The agent is then sent to one of the LICs for
processing. Since no agent is drained from the mustard 155mm projectiles, only minor
amounts of froth will enter the ACS.
There are three MDMs in the MPB. Associated with each MDM is a PPM. The PPMs
are robotic systems designed to transfer one munition at a time from the munitions trays to
the MDMs and then back to the munitions trays. The PPMs do not perform
demilitarization operations but are an integral part of the MDM demilitarization process.
Therefore, information about them is included in this Permit.
For purposes of defining the MDMs, they are considered to begin and end at the pick and
place robot loader. The loader is the part of the PPM that removes munitions from the
munitions tray. The demilitarization process begins when the munitions tray arrives at the
appropriate location in the MPB, as determined by an electronic sensor, and the pick and
place loader selects and removes a munition from the tray. The demilitarization process
ends, with respect to the MDM, when the pick and place loader retrieves the munition
from the MDM and returns it to the tray.
The MDMs process munitions that are not configured with explosives, propellants, or
other energetics, so the processing system is only concemed with separating the chemical
agent from the munition [the explosives, propellants, and energetics are removed in the
ECR by the PMDI. The MDMs are similar to the PMDs in that the munitions are placed
on an indexing tray that rotates the munitions from one processing station to the next.
Each station is designed to perform a different operation. The munitions enter and leave
the MDM from the same station (i.e., Load/Unload Station). The following munitions are
processed on the MDMs:
Reserved14.5.r.4.1
Attachment - 14 - Page 29
14.5.1 .4.2
14.5.1 .4.3
14.5.1 .4.4
14.5.1 ,4.5
14.5.1 .4.6
14.5.1 .4.7
14.5. 1 .4.8
14.5.1.5
r4.5. 1 .5. 1
14.5 .l .6
14.5. 1 .6.1
14.5 .l .6.2
14.5.1 .7
14.s .t .7 .l
t4.s. 1.8
14.5. 1.8.1
14.5.1 .9
t4.5. 1 .9.1
Derni li tari zati on M i scel I an eou r rr""* J:JX,,:
June 2009
Reserved
M104, l55mm Projectiles (H)
Ml10, 155mm Projectiles (H)
Reserved
Reserved
M2, 4.Z-rnch Mortar Cartridges (HT)
M2, 4.2-inch Mortar Cartridges (HD).
Equipment Installation
The equipment that constitutes the MDMs and PPMs has already been installed, and the
installation of these machines and their support equipment has been verified through the
Facility Construction Certification documentation required by Condition I.S. This
Certification attests that the MDM/PPM processing system equipment has been installed
in accordance with the equipment's design specification and drawings, as stated in the
Permit. Information about the Certification documentation is referenced herein to avoid
duplication in this Permit.
Dimensions and Location
The PPMs straddle the MDMs as well as each conveyor line (Line A and Line B) in the
MPB. The width of the PPMs is approximately 35 feet. The height to the centerline of
the mast, which supports the pick and place robot loader carriage, is approximately 12
feet. The height to the top of the carriage is approximately 15 feet.
The MDMs and PPMs are located on the second floor of the MDB in the MPB.
Conveyors
Munitions are transported to the MDMs using Line A and Line B conveyor systems. Each
line is composed of three conveyors. The conveyors automatically transport munitions
trays to the correct location for pick and place operations. Various sensors located along
the conveyor rails detect the presence of munitions trays, adjust the tray speed, and stop
the trays as needed.
Gates
The munitions trays are transferred automatically from the Upper Munitions Corridor into
the MPB through one of the two MPB gates. These gates are opened to receive munitions.
The gates are not interlocked with the MDMs or PPMs, but they are interlocked with
sensors that detect the presence of a munitions tray beneath the gate (see Section 14.5.2.6,
"laterlock Processes").
Pump and Transfer Lines
The MDMs are equipped with pumps to remove agent from the munitions. The agent is
transferred by a pump from the munitions through lines connecting the pumps to the ACS.
The ACS storage tanks are located in the MDB.
Tanks and Containers14.5. 1.10
Attachrnent - 14 - Page 30
14.5.1 .10.1
14.5.1.11
14.5.1.11.1
14.5.1 .1I.2
14.5.1 .12
14.5.1 .12.1
14.5.1 .12.2
14.5.1 .13
t4.5.1 .1 3.1
14.5.r.14
14.5.r.14.1
14.5.1.15
14.5.1.15.1
14.5.1.16
14.s.1 .16.1
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
There are no tanks or containers directly associated with the MDMs for the processes
addressed in this Permit. However, there is a tank on each MDM that is part of the AQS,
which is part of the ACS. The tank associated with the MDMs is either a 1.5-inch or 3-
inch diameter tank. The 3-inch diameter tanks are used during processing of 4.2 nch
mortars. Agent is not drained from the mustard 155mm projectiles.
Feed System
The PPMs are the waste feed system for the MDMs. The PPMs are fully automated (or
manually operated) robotic systems that move waste munitions to the MDMs for
processing and then return them to the munitions trays. Agent removed from munitions at
the MDM is collected by the AQS and sent to the LICs. In addition, the processed
munitions are fed to the MPF for thermal treatment.
As will be discussed in later sections, the PPM is connected to the PDARS that records the
number of munitions processed by the MDMs. The rate at which waste munitions are fed
to the MDM depends on the type of munition (only one type of munition is processed at a
time). The MDMs can hold up to six munitions of the same caliber and fill-type at a time.
Processing time varies depending primarily on the time it takes to drain the various size
munitions and load/unload them.
Instrumentation
Instruments associated with the MDMs are remotely monitored in the TOCDF CON. The
instruments are primarily associated with the hydraulic and pneumatic systems, electronic
position sensors, drain verification system, and interlocks. The sensors provide input to
the programmable logic controllers (PLC) for automatic processing of various munitions.
The PLCs, in tum, control the automatic function of the various MDM instruments.
Table 14-5-1 & Table l4-5-l{ summarizes the various sensors for the MDM and their
functions. The instruments, and their tag numbers, are shown on drawings contained in
Attachment 11 (General Facility Drawings).
Electrical System
See Section 14.3.1.12.
Heatine. Ventilation. and Air Conditioning System GryAC)
See Section 14.3.1.13.
Fire Protection System
See Section 14.3.1.14.
Alarm and Communication Systems
See paragraph 14.3. 1. 1 5.
All tables are located at the end of this Attachment.
Attachment -14 - Page 3l
14.5.2
14.5.2.1
14.5.2.2
14.5.2.2.1
14.5.2.2.2
14.5.2.2.3
t4.5.2.2.4
14.5.2.2.5
t4.s.2.2.6
Dernil i tarizati on M i scel I an eou. r.""*J.of,3rl
June 2009
Operations and Maintenance
After the explosive components of the munitions have been removed in the ECR, trays of
munitions are transported by the Charge Car, located in the Upper Munitions Corridor, to
the MDMs in the MPB via the Line A or Line B MPB feed conveyors. The MDMs and
PPMs are fully automated but can be operated manually (remotely or locally controlled), if
required. A brief description of the MDMs and PPMs operation is contained in the
following sections.
General System Operation
Each of the three MDMs can be operated separately, in conjunction with either of the
othertwo MDMs, or simultaneouslywithboth of the othertwo MDMs.
Prior to startup, the CON operators execute a series of computer commands to initiate the
MDMs and PPMs. To begin MDM operations, the operators in the CON then issue a
"start" command. The initiation and startup procedures, respectively, are described in the
next sections.
The trays come into the MPB through the MPB gates after being processed in the ECR
(see Section 14.4 for ECR demilitarization machine operations). The CON operators use
the CCTVs to verify that a munitions tray has arrived at the correct conveyor location for
pick and place operations and also to veriff the number of munitions in each tray. The
number of munitions is recorded in a logbook.
The PPM selects a munition and lifts it from the munitions tray. The munition is carried
to MDM Station 1 (LoadAJnload Station), which serves as the deliverypoint for
munitions entering the MDM and as the pickup point for munitions exiting the MDM.
Several electronic sensors are used to monitor the presence of munitions at each MDM
station (see Section 14.5.2.6 for a description of these sensors). Each munition is placed
in the station vertically with the base down and the nose up.
The first munition delivered to the MDM is rotated to Station 2, and another munition is
retrieved by the PPM and delivered to the Load/Unload Station. Then both munitions are
rotated so that the first munition goes to Station 3 and the second moves to Station 2.
Another munition is placed in the Load/Unload Station and the table is rotated again.
Eventually, the MDM is operated so that all six stations have a munition (except when the
munitions tray does not have enough remaining unprocessed munitions to deliver to the
MDM). Stations 2 and3 do not perform any operations.
At MDM-101, Station 4 is normally used as the Bore Station. It is designed to bore out
welded or stuck burster wells. This station is not expected to be used very frequently
because most of the munition burster wells were assembled with the press fit method. If a
munition requires boring, a clamp cylinder extends and holds the munition in place while
the boring head (consisting of an appropriately sized spade drill bit) bores vertically down
through the top of the munition. The bore head is raised and lowered by a feed cylinder
that contains the bore head drill and motor and is mounted on four vertically-mounted
bolster rods. As an altemative, this position can also be configured as a Nose Closure
RemovallBurster Detection Station, which may be used to process projectiles received at
the TOCDF without bursters. At this station, the nose plugs will be removed and the
absence of a burster will be confirmed. At Station 4 of MDM-102 and MDM-103, aO
Attachment -14 - Page32
14.5.2.2.7
14.5.2.2.8
14.5.2.2.9
t4.5.2.2.10
Demi I i tari zati on M i scel I an eou. r.".t. J:,tl, r:
June 2009
Burster Well Punch Station is installed in place of the original bore station for the "punch"
or collapsing of mustard 155mm projectile burster wells down into the projectile body.
Station 4 of MDM-I02 and MDM-103 is not used during mortar processing.
Station 5 is the Pull and Drain Station. It is designed to remove the burster well, thus
providing access to the agent-filled cavity in the munition, and then to drain the agent
from the munition. Upon entering Station 5, the munition is lifted slightly and held in
place while the carriage assembly, which contains a collet assembly and pull cylinders, is
lowered so that the collet assembly enters the munition. The collet expands to grip the
burster well, and the pull cylinders extend to raise the collet assembly and the burster well
from the munition. Station 5 is blpassed for mustard 155mm projectiles since the agent
cavity is previously breached at Station 4, ard no agent is removed from the projectiles.
After the burster well is removed from the munition, the munition is shifted horizontally
into the Drain Station position. A drain tube, which consists of a straight, hollow, steel
tube, is lowered into the munition, and the ACS removes the agent from the munition.
Under normal operations, it is expected that some of the agent will not be removed by this
process. After draining the munition, the drain tube is retracted, the munition retums to
the Pull Station, and the burster well is placed back in the munition (or, for some munition
t1pes, it is dropped into the burster well chute). Station 5 contains a drip pan to collect
residual agent that may drip from the burster well and agent drain tube. During mortar
processing, the bursters are not reinserted but dropped onto the reject chute where they fall
to a small conveyor which transports them to a container where they are accumulated until
the container holds approximately the same number of burster wells as there are drained
mortars on a MPF Feed tray. When full the container is lifted onto the tray of drained
mortars and fed with it to the MPF. Alternatively, if the equipment used to transfer the
burster to the feed container then onto the feed tray is unavailable, thur up to 96 burster
wells maybe collected and fed separately to the MPF.
Station 6 is the Crimp Station. It is designed to remove the burster well from the munition
and crimp it. Crimping the burster well deforms it so that it no longer seats completely in
the munition when replaced. The resulting gap between the burster well and the agent
cavity allows a more thorough thermal combustion of the agent heel in the MPF. The
burster well is removed from the munition by the burster well gripper assembly. The
burster well crimp jaw closes around the burster and deforms it. A strip cylinder is used to
remove the burster well from the gripper assembly, where it may become stuck during
compression. Station 6 is bypassed for the mustard l55mm projectiles since the burster
well is not removed. Station 6 is also blpassed during mortar processing because the
mortar burster wells are discarded at Station 5.
The munition is rotated to Station I after it is drained and the crimped burster well is
placed back into the munition (except for mortar processing during which where the
burster wells are discarded at Station 5 or for mustard 155 mm projectiles which are not
drained). A burster well detector sensor located at Station 1 checks for the presence of a
burster well except during processing of the mustard projectiles. If a burster well is not
detected, the PPM places the munition on the reject table. If a burster well is detected, the
munition is removed by the PPM and placed back in the munitions tray. The PPM
straddles both conveyor lines so that, if needed, the MDMs could be fed from either line.
The MDMs are not currently designed to feed munitions from one munitions tray on Line
A, for example, and place it in a different munitions tray on Line B. The system is only
Attachrnent - 14 - Page 33
14.5.2.3
14.5.2.3.1
14.5.2.4
t4.s.2.4.1
14.5.2.5
14.5.2.5.1
14.5.2.5.2
t4.5.2.6
t4.s .2.6.t
14.5.2.6.1.1
DemilitarizationMiscellaneourr.""*Jr0r:,1r,:
designed to pick and place munitions from the same munitions tray on the ,.-" ";';;:r1:'line.
Setup Procedures
The MDMs are initialized before being placed in service. All major system components
are remotely activated from the CON, and the PLCs veri$ the proper operation of the
system. These systems include instrument air, plant air, hydraulics, ACS, and conveyors.
The indicators in the CON are observed to veriff the status of the MDMs and auxiliary
systems. The MDM system initialization icon is selected and, after the flashing green icon
turns steady groffi, the MDMs are ready to receive a start comnund from the CON.
System Startup
The startup of the MDMs consists of preparing the MPB conveyors, preparing the MDMs,
and preparing the pick and place loader. The MDM/PPM startup procedures are described
in the standard operating procedures document. In summary, the CON operators start the
system by placing the equipment in automatic mode (which is done remotely from the
CON) and issuing a start command to the Line A and Line B conveyors and
MDMsIPPMs. An initialization comrnand is issued before the machines are ready to
receive munitions.
Feed
As discussed earlier, each munition is fed one at a time to the MDMs by the pick and
place loader. The munitions arrive on a munitions tray with the head (top) of the munition
pointing up toward the ceiling. The trays are referred to as "egg crates" because of the
way the munitions are arranged in rows and columns on the tray. The munitions tray does
not have to be completely filled for MDM operations.
The munitions tray is automatically adjusted by the conveyors into a pre-established
position under the pick and place loader. The munitions tray is indexed forward (or
backward) so that each row and column of munitions is accessible by the pick and place
loader. This is done automatically, but the CON operators can also input a rodcolumn
designation so that the tray will be moved to a corresponding location on the conveyor.
The CON operators record each munition that is loaded, unloaded, or rejected. In
addition, the PDARS maintains a similar count for each munitions tray.
lnterlock Processes
Conveyor Systems
The MDM conveyors are interlocked with the MDMs. That is, when the MDMs are
processing munitions, the corresponding MDM conveyors will not automatically move the
munitions tray to the next (or previous) conveyor. In addition, the individual conveyors
are interlocked so that if two munitions trays are on the same line, the conveyors cannot be
activated so that two munitions trays are sent to the same conveyor section. Tables 14-5-1
md 14-5-2 indicate the sensors on the MDMs and the conveyors.
Attachrnent -14 - Page34
14.5.2.6.1 .2
14.5.2.6.2
14.5.2.6.2.1
14.5.2.6.3
14.5 .2.6.3. I
14.5.2.6.4
14.5.2.6.4.1
14.5.2.6.5
14.5 .2.6.5. 1
14.5.2.6.5.2
14.5.2.6.5.3
14.5.2.6.5.4
14.5.2.6.6
DernilitarizationMiscellaneorrr.""*J:;lr,:
June 2009
The MPB Feed Conveyors are interlocked with the MPB gates so that when a munitions
tray is entering the MPB, the gates cannot close. The sensors that interlock the gates are
photoreflective se,nsors ZS-374 (Line A) andZS-474 (Line B).
Station 1: Load Station
The PPM delivers munitions one at a time to and from the Load/Unload Station. This
station has two sensors. Sensor X-101C (where X is a value of 1,2, or 3 and refers to the
specific MDM) checks for the presence of a munition at the Station, and sensor X-l01D
checks for the presence of a burster well before the pick and place loader lowers for
pickup to discharge a drained projectile body. The MDM and PPM are interlocked so the
MDM does not operate independently from the pick and place loader during loading or
unloading operations.
Station2: Spare Station 1
This station is a spare and does not have any sensors or interlocks. No demilitaization
operations are conducted at this station.
Station 3: Spare Station2
This station is a spare and does not have any sensors or interlocks. No demili taization
operations are conducted at this station.
Station 4: Bore Station at MDM-101 (or Burster Well Punch Station at MDM-102 and
MpM-103)
The MDM-101 Bore Station is normally blpassed unless the munitions lot is determined
to have burster wells that are seal-welded. However, if the lot does include seal-welded
burster wells, the Bore Station is enabled and is the first stop for the munition at the
MDM. Station 4 of MDM-I01 is available for use if required during the processing of
mortars.
The Bore Station has several sensors. S"rro., 4OZA/Bsense if the projectile ctamp is
extended or retracted, and sensor 404C indicates whether the munition is clamped. These
sensors interlock the MDM Indexing Table and bore head. The bore will not start until
the munition is clamped. In addition, sensors 403N8, which sense the position of the
bore head, also are interlocked with the MDM. The original Bore Stations at MDM-102
and MDM-103 have been removed and replaced with the Burster Well Punch Station.
As an alternative, this position can also be configured as a Nose Closure Removal/Burster
Detection Station which may be used to process projectiles received at the TOCDF
without bursters. At this station, the nose plugs will be removed and the absence of a
burster will be confirmed. Sensors 404N8 confirm the absence of a burster and activate
an alarm ifa burster is detected.
At Station 4 of MDM-I02 and MDM-103, a Burster Well Punch Station "punches" or
collapses mustard 155mm projectile burster well downward into the projectile body.
Sensor 504A2 confirms the punch cylinder is fully extended into the projectile body.
Station 5: Pull and Drain Station
Attachrnent -14 - Page 35
o
14.5.2.6.6.1
14.5.2.6.6.2
14.5.2.6.6.3
14.5.2.6.6.4
14.5.2.6.6.5
| 4.s .2 .6 .7
14.5.2.6.7 .l
t4.5.2.6.7.2
14.5.2.6.7 .3
14.5.2.6.8
t4.s.2.6.8.1
Derni I itarization M iscell aneour r.".*J:r:i,:
June 2009
The Pull and Drain Station is a two-step process. Step one is the removal of the burster
well from the munition. Sensor X-504C on the Pull and Drain Station indicates whether
the burster is removed from the munition.
Step two is the draining of agent. Sensors X-510A/B indicates whether the drain tube has
been extended into the munition, and sensors X-506A/B indicate if the drip pan and
burster well chute are in the correct place. Additional sensors indicate whether the various
hydraulic cylinders are extended or retracted.
The Station 5 sensors are important because they interlock the MDM Index Table so that it
does not rotate during operations. In fact, each Station must have completed its operation
before the MDM Index Table will rotate the munitions to the next station.
Mustard 155mm projectiles blpass Station 5 entirely since the burster well is not removed
and the agent is not drained.
. During mortar processing, the burster wells are not reinserted but dropped onto the
reject chute where they fall to a small conveyor which transports them to a container
where they are accumulated until the container holds approximately the same number of
burster wells as there are drained mortars on a MPF Feed tray. When full the container is
lifted onto the tray of drained mortars and fed with it to the MPF. Alternatively, if the
equipment used to transfer the burster to the feed container then onto the feed tray is
unavailable, then up to 96 burster wells may be collected and fed separately to the MPF.
Station 6: Crimp Station
The Crimp Station has two operations that depend on whether the burster well is removed
and discarded at Station 5. A collet cylinder gnpper (an expandable collet) enters the
munition, and pressure sensor X-603C indicates the presence or absence of the burster
well. An alarm will be sent to the CON if a burster well is present when it should have
been discarded or if the burster well is absent when it should be present. If either
condition exists, the munition is rejected and the pick and place loader will place the
munition in the corresponding reject table, which can hold four 155 mm munitions or six
4.2 inch mortars. For each MDM, there is one reject table (see Section 14.5.3.4 for more
on waste throughput).
The remaining sensors at Station 6 indicate the position status of the various hydraulic
cylinders. Station 6 sensors are important because they interlock the MDM Index Table
so that it does not rotate during operation. When operations are completed at Station 6
and all other stations on the MDM have finished, the munition in Station 6 is rotated to
Station 1.
Mustard 155mm projectiles blpass Station 6 entirely since the burster well is not removed
and reinserted. Mortars blpass Station 6 since the burster wells are discarded at Station 5.
Station 1: Unload Station
Sensor X-101D checks for the presence of a burster well before the pick and place loader
lowers for pickup except for the mustard 155mm projectiles.
Attachment - 14 - Page 36
14.5.2.7
14.5.2.7 .l
14.5.2.'7 .2
14.5.2.7 .3
14.5.2.8
14.5.2.8.1
14.5.2.9
14.5.2.9.1
14.s.2.t0
14.5.2.t0.1
14.5.3
14.5.3.1
Dem i I i tari zati on M i scell aneou. r.""- J:t5rl,,:
June 2009
System Shutdown (Automatic. Normal)
Shutdown of the MDMs consists of stopping and "parking" the PPM loader, MDMs, and
MPB conveyors. The pick and place loader is issued a command that places the carriage
in its "home" position and lowers the loader (end effector) to its fail safe position. The
MDMs are shut down only after the Index Tables are verified to be clear of munitions.
The MDM conveyors are shut down one line at a time (if both were being used for
operations). Both lines must be clear of munitions trays before stopping the conveyor
systems. The conveyors are issued a "stop" command, and the Line A and/or Line B icon
tums to magenta to indicate that the MDM conveyors are no longer started. After these
commands are completed, the MDM, PPM, and conveyors are "parked" and system
components are in their home positions.
Mustard 155mm projectiles bypass Station 6 entirely since the burster well is not removed
and reinserted.
Emergency Shutdown
In the event of an abnormal or upset condition associated with the MDMs, PPMs, or
MDM conveyors, the processing operations are modified in order to mitigate the
condition. Abnormal or upset conditions are any conditions that cause an emergency
termination in processing, nonconfornance to a specified procedure, a safety hazard,
equipment damage, or injury to personnel. These conditions are identified by plant
personnel or indicated by the process sensors (which send signals to the CON through the
PLCs). After conditions are identified, the CON issues an emergency stop command to
the MDM. When this command is issued, the MDM components are stopped.
Extended Shutdown
Extended shutdown procedures are in addition to normal shutdown procedures. Extended
shutdown involves installing a spectacle blind in the agent line going to the Toxic Cubicle.
This prevents backflushing and leakage ofagent from the agent holding tanks.
Maintenance
Maintenance of the MDMs and PPMs includes preventive maintenance procedures and
corrective maintenance procedures. Preventive maintenance procedures generally involve
inspections, cleaning (as required), and lubricating (as required) of the MDMs and PPMs.
Monitoring Procedures
Each MDM is equipped with sensors to detect the presence, position, and configuration of
each munition during operations. The sensors, which are connected through PLCs, ensure
that the munitions are processed safely by relaying information to the CON. The locations
and functions of these sensors are described in Tables 14-5-l and 14-5-2.
The CON monitors the operations of the MDMs and PPMs through the demilitarization
operator consoles and CCTV. The demilitaization operator consoles can display
information from the PLCs and sensors. The PDARS acquires operational data for
14.5.3.2
Attachrnent - 14 - Page 37
o
14.5.3.3
r4.5.3.4
14.5.3.4.1
r4.5.3.4
14.5.3.4.7
14.5.3.4.2
14.5 .4
14.5.4,1
14.5.5
14.5.5. 1
14.5.5. 1 . I
Dernilitarization Miscellaneou. r*"rrJ:fil
June 2009
analysis and historical record keeping. Information obtained by the PDARS can be used
to meet environrnental monitoring and reporting requirements. In addition, the CON
operators and outside operators are required to log the events that occur during their shift
into their respective logbooks.
The MPB is a Category A room, and it is expected that this area will be contaminated by
agent (liquid or vapor) as part of normal operations. ACAMSs are used to detect the
presence of agent vapors in the MPB.
Waste Identification
As mentioned previously, waste munitions are identified prior to entering the MDMs. The
quantrty of munitions processed by the MDMs is recorded by the PDARS and confirmed
visually by CON operators.
Waste Throughput
The waste entering the MDMs is an agent-filled munition. During treatment by the
MDMs, the agent is separated from the munition and handled through the ACS. The
metal casing is then retumed to the munitions tray for thermal treatment in the MPF. In
each case, quantification of waste occrus; the metal casing is quantified through the
PDARS record and by the manual record created by the CON operator who observes the
MDM operations.
As mentioned previously, some munitions may be rejected by the MDMs. The MDM
sensors are designed to detect "reject" munitions and notify the CON operators. These
munitions are sent to the associated reject table which stands next to the MDM Index
Table. These munitions are retrieved manually by plant personnel dressed in appropriate
PPE. In every case, the quantity of munitions are recorded by the PDARS and the CON
operators maintain a record in their logbooks.
Inspection
See Section 14.3.4.
Closure
Partial Closure
At the conclusion of each agent campaign or the beginning of a new munition campaign,
the MDMs will be thoroughly decontaminated, as necessary; all decontamination films
shall be removed using an appropriate rinse; all clouded observation windows that
compromise the ability to view operations shall be cleaned or replaced; and maintenance
and repair will be performed, as necessary, on the machines and other room components.
The TOCDF will submit in writing to the Executive Secretary, a request for partial closure
of the room, since either the agent or the munition type is being changed. Upon approval
for partial closure by the Executive Secretary the next campaign will commence, when
authorized, and when it is appropriate to do so.
Final ClosureI4.5.5.2
Attachment - 14 - Page 38
14.5.5.2.1
14.5.6
14.5.6.1
14.5.6.2
14.5.6.3
14.5.J
14.5.7 .l
14.5 .7 .2
14.5.7 .2.7
14.5.7 .2.2
14.5.7 .3
t4.s.7 .3.1
t4.5.7 .3.2
Demilitarization Miscellaneorr r.""t-J:t!3l
June 2009
Final closure is addressed in Attachment 10 (Closure Plan).
Mitigative Design and Operating Standards
The MDMs are designed for demilitarizationpurposes and do not contain inherent
components to mitigate the potential for waste migration to the environment. However,
the MPB was designed for this purpose. The MPB will be operated in a manner to reduce
the risk of waste constituent migration to the environment, as explained below.
The floor of the MPB is impervious and sloped to drain any spills to sumps located in the
floor. Protective clothing is mandatory during cleanup of spilled agent in the room, and
care is taken to reduce the potential for spills.
The MPB will not contain explosively configured mtrnitions. Therefore, the room is not
designed for, nor expected to incur, an explosion during munitions demilitarization.
However, if an accident occurs, air from the MPB would be captured by the MDB
ventilation filter system and would not escape to the atmosphere.
Environmental Performance Standards for Miscellaneous Units
The MDMs have been designed, installed, and are operated in a manner to preclude the
release of hazardous chemical constituents that may have adverse effects on human health
or the environment. The following sections describe the potential for waste constituent
releases to the environment (air, soil, and water), the potential impact of such releases, and
the location feattres of the TOCDF that will mitigate these releases.
Miscellaneoris Unit Wastes
The volume and the physical and chemical characteristics of the wastes to be treated at the
MDMs are associated with projectiles and mortar cartridges. These wastes have been
fully identified, and information about their physical and chemical characteristics may be
found in Attachment 2 (Waste Analysis PlaQ.
The maximum volume of agent being processed at the MDMs is equivalent to the number
of munitions at each MDM station where agent has not been removed. This is equivalent
to five munitions at each MDM time's three machines for a total of 15 munitions. This
assumes each MDM is being utilized. The largest quantity of agent is associated with the
M104 or Ml10 155mm projectiles (agent H), which were filled with 11.7 pounds of
mustard. Thus, lhe total quantity of agent being processed on all three MDMs is 1 75.5
pounds. The MDMs do not generate additional hazardous waste except for waste
decontamination solution.
Containment System
See Section 14.3.7.3.
As mentioned previously, the maximum number of munitions (containing agent) in the
MPB at any time during MDM operations is associated with five munitions trays.
However, under normal operations, less than five trays may be present in the MPB. This
is because only three trays can be actively used for pick and place operations while any
other tray would be idle on one of the BDS indexing conveyors. For analysis purposes, it
Attachrnent - 14 - Page 39
14.5.7 .3.2.7
r4.5.7 .3.2.2
14.5.7 .3.3
14.5.7 .3.4
14.5.7 .4
14.5.7 .4.1
14.5 .7 .5
14.5.7 .5.1
14.5.7 .6
14.5.7 .6.1
14.5.7 .7
14.5.7 .7 .l
14.5.7 .8
14.5 .7 .8.r
14.5.7 .9
14.s.7 .9.1
DemilitarizationMiscellaneorrr."urrJ,Or!,lrrl
June 2009
will be assumed that five munitions trays will be present and that each tray is completely
filled with agent-filled munitions. This is equivalent to one of the following:
240 lllmmprojectiles (48 per tray)
480 mortar-cartridges (96 per tray).
Assuming, for example, each munition is completely filled, the maximum inventory of
agent in the MPB during MDM operations is 264 gallons (this corresponds to 240
munitionstimesamaximum of ll.7 poundsofHpermunition). Intheeventalltheagent
spills onto the floor of the MPB, the sumps will be able to hold all the spilled liquid.
In addition to the sumps, the MPB contains curbed walls so that liquid spills and
decontamination solution will not leak under doors and gates. The floors and walls are
painted with epoxy chemical-agent resistant paints to aid in decontamination.
Site Air Conditions
See Section 14.3.7 .4.
ry
See paragraphl4.3 .7 .5 .
Meteorologic and Atmospheric Conditions
See paragraph 14.3.7 .6.
Air Ouality
See Section 14.3.7 .7 .
Prevention of Air Emissions
See Section 14.3.7.8.
Operating Standards
The MPB is a Category A area and is under engineering controls at all times, as previously
discussed. Liquid wastes are captured and controlled in the containment slstem, air
emissions are controlled by the HVAC system and cleaned through filters, and the MDM
operations are continuously monitored by the CON and PDARS. As a result, there is
virtually no opportunity for the waste constituents to be released in such a way as to have
adverse effects on human health or the environment due to migration into the outdoor
environment. The liquids are placed in tanks or, if spilled, are contained in sumps and
from there placed in tanks. Volatilized agent is captured by the HVAC system, primarily
in carbon beds. The MDMs themselves are operated in a systematic and safe marurer
whether in automatic or manual mode, thereby reducing the potential for agent to be
released and migrate into the air.
Site Hydrologic Conditions14.5 .7 .r0
Attachment - 14 - Page 40
14.5.7 .10.1
14.5.7 .ll
14.5.7 .lr.l
14.6
t4.7
14.7.1
14.7.1.1.
t4.7 .t.2.
14.7 .1 .2.L.
14.7.1 .3
t4.7.1.3.1.
14.7 .l .4.
14.7 .1 .4.1 .
14.7.1 .5
14.J. 1 .5.1 .
TOCDF
Dernilitarization Miscellaneous Treatment Units
June 2009
A summary of site hydrologic conditions is given in Attachment 1 (Facility Description).
Migration of Waste Constituents
See Section 14.3.7.11.
Reserved
AIR OPERATED REMOTE ORDNAI\CE ACCESS SYSTEM (CUTTER
MACHINE)
Physical Characteristics
The cutter machine is designed to remotely cut into cylindrical items. It may be used for
nose closure removal, fuze removal, venting, and access to material or interior
components. The machine is primarily made of aluminum and is a commercially available
radial pipe cutting machine that has been modified for use in toxic areas. The major
components of the system are a stabilizing base, split frame Wachs@ cutter, cutter base and
stabilizing legs, air motor and speed controller, vent hose, air lubrication mister, mister
tube and stand, pyrometer and stand, and an air isolation valve. The split frame major
components are: a tool slide, cutter blade, trip assembly, and star wheel. The split frame
portion of the cutter is a pre-fabricated stand which has four bolts on the cutter frame.
These bolts determine the level of the cut on the item by adjusting the height of the item
and positioning it for the cutter.
Equipment Installation
The equipment that constitutes the cutter machine is not a permanently installed item. The
cutter machine is intended to be used for the duration of the specialized campaign and
then managed in accordance with paragraph 14.7.4, Closure. A cutter machine may be set
up in the ECR for explosive or non-explosive configured items or in the MPB for non-
explosive configured items only. In the event of an equipment failure beyond repair, a
new cutter machine will be set up as a replacement-in-kind.
Dimensions and Location
The approximate size of the cutter machine is 14 inches in diameter, and24 inches in
height. Machine components are aluminum and steel. Some of the machine components
are nickel plated. Dead weight of the cutter machine and split frame cutter is estimated at
60lbs.
Conveyors
The are no conveyors associated with the Cutter Machine. Items to be processed by the
cutter machine are manually placed upon the pre-fabricated stand to position the item.
Gates
Items that are configured with energetics or non-energetics may be transferred either
automatically or by rernote manual control from the ECV into the ECRs through one of
two ECR blast gates. These gates open to receive an item and will not close until the item
Attachrnent - 14 - Page 4l
14.7.1.6.
14.7.1.6.1.
14.7 .l .7 .
14.7 .1 .7 .t.
14.7.1.8.
14.7.1.8.1.
14.7.1 .9.
14.7.1.9.1.
14.7.1 . 1 0.
14.7.1.10.1.
t4.7.1.11.
t4.7.1 .1 1 .1 .
14.7 .1 .12.
14.1 .1 .12.1
14.7.1.13.
t4.7.1.13.1.
Demilitarization Miscellaneour r.""*"]:f,|,,:
June 2009
is transferred completely into the ECR. For non-energetic items to be processed in the
MPB, trays are transferred automatically from the Munitions Corridor into the MPB
through one of two MPB gates. The gates are opened to receive items and they will not
close until the items are transferred completely into the MPB.
Pumps and Transfer Lines
There are no pumps or transfer lines directly associated with the cutter machine.
Sump Pump
Both the ECRs and the MPB are equipped with containment sumps. Sump pump
operation is controlled by a local-off-remote switch. When a sump level alarm is sent to
the CON, the liquids collected in the sump are pumped to a spent decontamination
holding tank.
Tanks and Containers
There are no tanks or containers directly associated with the cutter machine. Agent from
the items processed by the cutter machine is either pumped to the ACS or SDS (after
initial decontamination at the point of removal) or may be placed in the sumps for further
processing.
Feed System
Items to be processed using the cutter machine will be manually placed on the cutter by
person:rel clad in the appropriate level ofPPE based upon the hazards ofthe operation.
All items will be manually processed in accordance with site approved operating
procedures.
Instrumentation
There is no permanent PLC interface with the controls and instruments for the cutter
machine. Any PLC interfaces that are added will be installed via the Temporary Change
Process with all site required signatures and appropriate site reviews. The cutter machine
operation is controlled remotely from the CON with careful monitoring via closed-circuit
television.
Electrical System
See Section 14.3.1.12.
Heating. Ventilation. and Air Conditioning System (HVAC)
See Section 14.3.i.13.
Fire Protection System
The ECR High-Speed Deluge Systems are located in the ECRs and installed above the
miscellaneous parts conveyors of the PMDs. Each system consists of three W flame
detectors, three Rapid-Response deluge valves, and a manual pull station located in each
Attachrnent - 14 - Page 42
14.7 .l .L4.
14.7.1 .1 4.1 .
14.J.2.
t4.7 .2.1 .
14.7.2.2.
r4.7 .2.2.1 .
r4.7 .2.3.
14.7 .2.3.1 .
14.7.2.4.
t4.7 .2.4.t.
DemilitarizationMiscellaneourr.""*rT.or!rlnl
June 2009
ECR. When a flame is detected on the miscellaneous parts conveyor, the UV sensor sends
a signal to the Rapid-Response deluge control panel, which in turn actuates the High-
Speed Deluge Solenoid Valve and sends an alarm to the control panel. The detection of a
flam will operate the High-Speed Solenoid in approximately 49 miliseconds. The system
is activated and ready to respond during projectile campaigns that result in explosive
debris on the miscellaneous parts conveyors (i.e. 105mm M604d360 projectile campaign
when fuze booster-cups were punched above the miscellaneous parts conveyor).
Alarm and Communications Systems
See Section 14.3.1.15.
Operations and Maintenance
The cutter machine will be utilized inside the Explosives Containment Rooms or in the
Munitions Processing Bay to gain access to munitions or cylindrical items that require
special handling. It may be used for nose closure removal, fuze removal, venting, and/or
access to interior components. The cutter machine will be used in accordance with site
approved operating procedures.
General System Operation
The cutter machine will be located in either ECR A, ECR B, or in the Munitions
Processing Bay. The cutter is comprised of two components, the cutter and the split frame
which correctly positions the item for the cutter. The cutter machine is a commercially
available radial type pipe cutter designed to cut cylindrical items. The cutter is comprised
primarily of aluminum components. It has been modified with an air isolation valve and
mister tube. After the munition or cylindrical item is placed on the stabilizing base and
appropriately prepared for cutting operations, the Control Room remotely activates
supplied air to the cutter. The spray mister will begin to function and the cutting speed
may be adjusted by the entrants. The mister nozzle tip will spray on the cut path in order
to ensure that cutting temperatures remain near ambient. The cut is lubricated by an air
mist of water based lubricant. The control room then monitors the cutter operation
through the use of CCTV and process indicators in the Control Room. In the case of
explosive configured items, while the cutting operations are in progress, entrants will exit
the ECR.
SyStem Startup
The procedure for the cutter machine start-up is contained in the appropriate Unusual
Munition Handling SOP and related documents. In summary, the machine will be set-up
by site personnel who will veri$ that the equipment is configured properly prior to use.
Feed
The munitions or cylindrical items will be placed upon the cutter machine one at a time for
handling. Careful coordination of the operation will occur between the entrants and the
Control Room persormel in accordance with site approved standard operating procedures.
Interlocksl4.J .2.5.
Attachment - 14 - Page 43
Demi I i tari zati on M i scel I aneour r.""* Jtorti,,:
June 2009
14.7.2.5.1. Emergency shutoff of the cutter machine is via an air isolation valve. All emefgency
shutoff valves will be referenced in the appropriate SOPs of the operation.
t4.7.2.6. SystemShutdown(Normal)
14.7 .2.6.1. The cutter machine operation is controlled remotely from the CON. To stop the cutter
machine, the air solenoid is closed from the Control Room.
14.7.2.7. EmergencyShutdown
14.7 .2.7.1. The Emergency Shutdown process is controlled remotely from the CON. The air solenoid
will be shutdown from the CON, causing the cutter machine to stop. All activities are
closely monitored by the CON via the CCTV.
14.7.2.8. Maintenance
14.7.2.8.1. The cutter machine is set up for a short-duration use to handle unusually configured
munitions or cylindrical items. Since the duration of its operation is very short, no
maintenance plan is required.
14.7.2.9. MonitoringProcedures
14.7 .2.9 .l . The CON operators monitor the operations of the cutter machine through the use of the
CCTVs. Ir addition, CON operators are required to log the events that occur during their
shift into logbooks and the appropriate munitions waste tracking forms.
14.7.2.10. Waste Identification
14.7.2.10.1 By the time a munition or cylindrical item reaches the cutter machine, it will have been
fully identified in accordance with Attachment 2 (Waste Analysis Plan).
14.7.2.11. WasteThroughput
14.7 .2.ll.l The cutter machine is, by design, used to gain access to the interior portions of a munition
or a cylindrical item, to facilitate the appropriate treatment of the waste by allowing
munitions or other items to be managed through the other approved treatment processed
for agent, overpack material, or metal munition bodies or cylinders. Munitions are
manually placed in the cutter by site personnel dressed in the appropriate level of PPE.
Any liquid agent that is present during the cutting process is decontaminated with
decontamination solution. The spent decontamination solution is collected in the sump
and pumped to the SDS tank for eventual thermal treatment in the LIC. Any liquid
collected in the sumps is emptied at least daily.
14.7.3. Inspection
14.7 .3.1. The cutter machine will be inspected prior to first use after it has been assembled. Since
the duration of the cutter machine operation is expected to be short, no permanent
inspection plan is in place. The cutter machine is intended to be set-up, used for a short
duration that is campaign specific, and dismantled when no longer needed.
14.7.4. Closure
Attachrnent -14 - Page44
14.7 .4.1 .
14.7 .4.1 .l .
14.7.4.2.
14.7 .4.2.1 .
14.7 .,5.
14.7.5.1.
14.7 .5.2.
r4.7.5.3.
t4.7.5.3. 1 .
14.7 .5.4.
14.7 .5.4.1 .
14.7.5.5
t4.7.5.5. I .
Demi lit anzation M i scel laneous TreatmJ:;#I
June 2009
Partial Closure
At the conclusion of the agent campaign, the cutter machine will be thoroughly
decontaminated. The equipment maybe re-used or scrapped and managed as waste. The
TOCDF will submit in writing to the Executive Secretary, a request for partial closure of
the cutter.
Final Closure
Final closure of this site is addressed in Attachment 10 (Closure Plan).
Mitigative Design and Operating Standards
For the Mitigative Design and Operating Standards for the ECRs, refer to paragraphs
14.4.6.1. through 14.4.6.6. For the Mitigative Design and Operating Standards in the
MPB, refer to paragraphs 14.3.6.2. and 14.3.6.3
The cutter machine will be operated in a manner to preclude the release of hazardous
chemical constituents that may have an adverse effect on human health and the
environment. The following section describes the potential for waste constituent releases
to the environment (air, soil, and water), the potential impacts of such releases, and the
location features of the TOCDF that will mitigate these releases.
Environmental Performance Standards for Miscellaneous Units
The cutter machine can be installed in either of the ECRs, or in the Munitions Processing
Bay for non-explosive configured items. The ECRs and the Munitions Processing Bay
have been designed, installed, and operated in a manner to preclude the release of
hazardous chemical constituents that may have adverse effects on human health and the
environment. Section 14.2.7.2 describes the potential for waste constituent's releases to
the environment (air, soil, and water), the potential impact of such releases, and the
location features of the TOCDF that will mitigate these releases.
Miscellaneous Unit Wastes
The volume and the physical and chemical characteristics of the wastes to be treated at the
cutter machine include munitions or other cylindrical items. These wastes will be fully
identified and information about their physical and chemical characteristics may be found
in Attachment 2 (Waste Analysis Plan) or characteized in accordance with Attachment 2
(Waste Analysis Plan). The maximum volume of these wastes that can be processed in the
cutter machine at one time is equivalent to the number of munitions that can be processed
by the cutter, which is one. All metal components will be incinerated in the DFS or MPF.
Energetic components may be fed to the DFS unsheared in accordance with site approved
operating procedures. Al1 drained chemical agent will be pumped to the ACS or the SDS
(after initial decontamination at the point of removal) for incineration in the LICs.
Containment System
See Section 14.3.7.3.
Attachment - 14 - Page 45
14.J.5.6.
14.7.5.6.1 .
14.J .5.7 .
14.7 .5 .7 .l .
14.7.5.8.
14.7.5.8.1.
14.7.5.9.
14.7.5.9.1.
14.7 .5. 10.
14.7.5.10.1 .
14.7.5. 1 1 .
14.J.5.11.1.
14.7 .5.12.
14.7.5.1 2.1 .
14.7.5. 1 3.
I4.7.5.31.1.
14.8
14.8. 1
14.8.1.1.
14.8.1.1.1
TOCDF
Demi I it atnzation M i s cel I aneou s Treatmen t Un its
June 2009
Site Air Conditions
See Sectio n 14.3 .l .4.
Topography
See Section 14.3 .7 .5 .
Meteorological and Atmospheric Conditions
See Section 14.3 .7 .6.
Air Ouality
See Section 14.3.7 .7 .
Prevention of Air Emissions
The cutter machine itself is not a source of air emission in and of itself, but it is associated
with treatment operations that could potentially emit air pollutants. See Section
14.3.7 .8.1. through 14.3.7 .8.5.
Operating Standards
The cutter machine is a commercially available radial pipe cutter. It will be operated in
accordance with manufacturer's guidelines and site approved operating procedures.
Site Hydrologic Conditions
A summary of site hydrologic conditions is given in Attachment 1 (Facility Description).
Migration of Waste Constituents
Migration of wastes into the environment from the cutter machine is not expected to
occur. The cutter machine will be operated in the MDB, which is designed to prevent the
migration of waste to the environment. Therefore, no impacts on human health and the
environment from the cutter machine are expected.
DVS-Drum Ventilation Svstem Enclosures and Sorting Room (Igloo 1632)
Physical Characteristics
The major components are the two drum ventilation enclosures (DVS), the sorting room
(DVSSR) and the Igloo Carbon Adsorption Filtration System.
Each DVS Enclosure is designed to completely enclose a maximum of six (6) 55-gallon
drums of secondary waste for the purpose. The enclosures are closed-vented to an
induced-air carbon adsorption filtration system designed for effective removal of
particulates and chemical agents. The enclosures are made primarily of carbon steel and
each possesses a total of six observation windows and glove-port pairs to enable
manipulation of the drums while they are enclosed. An additional glove-port pair is
Attachrnent - 14 - Page 46
14.8 .l.l .2
14.8. 1 .1 .3
14.8 .1.2.
14.9 .1.2.1.
14.8. 1 .3
14.8.1.3.1.
14.8 .t .3.2
DemilitarizationMiscellaneou.r.""*"]:fi,,:
June 2009
provided near the enclosure sump low-point. Each enclosure is equipped with non-
powered conveyor rollers and a shuttle tray that enables the drums to be rolled into and out
of it. The bottom plenum of each enclosure is designed to provide secondary containment
of liquid.
The DVSSR is designed to completely enclose two (2) personnel and four (4) 55-gallon
drums of secondary waste for the purpose of opening up the drums to gain access to their
contents, monitor the headspace for agent contamination, sort and characterizethe
contents, and treat agent-contaminated contents by decontamination. The DVSSR is
closed-vented to the shared (with the DVS enclosures) induced-air carbon adsorption
filtration system, which is designed for effective removal of particulates and chemical
agents. The DVSSR is made primarily of carbon steel and possesses two serial
intgrmediate personnel airlocks. All three compartments (i.e., the two airlocks and the
working compartment sorting room) are equipped with compressed air, water and
decontaminant drops. Each compartment possesses an observation window and an
elevated floor sloped to a sump. In addition to personnel doors, the working compartment
sorting room is equipped with non-powered conveyor rollers and a sliding access door that
enables the drums to be rolled into and out of it. The sorting room possesses an overhead
trolleythat simplifies the movement of waste drums.
The Igloo Carbon Adsorption Filtration System is designed to effectively remove and
capture agent from airspace within the Igloo and each DVS and DVSSR by 1) maintaining
a constant negative pressure within each DVS enclosure and DVSSR and the direct vent
duct leading to the induced-draft faq2) directing each DVS enclosure and DVSSR
headspace gas through an activated carbon adsorption bed, 3) providing activated carbon
capacity in excess of the combined total volume of agent present in the Igloos, and 4)
discharging the filtered air to the atmosphere. The activated carbon bed is monitored
continuously for breakthrough per Attachment 22 (Agent Monitoring Plan).
Equipment Installation
Prior to hazardous waste operations at each DVS and DVSSR, its design and installation
will have been verified through the Facility Construction Certification (FCC)
documentation required by Condition I.S. This Certification attests that each DVS and
DVSSR equipment has been constructed and installed in compliance with this Permit per
Condition I.S.1.
Dimensions and Location
Both DVS enclosures are permanently mounted to the floor of DCD Area 10 Igloo 1632.
The size of each enclosure is approximat ely 8' -7" tall, 9' -2" long, and 5 '-8" wide. The
non-powered feed conveyor and pass-through air lock extend the overall length of the
entire unit to approximately 19'-0".
The DVSSR is a fabricated enclosure with three separate compartments (i.e., two serial
intermediate personnel airlocks and the main working compartment.) The DVSSR resides
at the east end of Igloo 1632. The overall size of the DVSSR is approximately 19' long
and 14' wide. The non-powered feed conveyor extends an additional four feet.
Convevors14.8 .1 .4.
Attachment - 14 - Page 47
DemilitarizationMiscellaneourr.""OrJ:;3r,:
June 2009
14.8.1.4.1. TherearenopoweredconveyorsassociatedwiththeDVSandDVSSR. Secondarywaste
drums to be process within the DVS and DVSSR are placed upon a shuttle tray that rests
on feed conveyor rollers spaced approximately 12". Once the main sliding access door is
opened, the shuttle tray and drums are rolled directly into the unit.
14.8.1.5 Gates
14.8.1.5.1. EachDVSenclosurehasanaccessdoor/gateoneachend. Ononeendisapass-through
airlock for passage of various tools and materials. The pass-through airlock has door pairs
(e.g., two inboard and two outboard) that measure approximately 20" x 20" square. On
the opposite end is the full-width sliding main feed door that enables the feed and removal
of the secondary waste drums. The main door is approximately 5' wide artd 4' high. All
doors are manually-operated. The latches of the main feed door are electronically
supervised to provide assurance ofdoor closure.
14.8.1.5.2 In addition to the personnel doors, the DVSSR has a sliding door/gate that provides access
directly into the working compartment (e.g., the sorting room). The sliding door is
approximately 5' wide and4' high. A1l doors and gates are manually-operated. The
latches ofthe sliding door/gate are electronically supervised to provide assurance ofdoor
closure.
14.8.1.6. Pumps and Transfer Lines
14.8.1.6.1. The only pump/transfer lines associated with the DVS catch basin are the enclosure and
DVSSR sump pumps and transfer lines leading to the nearby accumulation tank.
14.8.1.7. Sump Pump
14.8.1.7.1. The DVS catch basin and DVSSR sumps serve to collect liquid inside the compartments.
Each enclosure sump and DVSSR sump has been equipped with a transfer pump for
conveying liquid to a nearby tank for accumulation. The sumps will be emptied wit}ttn24
hours in order to ensure the secondary containment capacity of the sumps remains
available.
14.8.1.8. Tanks and Containers
14.8.1.8.1. Spent decontamination solution is manually transferred to a nearby <90-day accumulation
tank.
14.8.1.9. Feed System
14.8.1.9.1. Secondary waste drums to be opened, stored, or treated in the DVS Enclosures and
DVSSR are placed upon the shuttle tray and manually rolled into the unit through the
open main feed door. Secondary waste is removed from the enclosure through the same
main feed door. Waste drums are moved into the DVSSR through the main door.
14.8.1.10. Instrumentation
14.8.1.10.1. With the exception of agent monitoring, all instrumentation is local only to the Igloo 1632
and the adjacent filtration system facility.
Attachrnent - l4 - Page 48
14.8.1.11.
14.8.1.11.1.
14.8 .1 .12.
14.9 .l .12.1
14.8.1.13.
14.9.1.13.1.
14.9 .l .14.
14.8.1.14.1 .
14.8 .2.1 .
14.9 .2.1 .l .
14.8 .2.2.
14.8 .2.2.1 .
14.8 .2,3 .
14.8 .2.3 .l
Derni litari zati on M i scel l aneour t ".* J,ofr|,,:
June 2009
Electrical System
The only electrical system pertaining Igloo 1632 (DVS/DVSSR) is associated with
instrumentation, monitoring, and lighting.
Heating. Ventilation. and Air Conditioning System (HVAC)
The DVS enclosures and DVSSR reside within DCD Area 10 Igloo 1632. General-area
heating, ventilation and air conditioning of Igloo 1632 are provided separate of the Igloo
Carbon Adsorption Filtration system.
Fire Protection System
Type ABC hand-held fire extinguishers are staged in Igloo 1632. See Attachment 9
(Contingency Plan.)
Alarm and Communications Systems
Igloo 1632 and the adjacent support building are equipped with a communication system
that is similar to that of the TOCDF site to include local area network phone service and
Public Announcement (PA) system, hand-held radios and cell phones. These systems are
available to alert employees of emergencies or to sunmon assistance.
Maintenance
The DVS enclosures and DVSSR possess moving parts such as door latches, door seals,
conveyor rollers, gloves, sump pumps, pressure gauges, etc. These moving parts will be
maintained via Maintenance Work Order as necessary when identified by visual
inspection. The Carbon Adsorption Filtration System frst and second carbon beds are
monitored continuously for breakthrough and/or leakage that would indicate end-of-life or
failure of the carbon beds. Carbon change out must begin within 15 days of break though.
Upon replacement of carbon, a post-installation leak test of the bed seals verifies proper
installation. lnduced-draft fan operations will be maintained as part of a preventive
maintenance schedule. Induced-draft fan degradation or failure is detected by adverse
flow rates and enclosure negative pressure, as monitored during the operation.
The DVS instrumentation have a local alarm if enclosure of the units are not operated
under negative pressure. Agent monitoring will be accomplished locally using ACAMS.
The ACAMS can also be monitored via the Control Point located adjacent to, and west of,
the Igloos.
Waste Identification
The DVSSR will be used to sort and treat secondary waste. Secondary waste will be
received at the Igloo 1632 from storage with predetermined waste stream identification.
No new previously-unspecified waste streams will result from operation of the DVS.
Liquid residue resulting from the decontamination of the waste in the enclosure is
managed as newly-generated hazardous waste.
Monitorins Procedures
Attachrnent -14 - Page 49
14.8 .2.3.2
14.8 .2.3.3
14.8.3.
14.9.3. 1 .
14.8.4.
14.8 .4.1.
14.8 .4.t .l .
14.8 .4.2.
14.8 .4.2.1 .
14.8.5
1 4.8.s. 1
14.8.5.1.1.
14.8 .5.2.
14.8 .s .2.t .
14.8.5.3.
1 4.8.s.3. 1 .
DernilitarizationMiscellaneourr.."*"],of,l,,l
June 2009
The application of decontamination solution in order to enable offsite shipment of the
TOCDF-originated sample waste only as described in the WAP (e.g., ensure agent
concentration of the residual spent decon is below 20 ppb GBA/X or 200ppb Mustard)
(i.e., waste streams CAL Aqueous Wastes, CAL Solid Wastes and MSB Solid Waste).
Waste streams that are allowed to be reclassified by headspace monitoring for agent
contamination (i.e., P999 to F999 or P9991F999) are specified Condition VIII.E.16.d.
Inspection
The DVS enclosures,DvssR and its Carbon Adsorption Filtration System will be
inspected as specified in Attachment 5.
Closure
Partial Closure
Partial closure does not apply to the DVS and DVSSR. Following the final closure of the
DVS and DVSSR, TOCDF will submit in writing to the Executive Secretary, a request for
partial closure of Igloo 1632. The TOCDF will submit in writing to the Executive
Secretary, a request for partial closure of Igloo 1632. After approval of partial closure,
Igloo 1632 will be tumed back over to DCD Area 10 for final closure.
Final Closure
Final closure of the DVS and DVSSR will be performed in compliance with R315-8-7 and
this permit. Final closure of Igloo 1632will be accomplished via the DCD Area 10
Closure Plan.
Mitigative Design and Operating Standards
Containment System
The DVS enclosures have been designed with secondary containment capacity to store in
excess of six (6) 55-gallon drums of liquid waste. The floor and sump of the DVSSR
working compartment (sorting room) has been designed with secondary containment
capacity to store in excess of four (4) 1lO-gallon drums. This enables the storage of any
combination of liquid-bearing and non-liquid bearing containers in the enclosures and
DVSSR.
Site Air Conditions
The following paragraphs describe the potential impacts of air emissions due to operation
of the DVS Enclosures, DVSSR and Igloo Carbon Adsorption Filtration System. A brief
description of topographic and meteorological characteristics of the Tooele area are
presented as well as a sunmary of potential impacts on existing air quality in the Tooele
region.
Topoeraphy
See Section 14.3.7.5.
Attachrnent - 14 - Page 50
14.8 .5.4.
14.8 .5.4.1 .
14.8.5.5.
14.8.5.5. 1 .
14.8 .5 .5.2
14.8.5.6.
14.8.5.6.1 .
14.8 .5.7 .
14.8 .s .7 .t .
14.8.5 .8.
14.8.5.8.1.
14.9
14.9.1
t4.9.1.1.
TOCDF
Demi li t anzation M i scel I an eou s Treatment Un i ts
June 2009
Meteorological and Atmospheric Conditions
See Section 14.3.7.6.
Air Ouality
See Section I4.3.7.7.
Any air emissions from the DVS Enclosures and DVSSR are captured and processed
through the Igloo Carbon Adsorption Filtration system before being exhausted to the
atmosphere.
Prevention of Air Emissions
The DVS Enclosures and DVSSR are served by a Level 3 40 CFR 264 Subpart CC air
pollutant emissions control device. All emissions are routed through the carbon
adsorption beds via an induced-draft fan. The carbon beds effectively remove air pollutant
compounds and are monitored continuously for agent break+hrough.
Operating Standards
The DVS Enclosures, DVSSR and the Carbon Adsorption Filtration System will be
operated in accordance with engineer's and manufacturer's specifications. Negative
pressure, door closure and operation of the filtration system will be verified during
treatment operations in the enclosures and DVSSR.
Site Hydroloeic Conditions
A summary of site hydrologic conditions is given in Attachment 1 (Facility Description).
AUTOCLAVE
Physical Characteristics
The Autoclave is designed to destroy the chemical agent contamination occurring on
Secondary Waste articles through hydrolysis of the chemical agents. The Autoclave is of
direct steam design (i.e., the steam contacts the articles), and is a horizontal cylinder 20
feet in length and six feet in diameter. The sealing door is equipped with an O-ring. The
entire Autoclave installation includes the Autoclave, a 5.2 million BTU/hr boiler, a boiler
water conditioning system, a steam operated eductor used to evacuate the Autoclave, a
chilled water condenser and a refrigerant based condenser used to condense and dry the air
and water mixtures evacuated from the Autoclave prior to the dried and cooled gases
being directed to the forced-air carbon adsorption filtration system. The installation also
includes valves, process instrumentation; waste bins in which waste drums are placed for
Autoclave treatment, and a Programmable Logic Controller (PLC). Note disposable
thermocouples are used to monitor the temperature of the wastes being treated. Two
1,0O0-gallon condensate storage tanks and a 175-gallon transfer tank with associated
pump and transfer lines are also included in the installation. The condensate tanks will be
operated as less than 90-day accumulation tanks.
Attachrnent - 14 - Page 5l
l4.g.l .2.
14.9.1 .2.r.
r4.9.1 .3
14.9.1.3.1.
l4.g.r.4.
r4.g.l .4.1 .
14.9.1 .5
14.9. 1 .5.1 .
14.9. 1.6.
r4.9.1.6.1.
14.g.l .7 .
t4.9.t.7 .r.
14.9. 1.8.
14.9.1.8.1.
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
Equipment Installation
Prior to initiation of hazardous waste operation activities in the Autoclave, its HVAC
filtration system and the condensate tanks, their design and installation has been
constructed in compliance with I.S.1. This Certification attests that the Autoclave
equipment has been constructed and installed in accordance with the equipment's design
specification and drawings.
Dimensions and Location
The Autoclave is a horizontally placed steel cylinder measuring 20 feet long and six feet in
diameter. Installation is in Igloo 1631 of Area 10.
Conveyors
There is an intemal chain conveyor that is used to move waste bins in and out of the
Autoclave. The content of Secondary Waste drums to be processed in the Autoclave is
transferred to 64.7 cubic foot waste bins. Drums containing specific Secondary Wastes
are placed directly into the waste bins for treatment as allowed by permit conditions found
in Module VIII. A liner is placed into each waste bin before it is loaded with drums. The
Autoclave will hold up to four of these waste bins. The waste bins are then loaded on the
conveyor in front of the Autoclave load/unload side-hinged door. Once each waste bin is
loaded a hydraulic lift is used to lift the waste bin onto the chain conveyor. The waste
bins are moved by the chain conveyor to their selected position in the Autoclave.
Gates
The Autoclave is equipped with a side-hinged, hydraulic operated load/unload door that is
also six feet in diameter. The door is equipped with an O-ring so that a positive seal is
made when it is shut. It is at this location that wastes are loaded into the 64.7 cubic foot
waste bins.
Pumps and Transfer Lines
The autoclave uses a pump and transfer line to move condensate generated by the two
condensers and steam traps located along the bottom of the Autoclave. As condensate is
generated it is collected in a 175-gallon transfer tank. When full, the contents of this tank
are pumped to one of two 1,000 gallon less than 90-day accumulation tanks which are
used to store condensate.
Sump Pump
There are no sump pumps associated with the Autoclave operation.
Tanks and Containers
Condensate generated from the cooling and drying of gases evacuated from the Autoclave
by use of the steam eductor are first accumulated in a t75-gallon transfer tank and
intermittently transferred to one of two 1,00O-gallon tanks that are operated as < 90-day
accumulation tanks. Once full, the contents of the tank are agitated for 30 minutes and a
sample taken and screened for chemical agent; if the results are less than the Waste
Attachrnent - l4 - Page 52
14.9.1 .9.
t4.9.1.9.1.
t4.9.1 .10.
14.9.1.10.1.
r4.9. 1 .1 0.2.
14.9.1.11.
14.9.1 .1 1 .1 .
TOCDF
Demilitarization Miscellaneous Treatment Units
June 2009
Control Limit (WCL) the condensate is transferred to an off-site Subtitle C TSDF. If the
analytical results show agent concentrations greater than the WCL, the tank's contents are
treated with decontamination solution andreanalyzed. Additional analyses are performed
to identiff required Land Disposal Restriction (LDR) notifications.
Feed Svstem
Secondary Waste drums to be treated in the Autoclave are staged near the side-hinged '
load/unload door. The drum is then transferred into a lined waste bin. Once fulIthe waste
bin is lifted onto a chain conveyorby a hydraulic lift and moved into the Autoclave. The
weight specified on the drums (total weight) is the basis for batch process weight for each
waste bin and will documented in the operating record. Altematively, instead of
transferring wastes to the waste bins, select Secondary Wastes may be processed in the
Autoclave in their storage container (i.e., drum) as specified in permit conditions found in
ModuleVItr.
Lrstrumentation
The Autoclave is equipped with pressure and temperature sensors that allow operations to
be managed by a Programmable Logic Controller (PLC), and an ACAMS and DAAMS
station that is used to veriff the successful treatment of each batch of Secondary Waste
treated. The PLC performs automatic decontamination control that includes pre-treatment
vacuum, pressurization and heat soak, vent, post-treatment vacuum, and air purge. The
operator selects the desired treatment temperature and temperature soak time. The PLC
controls the steam pressure in the Autoclave which controls the temperature. The PLC
also allows for process data recording so that process parameters associated with each
batch of waste treated can be reviewed and archived.
The control systern provides the following information to the operators:
o Boiler status
o Cooling tower fan status
. Cooling tower pump status
e Condenser crossover temperature
. Condensate transfer pump stafus
. Chiller unit status
o Autoclave vessel temperature
. Imbedded thermocouple temperatures
o Autoclave pressure
o Autoclave function status
Electrical System
The electrical system powers condensate pumps, igloo lighting, agent monitors, igloo air
handlers, the carbon filter system induced draft fan, Autoclave instrumentation, and the
PLC that controls Autoclave operations.
Commercial power is provided. An unintemrptable power supply (UPS) is provided to
supply power to the systems referenced in Condition 14.9.7.2 for five seconds, after which
power is restored by a natural gas fired emergency generator. Attachment 9 (Contingency
Plan) provides detailed information regarding the backup power systems.
14.9. 1.1r.2.
Attachrnent -14 - Page 53
14.g.l .r2.
14.9.1 .12.1
14.9.1.13.
14.9.1.13.1.
14.9.1 .14.
14.9.1.14.1 .
14.9.2.
14.9.2.1 .
14.9.2.2.
14.9.2.3.
t4.9.2.4.
Demilitarization Miscellaneou. r.""-J:,t3,:
June 2009
Heating. Ventilation. and Air Conditioning System (IIVAC)
The Autoclave resides within DCD Area 10, Igloo 1631. General-area heating, ventilation
and air conditioning of Igloo 1631 is provided separate of the carbon adsorption filtration
system.
Fire Protection System
Type ABC hand-held fire extinguishers are staged in Igloo 163l (See Attachment 9
Contingency Plan).
Alarm and Communications Systems
Igloo 1631 and the adjacent support building are equipped with a communication system
that is similar to that of the TOCDF site to include local area network phone service and
Public Announcement (PA) system, hand-held radios and cell phones. These systems are
available to alert employees of emergencies or to summon assistance.
General System Operation
The Autoclave is a batch feed system. The process begins with the transfer of Secondary
Waste drums to the 64.7 cubic foot Autoclave waste bins. The Secondary Waste drums
are transferred to the waste bins using a crane. This transfer occurs near the side-hinged
load/unload Autoclave door. Altematively, instead of transferring wastes to the waste bins,
select secondary wastes may be processed in the Autoclave in their storage container (i.e.
drum) as specified in permit conditions in Module VIIL
A liner is placed into each waste bin prior to the Secondary Waste being placed into the
bin. Once full, a thermocouple is inserted into the heaviest drum of each type of waste in
each waste bin or other configuration based on results obtained during shakedown and
approved by Executive Secretary. These thermocouples allow for the temperature of the
bins or drum's content to be continuously monitored throughout the treatment process.
The waste bins are placed onto a hydraulic lift prior to being filled. When frlled the lift
raise the waste bin onto a chain conveyor that runs the interior length of the Autoclave and
the chain conveyor moves the filled waste bin into the Autoclave. The Autoclave can hold
up to four waste bins.
Once the batch of waste is loaded into the Autoclave the door is closed and the PLC
controlled treatment process begins. The treatment process consists of the following
discrete steps; l) pre-treatment evacuation, 2) ramp-to-temperature, 3) temperature soak,
4) post-treatment evacuation, 5) post-treatment cooling and drying, 6) Autoclave
headspace equilibration, and 7) Autoclave headspace monitoring.
The pre-treatment vacuum is accomplished using the steam eductor that evacuates the
Autoclave to a pressure of approximately ten inches of Mercury Gg). The purpose of the
pre-treatment vacuum is to remove the air from the Autoclave which allows for a quick
and efficient penetration of steam throughout the load to be processed. Upon completion
of this process step steam is introduced into the Autoclave, beginning the ramp-to-
temperature step.
r4.9.2.s.
Attachrnent -14 - Page 54
14.9.2.6.
t4.9.2.7 .
14.9.2.8.
14.9.2.9.
t4.9.2.r0.
14.9.2.11.
t4.9 .3 .
14.9.3. 1 .
t4.9.4.
14.9 .4.1 .
DernilitarizationMiscellaneourr.""*J,OI9r',,:
June 2009
Multiple puge, evacuation, and re-heat cycles are used throughout the ramp-to-
temperature step to minimize the time it takes the wastes within the Autoclave to reach the
treatment ternperature. The number of purge, evacuation, and re-heat cycles used during
the ramp-to-temperature process step varies with the type of waste being processed.
The temperature soak does not begin until the temperature read by each of the
thermocouples is equal to or greater than the treatment temperature set point. If a
thermocouple fails in a waste bin and another waste bin has the same tlpe of waste with a
functioning thermocouple, then the waste is not required to be retreated. If two
thermocouples fail from the same waste type then all waste bins will be retreated. If the
waste bins consist of different types of wastes streams, then the contents of all waste bins
will be retreated. Failed thermocouples will be replaced with new thermocouples for all
waste streams except DPE, plastic and butyl rubber prior to retreating.
Upon completion of the temperature soak process step, the PLC activates a post-treatment
vacuum process step. This process step removes excess moisture from the waste load.
A cooling and drying step follows the post-treatment evacuation step. During this step,
arnbient air is drawn from Igloo 1631, and moved through and out of Autoclave by an
approximate 300 cubic foot per minute fan. The air exhausting the Autoclave is vented
through the carbon filter system.
The cooling and drying process step is stopped by closing the Autoclave air inlet and
outlet valves. The air within the sealed Autoclave is then allowed to equilibrate. Agent
monitoring of the interior of the Autoclave begins a minimum fifteen minutes after the
flow of cooling and dryrng air is stopped per Module VIII, Table VIII A. Agent
monitoring is performed using an ACAMS and associated DAAMS station. Agent
monitoring results are used to confirm that the autoclave atmosphere is safe to open the
door.
Upon completion of successful treatment, the wastes bins are removed from the Autoclave
and transferred via forklift out of Igloo 1631 to a pre-positioned roll-off. The waste bin
liners (containing the treated Secondary Waste) are removed from the waste bins and
placed into roll-offs. Full roll-offs are transferred to an off-site Subtitle C TSDF.
Svstem Startup
The Autoclave is PLC controlled. To begin operations requires; l) the steam pressure of
the boiler to be sufficient to support Autoclave operations, 2) proper operation of the
condensers used to dry gases vented to the carbon filter system, and 3) operation of the
carbon filter system.
Feed
The Autoclave is a batch feed operation. Secondary wastes are fed to the Autoclave either
by transferring the wastes from their original storage containers (i.e., I to 110 gallon
drums) to lined 64.7 cr,tbic foot waste bins, or by placing full drums of waste directly in
the waste bins. The weight specified on the drums (total weight) is the basis for batch
process weight for each waste bin and will be documented in the operating record. The
Attachment - 14 - Page 55
14.9.5.
14.9.5. 1 .
14.9.6.
14.9.6.1.
14.9 .7 .
t4.9.7 .r.
14.9.7 .2.
14.9 .8.
14.9.8.1.
t4.9.8.2.
14.9.8.3.
DernilitarizationMiscellaneorrr.."*"1:,ti,r:
June 2009
tlpes of Secondary Wastes that may be treated directly in their storage containers are
identified in permit conditions found in Module VtrI.
Interlocks
Autoclave operations include interlocks that; 1) prevent the load/unload door from being
opened during operations; 2) prevent the start of Autoclave operations if the condensers
which are used to cool and condense gases removed from the Autoclave during the pre-
and post-treatment evacuation process steps are not functioning properly, and 3) prevent
the start of Autoclave operations if any of the thermocouples which are placed in the
waste loads and used to initiate the start of the treatment timer are not functioning
properly.
System Shutdown (Normal)
The Autoclave is shutdown by the PLC after the treatment of each waste batch. The boiler
may be shut down when the Autoclave is not in operation.
Emergency Shutdown
Autoclave operations are locally controlled which allows the system to be shutdown by the
operator should abnormal conditions develop. The hydraulic load/unload door, carbon
filter system and associated spare filter, and emergency generator allow for Autoclave
operations to be intemrpted during any of the previously described process steps without a
resulting release of hazardous waste to the environment.
During emergency operations resulting from a loss of commercial power, operation of the
carbon filter system induced draft fan and agent monitoring equipment is maintained by an
UPS and emergency generator.
Monitoring Procedures
Autoclave operations are monitored by the PLC to ensure complete destruction of the
agent contaminating the Secondary Waste articles. Instrumentation used to ensure
destruction of the agent includes pressure monitors for Autoclave intemal pressure,
temperature monitors, in the form of thermocouples, which are placed in the waste loads
and an ACAMS used to confirm that the autoclave atmosphere is safe to release.
ACAMS are used to monitor the interior of the Autoclave upon completion of the
treatment process. ACAMS monitoring is performed prior to the treated waste being
removed from the Autoclave. These results are used to determine the applicable waste
handling practices.
The Autoclave system uses two tlpes of control equipment to minimize emissions of
organic compounds to the environment. Gases removed from the Autoclave during the
pre- and post- treatment evacuation process steps first pass through a glycol cooled
condenser, then through a refrigerant condenser, and finally through a fixed bed carbon
filter. The fixed bed carbon filter is the primary method of controlling emissions to the
environment.
Attachrnent -14 - Page 56
14.9.8.4.
14.9.8.5.
14.9.9.
14.9.9.1 .
14.9.10.
14.9.10.1 .
14.9. 1 1 .
14.9.11.1.
14.9.12.
14.9.12.1 .
t4.9.t2.1 .1 .
14.9.12.2.
14.9.12.2.1 .
14.9. 1 3.
14.9.13.1.
Demilitarization Miscellaneour r.".r.J:;"?,:
June 2009
The carbon filter system consists of a primary and secondary filter system. Each system
includes two carbon beds. Agent monitoring using ACAMS is conducted at the mid-bed
location and at the exhaust stack.
The carbon filter systems are additionally equipped with a pressure gauge that is located in
a readily accessible location so that it can be verified that the carbon filters are being
operated at a negative pressure when in use.
Waste Identification
The Secondary Wastes treated in the Autoclave includes DPE Suits contained in plastic
bags, wood and LSS air hoses. Additional waste types may be allowed following function
testing approved by the Executive Secretary. These waste matrices may include the
following waste codes;P999, F999, D002, D003, D004, D005, D006, D007, D008,
D010, andD011.
Waste Throughput
The waste throughput rates and process parameters are established through results of a
function test executed per a test plan approved by the Executive Secretary. Autoclave
operating parameters, including waste feed are specified in Module VI[.
Inspection
The Autoclave system, including ancillary equipment will be inspected as specified in
Attachment 5.
Closure
Partial Closure
Partial closure does not apply to the autoclave. Following final closure of the autoclave
the TODF will submit in writing to the Executive Secretary a request for partial closure of
Igloo 1 63 1 . After approval of partial closure, Igloo 1 63 I will be turned back over to DCD
Area 10 for final closure.
Final Closure
Final closure of the autoclave will be performed in compliance with R3 I 5-8-7 and this
permit. Final closure of Igloo 1631 will be accomplished via DCD Area 10 Closure Plan.
Mitigative Design and Operating Standards
The following section describes waste constituent releases to the environment (air, soil,
and water), the potential impacts of such releases, and the location features of the TOCDF
that will mitigate these releases.
Containment Svstem14.9.13.2
Attachrnent - 14 - Page 57
14.9.13.2.1 .
,-,74.9.13.2.2.
DemilitarizationMiscellaneou.r.".*.]li"rf,,l
June 2009
Containment systems associated with the igloo housing the Autoclave include; 1) the
epoxy paint sealed floor of Igloo 1 63 I , and 2) the walls of the igloo which prevents liquid
wastes from escaping the igloo.
The secondary containment tray will be positioned at the lip of the junction between the
Autoclave vessel and the load/unload door if necessary. This containment tray will be
utilized if the cooling and drying autoclave process step does not perform as expected.
Site Air Conditions
See Section 14.3.7.4.
Topography
See Section 14.3.7.5.
Meteorological and Atmospheric Conditions
See Section 14.3.7.6.
Air Quality
See Section 14.3.7.7.
Prevention of Air Emissions
Emissions to air of organic compounds from the Autoclave are controlled using fixed-bed
carbon filter system. The carbon filter system is shared with the DVS/DVSSR treatment
units. See 14.8.1.1.3 formore description.
Operatins Standards
The operating standards applicable for Autoclave operations are specified in Module VIII
of this permit.
Site Hydrologic Conditions
A summary of site hydrologic conditions is given in Attachment 1 (Facility Description).
Mieration of Waste Constituents
14.9. 1 3.3.
14.9.13.3.1.
14.9.13.4.
r4.9.r3.4.1 .
14.9. 1 3.5.
14.9.13.5.1.
14.9 .r3.6.
r4.9.13.6.1.
14.9 .13 .7 .
t4.9. 1 3.7 .t .
14.9.13.8.
t4.9.13.8.1.
t4.9. I 3.9.
r4.9. 13.9.1 .
t4.9. 13.10.
t4.9. 13.10.1.The migration of waste constituents is controlled by the use of the fixed bed carbon filter
system that captures gases vented from Autoclave operations, the sealed floor oflgloo
1631 and the enclosed space created by placing the Autoclave inside the igloo that
prevents waste constituents from migrating to ground water, or being released to the
environment during Autoclave loading and unloading operations.
14.9.13.10.2. Releases to the environment while loading treated wastes into the roll-off are controlled by
ihE use of waste bin liners that prevent treated waste from being spilled during roll-off
loading operations and by the ACAMS results associated with each batch of Autoclave-
treated waste.
Attachment - 14 - Page 58
TOCDF
Demi I it anzation M i scel I an eou s Treatmen t Un i ts
June 2009
14.10 ATLIC Ton Container Rinse and Drain Gloveboxes
14.10.1 Physical Characteristics
14.10.1.1. Unlike the TOCDF which uses the Bulk Drain Stations to first ounch holes in ton
container and then drain their chernical agent fill and then uses the Metals Parts Furnace to
decontaminate the drained ton containers by the.rmal treahnent. the ATLIC will use slove
boxes equipped with a series of val+e valves which are connected to supply and receiving
tanks to drain the ton container ageirt fills and decontaminate the ton container by oartially
filline. rotatine. and drainins thern with a series of dacontamination sglutions. acid
solutioqs. and water.
14.IQ.1.2. Ton containers treated at the ATLIC are placed into one of two Gloveboxes which are
used to control chemical agent emissions and to contain aeent and hazardous waste
releases pnd drips that may occur durins the connectinq and disconnecting of fill and drain
lines and the opening and closing of the ton contain€r valves.
14.10.2. Equipment Installation
14.10.2.1. Prior to initiation of hazardous waste oneration activities at the ATLIC. the incinerator and
Pollution Abatement System (PAS). the ATLIC HVAC filhation sLsten-r- hazardous waste
storaee and treatrribnt tanks. and Subpart X treatm€nt units. to include the gloveboxgs.
their desiqnand installation will have be€n verified throushthe Facilitv Construction
Certification (FCC) documentation as required by Condition I.S. This C€rtification attests
that the eouipment has been constructed and installed in accordance with the equipment's
desien spocification and drawings.
14.10.3 Dimensigns an4 Lncation
14.10.3.1. . The two gloveboxes are identical and identified as GloJebox 8501 and Glove-box 8502.
The dimensions of each elovebox are 9.7 feet lone by 4.3 fect high by 4.5 feet wide.
Installation is in the ATLIC -Processine Bay located in lgloo 1639 of Area 10.
14.10.4. Conveyors
14.10.4.1. There are no convelrors associated with the ATLIC eloveboxes. Ton containers are
moved into and out of the gloveboxes by beine olaced on a cart referred to as a "transfer
table". The ton container is manually moved from the transfer table and olaced uBon
multi-directional rollers that are used to move a ton container (alons its axis) in and
out of ndthin the dovebox. The same rollers are used to rotate the ton container around
its axis relles-arerxed during the rinse processing step to rotate the ton container to
u',hieh allows for its entire interior surface to be contacted with the different rinse
solutions.
Gates
14.10.5.1. There are no automated gates associated with the ATLIC slove-boxes. Each elove-box is
eouiooed with an access door to allow ton containers to be placed in and removed from
the glovebox. and small air-locks to allow tools and sampline equipm€nt be moved into
and out of the slovebox.
14.10.5
Attachment - 14 - Page 59
:
14.10.6. Pumps and Transfer Lines
TOCDF
Demi I i t anzation M i scel I an eous Treatm en t Un i ts
June 2009
14.10.6.1. There are numerous pumps and transfer lines associated with the elove-boxes. There are
two Bumps available to drain Ag€,nt GA from the ton containers and transfer this agent
directly to the ATLIC orimary combustion chamber. a pump to drain spent
decontamination solution from GA ton containers and water from rinsed out GA. Lewisite
. and "Transparerlcy''ton containers and transfer the solution to a storaee tank in the
ATLIC Toxic fuea. a pump to drain Lewisite from ton containos and transfer it to a
storaee tank in the ATLIC Toxic Area. and a pumo to drain Nitric Acid from rinsed
Lewisite and "Transoarenct''ton containers and transfer it to a storaee tanks located in the
ATLIC Toxic Area. Each of these Bumps services both gloveboxes.
14.10.6.2. The drained asents and rinse solutions are directed to the primary combustion chamber or
dedicated hazardous waste storaee and lreatment tanks by manually adjusted valn€ valve
line-uos. Each glovebox has four se,parate transfer lines running from the exterior of the
glovebox to the pumos refar€nced in the previous paragraph. The pumps are located in
the ATLIC Toxic Area where secondary containment is orovided. The sections of transfer
lines spanning the distance between the exterior of each glovebox to the wall of the Toxic
Area are doubled walled.
14.10.7. Sump Pump
14.10.7.1. There are no sump pumDs associated with the glove-box hazardous waste manaeernent
units. Solutions accumulatinq within a elove-box. as a result of a soill and associated
decontamination. can be transferred to a container bv openins a drain line located
in the bottom of the slovebox.
14.10.8. Tanks and Containers
14.10.8.1. The glove-boxes are used to eirclose Agent GA. Lewisite. and "Transparency''ton
containers while there they are drained and rinsed. Each elove-box has valves and
transfer lines to allow for the draining of chemical agent. and the filline and draining of
decontamination and rinse solutions to include sodium hydroxide. and Nitric Acid
solutions and water. The valves and transfer lines used to convey solutions into the ton
containers and the tanks used to store these materials are not discussed in this section
because these materials are Broducts.
14.10.8.]. -.. The tanks to which the spent decontamination and rinse solutions are transferred are
located in the ATLIC Toxic Area. These permitted hazard waste storase and treatment
tanks are identified in Module IV and Attachment 16 of this permit,
14.10.9. Feed System
14.10.9.1. Toncontainersaremanuallyoositionedintoeachelove-boxbyuseoftheTransferTable
and roller within the glove-box.
14.10.10. lnstrumentation
14.10.10.1. Instrumentation associated with each glove-box includes pressure differential indicating
a
Attachrnent - 14 - Page 60
TOCDF
Demi I i t arizati on M i scel I aneou s Treatmen t Units
June 2009
transmitters which provide both a local and remote reading of the differerrtial pressure
betwee,lr the interior of the slove-box and the ATLIC Processine fuea. Th€re are also
mass flow meters whichprovide a local readins of the mass of decontamination. Nitric
Acid solutio{rs. or water added to the ton cgntainers for decontamination and rinsing.
14.10.10.2. For A&ent GA processins. there are also solenoid switches that can activate interlock feeds
to the incinerator and hazardous waste storaee and treatment tanks to orev€nt both elove-
boxes from transferrine the same age,nt decontamination or rins,e solution tg the incinerator
or tanks at the same time.
14.1Q.10.3 For Ae€nt Lewisite processing. there are sole,noid switches that orev€,nt the rinse solutions
from beins transf€rred betlveen the two slove-boxes but have no imoact on incherator
feed since the ae€nt is transf€rred to a holding tank rathar than fed directly fromthe elove-
bn&
14.10.11. ElectricalSystem
14.10.11.1. The electrical systern oowers all the ATLIC systsms. ATLIC PAS. the scrubb€r brine
chiller. idoo liehtine. aeent monitors. igloo air handlers. the carbon fllter slstem Induced
Draft (ID) fans. incine, ator instrumerrtation. and the PLC that controls facility operations.
The electrical system also Dower a motor within each elovebox which is used to rotate ton
containers after thcn they have been filled at least half way with decontarqination and
rinse solutions.
14. 10. I I .2. Commercial oower is provided. An unintemrotable gower supDly (JPS) is orovided to
supply power to critical systeins for uD to 45 minutes. after which Dower is restored by one
of two diesel stand-by s€nerators. Attachment 9 (Contins€,ncy'Plan) provides detailed
information resardine the backup power systems.
14.10.12. Heatinq- V€ntilation. and Air Conditionine Systern ([IYAC)
14.10.12.1 Emissions from thceach qlove-box are controlled by the ATLIC IryAC Carbon Filter
System. Durinc draininq and rinsinc ogeration the qlove-boxes are oD€rated under a
negative pressure relative to the ATLIC Processins Bay. The neeative oressure is created
by adjusting dampers in the duct that connects each glove-box to ATLIC IIVAC system.
which ultimateh,vents to two of three activatqd carbon filters. The ATLIC HVAC
supports the ieloo and the enclosure connected to the igloo that comprises the ATLIC.
14.10.12.2. Each carbon filter contains a bank of pre-filters. followed by a bank of High Efliciency
Particulate Air (HEPA) filters. followed by three banks of activated carbon filters.
followed finally by an additional bank of HEPA filters. Two of the three available filter
units are onJine from the time agent operations beein until the facility is decontaminated.
The exhaust gas flow ratq for a sinde filter unit is aporoximately 6.000 cubic feet per
minute.
14.10.13. Fire Protection System
14.10.13.1. See Attachment 9. parasaohs 9.1.4.9 throush 9.1.4.14
14.10.14. Alarm and Cofnmunications Systems
Attachrnent -14 - Page 61
TOCDF
Dem i I i t anzation M i scel I aneou s Treatmen t Un i ts
June 2009
14.10.14.1. Isloo 1639 and the attached ATLIC Environmelrtal Control System (encloses the PAS) are
equipped with a communieation systsrn that is similar to that of the TOCDF site to include
local area network phone service and Public Announcement (PA) system. hand-held' . radios and cell ohones. These systerns are available to al€rt ernployegs of emereencies or
to summon assistance.
14.10.15. GeneralSystemOperation
14.10.15.1. The draining and rinsine of TCs is nerformed in the glove-boxes. Glove-box operations
are oerformed manually by an operator who can reach into the elove-box by inserting their
hands into giloves that nenetrate thq two width-wide ends of each slove-box. Each process
siep is initiated by a local ooqrator. Process steos are described below aud essentially
involve the realienment of valves to either drain or fill the TC beingprocessed.
14.1,0.15.2. The processine of GA TCs differs slightly from that of L TCs. GA TCs are processed by
. olacing the TC into the dove-bo?r ?nd rotafing it so.the two fill and drain valves are
aligrrred vertically. Ouick connect couolers are used to attach the drain and fill lines within
the glove-box to the ton container valves. The ton container valves are then opened.
14.10.15.3. Valves.within each glove-box can be arrayed to transfer the contents of each TC to the
ATLIC PCC. the Lewisite Agent Collection Tanlc the Soeirt Decontamination Tank. or to
one of trro Nitric Acid Holding Tanks. Valves located outside each elove-box can be
arrayed to fill ton containers which have been drained of their agent fill with
4: .. . decontamination solution. Nitric Acid Solution. or water.
14.10.15.4. A process qir line is attached to the upper valve. and drain line is attached to the lower
valve. The connections are made usins soecially desisned shutoffquick-connect couplers.
The valves are then opened. the air added to the TC through the top valve both prevents a
vacuum from forming in the TC as the agent is rernoved and provides additional pressure
to assist in draining the asent. The GA is fed from the TC directly to the LIC PCC.
14.10.15.5. tf plugged drain and fill valvq are encountered. the same air line can be used to unplug the
valve(s). If the valve(s) qannot be unglugged using compressed air. a drain lance can be
inserted into the TC by removing one of the "blow-out" olugs which are located end of the
TC opposite the drain and fill valves.
14.10.15.6. Once ernptied of the agent fill. the GA TC is back-flushed with a sodium hydroxide
(NaOH) based decontamination solution. Suffrcient decontamination solution is added
throush both drain and fills valves to fill the TC more than half wav with this solution.
The TC is then rotated for a gredetermined period of time. The rotation of.the TC eirsures
that the solution contacts all of the TCs' interior surfaces. The soent decon solution is
tben drained from the TC to the SDS Tank located in the ATLIC Toxic Area. Once
anotied of speht decon. the TC is rinsed by filling it more than halfivay with water.
. - rotatingthe TC and draining the water. The water rinse process is repeated at least three
I' TCs are transferred to off-site Subtitle C Treatment. Storaee. and Disposal Facilities
(TSDF) when the results of the samoles collected from the third (or additional water rinses
if required) show an aeent concentration of less than the Waste Control Limit (WCL) for
the asent beins orocessed. The WCL for Agent GA is 20 parts oer billion (pob). The
spent decon and water ge,lrerated from rinsins GA TCs is transferred to the SDS Tank and
treated in the LIC SCC.
Attachment - 14 - Page 62
TOCDF
Demi I i t anzation M i scel I an eou s Treatment Units
June 2009
14.10.15.7. Agent L TCs are preoared for draining in the same manner as the GA TCs: the difference
in how GA and L TCs are orocessed involves where the drained ae€nt is transf€rred and
how the interior of the emotied TCs are rinsed and decontaminated.
14.10.15.8. Aeent L TCs are drained in the same manner as GA TCs. The drained L however is
transferred from the TC to the Lewisite Aqent Holding Tank located in the ATLIC Toxic
Area. The L accumulates in the tank where it is mixed and sampled orior to being fed to
the LIC PCC. Once drained. L TCs are filled more than halfiray with a 3 Molar (M) nitric
acid solution. The TC is then rotated for a oeriod of time. The resulting soent nitric acid
is transferred to one of hryo Nitric Acid Holding Tanlc. also locatedjn the ATLIC ToXic
Area. where it accumulntes until it is sampled and screened fot asexil gonc€,ntration. 3 M
nitic acid or ereat€r is added to the tank's cont€nts to treat the L to a conccntration of less
than the WCL for L. which is 200 ppb. When the concentration i+ the Spent Nitric Acid
is less.than the WCL the tank's contents are transferred to a 90day accumulation tank
located in the PAS Enclosure where it accumulates oendinq off-site transf€r to a deq) well
injection facility.
14.10.15.9. Once the L TC is drained of the spent nitric acid. the L TCs are filled more than halfivav
with water. rotated. and then drained. This orocess is reneated at least three times. A
samole is collected fromthe final water rinse and anallzed for aeent content. TCs are
transferred to an off-site Subtitle C Treatment. TSDF) wheir the results of the samples
collected from the third or final water rinse show an agent concentration of less than the
Waste Control.Limit (WCL). The water generated from rinsine L TCs is transf€rred to the
SDS Tankandtreated inthe LIC SCC.
14.10.15.10. All Transparencv TCs undergo one Nitric Acid rinse followed bv three water rinses.
Each rinse consists of lillins bv more than half wrv (anproximatelv 110 sallons) the
emotied TC with the rinse solution and rotating the TC for a minimum of one hour.
as{-+€*
1a.10.15.11.
Reserred.
14.10.15.12. After the series of water rinses is comoleted. TCs processed at the ATLIC are placed into
a permitted container storage HWMU. At the completion of TC rinsins and drainine
operations. the elove-boxes are rernoved from the ATLIC Processing Bay to make room
for the TC cutting machine which will cut the decontaminated TCs in half after which the
TCs are transfe'rred to an off-site Subtitle C TSDF.
14.10.16. System Startuo
14.10.16.1. There are no automated features associated with dove-box operations. all operations are
manual and performed by a local ooerator. Operations beein with a TC being placed into
a elove-box. The qlove-box is sealed and a negative Bressure is established between the
interior of the glove-box and the ATLIC Processine Bay.
14.10.17. Interlocks
Attachment - 14 - Page 63
Demi I it anzation Mi scel I aneou s Treatm;Til
June 2009
Interlocks associated with the slove-boxes are activated bv solenoid switches that sense
valve positions. The interlocks are included to prevent both elove-boxes from transferrine
asent. decontamination. or rinse solutions to the same tank at the same time. This
prevents the accidental and unintended filling of a TC in one glove-box by the TC in the
other slove-box.
14.10.18. SystemShutdown(Normal)
l4.l0.l 8.1 . There are no automated features associated with gflove-box operations. all oLerations are
manual and performed by a local operator. Decontaminated TCs are not removed from a
glove-box until the interior of the glove-box has been monitored and aeent concentrations
have been determined to be less than 0.5 Vapor Screening l,imit (VSL). Once the TCs are
rernoved there is no need to maintain a negative oressure within the glove-box.
14.10.19. AsentMonitorineProcedures
14.10.19.1. AsampleanalysisisusedtodeterminewhenaTCcissufficientlydecontaminatedto
_: ... assisn the F999 waste code.
14.10.19.2. First. the orocessing of TC in a elove-box is deterrnined complete based on analltical
results obtained from rinsate sample anabrsis. Each TC undereoes rinses with
decontamination solutions. and/or oxidizers (i.e.. Nitric Acid solution). After these are
comoleted. each TC undergoes at least three water rinses. A sample of rinse water from
the final water rinse is collected arid screexred for aeent concentration relative to the Waste
Control Limit (WCL). The interior space of TCs is determined to be suffrcientii '
decontaminated if the results of aeent screen conducted on a sample of the third .or final.
water rinse are below the WCL which is 20 parts per billion (ppb) for Aeent GA and 200
ppb for Lewisite. TCs havine third (or final) rinse water samole aeent screen results of
less than the WCL are characterized as F999 wastel other waste codes may aBply.
14.10.19.34. TCs are removed from the glove-box based on results obtained from the monitoring of the
interior of the glove-box. For GA TCs. elove-box monitorinq results of < g? 0.5 VSL
allow for the TC to be rerroved from the glove-box. For Lewisite TCs. glove-box
monitorine results of < 4S 0.4 VSL allow for the TC to be rernoved from the elove-box.
These monitorine criteria for remoyinq TCs from a slove-box are based on
monitorins results obtained from two sample/analvsis cvcles of the Near Real Time
Monitor or one comDlete cvcle preceded bv a nurse cvcle to ensure the sample line is
14.10.20. Waste Identification
14.10.20.1. The wastqs that will be treated in the ATLIC glove-boxes (Jhe treatment being the draining
and decontamination of chemical aeent filled ton containers and emptv ton container
contaminated with Lewisite) are:
o Four ton containers partially filled with Agent GA having an aporoximate total
weieht of 4.000 pounds of chemical agent. The waste codes applicable to Agent
GA are P999. D004. D007. D008. and D021.
Attachrnent -14 - Page 64
Demilitarization Miscellaneous t ""*J:;rTJune 2009o Ten to.n containers filled with Lewisite havine an aooroximate total \f,eigfit of
ZS.OOO pounOi of qn ,{ni"al us.nMo fe*isit" ar"
P999. D004. D007. D008. D009 and D010.
o Up to ten empty ton containers. which are referred to as,"Transparency Ton
Containers". These TCs underso one Nitric Acid Solution rinse followed bv
three water rinses.
rarnpb' franryareney fgs tnat were A
r ewisite besc en tlrc'm
.
14.10.21. Waste Ttroughput
14.10.21.1.,. Thewastethrouehputratevariesdep€'ndingonthpamountofaqeotrequiringdrainingand
,
' 'thq number of rinses requir€d to decontaminate the interior (and exterior if ncaessary) of
the ton container. Note ton containers are under engineering controls the entire time they
are within a glove;box. Each elove-box v€nts to the ATLIC carbon filter absorber
eouiBpedHVAC system.
14.10.22. lnspection
14.10.22.1. Each ATLIC Glove-box system. includins ancillarlequipment will be inspected as
spegif,ed in Attachment 5.
14. 10.23. Closure
14.10.23.1 Partial Closure
1a.10.23.1.1.
TeeDf witr^ubmit in writingt
ffi. The qlove-boxes will be closed as individual Hazardous
Waste Manasement Units fifWMU) bv disnosal as hazardous waste debris/waste.
14.10.23.2. Final Closure
14.10.23.2.1. Final closure of the ATLIC glove-boxes will be oerformed in compliance with R315-8-7
and this p€'mlit. Final closure of Iqloo 1639 will be acqomplished via DCD Area 10
Closure Plan.
14.10.24. Mitigative Design and Operating Standards
14.10.24.1. The following section describes waste constituent releasbs to the eirvironment (air. soil.
and water). the potential impacts of such releases. and the location features of the ATLIC
14.10.24.2 . . CqntainmentSystem
14.10.24.2,.1. Theelove-boxorovidessecondarycontafumentforthetoncontainerbeingtreated. The
sealed desiqn ofthe glove-box controls both air enrissions and contains any release that
Attachrnent -14 - Page 65
DemilitarizationMiscellaneourr."u*"lrO,!nT
June 2009
may occur wheir the transfer lines rvhieh:aredetaehe*{e are detached and rqmoved
from the ton container valvesrre+emsried.
14.10.24.2.2. Releases of agent caused from detaching the treated ton container from the hansfer lines
are controlled by the use ofquick connect couplers which are desiened to seal the transfer
lines when they are disconnected from the emptied ton container.
14.10.24.3. Site Air Conditions
14.10.24.3.1. See Section 14.3.7.4.
14.10.24.4. Toooeraphy
14.10.24.4.1. SeeSection 14.3.7,5.
14.10.24.5. MaeorologicalandAtmospheric Conditions
14.10.24.5.1. See Section 14.3.7.6.
14.10.24.6. Air Ouality
14.10.24.6.1. See Seption 14.3.7.7.
14.10.24.7.
-'
Prevention of Air Emissions
14.10.24.7.1. Air emissions resulting from qlove-box ton cont4iner draining and rinsinq operations are
controlled by the ATTIC HVAC filter system to which each glove-box is directly
connected.
14.10.24.7.2. A negative pressure is maintained within the gloye-box (relative to the ATLIC Processing
Bay) from the time a ton container is placed in each elove-box until the time the ton
container is decontaminated and removed from the glove-box.
14.10.24.8. OoeratingStandards
14.10.24.8.1. The oBeratins standards applicable for ATLIC glove-box operations are specified in
Module VIII of this permit.
14.10.24.9.1. A summary of site hydroloeic conditions is given in Attachment I (Facility Description).
14.10.24.10. Migration of Waste Constituents
14.10.24.10.1. The migration of waste constituents to ground and surface waters is controlled by the
sealed desien of each glove-box which provides secondary containment for the ton
containerbeing rinsed and drained. Additionally each slove-box is located within Igloo
1639. the base of which is coated with an epoxy coatine that provides an impermeable
Attachnient : 14 , Page 66
DemilitarizationMiscellaneousTreatm;"Jr',1
June 2009
Table l4-3-l
LIST OF BULK DRAIN STATION SENSORS AND CRITICAL INTERLOCKS
Sensor Tag Sensor Type Functional Description
49-l-P I (Line A)u
49-2-P I (Line B)u
Retroreflector Beam Sensor Indicates the tray is on the BDS Transfer Conveyor, shifts
Transfer Conveyor to slow speed (Start of BDS).
49-l-P2 (Line A)*
49-2-PZ (Line B)*Inductive Proximity Sensor Indicates the cradle is at the punch position.b
49-l-P3 (Line A)*
49-2-P3 (Line B)*Inductive Proximity Sensor Indicates the TC cradle is at the agent drain position AND
indicates the TC cradle is in the first vent punch position.
49-l-P4 (Line A)*
49-2-P4 (Line B)*Inductive Proximity Sensor Indicates the TC cradle is in the second vent punch position
AND indicates the TC cradle is in the HTS spray position.
49-l-P5 (Line A)
49-2-P5 Gine B)Retrorefl ector Beam Sensor Indicates the tray is transferring to the next Hydraulic
Conveyor.
49-l-P6 (Line A)
49-l-P6 (Line B)Inductive Proximity Sensor Indicates the TC cradle is in the rinsate drain position.
49 -l -l 02 Al -l 02A4 (Line A)*
49-2-1 02A I - I 02A4 (Line B)*Inductive Proximity Sensors Indicate the Transfer Conveyor Lift Cylinders are extended.
49-l- l02B l - 10284 (Line A)
49-2-1028I - 10284 (Line B)Inductive Proximity Sensors Indicate the Transfer Conveyor Lift Cylinders are retracted.
49-l- l03A (Line A)
49-2-103A (Line B)Inductive Proximity Sensor Indicates the Punch Cylinder is extended.
49-l- l03B (Line A)
49-2-1038 (Line B)Inductive Proximity Sensor Indicates the Punch Cylinder is retracted.
49-l-104A (Line A)*
49-2-104A (Line B)*Inductive Proximity Sensor lndicates the Agent Drain Tube is fully extended.
49-l-104B (Line A)*
49-2-1048 (Line B)*Inductive Proximity Sensor Indicates the Agent Drain Tube is fully retracted.
49-l- 104C (Line A)
49-2-104C (Line B)Inductive Proximity Sensor Indicates the Agent Drain Tube cornes in contact with heel
or top of ton container.
49-1- I 06A1-A2 (Line A)
49-2-1064'l-A2 (Line B)Inductive Proximity Sensor Indicates the Hold Down Cylinders are extended.
49-l-1068l-82 (Line A)
49-2-1068l-BZ (Line B)Inductive Proximity Sensor Indicates the Hold Down Cylinders are retracted.
49-ZT-9104 (Line A)
49-ZT-9204 (Line B)Rotational Count Encoders Indicates Agent Drain Tube linear position and distance
traveled.
66-Z3-910lA (Line A)
66-Z3-9201A (Line B)Inductive Proximity Sensor Indicates the HTS Spray Wand Cylinder is fully extended.
66-Z3-9101B (Line A)*
66-Z3-92018 (Line B)*Inductive Proximity Sensor Indicates the HTS Spray Wand Cylinder is fully retracted.
66-Z3-9101C (Line A)
66-ZS-9201C (Line B)lnductive Proximity Sensor Indicates the HTS Spray Wand Heel Detect.
66-ZT-9101 (Line A)
66-ZT-9201 (Line B)Rotational Count Encoder Indicates the HTS Spray Wand linear position and distance
traveled.
66-Z3-9103A (Line A)
66-Z3-9203A (Line B)Inductive Proximity Sensor Indicated the HTS Rinsate Drain Tube Cylinder is fully
extended.
66-Z3-91038 (Line A)*
66-Z3-92038 (Line B)*Inductive Proximity Sensor Indicated the HTS Rinsate Drain Tube Cylinder is fully
retracted.
66-Z3-9103C (Line A)
66-ZS-9203C (Line B)Inductive Proximity Sensor lndicates the HTS Rinsate Drain Tube Heel Detect.
66-ZT-9103 (Line A)
66-ZT-9203 (Line B)Rotational Count Encoder Indicates HTS Rinsate Drain Tube linear position and
distance traveled.
Notes:
u Sensor can be used to monitor throughput of munitions/bulk iterns.
b Interlocks MDM-GATE-I01 and -102* Critical Sensor or Interlock that must be functional when the associated miscellaneous unit is operating.
BDS = Bulk Drain Station
Attachment - 14 - Page 67
Demi lit anzation M i scel laneous TreatmJ:;3l
June 2009
Table l4-4-l
MAXIMUM EXPLOSIVE WEIGHT IN EXPLOSIVE CONTAINMENT ROOM
Normal Process Mode Reject Process Mode
Munitions
(Explosive Type)
No. of
Rounds/Burster
In ECR
Explosive
Weight
In ECR
(TNTE")
No. of
Rounds/Burster in
ECR
Explosive
Weight
In ECR
(TNTn")
l55mm/M 104 and M I l0
(Tetrvtol)4 1.99 4 1.99
4.2-in.lM2 and M2 (Tetryll)2 0.40 4 0.80
Note:
ECR = Explosive Containment Room
I . Based upon ECR design (ref: Section 14.4.1 .4.2), the maximum quantity of explosive material allowed in an ECR is l5 lbs
(trinitrotoluene equivalent (TNTeq)). Therefore, in addition to the quantities identified above, the TOCDF may have additional
in-process munitions, other explosive materials in the ECR provided that the total quantity in the ECR does not exceed 15 lbs
(TNT equivalenQ. TNT Equivalence is based on the specific explosive type's brisance as compared to TNT as reported in Army
Technical Manual TM 9- I 300-214. A mustard I 55mm projectile burster contains 0.414 of tetryl/TNT/tetrytol compound with a
TNT equivalent of 1.2 lbs.nn/pound
Attachrnent - 14 - Page 68
TOCDF
Demi I i t anzation M i scel I an eou s Treatmen t Units
June 2009
Table 14-4-2
PROJECTILE/MORTAR DISASSEMBLY MACHINE SENSORS
Sensor Tag Sensor Type Functional Description
P-l*Inductiv. P..ung. I
Indicates the munition is in the Transfer Station.
I 02B Inductive Proximity Sensor, lOmm
range
Indir.qfes fhe Trqnsfer Cnnrrerrnr Trnllcrr is in ifs hnrneJ
position.
I 03A Inductive Proximity Sensor, 5mm
range
Indicates the saddle is in the load position.
I 038 Inductive Proximity Sensor, 5mm
range
Indicates the saddle is in the unload position.
l 03c Inductive Proximity Sensor, 1Omm
range
Indicates the Index Table is indexed at proper position to
line up with each other.
I l0A/B*NAMCO Switch Senses when the burster probe is extended or retracted.
P-2*Inductive Proximity Sensor, 35mm
range
Indicates the munition is in correct position to begin
operation at the NCRS.
P-21*Fiber Optic Sensor Indicates the fuzelnose closure is in the Chuck Jaws when
the NCR carriage is fullv retracted.
P-22 Fiber Optic Sensor Indicates the burster is in position for unscrewing fuzes
from bursters (M2).
201 B*Inductive Proximity Sensor, 5mm
range
Indicates the Projectile Clamp Cylinder is extended and
munition is clamped.
20tc Inductive Proximity Sensor, 5mm
range
Indicates the Projectile Clamp Cylinder is retracted and the
munition is unclarnped.
2o2Al Induct ve Prox m ty Sensor Ind cates the NCR Carriage is fully extended.
202B'Induct ve Prox m ty Sensor Ind cates the NCR Carriage is fully retracted.
202C1 Inductive Proxirnity Sensor, 5mm
range
Indicates the NCR Carriage is in the mid-position.
P5-203A Pressure Switch Indicates the Hydraulic Chuck Jaws are fully extended or
clamped on a nose closure/fuze.
P5-2038 Pressure Sw tch Ind cates the Hvdraulic Chuck Jaws are fully retracted.
PS-204A*Pressure Sw tch Ind cates the Chuck Motor (spindle) has stalled.
206A Inductive Proximity Sensor Indicates the Gripper Slide Cylinder is fully extended and
the Gripper Slide Assemblv is in the "up" position.
2068 Inductive Proximity Sensor Indicates the Gripper Slide Cylinder is fully retracted and
the Gripper Slide Assemblv is in the down position.
207 A Inductive Proximity Sensor Indicates the Booster/Burster Gripper Cylinder is fully
extended, .iaws "open."
P-3 *Inductive Proxirnity Sensor, l0rnrn
range
Indicates the projectile is in position at the MPRS.
P-31 *Fiber Optic Sensor Indicates the fuze and burster are conveyed to the DFS feed
gate to cause the feed gate to cycle
301 Al lnductive Proxirnity Sensor Indicates the Projectile Positioning Cylinder is fully
extended and the V-plate is raised.
30lBl Inductive Proximity Sensor Indicates the Projectile Positioning Cylinder is fully
retracted and the V-plate is "down."
3024 Induct ve Proxim ty Sensor Indicates the Pro ectile Hold Down Cylinder is extended.
3028 Induct ve Proxim ty Sensor Indicates the Pro ectile Hold Down Cylinder is retracted.
303Ar Inductive Proxirnity Sensor Indicates the MPR Carriage Cylincler is extended and
carriage is in "horne" position.
3038r Inductive Proxirnity Sensor Indicates the MPR Cariage Cylinder is retracted and
carriage is in fullv "fbrward" position.
303C I Inductive Proximity Sensor, 5mm
range
lndicates the MPR Carriage is in mid-position.
Attachrnent -14 - Page 69
Demi I it arization M i scellaneous TreatmJ:;#I
June 2009
Table 14-4-2
PROJECTILE/MORTAR DISASSEMBLY MACHINE SENSORS
Sensor Tag Sensor Type Functional Description
303Dr Inductive Proximity Sensor, 5mm
rallge
Indicates the MPR Carriage is in position to begin bakelite
fuze well cup cutting sequence (for Ml l0 proiectiles only).
304A1 Inductive Proximity Sensor Indicates the Fuze Well Cup Collet Release Cylinder is
extended to release Collet.
3048'Inductive Proximity Sensor Indicates the Fuze Well Cup Collet Release Cylinder is
retracted to set the Collet.
304C'Inductive Proximity Sensor Indicates BRAD is extended to rotate burster.
30gAl Inductive Proximity Sensor, 5mm
range
Indicates the Air-Probe Cylinder is extended (M I 2l Al
only).
3O8B I Inductive Proximity Sensor, 5mm
range
Indicates the Air-Probe Cylinder is retracted (M l2l Al
only).
P-4*r Inductive Proximity Sensor, 35mm
range
Indicates a projectile is in correct position at the BRS.
401Al Inductive Proximity Sensor Indicates the Projectile Positioning Cylinder is fully
extended and the V-plate is "raised."
40lB'Inductive Proximity Sensor Indicates the Projectile Positioning Cylinder is fully
retracted and the V-plate is "down."
402A'Inductive Proximity Sensor, 5mm
range
Indicates the BRS Carriage is fully extended (forward).
40281 Inductive Proximity Sensor, 5mm
range
Indicates the BRS Carriage is in the retracted position.
402C1 Inductive Proximity Sensor, lOmm
range
Indicates the BRS Carriage has retracted to the rnid-
position to allow the burster to be gripped by the Burster
Gripper.
403A* I Inductive Proxirnity Sensor, I Ornrn
range
Indicates the Delta-P Cylinder is fully extended.
4038* I Inductive Proxirnity Sensor, I Ornrn
range
lndicates the Delta-P Cylinder has fully retracted to the
"f'ailed to Extract Burster" position.
403Cr Inductive Proximity Sensor, lOmm
range
Indicates the Delta-P Cylinder head has retracted paft way
to the "Air Offl' position and extended part way to the
"Collet Released" position.
404A1 Inductive Proximity Sensor Indicates the Burster Conveyor Lift Cylinder is f'ully
extended and the Burster Conveyor is in the "lowered"
position.
4048'Inductive Proximity Sensor Indicates the Burster Conveyor Lift Cylinder is fully
retracted and the Burster Conveyor is in the "raised"
position.
405A I Inductive Proxirnity Sensor Indicates the Burster Gripper Cylinder is extendecl and jaws
are '!closed. "
4058 I Inductive Proximity Sensor Indicates the Burster Gripper Cylinder is retracted and jaws
are ttopen.tt
406A1 Inductive Proxirnity Sensor, 1 Ornm
range
Indicates the Burster Gripper Assembly is in position over
the burster.
4068 I Inductive Proxirnity Sensor, I Ornrn
range
Indicates the Burster Gripper Assernbly is in its "Home"
position over the BSR chute.
PMD-ENC-I *Transfer Conveyor Optical Encoder (20904\
300v I 2-way solenoid valve, normally
closed
Used to provide 100 psi compressed air to the MPRS Air
Blast Tube.
300v2 r 2-way solenoid valve, normally
cl osed
Used to provide 300 psi cornpressed air to the MPRS Air
Blast Tube.
308VA l 4-way, two position, solenoid valve Used to provide 100 psi compressed air to extend and
I
retract the MPRS Air-Prohg{Ml !?1A1). I
400v I Z-way solenoid valve, normally
closed
Used to provide 100 psi compressed air to the BRS Delta-P
I
Head Assernbly (and 300 psi cornpresse{ qir jn when
I
o
Attachrnent - l4 - Page 70
TOCDF
Demi I i t anzation M i scel I an eou s Treatmen t Un i ts
June 2409
Table 14-4-2
PROJECTILE/MORTAR DISASSEMBLY MACHINE SENSORS
Sensor Tag Sensor Type Functional Description
operated with 400V3).
40oY2l 2-way solenoid valve, normally
closed
Used to vent 100 psi or 300 psi compressed air from the
Delta-P Head Assembly.
400v3 '2-way solenoid valve, normally
closed
Used to provide 300 psi compressed air to the BRS Delta-P
Head Assembly.
PLS-4XI
(PMD-r0l)
Inductive Proximity Sensor Indicates that the pusher is at the home position. This
information is also used to reset the pusher position optical
encoder.
RSM.ENC-I*,
(PMD-I0l)
Optical Encoder BSR Pusher Optical Encoder
4l-2-ZTl
(PMD-I02)
Pusher Cylinder Linear Position
Transducer
Indicates position of burster pusher hydraulic cylinder.
PLS-7*
PLS-8*
PLS.9*
Inductive Proximity Sensor All three switches (PLS -7,8, and 9) are installed and used
only during Burster Size Reduction operations. Each
switch indicates that the burster is present in that particular
zone of the burster chute. The system requires that the
burster must make two of three switches before they are
indexed forward to the shear station.
Notes:
BRAD = Burster Rotating Adapter Device
BRS: Burster Rernoval Systern
BSR: Burster Size Reducer
MPR: Miscellaneous Parts Rernoval
MPRS: Miscellaneous Parts Removal Station
NCR: Nose Closure Removal
NCRS: Nose Closure Rernoval Systern
PLC : Programmable Logic Controller
Psi = Pounds per Square Inch
o : Critical Sensor or Interlock that must be functional when the associated miscellaneous unit is operating.
.'Not used during 4.2inchHTmortarprocessing.
Attachrnent - 14 - Page 7l
TOCDF
Demi I it anzation M i scel I aneou s Treatment Un i ts
June 2009
Table 14-5-1
SUMMARY OF MULTIPURPOSE DEMILITARIZATION MACIIINE AND PICK AND PLACE MACIIINE
SENSORS, 155 mm H Projectile MDM-101, MDM-102 & MDM-103!
Sensor
Type Sensor Tugo Location of
Sensor Functional Description
Proximity
Detector
4s-l-100c
45-2-100c
45-3-100C
Corresponding
MDM Index Table
Indicates the MDM's Index Table is properly aligned within the
MDM.
NAMCO
Switch
45-l-l0rA/B
4s-2-l0t NB
4s-3-l0 t A/B
Corresponding
MDM Index Table Senses when projectile slide cylinder #l is extended/retracted.
Proximity
Detector
45-1-101C*
45-2-t0lc*
45-3-10l c*
MDM-101 Sta. I
MDM-102 Sta. 1
MDM-103 Sta. I
Senses when a munition is at the LUS.
Fiber Optic
Sensor
45-t- l0l D*MDM-l0l Sta. I Senses the presence of a crimped burster well at the LUS during
the reinsert mode.
NAMCO
Switch
45-t-401A/B MDM-lOl Sta. 4
Senses when projectile slide cylinder #4 is extended/retracted.45-2-401AlB MDM-102 Sta. 4
45-3-401AlB MDM-103 Sta. 4
NAMCO
Switch
4s-t-402N8 MDM-l0l Sta. 4 Senses when the projectile clamp cylinder is extended/ retracted.
45-2-4028 MDM-102 Sta. 4 Senses when the proiectile clamp is retracted
45-3-4028 MDM-I03 Sta. 4 Senses when the proiectile clamp is retracted
Fiber Optic
Sensor
45-ZS-9203 MDM-102 Sta. 4 Senses proj ectile defbnnati on
45-ZS-9303 MDM-103 Sta. 4 Senses proi ectile defonnation
Pressure
Switch
4s-t-402c MDM- l0l Sta. 4
Senses when the projectile clarnps are clamped.45-2-402C MDM-I02 Sta. 4
45-3-402C MDM-103 Sta. 4
NAMCO
Switch 4s-t-403AlB MDM-I01 Sta. 4 Senses when the boring head feed cylinder is fully
extended/retracted.
Hall Effect
Switch
45-Z3-9201A/B MDM- 102 Sta. 4
Senses when the burster probe cylinder is fully extended/retracted45-ZS-9301AlB MDM-103 Sta. 4
NAMCO
Switch
45-t-404N8*MDM-l0l Sta. 4 Senses when the burster probe is extended or retracted.ffi
ffi1l $
u
NAMCO
Switch
4s-t-406N8 MDM-101 Sta. 4 Senses when the plus transition chute is extended/retracted.
[l-t11i1+t1,11ffi
',t!,i
|1ffifl .Etrt[
Vaccon
Vacuum
Switch
4s-1-407 MDM- l0l Sta. 4 Verifies that a plug is present in the socket assernbly.
it ilji!
i:,fr1ii ,: fl,l...H H
NAMCO
Switch
45-t-501A/B MDM-101 Sta. 5 Senses when the proiectile slide cylinder #5 is extended/retracted.
+lffirB '"ffit*ilifr;ff,f$ iiffi$iffi
'll ffi
NAMCO
Switch
4s-t-s02NB MDM-l0l Sta. 5 Senses when the proiectile lift cvlinder is extended/retracted.
,il{iii#,iiii!;iiii j,;i!.;'#ffi
*#ffi
NAMCO
Switch 45-1-5034/B 18{,2 MDM-I01 Sta. 5 Senses when the carriage cylinder is extended/retracted.
Hall Effect
Switch
45-ZS-9202,\MDM- 102 Sta. 4
Senses when the punch probe cylinder is extended4s-zs-9302,\MDM-103 Sta.4
4s-zs-92028 MDM-I02 Sta. 4 Senses when the punch probe cylinder is retracted45-ZS-93028 MDM-103 Sta.4
NAMCO 45-2-4038 MDM- 102 Sta. 4 Senses when the punch cylinder is retracted
Attachrnent - 14 - Page 12
TOCDF
Demil i t anzation M i scell aneous Treatment Uni ts
June 2009
Table 14-5-1
SUMMARY OF MULTIPURPOSE DEMILITARIZATION MACHINE AND PICK AND PLACE MACHINE
SENSORS, 155 mm H Projectite MDM-101, MDM-102 & MDM-103"
Sensor
Type Sensor Tugo Location of
Sensor Functional Description
Switch 45-3-4038 MDM- 103 Sta.4
NAMCO
45-r-504A/B t&2 MDM-lOl Sta. 5 Senses when the pull cylinder is extended/retracted.
45-2-403A*MDM-I02 Sta. 4
Senses when the punch cylinder is extended
45-3-403A*MDM-103 Sta. 4
Proximity
Detector
45-t-504C*MDM-l0l Sta.5 Senses burster well when pulled.
NAMCO
Switch
45-t-s05A/B MDM-l0l Sta. 5 Senses when the collet set cylinder is extended/retracted.
NAMCO
Switch
45-t-s0sc MDM-l0l Sta. 5 Senses when the collet is set in the burster well.
NAMCO
Switch
4s-1-s064/B MDM-lOl Sta. 5
Senses when the drip pan cylinder (pull Station) is
extended/retracted.
NAMCO
Switch
4s-1-s07 NB MDM-101 Sta. 5 Senses when the burster well chute cylinder is extended/retracted.
ffi
NAMCO
Switch
4s-t-s09A/B MDM-101 Sta. 5
Senses when the drip pan cylinder (Drain Station) is
extended/retracted.
NAMCO
Switch
45-t-510A/B*MDM-l0l Sta. 5 Senses when the drain tube cylinder is extended/retracted.
ffi,.J
Proxirnity
Sensor
45-t-510c*MDM-l0l Sta. 5 Senses when the drain tube is at the bottom of the munition.
NAMCO
Switch
45-t-601A/B MDM-l0l Sta. 6 Senses when the proiectile sl de cylinder #6 s extended/retracted.
NAMCO
Switch
4s-t-602N8 MDM-101 Sta. 6 Senses when the burster well lift cvlinder is extended/retracted.
ffi
NAMCO
Switch
4s-1-603A/B MDM-101 Sta. 6 Senses when the collet set cylinder is extended/retracted.
Pressure
Switch
4s-t-603c MDM-l0l Sta. 6 Senses when the collet is set in the burster well.
NAMCO
Switch
4s-t-604NB,MDM-101 Sta. 6 Senses when the burster well crimp cylinder s extended/retracted.
iiiif,lilll++irli
Attachment -14 - Page73
7
o
TOCDF
Demi I i t arization M i scel I an eou s Treatment Un i ts
June 2009
Table 14-5-1
SUMMARY OF MULTIPURPOSE DEMILITARIZATION MACHINE AND PICK AND PLACE MACHINE
SENSORS, 155 mm H Projectile MDM-101, MDM-102 & MDM-103"
Sensor
Tvpe Sensor Tug"Location of
Sensor Functional Description
Notes:
u Currently, MDM-I01 is configured to process 4.2-inch mortars whereas MDM-I02 and MDM-103 are configured to process
155-mm projectiles. Because the MDM processing of I 55-mm projectiles is limited to the burster well punch step only, the
majority of the instruments at MDM- I 02 and MDM- I 03 are not active, as indicated in the shaded cells of this table.
b Sensor tags specifo which MDM the instrument serves (45- I -XXXA/B or C is at MDM- I 0l , 45-2-XXXNB or C is at MDM-
102, etc.)
LUS : Load/Unload Station
MDM = Multipurpose Dernilitarization Machine
* = Critical Sensor or Interlock that must be functional when the associated miscellaneous unit is operating.
Table l4-5-la
SUMMARY OF MULTIPURPOSE DEMILITARIZATION MACHINE AND PICK AND PLACE MACHINE SENSORS,
4.2" HT Mortars MDM-101, MDM-102 & MDM-103!
Sensor Type Sensor Tugo Location of
Sensor Functional Description
Proximity
Detector
45-t- l00c Corresponding
MDM Index Table
lndicates the MDM's Index Table is properly aligned within the
MDM.45-2-100C
45-3-100C
NAMCO
Switch
45-t- l01A/rl Corresponding
MDM Index Table Senses when projectile slide cylinder #1 is extended/retracted.45-2-10l A/B
45-3-10 r A/B
Proxirnity
Detector
45-t- I 0l c*MDM-l0l Sta. I
Senses when a munition is at the LUS.45-2- I 0l C*MDM-102 Sta. I
45-3- I 0l C*MDM-103 Sta. I
NAMCO
Switch 45-t-402Nt)MDM-l0l Sta. 4 Senses when the projectile clamp cylinder is extended/ retracted.
NAMCO
Switch 45-t-403tuu MDM-101 Sta. 4 Senses when the boring head feed cylinder is fully
extended/retracted.
NAMCO
Switch 45-1-404NB-*MDM-101 Sta. 4 Senses when the burster probe is extended or retracted.
NAMCO
Switch 45-t -406Nt)MDM-l0l Sta. 4 Senses when the plug transition chute is extended/retracted.
Vaccon
Vacuum
Switch
45-t -407 MDM- l0l Sta. 4 Verifies that a plug is present in the socket assembly.
NAMCO
Switch
45-t -50 r A/B
45-2-501 A/rl
45-3-50 r A/B
MDM
MDM
MDM
0l Sta. 5
02 Sta. 5
03 Sta. 5
Senses when the projectile slide cylinder #5 is extended/retracted.
NAMCO
Switch
45-t-502NF-
45-2-s02NB
45-3-s02NB
MDM
MDM
MDM
0l Sta. 5
02 Sta. 5
03 Sta. 5
Senses when the projectile lift cylinder is extended/retracted.
NAMCO
Switch
45-1-5034/8 t &2 MDM-0l Sta. 5
Senses when the carriage cylinder is extended/retracted.45-2-s03AlB t &2 MDM-02 Sta.5
4s-3-s03A/B I &2 MDM-03 Sta.5
NAMCO
45-l-504A/B t &2 MDM-0l Sta. 5
Senses when the pull cylinder is extendediretracted.45-2-s04NB t&2 MDM-02 Sta.5
45-3-504NB- | &2 MDM-03 Sta.5
Proxirnity
Detector
45-t-504C*MDM-0l Sta. 5 Senses burster well when pulled.
45-t-504C*MDM.02 Sta.5
Attdchrnent -14 - Page74
\
o
TOCDF
Demi I i t anzation M i scel I an eous Treatmen t Uni ts
June 2009
Table 14-5-1a
SUMMARY OF MULTIPURPOSE DEMILITARIZATION MACHINE AND PICK AND PLACE MACHINE SENSORS,
4.2" H^f Mortars MDM-101, MDM-102 & MDM-103I
Sensor Type Sensor Tugo Location of
Sensor Functional Description
45-t-504C*MDM-10 Sta. 5
NAMCO
Switch
45-t-50sA/B MDM-l0l Sta. 5
Senses when the collet set cylinder is extended/retracted.45-2-s0sAlB MDM-102 Sta. 5
45-3-505A/B MDM-103 Sta. 5
NAMCO
Switch
4s-t-s0sc MDM-101 Sta. 5
Senses when the collet is set in the burster well.4s-2-505C MDM-I02 Sta. 5
4s-3-s05c MDM-103 Sta. 5
NAMCO
Switch
45-r-5064/8 MDM-101 Sta.5
Senses when the drip pan cylinder (pull Station) is
extended/retracted.45-2-506N8 MDM-102 Sta. 5
45-3-506N8 MDM-103 Sta. 5
NAMCO
Switch
45-l-507 NB MDM-101 Sta. 5
Senses when the burster well chute cylinder is extended/retracted.45-2-507 NB MDM-102 Sta. 5
4s-3-s07 NB MDM-I03 Sta. 5
NAMCO
Switch
4s-t-sOeA/B MDM-l0l Sta. 5
Senses when the drip pan cylinder (Drain Station) is
extendediretracted.45-2-509N8 MDM- 102 Sta. 5
45-3-509N8 MDM-103 Sta. 5
NAMCO
Switch
45-t-5 lOA/B*MDM-101 Sta. 5
Senses when the drain tube cylinder is extended/retracted.45-2-510AlB*MDM-I02 Sta. 5
45-3-510A/B*MDM-103 Sta. 5
Proximity
Sensor
45-t-510c*MDM-l0l Sta. 5
Senses when the drain tube is at the bottom of the munition.45-2-51OCx MDM-I02 Sta. 5
45-2-510C*MDM-103 Sta. 5
Notes:
" MDM configuration for 4.2" HT Mortar processing. Note MDM-l0l includes a functioning station 4 (bore station) to allow
removal of burster wells that are welded in-place. Station 4 is not used on MDM-102 and -103. Station 6 is not used on any MDM
since 4.2" HT burster well are not crimped or placed back into the drained mortar. Burster wells are removed and transferred to
an accumulation container which is fed to the MPF with each tray of 4.2" Mortars.
bSensortagsspecifiwhichMDMtheinstrumentserves(45-1-XXXA/BorCisatMDM-101,4i-}-XXXNBoTC isatMDM-
102, etc.)
LUS = Load/Unload Station
MDM = Multipulpose Dernilitarization Machine
* = Critical Sensor or Interlock that must be functional when the associated miscellaneous unit is operating.
Attachrnent - 14 - Page 75
Demilit anzation M i scel I aneous TreatmJ:;il
June 2009
MULTIPURPOSE I
Table 14-5-2
)EMILITARIZATION MACHINE AND PICK AND PLA CE MACHINE CRITICAL SENSORS
AND INTERLOCKS
Sensor Tag
I
I
I
Functional Description
Senses munition tray at Line
A, MDM-IOI
Interlock
Conveyor MDM-CNVP-l0l
45-10-25-170 Proximity Detector Senses munition tray at Line
A, MDM-102
Conveyor MDM-CNVP-103
45-10-25- t 60 Proximity Detector Senses munition tray at Line
A, MDM-I03
Conveyor MDM-CNVP- 1 05
45-10-25-254 Proximity Detector Senses munition tray at Line
B, MDM-IOI
Conveyor MDM-CNVP -102
45-t0-25-270 Proximity Detector Senses munition tray at Line
B, MDM -IO2
Conveyor MDM-CNVP-104
45-t0-25-260 Proximity Detector Senses munition tray at Line
B, MDM-103
Conveyor MDM-CNVP-106
Table 14-6-l
Reserved
Attachrnent - 14 - Page I6
o
TOCDF
Tank Systems
March 2007
Or
ATTACHMENT 16
TANK SYSTEMS
\,^
Attachment 16 - Page r
TOCDF
Tank Systans
March 2007
Table of Contents
Table of Contents
List of Tables
List of Acronyms
16.1 Introduction
16.2 Extemal Corrosion Protection
16.3 Description Of Feed Systems, Saf*y Cutofl Bypass Systems, and Pressure Control
16.3.2 Common Tank Components
16.3.3 TOCDF Agent Collection Tank System
16.3.4 TOCDF Spent Decontamination Tank System
16.3.5 TOCDF Brine Reduction Area Tank System
16.3.6 ATLIC Lewisite Collection Tank System
16.3.7 ATLIC Spsnt Decontamination Tank System
16.3.8 ATLIC Nitric Acid Holding Tenk Systern
16.4 Plans and Description Of The Design, Construction, and Operations Of The Secondary
Containment System For Each Tank System
16.4.5 TOCDF Agent Collection Tank System
16.4.6 TOCDF Spent Decontamination Tank System
16.4.7 External Liner Common Elements
16.4.8 TOCDF Brine Reduction Area Tank System
16.4.9 ATLIC Tank System Secondary Containment
16.5 Tank Age Determination
16.6 Tank System Secondary Containment Requirements
16.7 Tank System Leak Detection Requirements
16.8 AncillaryEquipment Secondary Containment Requirements
Attachment 16 - Page rr
-/
TOCDF
Tank Systems
March 2007
16.9 Ancillary Equipment Leak Detection Requirements
16.10 Tank System Managemeflt Practices
!
16.10.1 Management of.Incompatible Wastes in Tanls
16.10.2 Management of Ignitable or Reactive Wastes in Tanks
1 6.1 0.3 General Operating Requirements
List of Tables
16-1 TOCDF Agent Collection System Storage Tanks
16-2 TOCDF Spent Decontamination Holding Tank System
16-3 TOCDF Brine Storage Tank System
16-4 ATLIC Lewisite Agent Collection System Storage Tanks
16-5 ATLIQ Spent Decontamination System Storage Tarrk
16-6 ATLIC Nitric Acid Holding System Storage Tanks
\
Attachment 16 - Page ru
List of Acronyms
ACS Agent Collection System
AQS Agent Quantification System
ATLIQ Area l0 Li$lid lncinerator
BDS Bulk Drain Station
BRA Brine Reduction Area
CRO Control Room Operator
DFS Deactivation Furnace System
ECR Explosive Containment Room
ECV Explosive Containment Room Vestibule
ICU Intermittent Containment Unit
LIC Liquid Incinerator
MDB Munitions Demilrtanzation Building
MDM Multipurpose Demilrtanzation Machine
MPB Munition Processing Bay
MPF Metal Parts Furnace
NFPA National Fire Protection Association
PAS Pollution Abatement System
PDARS Process Data Acquisition and Recording System
PLC Programmable Logic Controller
RCRA Resource Conservation Recovery Act
SDS Spent Decontamination System
TMA Toxic Maintenance Area
TOCDF Tooele Chemical Agent Disposal Facility
TOX Toxic Cubicle
TSDF Treatment Storage and Disposal Facility
TOCDF
Tank Systems
March 2007
_a
Attachment 16 - Page iv
16.1
16.1.1
16.1 .1 .1
TOCDF
'ilHiliffi;
INTRODUCTION
Tooele Chemical Agent Disposal Facility (TOCDF) nunages liquid hazardous wastes in
three different tank systems:
Agent Collection System (ACS): Consisting of ACS-TANK-IOI, ACS-TANK-
102 and ancillary equipment (See Table 16-1 for design specifications). These tanks
receive and accumulate the chemical agent that is drained from the munitions and bulk
containers processed at the TOCDF. The collected agent is sent from the ACS tanks to
the primary chamber of the Liquid Incinerators.
Spent Decontamination Systern (SDS): Consisting of SDS-TANK-I01, SDS-
TANK-102, SDS-TANK-103, and ancillary equipment (See Table 16-2 for design
specifications). These tanks receive and accumulate spent decontamination solution
generated within the Munitions DemilitarizationBuilding (MDB) during maintenance
activities. As solutions are sprayed over the area or equipment being decontaminated,
spent solutions collect in double lined sumps (referred to as Intermittent Collection Units
[ICU] because of the management constraints placed upon them through RCRA Permit
conditions). From the ICU the spent decontamination solution is pumped to the SDS
tanks. Spent decontamination solutions is sent from the SDS Tanks to the secondary
chamber of the Liquid Incinerators. One SDS tank is left empty when chemical agent is
being processed inside the MDB and is to be used as storage in case there is an agent spill.
Brine Reduction Area (BRA) Tank Svstem: ConsiSting of BRA-TANK-101,
BRA-TANK- 1 02, BRA-TANK-20 1, BRA-TANK -202, ard ancillary equipment (See
Table 16-3 for design specifications). The BRA tanks receive and accumulate spent
scrubber brines generated by the Pollution Abatement Systems associated with the Liquid
Incinerators, Metal Parts Fumace, and Deactivation Fumace System. From the BRA
tanks, spent scrubber brine is either treated onsite in the BRA or transferred to tankers for
transport to an offsite Treatment Storage and Disposal Facility (TSDF).
16.1 .1.2
16.1 .1 .3
16.1.2 ATLIC manaees liquid hazardous wastes in three different tank systems: 'l
16.1.2.1 LewisiteCollectionSystem(LCS): Consistineofhilotanls.LCS-TAI.{K-8511and-8534.
and ancillary egipment (See Table 16,4 for desien specifications). LCS-TANK-8511
receives and accumulates the chanical aeent that is drained from Lewisite ton containers
processed through the ATLIC glove-boxes. The collected asent is sent from the LCS
tanks to the primary chamber of the ATLIC LIC. LCS-TANK-8534 is maintained ernpt],
and used for the collection of major spills that occur in the ATLIC.
16.1.2.2 Spent Decontamination Syste.m (SDS): Consistine of one SDS tank. SDS-TANK-8523.
and ancillary equipment (See Table 16-5 for desien specifications). This tank receives
and accumulates soent decontamination solution rinse water eenerated from the processine
of GA ton containers. rinse water generated from the processing of Lewisite ton
containers. and spent decontamination solution eenerated from maintenance activities
within the AILIC. Sumps are located in the ATLIC Toxic Area Room. the ATLIC
LIC Room. the Level B. and Level A Airlocks. Each area's floor is sloped such
that the spent decon solution is collected in below-srade sumBs constructed of
co+crete with a steel Ban placed within the concrete sumo. The steel pan is lined
\
Attachment l6 - Page I
TOCDF
Tank Systerns
March 2007
with a protective liner compatible with the materials that are in the area. From
these sumps (or ICUs) the spent decontamination solution is pumped to the SDS tanks.
and from the tanks to the secondary chamber of the Liquid Incinerator.
16.1.2.3 Nitric Acid Holdine Tank System (NSF): Consisting of two tanks. NSF-TANK-8514 and
LCS-TANK-8516. and ancillary equipment (See Table 16:6 for design specifications).
These tanks receive and accumulate the corrosive and hish metals content waste stream
generated from the rinsine out of L TCs.
16.1.2.4 Brine Holding Tank System: The three brine holding tanks. which receive spent scrubber
brines generated by the ATLIC Pollution Abatement System. are rnanaged as less than 90-
day accumulation tanks. The spent scrubber brine is transfeired to tankers for transport to
an offsite Treatment Storage and Disposal Facility (TSDF).
16.1.2.5. Less Than (<) Waste Control Limit Spent Nitric Acid Tank: Consisting of one holding
tank which receives Spent Nitric Acid. This tank (PAS-Tank-8569) is manaeed as a less
than 90-day accumulation tank. Note onlv Spent Nitric Acid having a Lewisite
concentration of less than the Waste Control Limit of 200 parts oer billion (ppb) is
transferred to this tank.
16.2
With the exception of the TOCDF BRA tanks, which are located outside on concrete pads,
all of the hazardous waste tanks at TOCDF are located inside and are not extemally
exposed to soil or precipitation. The exterior of the BRA tanks is painted for protection
against atmospheric conditions. Flat-bottomed tanks that are permitted to store hazardous
waste are supported above their respective concrete pads to allow for leak detection. All
tanks are painted for protection from rusting and atmospheric conditions. Painting
specifications and other information on external corrosion protection are maintained at the
site, and are available for inspection upon request. The integrity of the tank systems is
ensured by the corrosion protection coatings and inspections. The tanks are located above
ground and are set on concrete pads or are elevated to assist in visual inspection.
Specifically, the TOCDF ACS tanks are constructed of carbon steel and coated with an
epoxy paint system on the outside surface. The TOCDF SDS tanks are carbon steel tanks
coated with an epoxy paint system on the outside surface. The TOCDF BRA tanks are
carbon steel tanks lined with modified epoxy and coated with the manufacturer's standard
coating. The TOCDF ACS-TANK-I02 andthe SDS tanks are supported above the floor
on epoxy-coated steel legs. ACS-TANK-101 is supported above the floor by steel
supports attached to the first floor platform. The legs are supported above the floor on
concrete pads. Small spills are decontaminated and flushed with water as quickly as
practical. Any spills and wash down liquids will drain away from the tanks and support
legs to the sumps. Because the tanks and steel support legs are not normally exposed to
liquids, exterior corrosion measures, such as cathodic protection, are not necessary. The
BRA tanks are supported above ground on a concrete pad. Spills are handled in the
manner previously described.
16.2.1
16.2.3. All hazardous waste storase and treatment tanks located at the ATLIC are within the Area
10 igloo which houses the ATLIC or within the Environmental Enclosure that is attached
to the igloo. All ATLIC permitted hazardous waste storage and treatment tanks are
16.2.2
Attachment l6-Page2
TOCDF
Tank Systerns
elevated above theflgp{ by steel supports. LCS-Tar:k-8S11 is the onlyoermitted
hazardous waste storiqb and trgatment tankthat is made of carbon steel. The exterior
of this tank is oailrted with an epoxy coating. All other ATLIC storage and treatment
tanks are made of stainless steel.
16.3 DESCRIPTIONS OF FEED SYSTEMS. SAFETY CUTOFF. BYPASS SYSTEMS.
AND PRESSURE CONTROI. taO -CFR 264.19a6X2) and 270.16(c)J
16.3.1 The following paragraphs discuss feed systems, safety cutofl blpass systems and pressure
control for the TOCDF and ATLIC tank systerns. General information that is applicable
to more than one system is given, as well as specific information for the fOCDE ACS,
SDS, and BRA tanks. and the ATLIC LCS. SDS. and NSF tanks. These controls are
described further in the Piping and Instrumentation Diagram drawings that are included in
Attachment 11 (General Facility Drawings) of this Permit.
16.3.2 Common Tank Components
16.3.2.1 fhe following description applies to the two TOCDF tanks for agent collection, ACS-
TANK-I01 and -I02; the three tanks for spent decontamination solution, SDS-TANK-
101, -102, and -103; and the four tanks for brine, BRA-TANK-101, -102, -201, and -202.
16.3.2.2 All of the tanks have a level transmitter that provides both low- and high-level alarms to
the Process Data Acquisition and Recording System (PDARS). A listing of the
instruments for the tanks, piping, and valving follows:
16.3.2.2.1 Tank level transmittersr indicating an alarm at low'level and highJevel.
16.3.2.2.2 Tank-level switches indicating an alarm at low-low level and high-high level.
16.3.2.2.3 Valvepositionswitches.
16.3.2.2.4 Strainer differential pressure transmitters are part of the Agent and Spent Decontamination
Tank Systems.
16.3.2.2.5 Liquid flow control.
16.3.2.2.6 Liquid flow pressure indicator and transmitter.
16.3.2.2.7 Mass flow measurement and transmitter.
16.3.2.3 All TOCDF tanks are at atmospheric pressure and pressure is not measured. Temperature
of liquids is ambient and is not measured in the ACS and SDS tanks. Temperature is
measured in the BRA tanks to provide input to the temperature compensating level
indicators. Flows to the tanks are not measured. Liquid level monitoring and alarms in
the Agent Collection and Spent Decontamination Tanks are provided by either an
ultrasonic level transmitter or a radar level transmitter.
I NOTE: Tank transmitters indicate low and high level alarms while tank switches indicate low-low and high-high
levels.
Attachrnent l6 - Page 3
16.3.3
16.3.3.1
16.3.3.2
16.3 .3.3
16.3.3.4
16.3.3.s
16.3.3.6
TOCDF
'ffi:.:niffi;
TOCDF Agent Collection Tank System
Reserved
Agent collected from bulk munitions at the TOCDF bulk drain stations is routed to ACS-
TANKS-101 or 102 via an unpocketed line to agent pumps ACS-PUMP-I14 and 115.
Accompanying the drain process is a bubbler t1,pe level measurement system that indicates
the drain status of the munition when the maximum amount of agent is drained. The
drain/bubbler probe is purged with air to remove any residual agent before retraction from
the munition. The amount of agent removed from the munition is quantified by weighing
the munition before and after the draining operation is completed.
Three air-operated diaphragm agent pumps, ACS-PUMP-105, 106, and 107, pump agent
drained from the munitions to either TOCpE ACS-TANK-I01 or 102. Operation of these
agent pump(s) induces a vacuum in the AQS system that is controlled by opening and
closing isolation valves. The vacuum enables the draining of agent from the munitions.
Accompanying the drain process is a bubbler type level measurement system that indicates
when the drain process is complete.
The TOCDF ACS-TANK-IOI and ACS-TANK-102, the agent holding tanks, are the
primary tanks for demilitarization operations. When a tank has been selected to fill and
the system is placed in automatic, the inlet valve is opened and'draining is permitted to
proceed. In order to allow draining of agent to be initiated, an inlet valve must be open
and the corresponding tank cannot be at a high level (corresponding to the maximum
allowable volume of 500 gallons for ACS-TANK-l0l and 1130 gallons for ACS-TANK-
102). If these conditions do not exist for one of the tanks, no additional munitions shall be
drained. Should both TOCDF tanks reach their high-high levels, all draining activities
shall automatically cease. An alarm shall sound in the control room if either tank reaches
its high-high level. Once draining activities are discontinued because of lack of storage
volume, demilitarization processing shall not begin until one of the tanks has sufficient
capacity to collect the drained agent. When the tank is filled to a preset level, a highJevel
alarm sounds in the control room to alert the operator. If the level in the tank continues to
rise until a high-high level is reached, the control system automatically closes the inlet
valve to the tank and stops draining operations.
The venting of TOCDF agent tanks is controlled by pressure differentials without the need
for manual switching of vents. Vapors from the agent tanks escape through a conservation
breather vent on TOCDF ACS-TANK-I02, still within the TOX. The TOX is a level A
area and is maintained at negative pressure. Vapors passing through the conservation
breather vent will combine with TOX ventilation air and be drawn through the exhaust
carbon filter units.
In the event ofa rapid pressure buildup, such as during a fire, the vent is sized large
enough to handle the expected agent vaporizationrate. A rupture disk, rated at 15 psig
and vented to the TOX, is installed on TOCDF ACS-TANK-I01. The rupture disk is
located inanozzle.
Adjacent to the rupture disk, in a separate nozzle, is a vacuum relief valve set at 10 psia.
If agent is pumped from the tank at a rate faster than it is supplied to the tank by the drain
16.3.3.J
Attachrnent l6 - Page 4
16.3.3.8
16.3.3.9
16.3.3.10
16.3.4
16.3.4.1
t6.3.4.2
TOCDF
'ill:iliffi;
station, a vacuum in the tank may develop. This vacuum relief valve allows air to pass
into the tank from the TOX. It does not vent air out of the agent tanks.
Downstream of the strainers, the discharge lines from the TOCDF ACS-TANK-l01 and
ACS-TANK-I02 combine in a common line to the agent feed pump header. Two Liquid
lncinerator (LIC) agent feed pumps and a spare are provided. Each of the operating agent
feed pumps has a flow control loop that recirculates agent from the pump discharge line to
the pump inlet header. During normal operation, agent will be continuously recirculated
in the flow control loops since the design flow rate is lower than the rated capacity of the
pumps. Pressure safety valves are provided with each pump to recirculate agent from the
discharge to the pump inlet if the pressure at the pump discharge reaches a specified
setpoint. These pressure safety valves protect the pumps in case a downstream control or
manual valve is closed. When an Automatic Waste Feed Cut-Off occurs, the agent feed
pump providing feed to the effected LIC is shut down and a shutoff valve in the agent line
is closed.
A mass flow element, pressure-indicating transmitter, low pressure switch, and shutoff
valve are located on each agent line prior to penetration into the TOCDF primary LIC
room. Thgse instruments indicate low flow or low pressure in the agent line. If low flow
is sensed in the agent line downstream of the hgent pump, an alarm will qound in the
'control room and the agent lihe shutoff valve is closed. When lo'w pressure occurs in the
agent line an alarm will sound in the control room, the online pump is shut'down and the
spare pump is started. If a lowJow pressure is sensed in this line, the corresponding agent
feed pump is stopped.
A low pressure switch and two tight shutoff valves are also located on the agent line inside
the TOCDF primary LIC Room. If a low pressure is sensed in the agent line upstream of
the primary LIC, an alarm will sound in the control room and a signal is sent to the
corresponding LIC flame safety shutdown system. In addition, the shutoff valves are
closed, thereby stopping flow to the incinerator. The length of agent piping from the last
shutoff valve to the incinerator inlet (where the agent tank system terminates) is
minimized.
TOCDF Spent Decontamination Tank System
Each SDS tank has one vent to the SDS Room in order to maintain the tank at atmospheric
pressure. To allow for initiation of spent decontamination solution pumping, an inlet
valve to a SDS tank must be open and the tank cannot be at high level. If these conditions
do not exist, pumping is not initiated. When a tank has been selected to fill and the system
is placed on automatic, the inlet valve is opened and pumping is permitted to progress.
When the tank is filled to a preset level, the system switches automatically to the second
tank unless that tank indicates a maximum capacity level or the contents of the second
tank are being fed to the secondary chamber of one of the LICs. If the second tank
indicates a high maximum capacity level, or the contents of the second tank are being fed
to one of the LICs, the inlet valves to both filled tanks are closed and pumping operations
are halted. In addition to an alarm sounding during this condition, the control system
automatically closes the inlet valve to the tank and stops pumping operations. The third
tank shall be held in reserve to provide emergency storage in case there is an agent spill.
Attachrnent l6 - Page 5
16.3.5
16.3.5. 1
I t 6.3.5.2
16.3.5.3
16.3.5.4
I 6.3.5.5
16.3.5.6
TOCDF
Tank Systons
March 2007
TOCDF Brine Reduction Area Tank System
The TOCDF BRA tank system is composed of four brine storage tanks. Each brine
storage tank has one inlet for feed from the Pollution Abatement Systems (PASs).
Startup of the TOCDF incinerators ftoth LICs, Deactivation Furnace System (DFS), and
Metal Parts Furnace (MPF) and subsequent pumping of the brine from its PAS to the
brine surge tanks require that an outlet valve be closed (draining from tank) and that the
tank is not at high-high level. This will satisff the interlock and the inlet valve may be
opened. When a tank has been selected to fill and the system is placed on automatic, the
inlet valve is opened, and pumping is permitted to progress. When the tank is filled to the
high level, the programrnable logic controller (PLC) closes the inlet valve as well as
annunciates this condition to the Control Room Operator (CRO). This high level alarm
prompts the CRO to prepare the next tank to be filled. This condition (closed inlet valve)
can be blpassed by the CRO and filling can resume until the high-high level is reached.
The high-high level is hard-wired and cannot be bypassed by the CRO. When an inlet
valve closes, the PASs have approximately l0 minutes of surge capacrty within which the
CRO must select another brine tank to fill. If this operation is not successful (e.g., the
remaining three BRA tanks indicate high-high level, or two tanks indicate high-high level
and one is draining), the level will continue to rise until it reaches the high-high level on
the tank selected. At this point, an alarm sounds and an interlock stops feed to the
TOCDF MPF, DFS, andboth LICs.
If all of the BRA tanks are at high-high level, the LICs are immediately placed in an idle
state. This procedure shuts off the agent and spent decontamination solution feeds to both
LICs, reduces the production of brine, but keeps the LIC system in an idle condition for an
easy restart. Idle conditions are continued until the levels in the BRA tanks are such that
the LICs can resume operation. During LIC idle conditions, brine generation is
minimized.
The BRA tanks are protected from overfilling by level switches that close the brine inlet
valves upon reaching high-high level. In the event of instrument failure, tank overflow
outlets to the secondary containment system are provided.
Reserved
The TOCDF brine system also has a pump and associated piping used to load transport
tankers. This piping ties into a plastic lined pipe that exits the Process Utilities Building
(PUB) to the pipe rack west of the PUB. This pipe continues south in the overhead pipe
rack. This pipe enters a pipe trench that goes under the double fence to a load/unload
station. The brine is loaded into tankers which are transferred to an off-site TSDF for
further treatment and ultimate disposal. The pipe trench is concrete lined with removable
roof sections. The pipe trench floor and loading dock floor area and sump are coated with
a chemical resistant coating. The plastic lined pipe is equipped with weep holes. These
weep holes are connected to a common header. This header drains to a sump. If liquid is
indicated in the sump an alarm is activated in the control room.
TOCDF will transport the scrubber brine to a pre-approved off-site TSDF for disposal per
the TOCDF Waste Analysis Plan.
16.3.5.7
Attachrnent l6 - Page 6
TOCDF
Tank Systems
March 20A7
16.3.6. ATLIC Lewisite Collection Tank System (LCS)
I 6.3.6. 1 . The only chemical aeent that will be rnanaged by the LCS-Tank-85 1 1 is asent drained
from Lewisite ton containers. Note Agent GA is fed from the ton container directlyto the
ATLIC Primary Combustion Chamber.
16.3.6.2. The amount of l:ewisite drained from each ton container is not quantified. Lewisite ton
containers are drained to the maximum extent possible ffi
pumpable+Eien##llwhen the comoressed air used to pressurize the ton container during
draining blows through the ton container drain valve and the cyclingof the diaohrasm
LumLthat is used to drain the agent increases. which notes that there are no liquids
16.3.6.3. LCS-Tank-851 I is equipped with both radar type level indication transmitters (LIT) and
ultrasonic level switches. The LIT are used to determine the heieht of the liouid column
of aeent stored in the tank while the level switches are used to activate level low-low
&SLL) and level hieh-hish (LSHH) alarms. LSLL alarms stopJhe operation of the
selected waste feed pump which is used to feed the tank's contents to the LIC Primary
Combustion Chamber. LSHH alarms stop the operation of LDS-Pump-8503 which is
used to transfer Lewisite from ton containers to the LCS-Tank-8511. Activation of the
LSIIH alarm also automatically closes the inlet valve to the tank.
16.3.6.4. The amount of Lewisite transferred to LCS-Tank-8S11 is controlled from the control
room. The capacity of the tank is.such that the volume of a full tank is equival€nt to the
volume of six ton containers. The Control Room Ooerator can determine if there is
sufficient unused volume capacity in the tank to hold the contents of the next ton container
to be processed.
16.3.6.4. The LCS-Tank is opriltedat atmospheric pressure and the tank's vent is open to the
ATLIC Toxic Area which is a Level A area. Emissions from the LCS-Tank are captured
by the ATLIC Heating Veirtilation and Air Conditioning (HVAC) filters which
incorporate activated carbon as an adsorbine media.
16.3.6.5. A diaphragm pump (LDS-Pump-8503) is used to transfer Lewisite from the ton coptainer
to LCS-Tank-8511. The asent passes through a duplex strainer (LDS-FILT-8501 before it
reaches the tank. There is a diaphraem pump available for mixine the contents of the
tank LCS-Pump-8512. Lewisite is rernoved from the tank and fed to the Primary
Combustion Chamber of the ATLIC using variable frequency drive equipped waste feed
pumps WFS-Pump-8655 or 8656. The agent passes throush a basket strainer located prior
to the pumps. Pressure Differential Indicatins Transmitters (PDITs) associated with.
the strainers allows the ATLIC Control Room Operator to determine when a
strainer needs to be cleaned.
16.3.6.6. Major Spill Tank LCS-Tank-8534 is also included as part of the Lewisite Collection Tank
System. This tank does not have any pumps associated with it. m
ien
LCS-Tank-8534 can be filled with liouid
that accumulates in the Toxic Area Room Sump 107 usine SDS-Pump-8530. or bv
connectins a flex hose between the outnut of LCS-Pump-8522 (which services the
Attachment l6-Page7
ITOCDF
Tank Systerns
March 2007
bermed area that sunports the soent nitric acid tanks) and valve 1"-V-8636. Each
tank's piping systern is equipped with a t-connection that a flexible hose can be attached.
To transfer the contents of LCS-Tank-8534. a flexible hose is attached to the Major Spill
Tank t-connection and to the t-connection that the soill tank's contents are to be
transferred. The "destination" tank's circulation pump is then used to transfer the waste to
the desired tank.
t0,a,0,2, Uajer Sp i+
sutrffi{tffit
16.3.7. ATLIC Spent Decontamination Tank System (SDS)
16.3.7.1. The ATLIC SDS System tank SDS-Tank-8523 is used to accumulate spent
decontamination solution and rinse water generated from the processine of Aeent GA ton
containers. rinse water eenerated from orocessing of Lewisite and Transparency ton
containers. and soent decontamination solutions generated from ATLIC maintenance
activities.
16.3.7.2. SDS-Tank-8523 is equioped with both radar t),pe level indication transmitters (LIT) and
ultrasonic level switches. The LIT are used to determine the height of the liquid column
of agent stored in the tank while the level switches are used to activate level low-low
(LSLL) and level hieh-high [SHH) alarms. LSLL alarms stop the operation of the
selected waste feed pump which is used to feed the tank's contents to the LIC Secondary
Combustion Chamber. LSHH alarms stop the operation of LDS-Pump-8506 which is
used to transfer spent decontamination solutions and rinse waters to the SDS-Tank-8523.
Activation of the LSHH alarm also automaticallv closes the inlet valve to the tank.
16.3.7.3. The amount of spent decontamination solution transferred to SDS-Tank-8523 is controlled
from the control room. The Control Room Operator can determine if there is sufficient
unused volume caoacitv in the tank to hold the contents of the ton container that has been
rinsed.
16.3.7.4. The SDS-Tank is operated at atmosoheric pressure and the tank's vent is open to the
ATLIC Toxic Area which is a Level A area. Emissions from the SDS-Tank are captured
by the ATLIC HVAC filters which incomorate activated carbon as an adsorbine media.
16.3.7.5. A diaphragm oump (LDS-Pump-8506) is used to transfer spent decontamination solution
and rinse water from the ton containers to SDS-Tank-8523. The decontamination solution
and rinse water passes throueh a duplex strainer (LDS-FILT-8510) before it reaches the
tank. There is a diaphraem pump available for mixine the contents of the tank SDS-
Pumo-8524. After beins sampled and analvzed ner Attachment 2 of this permit the
The tank's contents are fed to the Secondary Combustion Chamber of the ATLIC usins
variable frequency drive equipped spent decon feed pumos SDF-Pump-8330 or 8340.
The waste feed oasses throush a basket strainer located prior to the pumps.
Nitric Acid Holdins Tank Svstem NSF)16.3.8.
Attachment l6 - Page 8
TOCDF
Tank Systems
March 2007
16.3.8.1. The Nitric Acid Holdine Tanks (NSF-Tank-8514 and LCS-Tank-8516) are used to store- and treat the metal laden corrosive waste steam that is eenerated during the rinsing out of
Lewisite TCs. This waste stream may contain Lewisite at concentration greater than the
WCL of 200 ppb. The treatment that may occur in this tank is limited to the addition of 3
Molar (M) sreater strength nitric acid to lower the Lewisite concentration to below the
WCL. NSF-Tank-8514 and LCS-Tank-8516 are located in the ATLIC Toxic Area and
like all the tanks located in this area vent freelv to the air within the Toxic Area. The
16.3.8.2. NSF-Tank-8514 and LCS-Tank-8516 are operated at atmospheric pressure and each
tank's vent is open to the ATLIC Toxic Area which is a Level A area. Emissions from
NSF-Tank-8514 and LCS-Tank-8516 are captured by the ATLIC HVAC filters which
incorporate actiVated carbon as an adsorbing media.
16.3.8.3. NSF-Tank-8514 and LCS-Tank-8516 each have a dedicated diaphrasm circulation pump
(NSF-Pump-8515 and LCS-Pump-8519. respectively) that can be used to mix the contents
ofeach tank.
16.3.8.4. Spent Nitric Acid is transferred from NSF-Tank-8514 or LCS-Tank-8516 to a hazardous
16.4
waste storaee tank located in the ATLIC Environmental Enclosure which also houses the
LIC Pollution Abatement System usine diaohrasrn pumo NSF-Pump-85658577. The tank
in the Environmental Enclosure is manaeed as a less than 90 day accumulation tank. The
Soant Nitric Acid waste stream is transferred from NSF-Tank-8514 or LCS-Tank-8516.
which are located in the ATLIC Toxic Area. when analytical results confirm that the
tank's contents have a Lewisite concentration that is less than the WCL of 200 ppb.
PLANS AND DESCRIPTION OF THE DESIGN. CONSTRUCTION. AND
OPERATION OF THE SECONDARY CONTAINMENT SYSTEM FOR EACH TANK
16.4.1
SYSTEM [40 CFR 264.193(a)-(fl and 270.16(e)]
This section addresses the containment and detection of releases for the three TOCDF tank
systems: ACS (Section16.4.5), SDS (Section 16.4.6), ar+BRA (Section 16.a.8),@d_jh9
three ATLIC tank systans: LCS. SDS. and NSF (Section 16.4.9). Eaehsubseetiea
Secondary containment systems are designed, installed, and operated to prevent any
migration of wastes out of the system at any time and are capable of detecting and
collecting releases and accumulated liquids until the collected material is removed.
Secondary containment systems are constructed of compatible materials, placed on an
acceptable foundation or base, provided with a leak-detection system, and sloped or
otherwise designed to remove spills or leaked wastes.
Specific information on the design and construction of the secondary containment system
for each tank system is maintained at the site and is available for inspection upon request.
Attachment 11 contains the process flow diagrams, piping and instrumentation diagrams,
and other information on the three tank systems.
Secondary containment for all storage tanks in the tank systems is provided by sumps
t6.4.2
16.4.3
Toxic Area is serviced by the ATLIC filtration system.
16.4.4
Attachrnent l6 - Page 9
I t 6.4.5
16.4.5.7
16.4.5.2
16.4.5.3
t6.4.s.4
I t 6.4.6
t6.4.6.1 .
t6.4.6.2.
TOCDF
'il|:il1ffi;
under the tanks, or dikes or vaults around the tanks. Secondary containment for all of the
primary containment sumps that are regulated through this Permit is provided by using the
external liner concept. The secondary containment system is described for each tank in
each system.
TOCDF Agent Collection Tank System
ACS-TANK-10l and ACS-TANK-L02 are located in the TOX on the first floor of the
MDB. The MDB is designed to contain an accidental release of agent within the
structure.
The floor of the TOX is sloped to a depressed area and that to a 500-gallon sump. The
secondary containment volume of the containment trench and sump is approximately
2,000 gallons. Because the TOX is located inside a building, there is no run-on or
infiltration expected, and no increase in containment volume is required for these factors.
The ventilation system is designed to act as a key element in the confinement of agent by
operating and maintaining the MDB at a negative pressure. The interior faces of the
exterior walls are sealed to protect the extemal environment. The same sealing procedure
is applied to ventilation ducting and instrumentation lines that penetrate the walls. Agent
monitors will detect any agent leaks from Category A areas through the walls or
ventilation systems. The material used to provide sealing of the surfaces and joints of the
floors, walls, ceilings, and wall penetrations are Plastite Protect Coating No. 7122 with
PrimerNo. 7100, Epoloid No. 5-65 with PrimerNo. 7-W-20, and Epoloid Mastic No. 5-
E-84. These materials are described in the specifications which are maintained at the site.
Equivalent or superior materials may be used in accordance with Condition II.L.
The TOX is located aboveground, inside a building, and is not subject to hydraulic
pressure, so the requirement for the exterior moisture barrier to prevent migration of
moisture into the vault is not applicable.
TOCDF Spent Decontamination Tank System
SDS-TANK-101, -102, and -103 are located in the SDS Room next to the TOX on the
first floor of the MDB. The floor of the SDS Room is sloped to a containment area and a
secondary containment sump. The containment volume is approximately 3,000 gallons.
This volume is greater than the capacity of the largest tank. Because the SDS Room is
located inside a building, there is no run-on or infiltration expected and no increase in
containment volume is required for these factors.
Spent decontamination solutions are collected from the MDB sumps. There are22 on the
first floor, 3 on the first floor platform, 34 on the second floor, and 5 on the second floor
platform. (See Table 4 in the Tables Section of the Permit for a listing of 24-Hour
lntermittent Collection Units (ICUs).) Secondary containment for all of the 24-Hour ICUs
in the spent decontamination holding tank system is addressed by applying the extemal
liner concept. Generally, each 24-Hour ICU is of welded steel construction and is
surrounded by an extemal concrete liner. Because all of the tanks and associated extemal
liners are in the same building, the specific aspects of the external liner requirements are
duplicated throughout this tank system. These aspects are addressed in the following
paragraphs.
Attachrnent l6 - Page l0
16.4.7
u.t0.4.7.1
16.4.3.2
1.,
;
16.4.7.3
16.4.8
16.4.8. 1
t6.4.8.2
t6.4.8.3.
t6.4.8.4.
t6.4.8.s
TOCDF
Tank Systems
March 2007
External Liner Common Elements
All of the sumps that are used for primary containment in the spent decontamination
holding tank system are basically similar. Most sumps are constructed of epoxy-coated
welded steel, measure 2.3 feetby 2.3 feet by 2.25 feet, and contain 89 gallons. The sump
is surrounded by a cast-in-place, epoxy-coated (Epoloid E or equivalent) extemal concrete
liner. The dimensions of the liner arc2.75 feet by 2.75 feetby 2.38 feet. The capacities
of the regulated sumps and liners are shown in Tables 4 and 5.
All oithe 24-Hour ICUs in the spent decontamination holding tank system are located
inside the MDB. There is no nm-on or infiltration of precipitation expected inside the
building.
The extemal concrete liner is designed to be free from cracks or gaps. The liner has an
Epoloid E (or equivalent) epoxy coating to ensure compatibility with the wastes being
handled. The liner was monolithically poured as a part of the floor in the MDB and
completely contains the sump contained within the liner. The liner is designed and
installed to surround the sump completely. The liner will contain any waste material that
may leak from the sump and will prevent both lateral and vertical migration of the waste.
TOCDF Brine Reductipn Area Tank Systern
BRA-TANK-I01, -i02, -201, and -202 are located outside, in a diked area immediately
adjacent to the PUB.
Secondary containment for all of the tanks in the brine reduction tank system is addressed
by applying the vault concept. The diked area surrounding the brine storpge/treatment
tanks is designed and constructed as a vault. The BRA Tank secondary containment
system has a capacity of 47,000 gallons.
The construction specifications for the installation required chemical-resistant water stops
at all joints in the diked area. The foundation and interior walls of the diked area are
sealed with an impermeable Epoloid E (or equivalent) epoxy paint coating.
The BRA tank system is located outside aboveground and is not subject to hydraulic
pressure because the foundation is located above the high water table, so the requirement
for an exterior moisture barrier to prevent migration of moisture into the vault is not
applicable. The brine storage tanks are located in a nonporous, epoxy-coated, reinforced-
concrete, diked area outside of the Brine Reduction Building. The diked area contains one
sump with a sloped bottom and level probe. A vapor barrier and a 4-inch capillary barrier
are used below the vault bottom to resist surface water intrusion.
There is a sump and sump pump located at the load/unload station. The sump provides
secondary containment for any leakage from the equipment in the loading area and the
pipe trench. The pipe trench drains into this sump. This sump is 36 inches wide by 36
inches long by 72 inches deep. The sump is made of 6-inch thick reinforced concrete and
covered with steel grate. The sump and pipe trench are coated with a chemical resistant
epoxy. The sump has a capacity of 400 gallons. Liquid collected in the pipe trench and
the sump is transferred and managed in accordance with Module IV. Thd sump is pumped
Attachrnent l6 - Page I I
TOCDF
Tank Systems
March 2007
to a transport tanker for subsequent disposal. The sump is equipped with a level
indicating monitor. If liquid is indicated in the sump an alarm is activated in the control.
16.4.9. ATLIC Tank System Secondary Containment
16.4.9.1. The ATLIC permitted hazardous waste storaee and treatment tanks are located in the
Toxic Area. The secondary containment for these tank systems is provided by the
impermeable base of the Toxic Area and the six inch curb that run the langth of the area's
outer perimeter. The impermeable base is created by coatine the concrete floor and b€rrn
with an epoxv coatine. There is second berm that runs the lensth of the Toxic Area.
This "length wise" berm separates the secondarv containment area into two areas.
The purpose of the berm is to isolate spill from the Spent Nitric Acid Storage Tanks
which prevents the comingling of spill residues from the these tanks and the Soent
Decon Tanlc
16.4.9.2. In addition there are*re is one sumps located inrvi*frr the bermed Toxic Area. The
flrmps.are This sumo (TOX Area Sumo 10n is of ide,ntical desien as the Intermitt€'nt
Collection Units located at the TOCDF. LCS-Pumo-8522 is provided to transfer
liouids that accumulate within the bermed area sunporting the Snent Nitric Acid
Tanks to the Maior Snill Tank or to the intact Spent Nitric Acid Tank should one of
the acid tanks reouire service.
16.4.9.3. Further the Major Spill Tank that is located in the Toxic Area is maintained emoty as a
contingency should one of the tanks within the Toxic Area fail. The requirenrent to hold
this tank in reserve to address ootential major spill essentially creetes an additional 1.020
eallons of secondary containment capacity. This tank is constructed of stainless steal
which is compatible with all the wastes and materials that are stored in the tanks located
within the ATLIC Toxic Area. Liquids are transferred to the Maior Soill tank
throush the use of SDS-Pumn-8530 bv first lettine the spilled liquids accumulate in
the secondarv containment area. or bv flex hose connections and the use of LCS-
Pumo-8522.
16.4.9.4. There are five oermitted hazardous waste storage and treatment tanks. and one tank that is
exempt from the hazardous waste reeulations because it hold Nitric Acid that will be used
to rinse out Lewisite TCs (i.e.. product). within the Toxic Area bermed area. One of the
five oermitted tanks is maintained empty to address major spills. Each tank is of identical
desisn exce,pt for the materials of construction (Jhe Lewisite Collection Tank beine made
of carbon steel. the others made of stainless steel). The permitted storage capacity of each
tank is 1.020 eallons. The volume of the overall secondary containment created by the
bermed Toxic Area is **86 2.555 sallons. The volume of the secondarv containment
area that supnorts the Spent Nitric Acid Storaee Tanks is 958 sallons. A snill ereater
than 958 sallons would overflow the berm and flow into the Toxic Area secondarv
containment area. The total volume available to address spills in the Toxic Area.
including that provided bythe Major Soill Tank is 2J06 3.575 gallons.
TANK AGE pETERMTNATTON [40 CFR 264.191(bX4)]16.s
Attachment l6-Page12
16.5.2. The fabrication date of the three ATLIC hazardous waste tank systems is after January 12.
1998 and each tank is required to undergo a Facility Construction Certification. The
certification will be submitted for apnroval isrEErevC by the Division of Solid and
Hazardous Waste. Therefore the requirements of 40 CFR 264.191 are not applicable.
16.6 TANK SYSTEM SECONDARY CONTAINMENT REOUIREMENTS I4O CFR
264. I 93(b)-(e) and 270. 1 6(g)l
16.6.1 TOCDF Secondary Containment Requirements
1 6.5. I
16.6.1 . L
16.6.L.2
16.6. 1 .3
16.6.1 .4
TOCDP
Tank Systems
Marcb2007
The three TOCDF hazardous waste tank systems were fabricated after January 12, 1988
and each underwent a Facility Construction Certification approved by the Division of
Solid and Hazardous Waste. Therefore the requirements of 40 CFR 264.191 are not
applicable.
Earlier in this section, the extemal liner and vault concepts were used to describe
secondary containment for each one of the hazardous waste storage tanks at the
installation. Each system is described in terms of the specific requirements for extemal
liner and vault systems given in 264.193(e). This section addresses the general
requirements for secondary containment systems. It is intended to supplement the specific
information presented in Section 16.4, titled Plans and Description of the Design,
Construction, and Operation of the Secondary Containment System for Each Tank
System.
Each secondary containment system is designed, installed, and operated to prevent any
migration of wastes outside of the systern. The external liner and vault concepts that have
been described perform this function for the hazardous waste storage tanks at the facility.
ln the event of a spill or leak, the waste material will be collected in a sump in the area.
Pumpable quantities of agent will be transferred directly to the ACS tanks. Non-pumpable
quantities of agent will be decontaminated according to the procedures in Attachment 9
(Contingency Plan) and transported to the SDS tanks. The incinerator pollution abatement
system brines will be transported to the BRA tanks. There are no underground hazardous
waste storage tanks.
The secondary containment systems are capable of detecting and collecting releases until
the material can be removed. The specific discussion for each secondary containment
system gives the containment volume. This volume is larger than the tank for which
secondary containment is being provided. The method of detecting releases from the
tanks is discussed in Section 16.7, titled Tank System Leak Detection Requirements.
Secondary containment systems are lined with compatible materials and have the strength
and thickness to prevent failure from pressure gradients, physical contact with the waste,
climatic conditions, and the daily stresses of operation. The external liner and vault
systems previously described meet these criteria. The extemal liners and floors, walls,
sills, and other components of the vaults are covered with an impermeable epoxy coating
as specified in the construction specifications which are maintained at the site.
Specifically, the sump was constructed of mild steel. Both the sump and sump liner are
coated with an epoxy paint systern, as described in the specifications which are maintained
at the site. This paint system has been approved by the Army for protection of coated
O
Attachrnent l6 - Page l3
I t 6.6. r.5
I t 6.6. r.6
TOCDF
'ffi::iliffi;
surfaces against corrosion by agents or spent decontamination solutions. Chemical-
resistant water-stops of virgin poly-vinyl chloride or rubber with adequate tensile strength,
elongation, resistance to applicable chemicals, and aging are used for all vault joints. The
exterior moisture barrier used is'a l9-mil-thick polyethylene sheeting.
The external liners for the sumps in the spent decontamination holding tank system are
constructed of reinforced concrete and are designed for maximum inside head and outside
active pressure. The bearing on the soil with the sump and liner is within the allowable
soil-bearing capacity. The external liners are designed to withstand any settlement or
uplift. The weight of the sump and liner is such that there is a factor of safety of 1.5
against uplift from hydraulic pressure. Other equipment and piping are designed to
withstand intemal pressures. The equipment is designed for pressures that are at least 10
percent above the maximum operating pressures and is listed to 1.5 times the maximum
pressure per the American National Standards Institute.
Climatic conditions have been taken into account for the BRA tank secondary containment
system that is located outdoors. Adequate protective coatings have been specified for the
outdoor components in the specifications which are located at the site. Additional
protection of piping and equipment from climatic conditions is provided by specifring
minimum design temperatures, as well as insulation and/or heat tracing. The stresses of
daily traffic, including nearby vehicular traffic, have been considered in the design of the
secondary containment systems.
The installation is not located near major traffic routes. The only nearby traffic is from
installation vehicles. These vehicles will not adversely impact the integrity of the
Secondary containment systems.
All of the secondary containment vaults are located on sound foundations that are capable
of providing support to the tank systems. Information on the structural aspects of the
external liner and vault systems is located in the specifications which is located at the site.
The secondary containment sump systems are provided with a leak-detection system that
will detect (within 24 hours) the failure of the primary or secondary containment structure
or releases of any waste. Further information on detection of releases is given in
subsequent sections on leak detection for both the tank systems (Section 16.7) and
ancillary equipment (Section 1 6.9).
The secondary containment sump system extemal liners and vaults are sloped or otherwise
designed to remove accumulated liquids. In most cases, the accumulated liquids flow to
the bottom of the sloped area. Sump pumps then pump the accumulated liquid to the SDS
tanks before incineration in the LICs.
The design standards for construction of the secondary containment systems are located at
the site. Certain features of the secondary containment systems have been specifically
designed for the TOCDF. These features utilize applicable parts of commonly accepted
industrial design standards as the best available standards, even though these standards
have not been written specifically for the applications proposed in this Permit. The
General Painting specification which is maintained at the site, and available for inspection
upon request, is applicable to all features of the secondary containment system. The
specification for Concrete Work for Building Construction is maintained at the site, and is
I t 6.6. 1.8
I t 6.6.1.9
I t 6.6. 1.ro
I t 6.6.r.7
I t 6.6. 1.rr
Attachrnent l6-Page14
16.6.2.
TOCDF
,. Tank Systerns
March 2007
applicable for construction of the secondary containment sumps, vaults, and the liner
surrounding the sumps (24-Hour ICUs). The specification for Expansion Joints,
Construction Joints, and Waterstops is maintained at the site, and is applicable to the
' waterstops required for vaults. The Specification for Miscellaneous Metal Work is
maintained at the site, and is applicable to the construction of the 24-Hour ICUs.
ATLIC Secondary Containment Requirements
Secondary containment systems are capable of detecting and collecting releases and
accumulated liquids until the collected material is removed. The containment system is
provided with a leak dejection system that is designed and operated so that it will detect
the failure of either the primary or secondary containment structure or the presence of any
release of hazardous waste or accurnulated liquid in the secondary containment system
within 24 hours. The extemal liner and vault systems used for secondary containment for
the three tank systems and ICUs meet these requirements.
The principles of the leak detection system are similar for the ACS tanks, SDS tanks, and
sumps inside the MDB. There is an agent monitoring system installed throughout the
facility. This system monitors the ambient air for the presence of agent and is a primary
indicator of agent releases. This monitoring system is described in more detail in
Attachment 22 (Agent Monitoring Plan).
The sumps below the agent collection and spent decontamination holding tanks will
contain any tank leakage. Tank leakage is detected by a decrease in the level of material
in the tank, as well as by the level indicators and alarms in the sumps below the tanks.
These level indicators are displayed in the Control Room.
Regulated sumps at the facility are configured with a level indicator which is provided
with an alarm and a sump pump. These level indicators and alarms provide another
method of leak detection. Any rise in sump level is cause for operator attention. The
sump levels and operating status of the sump pumps for the agent collection and spent
decontamination holding tank systems are displayed in the Control Room. From here, the
control room panel indicates which sump level is increased, and the operator determines
whether there is an operational explanation for the rise in sump level, such as general
housekeeping duties, equipment wash down, or other process activities that might impact
the sump level. Leaks or releases would be detected by the sump alarms and level
indicators and would appear as a rise in sump level without an accompanying operational
explanation. The sump levels and sump pump operating status for the BRA are displayed
16.6.2.1. Secondary containment for ATLIC storage and treatment tanks is provided by the Toxic
Area floor which is made imoermeable by the e,poxy coatine and the six inch hish berm
that circumscribes the secondary containment area. Additional secondary containment
capacity is provided by the Major Spill Tank that is maintained emoty unless it is required
to address major spills and the Toxic Area sumps whose design includes a concrete vault
that is covered with a metal liner coated with epoxy coatine.
TANK SYSTEM LEAK pETECTTON REOUTREMENTS [40 CFR 264.193(b)(2).
(c)(3). and (eXl)(iii)l
16.7.1. TOCDF Leak Detection Requirements
16.7
16.7.1.1.
16.7 .l .2
r6.1.1 .3
16.7 .l .4
o
Attachment l6 - Page l5
16.7.1 .5
16.7.1 .6
16.8.1.1
16.7.2. ATLIC Leak Detection Requirements
16.7.2.1. Releases to the ATLIC Toxic Area secondary containmant systern can be detected in
multiple ways. Each,tank is equipped with a level indicator. An unexpected drop in tank
liquid level as observed on a Control Room Advisor Screen could indicate a release from
the associated tank.
16.7.2.2. Each sump is equipped with a level indicator. sumo nump. and a leak detection system
located between the concrete vault and the metal liner. A leakine metal liner would cause
the leak detection systern for the associated sump to alarm as observed on a Control Room
Advisor Screen.
I 6.7.2.3. A release of aeent from the tCS tank system can initially be detected b), the agent
monitors dedicated to lhe Toxic Area.
16.7.2.4. Releases of hazardous waste can also be detected durine daily visual inspections that are
conducted rsmotely from the Control Room through the use of close circuit televisions.
The equiBment in the Toxic Area also undereoes a ohysical insoected weeklyby entrants
that enter the area (see Attachment 5).
16.8 ANCILLARY EOUIPMENT SECONDARY CONTAINMENT REOUIREMENTS I4O
CFR 264.193(fl and 270.16(e)l
16.8.1. TOCDF Ancillary Eouioment Secondary Containment Requirements
TOCDF
'il|:iliffi;
on a control panel in the area.
Secondary protection for 24-Hour ICUs and primary sumps is provided by the extemal
concrete liner concept. Each liner is equipped with a probe to detect any leakage into the
liner. The liners are normally empty and the presence of material in the concrete liner is
an indication of leakage from the metal sump. Any leakage is detected by the level
indication for the liner and by the inspection of process sumps. The bottom of the liner is
sloped to the level sensor. The level sensor is screwed into a coupling that is welded into
the mounting flange for the sump. Material collected in the external liner is removed by
inserting a dip pipe into the liner through a coupling that is welded on the support flange
for the metal sump. The material is then pumped to the SDS tanks for incineration in the
secondary combustion chamber of the LICs. The liner is then decontaminated, as
necessary, and triple-rinsed. All rinsing materials are collected and disposed of in the
LICs.
Each sump is visually inspected when waste is present, for the presence of liquids as
described in Attachment 5 (Inspection Plan).
Secondary containment has been provided for all ancillary equipment, with only a few
exceptions, such as equipment that is inspected for leaks on a daily basis. This equipment
include aboveground piping (exclusive of flanges, joints, valves, and other connections);
welded flanges, joints, and connections; sealless or magnetically coupled pumps; and
pressurized aboveglound piping systems with automatic shutoff devices.
Attachment 16 - Page l6
l6.g .t.2
TOCDF
'i;L:iliffi;
The ancillary equipment associated with the three hazardous waste storage tank systems at
the installation have the necessary secondary containment features. Secondary
containment for each tank system is addressed in the following paragraphs.
Secondary containment for ancillary equipment in the Agent Collection and the Spent
Decontamination Holding Tank System relies on the extemal liner concept. These two
tank systems are totally contained within the Munitions DemilitarizationBuilding where
all ancillary equipment is provided with secondary containment in the same manner as the
tank systems. This description is given in Section 16.4, Plans and Description of the
Design, Construction, and Operation of the Secondary Containment System for Each Tank
System. The series of sumps, trenches, and extemal liners provides secondary
containment for the ancillary equipment in the same maruler as for the tanks themselves.
'Secondary containment within Category A areas is provided by Primary Containment
Sumps which are located for containment of leaks from agent piping. Piping from the
ACS tanks to the LICs stays within Category A areas.
Secondary containment for ancillary equipment associated with the BRA tanks relies on
the vault concept and the use of welded pipe with daily inspections for leaks. The
ancillary equipment located in the diked area outside and the ancillary equipment located
within the BRA are provided with secondary containment in the same mailrer as the BRA
tanks. The diked area around the BRA tanks and the BRA are vaults. A more detailed
description of these vault systems is given in Section 16.4, Plans and Description of the
Design, Construction, and Operation of the Secondary Containment System for Each Tank
System. The BRA tank system also includes the brine transfer line, which brings the brine
solution from the PAS area to the BRA. The brine transfer line is constructed of welded
pipe and inspected for leaks daily. When flanges are required, piping is routed in an
epoxy-coated trench with a grate cover so that full view of the piping is available for
inspection purposes. Inspection procedures are given in Attachment 5 (Inspection Plan).
The piping specifications are maintained at the site and are available for inspection upon
request.
Secondary containment for the ancillary equipment associated with the brine loading
station partially relies on the vault concept. The portion of the pipe line that is above
ground is visible and is inspected daily for leaks. The portion of the pipe line that is in the
pipe trench is equipped with weep holes. These weep holes are connected to a common
header. This header drains to a sump. The pipe trench concrete and sump are coated with
a chemical-resistant epoxy coating.
1 6.8. I .3
16.8 .r.4
16.8.1.5.
1 6.8.1 .6
l6;8.2. ATLICAncillaryEquipmentSecondaryContainmentRequir€rnents
16.8.2.1. Secondary containment for permitted hazardous waste storaee and treatment tank ancillary
equipment that is located in the ATLIC Toxic Area to include pumps and pipins systems
is provided byjhe bermed and impermeable base of the Toxic Area (i.e.. the epoxy coated
Toxic Area floor). Hazardous waste transfer lines that traverse the Processins Area.
running from the glove-boxes to the Toxic Area are double-walled.
ANCILLARY EOUIPMENT LEAK DETECTION REOUIREMENTS [40 CFR
26 4.1 9 3 fi and 27 0 .l 6(.s\1
16.9
Attachrnent l6-PagelT
TOCDF
Tank Systems
March 2007
16.9.1 TOCDF Ancillary Equipment Leak Detection
16.9.1 .l Leak detection is provided for all ancillary equipment in a similar firanner as described for
secondary containment Section 16.7. The ancillary equipment associated with the four
hazardous waste storage tank systems at the installation has the necessary leak detection
features. Leak detection for all tank systems is addressed in the following paragraphs.
Leak detection for ancillary equipmort in the ACS, SDS, and BRA tank systems relies on
the agent monitoring system and the level indicator alarm and sump pump in each sump at
the facility. This leak detection system is described in more detail in Section 16.7, titled
Tank System Leak Detection Requirements. The principles remain the same. The agent
monitoring system monitors the ambient air for the presence of agent and the level
indicators and alarms sound when sump level changes. This level change is investigated,
and the operators determine whether the level change is a result of a process operation or
some other cause. The one exception to this leak detection system is the brine transfer
line. This line, which brings brine from the PAS to the BRA, is constructed of welded
pipe and is inspected for leaks at least once during each operating shift, as explained in
Section 16.8 and given in Attachmeirt 5 (Inspection Plan). Piping specifications are
maintained at the site and are available for inspection upon request.
16.9.1.2
1 6.1 0.1
I 6.1 0.1 .1
16.9.2 ATLIC Ancillary Eouipment Leak Detection
16.9.2.1 ATLIC ancillary equiom€nt leak detection is provided by the aeent monitors located
within the ATLIC Toxic Area and.level indicators located in the two Toxic Area sumps.
In addition each Toxic Area sump is provided with leak detection sensors located in the
interstitial soace between the concrete sump and the metal liner.
16.10 TANK SYSTEM MANAGEMENT PRACTICES [40 CFR 264.194(b) and 270.16(c) and
(d)t
Manaeement of Incompatible Wastes in Tanks
The design of the fa€iliqfTOQDF allows for brines from the PAS to go to the TOCDF
BRA tank system, spent decontamination solutions from the sumps to go to the SDS, and
agent from the demilitarizationmachines to go to the ACS. In addition, agent
contaminated fluids (hydraulic fluid, fuel oil, lubricating oil, etc.) from a spill or
maintenance activities can be transferred to the SDS after the fluid has been
decontaminated. These fluids will be transferred to the ACS tanks prior to treatment in
the primary combustion chamber of the LICs. These miscellaneous liquid wastes, if,
placed in the SDS and ACS tanks, must be compatible with any other fluids within these
tank systems. All PAS brines from all of the incinerators are compatible because the
pollution abatement systems are the same for each incinerator and they use the same
scrubbing material (e.g., sodium hydroxide). When changing from one agent to anotheq
the ACS tanks are rinsed with decontamination solution to remove any residual agent.
The spent decontamination solution is then drained from the ACS tanks and pumped to an
SDS tank for subsequent processing through one of the LIC secondary chambers.
16.10.1.2 The desieur of the ATLIC Toxic Area Brovides separation between tanks storine
incompatible wastes. The Soent Decontamination Solution and the nitric acid solutions
Attachment 16 - Page I 8
16.1 0.2
TOCDF
'il:.:iliffi;
that are used to rinse out Lewisite ton containers are incompatible. To prevent their
mixing should there be a failure of two of the tanls in the Toxic Area. a berm.is provided
which separates the area where SDS-Tank-8523 and the area where the tanks storine sp€nt
and product nitric acid are located.
Manasernent of Isnitable or Reactive Wastes in Tanks
For the TOCDF: Aagent, brine and spent decontamination solutions have flash points that
classiff them as Class IIIB liquids in accordance with the National Fire Protection
Association. Additionally, agent contaminated fluids (hydraulic fluid, fuel oil, lubricating
oil, etc.) from a spill or maintenance activities, can be stored in the SDS Tanks and the
ACS tanks prior to treatment in the primary combustion chamber of the LICs. These are
not unstable or reactive liquids as defined by the National Fire Protection Association.
The BRA tanls are in fulI compliance with National Fire Protection Association
' requirements. The agent collection and spent decontamination holding tanks are located
, in the TOX and SDS Roorr5 respectively, which are provided with a containment volume
that is in excess of the largest tank capacity. The TOCDF brine holding tanks are located
outdoors within a diked containment area capable of containing the full contents of one of
these tanks. All tank systems are located at least 50 feet away from the property line of the
facility.
16.1 0.2.1
16.10.2.2 For the ATLIC. all hazardous waste storaee and treatment tank systems are located within
16.10.3
the ATLIC Toxic Area which verrts to the ATLIC HVAC Filter System and provides
secondary containrnent. Therefore releases from the tanks are prevented from escagins to
the environment. Additionally the tank systems are located at least 50 feet away from the
property line of the facilit]r.
General Operatine Requirements
16.10.3.1 TOCDF General Operating Requirements
I 6. 10.3.1 .1
16.1 0.3.1,.2
The environmental effects of a release from the rupture disc and conservation breather
vent on the agent collection system storage tanks are minimized by design, rather than
procedures. The ventilation filter system contains any vapors that are released. Liquid
releases are contained in the sump and drainage systems. Leak protection is addressed in
Section 16.7, titled Tank System Leak Detection Requirements and Attachment 5
(Inspection Plan). Corrosion protection is addressed in Section 16.2, titled.External
Corrosion Protection of the specifications which is maintained at the site and is available
for inspection upon request.
Should there be a release to the secondary containment system of agent, brine, or spent
decontamination solution, the area would be cleaned up expeditiously and, in any case,
within 24 hours. The spill is collected in an appropriate sump and pumped to a similarly
classified tank. The floors in the area are sloped to encourage spill runoff into the sumps.
Cleanup includes collecting the spilled material and, if necessary, rinsing the area with
decontamination solution to minimize agent contamination. All sumps and equipment in
the area of the release would then be rinsed with process water. All of the rinses, both
spent decontamination holding and process water, are pumped to the spent
decontamination holding tanks before disposal in the LICs. After the cleanup of the
Attachrnent l6 - Page l9
I 6. 10.3. 1 .3
16.10.3.L4
I 6.10.3. 1 .5
TOCDF
'ffi::iliffi;
release and the rinsing, there would be a small amount of residual process water remaining
in the sumps.
Wash downs are frequent occrurences, especially in the Toxic Maintenance Area where
wash downs are routine in the decontamination of contaminated parts that are in need of
repair.
Specific procedures for an agent spill or leaked waste in the nontoxic areas (Categories C,
D, and E) of the MDB are addressed in Attachment 9 (Contingency Plan).
Specific procedures for spills, leaked wastes, and precipitation outside of the MDB are
addressed in Attachment 9 (ContingencyPlan).
16.10.3.1.6 Anytanksystemorsecondarycontainmentsystemfromwhichthereisaspillorleakis
removed from service immediately. All material flows into the tank are stopped. The
system is inspected to determine the cause of the release. If the release is from a tank
system, sufficient waste is removed from the tank system to prevent any further release. If
the release is to a secondary containment system, all released materials are removed within
24 hours, or in as timely a nnnner as is possible to prevent harm to human health and the
environment.
Attachrnent l6 - Page20
TOCDF
Tank Systems
March 2007
16.10.3.2 ATLICGeneralOperatineRequir€rn€nts
16.10.3.2.1 All ATLIC tank systems operate at ambient oressure. The filling of the tanks will result in
vapors being released to the ATLIC Toxic Area which is under ensineering controls
provided by the ATLIC TIVAC System.
16.10.3.2.2 Similar to the TOCDF. leaks are addressed in as timely a manner as possible. Should a
tank system fail. the content of the failed tank system will be transfened to the Major Spill
Tank. Liquid wastes accumulatine in the sumps are transferred to the corresoondine tank
system within 24-hours from the time the liquids begin to accumulate.
16.10.3.2.3 Any tank system or secondary containmeirt system from which there is a spill or leak is
removed from service immediately. All material flows into the tank are stoooed. The
system is inspected to determine the cause of the release. If the release is from a tank
system. suflicient waste is removed from the tank syst€m to prevent any further release. If
the release is to a secondary containment systern. all released materials are removed within
24 hours. or in as timely a manner as is possible to prevent harm to human health and the
environment
Attachment 16 -Page2l
TOCDF
Tank Systems
March 2007
Table 16-l
TOCDFAGENT COLLECTION SYSTEM STORAGE TANKS
Tanks System Tank Identification
Number
Tank Identification
Number
ACS-TANK.lOI ACS-TANK-IO2
Design Standard ASME Section VIII
Division I
ASME Section VIII
Division I
Tank Capactty, gal.660 1,300
Working Volume, gal.500 agent, 582 other
liquids -.
1,130
Corrosion Allowance, in.Y^%
Calculated Shell Thickness, in.'0.0763 0.07 63
Specified Shell Thickness, in.o v,v,
Lining Material None None
Dimensions:Diameter, ft 3.5 I.D.4.5 I.D.
Height, ft 9 .7 5 incl. domed heads ll.7 5 incl. domed heads
Design Temperature, oF 150 150
Design Pressure, psig 15 15
Pressure Control None None
Vapor Pressure HD 0.11mmHe @25o C 0.11 mm He @25" C
GB 2.9 nlmHe @25o C 2.9 mmHe @25" C
VX 0.00063 mm He @ ZSo C 0.00063 mm He @ 25o C
Maximum Height of Liquid in Tank
(LSHH nozzle)
80% of height from
bottom of tank 7'-6"
above tangentd
80% of height from
bottom of tank 8'-9"
above tangentd
Projected Corrosion Rate Based on NACE
Corrosion Survet'
0.2 mil/yr 0.2 mil/yr
Tank Spacing, ft 3.5 3.5
Notes:
a. Calculated shell thickness is the minimum thickness necessary to adequately support the liquid in
the tanks. It is calculated by taking into account liquid, wind and earthquake loads, design code,
and construction material. It does not include corrosion allowances.
b. Specified shell thickness is the corrosion allowance plus calculated shell thickness and then
specified at the next larger nominal plate size.
c. Agent is not specifically listed in the National Association of Corrosion Engineer's Corrosion
Survey.
d. The tank tangent is the geometric transition where the cylindrical side meets the ellipsoidal bottom,
approximately two inches below the head-to-shell weld.
Attachment 16 - PageLl
TOCDF
Tank Systems
March 2007
Table 16-2
TOCDF SPENT DECONTAMINATION HOLDING TANK SYSTEM"
Tank System Tank Identifi cation Nurnber
SDS-TANK- 1 0 1, SDS-TANK -102, and SDS-
TANK-I03
Desierl Standard ASME, Section VIII, Division I
Tank CapacLty, gal.2,300
Working Volume, gal.2,200
Corrosion Allowance, in.U8
Calculated Shell Thickness, in.o 0.1 02
Specified Shell Thickness, in.'slt6
Dimensions:Diameter, ft 6.0 I.D.
Height, ft I 1.5 incl. domed bottom
Design Temperature, oF 150
Design Pressure, psig 15
Pressure Control None
Vapor Pressure 0.6 psia (A 85" F
Maximum Heisht of Liquid in Tank 9 ft-5 in. from bottom tangent of tank
Projected Corrosion Rate Based on RISUN
Technologies Design Assessment Report, October
1997
0.002 to 0.004 inch per year
Tank Spacing, ft 3.5
Notes:
a. The above data is for the unlined carbon steel tanks used during the GB campaign. Before sodium
hypochlorite decontamination solution is used in the VX and mustard campaigns, these tanks will
be equipped with a 3/16 inch polyvrnyl chloride liner that increases the corrosion allowance
accordingly and the corrosion rate is therefore projected to be negligible. A skeletal system
consisting of four Titanium rings has been placed inside the tank to ensure the stability of the liner.
b. Calculated shell thickness is the minimum thickness necessary to adequately support the liquid in
the tanks. It is calculated by taking into account liquid, wind and earthquake loads, design code.
and construction material. It does not include corrosion allowances.
c. Specified shell thickness is the corrosion allowance plus calculated shell thickness and then
specified at the next larger nominal plate size.
Attachment l6-Page23
TOCDF
Tank Systems
March 2007
Table 16-3
TOCDF BRINE STORAGB TAI\K SYSTEM
Tank System Tank Identification Number
BRA-101 , 102,201 and 202
Design Standard API 650
Tank Capacity, gal.47,000
Working Volume, gal.42,900
Corrosion Allowance, in.u r/4
Calculated Shell Thickness, in.u'b 0.0507
Recommended Shell Thickness, in.318
Lining Material Epoxy
Dimensions:Diameter, ft 20
Height, ft 20
Design Ternperature, oF 185
Design Pressure, psig 15
Pressure Control None
Vapor Pressure 4.4 psia @ t60o F
Maximum Height of Liquid in Tank 18 ft 3 in. from bottom of tank
Projected Corrosion Rate Based on NACE
Corrosion Survey
None with liner
Tank Spacing, ft 5
Notes:
a. Calculated shell thickness is the minimum thickness necessary to adequately support the liquid in
the tanks. It is calculated by taking into account liquid, wind and earthquake loads, design code.
and construction material. It does not include corrosion allowances.
b. Specified shell thickness is the corrosion allowance plus calculated shell thickness and then
specified at the next larger nominal plate size.
Attachment l6-Page24
TOCDF
Tank Systems
March 2007
Table 1G4
ATLIC LEWISITE AGENT COLLECTION SYSTEM STORAGE TANKS
Tank System Tank Identification Number
LCS-Tank-85 1 1 (agent) and
LCS-Tank-8534 (spillt
Design Standard:ASME Boiler & Process Vessel Code
Section VIII
Material of Construction:LCS-Tank-851 I (.carbon steel)
LCS-Tank-8534 (stainless steel
Tank Capacitv. gal.1.065
Working Volume. gal.884
Corrosion Allowance. in.0.2500
Calculated Shell Thickness. in.u 0.325
Specified Shell Thickness. in.o 0.t25
Linine Material None
Dimensions:Diameter. ft 5.333
Heieht. ft 6.833
Desisn Temperature. oF 100
Design Pressure. psig 5
Pressure Control None
Vapor Pressure ( mm He)L 34.6
Maximum Height of Liquid in Tank
(I-SHH nozzle)'. in.67 .5
Volume below working volume, eal.120.9s
Tank Spacins. ft Greater than 8 ft.
Notes:
a. Calculated shell thickness is the minimum thickness necessaryto adequatelv supDort the liquid in
the tanks. It is calculated by takine into account liquid. wind and earthquake loads. desisn code.
and construction material. It does not include corrosion allowances.
b. Specified shell thickness is the corrosion allowance olus calculated shell thickness and then
specified at the next larger nominal plate size.
c. The tank tansent is the seometric transition where the cylindrical side meets the ellipsoidal bottom.
approximately two inches below the head-to-shell weld.
Attachrnent l6-Page25
TOCDF
Tank Systems
March 2007
Table 1G5
ATLIC SPENT DECONTAMINATION SYSTEM STORAGE TAIIK
Tank System Tank Identification Number
SDS-Tank-8 523
Design Standard:ASME Boiler & Process Vessel Code
Section VIII
Material of Construction:Stainless Steel
Tank Capacity. gal.1.065
Workins Volume. gal.884
Corrosion Allowance 111.0.2500
Calculated Shell Thickness in.u 0.325
Specified Shell Thickness. in.o 0.125
Linine Material None
Dimensions:Diameter. ft 5.333
Heieht. ft 6.833
Design Temperature. oF 100
Desien Pressure. psig 5
Pressure Control None
Vapor Pressure ( mm He)L 34.6
Maximum Height of Liguid in Tank
(LSHH nozzle)'. in.67.5
Volume below workins volume. sal.r20.95
Tank Spacins. ft Greater than 8 ft.
Notes:
a. Calculated shell thickness is the minimum thickness necessary to adequately support the liquid in
the tanks. [t is calculated bv takins into account liquid. wind and earthquake loads. desien code.
and construction material. It does not include corrosion allowances.
b. Specified shell thickness is the corrosion allowance plus calculated shell thickness and then
specified at the next larger nominal plate size.
c. The tank tansent is the qeometric transition where the cvlindrical side meets the ellipsoidal bottom.
approximately two inches below the head-to-shell weld.
Attachrnent l6-Page26
TOCDI.
Tank Systems
March 2007
Table 16-6
ATLIC NITRIC ACID HOLDING SYSTEM STORAGE TAI\KS
Tank System Tank Identification Number
NSF-Tank-8514
LCS-Tank-8516
Design Standard:ASME Boiler & Process Vessel Code
Section VIII
Material of Cohstruction:Stainless Steel
Tank Capacity. gal.1.065
Working Volume. gal.884
Corrosion Allowance. in.0.2500
Calculated Shell Thickness in.'0.325
Specified Shell Thickness. in.o 0.125
Linins Material None
Dimensions:Diameter. ft 5.333
Heieht. ft 6.833
Design Temperature. oF 100
Desierr Pressure, psig 5
Pressure Control None
Vapor Pressurd( dm He)L 34.6
Maximum Height of Liquid in Tank
(LSHH nozzle)'. in.67 .s
Volume below workine volume, gal.120.95
Tank Spacins. ft Greater than 8 ft.
Notes:
a. Calculated shell thickness is the minimum thickness necessary to adequately support the liquid in
the tanks. It is calculated by takine into account liquid. wind and earthquake loads. desisn code.
and construction material. It does not include corrosion allowances.
b.Soecified shell thickness is the corrosion allowance olus calculated shell thickne and then
specified at the next larger nominal plate size.
c. The tank tangent is the seometric transition where the cylindrical side meets the ellipsoidal bottom,
approximately two inches below the head-to-shell weld.
Attachrnent l6 - Page27
(+(+
FD())
H
CD
HP
{
ATTACHMENT 17
Equipment Lists
a:)Eq)EoL.---(t
q)
ilmml)Lcngs--U)
t+\oN
..
t
lE
r
f-
9
Er
l
,-
\
gV
EO
cn

+r
HE
c)
.l
r
l
:E--U)+,
trc)AF(EIo
.F
l
t-I9F{aUr=
l
RIUIcl
t'
(
l
0)
d-+.
d-+r
or
lBq)
I-Hc€
ol
-l
at)rEoUEE
Fl

li
Xc
t
t
=E
i=
E
q)
G
I
=+
,
).

0A
o\
(aO€Cd
oo
\nO+\oc{&IJ
.
(-
)$oo
I
oo
t
\ncOd.
o\
rnOEcd
oo
(nO+\oN&lJ
.UO$oo
I
oo
!
\neod.
o\
\aoEcd
oo
(nO+\oc!&IJ
.UO$oo
I
oo
I
|.
ncAd.
o\
rnO'o
GI
oo
rnO+\oN&EUO$oo
I
oo
I
rncad,
o\
(aO'(
,
CB
oo
\nO+\oc{&tJ
.
'
.U$@I
oo
I
\ncad
o\
(nO'o
Cd
oo
rnO+\oc{&lL
'
.UO$oo
I
oo
I
\ncAd,
o\
\nO:ocd
oo
taO+\oN&fJ
.
.
rQO\f
,
oo
I
oo
I
\nead,
o\
\nO.otrcl
oo
\n+\oNdtuQ.f@I
oo
I
tncAd,
o\
rnOEcg
oo
\nO+\oc!&tuUo$oo
I
oo
!
\acad,
o\
\noEcB
oo
l.
nO+\oN/,T\UO.+oo
I
oo
I
\.
)
cad,
o\
\nO'o
cd
oo
(nO+\oN&tJ
.
.Ua$oo
I
oo
!
\ncad,
o\
(no'o
cd
oo
\n+\oNd,
tJ
.
,UO$oo
I
oo
I
\r
)
cad,
o\
\nO'o
cB
oo
(nO+\oN&fJ
.
,UO.+oo
I
oo
I
\ncad,
o\
\nOEdoo
(.
)O+\oc\&fJ
.
,U$oo
I
oo
I
tncad.
o\
rnOEcd
oo
(r
)O+\oc!
/"
tJ
.UO$oo
I@I
rncad,
o\
\nOEcB
oo
\no+\oe!&tJ
.
,UO$oo
I
oo
t
\ncAd,
o\
(nOEtrcd
oo
(nO+\oc{dtJ
rUO$oo
!
rc
I
rnead,
o\
fnOEtrCd
oo
LO+\oc{
ilt\UO$oo
!
oo
I
\acAd,
o\
\nO'o
cd
oo
\no+\oN&fJ
"UO\too
I
oo
I
l.
ncad,
o\
rno.dCO
oo
[nO+\oc!&tJ
<UO.f
,
oo
I
oo
I
r.
)
ead
o\
(aoGt
oo
\nO+\oe{&rLU.f
,
oo
t
oo
I
\r
)
cad
o\
\n.otrcd
oo
\nO+\oN&tJ
.UO\f
,
oo
I
oo
I
rncad
o\
\nO'o
cd
oo
tnO+\oc!
ilt!UO.t@I
oo
I
\ncod
o\
\na'o
cd
oo
(nO+\oc\
l&ILU.tao
I
oo
I
rcad
o\
\nO'd
cd
oo
(aO+\o6t
ilILUO.+oo
I
oo
I
(ncad
,<6€
c,
)
'd
o>:
d
Ir
Y
-1
,Ar

U)
'o
'o
)C'
J
E=C,
J
E)oJ
E
rc
'd
=(,
J
'o
)gJ
E(,
J
to)gJ
"oc,
J
€)C,
J
'o
'd
rE
)
rd
E
€
E
€
E
E
)qJ
)(,
J
aoJ
)oJ
J
)C,
tU
q
)C,
)o
)c,
)g
(,
Jc,
a(,
aq
J
J
J
J
J
J
J
J
J
J
J
gs
E
sOn
sOn
sO
sO
rOo\
o\On
son
sOn
sO
sOn
so
sO
sOn
rO6|n
sOn
sn
sA
sOn
sOA
sOn
sO
sn
sOn
sOn
sOn
q)cF.
t
:)dH0)axtsc
.
tr
(
I-t,
EN
abI
tE
OLd
tJ
.
of-
ff
)
t-
.ooC)ooXOLJ
-
o
o
oCd
o()()ooOo(
cB
tr
-
ocd
b(
tIB-oO(naaF()ozocr
3
Ocd
t-ooOo()Xo
tL
9.
tro-
trooOo()xOtL
C)b{
cOGEsB0)
c!
3
6)
63
'l
4
()0)
tJ
oCd
oc'
3
0)
63
ab{
rEoL(B
t!of-ar
)
0)Cd
l-
.o()0)o()x0)
u-
o
OCB
o()oo()
-oob{
cBE-
()oo()
'o
Ob(
Cd
IJ
-
O0)o()
'o
obt
cd
lJ
-
Oooo
'o
oOI
Cd
tJ
-
()OooC)b{dtr
-
FI
dxo
.r
(+,
6gCJoJ
mA-
'
,
mor
mFr
mPr
mor
mo<
mFr
H2-
Eo.
.
mOr
trOr
EF.
mo.
.
mO.
'
.
mo<
mOr
mOr
mO.
t
mFr
EA
mFr
mo.
.
mOr
mO.
(
mo<
mAr
ozbI
cgF{
*)dx0)axxo
.l
t-)E'
fr
l
f-coc{o\IO.
rr
)
\ooco
IX
O.
I
t
C-
(
(1
,
oo
\n
IFa.
-
\o\o
IFoa-
-
co
IX
OIFJfJ
.
'
,
Ia
NOca
IX
C!
ca
IIN
$IIN
tI
ta
l
O.
\n
IC.a
$I
O-
,DO.IaU
O.
\n
Io-a
eo$!!I
t.
.
r
$$II!
La
r
UONOo\II$tf
i
ONI
tL
c!II
f-cANo\Io.U1
\oo\
-t
IX
O,
(n
I
o.
.a
O,
ca
IFO-
f-\o
IFoO-
$IX
olOIFJtr
Ia
q)
{i,
U)
6gBtD
!='
=
OA
rd

>)
L+
,
-dNH
EE
=
aocoo
,t
s
aoao,i
anmtro&cdIaU
anmo<.
h3<EIaU
aocotro,icd
t<
!aU
aomo,l
-cOL-c
IaU
aom,t
aocoFo
,.
t
s
cnEIaU
aomo,Ic0trtaU
aomo,I
.El-
!
IaU
aomo,ft-
'o
IaU
aomo
,t
-
cd
t-
!
IaU
aoc0o
,l
-
.E
l-EI0U
anmtro,lCB
l-
IaU
aomtro&cdt-IaU
aomo.tcd
t<IaU
aomFo.t
.E
t<EIaU
aomtro,i
.ELEIaU
aoc0Ho
.
l'
rdt<EIaU
aomtro,icd
!
IaU
anmtro't
.E
t-EIaU
aomo,icdtiIa(J
aomo.t
rad
t<EIaU
aoetro
,t
s
edtrIaU
aoEOtro
,t
s
l-EIV)U
cd
l-
'o
IaU
03t-EIaU
(n
f-
i
IoU
C)u0
(dPr
6
f-l-
{
(.
)
tr()Cd
{J
.

A
oo
ii

6
o
.
rr
{
7\
\
V
L.
/

FI

GI
Ot
s
s
{
t-
{
b
R
1E
!l
3B
Ir
]
A
t-
a+,
dI€)
tts
l
xc)
li
a-I-Uc)
tEFE:)LcnIsI-V)
.s\oN
..
t
'i

Fr
*
r{
U
El-g
3
EoGI
P
3E
0)EI-V)+)/Hq)
d)rHc.--tIL)
FI
]aUrr
l
nlUIol
F'
(
l
q)
d-+)
d-+)
.-Bq)
cJ
dxcg
.--al-
,
1FI
xoUqt

u)
eE
rd
!
At
\
.=E
i5
E
q)
G
I
ts
{

+)
o\
(nO'o
doo
(n+\oe{&fJ
.
'
.UO$oo
I
oo
I
l.
ncad,
o\
\nO'o
Cd
oo
\nO+\oC.
l&tJ
rUO.f
,
oo
!
oo
I
\ncad,
o\
\nO'd
03
oo
\nO+\oNil
fJ
rUOsoo
I
oo
I
\ncad.
o\
(.
)o€cB
oo
\r
|+\oc!&tJ
.
.UO.too
I
oo
I
\nead.
o\
rnOEcB
oo
\nO+\oN&tJ
.
,
.U$@I@!
\ncad,
o\
lnOEcB
oo
\n+\oNc,
,
tJ
.
,
,
(Jwoo
I
oo
I
(ncad,
o\
(nO€cd
oo
\oO+\oe{&t!
'
,UO$oo
I
oo
I
\ncod.
'o
\
lnOE(d
oo
\n+\oN&tuU\too
I@I
\nead,
o\
\nO'1
,
CB
oo
(n+\oN&fJ
-
,
(U.f
,
oo
I
oo
I
(ncad.
o\
\nO'(
,
Cd@\.
)+\oN&tJ
-
'
.UO.+oo
I
oo
I
\nead,
o\
l'
nO'o
63
oo
rn+\oe!cf!U$oo
I
oo
I
\ncAd,
o\
\r
)O€cd
oo
\n+\oe{&E-
,
,UO$oo
I
oo
I
r.
)
ead,
o\
\aOEcg
oo
(nO+\oN&tJ
-
.
.UO\f
,
oo
I
oo
I
(ncod,
o\
\nECd
oo
(n+\oN&tJ
.
'
.UO.+oo
I
oo
I
(ncad
o\
\nO'o
d@\nO+\oN&fr
rUO$oo
I
oo
I
\nead,
o\
(nO'o
GI
oo
\a+\oN&tJ
-
'
.Us@I
oo
I
\ncad,
o\
(nO'o
CU
oo
\n+\oN&tr
r
()s@I@I
[ncAd,
o\
\.
)OEcd
oo
\nO+\oNil
tuUO$oo
t
oo
t
\ncad
o\
\nO€Cd
oo
\.
)+\oe{&IJ
rU$@I
oo
I
\ocOd,
o\
\nO'o
Cd
oo
\nO+\oNIJ
*UO=f
,
oo
I
oo
I
\nead,
o\
(nO'o
doo
\nO+\oN&lL
'
.UO.+oo
I
oo
I
\ncad
o\
(nOEcd@\.
)+\oc{&tJ
rUO$oo
I@I
\acAd
o\
\nOEcB
oo
\nO+\oN&tuUO$oo
!
oo
I
\ncad,
o\
\nO11
,doo
(.
)O+\oN&IL
,
,UO\f
,
oo
I
oo
I
\ncad
o\
\.
)OCd
oo
\n+\oN&tJ
.
,
.U\f
,
oo
I@I
(ncod,
o\
(nO'o
CO
oo
(r
)+\oN&tJ
<UO.too
I
oo
I
(ncad.
-cl
l
CJ
'd

c)
i.
H
-+
a&
(r
1
Ec,
)g
'o
)U
)oJ
'o
o
'o
.o
E
.d
T,
'o
E
EU
'(
,
)o
'o
)C,
J
'o
qJ
'd
'd
E
.o
'o
'o
€
E
E
c,
J
)gJ
)UJ
)qJ
)o
o
=C'
ac,
J
t(,
J
=c,J
toJ
)oJ
)oJ
)(,
J
)C,
J
)UJ
)oJ
J
J
J
J
J
J
J
J
J
9+
.
.l
A
EE
G
SS
E
\oo\O
10o\O
rO^\O
1.
OO
1O6\
rOg\
1Oo\O
10O
1.
O
109\O
sO
qO9\
1O
10o\O
1.
Oo\O
s
rO6|O
rOO
10o\
rOo\O
qOg\O
10o\O
19O
1€
)
o\O
10O
1Oo\O
q)cFr
5ldHe)
(4x,Lro
.r
<
/-Urn
o(d
bIo0daaC)6i
ocd
t-
ro()Oo()XC)
tJ
-
0o-
t-
(oC)oo()xOLr
-
0)dJZoo(J
Ocd
O
C)
cd
O(d
oCd
ocO
Ocd
OdJoot)
oc3
I)O-
u)oC)C)o()ob{
cdE-
t<o()()oUX0)
tl
-
o(d
0)
cd
Od
oc0
CJ
c!
3
o03
6l
axo.-:)60CJ
A!,J
mo<
mor
E0r
mAl<).
mo<
mA-
(
mRi
mo<
mor
mF<
mo<
ts
{
mPr
mOr
mo.
l
mOr
mOr
mA-
'
,
mor
mP-
'
,
mor
mcr
EA
mA=.?
,
mAr
EAOr
ma<
lF
l
dzbI
c{
E-
l
It4xq)
t1-Lio
.r
{
t-(,
fr
l
N.f
,
IX
O$o\IIN
C\tINII
ta
r
o\
\n
IO.
(r
)
!IA.Uz.DO.
,
.
IaU
Ot
l'
n
tOra
$NIII
t.
l
^
)
aNO'
,
II$a6
c!I
tL
O.I!
6o
No\
a
I
6o
CAo6
I
6
$o6
I
n
\nOO,
G
I
oo
\oO.
o
I
6o
cao\
^
I
o
f-Oo\Ix
o\IOraDC-
,
.
IaF:E
O.IF-]
IJ
r
I
\o
oJt<aa(dl-
{Fc\OIaem
c!o\II
Gn
NNo\!I
66
CAc!o\II
6
-f
,NO,!I
ao
[nC!O.II
6al
\oNO,I!
G6
q)
+)0cqBrr
)

q
-J-'-
-
li
J
fd

l-
)
L+
,
)dbY

)r
si
l
aomtro,t
s
.Et<
IaQ
aomo
,t
s
03l-IaU4
aotro,t
.ELEIaU
aomo,tdtrIaU
aomo,t
s
.E
t-
-o
IaU
aomtro
,.
t
s
.Et-
!
IaU
aomo,.
i
.Et<EIaU
aomo,I
.Et<EIaU
aomo,i
.E
L
'o
IaU
!aoca
!aF:l
O!aomIaF:E
OIaomIaF
O
O
c!OO
NO
N
e\
N
c{
N
IaomIaF
Iacca
IaF:E
IaRmIaF:t
IaRmIaF:E
IaomIaF:E
!anm!aF:t
IaomIaFE
IaomIaF:E
IaomIaF:l
IaoEIaF:E
IaomIaF:E
IaomIaF:E
IaoEIaF:t
r
Iao!o
IaF:E
E
Y=
H
r\
\
\
/
L,
/

Fl

6l
O!
k
t-
U
R
IE
,r
-
)
3B
rr
l

a
Noa0
63
F<F-OH()Cd
r-
(
a+rEottsEq)
li
.l
I-g6)
il
trtr
Ilicncs!l-al+\oN
..
t
'i

fr
tr
-
U
I
,-
\
Y
QJ
*
H\
.EOGI

+J
Er

+r
L(
)
q)€-,-a+JE()/HEa.---C'
FdaUtuRUcFr
q)
d-+f
d-I.-Bq)c)
dHct
l
.r
<-aAxHoQq!

rt
)
o1
3
rF
{

L
X€
t
=E
i=
t
(l
)
c
l
li

+.
a.

rr
\
o\
\nO'(
,
cd
oo
(nO+\o6l&tJ
.U.+oo
I
oo
I
rncad,
o\
\no.ocd
oo
(nO+\oc\
t&IJ
.
,
.UOsoo
I
oo
I
rneAd.
o\
rnO€63
oo
(n+\oc!&tJ
-
.QO$oo
I
oo
I
rncAd,
O,
r.
nO'o
cd
oo
\nO+\oC.
ldfJ
rU$@I
oo
I
\ncad.
o\
\nOECd
oo
\r
)O+\oN&hUO.+@I
oo
I
r.
)
ead,
o\
\nO'ocl
oo
tr
)+\oN&fJ
.
'
.UO\t@I
oo
I
\neAd.
o\
(aO'o
co
oo
(.
)O+\oc{&fJ
.
'
.UO$oo
I
oo
!
tr
)
cad,
o\
\nOt(
,
cd
oo
(nO+\oc\&tLUO\f
,
oo
I
oo
I
\ncod
o\
\no.ocB
oo
\na+\oc{&tJ
.UO.+oo
t
oo
!
(r
)
cod
o\
\noEcd
oo
(r
)O+\oe{&ILUO$oo
I€I
\ncad
o\
\no"ocd
oo
\.
)O+\oc!d,
tJ
rUO.+oo
I
oo
!
(a
)
cad.
o\
\nOEcB
oo
\no+\oe{&IJ
.UO$oo
I
oo
I
rncad,
o\
(no.oCd
oo
(o+\oN&tJ
.
,UOrtoo
I
oo
I
\ncad
o\
\noGI
oo
\r
)O+\oN&8,
,
()O$@I
oo
I
l.
ncad,
o\
\nO'o
cU@rnO+\oc{&ILQO$oo
I
oo
I
\ncad,
o\
\no'o
trcd
oo
\r
)O+\oN&tJ
.
,
.UO.+oo
I
oo
I
\neod.
o\
\nOcd
oo
[nO+\oc!
ilhUO$oo
I
oo
I
\ncAd,
o\
\nO03
oo
rn+\oe{
fJ
.UO$oo
I
oo
I
\ncAd.
o\
\no1,cd@\nO+\oN&tJ
.
,UO.+oo
I
oo
I
\ncad
o\
\nOl-
r
63
oo
\nO+\oe{
il
tJ
.UO$oo
I
oo
I
\ncad
o\
\noEcd
oo
(nO+\oc{
/,
,
tr
.
,
,UO$oo
I
oo
I
\r
)
ead,
o\
\ao'o
d@tr
)O+\oc!&fJ
.
,UO-+oo
I
oo
!
\r
)
ead.
o\
ll
nOCU
oo
(nO+\oGI&IJ
.
.
.UO$oo
I
oo
I
\ncad
o\
\noEGI
oo
\nO+\oN&ILUo$oo
!
oo
!
(ncad
o\
\nOEcd
oo
l.
aO+\oc!&t\UO$oo
I
oo
!
l.
r
)
cad,
o\
\nOtdc€
oo
\n+\oc!&tJ
.
'
.UO$oo
!
oo
I
\ncad,
-cl
()
'd

q)
}E
-5
}Ar

U1
E
E
'o
'o
'o
'o(,
'o
'o
E
)ct
J
'o
)C'
'o
'o
rc
'o
'o
=tr
t
'(
,
.C
,
'd
E
.o
'd
'd
'o
gJ
)g
C'
J
(,
)U
=c,
U
)g
)U
=g
)gJ
=C'
J
)U
)ct
=g
)(,
3(,
)qJ
)gJ
gJ
qJ
)q,
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
*E
f
ou
e
sOn
sOn
sOn
.sOn
sOn
rOo\
rO6i
:On
s=
r.
O6|O
1O6\On
sOn
sOn
sOn
sOn
sOn
son
1O6\OA
rO6\On
sOn
sOn
sOn
sO
rOo\On
sOn
sOn
sOn
q)cH+,
dHq)
t4xxooi--E'
Er
)
OcO
J4oo()
ocC
o.aO-
aoC)
0)oU'oob(
cd
tJ
-
ocO
t<ooOoUxO
tJ
-
Ocd
(t
)
()0)oUob(
(o
tL
OcB
ao()OoUEoo{
cO
tr
-
0)
COoC€oa>o()OoUE()b{
cd
lJ
.
-
tro()ooUX0)
tL
Ocd
C)b{G'1
,
C)b(
edG'o
Od.VOoO
ocn
t-oOoUxO
tJ
-
ga-
t<o()ooUXotJ
-
od
OCd
()0)oUrdOb{
cr
t
tL
LoOOooxotL
od
ocda()
O-
,
.
troooooxo
tL
EBOcd
5>ocd
N
dlro
.i+)cgCJoJ
EAa<
tra<
mOr
mo<
mO.
mc.
.
mcr
mo.
l
mOr
mOr
mF<
ap<
mO.
,
.
mo<
ao.
'
.
m0<
mF.
r
ma<
m0"
trOr
EF-
'
.
mF.
.
mA
caP.
mA
mc<
ozAIGF+,Axq)AI>(g
.l
/-Urn
eae{o\tt
ao
f-ONO.IX
c\O.IC-
,aDO-
,
I0F:c
oNoIFJIJ
.
'
.
I
\o
\a
)
\oc!I!
o0xO
tJ
-
O-oFe0trots
rzo
$f-
IX
oo
IgzFIaU
l.
n
f-
IX
(nOIFJlr
.
,
I8
cA
f-
aa-
oaoFxo
tJ
-
\n
IIe!
\n
!I
.+\n
II
oo
(.
)
II
eo
\n
II
C)aoxC)
tJ
-
roOI0.zO-
,
i
taU
oao>J
.xotl
-
f-f-o\IX
mca
f-
IX
ca
f-
IFJ
oao
;J
<
Xgt!()
.o)F63
t-
.oa
$oo
tX
oaoXC)
fJ
.
oooo(-
)oL.
Lt
-
q)
+r
,
ra6€B3.
E
os
L
{.
J
id
IT
Y

H
si
l
ri
=
NOIaomIaFF
c\
lOIoom!aF
N!anmIaF:l
NIaoco
IaFU
aRmo,l
.EL
'o
IaU
oo,l
-63L!
IaU
aoFo
,l.Elirc
!aU
oo
,l
-
.E'o
IaU
o<rzFo,l
-cOt-IaU
otro
,F
cd
t-
.
'o
IaU
oo&.Et-€IaU
oo,iCO
l-
IaU
oztro,l03LIaU
oo&.El-IaU
otro,t
otro,t
tizoo,t
otro
,F
otro&
aZ,tro
,l
-
<(aoo&
-{zoo,tcd
t<
IaU
az><oc,
t
s
oo,t
oo
,1
.
ozo,t
'=
tr
'o
IaU
cdtr
'(
,
t.aU
Cd
t-
(taU
c3IaU
03EIaU
Cd
t-IaU
e3t-
'o
IaU
63
LIaU
Cd
t-IaU
COLIa(J
Cd
l-EIaU4
Ef
i
H
UJ
X
Ot
s
-
j
FU
P
$E3B
IJ
]

A
eo(.
)a0
CB
0<pos
8'
-
Ef
r
H
7\
\
\
/L/

F.
{

cN
OE
k
t-
.
.
U
R
tr

-t
4
AE
!)
=o
.
ct

0)
'
IJ
]

A
.f
,oa0
63Or
f-
.ood
t-
(
a+rH€)Ax-o
.L
{
.l
-l.,t
a\.
,q)ttrm{,
,L€ggsi-
'a$\oN
..
&
'i

tr
tr
-
U
tr
ls3
So
ct

:)
?+
r
LC
J
q)Et-a+)
t4xq)-)rHq-t-ItJFI
]U)Urr
l
alUIcl
Ei
l
q)
d-{r
)d
I:)
r-
B
'q
)
c.
)ax6g
or
(-adHEoUq!
aoE
Ft
L
v-AL
Y=E
EEoc
n
ts
(

s)
Z,

u)
o\
r.
)OEdoo
rn+\oN&tJ
.
'
.U$oo
t
oo
I
rncad,
o\
(nOrc(d
oo
rn+\oN&ILUO$oo
I@I
\ncr
)
d,
o\
(nO'o
(€
oo
rnO+\oe.
l&ILUO\f
,
oo
I@I
|'
ncad
o\
tr
)Oroed
oo
rn+\oN&fJ
.U.f
,
oo
I
oo
I
\ocad
o\
\nO'o
Cd@\nO+\oN&
't
J
.
'
.
U.+oo
I
oo
I
\ncad
o\
[aO€Cd
oo
rnO+\oN&tJ
.
'
,UO$oo
I
oo
I
[nead
o\
\nrd(doo
\n+\oN&ftUO$oo
I
oo
I
\ncOd,
o\
\nO\,doo
\n+\oNcfJ
.UO$oo
t
oo
I
\ncod.
o\
Lr
)Odoo
\ao+\oe!&rI
.UO$oo
I
oo
I
(ncad
o\
(.
|O'o
cd@\n+\oNil
tJ
.
,
.UO\f
,
oo
I
oo
I
(nead,
o\
\nO'o
cB
oo
\nO+\oN&tJ
rU.+oo
I
oo
I
\neod,
o\
\nOEcd
oo
[nO+\oc{&fJ
.UO$oo
!
oo
I
(ncad,
o\
\nOE(d
oo
(n+\oc\&tr
.
,
,UO\f
,
oo
I
oo
I
l.
n
.Ad,
o\
l.
n
'1
3
c!
3
oo
(n+\oe!dtJ
.
(_
)O.+oo
I
oo
I
\nC.
l
d
o\
\n
'o
cd@\n+\oN&tJ
.UO$oo
I
oo
I
\nead
o\
rnO.dCB
oo
rn+\oN&ILU$oo
t
oo
I
rnead
o\
\nO.ocB
oo
tnO+\oc!&tuUO.+oo
I
oo
I
\ncad.
o\
(nO'o
Cg
oo
\n+\oN&lJ
.
.UO$oo
I@I
\ncAd,
o\
\r
)o.ocd
oo
|.
nO+\oN&fJ
.
,UO$oo
I
oo
I
rncad
o\
\nO'o
cd
oo
\n+\oN&tJ
.
,
.UO.too
t
oo
l.
\ncad,
o\
|'
aOECg
oo
(n+\oN&tJ
.
.
.U.f
,
oo
!
oo
!
\.
)
cad
o\
\nO1,Cd
oo
(nO+\oNilErUo.+@I
oo
I
[nead
o\
(nO'o
cB
ooV)O+\oN&f!
,
,U$oo
t
oo
I
|.
ncod
o\
\.
)OEcd
oo
(r
)O+\oc!&ILU\f
,
oo
I
oo
I
(ncad,
o\
\nOE(doo
[n+\oN&tJ
rUO$oo
I@I
(ncod,
o\
\nOEcl
oo
(n+\oc\&tJ
-
,
.UOsf
,
oo
I
oo
!
(ncad
t
c{C'
)
'd

q)
>:
d
Ir
Y
-+
,
Ar
A
r3)gJ
.o)gJ
rd=(,
J
.o)oJ
'o
oJ
E
r3
rd
'o
'o
'o
'o
.o
'(
,
)g
ao
E
1,
E
'o
E
E=U
'o
)o
'o
oJ
'o
)(,
J
o
)q
aq
o
)C,
aUJ
=g
)(,
J
)q
=
=o
ao
)c,
)U
)(,
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
$E
f
or
J
e
10
10O
rO61
\
10o
qgo\
10o\O
10o\O
qOO
1Oo\O
qO9\
10o\
yO9\O
10o\O
10O
1Og\
10o\O
105\
10o\O
10O
10O
10o\
1O6\O
yO
10o\
\oo\O
yg9\O
q)aF.
t
:.dxq)
(<-aLTc
.r
(
--(t
EN
aoo0)O0)b{
0d
tJ
-
O03
Od
aoooooob(d
tL
oedodoaoL)OU'o
oo{
cB
tr
-
t-
roOOo()XotL
o63
ob(
03
-o
ob{
cdE
ood
}l()ot)
Ooi
l-
(oOoOXo
lJ
-
o)O-
t-
toOoooxCJ
tL
Ocd
C)
cd
o()o()
'(
,
ob{
tL
t-
r
()0)oL)xO
lJ
-
ocd
ocda())p<dl-ooOo()xOtL
aoo0)o()0)OI
CB
tL
bI0CdaOoo
Oed
aooOo()
-oob{d
lJ
-
o63odoaBooooUEC)b(d
lJ
-
$-o()OoOxotL
-o>C)
cO
.c>ocd
FI
FIHo
.r
l+)ct
(J^!/J
mo<
ma<
ea0r
mAr
ma<
mFr
mc<
mo<
aOr
mF<
e0r
\3.?
.
ca
mCr
g2.
mFr
mO-
,
.
mCr
mc<
mAr
mO.
mo<
\<
{
2,
mo<-2.
mc<
mA.
{
FI
m0r
mOr
mo-
,
,
ozbI
6n3'+
;
IL(0)
t)<He
.r
<
t-(,
kl
\oTvZF!aU
oo
f-OO,IX
rnoo
Ix
\oOIFJtL
,
.
IaU
CAoo
Io-
Oaox6)
tr
-
f-
IIN
t-
-
II
-t
f-
It
oo
f-
tI
ca
f-
II
OaoXo
tJ
-
\o
IAH
IaU
0)aoJ.X0)
tJ
-
f-ooo\IX
cacaoo
IX
caoo
!FJ
0)aoxgtL
,
o.o)F.ELeo
\f
,oIx
0)0oX0)
tJ
-
,
.
()0)oUol-
(
tJ
-
ooooOo\tx
F.
l
CAO,II$
(nO,IX
r-
-
IFJfL
IaU
cao\
'.
.

Io-
o.t
)oxo
tL
q)+,a.
cg
-B
ut
'

*)
.
-.
-
iJ
FL
{.
J
-dNT
zoo,t
zozo,t
-z,c<<Z,o
,F
oZo&
oo,!
.Et<
-o
!aU
zotro&.E
LEIaU4
r-z,e<(z,tro,i
.Etr1,IaU
oo&.El<
'o
IaU
<<zo\<
r
rzo,i03LIaU
a)<o,!
.El-EtaU
zoao,l
-03LIaU
zozo
,t
s
oo,t
oao
,l
-
r<z,oo,!
=rzRo&
zozo&
oatro&
zRo,i
zo\=
<ztro,idt-
'o
Ia()
\<aczo<.
t
s
zoo,i
oao.l
cztro
,t
s
zozo<.
Ed!
IaU
Znl=
r2,o,l
-
!
IaU
cd
l-EIaQ
cd
t-IaU
dL.
t
IaU
63t-IaU
cdL
!
Ia()
dL!aU
COt-o
!aU
edt-
'o
I0U
d!
IaU
IaU
edEI
(t
)
(-
)
l-IaU
cd
liIaU
co
t<EIaU
dL
'1
5
!aU
trIa()
F{
a+,Eq)
rltrofr
.l
--Uq)
ilmm*rLc{gs--a!f
,
\oN
..
i
l
qf
r
tr
-
U
ri-g
3
Eo
cl

:'
9a

:)
LC
J
o
a-E--a+,
dHq)axhrg.---E'
FE
IaUrr
l
.lUI
clFl
q)--+,
d-{.
r
.l
Bq)CJdxGI
.l-a-HtsoUEE
r=
{
L
Y'AL
YXE
ir
Ee)
G
I
ts
l

+,
>.

(n
o\
tnO'o
cl
oo
\r
)O+\oN&tuUO+oo
I
oo
I
(ncod
o\
faO€cd@\nO+\oc\
/,
tJ
rUO$oo
I
oo
I
\oc.
l
d,
o\
\nOcd
oo
\nO+\oN&Ir
.
,
,UO.+@I
oo
I
rr
)
c.
t
d,
o\
l.
nO.oct
r
oo
(n+\oN&fJ
.
,
.Ua.+oo
!
oo
I
r,
a
)
c.
)d
o\
(aO'd
Cd
oo
rn+\oN&tJ
"Usoo
I@I
\ncad,
o\
tnO'o
cB@\n+\oN&tuU$oo
!
oo
I
\ncad,
o\
\nOC€
oo
(nO+\oN&fr
.
,
,U$oo
I
oo
I
\ncad,
o\
rnO'o
trcd
oo
rnO+\oc!
/,
tJ
-
(U.+oo
I
oo
I
\ncad,
o\
(nO'o
cd
oo
\nO+\oN&FrU$oo
I@I
\ncad,
o\
\nOdoo
rnO+\oN&ILUO.f
,
oo
I
oo
I
rr
)
cad,
o\
rnO'o
cd
oo
[r
)+\oe\&lL
'
,UO$oo
I
oo
t
\ncad
o\
\nOtr
c!
3
oo
\.
)+\oc!&IJ
.
'
.U$oo
t@I
racad,
o\
rnO'o
cd
oo
\nO+\oN&tJ
rUO$oo
I
oo
I
\ncad,
o\
\nO1,cd
oo
(nO+\oc{&lJ
.
'
,U$oo
I
oo
I
(r
)
cad,
o\
\nO'o
cd@|.
nO+\oN&t!UO.+oo
I
oo
I
\ncad,
o\
r.
)O'd
Cd
oo
[nO+\oc!&IJ
rU.+@I@I
\ncad,
o\
(no'o
doo
\nO+\oe!&tJ
.
,UO$oo
I
oo
I
|'
ncad
o\
\r
)O6d€(nO+\oN&lJ
.
,UO$oo
I
oo
!
(r
)
cad,
o\
\nO'(
,
Cd
oo
rnO+\oe.
l&fJ
rUO\f
,
oo
I
oo
t
l,
r
)
cad,
o\
\nO'd
Cd
oo
\nO+\oc!&tJ
.UO.+oo
I
oo
!
tacad.
o\
tr
)O'o
G,
oo
\nO+\oN&tJ
.
.U.+oo
I
oo
!
tncod,
o\
\nOEcd
oo
\nO+\oc{dtuUO$oo
I
oo
I
(r
)
cod,
o\
\nO'o
GI
oo
\nO+\oe{&tJ
"Uatf
,
oo
I
oo
!
\nead,
o\
rnO'o
doo
\.
)O+\oe\&tJ
<U\f
,
oo
I
oo
t
(ncad,
o\
\no'o
cd
oo
LNO+\oNil
tJ
.
.
.UO$oo
I
oo
I
\ncad,
o\
roO'o
GI
oo
\aO+\oc{&tJ
.
,U$oo
I
oo
I
rncad,
t
c€
(J
'd

q)
h.
E
-t

+,
Ar

rn
'o
'd
'o
'o
'o
E
'o
'o
rc)gJ
'o
'o
E
)C'
ao
'o
€oJ
E)C'
J
.U
aoJ
'd
)gJ
)oJ
'o
)oJ
1-
l)oJ
)oJ
ag
o
)(,
)g
g
)(,
)C'
J
)UJ
=g
)(,
)U
=gJ
)C'
)g
)g
J
J
J
J
J
J
J
J
J
J
J
J
J
J
$E
u
Ou
-
2
.
sOn
sO
sOn
1.
Oo\O
\oo\On
qg6\O
s=
s
yO6\O
yO6\o
1O6\O
rOo\O
s=A
s=A
sOA.
\oO
rO€)
\O
1.
O
1O6\On
106\O
qOo\On
1Og\O
r.
g6|On
sOn
yOo\On
1OO
q)oE-
{
+r
dH6)AxHtr
a
r-
(
t)Urn
ocd
obI
63E-oBocn
obI
qE
.o6)
cd
C)
CB
'l
l
o0)
L)
o
t<oooo()XO
lJ
-
0)o_
tio()OooxC)
LL
C)
c0
(Jcd
o0)o()obI
cd
TJ
.
Oci
oc!
3
JoO(-
)
O(d
C)
cd
J4()oO
Od
o03
oOo()Ob{
cB
tL
ado0odOO()Baoooo()ob(
cB
tr
-
odcd
l-
.
'd
b{)oIooOoooo{
cB
lJ
-
0)
03
ocd
C)
cd
o
N
dHo
.i5)cgIoJ
mor
mFr
mF<
mOr
mci
mC.
mO.
mOi
c0O.
'
.
m
mo<
mOi
XoF-
.
XoF-
r
Xof-
{
XoF-
r
XoF-
'
(
XoF-
,
(
Xot-
{
Xof-
(
Xof-
r
XoF-
{
XoF-
{
Xo-
Xo-
Xor-
<
ozbr
6gFr+,
dHq)
dLTxq
a
rr
(
t-t,
rn
o\IIc{
O,II
\f
,O,II
ooO,II
caO.II
()Qox0)
tL
f-OI)taU
oaox0)
tL
f-o\OO.IX
ooO.OO.IX
mcao\!x
caoIFJ
Noo
I!
,\
l
\of-
II
,\
l
@IIN
f-f-
IINI
$oo
IJ
oo
f-
II
d
o\I
rr
.
l
J
caO.tFJ
l.
nO,I
I!J
(noo
II
N
I
\ooo
IINI
oo
tI
t\
l
$oo
!I
t\
t
o\
f-
II
l\
l
q)
+.
,
(r
)
cgB2.
t
s
3a
!os
rd
-
L+
)
--
l
LY
HNi
l
fi
=
nzo,t
ctro
,t
s
.El-IaU
otro,*6d
t<
-o
IaU
otro't
zo\<
,
(Zo.t
zoo
,F
cdL
'o
Ia()
zozo.i
oo,i
rr
(zor-Zo
,l
-
zo,,cdLEIaU
aozo'i
=ao\-zo,i
a}4dFaU
a}4dFaU
aJ63FaU
a-yFaU
aJcOFaU
a.ycdFaU
aJ63FaU
a!a3FaU
a
.VFaQ
a
'}
4
cOFaU
aJdFaU
a
.\
4
cdFa(J
aCdFaU
a.vcOFaU
c3LEIaU
03t!
!aU
c3t-!aU
Cg
tr
-o
IaU
c'
3
t-EIaU
c0I
(t
)U
a3t-
-o
IaU
e3LIaU
xv
8
.F
{
7\
\
VL/

F]

t:
I
OE
L
{
FU
R
1E
!)
3B
f!
a
\n(l
)b0
(d
p<poco
FT
ro+)Eq)Ax-otr
.-I-Uq)ttrFA:)li6l
,cs-l-at+\oN
..
t
.i

FE
tr
-
U
-is3
Eo
Cg

{.
,
FT
E
q)
.F
.
l
ra---a+)/Hot)rHP.--JI\JFdaUrr
l
clU]C]
Fr
l
q)
d
-t+,
d-{i,.t
l
B()Itr€n
.--adIIoUEE
E!
AL
Y=E
i5
E
oG
t
h.
{

.a
r
J
>.

(r
\
o\
\r
)OECd
oo
\nO+\oN&I!UO$oo
I
oo
I
\ncad
o\
\nOECd
oo
\n+\oN&tJ
.
,UO$oo
I
oo
I
rncad
o\
\no'o
doo
\n+\oc!&tJ
.
,U$oo
I
oo
I
\ncad
o\
\nOEcd
oo
\nO+\oN&tJ
-
'
,UO$oo
I@I
tncad
o\
rnO'o
Cd
oo
(n+\oN&E,U\f
,
oo
I
oo
!
\neAd
o\
\nO.ucd
oo
\nO+\oN&tJ
.
,
.U$oo
I
oo
',
1
t.
)
cAd,
o\
\nOrdcd
oo
\r
)O+\oc{
il
tJ
.
'
,UO-f
,@IaI
\ncod,
o\
rnO'o
cd
oo
\n+\oe!&IJ
.
'
.UO\f
,
oo
!
oo
I
[ncAd
o\
\nO'o
cd
oo
\nO+\oc{&E'
.UO$oo
!
oo
I
\neAd
o\
\nO.ocd
oo
(oO+\oN&tJ
.UO\f
,
oo
I
oo
I
r.
)
cad,
o\
(oo'o
cB
oo
\n+\oN&fJ
.
.UO.f
,
oo
I
oo
I
\ncod,
o\
\nO'o
Cd
oo
(n+\oN&tL
,
,U.+oo
I
oo
I
\ncad,
o\
r.
)Orotrdoo
|.
a+\oN&tJ
.
.
.UO$oo
I
oo
I
\ncad,
o\
rnO'(
,
03
oo
tn+\oN&tJ
.UO$oo
I
oo
!
(n
et
^
)
d,
o\
(nOCU
oo
rnO+\oc!&tJ
.
'
.UOxf
,
oo
I@I
rr
|
cad,
o\
\no'o
cd
oo
\nO+\oNdtJ
.
'
,UO$oo
I@I
\.
)
cad
o\
(nO'o
Cd
oo
rn+\oN&t!UO.+oo
I
oo
I
\.
)
cad,
o\
\nOEcB
oo
l.
a+\oN/.
tuUO.+oo
I
oo
I
rncnd,
o\
\nrocd
oo
\n+\oN&1J
.
,
,UO$oo
!
oo
I
(ncad
o\
\nO1,oo
oo
(nO+\oN/,
t!
,
.U$oo
!
oo
I
\ncAd,
o\
rnO'o
(d
oo
\n+\oc!&fJ
.
'
,U.f
,
oo
I@I
rncAd
o\
\nOE(d
oo
\a
t+\oNdtL(JO$oo
I@I
tncOd
o\
|.
nO.odoo
tn+\oN&tL
,
.U$oo
I
oo
I
\ncad
o\
\nOroC€
oo
\n+\oc!&ILUO$oo
I
oo
I
\ncod
o\
(nO13trcd
oo
\.
)+\oc\
l&lJ
<UO$oo
I
oo
I
\ocod
o\
t.
nOc!
3
oo
\a+\oN&tJ
.
,UO\f
,@I
oo
I
\acAd,
-lcgI'd

q)
>.
:
-L
Y
-+
)&u
)
'o
aoJ
E
E
E
rc
'o
'o
E
'o
E)o
'o
)o
E)o
t(,
'l
5
)(,
J
'o
)oJ
'o
)(,
J
E)C'
J
.c)oJ
-o)oJ
I3)gJ
'o
)J
)(,
J
)q
)q
=o
)UJ
qJ
)o
)o
)o
)c,
=C'
J
)UJ
c,
J
J
J
J
J
J
J
J
J
J
J
J
I
'+
r
$E

I
yO9\o
1g9\
1go\
10O
yOo\
10O
10
10O
1.
OO
rO6|O
1.
o
o\
rO^\O
1O6|O
106\
19o\
s
rO^\O
10o\
10o\O
rO6|
1Oo\O
rOo\O
rOo\O
1.
Oo\O
1Oo\
rO
q)cFr+,dL(q)
?1x)rc
.F
(
d)(,
kl
ocd
o0ioacdOooBaOq)ooOb{dtL
V)o
E0)OIOI=po03
0)
COb{
o-
C)
cd
oC€
OcO
()cd
0)
63
.V()oIJ
C)
Cd
oCd
}Zoot-
)
oc0
Ocd
'5
4
()o()
Ocd
0)
CO
L)oooob{6tL
acdoado0)Oa()Ooo6)b{
CB
tr
-
odcd
l<
rcbIo>o()0)o()0)bIdtL
oCB
OCd
O
0)
O
O
adoa63o)rootsaO6)
()ObId
lJ
-
oO()C)bI
CO
tL
c0
(d
cg
63
N
dIo
.H.t
-
)ct
()oJ
Xot-
<
XoF-
{
Xot-
r
Xot-
'
(
XcF-
r
Xot-
.
.
Xot-
r
Xcf-
r
XcF-
{
Xof-
i
Xof-
{
XoF-
(
XoF-
t
XoF-
(
XoF-
(
Xot-
'
(
Xo-
Xo-
XoF-
{
XcF-
r
Xcl-
1
Xc-
Xof-
r
Xct-
(
Xct-
(
Xot-
r
ozbI
cgFr+)
t4xq)
taE)-
(oar
<
t-Urn
f-O.I
J
O.O,!Fca.
-
NI
o<
(r
)
$NIIc!
\nNIIN
c\@II
CAoo
II
oo
II
d
O.II
l\
l
\oo\II
l\
t
oooo
IINI
f-O,IINI
\ooo
tJ
ooO,II
r\
l
I
=t
,\
l
NO.IINI
I
IJ
.
]
J
oOIFJ
f-
I
rr
.
l
J
\n
IINI
\o
IINI
II
,\
l
$II
,\
l
O,II
,\
l
rn
IJ
-f
,
IFoo-
-
q)
:)acq
,.2.
E
')
srr
-
L+
r
-dLv

)r
Ni
l
a-va3FaU
a-vdFaU
aJZdFaU
a}4FaO
aJrgaU
a.VFaU
(n
-VFaU
a-vdFaU
a3dFaQ
aJCdFaQ
aJ63Fa()
aJla3FaU
a,&Fa(-
)
a-VFaU
a.Y63FaU
ax63FaO4
a-Vc0FaU4
a
j4
dFaU
a&a3FaU
a
-5
4
a3FaQ4
a.vcdFaU
a!FaU
O}Z63FaU
aJ03Fa()4
aJIc3FaU4
a-\
4FaU
H#
3
7\
\
\
/L/

)-
l

c\
OE
I
-
{
FU
R
(j
=E.
E
!)
3B
rr
l

a
\oobo
63
p<
G
f-
.C)>r
F{oCB
F(
a+JEodEEc)L
.l
I-UoilEml)Lcngs,(-a!+\oN
..
t
'i

Fr
tr
-
U
-a.g
Y
&o
6l

:)
-r
l
Lq
J
o&-l-0+r
tli()
tFIEg---uF]aUfrAFIUcH
q)-Hl,A-{.
a
.-Bq)CJaxcg
.--aAL(
IoUq!

c)
cE
r-
t
!Xc
t
:E
i=
E
€)

Gl
E{

r.
z,
a
o\
tnO'o
trd@rnO+\oc{dfJ
rUO$oo
I
oo
I
(acad
o\
\nO'o
(d
oo
\nO+\oc!
il
tJ
-
,
,UO\f
,
oo
I
oo
I
\ncad,
o\
tr
)O.ocd
oo
rnO+\oe!&ErU$oo
I
oo
I
[r
)
cad,
o\
rnO.dcB
oo
rnO+\oN&I!U$oo
I
oo
I
\ncad,
o\
tnO'o
d@(n+\oe{&fJ
.
'
.U.+oo
I
oo
!
\r
)
cad
o\
(.
)OEcB
oo
rr
)O+\o6t&rUO.+oo
I€I
\ncad
o\
\aOECd
oo
\r
)O+\oc\
il
tJ
.
'
.U+oo
!
oo
I
r.
)
cAd
o\
\aOcd
oo
\n+\oNil
tJ
.U$oo
I
oo
I
(ncad
o\
(nOEdoo
|.
nO+\oN&tLUO$oo
I
oo
I
\nead
o\
(nO'o
cd
oo
rnO+\oN&TLUO$oo
!
oo
I
\ncAd,
o\
\.
|O'o
ed
oo
rn+\oN&IJ
.U\f
,
oo
I
oo
t
\ncAd,
o\
\nOcd
oo
r.
)O+\oc!
IJ
.
'
,UO.+oo
!
oo
I
\ncOd,
o\
\.
)OEtrcd
oo
\nO+\oN&tJ
.
.
.UO.+oo
I
oo
I
rneod
o\
\r
)OECd
oo
l.
nO+\oc!dtJ
.
,UO$oo
I
oo
I
\nead,
o\
\nO'1
3
cd@[nO+\oN&IJ
.U.+oo
I
oo
I
(ncad,
o\
\nO'o
cd
oo
l.
nO+\oe{
/,
tJ
.U$oo
I
oo
I
\ncad,
o\
\nO'o63
oo
\n+\oe{cfJ
<UO$oo
I
oo
I
|.cad,
o\
\nOEcd
oo
rnO+\oN&tJ
.
'
.UO.+oo
I
oo
I
\ncad.
o\
(nOEcd
oo
\nO+\oNil
tJ
.
'
.UO.+oo
!
oo
I
\ncad,
o\
t.
nO€C€
oo
\nO+\oc!&hUO.+oo
!
oo
I
\ncad.
o\
\nOECd
oo
r.
)O+\oN&tJ
.
.
.UO.+oo
t@I
\acad,
o\
l.
nO'o
cd
oo
\nO+\oN&EUOsoo
I
oo
I
\ncad.
o\
\.
)O'd
trdoo
rnO+\oN/,
tJ
-
,
.UO$ooI@I
rncad,
o\
\nOcB
oo
raO+\oc\&tJ
.
'
,
(-
)O.+oo
I@!
(r
)
ead,
o\
rnO'o
cC
I
oo
rno+\oNil
fJ
.UO$oo
I
oo
!
\ncad,
o\
\nOad
oo
|.
nO+\oN&fLUO.f
,
oo
I
oo
I
\ncad.
-ctCJ
'd

q)
>:
-
tY
-{
r
,&c
n
t)qJ'
E
'o
'C
,
'd
E
'o
E
E
'o
'd
€
€
1'
'o
rO
'o
'o
U
E)C'
E=ct
E)C,
.o)c,
tc,
1,(,
J
'(
,
aC,
=gJ
)oJ
)gJ
)gJ
aC'
J
)(,
q
aC'
)g
)g
)
C'
J
)C'
=(,
J
UJ
agJ
)o
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
gs
E
sO
sO
sO
sO
sOn
rO6|OA
sO
1.
O
g\O
1g6\O
qO6\O
sO
so
1.
o
o\O
rOo\O
sOn
sOn
rOo\On
sOn
sO
sOn
rOo\On
yOo\On
rO6\On
qOo\
qOo\O
1O9\
Q)gFr+,d-odF(xo
.l
/)oEN
aoL)C)oobI
cd
fJ
-
ocdb{
O-
Oo0
Ocd
Oc0
C)d
o(n
tr()ooUxOIr
-
Ocd
o()OoUxC)
LL
0tro-
C)
cO
ooC
ooooUob(
cd
tr
-
troo0)oUxotL
ocd
o()ooUob(
cn
tL
ocn
oC€
o(d
Ocn
C)
cd
ooooUoo{
Cd
c-
Od
ocd
LooOoUXotr
-
N
/Ho
.t
(€c€CJoJ
XoF-
r
Xo-
Xot-
{
Xol-
1
Xol-
l
XoF<
XoF-
(
XoF-
,
(
Xot-
<
Xo-
Xof-
(
XoF.
.
<
XoF-
(
XoF-
(
Xol-
1
Xot-
{
Xot-
(
XoF-
(
Xo-
Xo-
Xof-
(
XoF-
(
Xof-
r
Xot-
r
Xof-
r
Xot-
{
ozOI
cgFr
:)tHq)-Li>(o
a
rr
l-)grn
c{OI
4.
.
.
rr
)
\oc\IIc\
NII
c.
)
It
tI
d
e\
c\
lOO'
,
It
N
V)O.IX
c0O,
rn
ta
OCOC.t!c{
O.
\n
IO-
(r
)
coO.!3O-IaU
COcoO,II
-t
NcaO.II
-f
,
\oooooo\!O-
(r
)
O.
\n
IO-
(r
)
Od'
)O.IIN
O,IFtr
-
\oo\Ix
\o$F-O,ItN
(n$f-O,I
3'
o\$f-O.IIhl
(nf-O.IIc!
O.I
(Jarq
Ia(J
caNOO.I!
N
ooO.IX
UO,
tn
!O.
rr
)
q)
{i,
(acgB3.
E
oq
rd
-
L+
)
-t
4SH
a.ydFaU
aJZFaU
a
j4
dFaU
aj403FaU
aJCTFaU
o(o()
t<
o
o
odot-
cda()L
oc3Ot-
ocd)ot-()OIaU
oCdo!
ocd3ot<
odot<
odotr
odC)
tr
ocd()L
oCO()
t<
ocd()
t<
oCOolr
oCda()
od)()L
od()
dC)
tr
cdJOl-L)o&IaU
cdaoLooIaU
CdOt-
()o&taU
()o&IoU
oO&!aU
ooc,IaU
Oo&IaU
oo&IaU
oOIaU
OoIaU
OC)&IaU
oo&IaU
oOIaU
oOdIaU
oO&Ia(-
)
oo&!aU
oodIaU
C)OcIaU
OO&IaU
Oo&taU
tJ
.
,

A
oo
A
6
O
7\
\
\
/
\,
/

r-
{

cl
8H
E
1E
5)
3B
rr
l

a
f-
.0)b0
(o0rp()
(s
(t
)+,
tr€)
dHtsq)
t(
.---oq)&trtr+)Lcggs--a!+\oN
..
t
ll
r
f-
9
-l-g
3
so
ct

+)
-+
r
L9
o
.F
lE-l
ta+,AHe);Itra.--l
t5FdaUrr
l
alUIclHI
q)
d-:)A-+r
.l
Bq)
Iaxcl
.--ad)r
tsoUq!
(

u)
eE
E!
A
{r
Y
=r
d
i5
E
q)
G
t
E{

{r
,
o\
[aO€CB
oo
l.
.
)O+\oN&tJ
.Utoo
t
oo
t
rncad,
o\
l.
)OECd€tnO+\o6ldtJ
.
'
.U.+oo
I
oo
I
\ncod,
o\
\naEcB
oo
(n+\oc{
ilE<UO$@IooI
|.
nB
o\
rnO.odoo
rnO+\oe!&tJ
.UO-f
,
oo
I
oo
I
\ncad,
o\
(.
)adoo
\a+\oe{&tJ
-
,U-too
I@I
[ncad
o\
(aO'o
Cd
oo
l.
nO+\oN&E,
.UO.+oo
!
oo
I
\ncod
o\
(nOE(Boo
\.
)+\oc{&tJ
.
.
.UO$oo
t
oo
I
(ncad,
o\
(O\,Cd
oo
(nO+\oNil
fJ
.U-too
I
oo
I
(ncad
o\
\aOEcd
oo
l.
nO+\oN&1J
.
,
,UO\too
I
oo
I
\nB
o\
tnOECB
oo
(nO+\oN&lJ
-
,
.U.f
,
oo
!
oo
t
(acad,
o\
tr
|O'o
cr
d
oo
(n+\oNctJ
rUO.+oo
I@I
\nc.
l
d,
o\
rnOCd
oo
\.
)O+\oN&tL
'
,UO$oo
I
oo
I
rncOd,
o\
(aO'o
ed
oo
\n+\oNI!U$oo
I
oo
I
\ncad.
o\
\.
lOEcd
oo
rn+\oNil
tJ
rUO\f
,
oo
I@I
(ncad,
o\
raOcd
oo
\nO+\oe!
il
IJ
rUO.+oo
I
oo
I
\ncad,
o\
r.
)O€(3
oo
rn+\oe\
l
il
tr
rU$oo
I
oo
!
(ncad,
o\
rnOEC€
oo
\n+\oN&t!U\f
,
oo
!
oo
I
rncad
o\
\aO'o
cd
oo
\n+\oN&fJ
.
(UO\f
,
oo
I
oo
!
rneod,
o\
\.
|O'o
Cd
oo
(n+\oN&tJ
.
'
.Uo.f
,
oo
I
oo
I
\ncad,
o\
\aO.ocB
oo
rn+\oe!
r'
.
,
tJ
rU$oo
t
oo
I
\ncad,
o\
rr
)O.ood
oo
\n+\oc{
il
IJ
.UO$oo
I
oo
!
(ncad,
o\
\nOEcu
oo
rn+\oN&IJ
.UO\too
I
oo
I
(ncad,
o\
l'
na'o
Cd
oo
[nO+\oN&lL
.UO$oo
I
oo
I
\ncAd,
o\
(.
)O'oc0@ln+\oN&IJ
.
'
,UO\foo
I
oo
I
(ncad,
o\
\.
)OEcB
oo
\n+\oN&f&UO\f
,
oo
I
oo
I
\nB
o\
rnO13(d
oo
\n+\oN/,
tJ
.
'
.UO.too
I
oo
I
\neod
-'c
t
I'd

q)
>.
:
-
tt
Y
rl

+l
A.

rr
l
'o
E)o
E)o
'o(,
'o
t(,
'd
)o
1,
'o
E
'(
,
'o
E
'1
,
1,
'd
'o
)UJ
E
'o
E
E
E)(,
'o
'd
.C
,
)o
)(,
)(,
a(,
)C'
)o
(,
=C'
)U
)o
oJ
gJ
)ct
)o
o
)o
)(,
tq
o
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
9+
l
.l
AgE
E
1Oo\O
..
.
o
61
\O
rOo\
rO6|O
1.
O
o\O
1Oo\O
yOO
1.
O
g\
\oo\O
rOq|O
10
1.
O
rO6|O
rO^\
qO6\O
qgo\O
\o
rOO
qO6\O
10o\
19O
10
g\
qOo\O
\oo\
\oO
1Og\O
q)cFr
+i
)-tsq)-Lrxgar
r
l
t-Urn
Ocd
trooOoUxO
lJ
-
oao-
C)
CB
Ocd
o0)oU0)bIdLt
-
t<oooUX0)
tr
-
-
oCB
ocd
t'o()OoUx0)
tr
-
-
ocd
oCd
Od
OCd
oO0)oUOb{
cd
tL
Oc€
0to-
oCd
o03
ooOooob{
cd
tL
Ocd
od}(L)0)
()
Ocd
o()Oo()ob{
cd
(t
-
oco
Ocd
6l
tfxo
.
tr
(+)cgCJoJ
XoF-
(
XoF-
r
Xof-
(
XoF-
t
XoF-
r
XCf-
t
Xct-
r
XcF-
r
Xof-
(
Xol-
l
XoF-
(
XcF-
{
XcF-
r
XoF-
{
XoF-
(
XoF-
(
Xo?
Xc-
XcF-
(
Xc?
Xo?
XoF-
r
Xof-
r
Xof-
r
Xc-
Xor-
<
ozbI
cg
E-
{
+Jt-q)
tllrHe.-a)E,
rn
\f
,O,IIN
O,
\n
I
O-
,
(r
)
$o\I
0-
,
.
A-
'
.
IaU
N-tO.II$
co$O,II
\f
,
\ooo@O,I
O-
,
.
(r
)
O.
\n
I
O-
.
.
(r
)
-f
,O.IIc\
F-o\IX
!oO,
\n
I
o.
,
,
(.
/
)
oo
.f
,
f-o\IIN
f-$f-o\II
6a
rnf-O,tN
\n
f-o\IIe!
OaI
()Dorr
.
l
IaU
$II
d
IO.DC.IaU
\nO,!I
\oOO.I
=t
oo
Io-
NIaO.
NII
CA
tI
CA$IO-
oo
II$,.
n
ca$IUo-
q)
:)06nBt)
q
a
.-
l
3;os
L
+r
)
-dNH
H<
!
tr
2
ocd
o
o
ocd
oCO
od
o63
ocd
o
oCO
d
o03
ocd
oCd
oCd
aUJooO
lJ
-
IaU
aUJo1,oo
lJ
.
Ia(J
aUJoOO
tr
-
,
,
Ia(J
aUJoott
IaU
a(-
)JoEooLL
IaU
aUJoEoC)
lJ
.
.
IaU
aUJoEC)orr
IaU
aUJoOOt!
IaU
aUJoOC)
tL
IV)U
aUJooOLL
IaU
aUJoEoo
IJ
.
Ia(-
)
cd
d
()
()
l-
O
aOt<
=C)L.
O
O
=()
t-
()
)()
l-
ot-OOd,I0(-
)
=O$<
ol-
=()
t-
()t-L)o&IaU
(Jo&IaQ
()o&IaU
oo!aU
O0)dIaU
()odIa()
()C)
d,!oU
O0)IaU
()6)IaU
C)OIaU
oocIaU
()C)
d.
,
IaQ4
()OcIaU
()o&!aU
tJ
,

A
oo
A
6
O
.F
{
7\
\
\
JL/

F{

c\
Ot
s
l
<
FU
R
EE
.*
E3B
r!
a
@ob0
adAFH0)
)-
{
t-
{oCO
(a+)Ec)EC)
lr
.---E,
q)
iltrEl,trcngs--0!+\oN
..
i
l
'i

Fr
tr
-
U
-l
-
.g
v
EOGl

''
'
J
2r
)
LC
J
G)
.t
l
is--a{.
rA-0)-)<H3.--)grdaUtuaUotr
q)--{r
,A-tf.-Fq)CJatsCB
.i-aAEHoU!=
a
rJ

rE
Fl

li
v)AL
Y=r
o
T3
E
oc
t
ts
{

+.
>,

r,
\
o\
(.
)OtoCd
oo
\.
tO+\oc!&fJ
.UO\f
,
oo
I
oo
I
(.
)
cnd,
o\
rnO'd
cd
oo
\nO+\oc!dt&U.+oo
I
oo
I
\r
)
cad.
o\
\aO'o
Gt
oo
(r
)O+\oc!&lJ
.
{UO.+oo
I@I
rncad,
o\
[nO€Cd
oo
(nO+\oc!dtJ
rUO.+oo
I
oo
I
\r
)
cad
o\
[.
|O€doo
(nO+\oe{&tJ
.
'
.UO$oo
I
oo
I
\ncad,
o\
\aoEcd
oo
\nO+\oc!&fJ
.
,
t)O$oo
I
oo
!
\ncad,
o\
rnOCg
oo
\nO+\oc{&fJ
.UO\f
,
oo
!
oo
I
\ncad
o\
lno'o
co
oo
\nO+\oN/,
tJ
.
,
.UO.+oo
I
oo
t
\r
)
cad
o\
\nO'(
,
ct
r
oo
tnO+\oN&tJ
.
'
,U$@I@I
[acad.
o\
\nO'o
cd@\n+\oNdIJ
-
.
.Q\f
,
oo
I
oo
I
\ncad,
o\
rno'o
cd
oo
\nO+\oc!
il
fJ
.
'
.UO.Soo
I
oo
I
\ncad
o\
(aO'o
Lr
CU
oo
l.
nO+\oe{&tJ
.UO.+oo
I
oo
!
\acad.
o\
\noEcd
oo
[no+\oc{&tJ
.
'
.U$oo
I@I
t'
acAd.
o\
\no.ocd
oo
\nO+\oe!
/.
tJ
-
,
,
(-
)
.f
,
oo
I
oo
I
I.
)
cad,
o\
\nO'd
doo
rnO+\oN&IJ
.
,
,UO.+@I
oo
I
|.
ncad,
o\
\nO'd
cd
oo
|.
nO+\oc!
d,
,
fJ
.
'
.UO.+or
f
I
oo
I
\ncad,
o\
(nOEed
oo
\nO+\oN&IJ
rUO$@I@I
facad,
o\
\no'o
cd
oo
\nO+\oc!
il
fJ
.
(-
)Orf
,
oo
I
oo
I
(ncad.
o\
\noEcd
oo
\nO+\oN&L\UO.f
,@I
oo
I
r)cad.
o\
\noro(s
oo
\nO+\oe{dtJ
rUO.+oo
I
oo
I
|.
r
)
cOd,
o\
(nOrdcd@\nO+\oN&tJ
.
'
.UO.f
,
oo
ImI
\ncad,
o\
\no€Cd
oo
(aa+\oc!
ilt\UO$oo
I
oo
!
|.
ncad
o\
(nOrocd
oo
\aO+\oGI&tLUtf
,@I
oo
I
rncad.
o\
\r
)Ordcg
oo
\nO+\oN&fJ
<UO$oo
!
oo
I
rncad
o\
(no.ocd
oo
lr
)O+\oe{&ILUO\f
,
oo
I
oo
I
rncod
o\
r,
/
)O'ocd
a\.
|O+\oe!&tLUOr+oo
t@I
\ncad,
-6\
l
c)
'd

q)
>:
-b
Y
rl
l

5)
or
u
)
'o
'1
,
'o
'o
'o
o
E)o
r3
'd
E
E
'o
'd
E
'(
,
.o
.o=g
'o
=c,
(,
J
EtoJ
'd
gJ
'd
=gJ
'o
(,
J
E(,
J
E)gJ
E=gJ
)o
)U
=o
=cr
)g
)q
=(,
g
)o
)q
=o
)o
)o
)g
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
J
gs
E
rO61
\On
sOn
rOo\
sOn
10o\On
sOn
sOn
sO
rO6|O
rO
a\O
yO6\O
10o\OA
10o\
sO
sO
rO6|On
sOn
sO
sn
s
sOn
sOn
sn
rO6i
:on
sO
rO6|n
C)aFr+)Faxq)
t)rxc
ot
{
--(,
EN
ocd
J()
(.
)O
E()b(
cBE"opO(d
0)
cd
otr=a-
ocd
Ocd
o()ooO(.
)b{
cd
TL
0)d
Oc0
}4()O()
'(
,
C)b{
cdG'(
,
()cd
oCB
ooOo()obI
cd
tL
o63
ocd
o63
}z()O(J
'd
C)o0
cB
'o.oo63
od
I=O-
0)
cd
od
ocn
od
o()Oooob{
cB
tL
N
dxo
.
tr
(+,ct
()oJ
XoF-
r
XoF-
{
Xof-
{
XoF-
(
Xof-
t
XoF<
XoF-
(
Xof-
{
XoF-
r
Xol-
l
XoF-
(
Xol-
4
Xo-
Xof-
1
XoF-
(
Xol-
l
XoF-
{
Xo-
XoF-
{
XoF-
r
XoF.
r
XoF-
(
Xct-
{
XoF-
{
XoF-
r
XoF-
,
(
dzbr
6gE'
t
+Jt4-q)-H)rc
rl
--Efr
)
o\OtI$
II
\f
,
oo
tIN
\nO.II
A.
l
Oc!I
o<<<zo<
IaU
NO.II
o\II
o\
eo
f-
Io-
ooco
f-
Iao-
,
coO,II
caO.II
$OtI!
.<
rO.II
N.f
,
f-
Io-
oooo
II
-f
,
\nca
f-
IUa-
o\
oo
II
.+
Oo\It
.+
o\IIN
f-
II
A.
l
NOt
o<
!a(J4
f-Oo\II
ooo\It
OtOO,II
It\
l
o\I
aGl\
l
IO-
o+)a6tB3.
E
os
rd
-
L+
)
-,
4NH
H<
r
ir
2
aUJooOtJ
.
!aU
aUJooC)
tJ
.
'
.
IaU
aUJoEOO
tJ
-
,
taU
aUJoEOO
tr
-
,
,
IaU
aUJEoO
tJ
-
.
r
IaU
aUJo'o
oo
tJ
-
,
IaU
aUJooo
tJ
.
IaU
aUJoEoOtu
IaU
0UJ1,C)o
tJ
-
.
.
IaU
aUJooO
tL
,
IaO
aUJoOO
I,
L
IaU
aUJo-oOOtu
IaU
a()JoOoIJ
.
taU
aUJo
'd
ooEIaU
aUJoEoO
IJ
.
IaU
aUJoot!
IaO
aUJo€o0)
IJ
.
'
,
IaU
aUJoEoO
fJ
.
'
,
IaU
aUJo1,oo
fJ
.
'
r
taU
aQJordoC)
r!IaU
aUJo
'o
oO
fJ
.
taU
aUJoEOo
tJ
-
.
IaU
aUJoEoo
IJ
.
'
,
IaU
aUJoEOoIr
"
IaU
aUJoEoo
tJ
.
IaU
aUJooo
lJ
-
,
IaU
Hg
8
.
tr
{
7\
\
VL/

F{

GI
O!
l
<
t-
{
U
R
E.
E
g
EB
tr
l

a
o\ob0
CBOr
o
ritr0)
troCd
a.{
-
,
trodx:oL
'.
-
I-IIJq)ttrtr
{-
)
trcncE--al+\oN
..
t
iF
E
tr
-
U
tr
l-g
3
EO
cg

+)
2+
,
L9
q)
.F
is--a:)Axq)axHg
.F
l
-)I:vFE
I0Urr
l
elUIcl
Er
l
od
I*,
d
I{i
).-B0)
Iaxct
a
rr
{-atL.xoUq!
aaa
1
rd
!
Ab
Y=E
i5
E
oc
l
It
{

+,
o\
\n<>doo
(n+\oc!
/.
,
fJ
.
,
.Usoo
I
oo
!
(nc.
)d,
o\
(nO'd
Cd
oo
rn+\oc\&tJ
.
'
,U\f
,
oo
I
oo
!
rncad,
o\
\nO.odoo
\n+\oN&tJ
.
'
.U\f
,@!
oo
I
\ncad,
o\
\naod
oo
\nO+\oe{&tJ
rUO-too
I@I
\nead
o\
(nO'o
(d
oo
(oO+\oN&tJ
.
'
.U-too
I
oo
I
\ncad,
o\
\nOE(d
oo
\nO+\oc\&fJ
.
,
.U.+oo
!
oo
I
(ncAd
o\
\nO'o
Cd
oo
roO+\oc\&tJ
.
.
.U$oo
t
oo
I
tr
)
cad
o\
(.
)O'o
cd
oo
\n+\oN&IJ
.
'
.U\f
,
oo
I@I
r.
|
cad
o\
\nO'o
doo
rn+\oN&tJ
.
,
.U$oo
I
oo
I
\ncad
o\
(na'o
cd
oo
[n+\oe{&IJ
.
()O.+oo
t
oo
I
(neAd,
o\
tnECU
oo
(n+\oc\dtJ
-
,UO.+oo
I
oo
thcr
)d
o\
\nOcd
oo
(nO+\oNr'
,
,
IJ
"U$@I
oo
I
(ncad,
o\
\na'o
cd
oo
tn+\oN&tJ
.
'
,U\f
,
oo
I
oo
!
\ncad,
o\
(.
)a'o
cd
oo
\n+\oN&tJ
.UO.f
,
oo
I
oo
I
(.
|
cAd.
o\
\nOEcd
oo
(r
)+\oc\&tuU$oo
I
oo
I
rncAd.
o\
\aO'oCd
oo
(.
)O+\oc\
r'
,
,
tJ
.
.
.U$oo
I
oo
I
rnead,
o\
(nO'o
cd
oo
(nO+\oNil
tJ
.
,U.+oo
I
oo
I
\ncad,
o\
(.
)O'o
cd
oo
\n+\oN&tJ
.
'
,UO.Soo
I
oo
I
\ncAd,
o\
\nO'd
cd
oo
|.
nO+\oc{dtJ
.
'
.U.+oo
I@I
|.
ncod
o\
\nOEcd
oo
t/
)O+\oN&TLU\f
,
oo
I
oo
I
(nead
o\
(nO'o
Cg
oo
\nO+\oN&tJ
.
'
.U.+oo
I
oo
I
(nead,
o\
l.
naCO
oo
\.
)O+\oN&fL(JO.+oo
I
oo
I
(ncad,
o\
(nOcB
oo
\n+\oNr'
,
tJ
-
,UO.+oo
I
oo
I
\ncad
o\
\nOcd
oo
\a
)O+\oN&tJ
.
'
.U-f
,
oo
I
oo
I
\r
)
ead
o\
\aE(d
oo
rn+\oN&tJ
.
'
.U.+oo
I
oo
I
\ncAd,
o\
\nOcB
oo
t.
.
)+\oN&IJ
.
,
,UO$@!
oo
I
l.
r
)
cad
-cgCJ
'd

a)
>,
:
-b
Y
-:
)
a,

(r
1
'o
E
'o
'o
)U
'o
€
'og
E
.o
'o
T'
'o
3c,
(,
J
'o
)oJ
)o
Ec,
J
'1
,
)UJ
'r
d
)C,
J
tgJ
Ea(,
J
'd
)(,
J
=(,
J
=(,
J
=oJ
)o
=o
)(,
=g
g
)gJ
aU
=(,
)(,
U
o
J
J
J
J
J
J
J
J
J
J
J
J
J
J
oE
f
ou
e
10O
10
rOo\O
r.
Oo\O
1(
)
o\O
sO
1OO
1.
Oo\O
10o\
10O
yO6\
rOo\O
10o\
rO61
\
O
rO6|O
rO61
\O
109\O
rg6|
s
1O9\
r.
Oo\
yO6\O
s
1.
Oo\
s
rO3\
q)
Atr3+,
dHq)
(1Elrc
.l
-Jgtr
l
0)
(o
o}zoot)
o03
Ocd
Ocd
oo()Ob{
ed
(t
0)d
o()oooC)b{
cd
tl
-
o
o
0)
o
O
o
'C
,
oo{b{o0)
cO
Od
€C)bIbI)I0)
63
Ocd
ocd
b(Ob(
(€ol-
(o0)ooo.oxO
lJ
-
-
()oOOb{
c3
LL
()cd
O(,
)ooo{
cd
tJ
-
od
O
CO
(d
c0
co
Cd
d
0d
6t
dF(o
.t
<+)6gCJoJ
Xc?
Xot-
{
Xc-
Xo-
Xot-
r
XoF-
(
XoF-
(
XoF-
r
Xor-
<
Xcl-
1
Xot-
r
UJ
UJ
UJ
UJ
UJ
UJ
(JJ
UJ
UJ
UJ
Xot-
r
XoF-
r
XoF-
r
Xo?
Xof-
r
ozbI
cg
F<
.l
i
,
d)rq)
t4F(-o
.t
r
(
--FI
vrn
CAOIaO-
(n
II
\o
II
\oco
f-
Ix
f-co
f-
IX
f-Ntr!
lJ
-
0)dc0a,O.IFa-
mf-C!I
rr
.
I
Lt
-
OBC\IJJJ)Jaa-
f-NI
tL
ONII
\f
,
NII
.t
OcdCOoatsc{!
r\
6)doaNIFO-
$ca
IX
NNIIN
no
\f
,
ca
IX
CAc\IIN
$NI!
.f
,
lf
i
$OIX
IzcDf!
IUJ
ca
f-
I
IJ
.
]
Ir
-
oC\
CA
f-
!Fo-
mco
f-
I
rr
.
l
LL
>COca
f-
!
-l
o
l
iE
\O

(<
f-
=
r
(l
l
ao
,.
r
a
cn
f-
I
tL
q)
+)
(A6gBrr
)

!
-Jt
r
'-
-
9fd

l-
t
fr

+)
_d
{.
Y

I
Ni
l
':
:

13
L!
2
(r
)UJoO0)
tr
IaU
aQJo-oOO
fJ
.
I0(J<-
aUJoEoo
lJ
-
IaU
aUJo0)O
tJ
-
IaU
aUJo
'o
O0)
tJ
.
IoO
aUJoEOC)
IJ
.
IaU4
a()Joo0)
IJ
-
taUd
U)UJo-doOt:
-
IaO4
U)UJoOO
IJ
-
,
,
IaU4
aUJo0)oIL
taU
aUJo1,oo
lJ
-
Ia(J
aUJo0)O
lJ
-
,
,
IoU
aUJoEoo
tJ
-
,
.
IaQ
aUJooo
tJ
-
,
IaU
aUJoT,oot!
IaU
aUJo
'o
0)o
lJ
-
tat)
aUJoC)o
tJ
.
,
.
IaU
aUJEOo
fr
.
,
,
IaU
aUJoO0)
lJ
-
!aU
aUJo-ooC)
tJ
.
IaU
aUJoOOlJ
-
IaU
oUJ!oC)
tL
IaQ
aUJEOOIL
IaU
aUJo-ooO
tJ
-
IaO4
aUJo130)C)
It
IV)U4
aUJo
'o
Oo
tJ
-
IaU
x#
3
7\
\
V
l/

Fl

c\
t
Ot
s
k
F-
U
R
1E
.F

LI
3B
rJ
l

a
Oob0
CS
p<
6
f-
.
t-
{0)
)-
'
a
t-
,
{C)
(o
-C2+,E()E0)L
.l
I-uoiltrE+lL6geE--a\f
,
\oN
..
t
'i

fr
r-
U
i-g
g
so
cl

+r
E{
E
0)
.r
r
'
l
|E--0+,
trq)aEIc.---E'
F{aUtroUctr
q)E{.
,--.4
.
,
.l
Bq)CJAtsc!
o--g-H)roQEE
Y-Ab
Y=E
T=
E
o6
t
ts
{

t,
2,

u)
o\
rnO'ocl
oo
(nO+\oc!
/,
fJ
rUO$oo
I
oo
I
l.
ncad,
o\
\nOEcd
oo
\a+\oN&fJ
.UO$oo
I
oo
I
(ncod
o\
\nOEcB
oo
\nO+\oc!&IJ
.
'
.UO$oo
I
oo
I
t.
r
)
cad
o\
\nOEcB
oo
\n+\oc{&fJ
.
'
,Q$oo
I@I
rncad
o\
rnO'o
cd
oo
(nO+\oN&F-
.
.U=f
,
oo
I
oo
I
\ncAd
o\
(aOtdG,
rc!nO+\oc!&t!
.
.U.f
,mI
oo
I
\ncad.
o\
\ao.ocd
oo
r.
)o+\oN&tJ
.
'
.UO$oo
I@I
\ncad,
o\
(nO'o
cd
oo
|.
r
)+\oN&fr
.
.
rUO$oo
I@t
\nead.
o\
(nO'o
doo
\nO+\oNil
tJ
-
,
.U.f
,
oo
I
oo
I
\ncad,
o\
\no'o
cB
oo
(aO+\oc!&tJ
.
'
.UO.+oo
I@I
tncad,
o\
\r
)O'1
,
cd
oo
\no+\oNtJ
.UO$oo
I@I
\ncad,
o\
\nO'o
cd@tnO+\oN&ILUO$@I
oo
I
\ncnd.
o\
(nocd
oo
(n+\oN&IJ
.
,
(JO.+oo
!
oo
I
\ncod,
O
gHH
E.
.
B.
g
L.o
Eu9H-
9
L
r.
,
ac
d
Cg

{1
€EPE
.=

-o
EE
atr
a
od

(,
'+
j

O
'd

rq
tr
F
cd
d
l+
{

r\
o-
,

!l
9E
ti
j

'{
-
EEEE
a.
c
tv

,a
|-
a

-aHt
oq
9
ti

o)
tr
€
.-h\
f
,
)\
/
8c
:Es|
;
t}
4
C4
a=
td

l\
)
Fr

!)
.2
a
cd

tJ
*o
\J

(--
r-

+)
.-cd

co
l-

\-
.
/
,1
,=G
t-
-
,

11v
'b
b

<
t-

\-
/
.d
\L3E
=?A>
r
da
:=

cr
i
+-
r

.j

n
a=+'
=

9
tr

!)

'
-L
r
r-

:i
EE
E

.=
o
cY

p
:
=.
=

g
cv

EH

cO
-C
0
)
H
O
;.
P

V
9
O)
a
tr
C
J
(
,
)

i
(-
,
1
-
*
J
EO
A-
v
D
N.
'
5

i-
oo
-

7
tr
cs

/i

bo

'=
tJ
A

C
E
Ei
e

;
.=
)
E

p
'F
E
O
.=

F
'!
l

e0
5E

S
6
U
\.

J
-
I
(i
)
'

E
.2
==
a
u
L.
=O.
=

,
U
.F

i_
)

e-
=
E2
,
E

tr
Qr
(
)

6
a.
q,
,

:
'F
{
9F
E

+
J-
.

\.
/

d.

1)
+-
)

v
{.
)

(-
u-
O
€$
=

€
-{
n

E
n
3
o
5.

=
z
-j

e
Jr
-

^i
-cl
a)
'd

q)
>:
-b
Y
r-
{

g
&u
)
'd
'd
E
E
'o
'o
'o
T'
'o
'o
E
\,
'o
)c,
J
(,
J
)g
)o
)g
)q
)g
=g
=o
=(,
)U
=ct
=c,
J
J
J
J
J
J
J
J
J
J
J
*E
u
s
rOo\O
sOn
c)
\O
rO6|O
sO
sO
sO
rOo\On
sO
sO
1oo\On
rOo\o
€)cH.a
r
,
dxq)/}.
r
tso
.l
t-grd
C)
c0
Od
0)C€
C)
cr
3
6)CB
'd
oOI
b{E0od
OC€
'o
0)utb{ooao
()CO
ocn
b{ob{dot<()OoOo.oxo
tJ
-
c)b{
IL
'o6
ouCd
lJ
-
,E6
6t
-tio
ol+a
)
c€CJoJ
Xol-
1
c\UJ
NUJ
NUJ
NUJ
NUJ
NUJ
c\UJ
c\UJ
c\
()J
c\UJ
Xo-
XoF-
i
ozbrclH.l
r
,
t4tsq)
tH)ro
.r
{
-)UEd
f-
II$tf
i
f-
II$rf
|
0)
cdoCBoa>\o
f-
Io-
()cdoa3\o
f-
IFa-
\of-
IX
Nf-
I!c{
m6f-
Ix
CA
f-
tIN
$f-
II
\f
,
aa
r
$NIX
c\IzIJ
.
'
,
IUJ
tJ
-
,
!0N
t!mN
o{r
,06lF2.
E
iJ
-bq
r5
-
lr

{.
)
_dNH
aUJoE()O
tJ
-
,
IaU
0()Jo€C)OtJ
.
IaU
a(-
)Jo
'(
,
OO
IJ
.
'
,
IaU
U)UJ'o
o()
tL
,
.
Ia(-
)
aUJoOt:
-
IaU
aUJoEOC)
tL
IaU
aUJoC)O
fJ
-
,
taU
OUJo.oC)C)
tJ
-
IaU
aUJooOtL
IaU
aUJoEoC)
tL
,
,
IaU
aUJ-oOOlJ
-
IaU
aaU=oFIaU
aaUJoFIaU
tJ
,

A
oo
A
6
O
.F
{
7\
\
\
/L/

F{

t:
t
Ot
s
k
t-
{
b
R
tr
-
A
H.
E
LI
3B
rr
l

a
lo
()b0
(€0{
t-
-
t-
{oEocd
(r
)

I
aD
l
3lEIolEI
(l
)
l
li
l
ot
l,l
t1(l
)
l
il
ldmlEI
cr
lcEI=l
at
oo
,

El
F(
I

NI
sl

tl
Et

;l
+.
1
:l9t
(l
)
l
oiEI=l
al
:lEI
(l
)
lEI
tr
l
ot
l'lol
Fr
l
{l<lelUI
-lFI
IHI<l
ilil
cJ
I
f,ol
UIEIEIol
€lEI
O\
l
nlol
-l
'c
,
EIml
nlOI
-lrl
\O
l
e{
l
el
fJ
.
lulol$l
€l
-l
!l
oo
l
rl
\r
)
l
r-
l
co
l
&1
o\
l
rr
l
ol
-l
'o
l
tr
l
cu
l
€lnlOt1
\O
l
e{
1el
IJ
.
lUo$€I
€l
tnl
cod
at
r,
a
l
ol
-l
'o
l
Lr
l
cd
l
oo
l
rr
lol
$l
\O
1
Gr
1dl
tLU]O$olI
oo
l
I
In
l
co
l&
o\
ino'O
l
trcO@rnOr+\o(\
l&lLUO$aI€t
(nca&
o\
iao'o
L.cd
oo
\no+\o6l&g.UOsoo
I@I
rncA&
O\
l
rt
lol
;ls.
l
cr
l
l
rc
l
tr
)
l
ol
'-
l
t+
l
\O
l
NIel
q-
lUIol
\t
i€l
"t
l
rl
rr
l
ca
l
dt
O\
l
ta
l
ol
-lEI
tr
l
ct
l
l
oo
l
ra
l
o1
-.
]
.l
.+
l
\O
i
e{
ldl
fJ
.
l
U1O]
r+ml
I
€l
rl
(r
)
l
co
l
dl
O\
l
la
l
ol
:f
lEIEI
€l
|.
a
l
ol
-l
.+
l
\O
l
6t
ldl
tJ
.
l
OIol$l
oo
l
TIml
,A
l
ca
l
dt
6l
r,
n
l
ol
-'
iEI
tr
t
cs
l
oo
l
rr
)
l
ol
$1
\O
l
e{
l
d\
tJ
-
1
U1ol$oo
I
€1
!
(n
i
cf
l
l
&1
o\
raoEL.cd€ir
)o+\oc\&t&UO.+€I
oo
I
(r
}
cad
O\
l
tr
)
l
ol
-.
1
'o
l
tr
l
cg
l
rc
l
\r
r
IOIalsl
c.
t
l
dl
IL
I
UIOI
$I€trl
6l
,A
l
ea
l
&t
O\
l
tr
l
lOI
-l
'o
l
tr
l
(B
l
€l
t.
n
l
ol.t
!f
,
1
\O
l
c.
l
lel
q.
l
ulol
\f
,
1
oo
l
-.
1
rl
TI
t.
)
l
EI
O\
l
la
l
ol
-lEI
tr
l
Gl
l
oo
l
1r
}
l
ol
-l$I
\o
lNl
&t
fJ
-
l
UIol
'+
l
€lrlmlrl
rr
)
l
c.
r
]
&t
O\
l
ra
lOI
-{
l
'o
l
tr
lc!
€l
\a
l
ol
-l$l
\o
l
(\
r
l
elUi
O1
t;-.
1
|l
oo
l
rl
\n
l
ca
l
&t
o\
tr
)
1oFa
'o
tcl
l
oo
\aO+\o(\
ldtJ
.UO$@I@I
rl
^
i
l
co&
o\
iaoEtrcl
ooanO+\o(\
IdtJ
.Uo*oo
I
oo
!
!nca&
o\
!nO't
,
trCd
oo
\r
)o+\oc!dTLUO$6I€I
lr
)
ca&
o\
lno'o
trGI
oo
\nO+\o(\
t&tLQo$ooI
rc
I
\nco
N)
-l
o\
rao'o
Lrcl
oo
\nO+\o(\
l&tJ
.UO.f
,
oo
I
oo
t
\nca&
o\
\aoEHcl
oo
\aO+\o(\
l&tJ
.UO$oo
I€!
\r
)
ca&
O\
l
ia
iOI
-lEIgI
cd
l
oo
l
ra
l
ol
-I
.+
l
\O
l
Nldl
fJ
.
l
UIOI
$I
oo
l
-.
1+l
t.
n
l
-.
1BI
El
s
E]5lol
.-
JJ]
EslJ
EaC,
J
Ea(,J
E
\J
I
E]
EI
-o
"t
EI
.o
l
EI
.o
l
E
E
'o
'(
,
'o
E
'o
l
=l
g'
l
.
rr
l
JI
o
=lol
aq]
=lo
,l
tr
,
o
=lql
alsl
pl
o1
,l01
aol5
)(,J
aoJ
pC'
J
=oJ
=trJ
J
JI
J]
JI
J]
J
JI
JI
JI
JI
Hg
I

g
sOA
rOo\on
rOo\On
s=n
:Oo\oA
sl
-.
]A
:O6]
:oA
slol
;l
106i
\OA
s=n
slol
-lAl
slol
-'
lAl
slol
-'
lAi
sloln
10o\on
sIn
stol^l
s=n
sIn
s=n
stol
-'
lnl
e)EI
t'
t
I-,
ts€)
t-aIc
.l
Jtr
r{
ocl
ot>t
cl
l
>t
C)ct
itB4t#l

e
\J

OF
l!
ol

e.
)
>l

o
:t

ri
cd
l

al
l
>l

a
ol>l
Gt
I
>l
0)d
()Cd
ol
>1
cd
l
>1
A--aoar
l
I()q)
t,oo,l
lclq,JOcB
()
I>t
Gl
l
>t
ot>l
fr
l
l
>l
ol>l
cg
l
>t
(l
)
I>l
(n
l
olcl
otr)o.
c)GI
ot>tdl
>t
ot>t
Gl
l
>l
OI
>t
c€
l
>l
ot>t
cd
l
>I
Il
L.
lol
r-
l5)
lol

ot
9l

El
Et

*l
HH
I
tr
l

€l
EIol
.-
l
{r
r
l
6l
lelol
Fl
l
oO.oout
mtQIolol
b{
Ea
t
mlelol
ot
b4
HI
xoFoobl
xtol
FI
:l
ototo{
HI
EO.oobI
-t
EAO.ooOI
maooat
ts
r
l
xoFoout
Fa
xtol
FIblOI
b{
HI
x1o1
F1\olob{
-a
l
xlol
F1
\t
oo1b!
H1
xoF\oobI
H
xoFoobI
tl
xoFoo0t
H
xlolHol
otbI
-l
XIolHol
oto{
xlolHolol
b{
HI
xl
otFIblolo!
rl
xlol
FIEIbI
Hl
xlol
FI
-l
ololb{
ti
dt
z1bi
ct
l
HI
-lEI
o)Ec.--)Efr
f
OI
6r
l
\a
l
"l?l
olnl$l
}I
6l-l
ra
t
oo
l
rl
?l
olol$lhl
o,
l
;tmlrl
?l
6l^l$l
\tca
l
\O
l
\O
l
f-
l
oo
l
rl
?l
alr{
l
oraoo
IX
\O
l
\O
l
hl"l?l
^l^l{l
eo
l
f-
l
\O
l
\r
r
l
"?
l
?l
^l^l{t
ea
t
oo
\o(aoo
I
t'{ca
ot
f-
l
f-
lTI>ltt
ol
6t$l
\l
c!
l
o1
(^
l
oo
IX]
oc{
\ooo
I
.!+eA
\o\o@ooII
6t+ca
(\
l
!f
,
(r
}
oo
!I
o!f
,eo
rn\ooooo
I
3l
!+ca
ca
l
olnl
oo
l
d.
l>l>l
O.
l
ea
l
$l
\r
t
l
oo
l
rl
>ltl
^{l
ca
l
$l
$1
ln
l€rI
oc{
\_
\n
t
rl
\a
r
l
oo
t
rl
?l
GolGt
i
\*
\O
isl.
aoo
I?66$ca
r-
l
$(r
)
oo
I
.l+\\co
f-\n@IF|r
r
loO.
ol
;lct
l
BlEI

E
sl

E
JI
il
(,
t
-lOI
rr
lmlrl
XIEI
JI
()
l
EOoI!Ji()
'o
l
otol
fL
l
JI
il
(,
t
JIelol
e{
l
ol
\r
r
l
"lXI
c0
l
JI
(,
l
E0)o)
ILJi(,
'o
oOfJ
.Q
'o
l
ol
ot
Ir
.
l
o)
l
+r
l
al=lOI
JI
Ef
r
H
7\
\
v
\.
/
F
{
G
t
PH
E
1E
!)
3B
I!
0
Nob0
CB
F<
6
f:
.HoHoCS
r)
t
u)
t
+.
1EI
(l
)
l
EIol
L.
l
ol
l5l
tr
1ol
tr
l
tr
l
tr
lEIclasl
rl
l
-lat
rl
o
ol

\O
l
F(
I

NI
sl

sl
f;
l

?i
fi
l

:l
ir
]
T191
(l
)
1
o_
{€t
,t-at)a€)E9l
.l
=E'HF1i()UHFlH
(l
)
l
sl
.E
l
rlel
EI
6t
l
=I
tr
l
5lEIEI€lEI
O\
l
nlol
-r
lEI
tr
l
dt
rc
l
nlol
-lsl
e{
ldIL(J
]ot@I
oo
I3eod
O\
l
rr
lol
-'
l
'o
l
tr
l
cu
l
ml
la
l
ol
-l
.t
l
\O
l
6ldE(-
)o$@I
oo
I
ip
o\
rr
)o"oL.GI€rao+\o6l&IL(Jo$@!
oo
I
rr
)
cf
l
il
o\
rao'o
trGI
oo
\no+\oc\
tdTL
(Jo$6!@I
rr
)
co
I&
o\
rr
toEEcl
oo
rr
|o+\oe\
ldrLUO\f
,@I
oo
I
\nca&
o\
rr
}oEtrcl€rao+\o6l&tJ
.Uo!CooI
oo
I
racod
o\
ir
)o'o
1
tr
l
(t
l
l€ro$\o6l&fJ
.Uo.t@I6I
raB
o\
iao\JtrGI
oo
rnO+\oGIdtJ
.UO$@I
oo
I
rr
)
cAd
O\
l
in
l
ot
-lEI
tr
l
cl
l
ol
rr
l
ol
-l$l
\O
l
tr
t
lel
rL
lUiolS]
oo
]
I€I
ra
l
B]
6iaoEtrcB@l.
r
)a+\o(\
ldtJ
.Uo.f
,
oo
I
oo
I
rncad
o\
\aoEtrc,@rno+\o6ldtJ
.UO.+oo
I@t
raca&
O\
l
la
l
ol
-(
l
EI
tr
i
cd
l
rc
l
tr
l
l
o1
tf
,
l
\oe{
ldtL
lUo$€I
oo
I
\a
r
]
cf
)
l
d)
o\
ioovtrCO€rnO+\o6ldtLUO$oo
!@I
racad
o\
(no1,L-G,€inO+\oc{dILUo$oo
!
oo
t
\ca
il
o\
rno'o
trc0€iao+\o6ldILUo$@I
oo
I
rca&
o\
1r
)oEtrcl@(r
)o+\o(\
IdILUot+oo
I
oo
I
t.
a
ca&
oir
}oEEc,
oo
\no+\o(\
I&tJ
.Uo$oo
I@I
ir
}
ea&
o\
r.
a
lo1r
l
tr
ldl
€i
\a
lo-l
\t
l
\O
l
c{
l&rL
l
U1o$1@I
oo
l
t
l^
l
'-
]
c.
t
l
d
o\
!4
1oFaE]
tr
l
cr
l
l
oo
ir
)
loFT$\o6l
il
IJ
.
]
U1otml
I
6
I
la
l
'-
]
cQ
l
x)
o\
ir
|o'o
trcl
oo1r
)o-t\o(\
l&tL
lUo$oo
!
oo
l
I
\a
1
co
l
&1
o\
rr
)o'otrCd
oo
\nO+\o6t&tLUo$€I@I
rr
|
cr
lx
E|
;
E)U
.IlJ
E
E
E
'o
.o
E
E
E
E(,J
E)oJ
E=s]
J
E)qJ
E)q
'o
-Jo
.oa(,
'o
F,t
€l,to1
EIal
o1
'o
o
E=oJ
tJoJ
ugJ
IgJ
ao;i
ao;5
)(,J
)oJ
ao1J
J
J
J
J
Ji
JI
J
Hg
I

I
so;
rOG)
\on
s=n
s=n
s=n
s=n
s=n
s=n
son
sIn
s=A
soA
s=n
sIn
s=n
s=n
sIn
s=n
sIn
sOn
s=n
(uoH.J
EIOELtr
.---E'
fr
l
*-oclL{-
,a+,0)
JQcto
0)
c0
ocl
0)
cO
c)cl
ocl
ocl
0)
cr
l
o)cl
'o
obt
trc,
tr
'o
troo)
ct
aEI
=,
l
O.
l
,-
lEoaoc(J\,0)
cO
tg6-+tol*il*0)cl
c)ct
l
OGI
c)c,
ol
ct
l
oGI
olcl
O]
cl
ilclol
.
-r
l
5)
l
ol

a
gl

E
Ht

{
HH
tr
l

€
EIo
.-
lTcCJoFl
xoFoobt
H
xoFooEH
xoFEo{
H
xoFoou!-
xoFIbI
ha
xoFaohl
F.
i
xoFoobt
|<
xotoobt
H
xoF8at
xoFooat
xloF]
\ool
b{
:-
(
i
xoFoobT
xoFoobl
l-
(
xoFoobl
H
xoFo,oal
)r
(
xtol
tiolol
b{
Hl
xoFoobl
xoFoobl
H
xoF8bt
XoFoout
xoFoobl
l-
a
dzETctr+.EIoEe
.r
l
-l-gri
].
-o\n€IFJ)-
a
tJ
.
oo
r+
\r
)@I
.ltca
f-ca
rr
|€tX
O,
\o\aoo
II
aG$ca
of-\n@II
G6$ca
fr
.
raoo
II
aa$ca
ooco
(oo
!X
(\
I
f-\a€!I
G{ca
ca
f-(n€I
.ltca
tfr
.
\noo
I
.ltcA
(\
I-rr
l
oo
IO-DO.
f-f-\aoo
t
.lt
\o
fr
.
\r
)
oo
I
ll{
\n
f-|'
noo
II
ao$ca
oo
f-\noo
I!
o$co
!+
l
r-
l
oo
l
oo
I?l+l
ca
l
rf-oo@I
.ltca
\of-aoo
II
66r+e?
t
fr
.
f:
.oooo
I!
6ntca
f-\orc
II
i6tca
6l
f-\o@IFoO.
(l
)
I
al
Gt
!
Bl3l

E
r,
l

F,
Ll
r
cr
l

E
f;
l

g
oLoodoPaBoJ
E0)Of&G)+,a>s
'o
0)C)
tJ
.
(,
'o
o0)
ILJto
He
8
7\
\
Y
\.
/

F.
{

6t
8H
E
1E
.l
J
3B
rr
l

a
ca()bo
(nP{?O
>{o(o+)
5)
fQ
l
al
{J
IEI
(D
l
EI
(l
)
l
LI
.-
l
!lol
(I
)
I
il
l
tr
l
tr
lEIcl
tr
l
et=t
at
..
,

El
nl

Nl
=l

fl
El

:l:lc)
t
(l
)
l
._
{EI=t
at
l)
IEI
(l
)
l
EIol
.-
l
=l
tr
t
rd
l
rl
(,
tUI
r-
l
El
l
HI<t
ililEI=lEIot
UI
tl

,g
El

{
(l
)
l

ct
E!

A
o\
\aoEL.c,
oo
\nO+\o(\
ldtLU$oo
I
oo
!
l.
acad
o\
rnoEGI@rno+\oGIdIL(Jo$oo
I€!
rca&
o\
\aoEL.cd@(r
)O+\o(\
t&ILUO$oo
I€I
tr
|
ca&
O\
l
nioi
.-
l
"o
l
tr
l
(d
l
oo
l
lr
)
l
ol
-1ri
\O
i
ot
i
dl
tL
I
U1ol
rlolrl
€ltl
tr
l
l
eo
l
dt
o\
rao-Etrcd
oo
rr
)Ot\o6l&ILUo$oo
I€I
\nea&
/+6la€D*t(l*CD**Etil
F{
.s
o\
rrorcl-cU@tr
)o+\o6t&tLUO!+oo
I€I
ir
}
tt
/.
F6lf
)+?Eto[
tf
)+t*lJ
.oI
€D
t\+
,
il
"1
,
Fa
(*
o\
inoEFicr
l
l
oo
\nO!+\oe{&tJ
.UO$€I
00
I
ir
l
ea
l&
.F€l
ta
)
CD*tC*etdo*il$
O\
l
nlol
-lEI
tr
l
cd
l
ml
nlol
;l
6r
l
dl
fJ
.
l
UIol
\f
l
rc
l
-l
rl
TInl
t-
lea
l
dt
6l
ra
t
al
-ldtr
l
co
l
ml
nlol
-l
\f
l
\O
l
6r
l
el
fJ
-
l
UIol
rlml
-.
1+lnl
-lpl
O\
l
ln
l
ot
-'
l
-O
l
tr
l
cl
l
oo
l
nlol
-lsl
tr
t
l
dl
t!
lUIol$l
oo
l
4lnl
t-
lco
l
&t
H;
E=qJ
EoJ
aoJ
EI=t
C,
1
JI
E=C'
J
gfi
'l
C
aE'
J
H
Eol
J]
t'soo--I
EoJ
tolfi
EI=l
q1
.-
lJI
gfi
EI
:,
l
o'
l
JI
Hg
I

u
s=n
s=A
s=n
slol
-'
lni
sOn
sl?l
s=n
>F?
son
s6Jr4
s=n
*
s=A
slol
;l
c)
tr
t'
(
traE€)
aIta
.i
tJgrd
otb[ql
Gl
l
EI
6)
t
.E
lGt
l

C
-b
l

o
3l

E
tl

r
tr
l

u
Gl
l
()
l
.-
l
EIol
6l
--
r
lBtcl
.9
1
!.
1olOIql
tr
lolololb{El
-
ct
l
l

cr
l
tr
l

9
oGI
o)
I>I
Rl
l
>l
aEO.
EI
E1dl
0)
c0
ol>d.(l*
Gt
l
()
l
EI
-q
l
()
I
--
*
l
3tel
ot
.
-r
lEIOIclclol
()
l
oJo[cl

-
6d
l

cl
tr
l

B
OI
il
cd
l
>t
-v
lol
ot
-q
l
UI
+tI4(,
ol>t
G,
I
>t
TC*
ot>t
Gl
l
>tol
&.
1
!r
ltr
lol
(J
l
or
l
LIJIalalol
l.
i
l
o.
I
Eo
.l+.GI
CJoFl
xoFoobl
xoFoobI
Fl
xoFoout
l-
x1o1
F1
\*
1
olob{
l-
xoFoobI
'rt
xoFoobt
I(
FTIs
xoF\oobI
F-
i
I(oI.*
xoFooUI
l-
a
{UHr
xlolHol
ot
AT
t-
r
l
,i
l
xtOI
FI
\-
l
ololbI
F.
.
l
ozOIGF:)Eq)-Lxo
.-
l
--IFr
1
.f
lnI
\O
l
ml
,h
l
ca
l
€f-\o€*rH.
l
slOI
JI
o.
I
c{
l
f-
l
\O
l
oo
l
ll?l
ol$l
;l
rr
)
f-\ooo
I!
66$\co
\n\n\ooo
IO.DO.
ssd*;DEl
.
oo
l
r-
l
rO
l
oo
l
rlal
o.
l
6rl
.
\o6*6Fl
.
O00
\ooo
I
taO.
I{T*
ca
l
f-
l
\O
l
oo
l
*l
6l
l
\*
l
s\oT=ldr{
{
sl
f-
l
\O
l
oo
l
tl
?l
6l
l
\_
l
rt
'
FIs*-l({*
e{
l
oo
\O
l
oo
I
(JO-
(l
)
l
;lGt
l
BIEI

E
sl

E
I
Ef
r
E
7\
\
v
\J

F{

6t
8H
E
$E3B
tI
]
A
.f
,C)o0
cd0{
i
f-
.L{o>rL{o(o
('
r
l
at
i.
l
tr
l
l
(l
)
l
EI
(l
)
l
LI
.l
l
5lUIot
il
l
tr
l
fl5lLlcloAI
-l=t
al
.+
l
o
ol

\O
i
F(
l

Nl
F:
l

el
;t

Hl
Et

:l+,Ul
C'
)oo_
lEI=a+r
]Eq)Ee
.l
=E'
I
fr
tJ?()U-F]Er
(u
l
sl
tlc)
l
.E
l
EIUI
:lol
€lEI
O\
l
ta
l
ot
--
l
'l
r
l
tr
l
Gl
l
rc
l
rr
l
oi
-1s1N1dl
ILU]o$€!@I3cad
O\
l
nlol
E1tr
l
cl
l
oo
\r
)o$\o6t
iltL()a$@I
oo
I
t,
ncq&
o\
iaoEtr(!€\o+\oGI&tJ
-Uo\too
!@I
\nB
O\
l
nlol
-l-d
l
tr
l
Gl
l
ml
rr
l
ol
-l
\f
l
\O
l
tr
t
l
dl
tl
IUIol
:t
l
rc
l
4l
1r
)
l
-.
1
cf
l
l
dt
O\
l
r,
a
l
ol
-.
1EIEI
rc
l
lr
)
l
ol
-l
.+
l
\O
l
r\
lel
lL
lUIol$lml
5l
"P
l
\r
r
l
-leQ
l
&t
O\
l
ta
l
ol
-.
1EI
tr
l
cl
lml
lr
}
l
ol
-l
'+
l
\O
l
e{
l
dl5lol$lml
-lrl
oo
l
rl
l.
a
l
t-
lca
l
&t
alr
)
l
ol
EI
tr
l
cr
l
@l
(a
l
ol
-l$l
\O
l
NI
il
l
fJ
.
l
ulot$l€tl1
oo
l
rl
\r
r
l
-.
1
c?
}
l
dl
6l
ta
l
al
'o
l
tr
l
cl
l
€l
1r
)
l
OI
--
l
tl
\O
I
e{
l
dl
rL
l
UIol
\f
,
1€l
-ltl
€lrl
ta
l
ca
l
dt
O\
l
r,
r
}
l
OI
-r
lEI
-tcl
l@l
\n
l
ol+t
\o
l
NI
e\
IJ
.
1
U1o$oo
I€lI
\nca
l&
O\
l
ra
l
ol
-,
]
'o
1
tr
l
Gl
l€r1oa3(\
l&ILUotf
,oo
!
oo
I
rnca
il
o\
tr
loEqGI
oo
rao+\o6l&ILUo$oo
I@I
ineo&
o\
ilol
'o
trGI€rr
to+\o6l&tJ
.Uo$oo
I€I
rr
}
ro&
O\
l
ta
l
olE]
trcl
l
€l
\o-$\o6ldIJ
.UOr+@I€I
!c.
I
d,
o\
1r
}oEgCO€rno+\o6l&tJ
.Uo.+@!€I
raca&
61
la
l
ol
-lEI
tr
l
cB
l
ml
tr
)
l
ol
-.
1
tl
\O
l
c{
l
el
lL
l
(J
I
ol
.+
l
oo
l
ll
oo
l
rl
\A
I
-.
<
l
c.
l
l
&t
O\
l
(n
l
olEI
tr
i
co
l
€l
ta
l
ol
-l
!+
\o
1
6t
ldILU]o$t6lI€1I
ln
l
co
l
&1
O\
l
rr
lol
-1
't
l
sl
cl
l@l
1lol
-lrl
\o
1N1e]
fJ
-
1
u1oi
.+
l
oo
l
r1@i!lq-lca
n
&1
O,
iao'otrc,€rao+\oN&ILUo$rc
I€I
r-c7
}
}YEI
E|
;
'o
ao-l
EoJ
EI,l
tr
1JI
EIatsl
JI
EI=l
s1
r-
lJI
EI
,lol
5l
E]5lUI
J
ar
l
31ol
J1
'1
,
atJ
EaoJ
'o
a(,J
Eag
'(
,
aC'
J
'o
)(,J
'o
l
=l
s1
atr
,
'o
l
=lE'
J]
'o
)oJ
J
JI
-J
Hg
I

s
s=n
slol
-'
lnl
slon
slolA
slol^l
slol
-.
1nl
soA
son
soA
s=n
slol
-'
lAl
slol
-l^l
106\on
s=n
slol
-ln1
son
son
son
€)aE(
1Jt-HoEa
.r
l
--rtH
EEI
€l
-_
l
:t€lOI
tr
l5l
()
l
oJboEI

_,
fi
t

sl
o)
cO
ocU
0)GI
Gt
l
OIHI
!l'lEI
'E
l
(J
!
G)
l
EI
ot
()
lai
b0El

-,
cd
l

cl
il
e
l
C)cl
0)cl
0.
)GI
0)
c0
OI>l
(€
l
>l
OI>l
cl
l
>l
(l
)
I>l
ct
t
l
>t
OI>l
G,
I
>l
€€)cc6lUGI
ot
lilAIOI>l
(d
I
>l
0)GI
0)cl
Gl
l
()
lEI
-t
r
1
ol
--
*
l
'l8
r-
l{J
l8t
tr
l
tr
lol
()
lolb[EI
-
cg
l

cd
il
9
ol>ldl
>t
rto
.r
l36l
IoF1
xoF]oobt
HI
aO.oobl
l-
(
aeoobI
-a
EI
rlolol
bd
-l
EO.oobl
It
EeooE-
EIalolol
b{
Ft
l
caO.oool
l-
a
ml
QIol
otbI
-l
E0
l
alolol
b{
tt
EQ]8o{
H
EA
I
o.
1El0{
HI
tr
IQIololg
tr
l
o1ol
e)U)-
.
1J]
troo&(JEaJ
EIolotelUI=l
EIolotelUI=l
EIolol
elUi
|-
(
lJI
oz0t6l
tr
IEO-lEc
.r
l
-l-gH
6to\
\o@IJJaO.
t+\n@II{ca
rr
}
(noo
II
.+eA
6U
\O
l
rc
l
TI?lsl
co
l
O\o\ooo
I
lro.
\o€oo
!I
.+ca
ot
\O
l
oo
l
?t?l
rl
\-
leo
l
ca
l
\O
l
ta
l
oo
t
rl
>Irl
rl-l
e{
l
\o
l
\n
l
mtrl
?l$l
\*
l
cA
l
f-oooo
rt$\\co
(\
l
\o\ooo
IHA
of-oooo
II{co
o\
\o00oo
Ii$co
6t
ca$oo
II
(\
l
O\
l
6t
l
$l"l?l
e{
l
-t
ea
l
ca
l
$l
rc
l
rl
?lSI
ol
en
l
$lTIFI
HlO.
l
tea$oo
Itol
(l
)
l
EIBI3l

E
EI

H
lr
l

r
cr
l

E
$l

g
alal
cr
ls:lot
rr
lgl

s
alal
cd
lsol
6i
lOI
rr
l
"lEl

I
6l

sl
EIotot
fJ
.
l
a;
l
!.
1al
ct
l
>l
>tclol
bT<t
Ef
r
E
7\
\
vL/

F-
{

ct
PE
E
1E
!)
3B
rq
a
\nob0
cB
p<?o
Ho(g
{J
o
('
)
ai'E€)E]
q)L.-!a-gl
€)
iltrtr3IrccE,l-at+
oo
l

\O
F{
l

t\
sl

s
f,
l

!
8t

v
\'
l

oi,+.
I€)
.r
lE=a+.E€)Ec
.l
=E'
FiFl
-r(,U-t]E(
:l:lelEIH:lol
EIol€lEI
O\
l
niol
tr
lEI
tr
l
c0
l
oo
l
tr
t
l
ol.l
$t
\O
l
ot
iel
tJ
.
1ui$l
oo
l
tt
oo
l
rl
nl
-.
1
ca
l
&t
o\
rr
)o'-
]E]
trcd
l€nlo$\o6ldlJ
.Ua$oo
I
oo
rnl
ca&)
o\
(AoFTEtrcl
oo
rnO+\o6ldtJ
.UO!+€I
oo
I
rr
)
ca&
,^o\
taetr
(1'Ec€lnetr
(+\oN&frUet\,€-t€I
laFt
(r
)
il
o\
\r
)o'o
cd
oo
l.
iO+\oe!dt&(.
)O.+€I@I
\ncad
o\
raoF.'o
trcl
oo
l
rao-rf
,
\o(\
ldILUo.+mI
oo
I
(n
l
ro&)
O\
l
\a
l
ol
-i
'o
l
tr
l
(€
l
€l
\r
r
l
ol
-i
t+
l
\O
l
6t
l
el
lL
l
U1ol
S]
oo
1
rl
oo
l
tt
(r
)
i
;<
l
ca
l
dt
o\
r.
)oEtrcl€\o+\o6tdtJ
-Ua$€I
oo
I
rcA&
o\
l.
r
)OEL.doo
raO+\o6tdIJ
.UO$oo
I
oo
I
rtB
o\
taoFa1,trcd
oo
rr
)
l
o-t\oc!dILUo.+oo
I
oo
l
tl
\n
l
ef
)
l
d1
fu
r
€l=l
o1
JI
'o
=trJ
'o
oJ
Eor
l=g.-FI
EagJ
E=qJ]
EI=ls]
JI
aqJ
'o
=oJ
E]=)qJI
HE
I

g
sloln
10o\On
rOo\On
set.
{A
10o\on
son
ro
l
o\
i
otAl
s=A
s=A
rO
l
o\
l
oln
€)0lH+r
-lx(l
)-Etsol
.-,l-sl
rd
ct
lolEI
-q
l
()
I>lclOI
EIol
tr
lclol
Ll
lol
br
OEl

-,
cd
l

cd
l
tr
l

B1
Ocd
Lro.l
r
lootro()ObIGI
tJ
.
^€€)
troGI
I€)-GI
C)
cd
oaaclUo6d
ot>l
Gl
l
>t
Eol
!,o1olel
tr
l
o1
u1o1o{
cl
l
lL
l
AFIo
.-
l+)GI
eJoFI
Eol
o1d]
U1
p<
l
JI
Eoo&()J
tr8d,Ul-
rJ
-LLooilUlr
iJ
o&UJ
troodUJ
Eiotol
dlUI
slJI
)-oodU-J
Foor.
/UJ
tr
lol
o1elUI
r-
t

1
J1
ozoi
6l
Fr€aIq)-LLo.-rt-tH
Oca$oo
IJJao.
rr
)
co$oo
II6t
ol
eo
l
\f
l
oo
l
dl
tr
.
l
N(r
)$€II
G-(\
I
F{
ea
l
$l
oo
l
tt
>tXI
f-cosf
,
oo
II6t
c{
ca$€IX
ooco$oo
IIGI
O,
l
co
l
$l
oo
l
rl
?lSI
\oeA
tf
,oo
IotJ
-
!
66oo\\ca
(l
)
I
+f
l
(a
l
ct
l
Bl3l

E
El

-'
Ll

+r
GI
I

E
fi
l

g
ao
o
EO
F.
I

N
HH
t-
i

l-
{
AE3B
rr
l

a
tJ
{
o3
\oOo0
(c
P.
{
t-
-
t.
.
'
a
(.
)
tr
t-
{
()
cC
o
o
o
TOCDF
Instrumentation and Waste Feed Cut-offTables
March 2009
ATTACHMENT 19
INSTRUMENTATION AND WASTE FEED CUT-OF'F TABLES
Consisting of:
Table D-I, Trial Burn Plans and Reports
Table D-5-1A, Liquid Incinerator #1 Process Data
Table D-5-2A, Liquid Incinerator #1 Automatic Waste Feed Cut-offs
Table D-5-lB, Liquid Incinerator #2 Process Data
Table D-5-2B, Liquid Incinerator #2 Afiomatic Waste Feed Cut-offs
Table D-6-1, Metal Parts Fumace Process Data
Table D-6-2, Metal Parts Fumace Waste Feed Cut-offs
Table D-7-1, Deactivation Furnace System Process Data
TableD-7-2, Deactivation Fumace System Automatic Waste Feed Cut-offs
Table D-8-1, Area 10 Liquid lncinerator (ATLIC) Process Data
O Table D-8-2, Area 10 Liquid Incinerator (ATLIC) Automatic Waste Feed Cut-offs
Index
Attachment 19 Page I
Instrumentation and Waste F""d Cru"#?"Cb:1.:
March 2009
Table D-l
TRIAL BURN PLANS A]\D REPORTS
Surroeate Trial Burn for Liquid Incinerator Number 1 (LICI)
o Surrogate Trial Burn Plan, submitted January 24,1995 and revised Api124,1995. Utah Division
of Solid and Hazardous Waste Tracking Numbers 95 .00325 and 95.01 95 1 .
o Surrogate Trial Burn Report submitted August 23,1995, and revised December 1, 1995.
Utah Division of Solid and Hazardous Waste Tracking Numbers 95.03837 and 95.05298.
Surrosate Trial Burn for the Deactivation Furnace Svstem (Dtr'S)
o Surrogate Trial Burn Plan, submitted March 9,1995 and revised August 8, 1995. Supplemental
DFS Trial Bum Test Special Conditions appended September 6,1995. Utah Division of Solid and
Hazardous Waste Tracking Number 95.03661.
o Surrogate Trial Burn Report, submitted November 20,1995, and revised December 12, t995.
Utah Division of Solid and Hazardous Waste Tracking Numbers 95.05217 and 96.00196.
Surrosate Trial Burn for Liquid Incinerator Number 2 (LIC2)
o Surrogate Trial Bum Plan, submitted June 15, 1995, and revised December 18, 1995. Utah
Division of Solid and Hazardous Waste Tracking Number 95.05551.
o Surrogate Trial Burn Report, dated April 19, 1996. Utah Division of Solid and Hazardous Waste
Tracking Number 96.0 I 98 8.
Surrogate Trial Burn for Metal Parts Furnace MPF)
o Surrogate Trial Burn Plan, submitted December 19,1995, and revised March 13,1996. Utah
Division of Solid and Hazardous Waste Tracking Numbers 95 .05572 and 96.01 1 81 .
o Surrogate Trial Burn Report, dated August L2,1996. Utah Division of Solid and Hazardous
Waste Tracking Number 96.03460.
RCRA GB Asent Trial Burn for the Deactivation Furnace Svstem fl)FS). GB Agent Trial Bum Plan, submitted November 29,1995, revised June 6, 1996 and August 13,
1998. Utah Division of Solid and Hazardous Waste Tracking Numbers 96.02580 and98.03.264.
. GB Agent Trial Bum Report, dated February 76, I 999, and revised }uly 7 , 1999. Utah Division of
Solid and Hazardous Waste Tracking Numbers 99.00735 and99.02812.
RCRA GB Aeent Trial Burn for the Liquid Incinerators (LIC)
. GB Agent Trial Burn Plan, submitted November 29,1995, and revised June 12, 1996. Utah
Division of Solid and Hazardous Waste Tracking Number 96.02670.
. GB Agent Trial Bum Report Liquid Incinerator 1(LIC1), submitted Revision 2 datedJuly 15,
1998. Utah Division of Solid and Hazardous Waste Tracking Number 97 .02654.
Index
Attachment l9Page2
TOCDF
Instrumentation and Waste Feed Cut-offTables
March 2009
GB Trial Burn Report for the Liquid Incinerator 2 (LIC 2), dated October 27,1997. Utah Division
of Solid and Hazardous Waste Tracking Number 97.04218.
RCRA GB Aeent Trial Burn for the Metal Parts f,'urnace MPF). GB Agent Trial Bum Plan, submitted April 20,1996, and revised October 30, 1996. Utah
Division of Solid and Hazardous Waste Tracking Number 96.04738. Modified March 12,1997,
Utah Division of Solid and Hazardous Waste Tracking Number 97.01013.
GB Agent Trial Bum Report, dated July 29,7997. Utah Division of Solid and Hazardous Waste
Tracking Number 97.03 1 83.
RCRA VX Aeent Trial Burn for the Deactivation Furnace Svstem (DFS)
. VX Agent Trial Bum Plan, submitted July 20, 2001 , and revised February 27 , 2002, and April 23,
2002. UtahDivision of Solid and Hazardous Waste Tracking Numbers 01.02406,02.00680, and
02.01364. Revised forpublic comment and approved July 5,2002.
RCRA VX Asent Trial Burn for the Metal Parts Furnace MPF). VX Agent Trial Burn Plan, submitted July 20,2001, and revised February 27,2002, and April 23,
2002. UtahDivision of Solid and Hazardous Waste Tracking Numbers 01.02408, 02.00680, and
02.01364. Revised forpublic comment and approved July 5,2002.
. VX Agent Trial Burn Report submitted December 10, 2003, revised September 30, 2005.
Utah Division of Solid and Hazardous Waste Tracking Number 05.03489; approved JuJy 2007 .
RCRA VX Aeent Trial Burn for the Liquid Incinerators (LIC)
. VX Agent Trial Burn Plan, submitted July 20,2001, and revised February 27,2002, and April 23,
2002. Utah Division of Solid and Hazardous Waste Tracking Nurnbers 01.02407 ,02.00680, and
02.01364. Revised forpublic comment and approved July 5,2002.
RCRA Mustard Asent Trial Burn for the Liquid Incinerators (LIC)
o Mustard Agent Trial Bum Plan, submitted December 21,2005. Utah Division of Solid and
Hazardous Waste Tracking Nurnber 05.04058, Revised June 2006.
Mustard Agent Trial Burn Report for the Liquid Incinerators (LICs), submitted Apil17,2007,
Utah Division of Solid and Hazardous Waste Tracking Number 07.01261.
RCRA Secondarv Waste Demonstration Test PIan for the Metal Parts f,'urnace MPF)
o Secondary Waste Demonstration Test Plan submitted May 26,2005, Utah Division of Solid and
Hazardous Waste, Tracking Number 05.03025.
Secondary Waste Demonstration Test Report submitted July 20, 2006, Utah Division of Solid and
Hazardous Waste, Tracking Number 06.02485.
RCRA Mustard Aeent Trial Burn for the Metal Parts Furnace MPF)o Mustard Agent Trial Bum Plan, submitted December 21,2005. Utah Division of Solid and
Hazardous Waste Tracking Number 05.04058. Revised June 2006.
Mustard Agent Trial Burn Report, submitted April 5, 2007,Utah Division of Solid and Hazardous
Waste, Tracking Number 07.0 1 1 30.
Index
Attachment l9 Page 3
TOCDF
Instrumentation and Waste Feed Cut-offTables
March 2009
RCRA Mustard Aeent Trial Burn for the Metal Parts Furnace (MPf,) (continued)
o Mustard 155 mm Projectiles Trial Bum Plan, submitted May 7 , 2007 Utah Division of Solid and
Hazardous Waste, Tracking Number 07.01457.
Mustard (H) 155 mm Projectiles Trial Burn Report, submitted April 3, 2008, Utah Division of
Solid and Hazardous Waste, Tracking Number 08.01235.
Attachment 19 Page 4
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-1A LIQUID INCINERATOR #1 PROCESS DATAI
Item
No.Control Parameter
Measuring
Device*[.ocation
Instrument
Range Expected Range
| 4b'c Agent Feed Rate to
Prirnary Charnberl 3-FIT-
127 At3-FrT-127B-
Mass Flowmeter
Vibrating U-
Tube Twe
hr-Line 0 - 1,500 lb/hr 0 - 1,209 lb/hr
2n'"Agent Feed Atornizing Air
Pressurel3-PIT-128
Diaphragn Plant Air Line
prior to Primary.
Charnber Waste
Feed Atornizing
Nozzle
0 - 200 psig 60 -75 psig
3h,.Agent Gun Nozzle
Pressurel3-PIT-l l2
Diaphragm Agent Line after
Pump
0 - 25 psig 5 - 25 psig
4 Reserved
5t,'.,Prirnary Charnber Exhaust
Gas Ternp. 13-TIT-610
Thennocouple In-Line 212 - 3,0000 F 2,550 - 2,8500 F
6b,t Secondary Charnber Spent
Decon/Process Water Feed
Rate 13-FIT-102
Mass Flowmeter
Vibrating U-
Tube Type
In-Line 0 - 2,250lbs/hr 0 - 1,809 lbs/hr.
7'\"Secondary Charnber Spent
Decon/Pl ocess Atornizing
Air Press Waste Feed
Interlockl 3-PSL-058
Diapluagrn Plant Air Line
prior to Sec.
Charnber Waste
Feed Atornizing
Nozzle
12 - 100 psig Setpoint 60 psig
gqe Secondary Charnber Slag
Gate Open Waste Feed
lnterlock13-ZS-361F
Lirnit Switch Outside Bottom
Secondary
Charnber
Not Applicable Not Applicable
gh'..Secondary Charnber
Exhaust Gas Ternp. l3-
TIT- I29
Thennocouple Incinerator Outlet 32 - 2,400" F 1,850-2,2000 F
9.atLt Secondary Charnber
Exhaust Gas Ternp tnw
Gas Tempemture Waste
Feed Interlockl 3-TSLL-
t29
Cument Switch In-Line 4 -20 nA Setpoint 1,822" F
[ 0h'"Exhaust Gas Flow Rate24-
FIT-943 I A,24-F IT-9431B
V-Cone In-Line at packed
bed scrubber PAS-
SCRB- 103 outlet
14,760 cfm 10,200-14,000 cfin
l0ah'"V-Cone Pressure (STP
pressure Comection) 24-
FIT-9431
Diaphrarn In-Line at packed
bed scrubber PAS
SCRB-103 outlet
8-13 psia l0-l I psia
lObn,'V-Cone Temperature (STP
Temperature Comection)
24-TtT-943t
Thennocouple In-Line at packed
bed scrubber PAS-
SCRB- l 03 outlet
100-200' F 140-l 80" F
I It""Quench Tower Exhaust
Gas Ternp.24-TlT-397
Thennocouple Irr-Line 0-300'F 140 - 225" F
I l.a'1"Quench Tower Exhaust
Gas Ternpemture High
Waste Feed Interlock24-
TSHH-089
Filled Systern In-Line 175 - 360" F Setpoint 225" F
l2b,'Quench Brine Delivery
Pressure 24-PIT- 100
D/P Cell In-Line 0 - 150 psig 40 - 150 psig
l3n,'Quench Brine to Venturi
Scrubber24-FlT-088
Electro-Magnetic
Flowmeter
ln-Line 0 - 150 gpm 100 - 120 gprn
l4h,'Venturi Scrubber Exhaust
Gas Diff. Pressure24-
PDIT-OgO
D/P Cell Verrturi Scrubber 0 -70in. w.c.20 - 50 in. w.c.
l5b''Clean Liquor to Scrubber
Tower Sprays24-FIT- I I 2
Electr o-Magnetrc
Flowrneter
ln-Line 0 - 1,000 gpm 400 - 800 gprn
16n,'Clean Liquor Delivery
Pressure 24-PlT-129
DiP Cell In-Line 0 - 100 psig 25 - 100 psig
LIC Tables
Attachment l9 Page 5
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-1A LIQUID INCINERATOR #1 PROCESS DATAI
Item
No.Control Pammeter
Measuring
Device*[,ocation
Instrurnent
Range Expected Ranse
l'lb,'Scrubber Brine pH24-AIT-
ogtA24-Arr-0el B
'Electrodes Discharge From
Pump llllll2
0 - 14 pH Units 7.0-l1.0pH
l gn'"Scrubber Brine Specific
GraviW24-DIT-083
Magnetically
Vibrated Tube
Purnp-PAS-
llllll2 Disch
0.6 - 1.4 sGU 1.0 - 1.20 sGU
lgb't'g'l Blower Exhaust Gas
co24-Arr-078
Infiared Cell
Analyzer
Blower Exhaust
Line (Extractive)
0-200&0-
5,000 ppm
0-100 ppm, one hour
rolling avel?ge, corrected
to 7o/o Oz dry volume.
20b,c,g'l Blower Exhaust Gas
cot3-AIT-083
Infiared Cell
Analyzer
ln-Line
(Extractive)
0-200&0-
5,000 ppm
0-100 ppm, one-hour
rolling average, corrected
to 7o/o Oz dry volume.
21.b,c,t Blower Exhaust Gas Oz24-
AIT.2IO
Zirconium Oxide
Cell Analyzer
In-Line
(Extractive)
0 -25%3-15%
22b'c,t Blower Exhaust Gas Ozl3-
Aff-229
Zirconiurn Oxide
Cell Analvzer
In-Line
(Extractive)
0 -25%3-15%
23"Blower Exhaust Gas Agent
PAS 7O4H''
ACAMSJ In-Line
(Extractive)
0 - sl2 sEu 0 - 1.0 sELk
24"Comrnon Stack Exhaust
Gas Asent PAS 70lGi
ACA]VISJ In-Line
(Extractive)
0 - 512 sEL-0 - 1.0 sEr
24a"Common Stack Exhaust
Gas AgentPAS 706Vi
ACAMSJ In-Line
(Extractive)
0 - sl2 sEr 0 - 1.0 sEL-
24b'Comrnon Stack Exhaust
Gas AeentPAS 7O7Hi
ACA]VISJ In-Line
(Extractive)
0 - 512 sEr 0 - 1.0 sELk
25"All BRA-TANKS Filled
Waste Feed Interlocl03-
LSHH.OO223-LSHH-
00623-LSHH-70223-
LSHH-706
Sonic l-evel
Switches
BRA.TANK.
IOIBRA.TANK
IO2BRA-TANK
20IBRA-TANK
202
Not Applicable Not Applicable
26 Slag Removal Systern
Shell I 3-TIT-3 74, I 3-TIT-
37 5, I 3-TIT-3 7 6, L3-TIT-
377
Thennocouple In-Lir"re 0-1000'F 70-500' F
Footnotes:
l. QA/QC procedures are found in Attachrnent 3 (Sampling, Analyical, and QA/QC Pnccedures).* Calibration information is shown in Attachment 6.o Reported value for agent feed rate is calculated by averaging the output of both mass flow fiansmittem.b Continuous monitoring with values being recorded electronically, appncxirnately every I 5 seconds.
" Continuous recording every hour with the rninimum and maxirnum values printed during one hour segment ofoperation.o Maintenance, at a minimum, in accordance with equipment manufacturerrs recommendations.
" Recorded upon activation or change in state of switch.r Only one analyzer active at any one tirne. The active analyzer provides the process variable to the controller. The Permittee shall
attempt to balance the usage time of each analyzer.g One hour rolling avemge is composed ofthe 60 rnost recent one-minute avemges. Each one-minute avemge is cornposed ofthe 4
most recent instantaneous CO process variables occuring at I 5-second intervals.I' PAS 704AH and PAS 7048H are the TAG IDs for the sarnpling location. One ACAMS is online at this location. A backup
monitol is available if the prirnary monitol is taken offline. Durir:g Agent Trial Bum performance luns, two ACAMS will be onJine
at all times during agent feed.
' PAS 701, PAS 706 and PAS 707are the TAG lDs for the sampling location. Two ACAMS are online with collocated DAAMS
tubes at all tirnes during agent opemtion for each agent.r ACAMS (Automatic Continuous Air Monitoring Systern) - ACAMS arr portable gas chlrmatogaphs configured to detect
airbome concentrations of agents GB, VX, or Mustard (IVHD/HT).k SEL (Source Emission Umit)- Thleshold values for the concentration of chemical agents in incinerator exhaust gases which have
been established by the Surgeon General of the United States to protect human health and the environment. The SEL (in mg/m3) for
each agent is: GB =0.0003, VX =0.0003 and Mustad ([VHD/HT) = 0.03.I One monitor is required to be online at all tirnes during waste feed. lf more than one monitor is onJine both will report data to
PDARS. All monitors onJine will be connected to a WFCO.
LIC Tables
Attachrnent l9 Page 6
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-2A
LIQUID INCINERATOR #1
AUTOMATIC WASTE FEED CUT-OFFS
Item
No.Tag Number Process Data Descriptionc Setpointk
I t3-Ftc-127 Agent Feed Rate Greater Than or Equal to > 1208 lb/hr Agent, one-hour rolling avemge
2 l3-PAL-128 Agent Atornizine Air Pressure kss Than < 60 psig
3 I3.PALL-II2B Agent Feed Nozzle Pressure at High Feed Rate kss Than or Equal to < 5 psig active l0 sec after LIC agent feed
pump is started and at feed mtes greater than
500 lbs/hr'
4 Reserved
5 13-TrT-610 Primarv Chamber Tempemfure kss Than < 2,544 F, one-hour rolling average
5.a 13-TAHH-610 Primarv Chamber temperature Greater Than or Equal to z 2,8500 F
6.13-FrC-102 Spent Decon Feed Rate Greater Than or Equal to > 1,809 lb/hr over one-hour rolling average
7 l3-PSLO58 Spent Decon Atomizine Air Pressure kss Than or Equal to S 60 psie
8 t3-zs-3678 Slae Removal System Discharse Gate Open Upper Cylinder Switch Closed
9 13-TIT-129 Secondary Charnber Temperature Irss Than < 1,822" F, one-hour rolling average
9.a 13-TAHH-129 Secondarv Chamber Temperature Greater Than or Equal to > 2,200" F
l0 24-FYt-9431 Exhaust Gas Flow Rate (Unit Production Rate) Greater Than or Equal
to
8,400 scfm, one-hour rolling average
ll 24-TSHH-o89 Quench Tower Exhaust Gas Temperafure Greater Than > 225" F
t2 24-PALL-100 Ouench Brine Pressure kss Than or Equal to S 40 psie
t3 24-Frr-088 Brine to Venturi Scrubber Flow l-ess Than or Equal to < 105 gpm one-hour rolling avelage
l4 24-PD[T-090 Venturi Exhaust Gas Pressure Drop kss Than or Equal to 532 in. w.c., one-hour rolling average
15 24-Frr-tt2 Clean Liquor to Scrubber Tower kss Than or Equal to
=
425 gpln, one-hour rolline aver?ge
L6 24-PYt-129 Clean Liquor Pressure l-ess Than or Equal to < 35 psig. one-hour rolline avelage
l7 24-AIT-091 Scrubber Brine to Venturi Scrubber pH l-ess Than to Equal to
=
7 .5 pH, one-hour rolling average
18 24-DrC-083 Brine Specific Gravity Greater Than or Equal to U l.l5 SGU, twelve-hour rolling average
l9 24-AtT-078 Blower Exhaust CO Concentmtion Greater Than or Equal to > 100 ppm, one-hour rolling average, corrected
to 7o/o Oz, dty volumen
20 t 3-AIT-083 Blower Exhaust CO Concentration Greater Than or Equal to Z 100 ppm, one-hour rolling avel?ge, comected
to 7o/o Oz, dry volumen
2t 24-AAt--210 Blower Exhaust Gas Oz I-ess Than or Equal to < 3o/o Oz
2l.a 24-AAH-210 Blower Exhaust Gas Oz Greater Than or Equal to > l5o/o Oz
22 t3-AAL-229 Blower Exhaust Gas Oz I-ess Than or Equal to < 3o/o Oz
22.a t3-AAH-229 Blower Exhaust Gas Oz Greater Than or Equal to > l5o/o Oz
23 PAS 7O4H PAS Blower Exhaust Agent Detected Greater Than or Equal to >_ 0.2 sELb,"
24 PAS 7O1G Comrnon Stack Exhaust Agent Detect Greater Than or Equal to > 0.2 sEL"$,'
24a PAS 7O6V Common Stack Exhaust Agent Detect Greater Than or Equal to >_0.2 sELuL'
24b PAS 7O7H Comrnon Stack Exhaust Agent Detect Greater Than or Equal to > 0.2 sElb"l
25 BRA.TNKS Brine Surge Tanks l0l, 102,201,202, Four [rvels High-High (BRA-
TNKS :23-LSHH-002 and23-LSHH-006 and 23-LSHH-702 and
23-LSHH -706\
I8'3" kvel
26 l3-TAHH-374
l3-TAHH -37 5
l3-TAHH -376
13-TAHH-377
SRS Shell Thennocouple Tempemture Greater Than or Equal to > 500" F
Footnotes* Waste feed culoffs recorded upon switch actiyation.
" One hour rollng average is composed of the 60 most recent one-minute auerages. Each one-minute average is composed of the 4 rnost recent
instantaneous CO process variables occuring at I 5-second intervals.
b The alann sefting (in rng/mr) for each agent is: GB:0.00006, VX =0.00006, and Mustard (IVHDIHT) = 0.006.
" l.ogic code description used to set the control WFCO alarms.
'r An Automatic WFCO occurs if the two online ACAMS are not staggered so that at least one unit is sampling the stack.
" In accordance with Condition 22.16.6.1 of the Agent Monitoring Plan for past agent, AWFCOs associated with GB and VX may'be disabled if no wastes
containing the agent are "inside the facility boundaries." This condition does not apply to the HVAC stack.
' Rolling avemge means the average of all one-minute averzge over the averaging period. A one-minute average means the average of detector responses
calculated at least every 60 seconds from responses obtained at least every 15 seconds
O
LIC Tables
Attachment l9PageT
Instrumentation and Waste Feed Crt-oJ?:#r:
April 2007
Table D-5-18
LIQUID INCINERATOR #2
PROCESS DATA1
Item
No.
Control
Parameter Measuring Device*Location
Instrument
Ranse Expected Ranee
l4b,c,d Agent Feed Rate to
Prirnary Chamber
l3-FIT-73 I A
l3-FrT-7318
Mass Flowmeter
Vibrating U-Tube
Type
In-Line 0 - 1,500 lb/ht'0 - 1208 lb/ht'
2b'c'tl Agent Feed Atomizing Air
Pressure
l3-PIT-736
Diaphragrn Plant Air Line prior to
Primary. Chamber
Waste Feed Atomizing
Nozzle
0 - 200 psig 60 -75 psig
3b,",c Agent Gun
Nozzle Pressure
l3-PIT-760
Diaphragm Agent Line after Pump 0 - 25 psig 5 - 25 psig
4 Reserved
5b'c'tl Primary Charnber
Exhaust Gas Temp.
l3-Trr-710
Thermocouple In-Line 212 - 3,0000 F 2,550 -2,8500 F
6b'c'0 Secondary Chamber
Spent Decon/Plocess
Water Feed Rate
13-FrT-763
Mass Flowmeter
Vibrating U-Tube
Tlpe
In-Line 0 - 2,250lbs/hr 0 - 1,809 lbs/ll'.
7rt1"Secondary Charnber
Spent Decon/Process
Atomizing Air Press.
Waste Feed lnterlock
l3-PSL-809
Diaphragrn Plant Air Line prior to
Sec. Chamber Waste
Feed Atornizing Nozzle
12 - 100 psig Setpoint 60 psig
g,t"Secondary Chamber
Slag Gate Open
Waste Feed Interlock
13-zs-5678
Lirnit Switch Outside Bottom
Secondary Charnber
Not Applicable Not Applicable
9b'c'tl Secondary Charnber
Exhaust Gas'Ternp.
l3-TrT-782
Thennocouple lncinerator Outlet 32 - 2,4000 F 1,850-2,2000 F
9.a'\"Secondary Charnber
Exhaust Gas Ternp.
[.ow Gas Ternpemfure
Waste Feed Interlock
l3-TSLL-782
Cument Switch ln-Line 4-20mA Setpoint 1,822" F
1gh,c,rl Secondary Charnber
Exhaust Gas Flow Rate
(Unit Production Rate)
24-Ftr-99024,24-FtT-
99028
V-Cone ln-Line at packed bed
scrubber PAS-SCRB-
203 outlet
14,760 cfm 10,200-14,000 cfm
lOan'""'V-Cone Pressure (STP
Pressure comection) 24-
PIT-9902
Diaphrarn ln-Line at packed bed
scrubber PAS-SCRB-
203 outlet
8-13 psia 10-1 1 psia
lgbb,",rl V-Cone Tempemture
(STP tempemture
c on'ectio n\ 24 -TlT -9 9 02
Thennocouple ln-Line at packed bed
scrubber PAS-SCRB-
203 outlet
100-200' F 140-180'F
1 t h,c'tl
Quench Tower
Exhaust Gas Ternp.
24-TrT-816
Thennocouple In-Line 0-300'F 140 - 225" F
I l.atl'"Quench Tower
Exhaust Gas Ternperature
High Waste Feed Interlock
24-TSHH-800
Filled Systern In-Line t75 - 360' F Setpoint 225'F
12tt,c,<t Quench Brine
Delivery Pressure
24-PIT-838
D/P Cell In-Line 0 - 150 psig 40 - 150 psig
LIC Tables
Attachment l9 Page 8
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-18
LIQUID INCINERATOR#2
PROCESS DATA1
Item
No.
Control
Parameter Measurine Device*Location
Instrument
Range Expected Ranse
13b,c,d Quench Brine to Venturi
Scrubber
24-FrT-828
Electro-Magnetic
Flowmeter
In-Line 0 - 150 gpm 100 - 120 gpm
14b,c,tl Venturi Scrubber Exhaust
Gas Diff. Pressure
24-PD[T-814
D/P Cell Venturi Scrubber 0 -70in. w.c.20 - 50 in. w.c.
l5b,c,d Clean Liquor to Scrubber
Tower Sprays
24-FYf -825
Electro-Magnetic
Flowmeter
In-Line 0 - 1,000 gpm 400 - 800 gprn
16b,c,d Clean Liquor
Delivery Pressure
24-PIT-839
D/P Cell In-Line 0 - 100 psig 25 - 100 psig
l7h'c'.Scrubber Brine pH
24-An-g3lAf
24-AYt-83 I B
Electrodes Discharge From Purnp
tnln2
0 - 14 pH Units 7.0-l1.0pH
13b,c,rl Scrubber Brine Specif,rc
Gravity
24-DrT-835
Magnetically
Vibrated Tube
Purnp-PAS-l I llll2
Disch.
0.6 - 1.40 sGU 1.0 - 1.20 sGU
1gh,c,g,l Blower
Exhaust Gas CO
24-AtT-716
Infiared Cell
Analyzer
Blower Exhaust Line
(Extractive)
0-200&0-
5,000 ppm
0-100 ppm, one-hour
rolling avelage,
corrected to 7o/o Oz
drv volume.
2gh,c,8,l Blower
Exhaust Gas CO
l3-AIT-778
Infiared Cell
Analyzer
ln-Line (Extractive)0-200&0-
5,000 ppm
0-100 ppm, onefiour
rolling avel?ge,
comected to 7o/o Oz
dry volume.
21n,",'Blower
Exhaust Gas Oz
24-ArT-717
Zirroniurn Oxide
Cell Analyzer
In-Line (Extractive)0 -2s%3-ts%
22n,")Blower
Exhaust Gas Oz
t 3-AIT-798
Zirconiurn Oxide
Cell fuialyzer
ln-Line (Extractive)0 -25%3-ts%
23"Blower
Exhaust Gas Agent
PAS 7O5Hh
ACAMSJ In-Line (Exhactive)0 - 512 sELk 0 - 1.0 sELk
24"Common Stack
Exhaust Gas Agent
PAS 7O1G'
ACAMSJ lrr-Line (Extractive)0 - 512 sELk 0 - 1.0 sELk
24a Comrnon Stack
Exhaust Gas Agent
PAS 7O6V'
ACAMSI In-Line (Extractive)0 - s12 sEu 0 - 1.0 sEL-
24a Common Stack
Exhaust Gas Agent
PAS 7O7H'
ACAMSJ Iu-Line (Extractive)0 - 512 sEL*0 - 1.0 sEL'*
25"All BRA-TANKS Filled
Waste Feed Interlock
23-LSHH -002
23-LSHH-006
23-LSHH -702
23-LSHH-706
Sonic lrvel Switches BRA.TANK-I OI
BRA-TANK-I02
BRA-TANK-2OI
BRA.TANK-202
Not Applicable Not Applicable
26 Slag Removal Systern
Shell
I 3-TIT-57 4, L3-TIT-575,
I 3 -TIT-5 7 6, 13 -TtT -57 7
Thennocouple In-Line 0-1000'F 70-500' F
LIC Tables
Attachment 19 Page 9
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-1B
LIQUID INCINERATOR#2
PROCESS DATA1
Item
No.
Control
Parameter Measurins Device*Location
Instrument
Ranse Exnected Ranse
Footnotes:
l. QA/QC procedures are found in Attachment 3 (Sampling, Analyical, and QA/QC Procedures).* Calibration information is shown in Attachment 6.
u Reported value for agent feed rate is calculated by averaging the output of both mass flow transmitters.
h Continuous monitoring with values being recorded electnonically, approximately every I 5 seconds.
" Continuous recording every hour with the minimum and maximum values printed during one hour segment ofoperation.tl Maintenance, at a minimum, in accordance with equipment manufacfurer's recomrnendations.
" Recorded upon activation or change in state of switch.r Only one analyzer active at any one time. The active analyzer provides the process variable to the controller. The Permittee shall attempt
to balance the usage time of each arnlyzer.
s One hour rolling average is composed ofthe 60 most recent one-minute averages. Each one-minute average is composed ofthe 4 most
recent instantaneous CO process variables occurring at I S-second intervals.
h PAS 705AH and PAS 705BH are the TAG IDs for the sampling location. One ACAMS is online at this location. A backup ACAMS is
available if the primary monitor is taken offline. During Agent Trial Bum performance runs only, two ACAMS will be on-line at all times
during agort feed.i PAS 701, PAS 706, and PAS 707 are the TAG IDs for the samptng location. Two ACAMS are on-line and collocated DAAMS tubes at
all times during agent operations for each agent.r ACAMS (Autornatic Continuous Air Monitoring Systern) - ACAMS are portable gas chromatographs configured to detect airtome
concentrations of agents GB, VX, or Mustard (H/HD/ffi).
SEL (Source Ernission Limit)- Threshold values for chernical agent emissions rates that have been established by the Surgeon General of
the United States to protect human health and the environment. The SEL (in mg/m3) for each agent is: GB =0.0003, VX =0.0003, and
IVHD/HT = 0.03.I One monitor is required to be on-line at all tirnes during waste feed. If more than one monitor is onJine both will report data to PDARS.
All monitors onJine will be connected to a WFCO.
LIC Tables
Attachrnent l9 Page l0
TOCDF
Instrumentation and Waste Feed Cut-off Tables
April 2007
Table D-5-28
LIQUID INCINERATOR #2
AUTOMATIC WASTE FEED CUT-OFFS
Item
No.Tag Nurnber Process Data Description'Setpoint&
I I3.FIC.73I Asent Feed Rate Greater Than or Equal to > I,208 lb/hr Agent, one--hour rrclline averase
2 t3-P AL-136 Agent Atornizine Air Pressure lrss Than < 60 osig
3 I3-PALL-7608 Agent Feed Nozzle Pressure at High Feed Rate lrss Than or Equal to < 5 psig active 10 sec. after LIC feed purnp is
started and at feed rates greater than 500 lbs/hr
4 Reserued
5 13-TIT-710 Pdmary Charnber Tempemture Irss Than < 2,544o F, one-hour rolling average
5.a l3-TAHH-710 Prirnary Charnber temperafure Greater Than or Equal to > 2,950o F
6.t 3-FIC-763 Spent Decon Feed Rate Greater Than or Equal to > I,809 lbs/hr, one-hour rolline average
7 l3-PSL809 Spent Decon Atomizine Air Pressure I-ess Than or Equal to < 60 psie
8 t3-zs-5678 Slae Removal Systern Discharge Gate Open Upper Cylinder Switch Closed
9 13-TIT-782 Secondary Chamber Temperature kss Than < 1,822o F, one-hour rolling average
9.a 13-TAHH-782 Secondarv Charnber Ternpemture Greater Than or Equal to > 2.2000 F
l0 l3-FrT-9902 Exhaust Gas Flow Rate (Unit Production Rate) Greater Than or Equal
to
8,400 scfm, one-hour rolling average
ll 24-TSHH-800 Ouench Tower Exhaust Gas Temperature Greater Than > 2250 F
l2 24-PALL-838 Quench Brine Pressure kss Than or Equal to S 40 psig
13 24-FrT-828 Brine to Venturi Scrubber Flow lrss Than or Equal to S 105 gpm, one-hour rolline avel?ge
L4 24-PD[T-814 Venfuri Exhaust Gas Pressure Drop I-ess Than or Equal to :.32 in. w.c., one-hour rolline average
l5 24-FtT-825 Clean Liquor to Scrubber Tower Less Than or Equal to S 425 gpm, one-hour rolling avemge
t6 24-PrT-839 Clean Liquor Pressure kss Than or Equal to S 35 psig
t7 24-AIT-831 Scrubber Brine to Venturi Scrubber pH kss Than or Equal to
=
7 .5 pH, one-hour r olling avemge
l8 l3-Drc-835 Brine Specific Gravity Greater Than or Equal to Z l.l5 SGU. twelve-hour rollins averase
l9 24-AtT-7 t6 Blower Exhaust CO Concentmtion Greater Than or Equal to Z 100 ppm, one-hour rolling avel?ge, comected
to 7Yo Oz, dry volutnen
20 t 3-AIT-778 Blower Exhaust CO Concentmtion Greater Than or Equal to Z 100 ppm, one-hour rolling aver?ge, comected
to 7o/o Oz, dry volutne"
2t 24-AAL-7 17 Blower Exhaust Gas Oz lrss Than or Equal to 53% Oz
2t.a 24-AAH-711 Blower Exhaust Gas Oz Greater Than or Equal to > l5o/o Oz
22 l3-AAL-798 Blower Exhaust Gas Oz lrss Than or Equal to < 3o/o Oz
22.a l3-AAH -798 Blower Exhaust Gas Oz Greater Than or Equal to > l1oh Oz
23 PAS 7O5H PAS Blower Exhaust Agent Detected Greater Than or Equal to > 0.2 sELb,
24 PAS 70IG Common Stack Exhaust Agent Detect Greater Than or Equal to > 0.2 sElhrl'"
24a PAS 7O6V Common Stack Exhaust Aeent Detect Greater Than or Equal to > 0.2 SELI"'L"
24b PAS 7O7H Common Stack Exhaust Agent Detect Greater Than or Equal to > 0.2 sEl-b"r
25 23-BRA.TNKS Brine Surge Tanks l0l , I 02,201 ,202, Four Levels High-High (BRA-
TNKS : 23-LSHH-002 and23-LSHH-006 and 23-LSHH-702 and
23-LSHH-706)
l8'3" lrvel
26 l3-TAHH -574
l3-TAHH -57 5
l3-TAHH -576
l3-TAHH -577
SRS Shell Thennocouple Temperature Greater Than or Equal To > 500' F
Footnotes* Waste feed cut-offs recorded upon switch activation
' One hour lolling avemge is cornposed of the 60 most rccent one-minute averages. Each one-minute average is composed of the 4 most recent
instantaneous CO process variables occuning at I S-second intervals.
h The alann setting (in rng/rn3) for each agent is: GB =0.00006, VX =0.00006, and Mustard ([VHD/HT) = 0.006.c logic code description used to set the contncl WFCO alanns.
'r An Automatic WFCO occurs if the two online ACAMS are not staggered so that at least one unit is sampling the stack.
" In accoldance with Condition 22.16.6.I of the Agent Monitoring Plan for past agents, AWFCOs associated with GB and VX may be suspended if no
wastes containing the agent are "inside the facility boundaries.
' Rolling average means the average ofall one-minute avemge over the averaging period. A one-minute avemge means the average ofdetector responses
calculated at least every 60 seconds fiom responses obtained at least every I 5 seconds
LIC Tables
Attachrnent l9 Page 1 I
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-6-1
METAL PARTS FURNACE
PROCESS DATA1
Item
No.
Control
Parameter
Measuring
Device Location
Instrument
Ranse Expected Ranse
| 4b'c MPF Prirnary Charnber
Tempemture Zone I
l4-TtT-152
Thermocouple Fumace 0-2,0000 F 1,170-1800*o F*
2\r1,c MPF
Temperafixe Tane 2
14-TIT-I4t
Thermocouple Fumace 0-2,000' F 1,360-1,8000 F*
]4tt,c MPF Primary Chamber
Ternperafure Tnne 3
l4-TIT-153
Thermocouple Furnace 0-2,000' F 1,260-1,800o F*
4 MPF Primary Chamber
Diff. Pressure
l4-PIT-070
D/P Cell Furnace -10.0 - 0.0
in. w.c.
-6.0 to 4.0 in.
w.c.
4.a.MPF Prirnary Charnber
Diff. Pressure High
Waste Feed Interlock
14-PSHH-034
Cument Switch Fumace 19.85 mA set point - 0.1 in.
w.c.
5qh,c MPF Afterburner
Tempemture
14-TIT-0652
l4-TIT-069
Thennocouple Afterburner 32- 2,7000 F 1,800 - 2,175' F
(,Ltt'c MPF Afterburner
Exhaust Gas Flow Rate (Unit
Production Rate) 24-FlT-9667 A,
24-FtT-96678
V-Cone In-Line at packed
bed scrubber PAS-
SCRB-I0l outlet
0- 16,990
cfm
10,000- 14,000
cfin
6a&n'"V-Cone Pressure (STP Pressure
Con'ec tio n) 24 -P lT -9 6 67
Diaphragrn In-Line at packed
bed scrubber PAS-
SCRB- l0l outlet
8-15 psia l0-1 I psia
6b'Ln'"V-Cone Tempemture (STP
Tempemture Comection)
24-TtT-9667
Thennocouple ln-Line at packed
bed scrubber PAS-
SCRB-l0l outlet
100-200" F 140-180'F
Jr\h'c Quench Tower
Exhaust Gas Tempemture
24-TIT-509
Thennocouple In-Line 0-300"F 140 - 225'F
'7.a.n'n''Quench Tower
Exhaust Gas Ternp. High
Waste Feed Interlock
24-TSHH-223
Filled Systern In-Line t75 - 360' F set point 225" F
8n'b'c Venturi Scrubber Exhaust Gas
Diff. Pressure
Z4-PD|T-222
D/P Cell Venturi Scrubber 0-50in.
w.c.
20 - 50 in. w.c.
9ub,c Quench Brine to
Venturi Scrubber
24-FrT-218
Electro-
Magnetic
Flowmeter
ln-Line 0 - 150 gprn 50 - 150 gprn
16n,h,c Quench Brine Pressure
24-PtT-233
DiP Cell In-Line 0 - 150 psig 70 - 140 psig
| 1tt
h,c Clean Liquor to Scrubber Tower
Sprays
24-FtT-248
Electr o-
Magnetic
Flowmeter
In-Lirre 0 - 1,000
gpm
400 - 900 gprn
l/a,o,c Clean Liquor
Delivery Pressure
24-PtT-258
DP Cell In-Line 0 - 100 psig 25 - 100 psig
l3a,D,c Quench Brine Specific Gmvity
24-DtT-216
Magnetically
Vibrated Tube
Purnp PAS Purnp-
l02ll03 Discharse
0.6 - 1.4
SGU
r.0 - r.20 sGU
l4n,b,"Quench Brine pH
24-Atr-224Ad
24-AtT-2248
Electrodes Purnp PAS-Pump-
l02ll03 Discharge
0- 14 pH
Urrits
7 -tl pH
MPF Tables
Attachment l9 Page 12
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-6-1
METAL PARTS FURI{ACE
PROCESS DATA1t]*;llNo. I
Control
Parameter
Measuring
Device Location
Exhaust Gas CO
l4-AIT-384
Infiared Cell
Analyzer
Blower E*huurt
Line (Extractive)
@
i t ou, rolling
II avemge.
I
I Sab'c Blower
Exhaust Gas CO
24-ArT-669
lnfrared Cell
Analyzer
Blower Exhaust
Line (Extractive)
0-200&0-
5,000 ppm
0 - 100 ppm, one-
hour rolling
average
l7\n,"Blower
Exhaust Gas Oz
l4-Arr-082
Zirconiurn
Oxide Cell
Analyzer
Blower Exhaust
Line (In-Situ)
0-2s%3-ts%
I g4b,c Blower
Exhaust Gas Oz
24-An-670
Zirconium
Oxide Cell
Analyzer
Blower Exhaust
Line (In-Situ)
0-25%3-15%
l9 Blower
Exhaust Gas Agent
PAS 703H, PAS 7O3GN"
trQ{1y5e In-Line
(Extractive)
0 - 512 sELh 0 - 1.0 sEL
20 Common Stack
Exhaust Gas Agent
PAS 7O1Gf
ACAMSg In-Line
(Extractive)
0 - 512 sELh 0 - 1.0 sEL
20a PAS 7O6Y ACAN4SS [n-Line
(Extractive)
0 - 512 sELr'0 - 1.0 sEL
20b PAS 7O7H ACAMSg In-Line
(Extractive)
0 - 512 sEL"0 - 1.0 sEL
2t All BRA-TANKS Filled
Waste Feed Interlock
23-LSHH-002
23-LSHH-006
23-LSHH -702
23-LSHH -106
Sonic Level
Switches
BRA-TANK-101
BRA.TANK-I02
BRA-TANK-2O1
BRA-TANK-202
Not
Applicable
Not Applicable
22 Prirnary to Secondary
Duct Temperature
l4-TrT-010
Thennocouple Duct 32- 2700" F 1,400 - 2500' F
MPF Tables
Attachrnent l9 Page l3
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-6-1
METAL PARTS FURNACE
PROCESS DATA'
Item
No.
Control
Parameter
Measuring
Device Location
Instrument
Ranse Exnected Ranse
Footnotes:
l. QA/QC procedures are found in Attachment 3 (Sampling, Analytical, and QA/QC Procedures).
2. Control loop tonperature TAG IDs appearing in bold font signifu two thermocouple./transmitter pairs are
used to measure the temperature. Controllers receiving inputs from two thermocouple/transmitter pairs
activate combustion chambo high and low temperature AWFCOs based on the most conservative
temperature measured. The PLC is programmed to activate high and low temperature combustion chamber
AWFCOS based on the thermocouple/transmitter pair measuring the highest temperature when the high
temperafure limit is approached, and the pair measuring the lowest ternperature when the low temperature
limit is approached.
" Continuous monitoring with values being recorded electronically, approximately every 15 secondsb Continuous recording every hour with the minimum and maximum values printed during one hour segment
of operation.
" Maintenance, at a minimum, in accordance with equipment manufacturer's recommendations.o Only one analyzer active at any one time. The active analyzer provides the process variable to the
controller. The Permittee shall attempt to balance the usage time of each analyzer.
" PAS 703AH, PAS 703BH and PAS 703C, PAS 703D are the TAG IDs for the sampling location. One
ACAMS is online for each agent being processed at this location. A backup ACAMS is available for each
agent if the primary monitor is taken offline. During Agent Trial Burn performance runs only, two ACAMS
will be online at all times during agent feed.r PAS 7Ol,706 and707 are the TAG IDs for the sampling location. Two ACAMS are online and collocated
DAAMS
tubes at all times during agent operations for each agent.s ACAMS (Automatic Continuous Air Monitoring System) - ACAMS are portable gas chromatographs
configured to detect airbome concentrations of agents GB, VX, or H/HD/HT.
' SEL (Source Emission Limit)- Threshold values for chemical agent emissions rates that have been
established by the Surgeon General of the United States to protect human health and the environment. The
SEL (in mglm3) for each agent is: GB =0.0003, VX:0.0003, and Mustard (H/HD/HT) = 0.03.* Calibration information is shown in Attachment 6.
MPF Tables
Attachrnent l9 Page 14
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-6-2
METAL PARTS FURI-.{ACE SYSTEM
AUTOMATIC WASTB FEED CUTOFF
Item
Number Tae Number Process Data Description Setpointe'
I l4-Trc452 Fumace Tempemture [,ow-[,ow (Zone I )
l. Mustard rnunitions and baseline ton container processing
2. Secondary Waste Processing
l.
2.
.1, lTloF*
< l,4l5oF*
l.a.14-TAHH-152 Fumace Temoemture High-Hish (hne I > 1.8000 F
2 14-TIT-141 Furnace Temperature [,ow-[,ow (Zone 2)
l. Mustard rnunitions and baseline ton container prccessing
2. Secondary Waste Processing
l.
2.
< 1,3180F*
< 1,4390F*
2.a.I4-TAHH-l4l Furnace Temperature Hieh-Hi eh (hne 2\> 1,8000 F
3 l4-TIr-153 Futnace Temperature [,ow-[,ow (7ane 3)
1. Mustard rnunitions and baseline ton container processing
2. Secondary Waste Processing
1. <1,321" F*
2., < 1,439 "F*
3.a.l4-TAHH-153 Furnace Temperature Hieh-H eh (Zone 3)> 1,900" F
4 l4-PSHH-034 Primary Chamber Pressure H sh Hieh > -0.1 in. w.c." 5 Second Delay
5 14-TIT-065 MPF Afterburner Temperature [,ow-[.ow
l. Mustard munitions and baseline ton container processing
2. Secondarv Waste Processins
l.
2.
< 1,976" F, one-hour rolling avemge*
< 2000 oF. one-hour rolline averaqe*
5.a.l4-TAHH-065 Afterburner Temperature Hieh-Hi gh > 2175' F
6 24-FtT-9667 Afterburner Exhaust Gas Flow Rate (Unit Production Rate)
l. Mustard munitions and baseline ton container processing
2. Secondary Waste Prccessins
1.
2.
>8,960 scftn, one-hour rolling average*
>7 .710 scfin. one-hour rolline average*
7 24-TSHH- 223 Ouench Tower Exhaust Gas Tempemture Hieh-Hish > 225" F
8 z4-PDft-222 Venturi Exhaust Gas Pressure Drop [.ow-Inw S 30 in. w.c.. one-hour rolline average
9 24-Fn-218 Brine to Venturi Scrubber Flow I.ow < 105 gpln. one-hour rolline average*
10 24-PALL-233 Ouench Brine Pressure [nw-[nw < 70 psie
ll 24-FtT-248 Clean Liquor to Scrubber Tower [.ow-[.ow S 420 gpln, one-hour rolling average*
t2 24-Ptr-2s8 Clean Liquor Pressure [.ow-[,ow S 35 psig. one-hour rolline averaqe
13 624-DtC-216 Ouench Brine Specific Gravity Hieh-Hieh > I . l5 SGU, twelve-hour rollins avemse*
t4 24-AtT-224 Brine to Venturi Scrubber pH [.ow =7.6
pH. one-hour rolline average*
15 l4-AIT-384 Blower Exhaust CO Concentmtion Z 100 ppm, one-hour rolling average.
Comecte d to 7o/o-Oz dry volumeb
l6 24-AtT-669 Blower Exhaust CO Concentration > 100 ppm, one-hour rolling avemge
Comecte d to 7o/o-Ozdry volumeb
l7 l4-AAL-082 Blower Exhaust Oz lnw < 3o/o Oz
17.a l4-AAH-082 Blower Exhaust Oz Hieh > l5Yo Oz
l8 24-AAL-670 Blower Exhaust Oz [.ow < 3'/o Oz
18.a 24-AAH-670 Blower Exhaust Oz High > l5o/o Oz
l9 PAS 703GVand
PAS 7O3Hf
PAS Blower Exhaust Agent Detected > 0.2 SEL for GB''', > 0.5 SEL for VX''"
>-0.2 SEL for Mustard'
20 PAS 701G Common Stack Exhaust Agent Detect >_ 0.2 sEu"r'"
20.a PAS 7O6V Common Stack Exhaust Asent Detect > 0.2 sEu,'L"
20.b PAS 7O7H Comrnon Stack Exhaust Asent Detect > 0.2 sErrr,"
2t 23-BRA-TNKS Brine Surge Tanks l0l, 102,201,202,, Four Levels High-High
(BRA-TNKS : 23-LSHH-02 and 23-LSHH-06 and 23-LSHH-
102 and 23-LSHH-706)
l8'3" Level
MPF Tables
Attachment 19 Page 15
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Footnotes:
" Waste feed cut-offs are activated and recorded by PDARS when the associated set point is equaled or exceeded.
b One hour rolling average is composed ofthe 60 most recent one minute averages. Each one-minute average is composed of4 most recent instantaneous
CO process variables, which occur at l5-second intervals.
" The alarm settings (in mg/m3) foreachagent are: GB=0.00006, VX:0.00015 at 0.5 SELandYX{.00006 at0.2 SEI. andMustard([VHD/HTp.006.
'r An Automatic WFCO occurs if the two online ACAMS are not staggered so that at least one unit is sampling the stack
" In accordance with Condition 22.16.6.1 of the Agent Monitoring Plan for past agent AWFCOs associated with GB and VX may be suspended if
no wastes containing the agent are "inside the facility boundaries.".
r PAS 703AV, PAS 7038V and PAS ?03CG, PAS 703DG are the TAG IDs for this sampling location. One ACAMS is online for each agent being
processed at this location. A backup ACAMS is available for each agent if the primary ACAMS is taken offline.
s Rolling average means the average of all one-minute average over the averaging period. A one-minute average means the average of detector
responses calculated at least every 60 seconds from responses obtained at least every 15 seconds
MPF Tables
Attachment l9 Page l6
TOCDF
lnstrumentation and Waste Feed Cut-off Tables
March 2009
Table D-7-l
DEACTIVATION FURI..{ACE SYSTEM
PROCESS DATA'
Item
No
Control
Parameter
Measuring
Device Location
Instrument
Ranqe Expected Ranee
I Jamrned Chute Line A
Waste Feed Interlock
l6-xs-207
Radioactive
Proxirnity Switch
Feed Chute
DFS Kiln Room
On-Off Not Applicable
2 Jammed Chute Line B
Waste Feed Interlock
16-XS-209
Radioactive
Proxirnity Switch
Feed Chute
DFS Kiln Room
On-Off Not Applicable
3 Reseryed
4 Reserved
4.b Propellant, Explosive, and
Pyrotechnic (PEP) Feed Rate
DFS
Process Control
Software
Not Applicable Not
Applicable
0 - 743.4 lb/hr
5 Kiln Rotational Speed
Calculated fi'orn
t6-zx-602
Proximity Switch Kiln Exterior Not
Applicable
0.33 to 2.0 rpm
6 Kiln Speed lnw Waste Feed
lnterlock
l6-SALL-602
Speed (proximity)
Switch
Kiln Exterior Not
Applicable
set point 0.33 rpm
7\b Kiln Pressure
t 6-PIT-01 8
Diaphragrn Furnace -2.0 to 1.0
in. w.c.
-0.1 to -2.0 in.
w.c.
7.a Kiln Pressure High Waste
Feed Interlock
l6-PSHH-204
Diaphragrn Fumace -0.5 to 0.5
in. w.c.
set point -0.1 in.
w.c.
gaI,h,c Kiln Exhaust Ternp.
Prr Quench
l6-TrT- I 82
t6-Ttr-244d
Thennocouple Fumace 0 - 2,3000 F 950- 1 ,7500 F
9u,b,c Kiln Exhaust Ternp.
Post Quench
l6-TrT-008
16-TIT- l 69'l
Thennocouple Kiln Exhaust Gas Duct 0 - 2,3000 F 850- 1,6500 F
1ga,b,c Discharge Conveyor
Temperature (lower)
l6-TtT-042
Thennocouple Conveyor 0 -1,6000 F 1,000-1,300" F
1 1ruh,c Discharge Conveyor
Temperature (upper)
16-TIT- 184
Thennocouple Conveyor 0 -1,600'F I ,000- I ,300" F
t2 Discharge Conveyor Tip Gate
Jam Waste Feed Interlock
l6-xs-058
Radioactive Lirnit
Switch
Upper Discharge
Conveyor Gate
Not
Applicable
Not Applicable
t3 Discharge Conveyor Slide
Gate Jarn Waste Feed
Interlock
l6-xs-821
Radioactive Lirnit
Switch
l.ower Discharge
Conveyor Gate
Not
Applicable
Not Applicable
t4 Discharge Conveyor Speed
[,ow Waste Feed Irrterlock
16-5SL-0s7
Speed ( Proxirnity)
Switch
Discharge Conveyor
Tail Shaft
On-Off set point zero
speed
l5'\b'"Exhaust Gas Aftertumer
16-TrT-092
l6-TIT-003"
Thennocouple Irr-Line 0-2,400' F 2,150-2,350" F
16tuh,c Afterburner Exhaust Gas
Flow Rate (Unit Production
Rate) 24-FlT -943 0A, 24 -FlT -
9430B
V-Corre In-Line at packed bed
scrubber PAS-SCRB-
102 outlet
38,120 ctrn 25,000-30,000
cfm
l6a'Lb'"V-Cone Pressure (STP
pressure comection) 24-PIT-
9430
Diaphragm In-Lirre at packed bed
scrubber PAS-SCRB-
102 outlet
8- l 3 psia l0-l I psia
l6bu'h''V-Cone Ternperature ( STP
Temperature con'ection) 24-
TIT-9430
Thennocouple In-Lirre at packed bed
scrubber PAS-SCRB-
102 outlet
100-200" F 140-l 80" F
GA/LEWI Tables
Attachrnent l9
Page 17
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2A09
Table D-7-l
D E AC
"UfT'Jl*# Yil+:P
S Y S T E M
Item
No
Control
Parameter
Measuring
Device Location
Instrument
Ranse Exnected Ranse
17\b,c Quench Tower Exhaust Gas
Ternp
24-TtT-374
Thermocouple In-Line 0-300'F 140-200' F
17.a Quench Tower Exhaust Gas
High Ternp
Waste Feed Interlock
24-TSHH-001
Filled System In-Line 175-360" F Set point 200' F
| $&n,c Quench Brine Specific
Gravity
24-Dm-033
Magnetically
Vibrated Tube
PAS Pump 1061107
Discharge
0.6 - 1.40
SGU
1.0- 1.20 sGU
l gqb,"Quench Brine pH
24-Atr-007A*
24-AtT-0078
Electrode PAS Purnp 1061107
Discharge
0-14 pH
Units
7 -ll pH Units
)Q\n,c Quench Brine Pressure
24-PrT-01I
Diaphragm In-Line 0-200 psig 7 5-200 psig
21ub,c Quench Brine to Venturi
Scrubber
24-FIT-006
Electro-rnagnetrc
Flowmeter
In-Line 0-400 GPM 300400 GPM
22\n,'Venturi Scrubber Exhaust
Gas
Diff. Pressurc
24-PD[T-008
DIP Cell Venturi Scrubber 0-50 in. w.c.20-50 in. w.c.
23\n,"Clean Liquor to Scrubber
Tower Sprays
24-FIT-030
Electro-rnagnetic
Flowmeter
In-Line 0-3,000
GPM
750 - 2,400 GPM
/{tt$'c Clean Liquor
Pressure
24-PtT-036
Diaphragrn ln-Line 0-100 psi 30-100 psig
25n b'c Blower
Exhaust Gas Oz
24-Arr-206
Zirrconiurn Oxide
Cell Analyzer
In-Lirre (Extractive)0-25%3-15%
26\n'',Blower
Exhaust Gas Oz
l6-ArT-175
Zirconiurn Oxide
Cell Analyzer
In-Line (Extractive)0-25%3-ts%
27a,t',,c Blower
Exhaust Gas CO
24-ArT-207
Infiared Cell
Analyzer
In-Line (Extractive)0-200 & 0-
5,000 ppm
0 - 100 ppm
/3on,c Blower
Exhaust Gas CO
l6-AIT-059
Infiared Cell
Analyzer
ln-Line (Extractive)0-200 & 0-
5,000 ppm
0 - 100 pprn
29n,b,',Blower
Exhaust Gas Agent
PAS 702H and7}2GNs
ACAMS'In-Line (Extractive)0-s l2 s Eu 0- 1.0 sEL
30 Cornmon Stack
Exhaust Gas Agent
PAS 701G"
ACAMS'In-Liue (Extractive)0-s l2 s Eu 0- 1.0 sEL
30a Cornmon Stack
Exhaust Gas Agent
PAS 7O6Vh
ACAMS'Irr-Line (Extractive)0-sl2 sEu 0- 1.0 sEL
30b Corrunon Stack
Exhaust Gas Agent
PAS 7O7HI'
ACAMS'In-Line (Extractive)0-s r 2 sEu 0- 1.0 sEL
3l All BRA-TANKS Filled
Waste Feed Interlock
23-LSHH-002
23-LSHH-006
23-LSHH -702
23-LSHH -706
Sonic I*vel
Switches
BRA.TANK.IOI
BRA-TANK-I 02
BRA-TANK.2OI
BRA.TANK-202
Not
Applicable
Not Applicable
GA/LEWI Tables
Attachrnent l9
Page 18
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-7-l
DEACTIVATION FURNACE SYSTEM
PROCESS DATA1
Item
No
Control
Parameter
Measuring
Device Location
Instrument
Ranse Expected Ranse
Footnotes:
L QA/QC pnccedures are found in Attachrnent 3 (Sarnpling, Analytical, and QA/QC Procedures).
u Continuous Monitoring with values being recorded electronically, approximately every 30 seconds.
h Continuous Recording every hour with the rninirnum and maximun values printe.d during one hour segrnent of operation.
" Maintenance, at a minimun, in accordance with equipment manufacturer's recommendations.
d Control loop temperature TAG IDs appearing in bold font signifu two thermocouple/transmitter pairs are used to
measure the ternperature. Controllers receiving inputs from two thermocouple/transmitter pairs activate combustion
chamber high and low ternperature AWFCOs based on the most conservative temperature measured. The PLC is
programmed to activate high and low temperature combustion chamber AWFCOS based on the
thermocouple/transmitter pair measuring the highest temperature when the high temperature limit is approached,
and the pair measuring the lowest temperature when the low temperature limit is approached
" Only one analyzer active at any one time. The active analyzer provides the process variable to the conholler. The Permittee shall
aftempt to balance the usage time ofeach analyzer.r Reserved.
c PAS 702AH, PAS 7028H and PAS 702C, PAS 702D are the TAG IDs for the sampling location. One ACAMS is online for each
agent at this location. A backup ACAMS is available for each agent if the primary ACAMS is taken offline. During Agent Trial
Bum perfomance runs only, two ACAMS will be online at all times during agent operations.
h PAS 701 , PAS 706 and PAS 707are the TAG IDs for the sarnpling location. Two ACAMS are online and co-located DAAMS
. tubes at all times during agent operations for each agent.
' ACAMS (Autornatic Continuous Air Monitoring System) - ACAMS are porlable gas chromatographs configured to detect airbome
concentrations of agents GB, VX, or Mustard ([VHD/HT).j SEL lsouce Emission Limit) - Threshold values for chemical agent emissions rates that have beur established by the Surgeon
General of the United States to protect human health and the environment. The SEL (in mg/m3) for each agent is: GB =0.0003,
VX =0.0003, and Mustard = 0.03.
kReserved
* Calibration infonnation is shown in Attachment 6.
GA/LEWI Tables
Attachrnent l9
Page l9
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-7-2
DEACTIVATION FURNACE SYSTEM
AUTOMATIC WASTE FEED CUT-OFFS'
Item
No.Tae Number
Kiln
sRotation Process Data Description r Set pointk
I l6-xs-207 3 Jamrned Chute Line A Feed Chute Filled
l0 second delay
2 l6-xs-209 3 Jarnrned Chute Line B Feed Chute Filled
l0 second delay
3 Reseryed
4.a Reserued
4.b PEP-IHR-DFS 3 Propellant, Explosives, and Pyrotechnics (PEP) Feed Greater
Than
> 479Ib PEP/hr
5 16-SAHH-602 4 Kiln Speed (rpm) Greater Than or Equal to Z2RPM
6 I6-SALL6O2 2 Kiln Rotation kss Than or Equal to s 0.33 RPM
7 l6-PSHH-204 3 Kiln Combustion Chamber Pressure: Grcater Than > -0.1 in. w.c.
8 l6-TIT-182 4 Kiln Exhaust Gas Pre Quench Ternperaturc kss Than or
Equal to
< 954o F, one-hour rolling
avel?ge
9 l6-TAHH-008 3 Kiln Exhaust Gas Post Quench Tempemture Greater Than > 1,6500 F
l0 16-TALL-042 5 l,ower Heated Discharge Conveyor Tempemture Less Than
or Equal to
< 1,000o F
ll l6-TALL-184 5 Upper Heated Discharge Conveyor Tempemture Less Than
or Equal to
< 1,000o F
t2 l6-xs-0s8 5 Jarn in Discharge Conveyor Discharge Chute Filled
l0 second delay
l3 l6-xs-821 5 Jarn in Discharge Conveyor Discharge Chute Filled
l0 second delay
t4 16-5SL057 5 No I\Iotion on Heated Discharge Conveyor No Motion
l5 l6-Trr-092 3 Afterburner Tempemture lrss Than or Equal to < 2150" F, one-hour r olling
avemge
l5.a l6-TAHH -092 3 Afterburner Temperature Greater Than or Equal to >23500 F
l6 24-FtT-943A 3 Exhaust Gas Flow Rate ( Unit Production Rate) Greater Than
or Equal to
> 13,210 scfrn, one-hour
rolling avemge
t7 24-TSHH-001 3 Quench Tower Exhaust Gas Ternperature Greater Than > 200' F
l8 24-DrC-033 3 Quench Brine Specific Gravity Greater Than or Equal to Z l.l0 SGU, twelve-hour
rolline avemge
l9 24-AtT-007 3 Brine to Venturi Scrubber pH lrss Than or Equal to < TBD pH, one-hour rolling
average
20 24-P ALL-}Il 3 Quench Brine Pressure Less Than or Equal to <75osis
2l 24-FrT-006 3 Brine to Venturi Scrubber Flow Less Than or Equal to S 310 gpm, one-hour rolling
avemge
22 24-PDIT-008 3 Venturi Exhaust Gas Pressure Drop Less Than or Equal to S 30 in. w.c., one-hour
rolline avemge
23 24-FIT-030 3 Clean Liquor to Scrubber Tower Less Than or Equal to S 800 Bpm, one-hourrolling
average
24 24-Ptr-036 3 Clean Liquor Pressure Less Than or Equal to S 35 psig, one-hourrolling
avemge
25 24-AAH-206 3 PAS Blower Exhaust Oz Greater Than or Equal to > l1oh Oz
25.a 24-AAL-206 3 PAS Blower Exhaust Oz Less Tharr or Equal to < 3o/o Oz
26 l6-AAH -t7 5 3 PAS Blower Exhaust Oz Greater Than or Equal to > l5o/o Oz
26.a 16-AAL-l7s 3 PAS Blower Exhaust Oz [,ess Than or Equal to < 3o/o Oz
27 24-AtT-207 3 PAS Blower Exhaust CO Greater Than or Equal to Z 100 ppm, one-hour rolling
average'
28 l6-ArT-059 3 PAS Blower Exhaust CO Greater Than or Equal to Z 100 ppm, one-hour rolling
average'
29 PAS 702H and
7OTGN
3 PAS Blower Exhaust Agerrt Detected Greater Than or Equal
to
>0.2 SEU|'" for GB, >0.2
SEL fbr Mustard and >0.5
SEL VX.I,"
30 PAS TOIG 3 Common Stack Exhaust Agent Detected Greater Than or
Equal to
> 0.2 s Eur,"'h
30a PAS 7O6V 3 Cotrunou Stack Exhaust Agent Detected Greater Than or
Equal to
> 0.2 sEL.l,.,'l'
GA/LEWI Tables
Attachment l9
Page 20
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-7-2
DEACTIVATION FURNACE SYSTEM
AUTOMATIC WASTE FEED CUT-OFFS'
Item
No.Tae Number
Kiln
sRotation Process Data Description r Set pointk
30b PAS 7O7H 3 Common Stack Exhaust Agent Detected Greater Than or
Equal to
> 0.2 sEl-t'"t'n
3l 23-BRA.TNKS 3 Brine Surge Tanks l0l , I 02,201 ,202,Four I-evels High-High
(BRA-TNKS :23-LSHH-02 and 23-LSHH-06 and
23 -LS HH -7 02 and 23 -LS HH-706)
I8'3" lrvel
Footnotes:
I Line A and B feed gates may be manually cycled once after a waste feed cut-off alarm is activated pnoviding the primary and secondary
combustion temperatures are above the minimum permit limits. This manual operation will be used to clear any partially treated (chopped)
energetic components from the outer surfaces ofthe gates.
u Reserved
b The rocket feed rate waste feed cutoff is activated when the rolling hourly sum of rockets fed to the DFS exceeds 3 3 nrckets per hour.
" One hour rolling average is composed ofthe 60 most recent one minute avemges. Each one-minute average is composed of4 instantaneous CO
process variables, which occurred at l5-second intervals.
d In accordance witl Condition 22.16.6.1 of the Agent Monitoring Plan for past agents, AWFCOs associated with GB and VX may be
suspended ifno wastes containing the agent are "inside the facility boundaries."
" Thealarmsettings(inmg/m3)foreachagentare:GB=0.00006,VX=0.00006at0.2SELandVX:0.000l5at0.5SEL,andFI/HD/HT=0.006.
r: [ogic code description used to set the control WFCO alanns.
g. Kiln rctation and HDC motion during a waste cut-offwill be as follows:
2. HDC motion shall be maintained when waste feed cut-offis activated.
3. Kiln rotation and HDC motion are maintained when waste feed cuFoffis activated.
4. Kiln oscillates and HDC motion is maintained when waste feed cut-off is activated.
5. Kiln oscillates and HDC motion stops when waste feed cut-off is activated.
h An Automatic WFCO occuls if the two on-line ACAMS are not staggered so that at least one unit is sampling the stack.
i Reserved.
i pRS Z0ZAH, PAS 702BH and PAS 702C, PAS 702D are the TAG IDs for this sampling location. One ACAMS is onlifle for each agent being
pnocessed at this location. A backup ACAMS is available for each agent if the prirnary ACAMS is taken offline.
* Rolling average means the avemge of all one-minute average over the avemging period. A one-minute avemge means the average of detector
responses calculated at least evel 60 seconds from responses obtained at least every I 5 seconds
GA/LEWI Tables
Attachrnent l9
Page 2l
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-8-1 ATLIC LIQUID INCINERATOR PROCESS DATA"b
Item
No.Control Parameter
Measuring
Device L.ocation
Instrument
kngt Expected Range
I Waste Feed Rate to
Primary Charnber 807-FT-
8430
Mass Flowmeter
Vibrating U-
Tube Type
In-Line 0- 1500 lbs/hr 0-210 lbs/hr GA
0-315 lbs.hr lrwisite
2 Waste Feed Atomizing Air
Pressure 822-PSL-8410
Diaphragm Plant Air Line
prior to Primary.
Charnber Waste
Feed Atomizing
Nozzle
0-200psig 45-65 psig
3 Primary Chamber Exhaust
Gas Temo. 815-TT-8471
Thermocouple Primary Chamber
Outlet
2 12-3000 'F 2550-2800 0F
4 Secondary Chamber Spent
Decon Feed Rate 829-FIT-
852 I
Rheotherm Flow
Meter (a sensor
and transmitter
unit)
In-Line 100-1000 lbs/hr 100-525 lbs/hr
5 Secondary Chamber Spent
Decon/Process Atomizing
Air Press Waste Feed
Interlock 822-PSL-85 I I
Diaphragm Plant Air Line
prior to Sec.
Chamber Waste
Feed Atomizing
Nozzle
l2- 100 psig 45-65 psig
6 Secondary Chamber
Exhaust Gas Temp. 815-
TIT-8571
Thermocouple lncinerator Outlet 32-2400 "F 1850-2200 0F
7 Exhaust Gas Flow Rate
8 l e-FT- S93i
TBID/P Cell In-Line prior to ID
Fan
g++#6e-aotu
0-3.25 in. W.C.
ffi
0-3.00 in. lV.C.
8 Pressure (STP pressure
Correction) 8 I 9-PT-8932
Diaphram In-Line prior to ID
Fan
8-13 psia l0- l I psia
9 Temperature (STP
Temperature Correc tion )
8 l e-TT-8932
Thermocouple In-Line prior to ID
Fan
100-200" F 140-180'F
l0'Scrubber Delivery Pressure
8 l9-PIT-8982
D/P Cell ln-Line 0- 100 psig 30-80 psig
lla ScrubberTower#l 819-
FIT-8921
Electro-Magnetrc
Flowmeter
In-Line 0- I 50 gpm 55-100 gpm
llb Scrubber Tower #2 819-
FtT-8922
Electro-Magnetic
Flowmeter
In-[-ine 0- I 50 gpm 55-100 gpm
llc Scrubber Tower #3 8 l9-
FIT-8923
Electro-Magnetrc
Flowmeter
In-Line 0-l 50 gpm 55- 100 gprn
l2a Scrubber #l Pressure Drop
8 l9-PT-8e l r
D/P Cell Scrubber Tower
#t
0-70 in. W.C.l-5 in. W.C.
r2b Scrubber #2 Pressure Drop
8 l e-PT-8912
DiP Cell Scrubber Tower
#2
0-70 in. W.C.l-5 in. W.C.
l2c Scrubber #3 Pressure Drop
8 l9-PT-891 3
D/P Cell Scrubber Tower
#3
0-70 in. W.C.l-5 in. W.C.
l3 Brine to Venturi Scrubber
819-FIT-8924
Electro-Magnetic
Flowmeter
In-Line 0-150 gpm 5-20 gpm
l4 Venturi Delivery Pressure
819-PIT-8956
D/P Cell In-Line 0- 100 psig 30-80 psis
l5 Venturi Scrubber Exhaust
Gas Diff. Pressure 8 l9-PT-
8915
D/P Cell Venturi Scrubber 0-70 in. W.C.3545 in. W.C.
t6 Venturi pH 8 I9-AIT-891 7 Electrodes Venturi Sump 0 - 14 pH Units 7-9.5 pH
l7 Venturi Specific Cravity
8 l9-AI-8927
Magnetically
Vibrated Tube
PAS Pump 8910
Discharee
0.6 - 1.4 sGU 0.9-1.20 sGU
t8 Scrubber Brine pH 8 19-
AIT-8952
Electrodes Common Sump 0 - 14 pH Unis 7-9.5 pH
l9 Brine Specific Gravity
819-AI-8983
Magnetically
Vibrated Tube
PAS Purnp
8908/8909
Discharge
0.6 - t.4 sGU 0.e-1.20 sGU
20 Baghouse Temperature
819-TIT-893 I
Thermocouple Prior to Bag-house 0-300 'F 160-200 'F
GA/LEWI Tables
Attachrnent l9
Page 22
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-8-1 ATLIC LIQUID INCINERATOR PROCESS DATA"b
Item
No.Control Parameter
Measuring
Device [,ocation
Instrument
Ranse Expected Range
21"Baghouse Differentual
Pressure 8 I 9-PDIT-8936
DiP Cell Baghouse 0-70 in. W.C.0.5-6 in. W.C.
22 Carbon Injection Feed Rate
819-FI-8933
TB.DLoed..Cs!!Prior to Baghouse +SD0-25!bs.TBD .25-2lbs./hr
23 Carton Injection Air Flow
Rate 8 l9-FI-8940
TBD D/P Cell Prior to Baghouse TBDo-r00
scfm
+BD 0-30 scfm
24 Carbon Filter Diff.
Pressure
8l9-PDr-894 U8942
D/P Cell Carton Filter Bed 0-70 in W.C 0.3-5 in. W.C.
25"Carbon Filter Inlet Temp.
8 19-TT-8939
Thermocouple Carbon Filter Bed
Exit
0-300 'F 160-200 'F
26"Blower Exhaust Gas CO
819-ArT-8302 A/B
Infrared Cell
Analyzer
In-Line
( Extractive)
0-200&0-
5,000 ppm
0-100 ppm, one-hour
rolling average, corrected
to TYo Or drv volume.
27"Blower Exhaust Gas Oz
8 l9-ArT-8301 A/B
Zirconium Oxide
Cell Analyzer
In-Line
(Extractive)
0 -25%3-15%
2gcid,t',1 €emmen Exhaust Stack
ExSaust Gas Agent TEN
708K
ACAMS/
MINICAMS
In-Line
(Extractive)
0-5 l2 sEL 0 - 1.0 sEL
29a""\q'€emmen Exhaust Stack
Exearct Cas AgentTEN
709L
ACAMS/
MINICAMS
ln-Line
(Extractive)
0-5 12 s EL 0 - 1.0 sEL
Footnotes:
u Calibration information is shown in Aiachment 6.h Maintermnce, at a minimum, in accordance with equipment manufactureds recommendations.
" Recorded upon activation or change in state of switch.d ACAMS/MINICAMS (Automatic Continuous Air Monitoring System) - Agent monitors are portable gas chromatographs
configured to detect airbome concentrations of agents GA and l.ewisite. ACAMS and MINICAMS are used to monitor for GA
and lewisite, respectively
" TEN 708 and TEN 709 are the TAG lDs for the sampling location. Two ACAMS are online with collocated
DAAMS tubes at all times during GA operations. Four MINICAMS (two pairs) each pair consists of a primary and confirmation
MINICAMS, each MINICAMS in a pair has a different analytical column.r SEL 1source Emission Limit)- Threshold values for the concentration of chernical agents in incinerator exhaust gases which have
been established by the Surgeon General ofthe United States to protect human health and the eirvironment. The SEL (in mg/m3)
for each agent is: GA =0.0003, and Lewisite=0.03.
TBD- These valrr will beh
GA/LEWI Tables
Attachrnent l9
Page 23
TOCDF
Instrumentation and Whste Feed Cut-off Tables
March 2009
Table D-8-2
ATLIC LIQUID INCINERATOR
AUTOMATIC WASTE FEED CUT-OFFS
Itern
No.Tag Number Process Data Descriptionu Setpointh
I 807-Fr-8430 Waste Feed Rate Greater Than or Equal to > 325 lbihr Waste Feed, one-hour rolling
average.
2 822-Pr-8410 Agent Atornizine Air Pressure lrss Than < 35 psig
3 8 I s-TIC -847 t Primary Charnber Temperature lrss Than < 2550" F. one-hour rolling average
4 82e-FtT-8521 Spent Decon Feed Rate Greater Than or Equal to > 4+7 550 lb/hr over one-hour rolline averase
5 822-PI-851 I Spent Decon Atomizine Air Pressure [.ess Than or Equal to < 35 psie
6 815-TrC-8571 Secondarv Chamber Temperature lrss Than < 1850" F. one-hour rolline averase
7 819-Fr-893D Exhaust Gas Flow Rate (Unit Production Rate) Greater Than or Equal
to
Z 960 scfm aSggtefrq one-hour nrlling
average
8 8 9-PI-8982 Scrubber Brine Pump Pressure Less Than or Equal to 525 psig
9 8 9-FI-8e21 Flow to Scrubber Tower # I Less Than or Equal to < 40 sDm. one-hour rolline average
10 8 9-Ft-8922 Flow to Scrubber Tower #2 l,ess Than or Equal to < 40 gpm. one-hour rolline average
ll 8 9-Fr-8923 Flow to Scrubber Tower #3 Less Than or Equal to < 40 gpm, one-hour rolling average
t2 8 9-PDI-891I Scrubber # I Pressure Drop lrss Than or Equal to < 0.3 in. w.c., one-hour rolling average
r3 8 9-PDI-89 l2 Scrubber #2 Pressure Dropfubs Than or Equal to S 0.3 in. w.c., one-hour roll ng average
l4 8 9-PDI-8913 Scrubber #3 Pressure Drop lrss Than or Equdl to s 0.3 in. w.c.. one-hour roll ng average
l5 8 9-Ft-8924 Brine to Venturi Scrubber Flow Lrss Than or Equal to < 8 gpm one-hour rolline average
l6 8 9-PI-8956 Venturi Pressure [ess Than or Equal to < 25 psie
t7 8 9-PDI-8e 15 Venturi Exhaust Gas Pressure Drop l-ess Than or Equal to S 12 in. w.c.. one-hour rolline average
l8 8 9-AtC-8e 17 Venturi Sump pH Less Than to Equal to S 7 pH, one-hour rolling average
l9 8 9-At-8927 Venturi Specific Cravity Greater Than or Equal to > 1.28 SGU, twelve-hour rolling average
20 8 9-AIC-8952 Scrubber Brine pH kss Than to Equal to < 7 pH, one-hour rolling average
2t 8 9-AI-8983 Brine Specific Gravitv Greater Than or Equal to > 1.28 SGU. twelve-hour rollinq averase
22 8 9-Tr-8931 Bae House Inlet Temnerature Greater Than or Equal to > 240" F, one-hour rolling average
23 8 9-PDI-8e36 Bas House Pressure Drop lrss Than or Equal to < .l in. w.c., one-hour rolling average
24 8 9-FI-8933 Carbon Iniection Feed Weieht lrss Than or Equal to < .5 lbs/hr., one-hour rolling average
25 8 9-FI-8e40 Carbon Iniection Air Flow lrss Than or Equal to S TBD 15 SCFM. one-hour rollinq averase
26 819-PDI-8941
t8942
Carbon Filter Pressure Drop lrss Than or Equal to S 0.3 in. w.c., one-hour rolling average
27 8 l9-TI-8939 Carbon Filter Inlet Temperature Greater Than or Equal to > 240" F, one-hour rolling average
28 8 t 9-AIT-8302
A/B
Blower Exhaust CO Concentration Creater Than or Equal to Z 100 ppm., one-hour rolling average, corrected
to 7Yo Oz, dry volume
29a 8 t9-AAL-8301
A/B
Blower Exhaust Gas Oz less Than or Equal to < 3o/o Oz
2eb 819-AAH-8301
A/B
Blower Exhatst Gas Oz Greater Than or Equal to Z l5oh Oz
GA/LEWI Tables
Attachrnent l9
Page 24
TOCDF
Instrumentation and Waste Feed Cut-off Tables
March 2009
Table D-8-2
ATLIC LIQUID INCINERATOR
AUTOMATIC WASTE FEED CUT-OFFS
Item
No.Tae Number Process Data Descriptionu Setpoint**
30a TEN 7O8AK Stack Exhaust GA Aeent Detect Greater Than or Equal to > 0+ 0.2sELd'
30b TEN 7O8BK Stack Exhaust GA Aeent Detect Greater Than or Equal to z &+ 0-2sEu'*
30c TEN 7O8CK Stack Exhaust GA Aeent Detect Greater Than or Equal to :05 0.2s8L""
3la TEN 7O9AL Stack Exhaust lrwisite Agent Detect Greater Than or Equal to > &4 (L2SEUb
3lb TEN 7O9BL Stack Exhaust lrwisite Agent Detect Greater Than or Equal to > e4 u2sEu'"
3lc TEN 7O9CL Stack Exhaust lrwisite Agent Detect Greater Than or Equal to > O+ (L2SELO
3+d TEN 7g9Dt ffi
+t€TEN 7g9Et ffi
+rf TEN 7O9Ft Staek Efthaust r ewisite A-.ent heeFGffite'f TLar er Eetral to ffi
32 voLl2HR-
ATLIC
Volatile Metal (Hg) Greater Than or Equal to > 0.70 lbllz hr tryelve-hour rolling average
33 SV-I2HR-
ATLIC
Semi-Volatile Metal (Pb+Cd) Greater Than or Equl to > eeel 0.39 lbl12 hr trvelve-hour rolling
aYerage
34 LV-I2HR-
ATLIC
[,ow-Volatile Metal (As+BcrCr) Greater Than or Equal to Z I I 56 lbllz hr trvelve-hour rolling average
35 ASH-I2HR-
ATLIC
Ash Greater Than or Equal to Z 1536 lbl12 hr twelve-hour rolling average
36 MC.I2HR-
ATLIC
Chlorine Greater Than or Equal to >- 2298 lbllz hr twelve-hour rolling average
Footnotes
" Logic code description used to set the contsol WFCO alarms.
b Rolling average means the avemge of all one-minute averages over the averaging period. A one-minute average means the average of at least four detector
respons€s ovcr a 60 secord interval
" Waste feed cut-offs recorded upon switch activation.
d The alarm setting (in mg/m3) for each agent is: GA =O000* Q,Q@Q[, and tewisite : eel2 Q{Q!.
" An Automatic WFCO occurs if the two on-line ACAMSA4INICAMS are not staggered so that at least one unit is sampling the stack
TBD- There vrlues will be ineorperoted prior the Iinid publle period,
o
GA/LEWI Tables
Attachrnent 19
Page 25
r)
-):))
G
l\)
CEMS
Rev.
GDRL 06
MONITORING PLAN
I Date:19 Mar 08
Procedure Owner: r Karl Scottcz
Mercu ry/CE MS, Ma naqerc2
Garv McCloskev
General Manager
(Original signatures on file)
Approved by:
1
2
3
4
5
6
CDRL 06 CEMS MONITORING PLAN
TABLE OF CONTENTS
PURPOSE .............2
scoPE... ..,............2
REFERENCES......... .............3
ACRONYMS/DEFINITIONS.... ..............4
PROCEDURE .......... ...........11
6.1 Pollutants and Diluents to be Measured and Expected Concentrations...l l
6.2 Emissions Flow Diagrams and Flow Charts of Emissions and Emissions
Monitoring Systems ..................11
6.3 Sampling Locations ..................11
6.4 Alternate Sampling Procedures.............. .............,....11
6.5 CEMS Site Description .............16
6.6 CEMS Equipment And Methods Description.............. ..............19
6.7 Certification, Audits, and Calibration .........28
6.8 Data Recording ....... .................29
6.9 Quality Assurance ................ ....................31
6.10 Data Validation and Reporting ..................35
6.11 CEMS Performance Specification Test Protocol ........... ...........36
6.12 State Electronic Data Report (SEDR) (CEMS Quarterly Report)..............36
RECORDS ..........37
LIST OF TABLES
Table 6.4-1. CEMS Operating Data....... ......13
Table 6.5-1. CEMS Data........ .......17
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx,09
Page 1
CDRL 06 CEMS MONITORING PLAN
PURPOSE
This Continuous Emissions Monitoring System (CEMS) Monitoring Plan describes
the monitoring system used to provide evidence of compliance with the Tooele
Chemical Agent Disposal Facility (TOCDF) RCRA and Title V permits. This plan
does not include detailed Quality Assurance (OA) information about CEMS
Certification or the annual Reference Method Audit (RMA). That information is
included in the CEMS Certification Test Protocol Plan (EG 037) and the CEMS
Quality Assurance Program Plan (EG 033).
SCOPE
2.1 This document is the TOCDF plan for complying with Title 40 of the
Code of Federal Regulations (CFR) Part 266, App IX, 40 CFR Part 60,
Appendix A and B, 40 CFR Part 63 subpart EEE, App. A and Utah Air
Conservation Rules R307 in the categories of:
o Calibration of CEMS
2.2
2.3
2.4
o Calibration Drift (CD) determination and adjustment of CEMS
. Preventive Maintenance (PM) of CEMS (including spare parts
inventory)
. Data recording, calculations, and.rqporting
. Corrective Action Program for malfunctioning CEMS
lnformation relating to analyzers used for Permit Compliance is included
in this plan. The RCRA and Air Quality programs are administered by
the State of Utah, Department of Environmental Quality.
Process control analyzers are used throughout the furnace systems, as
deemed necessary by TOCDF, to monitor the process exhaust streams
and to evaluate the operating condition of the respective
furnace/incinerator.
There are spare analyzers located in the common stack spare racks
which are certified for use in compliance locations. Only the analyzers
will be relocated (not the sampling system or sample conditioning
system). All compliance CEMS (RCRA, Air Quality, and certified spares)
will be audited quarterly to ensure a sound audit trail for their accuracy
from the time they are certified until they are used for compliance
purposes. Only certified and audited analyzers will be used for
compliance monitoring.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 2
2.5
GDRL 06 CEMS MONITORING PLAN
Certified analyzers have a certification tag attached to
with the following information:
the front panel
Serial Number
Quarterly Audit Due Date
Quarterly Audit Completed Date
Annual Audit Due Date
''CERTIFIED''
The TOCDF has four separate incinerator systems that exhaust into a
common stack. These four furnaces are monitored at the duct that feeds
the effluent from each furnace into the stack. This design allows
monitoring of the exhaust from individual furnaces rather than the
combination of the exhaust from more than one furnace. ATLIC has one
incinerator exhaustinq into one stack.c2 --Each furnace does, however,
have its own pollution abatement system.
This plan includes detai! about the location of all RCRA and Title V
monitors as well as their sample points. This information is provided to
show compliance with 40 CFR Part 60, 63 Subpart EEE, Part 266, and
R307.
All CEMS and analyzers are connected electronically to a computer in
the Control Room from which furnace operations are controlled. All
analyzer auditing, calibration, repair, and preventive maintenance (PM)
are performed by trained personnel.
o-
3
2.6
2.7
2.8
REFERENCES
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
40 CFR Part 266
4A CFR Part 60
40 CFR Part 63 subpart EEE, App. A
EG 033 - CEMS Quality Assurance Program Plan
EG 037 - CEMS Certification Test Protocol PIan
TOGDF RGRA Permit
TOCDF Title V Permit
Utah Air Gondervation RuleS R307
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 3
:4
CDRL 06 CEMS MONITORING PLAN
-,
ACRONYMS/DEFINITIONS
:.- .
a4.1 ACA - Absolute Calibration Audit
4.2 AIT - Analyzer lndicating Transmitter
ATLIC - Area 10 Liquid lncineratorc2
CD - Calibration Drift
GDRL - Contract Deliverable Requirements List
CDTF - Chemical Demilitarization Training Facility
CEMS - Continuous Emission Monitoring System
4.3
4.4
4.5
4.6
4.7
4.8 CERMS - Continuous Emission Rate Monitoring System
4.g CFR - Code of Federal Regulations
4.10 CO - Carbon Monoxidec2
4.11 "- pAQ - Department of Air Quality
412 DC - Direct Current
4.13 DCG - Document Control Center
4.14 DFS - Deactivation Furnace System
4.15 DSHW - Division of Solid Hazardous Waste (State of Utah)
4.16 EPA- Environmental Protection Agency
4.17 GA - GA Nerve Aqentc2
4.18 GFC -Gas Filtration Corrpl.ationc2
4.19 IGS - lnertial Gas Sampling
4.20 lR - lnfrared
4.21 L - Lewisite@
4.22 LIC - Liquid lncinerator
4.23 LOP - Laboratory Operating Procedure
4.24 M&TE - Measurement and Test Equipment
4.25 MPF - Metal Parts Furnace
4.26 MSB - Monitor Support Building
4.27. NDIR - Non-Dispersive lnfraredc2
4.23 'NIST - National lnstitute for Standards and Technology
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 4
4.29
4.30
4.31
CDRL 06 CEMS MONITORING PLAN
NO, - Nitrogen Oxidese
Oz- Oxygene
PAS - Pollution Abatement System
5
4.32 PDARS - Process Data Acquisition and Recording System
4.33 PLC - Programmable Logic Controller
4.34 PM - Preventive Maintenance
4.35 PPM (ppm) - Parts per Million
4.36 tSlG (psig) - Pounds per Square Inch Gauge
4.37 QA - Quality Assurance
4.38 QG - Quality Controt
4.39 RCRA - Resource Conservation and Recovery Act
4.40 RMA - Reference Method Audit
4.41 SEDR - State Electronic Data Report
4.42 SOW - Statement of Work
4.43 TOCDF - Tooele ChemicalAgent Disposal Facility
4.44 TSCA - Toxic Substance ControlAct
RESPONSIBILITIES
5.1
5.2
Monitoring Program Description
5.1.1 Organization
The monitoring mission at TOCDF includes requirements to
provide continuous monitoring for regulated environmental
pollutants. The personnel listed in the organization charts are
responsible for CEMS monitoring operations. Monitoring and QC
personnelfurnish coverage 24 hours a day, seven days a week.
Duties and Qualifications
5.2.1 Monitoring Manager
5.2.1.1 Responsible for the successful operation of the CEMS
program.
5.2.1.2 Ensures that personnel operate instruments and
,. sar.npling systems provide reliable and accurate
readings.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 5
CDRL 06 CEMS MONITORING PLAN
5.2. 1.3 Researches and understands permit requirements
and supervises the monitoring staff to comply with
those requirements.
Communicates with the Environmental Manager and
staff for assistance in regulatory and interpretational
matters.
Ensures that CEMS monitoring data is collected,
documented, and reviewed.
Ensures that the data reflect the fact that the CEMS
instruments and sampling system are certified,
audited, and 'tin control" during all furnace operations
and the data systems provide the furnace operators
with reliable readings from which to make operational
decisions.
Provides data to the Environmental Manager for
inclusion in reports to the State of Utah.
Reviews the data archiving process to ensure that a
complete and accurate audit trail of CEMS data is
maintained. .
5.2.1 .4
5.2. 1 .5
5.2. 1.6
5.2.1 .7
5.2. 1.8
5.2.2
5.2.1.9 Works with the Laboratory QC to develop and
maintain a QC system that provides an independent
overview of the operational status of the CEMS.
5.2.1.10 Ensures that corrective actions are developed and
implemented for CEMS malfunctions.
5.2.1.11 Have the following qualifications:
Successfully completed the course of study for CEMS
conducted at the Chemical Demilitarization Training
Facility (CDTF).
CEMS Specialist:
5.2.2.1 ls the on-site technical expert for the CEMS program.
5.2.2.2 Provides technical input to the content of the CEMS
Monitoring Plan, Laboratory Operating Procedure
(LOP), and the Statement of Work (SOW) for the
CEMS certification contract.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 6
5.2.2.5
CDRL 06 CEMS MONITORING PLAN
5.2.2.3 Testing of the Process Data Acquisition and
Recording System (PDARS) for the CEMS
instruments
5.2.2.4 Provides oversight of an independent contractor for
the annual certification and for CEMS program in
general.
Performs oversight of the CEMS operation during
plant operations. This effort is augmented by other
qualified Monitoring personnel. These efforts include:
r Calibrations and calibration drift checks
Preventive maintenance (PM)
Ma lfunction co rrection
Quarterly audits
Oversight of the data collection requirements for
above actions.
lnventory maintenance of parts and consumables
for the CEMS mission.
. The CEMS Specialist is responsible for technical
overview of the CEMS and for providing
improvements and developing corrective actions
as they are warranted.
5.2.2.6 Have the following qualifications:
. Successfully compl.eted the CEMS course at the
CDTF
. Certified in operation of the CEMS
Monitoring Team Lead
5.2.3.1 Coordinate with the CEMS Specialist and assign
Monitoring personnel to assist, as needed, to ensure
the CEMS mission is successful. The CEMS
Specialist is a day shift person, while Team Leaders
and lnstrument Technicians furnish coverage 24
hours a day, seven days a week.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 7
5.2.3
5.2.4
5.2.5
5.2.3.2
5.2.3.3
5.2.4.3
5.2.4.4
5.2.4.5
Quality
5.2.5.1
5.2.5.2
5.2.3.4 Have the following qualifications:
r Successfully completed the CEMS course taught
at the CDTF
Senior Monitoring Technicians
5.2.4.1 Supports the majority of the aspects of the CEMS
monitoring during off-shifts.
5.2.4.2 Perform PM, repair, calibration and calibration drift
checks.
Respond to alarms and malfunctions.
Ensures that the electronic data Iogging system is
operating correctly.
Have the following qualifications.
r Successfully completed the CEMS course taught
at the CDTF
CDRL 06 CEMS MONITORING PLAN
lnform the CEMS Specialist of any corrective actions
performed by Monitoring shift personnel to ensure
proper recertification steps are taken in accordance
with permit requirements.
Ensure that during off-shifts, the CEMS calibration
drift checks are performed by Monitoring technicians.
Responds to CEMS alarms and malfunctions when
notified by Contro! Room Operators.
r Successfully completed the Laboratory Equipment
Maintenance course taught at the CDTF
(l nstrument Technician only)
r Certified in CEMS operation.
Control (OC) Manager
Reports to the EG&G Quality Management Manager.
ls responsible to provide an independent assessment
of the CEMS monitoring mission.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 8
CDRL 06 CEMS MONITORING PLAN
5.2.5.3 With QC personnel, inspects and audits all aspects of
the CEMS program including but not limited to.
r Certification, colibratioh, and audits
r lnspection of the configuration of the CEMS
instruments and the sampling systems.
r lnspect the data collection system to verify
accuracy.
r Observe CEMS Audits; both "Quarter ly Audits"
and "Annual Audits"
Lab QC Manager along with QC Monitoring
inspectors ensures oversight of a representative
portion of these audits to validate the performance of
the CEMS.
5.2.5.4
5.2.5.5 Review CEMS documentation for accuracy with
special attention to malfunction and corrective action
documentations.
5.2.5.6 Have the following qualifications:
Successfully completed the CEMS course at the
CDTF.
5.2.6 Quality Control Monitoring Inspectors
5.2.6.1 Perform surveillances of all CEMS aspects.
5.2.6.2 Randomly observe the actions of any CEMS
operators
5.2.6.3 Randomly observe CEMS calibrations or calibration
drift checks to verify the recorded data.
5.2.6.4 Randomly observe CEMS audits to verify that
quarterly audits are performed correctly.
5.2.6.5 Spot check all CEMS documentation.
5.2.6.6 Have the following qualifications:
5.2.6.7 Successfully completed the CEMS course at the
CDTF.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 9
CDRL 06 GEMS MONITORING PLAN
5.3 Operator Certification
CEMS operators will be certified by completing initial training at CDTF
then completing a certification performance package that demonstrates
the operator's skill and knowledge of the CEMS.
5.3.1 Qualified Operator
Upon successful completion of the CEMS course taught at
CDTF an operator is considered a 'Qualified' operator. A
qualified operator may perform CEMS operations under the
direct supervision of a certified operator. The certified operator
is responsible to directly supervise the actions of the qualified
operator and ensure that applicable procedures are followed. All
work performed by the qualified operator must be signed for by
the certified operator.
Certified Operator
When a sufficient amount of supervised training has been
completed the qualified operator may become a 'Certified'
operator by completing a CEMS Operator Certification Package.
The package will consist of the successful completion of the
following:
Calibration and 4 days of operation
Absolute Calibration Audit or Cylinder Gas Audit
Response Time Test
Demonstrate basic knowledge of applicable operating
permits and procedures that govern the operation of the
CEMS
5.4
Monitoring QC inspectors will audit and approve the certification
package.
Operators must calibrate at least one CEMS analyzer per
calendar quarter to maintain certification.
Operator Recertification
Previously certified operators that allow their certification to lapse may
recertify by performing a calibration and a 3-Day calibration drift test on
any analyzer.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 0
5.3.2
CDRL 06 CEMS MONITORING PLAN
6 PROCEDURE
6.1
6.2
Pollutants and Diluents to be Measured and Expected Concentrations
See Table 6.4-1, CEMS Operating Data
Emissions Flow Diagrams and Flow Charts of Emissions and Emissions
Monitoring Systems
Drawings TE-6-F-501 and TE-6-FD-502 provide flow charts and CEMS
sample locations for the incinerator and fumace systems.
6.3 Sampling Locations
6.3.1 Sampling point sites for the Title V and RCRA Compliance
CEMS are in accordance with 40 CFR Part 60.
6.3.2 The following conditions shall be met:
6.3.2.1 The sample point is at least two equivalent duct
diameters downstream from the nearest control
device, the point of pollutant generation, or other point
at which a change in the pollutant concentration or
emission rate may occur.
6.3.2.2 The sample point is at least one half-equivalent duct
diameter upstream from the effluent exhaust or
control device.
6.3.2.3 When the above criteria can not be met, a
stratification test will be performed at the time of the
initial CEMS certification to validate the sampling
efficiency of the CEMS probe.
6.3.3 The sample probe is extended into the duct or stack to cause
the measurement point to be no less than (1) 1.0 meter from the
stack or duct wall, or (2) within the centroidal area of the stack
or duct cross-section but, no greater than 1 percent of the stack
duct cross-sectional area.
6.4 Alternate Sampling Procedures
6.4.1 There are no alternate sampling procedures because there are
back-up systems and previously certified spare analyzers that
may be moved to serve as replacement units.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 1
CDRL 06 CEMS MONITORING PLAN
6.4.2 All analyzers used to monitor at compliance locations are
certified, including spares. This allows them to be moved and
replace malfunctioning compliance instruments. When a
malfunctioning compliance CEMS instrument is replaced with a
spare unit, the replacement unit will:
Measure the same parameter
Have the same operating range
Have been certified
6.4.3
o Be calibrated before waste feed is started
o Have a Response Time Test completed before waste feed is
started
o Have an Absolute Calibration Audit (ACA) completed before
waste feed is started
At TOCDFC2 there is'a spare NOx analyzer operating at all
times. However since both units share one probe and PDRRS
link, only on6 analyzer can mohftor at a time.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 12
CDRL 06 CEMS MONITORING PLAN
Table 6.4-1. CEMS Operating Data
The CO and Oz analyzers are specified by 40 CFR, part 266, 60, and 63.
Set points are derived from the RCRA Permit and the Title V Operating Permit.
Expected concentrations are determined from data seen at TOCDF.
*HRA - Hourly Rolling Average.
MPF Analyzers
AIT-669 CO
RCRA
0-200 ppm
0-5000 ppm
0-15 ppm 6 ppm
1 50 ppm
100 ppm
5RA*
AIT-670 Oz
RCRA
0-25o/o 7 -12o/o 0.5o/o Oz LO
3
HI
15
AIT-384 CO
RCRA
0-200 ppm
0-5000 ppm
0-15 ppm 6 ppm
1 50 ppm
100 ppm
HRA
AIT-82 Oz
RCRA
0-25%7-12%0.5o/o Oz LO
3
HI
15
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 3
CDRL 06 CEMS MONITORING PLAN
Table 6.4-1 . CEMS Operating Data (cont.)
DFS Analyzer
The CO and Oz analyzers are specified by 40 CFR, part 266, 60, and 63.
Set points are derived from the RCRA Permit and the Title V Operating Permit.
Expected concentrations are determined from data seen at TOCDF.
*HRA - Hourly Rolling Average.
,,,wd ffi,%ffiffiffi
AtT-207 CO
RCRA
0-200 ppm
0-5000 ppm 0-1 5 ppm 6 ppm
1 50 ppm
100 ppm
11RA*
AIT'206 Oz
RCRA
0-25%7-12%0.5o/o Oz
LO
3
HI
15
AIT-59 CO
RCRA
0-200 ppm
0-5000 ppm 0-15 ppm 6 ppm
1 50 ppm
100 ppm
HRA
AIT-175 Oz
RCRA 0-25o/o 7-12%0.5o/o Oz LO
3
HI
15
Common Stack Analyzers
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 4
CDRL 06 CEMS MONITORING PLAN
Table 6.4-1 . CEMS Operating Data (cont.)
LIC lAnalyzers
The CO and Oz analyzers are specified by 40 CFR, part 266, 60, and 63.
Set points are derived from the RCRA Permit and the Title V Operating Permit.
Expected concentrations are determined from data seen at TOCDF.
*HRA - Hourly Rolling Average.
'.'''",r,i
fhE,,N il'ilt$11,1";t,i
,,An alyte, P g,IPp$e,.,,,,,,,
1;,fli6.;iir;i:...1,,-', :!' : ;i.,;ii'.1t,t | .!,.: : ;...i .1 ., I :.i
,i;
.:.ii,, u.fil:.i.!;iii;"=r;,:.h.+.1:ifitl1.1ci+iifl-{r,ffjti:wr. .}{ff,iif,$tiffiffi-tfr
AIT.7B CO
RCRA
0-200 ppm
0-5000 ppm 0-1 5 ppm 6 ppm
1 50 ppm
100 ppm
11RA*
AIT-210 Oz
RCRA
0-25%7-12%0.5o/o Oz LO
3
HI
15
AIT-83 CO
RCRA
0-200 ppm
0-5000 ppm 0-1 5 ppm 6 ppm
1 50 ppm
100 ppm
HRA
AIT-229 Oz
RCRA 0-25%7-12%0.5o/o Oz LO
3
HI
15
LIC 2 Analyzers
,,, Atilaf y. fig P* [ffi.$,p;'i:rl]
:iit
il;{:,i,.i
AtT-716 CO
RCRA
0-200 ppm
0-5000 ppm 0-1 5 ppm 6 ppm
1 50 ppm
100 ppm
HRA
AIT-7 17 Oz
RCRA
0-25%7-12%0.5o/o Oz LO
3
H!
15
AIT-778 CO
RCRA
0-200 ppm
0-5000 ppm 0-1 5 ppm 6 ppm
1 50 ppm
100 ppm
HRA
AIT-79B Oz
RCRA 0-25%7-12%0.5 o/o Oz LO
3
HI
15
GA/L lncinerat orcz
Tag Number ,
Analyte Purpose
,f nstrumen,t
Range
Expectbd
Conc.Accuracy Set point
AIT-830.L
Oal RCRA
0-25o/o
7 -12o/o
0.5o/o Oz LO
3
HI
15
Arr-8302
CO / RCRA
0-200 ppm
0-5000 ppm
0-15 ppm 6 opm
1 50 opm
100 ppm
HRA
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 5
o 6.5
CDRL 06 GEMS MONITORING PLAN
CEMS Site Description
6.5.1 Type/Make of lnstrument Shelter
6.5.2
6.5.3
6.5.1.1 All CEMS instrument shelters are constructed to
provide weather protection and insulation. Each
shelter is heated and cooled to provide a temperature
controlled environment for the CEMS. AII CEMS
shelters are an integral part of the site structures. All
the CEMS and process control analyzers are powered
by commercial power and have Uninterruptible Power
Supply backup.
1) Common Stack House (75-461) - located 60'
above ground and surrounds the Common
Stack.
2\ MPF/DFS Monitoring House (75-261) - located
18' above ground on the North East Side of the
PAS building.
3) LIC Monitoring House (75-262) - located 18'
above ground on the South East Side of the PAS
building.
Stacl</Duct Description, Dimensions and Sample Points
6.5.2.1 Table 6.5-1 provides the sample point description
information in a simplified format. When Oz or CO
analyzers are co-located in a single rack, the
sampling system is shared by both analyzers.
Alternate Gas Sampling Ports
For each CEMS sampling port, there is an equivalent spare port,
which is adjacent to the CEMS port. There are also two unused
environmental sampling ports for each set of CEMS ports. The
common stack has spare CEMS ports and environmental ports to
be used for manual stack sampling such as during RCRA test
burns.
CEMS Monitoring Plan
CDRL 06, Rev 8 Chg. 2, xx xxx 09
Page 1 6
co
)
l
(o
0
1
LX
I
o,

tr
l
Ed
'E
NSe
(D
o
>@8p
(oOJtoo
N(oN!
rf
)
lt
-
N(oNI
rO1'
-
N(oN!
LO
l'
-
N(oNI
rO
lt
-
N(oNI
rO
l\
'
r
.
N(oNt
tOf'
-
N(oNI
rO1'
-
N(oc\I
rO1'
-
r(oNI
rr
)
1'
-
r(oNI
rr
)N
(oNI
rOl'
-
r(oNI
lf
)
lt
-
LONN
rf
)D-N
roNN
LO
lt
-N
rONN
lf
,
)NN
rr
)
l-N
rf
)1-N
(o\t
(o\t
(orf
,
(o$
oCA
Oca
NCA
NCA
(ocf
)
r
(0CAr
1'
-Nr
1'
-NT-
(o$
(o\t
(o$
(0\f
,
r
rr
rr.
O)+
o?
\t
q$
q$
r
\I
-
ir
t
t
'
.
i
f
f
i
l
i
i
i
,
'
'
,
i
,

ri
+
i
i
;
i
;i
i

Q'
.
,

'
.r
n
i
:
i
i
,
:
'
,E

E'
,
,
a
f
r
,
,
,
fr
t
r
,
E
H
H
Ft
r
,
6
=
2
5H
.
.
6
8
-
-
z
rr
cf
)
r
COr
r!.r
.toco
$oco
(oNcf
)
(oNcf
)
@0r
)
r
@co
@c)
@cf
)
r
+
+
q$
q\t
r
oq
oq
cq
co
c)
cf
)
,l
I
J
'
=
,
3,
f
i
av
fr
:
;
'
a
aJ
O:l
OJ
Ol
NaJ
NaJ
NaJ
NaJ
U)
TLo
U)
LLo
U)
LLo
U)
TLo
'-
"
'
,
'

.
'[
l
Ja
E,
,
O
lu
'
()
i
|
&
;
q-,
'
,'
E
L
E,Ot
tot
tc)t
E.otr
tot
tOt
tot-
tOt-
tC)
t
tOt-
tOt
tOt
oo
No
oO
No
oO
No
oo
No
oC)
No
oo
c{o
o"
iK
,
.
ir
p
r
"=
'
..
1
U
,
ru
x
co@oLco
o)NNFcf
)
@NOF\tN
oNF.tN
@N1t
'
-Fco
@O)NFcr
)
(oNF.tN
NNF$N
o)
roOF(o
LONF(o
l'
-oNL$N
(0ONF.tN
zJo-(9
o
z6
po
EOu
)
I
ts
7u
J
6o
E
!
aL
O
r'uJ
o
O-
o
(o

.(
u
OF
JE,oo
c
ol
@
(U

Ol
r
tL

xl

o
PI
I

E
E
II
L
EN
9o
,
2-
c
(D

C)
>@8p
(oOtoO
ff
i
z
.
'

t
NY
=
u
l
JE
P
g
SP
i
l
,
=
i=
z
(oNI
ro
l'
-
(oNI
lr
)N
(oNI
lf
)N
(oNI
lo1'
-
(o$!
LO1'
-
(o.t
I
LON
(9\t
I
|(
)N
(o$I
lr
)N
OIml
FI
OI
co
l
F!
X
u-
.
i
rr
r

lr

!0
.
FO
n
u
r
tz
=
2
3
0-
o
LONN
qNN
LO
It
-N
lr
)NN
$@
$@
\t@
$@
olml
-l
olml
rl
-U
J
HU
I
O
F
,
a
;r
"
*
,
?
t

H
28
6
=
2
=H
6
=
-
E2

IJ
qNN
q1'
-N
caNr
cf
)N
@@r
o@r
Oo)
oO)
OIml
r-
l
olml
FI
q\r
q\t
qo
o'
lO
N
e.
i
lf
)q
rOq
ol
co
l
FI
olml
rl
II
J
=
2-
E
ut
r
e
H
H
v,
-
f
t
i
=
2
3H
6
;
I
Z
I
rr
)oj$
lf
)oi$
\tLO
.tLO
@(o
@(o
o)@
o)@
olml
FI
olml
FI
oq
oq
q
q
N
N
olml
-l
c)
Iml
rl
LU
-
?Fa9
ia
LLo_
LLo_
LLo-
LLo_
zQ=
=3 OA
z=*
z=*
zE;
JIal
C'
I
JIalol
II
J@
=o
tu

o-
ou
:)o-
tOt
tOt
tOt
t-Ot-
o)
tr
Q)
tr
G)
tr
o)=F
<t
tl
c-
:
l
xl
<tEI
c;
l
xl
IJ
JFJz
oO
No
oO
No
ON
:E
XoZ
a)o)=olr
t-o)o)3oLL
olol
NI
ol
(,
l-=lUo
o)
(o(oF$N
ol'
-
(oF-f
,N
.t@coF.f
,
N@oF$
(o
l'
-OO)F\f
,N
8E<k
NN
cf
)o)O)F$N
.f
,o)o)F.tN
NIOINIOI
co
l
co
l
+l
<I
e\
J
I
()
Irlol
eo
l
"lFI<t
]CofCrt
s
,Co()G+JGoal.
UO-I
ro(oc)
-o$F
zJo-
(9ze,ol-aa=UJo(0oJuoo
6.6
CDRL 06 GEMS MONITORING PLAN
CEMS Equipment And Methods Description
6.6.1 CO Analyzer
6.6.1.1 Manufacturer: Teledyne, Advanced Pollution
I nstrumentation (APl ) Division
6.6.1.2 Model: 300EM
6.6.1 .3
6.6 .1 .4
6.6.1 .5
Measurement
(NDrR)
Principle: Non-dispersive lnfrared
Operating range. All API analyzers are dual range,
a uto-rang i ng ana lyzers
1) Range One: 0-200 ppm CO
2) Range Two: 0-5000 ppm CO
Theory of Operation:
1) The 300EM uses a beam of broad-band IR light
with a known intensity (measured during
calibration) and directs it through a multi-pass filter
with sample gas. The sample cell uses mirrors at
each end to reflect the lR beam back and forth
through the sample gas to generate a 14m
absorption path giving the analyzer maximum
sensitivity to fluctuations in CO density.
2) The beam then passes through a band-pass filter
that only allows light at a wavelength of 4.7 pm to
pass. The beam then strikes a photo-detector that
converts it into a modulated voltage signal
representing the attenuated intensity of the beam.
3) The 300EM uses a Gas Filter Correlation (GFC)
Wheel in the light path to overcome the effects of
interfering gases that also absorb light at 4.7pm,
such as COz and HzO.
4) The GFC wheel contains two chambers; one that
contains nitrogen (Measurement cell) and the
other nitrogen and a high concentration of CO
(Reference cell).
CEMS Monitoring Plan
CDRL 06 Rev. 8 Chg. 2 xx xxx 08
Page 1 9
6.6.2
CDRL 06 CEMS MONITORING PLAN
5) As the wheel spins IR light passes alternately
thorough the two cell cavities. When the beam is
exposed to the Reference cell, the CO in the gas
filter wheel strips the beam of most of the IR at
4.7pm. When the beam is exposed to the
Measurement cell, the Nz in the wheel does not
absorb lR light. The fluctuation in the intensity of
the lR light striking the photo-detector that results
in the output of the detector resembles a square
wave. The 300EM determines the amount of CO
in the sample chamber by computing the ratio
between the peak of the Measurement pulse and
the peak of the Reference pulse. Once the 300EM
has computed the ratio, a lookup table is used,
with interpolation, to linearize the instrument. This
linearized concentration value is combined with
calibration SLOPE and OFFSET values to
produce a CO concentration which is then
corrected for changes in sample pressure. lf
interfering gases are introduced into the sample
chamber the spectrum of the IR beam is changed
in a way that is identical for both the Reference
and the Measurement cells but without changing
the ratio between the peak heights. ln this way,
the GFC wheel eliminates the effects of interfering
gases so that the analyzer responds only to the
presence of CO.
02 Analyzer
6.6.2.1 Manufacturer: Ametek, Thermox lnstrument Division
6.6.2.2 Model: Thermox FCA Micro-Control
6.6.2.3 Measurement Principle:
electrochemical cell
Zirconium oxide
6.6.2.4
6.6.2.5
Operating Range: Adjustable from 0-1% to 0-1 00o/o.
0z analyzers will be operated in the 0-25% range.
Theory of Operation
The Oz analyzer uses a zirconium oxide (ZrOz)
ceramic sensing element to determine the
concentration of Oz in the' stack gas. The CEMS rack
Oz system is made up of two major components; the
Detector and the Control Unit.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 20
CDRL 06 CEMS MONITORING PLAN
1) The Detector contains the following:
a. A furnace
b. Thermocouple
c. Cell housing
d. Oxygen cell
2) The furnace and thermocouple maintain the
environment for the oxygen cell. The oxygen cell is
a closed tube made up of zirconium oxide and is
coated with porous platinum on the inside and
outside of the cell. The cell operates at a
temperature of approximately 695'degrees C.
3) The cell measures the oxygen concentration by
comparing the oxygen pressure of the sample side
of the oxygen cell to the pressure on the reference
side of the cell.
4) Sample gas is drawn from the sample probe and
enters the Flowblock inlet. Most of the gas passes
through the Flowblock and out the exhaust;
however, by convection some gas flows up into the
cet! housing over the oxygen cell, through the
return loop into the Flowblock, and back out the
exhaust.-
5) If the pressure of the gas on the sample side differs
from that of the reference side, a signal is
produced.
6) The internal circuitry in the CEMS quantifies the
signal generated by the oxygen cell and displays it
as percent oxygen on the front panel.
7) Control Unit
The control unit operates all functions of the Oz
analyzer components. The control unit also
displays:
The current oxygen concentration reading
The current oxygen alarm status (only in the
event of an alarm)
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 21
a.
b.
6.6.3
CDRL 06 CEMS MONITORING PLAN
c. The current celltemperature
d. .The current eror status (only in the event of a
system malfunction)
GO/Oal nterorated Unitc2
1) Manufacturer: c2
2) CO: Teledvne Advanced Pollution lnstrumentation c2
3) Model: 300EMc2
4) Oa: Servomexc2
5) Model: 1158Pmc2
6\ Measurement Princiole: c2
7) CO: Non-Disoersive infrared (NDIR) c2
8) Oa Paramaoneticc2
9) Ooeratinq Ranoe: c2
10) CO: Ranoe One: 0-200oomc2
Ranqe Two: 0-5000o0m c2
11\ Qa Q-25o/oc2
12\ Theorv of Ooeration c2
This confiquration includes a Teledvne 3Q0EM CO analyzer
already described in Section 6.6.1 . however the anal)zer
latform also includes a Servomex Paramaqnetic Oxvoen
analvzer ffeledvne Option 65).
Reoular sample qas ooes into the CO chassis and is split
between the CO and Oa detectors. Oa_,concentration is
based on the chanoes in the detector's magnetic field due
to the maqnetic properties of Oa. Chanoes are measurable
and correlate to the concentration of Oa-,in the sample
strgam.t'-.,,.
Oxygen analvzer operation. calibration. and diaqnostics
are all oerformed ?nd controlled via, the front panel of the
CO analyzer chassis usinq the same, operatiho format at
t
CEMS Monitoring Plan
CDRL 06 Rev I Chg. 2, xx xxx 09
Page 22
6.6.4
CDRL 06 CEMS MONITORING PLAN
COIOz CEMS Sampling System
Theory of Operation
6.6.4.1 There are instances where Oz and CO analyzers
share a common sampling system.
6.6.4.2 The CEMS rack system draws stack emissions
through the stack probe assembly and transports it to
the CEMS rack system through a heat traced sample
transport tube bundle.
6.6.4.3 The gas sample is drawn through stage one of the
sample cooler/condenser, the first head of the sample
pump, under a vacuum, and exits the pump head
under positive pressure into the second stage of the
sample cooler; where:
6.6.4.4
6.6.4.5
6.6.4.6
6.6 .4.7
1) The sample stream temperature is lowered to
ambient
2) Additional particulates are washed away
The sample then passes through the coalescing filter
to remove any fine liquid mist carryover from the
sample cooler.
The gas sample then passes through a sample
pressure regulator that regulates line pressure at 4-11
pounds per square inch gauge (PSIG).
Then through the inner tube of the reflux permeation
dryer to further dry the sample stream.
The sample stream then splits into two streams, if
both Oz and CO are to be measured:
1) One stream flows through the Oz
indicatorlcontroller and into the Oz analyzer.
flow
2) The other stream flows through the CO flow
indicatorlcontroller and into the CO analyzer.
The analyzer exhaust is drawn from the analyzers
under negative pressure by means of the second
head of the sample pump; the line is maintained at
slight negative to zero pressure by the reflux pressure
regulator.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 23
6.6.4.8
6.6.5
CDRL 06 GEMS MONITORING PLAN
6.6.4.9 The gas then passes through the outer tube of the
reflux permeation dryer and into the second head of
the pump.
6.6.4.10 The gas sample is then exhausted under positive
pressure back to the source.
TOCDFC2 CERMS Sampling System
The CERMS consist of three components; the NO, analyzer, the
moisture analyzer, and the stack flow meter.
6.6.5.1 NOxAnalyzerManufacturer: TeledyneAPlcl
1) Model: 2OO EHcl
2) Measurement Principle: Chemiluminescent
Method.
3) Operating Range: 0-1000 ppm
4) Theory of Operation
The M200EH/EM Nitrogen Oxides Analyzer is a
microprocessor controlled instrument that
determines the concentration of nitric oxide (NO),
total nitrogen oxides (NO*, the sum of NO and NOz)
and nitrogen dioxide (NOz) in a sample gas drawn
through the instrument. lt requires that sample and
calibration gases are supplied at ambient
atmospheric pressure in order to establish a
constant gas flow through the reaction cell where
the sample gas is exposed to ozone (oe), initiating a
chemical reaction that gives off light
(chemiluminescence). The instrument measures
the amount of chemiluminescence to determine the
amount of NO in the sample gas. A catalytic
reactive converter converts any NOz in the sample
gas to NO, which is then including the NO in the
sample gas is then reported as NOr. NOz is
calculated as the difference between NO* and NO.
Calibration of the instrument is performed in
. . sofh,vare and usually does not require physical
adjustments to the instrument.cl
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 24
CDRL 06 CEMS MONITORING PLAN
During calibration, the microprocessor measures
the sensor output signal when gases with known
amounts of NO or NOz are supplied and stores
these results in memory. The microprocessor uses
these calibration values along with the signal from
the sample gas and data of the current temperature
and pressure of the gas to calculate a final NO,
concentration. The concentration values and the
original information from which is was calculated
are stored in the unit's interna! data acquisition
system and are reported to the user through a
vacuum fluorescence display or several output
ports.cl
cl
5) The Control Room readings and the PDAR results
for NO, must be in "pounds per hour". The pounds
per hour are calculated automatically by using the
input from a stack flow meter and moisture
analyzer. All of the readings are sent electronically
to the Control Room where software performs the
calculations "real time." During certification, the
complete system is compared to a reference
method system provided by the Certification
Contractor.
6.6.5.2 Moisture analyzer
1) Manufacturer: MAC lnstruments
2) Model: MAC 120
3) Measurement Principle:
Detector
lR Source/Pyroelectric
4) Operating Range: 0 to 100%
5) Theory of Operation
Stack gas is drawn through a probe, passed across
the moisture sensors, and then exhausted back into
the stack.
6.6.5.3 Stack Flow Meter
1) Model: Digital Flow Model GMBOB
2) Measurement Principle: Ultrasonic
3) Operating Range: 0.03 - 46 mls (0.1 1 sOfusec)
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 25
6.6.5.4
6.6,6 CEMS Rack
6.6.6.1
6.6.6.2
CDRL 06 GEMS MONITORING PLAN
4) Theory of operation
The meter consists of two parts; a measurement
section including ultrasonic transducers and
holders, and the electronics section necessary to
operate the transducers and process data.
5) The measurement section uses two ultrasonic
transducers to send ultrasonic pulses back and
forth across the diameter of the stack.
6) The electronic section measures the time ultrasonic
pulses take to travel the diameter of the stack.
Pulses travel faster in the direction of the flow
because the flow helps the pulse travel. The
upstream and downstream transit times are
compared. The difference is proportional to the
velocity of the flow in the stack. Corrections are
made to the measurement to compensate for
temperature and pressure that could affect the
speed of the pulse.
ATLIC NO, - The ATLIC NO, is the same -Teledyne
6.6.6.3
Sampling Equipment
Pre-lnsulated Sample Tube Bundte The sample
tubing bundle is electrically heated and contains
several Teflon or PFA lines used to transport sample,
calibration, and instrument air between the CEMS
rack and the source. The temperature of the sample
tube bundle is regulated by a controller located in the
rack for each CEMS system. The controller uses
thermocouple feedback to regulate the temperature of
the bundle.
Stack Probe Assembly The stack probe assemblies
used in the TOCDF program are made up of the
following components:
1) Probe
Ceramic or stainless probes are used for sampling.
Probes of either material are 112" outside diameter
(OD). The actual length of the probe depends upon
the diameter of the stack or duct. The end of the
probe is cut to a 45 degree angle and is faced
downstream to help avoid collection of particulates.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 26
6.6.7
CDRL 06 GEMS MONITORING PLAN
2) Three-way Air MotorActuated Valve
The three-way air motor actuated valve is a two-
position valve used to configure the stack probe
assembly into either "blowback" or "sample" mode.
When in blowback mode, the sample line is isolated
from the probe assembly. lnstrument air may becl
used to back-flush the probe to clean it out. The
valve motor actuator is operated by instrument air
supplied via the sample transport tube bundle from
the CEMS rack. Instrument air used for the back
flush is supplied locally via the air regulator (not
from the sample transport line). This configuration
allows the sampling probe to be operated remotely
from the CEMS rack so the operator does not have
to go to the probe to change modes (sample or
blowback). The three-way valve is normally aligned
in the sample mode (no instrument air applied). The
valve is switched to the blowback mode by applying
instrument air to the valve actuator. With this
configuration, a loss of instrument air will cause the
sample probe to remain in or return to the sample
position.
3) Calibration Gas lnlet - The calibration gas inlet
features a check valve (one-way valve) to prevent
sample gas from entering the calibration gas line
during normal sampling operations. The inlet is
attached to the sample line where it connects to the
probe. This configuration allows calibration gases
to flow through every part of the sampling system
except the probe assembly.
Cylinder Gas Calibration Equipment
6.6.7.1 Each CEMS rack has its own calibration gascl
system. With this system, each analyzer's accuracy
can be verified at the zero and span response values
against a known reference. Calibration gas is
controlled at the CEMS rack and sent through the
heated sample line bundle into the sampling system
at the Calibration Gas lnlet.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 27
6.7
CDRL 06 CEMS MONITORING PLAN
Certification, Audits, and Calibration
6.7.1 Certification
6.7 .1 ,1
6.7.2
6.7.3
Audits
6.7 .2.1
6.7.2.2
6.7.2.3
CEMS analyzers and associated equipment used in
compliance locations will be certified annually in
accordance with EG 37 (Continuous Emission
Monitoring System (CEMS) Certification Test
Protocol) using the applicable methods in CFR 40
Parts 60 App. B and/or 266 Appendix lX. An
independent contractor will be used to perform
reference method tests.
Quarterly
Absolute Calibration Audit (ACA)
The Absolute Calibration Audit (ACA) will be
performed quarterly for three of the four quarters in
each calendar year. lt will be performed by
Monitoring personnel identified Section 5.2. EPA
Protocol 1 gases will be used.
Reference Method Audit (RMA)
A Reference Method Audit (RMA) will be performed
annually by an independent contractor in accordance
with EG 37 (Continuoug Emission Monitoring System
(CEMS) Certificatibn Test Protocol)
Calibration and Calibration Drift Checks
Analyzers will be checked for calibration drift daily by
introducing zero and span Goncentrations of calibration gas to
the analyzer. The drift will be calculated by comparing the
analytical results from the analyzer to the target concentration
value of the gas. Drift tolerances are defined in Section 6.9.8,
Control Limits and Actions.
At least once per week all analyzers will be calibrated
regardless of drift.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 28
6.8
CDRL 06 CEMS MONITORING PLAN
Data Recording
6.8.1 Daily Calibration Check
6.8 .1 .1
6.8.2 Process
6.8,2.1
When each daily calibration or calibration drift check
is performed, the readings are recorded in three
Iocations:
PDARS
The PDARS computer in the Control Room records
all CEMS readings. By changing a switch position
at the CEMS instrument before the calibration, the
computer will differentiate between calibration data
and process data. The PDARS software allows
compilation of calibration data in electronic and
hard copy reports.
Strip Chart Recorder
CEMS readings are recorded as chart deflections
on a paper chart recorder. After the daily calibration
is performed, the operator marks the chart with at
Ieast the following information:
a. Date
Time
Operator name or identification number
Readings generated by the calibration or drift
check.
e. Reading after calibration adjustment
3) CEMS Rack Logbook
The above calibration information is also entered in
the instrument logbook.
Data Acquisition and Recording System (PDARS)
The Process Data Acquisition and Recording System
(PDARS) is an electronic data recording system
which receives its data through Programmable Logic
Controllers (PLCs). The data is stored on disc and/or
hard copy. All of the operating CEMS are connected
to the PDARS.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 29
1)
2)
b.
c.
d.
CDRL 06 GEMS MONITORING PLAN
6.8.2.2 Each gas analyzer is equipped with a switch marked
"Calibration" "ON", "OFF". The switch allows the
PDARS computer to differentiate between process
data and calibration data.
6.8.3 CEMS Certification Data
Certification of the CEMS is performed
contractor. The certification contractor will:
6.8.3.1 Comply with EG 033, CEM
Assurance Program Plan and
Emission Monitoring System
Protocol.
by an independent
Certification Quality
EG 037, Continuous
Certification Test
6.8.3.2 Provide a report documenting all data generated from
the performance specification tests required for
certification. The report will also include an
explanation of the test parameters, calculations, and
results of all testing.
6.8.4 CEMS Data during Operations
6.8.4.1 The analytical results from CEMS instruments are
collected on duplicate systems. Each CEMS analyzer
is connected to a chart recorder and a link to the
PDARS for data recording. The PDARS records all
CEMS readings.
6.8.4.2 CEMS lnstrument Log
A permanently bound log book with consecutively
numbered pages will be located in the proximity of
each CEMS instrument. The log will contain a running
history of the instrument and actions taken on any
equipment in the rack; including actions by Monitoring
and QC personnel. Each entry will include the date,
time , a description of actions taken or miscellaneous
annotatiohs, and the signature or initials with lD
number of the person making the entry.
6.8.5 CEMS Data Archiving
CEMS data is stored in two formats, hard copy and computer
software disc.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 30
6.8.5.1
Quality Assurance
6.9.1 lndependent Audits
6.9 .1 .1
6.9 .1 ,2
Each year, the annual Reference Method Technical
Audit will be performed by an outside contractor. An
outside contractor is used to lend validity to the
accuracy and reliability of the CEMS. The
requirements the contractor must comply with are
specified in the contract Statement of Work (SOW).
Non-scheduled audits maycl be performed by the
Laboratory Quality Control lnspectors who have
successfully completed the CEMS course of study at
the CDTF.
CDRL 06 GEMS MONITORING PLAN
6.8.5.2
Hard Copy
CEMS data hardcopy (logbooks, forms, chart recorder
charts, etc.) are maintained by Monitoring personnel
for a minimum of one month. The data are then
turned over to the TOCDF Document Control Center
(DCC) where they are stored until placed in
permanent archives.
Computer Software Copy
CEMS data collected by PDARS are kept on disc. The
data disc is maintained by the PDARS Engineer for 45
days. The discs are then sent to the DCC where they
are stored until placed in permanent archives.
6.9
6.9.2 National lnstitute for Standards and Technology (NIST)
Traceability
The measurement accuracy for the standards used to calibrate
the CEMS and the M&TE is traceable to the NIST. The accuracy
certificate for'the CEMS calibration gases is maintained on file
and made a part of certification and calibration records. Protocol
1 gases will be used for both calibration and audits.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 31
6.9.3
6.9.4
6.9.5
CDRL 06 CEMS MONITORING PLAN
Quality Control Calculations
6.9.3.1 The calculations used to evaluate calibration drift are
performed each day per the following equation:
1) TC-FC = CD
2) TC - Target Concentration
3) FC - Found Concentration
4) Calibration Drift must not exceed the control limits
specified in Section 6.9.8.
Operational Procedures
Laboratory Operating Procedures (LOPs) can be found on the
site network. At least once per year, the CEMS operators will
read the LOPs and sign a statement that they understand the
LOPs, including detailed procedures for operation, preventive
maintenance, and calibration of the CEMS. All LOPs require
approval by the TOCDF Project Manager.
Quality Control
6.9.5.1 TypeiFrequency of Quality Checks
1) Review Certificates of Compliance for cylinder gas
standards used for CEMS certification, calibration,
and audits to ensure they are NIST traceable and
meet EPA protocol requirements.
2) Periodic procedure, instrument and logbook
surveillances.
3) Random audits of CEMS instruments at the
discretion of the Laboratory QC Manager to
validate the accuracy of calibrations and calibration
drift checks.
4) Periodic review
documentation.
of quarterly CEMS audit
CEMS Opelalor Certification Packages and training
records of the personnel who perform CEMS
operations stated in Section 5.2, Duties and
Qualifications.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 32
5)
6.9.6
CDRL 06 CEMS MONITORING PLAN
Preventive Maintenance Program
6.9.6.1
6.9.6.2
6.9.6.3
6.9.7 I nstrument Calibration
6.9 .7 .1
6.9.7.2
6.9 .7.3
6.9.8 Control
6.9.8.1
The PM Program is administered by the CEMS
Specialist. Qualified Monitoring personnel perform
the PM.
The major part of the Preventive Maintenance
Program consists of documenting operational
readings or measurements from gauges, meters etc.
that indicate proper operation of the CEMS.
Other PM may include the periodic replacement of
consumable parts to prevent failure of a system.
M&TE used in support of certification, technical
audits, CEMS calibratiohs, and preventive
maintenance is calibrated using standards that are
traceable to the NIST.
Any M&TE used to support annual certification by the
sub-contractor shall be calibrated and the certificate
included in the CEMS certification or audit data
package.
M&TE that is used by the Monitoring personnel may
be calibrated either onsite or offsite.
1) Standards used to perform onsite calibrations shall
be NIST traceable and a copy of the calibration
certificate demonstrating NIST traceability shall be
kept on file at TOCDF.
2) Equipment that is calibrated offsite shall have a
certificate demonstrating NIST traceability that must
also be kept on file at TOCDF.
Limits and Actions
The control limits and actions stated here relate to
daily operations of the CEMS. These limits and
actions do not apply to CEMS certification.
Certification of CEMS is described in the TOCDF
CEMS Quality Assurance Program (EG 033) and the
CEMS Certification Test Protocol (EG 037).
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 33
GDRL 06 CEMS MONITORING PLAN
6.9.8.2 Calibration Drift (CD) is evaluated daily to determine if
it is excessive. The following describes control Iimits
and actions required to correct excessive drift:
1) oz
The CD for the Oz analyzer is determined to be
excessive if the Zero or Span reading differs
from the reference value by more than 0.5o/o C2.
lf the CD is excessive the analyzer must be
calibrated.
lf, on any given check the CD exceeds 1% Oz
the analyzer is considered "out of control" and
a successful ACA must be performed to verify
the analyzer is "in control" before it can be
used for compliance monitoring.
2) CO
a.The CD for the CO analyzer is determined to be
excessive if the Zero or Span reading differs
from the reference value by more than six ppm
for the low range (0-200 ppm). Or the Zero or
Span reading differs more than 150 ppm from
the reference value at the high range (0-5000).
lf the CD is excessive the analyzer must be
recalibrated.
lf, on any given check the CD exceeds two
times the limits the analyzer is considered "out
of control" and a successful ACA must be
performed to verify the analyzer is "in control"
before it can be used for compliance
monitoring.
3) NO*
a. The CD for the NO* CEMS is determined to be
excessive if the zero or span reading differs
from the reference value by 25 ppm. lf the CD is
excessive the analyzer must be calibrated. The
CD is determined to be 'out of control' if th e zero
or span reading differs from the reference value
by more than 100 ppm "orle time" or 50 ppm for
"five consecutive days".
CEMS Monitoring Plan
CDRL 06 Rev B Chg. 2, xx xxx 09
Page 34
a.
b.
b.
CDRL 06 CEMS MONITORING PLAN
lf the daily drift check indicates that the NO, is
'out of control', the following steps will be taken:
ldentify and correct the cause for the
excessive drift
Evaluate if any corrective action is
necessary to prevent future occurrences of
the same type of problem.
The occurrence of the excessive drift shall
be included in the quarterly technical audit
report to the State Division of Air Quality.
Data Validation and Reporting
6.10.1 Calibration Drift Data
Calibration drift data is validated by the individual performing the
calibration drift check. The CEMS Specialist shall screen data to
observe for trouble spots. The QC Monitoring lnspector observes
CD tests on a spot check basis.
6.1O.2 Data Validation
Data entered on the Daily CEMS Calibration Sheets, PDARS and
the CEMS logbooks are all reviewed by the CEMS Specialist on
an on-going basis to determine accuracy and consistency. All
errors or irregularities are corrected with an annotation indicating
the circumstance.
6.10.3 Missing Data
6.10.3.1 Because of redundant data collection methods for
CEMS data, it is highly unlikely that there will be any
missing data.
6.10.3.2 Should there be missing data, the Environmental
Manager shall be notified immediately. lf necessary
the Control Room Operators will be notified
immediately to allow them to take appropriate actions
relative to plant operations.
The cause for the missing data will be determined and
the following accomplished :
1) Replication of the missing data if possible.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 35
b.
ll.
lll.
6.1 0
6.10.3.3
CDRL 06 CEMS MONITORING PLAN
2) Documentation that data was lost to provide an
accurate audit trail.
3) Corrective action taken to prevent a future
reoccurrence of missing data.
6.10.3.4 All of the above will be included in the CEMS
quarterly report.
6.10.3.5 The appropriate notifications will be made to the
Environmental Manager.
6.11 CEMS Performance Specification Test Protocol
6.11.1 Certification
Certification testing of the CEMS is performed by an independent
subcontractor in accordance with EG-037, CEMS Certification
Test Protocol, CFR 40 Part 266, 60, and 63.
6.11.2 EG&G Environmental Manager
6.11.2.1 The Utah DSHW will be notified 45 days prior to
certification or annual recertification of CEMS
analyzers
6.1 1.2.2 The Utah DAQ
certification or
analyzers.
6.12
6.11.3 New CEMS analyzers used for monitoring in compliance
locations shallbe certified prior to use.
State Electronic Data Report (SEDR) (CEMS Quarterly Report)
A quarterly SEDR is submitted to the State of Utah DSHW and the
Division of Air Quality no later than 30 days after the end of each calendar
quarter. The SEDR is compiled and submitted by the Environmental
Manager.
6.12.1 The Quarterly SEDR includes:
o Source owner/operator name and address.
ldentification and location of monitor in the CEMS.
Manufacturer and model number of each monitor.
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 36
will be notified 45 days prior to
annual recertification of CEMS
CDRL 06 CEMS MONITORING PLAN
Report of data from quarterly audits.
Malfunctions and out-of-control conditions of CEMS,
corrections and corrective actions taken to prevent future
occurrences. Results of retest after corrections.
Breakdown reports (plant failures causing excess emissions).
Reports of any excessive emissions.
7-Day Calibration Drift Test
Absolute Calibration Aud it
Response Time Test
Performance Specification
7 RECORDS
7.1 lnformation Assets
7.1.1 All information generated by this CDRL is considered to be an
information asset. (Documents, forms, databases, etc.)
7.1.2 The following information assets were developed as a result of
implementation of this CDRL. Documents with an asterisk (*)
are considered Records.
. None
7.2 Retention/storage of records
. PRP-EV-041 identifies individual record retention requirements.
CEMS Monitoring Plan'
CDRL 06 Rev 8 Chg. 2, xx xxx 09
Page 37
".-_-
CDRL 06 CEMS MONITORING PLAN.t
LIST OF EFFECTIVE PAGES
LIST OF EFFECTIVE PAGES
PAGE NO.REV/CHG NO.
1-2 RBCO
3-5 R8C2
6 - 11 RBCO
12 R8C2
13 - 14 RBCO
15 R8C2
16 - 17 RBCO
18 R8C2
19-21 RBCO
22-37 R8C2
CEMS Monitoring Plan
CDRL 06 Rev 8 Chg. 2, xx xxx 09
EG 033
GEM CERTIFICATION QUALITY ASSURANCE
PROGRAM PLAN
Rev.Date: 05-08-07
Procedure Owner:Randv W. Roten'
Approved by:
Monitoring Manager
Gary McCloskev
General Manager
(Original signatures on file)
REVIEW
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
TABLE OF GONTENTS
1 PROGRAM PLAN DESGRIPTION........... ........3
2 CERTIFICATION PROGRAM ORGANIZATION AND RESPONSIBILITY ..........5
3 TOCDF GEMS DES!GN.... ..............6
4 SAMPLING METHODS REQUIREMENTS....... ..............10
5 SAMPLE HANDLING AND CUSTODY PROCEDURES.. ................17
6 QUALITY CONTROL REQUIREMENTS .......18
7 PTM INSTRUMENT/EQUIPMENT TESTING, INSPECTION, AND MAINTENANCEREQU!REMENTS........ .................21
8 PTM INSTRUMENT CALIBRATION AND FREQUENCY........... .....22
9 PTM DATA ACQUISITION REQUIREMENTS ................23
10DATAQUALITYMANAGEMENT...........................
LIST OF FIGURES
FIGURE 3-1. NON.DILUTING EXTRACTIVE TCEMS ............9
LIST OF TABLES
TABLE 3-1. SUMMARY OF TOOELE CHEMICAL AGENT DISPOSAL FACILITY CEMS........7
TABLE 3.2. TOCDF ANALYZER DESCRIPTIONS .................7
TABLE 4-1. ZERO AND CERTIFIED CALIBRATION GAS REQUIREMENTS FOR
CALIBRATION, CALIBRATION DRIFT, AND RESPONSE TIME TESTS................................16
TABLE 4.2. ACGEPTABLE GONCENTRATIONS FOR CEMS QUARTERLY AUDITS
(ACA/CYLTNDER GAS AUDTTS)........... ...............16
TABLE 4.3. ZERO AND PROTOCOL 1 GAS REQUIREMENTS FOR PERFORMANGE TEST
METHOD (PTM) ANALYZER OPERAT!ON............... ............16
TABLE 4-4. INTERFERENCE TEST GAS CONCENTRATIONS FOR REFERENCED METHODTCEMS ........ERROR! BOOKMARK NOT DEFINED.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1
o
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
ACRONYMS AND ABBREVIATIONS
Source: SOP Plan Narrative
ACRONYM DEFINITION
ACA Absolute Calibration Audit
ATLIC = Area 10 Liquid lncineratorc3
BIF
CC
CD
CDRL
CE
CEM
CEMS
CFR
DAS .
EPA
LIC
DFS
DUN
MPF
PAS
PC
PTM
QAPP
QA/OC
RA
RATA
RM
Confidence Coefficient
Calibration Drift
Contract Data Requirements List
Calibration Error
Continuous Emission Monitor
Continuous Emission Monitoring System
Code of Federal Regulations
CO Carbon Monoxidec3
COa Carbon Dioxidec3
NO- trtitrooen OxiOess
NSPS New Source Performance Standards
o^ Qx]llggno
GA GA Nerve Aoentc3
L Lewisitec3
Data Acquisition System
Environmental Protection Agency
Liquid lncinerator
Deactivation Furnace System
Dunnage lncinerator
Metal Parts Furnace
Pollution Abatement System
Personal Computer
Performance Test Method
Quality Assurance Program Plan
Quality Assurance/Quality Control
Relative Accuracy
Relative Accuracy Test Audit
Reference Method
PPMV (ppmv) Parts Per Million Volume
RT Response Timec3
TSCA
TCEMS
TOCDF
UDAQ
M&TE
Toxic Substance Control Act
Transportable Continuous Emission Monitoring System
Tooele Chemical Agent Disposal Facility
Utah Department of Air Quality
Measuring and Test Equipment
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 2
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
PROGRAM PLAN DESCRIPTION
1.1 This Quality Assurance Program Plan (OAPP) presents guidelines that the
Subcontractor shall follow for all Transportable Continuous Emission Monitoring
System (TCEMS) measurements performed for the Continuous Emission
Monitoring System (CEMS) certification so the user of the data generated by this
project can be assured that data are collected with sufficient detail and
documentation to meet the needs of the user.
This QAPP applies to certification testing and Relative Accuracy Test
Audit (RATA) field sampling activities pertaining to the operation of
TCEMS for measurement of gaseous air pollutant emissions from the
Tooele Chemical Agent Disposal Facility (TOCDF) exhaust vents. lt is
specific to the requirements of 40 GFR Part 266, Appendix lX; 40 CFR
Part 60, Appendix B; and 40 CFR Part 63 Subpart EEE.
The Monitoring Manager of the TOCDF has prepared two documents that
discuss the TOCDF CEMS equipment and operation in detail. Those
documents are the Continuous Emissions Monitoring System Plan (CDRL
06) and the Continuous Emissions Monitoring System Laboratory
Operating Procedure (TE-LOP-540). This QAPP is not intended to
supersede those documents in any way but incorporates them by
reference.
The Environmental Protection Agency (EPA) has defined Quality
Assurance (QA) as: an integrated system of activities involving planning,
Quality Control (QC), quality assessment, reporting, and quality
improvement to ensure that a product or service meets defined standards
of quality with a stated level of confidence.
1.4.1 There shall be trainino performed and maintaineC documented
evidence of training maintained for all personnel performing work-te
@. As a minimum this training shall include:
@
EG 037, Continuous Emission Monitor (CEM) Certification
Test Protocol Plan
EG 033, CEM Certification QA Plan
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 3
1.2
1.3
1.4
EG 033 - CEMS CERTIFIGATION QUALITY ASSURANCE PROGRAM PLAN
#1.4.2 Personnel performing certification testing shall be qualified
and certified in accordance with an established certification
program. Certification records shall be submitted to EG&G prior to
individuals performing testing.
1441.4.3 The certification sampling and testing shall be performed in
strict accordance with the CEMS Certification Monitoring Plan, the
CEMS Certification Quality Assurance Project Plan, and applicable
EPA Methodologies.
1, l.EPreeeCures shall be established te assure that MeaecrhrgFanC Teet
equipment (Uafe) I
felleffii
rThe lvl&TE shall be seteeted te previde the preper range and
oPreeisien and aeeuraey requirements ehall he identified and
rldentlfy and deeument all M&TE in a eentrelled inventery,
oGalibrate M&TE at preseribed ir*ervale (preeedure must iCentify
ing
Where ne sueh standards exist; the basis fer ealibratien shall
be deeumented,
oDefine the preeess used fer the ealibratien ef M&TE; ineluding
eq++
ealibra{ien+tatus
rAssess and deeument the valiCity ef previeus teet+esult+-when
M&TE is feund te be eut ef ealibratien by a preseribed and
@
ealibratiens; measurements; and tests being perfermed,
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 4
2
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
rSafeguard M&TE frem adjuetments that eeuld invalidate the
eat+Uratien+e*ings.
1#1.4.4 Procegdures shall be established for the review and
approval of CEMS Certification reports. Included within shall be:
o lnternal Review process for final repo(, i.e. who. (Note:
Review is to be by an individual other than the report writer).
o lnternal Approval requirements, including approval signature
authority. (Note: Approval is to be by an individual other than
the report writer).
lndividual record legibility, completion, accuracy, correction,
and approval requirements.
All corrections shall be made by placing one line through the
error, annotating the correct information next to the error, and
placing an initial and date of the individual making the
correction. WHITE OUT, ERASURES, OR SCRIBBLING
WILL NOT BE ACCEPTABLE.
o All reports shall be legible and professional.
CERTIFICATION PROGRAM ORGANIZATION AND RESPONSIBILITY
2.1 The CEMS certification program organization includes a line of QA/QC
management that is independent of technical management authority. The
QA/QC team is under the direction of the company president who has the
authority to direct and apply any company resources to ascertain the
quality of certification program performance and, if necessary, to bring
out-of-control activities back into control.
The Quality Manager for all QA activities has authority over all personnel
and facility resources and therefore has the authority to take corrective
action in any QA matter, as required. The Quality Manager will become
active in the technical direction of data collection only if it becomes
necessary to bring out-of-control programs back under control, and is
responsible to ensure that the commitment to QA is continuously active.
The Quality Manager is responsible to see that QC activities are carried
out. The Quality Manager's technical review team reviews all technical
reports for accuracy. Technical audits for field measurement activities are
under the Quality Manager's supervision. The Quality Manager reports
directly to Project Management and is in no way subservient to the
technical management.
2.2
2.3
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 5
EG 033 - GEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
2.4
2.5
The Technical Manager for all TCEMS related programs is responsible to
ensure that the OA/OC activities adequately address the technical
requirements and objectives and also to ensure that field measurement
procedures described in the QAPP are follo.wed.
The field activities include all aspects of the Performance Specifications
certification testing as described in Paragraph 4, Sampling Methods
Requirements.
TOCDF CEMS DESIGN
3.1 CEMS Description
3.1.1 For more detail regarding the TOCDF CEMS refer to the
Continuous Emissions Monitoring System Plan (CDRL 06) and the
Continuous Emissions Monitoring System Laboratory Operating
Proced ure (TE-LOP-540).
3.1.2 All compliance analyzers are to be included in the Performance
Specification Test Program. The analyzers are used as
compliance monitors and certified spares. Table 3-1 lists the
specific analyzers assigned to each fuinace system. c3
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 6
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
Table 3-1. Summary of Tooele Chemical Agent Disposat Facility CEMSE
LOCATION ANALYZER
DESCRIPTION
ID NUMBER
Pollution Abatement System Stack
Pollution Abatement System Stack
NO, Analyzer
NO" Analvzer
AIT-076
AIT-0768
Deact
Deact
Deact
Deact
vation Furnace !D Fan Outlet
vation Furnace ID Fan Outlet
vation Furnace lD Fan Outlet
vation Furnace lD Fan Outlet
Oz Analyzer
CO Analyzer
Oz Analyzer
CO Analvzer
AIT-175
AIT-059
AIT-206
AIT-207
Metal Parts Furnace lD Fan Outlet
Metal Parts Furnace lD Fan Outlet
Meta! Parts Furnace lD Fan Outlet
Meta! Parts Furnace lD Fan Outlet
Oz Analyzer
CO Analyzer
Oz Analyzer
CO Analyzer
AIT-082
AIT-384
AtT-670
AtT-669
Liqu
Liqu
Liqu
Liqu
d Incinerator 1 Furnace
d lncinerator 1 Furnace
d lncinerator 1 Furnace
d lncinerator 1 Furnace
D Fan Outlet
D Fan Outlet
D Fan Outlet
D Fan Outlet
Oz Analyzer
CO Analyzer
Oz An alyzer
CO Analvzer
AtT-229
AIT-083
AIT-210
AtT-078
Liqu
Liqu
Liqu
Liqu
d Incinerator 2 Furnace
d lncinerator 2 Furnace
d lncinerator 2 Furnace
d lncinerator 2 Furnace
D Fan Outlet
D Fan Outlet
D Fan Outlet
D Fan Outlet
Oz Analyzer
CO Analyzer
Oz Analyzer
CO Analyzer
AtT-798
AtT-778
AtT-717
AIT-716
Spares Oz An alyzer
CO Analyzer
Oz An alyzer
CO Analyzer
NO, Analvzer
AIT-1001
AIT-1000
AtT-1003
AIT-1002
AIT-9077
GA/L Stack
GA/L Stack
Oa Analyzer
CO Analvzer
AIT-8301
AIT-8302
3.1.3 The TOCDF CEMS analyzer manufacturers, models, and
ranges are shown in Table 3-2. All of the TOCDF CEMS
or correct the gas concentrations on a dry gas basis.
Tabte 3-2. TOCDF Analyzer Descriptions@
operating
measure
Parameter Manufacturer Model Range
CO
CO
O2
Nox
Oz
Teledyne API
Teledyne API
Thermox
Teledyne AP+
Servomex
3OOEM
300EM/OaOption
FCA-micro
ZOOEH
1158 om
0-200,5000 ppm
0-200,5000 ppm
0-25 %
0-1000 ppm
0-25 o/o
TCEMS Description
3.2.1 The TCEMS used to perform the RATA include two distinct types of
Reference Method (RM) measurement systems: direct non-diluting
measurement using an extractive system and measurement of an
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 7
3.2
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
in-stack diluted gas sample. The non-diluting extractive system is
suitable for direct measurement of O2,* CO, oxides of nitrogen(Nod,.@andothergaSeouSconstituentsusing
source-level instrumental techniques. The in-stack dilution system
is suitable for measuring all the above constituents except for Oz
and COz, and it employs ambient-level analyzers. The primary
system to be used for the TOCDF RATA will be the non-diluting
extractive system. The dilution system will may be used for MTAs
as a backup system should problems arise with use of the primary
system.
3.2.2 The TCEMS includes the sample extraction, transport,
conditioning, measurement analyzers, and Data Acquisition
Systems (DAS). For test locations where high stack gas
temperatures exist, appropriate probe materials (such as quartz or
inconel) will be used. Brief descriptions of the two types of systems
are provided below.
3.2.2.1 Non-Diluting Extractive System - A sample is extracted
from the test location through the stainless steel sample
probe. The sample is drawn through a heated sample
Iine. The Iine contains two separate channels; one for
sample extraction, and one for delivery of calibration
gases to the probe for determination of system bias. lf
particulate matter interference is an issue at the source,
the sample flows through a heated filter at the outlet of
the sample line; if particulate matter is not an issue, the
heated filter is bypassed. The sample then passes
through a heated sample pump, and is forced by the
pump into the condenser unit where moisture is
removed. From the condenser unit, the sample passes
through a silica gel trap to further remove moisture, and
then is routed into a sample manifold, where pressure is
regulated, and separate rotameters control flow to each
of the analyzers in the measurement system. The
analyzers output a signal to a scientific data logger,
which processes and records the data from each of the
analyzers. The data is then transferred to Person
Computer (PC), via an Ethernet connection, or by
removing the storage device (flash card) from the data
logger, and transferring the data directly from the storage
device onto the PC.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 8
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
SS Probe
Sample
Line
Calibration Gas
Sample
Line
lnside
Vehicle
Filter (if Necessary)
Heated Sample
Pr lmn
Condenser
Silica Gel
Filter/Water
Trap
tr!E
Figure 3-1 . Noh-Diluting Extractive TCEMS
Vent
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 9
Sample
Gas
DISTRIBUTION
PANEL
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
c2
3.2.3 Three test points will be used for sample extraction for RATA
programs. The points will be on a single traverse at 17o/o, 50o/o,
and 83% of the stack cross sectional diameter.
4 SAMPLING METHODS REQUIREMENTS
4.1 Genera!
4.1.1 Procedures described in this QAPP adhere to the requirements of
40 CFR 266, Appendix lX, Section 2 (Performance Specifications
for Continuous Emission Monitoring Systems) and 40 CFR 60,
Appendix B. Specifically, this QAPP addresses Calibration Drift
(CD), RA, or Absolute Calibration Audit (ACA), and Response Time
testing of the compliance CEMS at the TOCDF. When required, a
stratification test has been performed to evaluate the location of the
applicable CEMS probes.
4.1.2 The EPA Reference Methods (RM) or Performance Test Methods
(PTM) that apply to this QAPP include:
. RM 3A for Oz
RM 7E for NOx
RM 10 for CO
4.1 .3 The instrumental PTMs (RM3A, 7E, and 10) apply to both the non-
diluting and dilution probe TCEMS.
4.1.4 40 CFR 266, Appendix lX, specifies that PTMs be used to
determine the RA of CEMS used to monitor emissions from Boilers
and lndustrial Furnaces (BlFs). Those methods include RM 3A (for
02) and 10 for CO (40 CFR 60, Appendix A). Methods 3A and 10
describe TCEMS monitoring test methods.
4.1.5 Performance Specification 2 (40 CFR 60, Appendix B) applies to
the NOx analyzer in the Pollution Abatement System (PAS) stack.
lt specifies the use of RM 7 or equivalent. RM 7E is an
instrumental method and is generally preferred over the more
cumbersome wet techniques, which would not provide results for
approximately 48 hours.
4.1.6 The EPA does not certify stack monitors. The RM QA procedures,
instrument and system performance requirements, including
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 0
EG 033 - CEMS GERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
4.2
Protocol 1 gas requirements, assure the accuracy of the data.
Unlike the CEMS, the RM TCEMS will undergo zero and bias
checks after every 21 minutes of RATA sampling.
4.1.7 The CFRs containing the above referenced PTMs change
frequently and are not included in this document.
4.1.8 This TCEMS QA plan is intended to incorporate, at a minimum, the
requirements of the PTMs and Performance Specifications
included in the CFR Appendices as listed. Those requirements are
incorporated into this document in their entirety.
4.1.9 The individual Performance Specifications for both the CEMS and
the TCEMS are presented in Paragraphs 6.1 and 6.2, respectively,
of this QAPP. Failure of either system to meet those criteria would
equate to a failed test. lf the Subcontractor TCEMS do not meet
the criteria listed in Paragraph 6.2, corrections to the system are
made and the certification program can continue without repeating
tests for which the TCEMS met the criteria. Failure of the TOCDF
CEMS to meet the criteria in Paragraph 6.1 also requires
correction; however, repairs to the CEMS require that all
Performance Tests be repeated.
4.1.10 Operating configuration of the TOCDF CEMS, such as sample flow
rate and sample pressure, were established during the instrument
systemization and operational experience. As discussed in
Paragraph 4.2, daily system audits are performed to assure that
the analyzers are operating within configuration control. lf
problems are observed, TOCDF Monitoring will be notified
immediately.
4.1.11The specific timing of the tests are established by TOCDF
Monitoring. The certification tests for each incinerator system will
be conducted over an 8 to 9 consecutive day period.
Daily System Audit
4.2.1 As part of the CEMS documentation for each aspect of the
Performance Tests, Monitoring will conduct daily system audits for
all TOCDF CEMS in the furnace system being tested during that
visit. The daily system audit will verify that all equipment is in good
working order during the performance tests.
4.2.2 TOCDF CEMS specific daily system audit forms have been
developed for each furnace system CEMS. The forms include
instrument specific information such as gas flows, converter and
cell temperatures, instrument specific diagnostics, and other
information. The daily system audit will include a review of CD
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 1
EG 033 - CEMS CERTIFICATION QUALITY ASSURANGE PROGRAM PLAN
4.3
data; an inspection of the analyzer warning lights, potentiometer
settings, gas flows; an inspection of transport tubing, particulate
filters, and other conditioning equipment.
Response Time (RT) Test
4.3.1 Response time of each TOCDF CEMS will be determined within
the CD test period for the furnace system being tested to ensure
that the system performance meets the response time criteria. The
RT is performed in accordance with the applicable Performance
Specification (PS) in 40 CFR Parts 266, 60, and 63.
4.3.2 The TOCDF compliance CEMS are required by 40 CFR 266,
Appendix lX, to record a measurement once every 15 seconds and
the DAS must provide a report with averages every 60 seconds.
This DAS requirement is sufficient for all tests described below
except for Response Time tests. A DAS output of once every five
seconds is required to satisfactorily evaluate response times, or a
push button may be used to record time on the DAS.
4.3.3 The zero and high level gases used for the daily calibrations and
CD tests (shown in Table 4-1) may be used for the Response Time
tests.
4.4 Absolute Calibration Audit
4.4.1 The first quarter ACA test will be conducted by Monitoring during
the CD test to ensure the analyzers are operating properly before
the CD test is completed. The ACA test challenges the CEMS with
zero gas and EPA Protocol 1 gases at three measurement points in
each operating range of the analyzer. 40 CFR Part 60 Appendix
EEE QA guidelines require that the ACA test be repeated quarterly.
4.4.2 Based upon the operating ranges for the TOCDF CEMS, gas
concentrations shown in Table 4-2 will be needed for this aspect of
the Performance Tests. Zero nitrogen is recommended because it
will serve as a zero for all of the CEMS except the Oz analyzer.
The Oz analyzer requires a low concentration of 02, ?s indicated in
Table 4-2.
4.4.3 Test gases will be introduced to the CEMS as close to the sample
probe as possible in the order shown in 40 CFR Part 60, Appendix
B, Performance Specification 48, para 7.1, Calibration Error Test
Procedure. A standard form (Ref. PRP-MO-001) shall be used to
record ACA test data and report test results. As specified in the
Performance Specifications and reflected on the form, three (3)
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 12
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
4.5
nonconsecutive results are required for each gas for single range
analyzers.
Calibration Drift (CD) Tests
4.5.1 CD tests will be conducted by TOCDF Monitoring to determine
compliance of each CEMS in accordance with 40 CFR 266 App. lX
and Part 60. The CD tests will require a total of eight checks (a
baseline check and seven drift checks) for each furnace system.
4.5.2 Each CD test on CEMS will be conducted concurrently so that the
CD test is completed in eight consecutive days. lf the CD test is
interrupted before it is completed, one additional day will be
required for each interruption so the calibration baseline can be
reestablished after the interruption. lnterruptions include plant
upset conditions or downtime during which the CEMS are not
monitoring stack gas. As mentioned in Paragraph 4.1.9, problems
associated with the CEMS themselves void all portions of the
certification tests preceding the CEMS failure.
4.5.3 The daily CD checks will be conducted prior to any zero and span
adjustments and at approximately 24-hour intervals thereafter.
Monitoring will introduce zero and a span gas to each range used
to monitor the furnace system being tested. The CD gas
concentrations are identified in Table 4-1. CD gases and
calibration gases must be EPA Protocol 1.
4.5.4 The gases will be introduced as near to the sample probe outlet as
possible so that the entire CEMS is represented by the CD test.
.4.5.5 The data will be recorded and summarized on the CEMS
Calibration Drift Test Record (Ref. PRP-MO-001). The results will
be determined daily so that corrective action can be taken if
required.
4.6 RA Tests
4.6.1 RA tests will be performed during the CD test on the furnace
CEMS. PTM will be those RMs (40 CFR 60 Appendix A) listed
below:
Carbon Monoxide Reference Method 10
Oxygen Reference Method 3A
Nitrogen Oxides Reference Method 7E
4.6.2 Each RA test will be conducted at a sampling location meeting the
specifications of 40 CFR 266, Appendix lX. Tests will be conducted
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 3
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
for 21 minutes and will include sampling from three traverse points
for seven minutes "'p", point.
4.6.3 The overall approach for the RATA is to operate a single TCEMS.
Only one extraction point will be tested at a time. ur
4.6.4 A minimum of 9 and a maximum of 12 tests are required for the RA
tests. Data will be recorded on a standard form. The TOCDF
CEMS data are reported on a dry basis. Therefore, RA test
measurements will be made on a dry basis.
4.6.5 All RA test calibration gases will be Protocol 1 gases. The
measurement ranges for the Subcontractor's TCEMS used for the
PTM will be matched to the CEMS being certified. The RM
analyzer ranges and the required Protocol 1 gases are shown in
Table 4-3.
4.6.6 lnterference checks will be performed according to the^^specific RM
on all RM analyzers prior to their initial use at TOCDF. vg
4.6.7 RM catibrations (including a zero and two point span check) for the
TCEMS will be performed prior to the first of each set of I to 12
CEMS RATA tests. Each calibration gas will be introduced as near
to the probe inlet as possible so the entire TCEMS is calibrated.
After each RA test, a system bias check will be performed to
validate the data from the previous test, IAW 40 CFR, pt 60, App.
A, Method 6C.
4.6.8 lf problems are identified by the bias check, the previous test will
be voided and repeated after corrections to the system are made.
Problems that require corrections to the system and result in a
voided test automatically trigger the need for a complete system
calibration before testing is resumed.
4.6.9 Reports of the CEMS data will be obtained from EG&G for each
RATA. PTM and CEMS data for each test run will be entered into
a spreadsheet so the preliminary results can be evaluated. The
preliminary results, including the individual test differences and
arithmetic mean of the differences, standard deviation, confidence
coefficient, and the relative accuracy, are to be reported to EG&G
at the end of each test day.
CEM Certification Quality Assurance Program Plan
EG 033 Rev B Chg 3 xx xxx 09
Page 14
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
4.7 Stratification Test for the MPF Analyzers
Stratification is defined in 40 CFR 266 as a difference of 10o/o or more
between the average concentration in the duct and "the concentration at
any point more than 1.0 meter from the duct or stack wall". For the
purposes of this program stratification will be a difference of greater than
10% between the average concentration at the centroid (CEM
measurement location) and the average of the RM test points. This test
has been completed for the applicable Iocation.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 5
93
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
Table 4-1. Zero and Gertified Galibration Gas Requirements for Galibration,
Galibration Drift, and Response Time Tests
Table 4-2. Acceptable Concentrations for GEMS Quarterly Audits (AcA/Cylinder
Gas Audits)
Table 4-3. Zero and Protocol 1 Gas Requirements for Performance Test Method
(PTM) Analyzer Operation
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 6
Analyzer
Percent of
Range
co
0-200 ppmv
co
0-5000 ppmv
Oz
0'25 o/o
NO*
0-1000 ppmv
0-20
60-90
Nitrogen
120-1 B0
Nitrogen
3000-4500
0-2.5
15-22.5
Nitrogen
600-900
ANALYZER
TYPE
LOW GAS
RANGE
MID GAS
RANGE
HIGH GAS
RANGE
CO Range 1
CO Range 2
0-40 ppm
0-600 ppm
60-80 ppm
500-2000 pprn
140-1 60 ppm
3500-4000 ppm
Oz o-2.0c1 %8-1 0%14-16 o/o
NO*200-300 ppm NA 500-600 ppm
CALIBRATION SPAN GAS MUST BE 50-90 % FULL SCALE SPAN
Analyzer
Percent of
Range
co
0-200 ppmv
co
0-5000 ppmv
Oz
0-25 o/o
COz
0-20 o/o
NOr
0-1000 ppmv
0-0 .25
40-60
80-100
Nitrogen
B0- 120
160-200
Nitrogen
2000-3000
4000-5000
0-2.5%
10-15
20-25
Nitrogen
B-12
16-20
Nitrogen
400-600
800-1000
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
SAMPLE HANDLING AND CUSTODY PROCEDURES
5.1
5.2
5.3
5.4
5.5
Most measurements made for this program will be done by on-site CEMs.
All data collected for this program is recorded onto carbonless triplicate
forms. Custody of the original is transferred to the Subcontractor's
document control officer. The subcontractor will secure the original for up
to five years. One copy of the completed form will be retained by the field
team manager for data processing. Custody of the third copy will be
transferred to the QA manager so that review can proceed immediately.
The TCEMS DAS output for the RATA wil! be copied to three separate
distinctly labeled disks. The custody of the disk copies will be transferred
as described above for the data forms. The Field Team Manager's copy
will be transferred to the data processing team for formatting according to
the report requirements.
All samples and data transfers will be documented on carbonless triplicate
forms (or equivalent).
Subcontractor to provide TOCDF with electronic data.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 7
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
QUALITY CONTROL REQUIREMENTS
6.1
6.2
TOCDF CEMS Performance Specification
QC Requirements for the TOCDF CEMS are summarized below for each
measurement parameter.
6.1.1 CO CEMS Performance Specifications
Calibration Drift (24 hours) < 3o/o of span in either high or low
range"'
Absolute Calibration Audit < 5o/o of span in either high or low
range"'
ResponseTime <2minutes
Rerative Accuracv : #,i;{;?1XIf,, when M is
calculated as the absolute
average difference between the
RM and CEMS +2.5o/oCC
.c1
6.1.2 Oz CEMS Performance Specifications
Calibration Drift (24 hours) < 0.5o/o oxygen
Absolute Calibration Audit < 0.5% oxygen
< 2 minutes
<1 .O% Or"'
6.1 .3 NO* Performance Specifications
Response Time
Relative Accuracy
Calibration Drift
Calibration Gas Audit
Relative Accuracy
, < 2.5o/o of span
+ 15% or sppm, whichever is
greater
20% of RM or 10% of the emission
standard
TCEMS Performance Specifications
6.2.1 The PTMs identified in Paragraph 4 include strict QC performance
specifications for the measurement systems. Those QC
requirements are summarized below:
o Analyzer Calibration Error - Less than 2o/o of the span value
for the zero, mid-range, and high-range calibration gases.
Sampling System Bias - Less than 5% of the span for the
zero and mid -range or high-range calibration gases.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 8
EG 033 . CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
Zero Drift - Less than 3% of the span over the period of each
run.
Calibration Drift - Less than 3o/o of the span over the period of
each run.
o lnterference Response - Less tharl 2o/o of the span value.
6.2.2 The procedures for ensuring that the PTM measurement system
meets these QC requirements are discussed below.
6.2.2.1 TCEMS Interference Tests
ln order to establish that the TCEMS measurement
system does not demonstrate interference from
other gases, each analyzer will be challenged with
the interference gases shown in Paragraph 4.3 and
Table 4-1 .
o Results will be documented and will be on-hand for
all TCEMS test activities. lnterference checks are
done on the non-diluting TCEMS by introducing the
interference gas directly to the analyzers.
lnterference checks are done on the dilution probe
TCEMS by introducing the gas through the dilution
system.
6.2.2.2 Setup and Preliminary Checkout
1) Non-Diluting TCEMS
a) The non-diluting extractive TCEMS is illustrated
in Paragraph 3.2.2.1, Figure 3-1 . The sample
probe is usually constructed of stainless steel
but may also be constructed of either glass or
teflon. The sample gas passes through a
heated three-way valve before passing through
the glass fiber filter, condenser, and samplepump. The clean, dry sample is then
transported to the analyzer system for pollutant
measurement.
b) After the TCEMS is assembled it is leak-checked
from the probe tip to the pump outlet. The
system is equipped with a vacuum gage and
toggle valve arranged to allow isolation of the
portion of the TCEMS that will be under negative
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 1 9
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
pressure. The probe tip is plugged and a
vacuum of at least 12 inches of mercury is
applied to the system using the sampling pump.
The toggle valve is then closed isolating the
vacuum in the system. The pump is then turned
off and the vacuum gage observed for one
minute. lf no decrease in the vacuum is
observed over a period of one minute, the
system is considered leak free. lf a drop in the
vacuum is observed, the problem is corrected
and the leak check repeated.
c) The three-way valve mentioned above, allows
the test operators to introduce calibration, zero,
and response tlme gases to the TCEMS at the
back end of the sample probe at or ne ar ambient
pressure so that TCEMS leaks, should they
develop, are not masked by over-pressurization.
2) ln-stack Dilution Probe TCEMS
a)The dilution probe TCEMS is illustrated in,
Figure 3-2. The TCEMS includes a four line
umbilical that allows (1) zero dilution air and (2)
calibration gases to be transported to the probe
and allows (3) diluted sample gas and (4) the jet
eductor pressure to be transported to the
analyzers.' No system leak check is performed
because the system is operated under positive
pressure.' r
After the initial setup, the analyzers are calibrated
directly, bypassing the dilution system. This is
done using low-range zero and calibration gases
that are not available with Protocol 1 designations.
The direct analyzer calibrations are designed to
bring the analyzers into their normal operating
conditions. After the analyzers are adjusted with at
least a zero and one high-range calibration gas, a
calibration gas in the range of the expected stack
gas concentrations is introduced through the
dilution probe and the dilution air panel pressure is
adjusted to achieve the desired dilution ratio.
Once the dilution pressure is adjusted to the
correct dilution ratio, ho further adjustments can be
made without invalidating the system bias checks.
b)
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 20
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
6.2.3 TCEMS Response Time Determination
The response time of the TCEMS is measured by an operator
placing the sample probe in the stack. Zero gas is introduced to
the TCEMS through the three-way valve and the response allowed
to stabilize. After the response to the zero gas has stabilized, the
three-way valve is switched so that stack gas is delivered to the
TCEMS. The time required for the TCEMS to achieve 95% of the
final stabilized stack measurement is the TCEMS response time.
The process is repeated three times for each of the zero and high
level calibration gases, alternating between the two. The average
response time is determined from these six tests. The average
response time for the TCEMS must be less than two minutes
The response times shall be documented on a tracking form.
6.2.4 Systems Component Performance Checkc2
A system component performance check will be performed and
documented after each three test runs to ensure proper
performance of each component to verify that no malfunctions or
inadequate performance will adversely affect data collection.c2.
PTM INSTRUMENT/EQUIPMENT
MAINTENANCE REQUIREM E NTS
TESTING,INSPEGTION, AND
All components of the TCEMS are subject to scheduled tests, inspections, and
periodic preventive maintenance in the course of mobilization, setup, and field
testing. ln addition, extensive precautions are taken to prevent TCEMS
component failure. As a final precaution, spare parts and backup equipment will
be available to minimize equipment down-time due to unpreventable component
failures.
7.1 Pre-mobilizationSystemCheckout
Prior to mobilizing for field programs, the entire TCEMS is assembled,
leak checked (if appropriate), warmed up, and subjected to a complete
multipoint CE check. The response of each analyzer is checked for
linearity (error) and system bias. The CE check is repeated between 8
and 24 hours later to evaluate the tendency for instrument drift. Records
of these pre-mobilization checks are retained in the project files.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 21
EG 033 - CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
7.2
7.3
7.4
System Setup, Checkout, and Daily System Audits
7.2.1 After initial setup and checkout of the TCEMS at TOCDF, a
systems component performance check will be made to evaluate
pressures, vacuums, flows, and/or temperatures are at required or
expected levels. The system check will be performed and
documented as lease every three runs to alert the operator of an
impending malfunction or failure and corrective action can be
performed. c2
7.2.2 Changes in the status of the TCEMS operating conditions will be
documented. Corrective action will be taken if: moisture develops
in the sample lines, the sample vacuum buiHs, either of the filters
become plugged, or other changes in the system threaten the
reliability of the test results.
Preventive Mai ntenance
At the end of each test day, the TCEMS operator will evaluate the system
and perform preventive maintenance as necessary. Equipment^will be
secured in a configuration to prevent failure between test periods."
Critical Spare Parts
Critical spare parts necessary for the operation of the TCEMS will be on-
hand to minimize down-time. When possible, backup analyzers will be
transported to the test site so that complete replacement can be made
within a few hours in the event of an analyzer failure.
PTM INSTRUMENT CALIBRATION AND FREQUENCY
TCEMS calibrations include direct calibration of the analyzers at least once each
test day and a complete TCEMS zero and span check before and after each test
run.
8.1 Preliminary Analyzer Calibration Error
8.1.1 Each PTM analyzer will undergo multipoint calibrations using zero
and at least two Protocol 1 calibration gases prior to the first test on
each test day. Calibration gases are specified in Paragraph 4. The
cylinder and analyzer response data will be documented.
8.1.2 The CE will be calculated for each zero and calibration gas. lf any
of the CE exceed 2o/o, corrective action must be taken and the
multipoint analyzer calibration repeated. The CE checks for all
analyzers used to make measurements at any one location will be
recorded on a single form.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 22
EG 033 - CEMS CERTIFIGATION QUALITY ASSURANCE PROGRAM PLAN
8.2 Sample System Bias, Zero and Galibration Drift Ghecks
8.2.1 Following successful completion of the multipoint analyzer CE
checks prior to the first test, and after each test period, a zero and
single point calibration check is performed for each measured
parameter to determine the TCEMS bias, zero drift, and CD. Each
gas is introduced as near to the sample probe inlet as possible so
that the entire TCEMS is characterized by the system check.
8.2.2 The results of the TCEMS bias check will be documented. The
system bias and the system drift will be calculated for each of the
zero and upscale calibration gases. lf the system bias exceeds
So/oi ot either the zero or the CD exceed 3o/o, the preceding test is
considered unacceptable and corrections to the system must be
made. lf corrections to the system are required, the Subcontractor
will repeat the CE check and the System Bias check.
8.2.3 The results of all System Bias and CD checks conducted on a
given day on a single analyzer will be documented. Separate
documentation will be used for each analyzer.
I PTM DATA ACQUISITION REQUIREMENTS
9.1 General
9.1.1 Each analyzer outputs a signal to the DAS. The analyzer output
signals are direct current (DC) volts and are linear and directly
proportional (within the calibrated operating range of the
instrument) to the concentration of the specific parameter being
rneasured.
9.1.2 The DAS includes a scientific data logger that processes the output
signal from the analyzer and downloads it to a PC. lnput to the
scientific data logger is continuous. The scientific data logger
averages the signal over periods of time that are variable by the
operator. Typical averaging periods range from one second up to
five minutes, depending on the intended use of the data.
9.1.3 The averaged data are downloaded by the scientific data logger
into an ASCII file in the PC. The signal is simultaneously
processed and displayed on a color monitor. A hard copy of the
data is generated on a printer as it is downloaded from the
scientific data logger to the PC.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 23
EG 033 . CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
9.2 Data Quality Requirements
9.2.1 The analyzer performance requirements are listed in Paragraph
6.2. They are also repeated below:
Analyzer Calibration Error - Less than 2% of the span value
for the zero, mid-range, and high-range calibration gases.
Sampling System Bias - Less than 5o/o of the span for the
zero and mid-range or high-range calibration gases.
Zero Drift - Less than 3o/o of the span over the period of each
run.
Calibration Drift - Less than 3% of the span over the period of
each run.
o lnterference Response - Less lharl 2% of the span value.
9.2.2 lf the above TCEMS performance requirements are not met, the
test data are not acceptable for the purposes of this program.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 24
EG 033 - CEMS GERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
1O DATA QUALITY MANAGEMENT
10.1 Data collected during a field sampling program wil! be considered
preliminary. Copies of preliminary data may be relinquished to the
contractor's representative, EG&G or Lab QC Personnel. No data will be
relinquished without a qualification of the status of the data placed on the
data.
10.2 Preliminary daily report in hard copy or electronic format shall be
produced to monitor testing status. This preliminary report will include the
sampling location, tests that were conducted, passing criteria, and a
pass/fail status.
10.3 Preliminary status of data will apply until the data is included in a final test
report. The fina! report will be approved by the following entities:
o Sub-contractor Quality Manager
. TOCDF Laboratory QC Manager
EG&G Environmental Manager
CMA Field Office
o Deseret Chemical Depot Title V Responsible Official (for DAQ reports
onlY)
10.4 Rounding numbers, any number less than or equal to 5 round down, and
any number 6 or higher round up.
CEM Certification Quality Assurance Program Plan
EG 033 Rev 8 Chg 3 xx xxx 09
Page 25
EG 033 . CEMS CERTIFICATION QUALITY ASSURANCE PROGRAM PLAN
LIST OF EFFECTIVE PAGES
N:\Environmental\FICM\RCFIA-Mod\1092 - atlicVesoonse to state comments\2nd comment oeriod oermit chanqe paqes
word\ATCH-2O EG033 R8C3 atlic final Rev 1.do
CEM Certification Quality Assurance Program Plan
EG 033 Rev I Chg 3 xx xxx 09
LIST OF EFFECTIVE PAGES
PAGE NO.REV/CHG NO.
1 RBC2
2-8 R8C3
I - 13 R8C2
14 R8C3
15 RBC2
16 RBC3
17 -25 RBC2
(+
F|'
tD())l-a*
l-)o
H)(+
N)
N)
TOCDF
Agent Monitoring Plan
October 2009
ATTACHMENT 22
AGENT MONITORING PLAN
Attachm ent 22 - Page I
TOCDF
Agent Monitoring Plan
October 2009
TABLE OF CONTENTS
LIST OF APPENDTCES .............. ..................3
LIST OF ACRONYMS and TERMINOLOGY. ...............4
TERMINOLOGY .......... ..........6
22.1POLICY/GOALS OF MONITORING OPERATIONS ................ .................9
22.12 Perimeter Monitoring. ......................9
22.1.3 TOCDF StationNumbering and Locations............... .............9
22.1.4 Summarized Requirements ................. ................9
22.2 RESPONSIBILITIES ..........9
22.3 COORDTNATTON ............10
22.3.2 Monitoring Manager ......................10
22.3.3 Monitoring Operations Supervisor.. ..................11
22.3.4 Monitoring Team Leader ...............10
22.4 OBJECTIVES OF THE MOMTORING PLAN .......................10
22.5 AGENT MONITORING ACTIVITIES................. ....................10
22.6 TOCDF PLANTACTITIVES ..............11
22.7 CATEGORIES OF PLANT AREAS ......................11
22.7.1Toxic and Process Areas......... .......11
22.72 Toxic Process Areas Air1ocks............. .............11
22.7.3 Outside of Toxic Process Areas......... ...............11
22.7.4 WorkAreas......... ........11
22.7.5 Lunch Rooms ..............11
22.7 .6 Positive Pressure Areas......... .........1 1
22.7 .7 Positive Pressure Areas......... .........12
z2.8FtlTER MONrTORING......... .............12
22.9 SAMPLING PARAMETERS........... ......................13
22.t0 DATA HANDLING................ ..........13
22.11 QUALITY CONTROL.............. ........13
22.11.1 QualityManagementProgram... ......12
22.11.2 FailuretoMonitor. ...............12
33:13 U3$H8i1fi)lilF8I?ff^?s: : ::: : :,::::::::: :::: ::: :::: :: : ::::::: ::: :11
22.14 MONITOR/MONITORING LOCATIONS ................ ............15
22.15 MONTTORING PLAN ......................15
22.15.1 List of Monitors............. .............15
22.15.3 Temporary Changes..... ...............15
22.15.4 Additional Support ,.................. .....................15
22.16 MONITORING STRATEGY .........:..s..................14
22.162 STEL......... ................14',tril:lJSl " : :i;
22.16.5 AELLevels.. .............:.i ... ...15
22.16.6 Monitoring Cessation..... ........... ....15
22.17 EQUTPMENT .................16
Attachrnent 22 - Page 2
TOCDF
Agent Monito.ing Plan
October 2009
22.18 STACK CONFIGURATION........... ....................18
22.t8.2 ACAMS..... ..............18
22.t8.3 DAAMS. .......19
22.18.4 Dilution Air Flow Controllers .......................19
22.19 FURNACE STACK AND DUCT MONTTORTNG ........... ........................19
22.l9.|Calibrating,Challenging,orServicing.........'......'
22.19.2 Suspended Monitoring (Furnace Ducts Only)......... .........19
22.19.3 Suspended Common Stack Monitoring .......... ..................20
22.20 MOMTORTNG FOR AGENT FROM PAST CAMPAIGNS................. ......................21
22.2t Ltr.E SUPPORT SYSTEM (LSS) ArR HOSE MONTTORTNG ................ ...................21
22.22 ACANLS DATA COLLECTION............. .............20
22,23 DAANIS SYSTEM .,.,.,...20
22.24 BACKT.TP EQUrPMENT....... ............2t
22.2s MATNTENANCE ................... ...........2t
22.26 STARTUP OF MONITORING................ ...........21
22.27 SPECTAL ON-SITE CONTAINER (ONC) MONrTORrNG............ .........2t
22.28 ACANTS ALARM HORN.. . ... . .. . . . 21
22.29 ACANTS ALARM LEVEL...... ......................21
22.30 PORTABLE ACAMS/DAAMS MONITORING TRAILERS ,,,.,,,,.,,,,,., .21
22.31 CARBONFILTERS ONACAMS......... ,.,.,.,.22
22.32 I0/IPF DISCHARGE AIRLOCK (DAL) ACAMS/DAAMS...... ......,22
22.33 ACANTS/DAAMS AT EQUIPMENT HYDRAULIC MODULE.. . . ......... ,22
22.34 FUGITIVE EMISSIONMONITORING... .,,........,. .,22
22.35 ALARMRESPONSEREQUTREMENTS... ......23
22.35.1 Common Stack Alarm for VX or GB. ..... ...23
22.35.2 Duct (MPF/DFS/LIC1/LIC2) Alarm for VX and GB.....:... .....24
22.35.3 HVAC StackAlarm for VX or GB... .........24
22.35.4WorkplaceMonitoringforVX(CategoriesCandDAreas). ......24
22.35.5 Workplace Monitoring for GB (Categories C and D Areas)...... ... ...'. 24
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
APPENDIX G
APPENDIX H
APPENDIX I
APPENDIX J
List Of Appendices
AGENT MONITORING PLAN ..:................ .......................27
DRAWINGS OF AIR MONITORING LOCATIONS .,.,.,,,,64
HEATED SAMPLE LINE ASSEMBLY DRAWING .........82
HEATED SAMPLE LrNE PARTS DRAWTNG................ .....................84
DAAMS DILUTION AIR FLOW CONTROLLERS ..........86
DAAMS STACK SAMPLING ASSEMBLY ......................88
ACAMS STACK SAMPLING ASSEMBLY .......................90
ACAMS/DAAMS VX SAMPLING PROBE CONFIGURATION...............,,....,,....92
SAMPLE PROBE FOR ArRLOCKS........... ........................94
ACAMS/DAAMS VX SAMPLING PROBE CONFIGURATION...........................96
Attachrnent 22 - Page 3
TOCDF
Agent Monito.ing Plan
October 2009
LIST OF ACROIYYMS and TERMINOLOGY
ACRONYMS
ACAMS AutomaticContinuousAirMonitoringSystem
ADAFC ACAMS Dilution Air Flow Controller
AEL Airbome Exposure Limit
AL Alarm Level
AMP Attachment 22, Agent Monitoring Plan
ASR Agent Sampling Room
AWFCO Automatic Waste Feed Cutoff
BSA Buffer Storage Area
CAL Chemical Assessment Laboratory
CAMDS Chemical Agent Munitions Disposal System
CDC Center for Disease Control and Prevention, Department of Health and Human Services
CDRL Contract Data Requirements List
CHB ContainerHandling Building
CMA Chemical Materials Agency
CON Control Room
COR Corridor
CPA Conversion Pad Assembly
CWM Chemical Warfare material
CYC CycloneDAAMS Depot Area Air Monitoring System
DAL Discharge Airlock
DCD Deseret Chemical Depot
DFS Deactivation Furnace System
DPE Demilitarization Protective Ensemble
DSA DPE Support Area
DUC Duct
ECF Entry Control Facility
ECL Engineering Control Level
ECR Explosive Containment Room
ECV Explosive Containment Vestibule
EHM Equipment Hydraulic Modules
FIL Filter
GA Nerve Agent GA, Tabun
GB Nerve Agent GB. Sarin
GCTFPD Gas Chromatograph / Flame Photometric Detector
GCA{SD Gas Chromatograph / Mass Spectrometer Detector
GFP Government Furnished Property
GPL General Population Limit
H Levinstein Mustard, or bis(2-chloroethyl) sulfide
HD Blister Agent HD
HDC Heated Discharge Conveyer
HT Blister Agent HT (Thickened)
IDLH Immediately Dangerous to Life and Health
LCO Limiting Conditions of Operations
Attachrn ent 22 - Page 4
TOCDF
Agent Monitoring Plan
October 2009
LIC Liquid Incinerator
LOP Laboratory Operating Procedure
LOQ Limit of QuantificationLMQAP Laboratory and Monitoring Quality Assurance Plan
LQCP Laboratory Quality Control Plan, TOCDF Site Plan
LSS Life Support System
LVS Low-Volume Sampler
MCP Monitoring Concept Plan
MDB Munitions Demilitarization Building
MED Medical Facility
MER Mechanical Equipment Room
MON Monitoring
MPB Munitions Processing Bay
MPF Metal Parts Furnace
MSB Monitor Support Building
MLIN Munitions
NRT Near Real-Time
OBS Observation Corridor
ONC On-Site Container
ORR Operational Readiness Review
P&A Precision and Accuracy
PAS Pollution Abatement System
PDARS Process Data Acquisition and Reporting System
PMB Personnel Maintenance Building
PPE Personnel Protective Equipment
PUB Process Utilities Building
QA Quality Assurance
QC Quality Control
QP Field Quality Control Samples
RCRA Resource Conservation and Recovery Act
RDTE Research Development Test and Evaluation
RL Reporting Limit
RTAP Real Time Analytical Platform
SDS Spent Decontamination System
SEL Source Emission Limit
SOP Standard Operating Procedure
SPS Secondary Power (Distribution) System
STEL Short-Term Exposure Limit
TCB Treaty Compliance Building
TMA Toxic Maintenance Area
TOCDF Tooele Chemical Agent Disposal Facility
TOX Toxic Cubicle
UPA Unpack Area
UPS Unintemrptible Power Supply
VSL Vapor Screening Limit
VX Nerve Agent VX
WAP Waste Analysis Plan
WHS Warehouse
WPL Worker Population Limit
Z A generic designation of an applicable monitoring level such as STEL, WPL, VSL, GPL or SEL.
Attachm ent 22 - Page 5
TOCDF
Agent Monitoring Plan
October 2009
TERMINOLOGY
Action Level - A pre-determined set point that triggers a specified action.
AEL: Airborne exposure limit is the allowable concentration in the air for workplace and general
population exposures. AELs include worker population limits (WPLs), short-term exposure limits
(STELs), Vapor Screening Limit (VSL), immediately dangerous to life or health values (IDLHs), and
general population limits (GPLs).
Alarm Level (AL): Alarm Level at which the ACAMS (Near-Real Time) monitor will alarm to alert
personnel of a potential upset conditions. All sampling and analytical monitors must, at a minimum,
measure within +25% of the true concentration95o/o of the time. Alarm levels are defined in Attachment
22, Appendix A.
Baseline (Initial): Before each individual agent campaign the monitoring system is operated in the
configuration in which it will be used during the campaign. This is known as baseline operations. The
purpose for the baseline is to provide evidence that the whole system will perform within required
tolerances and requirements, and to document the configuration of the system at the time of the baseline.
Once a system is baselined, the configuration of the system must not be changed (within limits) or the
baseline has been violated and a new baseline must be performed.
Category A Area: The toxic processing area supported by the cascade ventilation system designated for
probable liquid and vapor agent contamination (for example, munitions processing bay, toxic cubicle).
Category B Area: The toxic processing area supported by the cascade ventilation system designated for
possible vapor agent contamination only.
Category C Area: The nontoxic work area adjacent to Category A or B areas that is supported by the
cascade ventilation system designated for possible lowJevel vapor agent contamination (for example,
observation corridors).
Category D Area: The nontoxic work area designation for areas considered uncontaminated.
Category E Area: The area designated for a positive pressure, filtered air environment (for example,
Control Room).
Distal End: Location where the air sample enters into the sampling system except for the MPF
Discharge Airlock and DAAMS duct monitors for VX. The distal end for VX at the MPF Discharge
Airlock ACAMS and duct DAAMS is at the V/G conversion pad located five inches from where the
sample enters the system. The MPF Discharge Airlock DAAMS V/G conversion pad is located 18 inches
from where the sample enters the system when VX agent is monitored.
ECL: Engineering Control Level (ECL) is uied to indicate that the sensitivity of the ACAMS at this
location has been increased to provide representative readings in agent contaminated areas that are higher
than the VSL and lower than IDLH monitoring.
Engineering Control or Under Engineering Control: When the environment in a room or area is
under negative atmospheric pressure and the evacuated- air is processed to remove contamination, the area
or room is considered to be "under engineering control." An example is a munitions processing room that
is expected to be contaminated with agent. The room is maintained under negative pressure to prevent
agent leakage out of the room. The air that is evacuated from the room is filtered through carbon to
remove the agent.
G-Agents: Either nerve agent GA (Tabun) or GB (Sarin).
Attachm ent 22 - Page 6
TOCDF
\Bent Monitoring Plan
GPL: General Population Limit: The allowable 72-hour time-weighted average concentration for the
general population. The limit applies to the entire population, including all ages and medical conditions.
For G-agents, the GPL is 1 x 10-6 mglrrf for 24 hours. For VX, the GPL is 6 x 10-7 mghrf for 24 hours.
For HD, the GPL is 2 x 10-5 mg/ri for 12 hours.
H - Levinstein Mustard, or bis(2-chloroethyl) sulfide. Mustard produced by the Levinstein process
contains about 30 percent sulfur impurities. H is monitored as HD.
HD - Distilled Mustard, or bis(2-chloroethyl) sulfide. HD is H that has been purified by washing and
vacuum distillation to reduce sulfur impurities. HD may be contaminated with trace concentrations of the
blister agent L.
HT - Blister agent mustard composed of approximately 60 percent HD and 40 percent agent T {bislz-(z-
chloroethylio)ethyllether). Both HD and T are alkylating agents. HT is monitored as HD.
IDLH: Immediately Dangerous To Life and Health (IDLH): The maximum concentration from which,
in the event of a respirator failure, one could escape within 30 minutes without a respirator and without
experiencing any escape impairing (for example, severe eye irritation) or irreversible health effects.
IDLH levels are 0.1mg/# for G-agents, 0.003 mdri for VX, and 0.7 mg/m3 for mustard. The mustard
IDLH is based only on non-carcinogenic effects. No IDLH has been established for carcinogens.
Interferent: An interferent is a chemical compound that will cause an Automatic Continuous Air
Monitoring System (ACAMS), Depot Area Air Monitoring System (DAAMS) to false alarm or
malfunction in such a way that they could not detect agent. There are some interferents that mask agent
so it is not detectable, including some paints, lubricants, and even some foods. The DAAMS analysis is
better at discriminating between agent and an interferent than the ACAMS. For this reason, DAAMS are
paired with ACAMS at many locations for the purpose of confirming or denying alarms.
Neat Agent: Neat agent is agent that has not been diluted since manufacture or preparation. It may not
be "pure" but it is as manufactured. Once it is diluted, it is no longer considered neat.
QP: Quality Plant sample: The quantitative result obtained from challenging an ACAMS/DAAMS or
sample line with a solution prepared at a known concentration.
RDTE Dilute Solutions: RDTE Dilute Solutions are defined by the agent concentration and by the
quantity in a single container. They are as follows:
Agent
G-agents
VX
Mustard
Maximum Total Ouantity
20 mg
10 mg
100 mg
Maximum Concentration
2.0 mg/ml
1.0 mglml
10.0 mg/ml
SEL: Source Emission Limit, the SEL was previously known as the Allowable Stack Concentration
(ASC). SEL is a ceiling value that serves as a source emission limit, and not as a health standard. It is
used for monitoring the furnace ducts, and cornmon stacks. The SEL provides "an early. indication of
upset conditions, and must be accurately measurable in a timely manner. Modeling of worst -case
credible and conditions at each installation must confirm that the general population limit (GPL)
monitoring level is not exceeded at the installation boundary as a consequence of releases at or below the
SEL. It should be noted when monitoring at the common stack, because of the high temperature and
moisture content of stack emissions, a dilution control device is used for the ACAMS and DAAMS. The
SEL value for G-agents and VX is 0.0003 *dm3 and mustard is 0.03 mg/m3.
STEL: Short Term Exposure Limit is the maximum concentration to which unprotected chemical
workers may be exposed to for up to 15 minutes continuously. For G-agents, the STEL is 1 x 10-a mdm3
four times daily. For VX, the STEL is 1 x 10-5 mg/m3, one time daily. For IID, the STEL is 3 x 10-3
miltf ., one time per day.
Attachm ent 22 - Page 7
STEL Concentration: A concentration equivalent to the
one-cycle reading of a Near-Real Time monitor).
TOCDF
Agent Monito.ing Plan
October 2009
STEL value but without time weighting (i.e., a
VSL: Vapor Screening Limit. A vapor concentration term that is independent of time. It may be used to
define the level to which an item is monitored to determine the agent contamination level, or alternately,
the readout of an NRT monitor. For G-agents, the VSL is 1 x 104 ^glrrf . For VX, the VSL is I x 10-s
-g/-'. For HD, the VSL is 3 x 10-3 n g/.'.
WPL: Worker Population Limits. The average allowable concentration that an unmasked worker could
be exposed to for an 8 to 12 hour workday 40 hours per week for 30 years without adverse effects. The
WPL for TOCDF has been adjusted to reflect a 12-hour work shift. The 12-hour WPL for G-agents is 2 x
10-5 mg/m3, VX is 6 x 10-7 mg/rrf ,and HD is 2.7 X 104 mg/m3.
Zt A geneic designation of an applicable monitoring level such as STEL, WPL, VSL, GPL or SEL.
Attachrnent 22 - Page 8
22,1
22.1 .1
22.1. 1 .1
22.1 .1 .2
22.1.2
22.t.2.1
22.1.3
22.L.3.1
22.1.4
22.t.4.t
22.2
22.2.1
TOCDF
Agent Monitoring Plan
October 2009
AGENT MONITORING PLAI\
POLICY/GOALS OF MONITORING OPERATIONS
Purpose
This Monitoring Plan contains monitoring requirements for Mustard (H, HT or HD) bulk
and munitions processing, and processing of Mustard, VX and GB secondary waste.,
Secondary wastE is only allowed per Conditions V.C.1.a.ii through V.C.1.a.viii for the
purpose of this plan, the term "Mustard" may mean agents H, HT, or HD). This plan
reflects the monitoring for each processing area when it is being used for agent work.
When agent work in a given area is suspended, the monitoring for that area may be
suspended as stated in Paragraphs 22.16.6, 22.19 .2 or 22.19 .3. Before campaigns other
than those listed above coillmence, a revised monitoring plan shall be developed.
The primary purpose of Monitoring is to have near real-time analytical data to
limit/prevent and document exposure of personnel to chemical warfare agents and protect
the environment from the introduction of agents. Agent monitoring is also performed for
process control putposes to identify upset conditions in the processes and to measure
agent concentrations in toxic areas which allow management to make decisions on
protective clothing requirements for entries into toxic areas.
Perimeter Monitoring
Monitoring of the perimeter of the Deseret Chemical Depot (DCD) is conducted by
Chemical Agent Munitions Disposal System (CAMDS) personnel. Perimeter monitoring
provides evidence and documents whether there is any chemical agent migration outside
of DCD.
TOCDF Station Numbering and Locations
This Monitoring Plan provides a table of locations and station numbers (Appendix A &
K) for agent monitors associated with TOCDF.
Summarized Requirements
Monitoring Operations monitors for Mustard bulk containers and munition processing
and Mustard, VX and GB secondary waste. There are three configurations employed at
TOCDF: ACAMS only, ACAMS with co-located DAAMS, and DAAMS only.
ACAMS-only stations primarily are used in toxic areas to provide information to
management for protective clothing determination for entries into toxic areas. ACAMS
with co-located DAAMS serve two purposes, 1) the ACAMS is the primary monitor,
which quantifies the amount of agent present. Concurrently, ACAMS provide an early
warning system to plant personnel ofa potential agent release at or above the alarm set
points in Attachment22, Appendix A. The colocated DAAMS are used to confirm or
deny the presence of agent. 2) DAAMS tubes are also analyzed from these stations on a
monthly rotational basis to monitor areas at the WPL. DAAMS only station are used for
historical purposes to monitor areas at the WPL. The DAAMS historical tubes are not
connected to an alarm. Historical DAAMS are located in areas not expecting to have
agent. Response to ACAMS alarms are in accordance with Section 22.35.
RESPONSIBILITIES
The Monitoring group supports TOCDF by operating and maintaining monitoring
equipment and routinely collecting liquid and solid samples in and around the TOCDF
Attachm ent 22 - Page 9
22,3
22.3.1
22.3.2
22.3.2.1
22.3.3
22.3.3.1
223.4
22.3.4.1
22.4
22.4.7
22.5
22.s.1
TOCDF
Agent Monitoring Plan
plant. Monitoring personnel may designate the sampling duties to a trained sample
technician. The Monitoring Department utilizes a variety of monitoring equipment.
Much of the equipment is Government Furnished Property (GFP), which is augmented by
equipment, and supplies that are obtained from commercial vendors. Liquid and solid
samples will be delivered to the Chemical Assessment Laboratory (CAL) for analysis.
The analytical department personnel are responsible for performing the analysis or
transferring the samples requiring analysis to a Utah certified subcontractor laboratory.
Laboratory Quality Control personnel are responsible for inspecting and auditing all
Laboratory (analytical and monitoring) operations.
COORDINATION
There are several levels of coordination performed by within the Monitoring Department.
Other than normal working relationships within the plant and at the CAL, there are three
supervisory levels.
Monitoring Manager
The Monitoring Manager coordinates additions or deletions of the workload such as new
sampling or monitoring requirements. S/tre will be the control point for any changes in
monitoring or sampling parameters such as changes of sampling times or sample flows.
Monitoring Operations Supervisor
The Monitoring Operations Supervisor works directly for the Monitoring Manager and
coordinates the work load with the Team Leaders of all shifts. The supervisor will
coordinate the timing of special monitoring and sampling operations with the Operations
Supervisor and Plant Shift Manager.
Monitoring Team Leader
The Monitoring Team Leader for each shift will coordinate the timing of routine
monitoring and sampling operations with the Control Room (CON) personnel. This
coordination is specified in the applicable Laboratory Operating Procedures (LOPs). The
Team Leader or designated certified monitoring technician and at least one team member
will respond to aII ACAMS alarms in accordance with approved monitoring procedures
and will be in direct contact with the Control Room.
OBJECTIVES OF THE MONITORING PLAN
The Monitoring Plan provides identification of monitoring devices and sampling
locations. The monitors are used to provide agent detection and measurement to aid in
providing worker and general population protection, and to indicate plant operations are
in control.
AGENT MONITORING ACTIVITIES
Monitoring activities are structured to support toxic operations. Maintenance and QC
activities for ACAMS are scheduled during times that do not interfere with plant
operations. This is done by obtaining permission from the Control Room before any
monitor or sampling device is taken out of service. The DAAMS is used for the
collection of samples of agent for confirmation of ACAMS alarms and as primary
monitoring in areas not monitored with ACAMS. The monitors listed in the Appendices
must be operational when performing the operations they support except when oflline
for challenging and corrective actions, as documented in approved procedures or
monitoring has been suspended in accordance with this plan.
Attachrn ent 22 - Page l0
TOCDF
Agent Monitoring Plan
22.6 TOCDX'PLAIIT MONITORINGACTTVITIES
22.6.1 In the dernilitarization plant area, hazard category classifications and personnel
occupancy are the factors used to determine monitoring activities. When monitoring is
conducted for personnel protection or to assess potential personnel exposure it must be
sufficient to identiff, veriff, and quantify the agent. VSL and WPL monitoring is
performed in areas of the facility where workers may have a potential exposure to
chemical warfare agent. Selected "C" hazard category areas of the plant have WPL
monitoring conducted on a daily basis for all work areas where chemical agent is present
without secondary vapor containment and workers are not required to wear respirator
protection, while other "C" hazard category areas have WPL monitoring conducted on a
monthly basis in accordance with this plan.
22.7 CATEGORMS OF'PLAIIT AREAS
22.7.1 Toxic and Process Areas
22.7.1.I These areas are potentially contaminated as a result of the presence of uncontained liquid
agent or agent vapor. An example is the Munitions Processing Bay (MPB). This area is
monitored using an ACAMS. The agent concentrations determine the Personnel
Protective Equipment (PPE) that is required for personnel entry. At times, the
monitoring may be enhanced to allow the PPE for specific toxic areas to be reduced to
enhance worker mobility. This requires Safety Manager approval. This could include
changing the ACAMS to a more sensitive detection level or adding DAAMS in order to
confirm or deny an ACAMS alarm. Toxic Area ACAMS are used to quantify potential
exposure ofpersonnel.
22.7.2 Toxic Process Area Airlocks
22.7.2.1 Airlocks serve as access/egress points between contaminated areas and clean work areas.
To limit the transfer of agent from "toxic" areas to "work areas", under normal
conditions, items and personnel are cleared through an airlock. Procedures govern egress
through airlocks to prevent items or personnel from exiting toxic areas until they have
been monitored by an ACAMS. Agent readings must be less than the level set by egress
procedures to clear items and personnel from the airlock.
22.7.3 Outside of Toxic Process Areas
22.7.3.1 The Unpack Area (UPA) is an area where agent vapor is not normally expected, but a
potential exists for low-level vapor cgntaryungli-o_n. This area is considered as "under
engineering control" and is monitored at the VSL and WPL level daily.
22.7.3.2 Observation corridors are hallways that run adjacent to toxic areas. The corridors are
considered to be "under engineering controls" and are monitored at the VSL daily and at
the WPL level at least monthly.
22.7.4 Work Areas
22.7.4.1 At the TOCDF site, there are many work areas where toxic operations are not conducted.
These areas are not "under engineering control" and have little or no potential for vapor
contamination. These areas are not monitored for agent. Inside the MDB, examples of
work areas include the Chiller Room, Electrical Rooms, Battery Room, Switchgear
Room, and UPS Rooms. Examples of work areas outside the MDB include the PUB and
warehouses.
22.7.5 Lunch Rooms
22.7.5.1 Lunch Rooms inside process areas require WPL monitoring. This is a safety requirement
to verify that workers have not carried contamination into these areas.
Attachrnent 22 - Page I I
22.7.6
22.7.6.1
22.8
22.8.1
22.8.1.1
22.8.1 .2
22.8.1.3
22.8.1 .4
22.8.2
22.8.3
TOCDF
Agent Monitoring Plan
October 2009
Positive Pressure Areas
These are areas in which there are no agent operations and no potential for vapor
contamination. These areas are maintained at a positive pressure with carbon filtered air.
This allows personnel in these'areas to perform without the need of a mask or protective
clothing, if an upset agent conditions existed outside of engineering controls. Examples
of these areas are the Control Room (COI.{), and DPE Support Area (DSA). Monitoring
is not required in these areas.
FILTER MONITORING
Multiple Bank Carbon Filter units provide negative pressure ventilation for potentially
contaminated areas throughout the plant. A description of the Munitions Demilitarization
Building (MDB) ventilation carbon filters is located in Attachment 5 (Inspection Plan),
Paragraph 5.9. Filter monitoring is performed at the VSL level in order to detect
evidence of filter degradation in order to allow changing of the filter media before there
is a possibility of an agent leak to the atmosphere.
The MDB IIVAC filter stack shall be monitored with ACAMS and DAAMS for any
agents being processed in the furnaces. Additionally, on the MDB stack, only DAAMS
tubes shall be required to monitor for agents from past campaigns, if the contaminated
charcoal has been removed after the completion date of the campaign. If the first three
filters are not changed out after an agent campaign, then the MDB IryAC stack shall be
monitored with ACAMS and DAAMS for agents from these past campaigns. Filter stack
DAAMS samples, shall be collected and analyzed every 12 hours. ln addition, HVAC
DAAMS tubes shall be collected and analyzed if an associated ACAMS goes into an
alarm.
The MDB HVAC filter mid-bed locationi shall be monitored continuously with DAAMS
for any agents being processed in the facility (filter online or offline). Sample stream
switches shall be used to allow one or more ACAMS to monitor the mid-beds,
alternately, for any agents being processed in the plpnt (filter online or offline). Locations
of the midbed ACAMS and DAAMS tubes are specified in Attachment 22, Appendix A.
DAAMS tubes monitoring the midbeds or vestibule shall be analyzed if the midbed
ACAMS goes into alarm.
The CAL filter stack shall be monitored with ACAMS and DAAMS for Mustard, GB and
VX. The tubes shall be collected andanalyzed when an associated ACAMS goes into
alarm.
The CAL DAAMS tubes, located in the midbeds (Attachment22, Appendix A), shall
monitor for GB, VX and Mustard and shall be analyzed daily.
If a confirmed ACAMS agent reading on the mid-beds reaches 3 VSL or any agent being
monitored, the change-out of the filters shall coflrmence as specified in Module X.
The Area 10 Igloo Carbon Adsorption Filtration System (101 and 102, are located
adjacent to Igloos 1631 and 1632, and supports secondary waste treatment (i.e., autoclave
and DVS/DVSSR) operations in DCD Igloo 163 I and 1632.
Carbon Adsorption Filtration Systems 101 or 102 shall continuously monitor for agent, in
accordance with Appendix A, at the midbeds and exhaust stack for whichever filter is on-
line. Monitoring consists of: 1) ACAMS/DAAMS (0.5VSL) between the first and
second carbon bed, and 2) AcAMs/Confirmation DAAMS, at the common exhaust stack
22.8.3.1
Attachrnent 22 - Page 12
22.8.3.2
22.8.3.3
22.9
229.1
22.10
22.10.1
22.11
22.11.1
22.11 .1 .1
TOCDF
Agent Monitoring Plan
for both Filters 101 and 102. Monitoring is performed at the 0.5 VSL level in order to
detect evidence offilter degradation or agent breakthrough to allow change-out ofthe
filter media before there is a possibility of an agent release to the atmosphere.
The on-line Area 10 Filter midbed locations (i.e., primary filter and backup filter) shall
have the DAAMS-sampled and analyzed daily.
Agent monitoring is required for past agent campaigns in the stack and midbeds for the
Area 10 Igloo Carbon Adsorption Filtration Systems until the carbon filters have been
replaced.
SAMPLING PARAMETERS
The operational control limits for sampling parameters such as sample flow rate and
duration of sample time are under configuration control and documented in precision and
accuracy studies before "Base Line" monitoring is performed and can only be changed by
the Monitoring Manager following approved procedures.
DATA HANDLING
Monitoring parameters, such as flow rates and sample collection start and end times are
recorded and accompany the sample to the laboratory. Comments pertaining to
equipment malfunction (such as failure to sequence) are currently recorded in logbooks at
each station and the information transferred to and maintained in a database. Before
eliminating ACAMS and DAAMS station logbooks, the TOCDF must demonstrate to the
Executive Secretary that the electronic recording and data retrieval system performs such
that all pertinent information is readily retrievable (written approval from Executive
Secretary required). Sample problems are also armotated with pertinent information. This
information is used to identify the need for corrective action to prevent recurring
deficiencies. The corrective action may consist of such things as additional training or
changing the types of preventive maintenance for particular types of equipment. All raw
data from ACAMS, including calibrations and challenges, (except those at the CAL and
some areas in the plant as noted in the Table in Appendix A) are gathered on the Process
Data Acquisition and Reporting System (PDARS) in the Control Room and maintained in
a database. The ACAMS strip-chart is used to evaluate agent concentration and alarm
cycle time.
QUALITY CONTROL
TOCDF QM (Quality Management) Program
Confidence in sampling methods that characterize actual ambient concentrations of agent
in a given matrix is of utmost importance. An extensive QA Program is required to
ensrue the quality of monitoring data is adequate for its intended use. The programmatic
Laboratory and Monitoring Quality Assurance Plan (LMQAP) and the Monitoring
Concept Plan (MCP) are guidance documents for all laboratories supporting agent
demilitarization operations. The TOCDF Laboratory Quality Control Plan (LQCP) and
the TOCDF Agent Monitoring Plan (AMP) were prepared in accordance with the
requirements of the LMQAP and MCP. The TOCDF LQCP and TOCDF AMP
(Attachment 22) must be at least as stringent as the programmatic guidance.
f,'ailure To Monitor22.11.2
Attachm ent 22 - Page 13
22.11 .2.1
22.1r.2.2
22.11 .2.3
22.11 .2.4
22.11 .2.5
22.12
22.12.1 .1
22.12.2
22.12.3
22.12.4
TOCDF
Agent Monitoring Plan
All of the monitoring identified in this plan must be operating and in control during
processing in a given area or it will be considered a'Missed Monitoring" and will be
reported as such. The following are exceptions:
During campaign changeover transition periods when monitors are being changed to a
new agent campaign.
When a Temporary Change has been approved (see Paragraph22.l5.3\.
If the ACAMS is olfline for more than one and a half hours, the DAAMS becomes the
primary monitor and therefore must be analyzed. This does not apply to the IIVAC
stack, common stack or ducts.
If mitigating measures have been taken to secure an area and processing has ceased, then
monitoring at that station will not be considered a "missed monitoring." This does not
apply to the IIVAC stack, common stack or ducts.
NOTIFICATION PROCEDI]RES
The PDARS in the Control Room collects data from each ACAMS and stores the
readings in a temporary computer file. A computer in the Control Room uses this file to
access agent readings from each ACAMS. These readings may be displayed on demand
in the Control Room and at the MSB. The ACAMS shall alarm at each location when
detected agent concentrations meets or exceed the alarm set points. ACAMS that
monitor toxic areas under engineering control may not have a local alarm. (See Section
22.28) This is because the ACAMS would be constantly in alarm.
In the event of an ACAMS alarming at or above the alarm level, outside of engineering
controls, or in category "C" areas or at the CAL, the Control Room will notify the
Monitoring Team Leader or designee. The Team Leader or designated certified
monitoring technician along with one other Monitoring person will respond by going to
the location of the ACAMS that is in alarm. Monitoring personnel evaluate alarms by
observing the chromatogram and troubleshooting for malfunctions, verifying the alarm
level set point, challenging an ACAMS with an agent standard to ensure that it is
operating correctly, and collecting the associated DAAMS tubes for analysis. The Alarm
Response Requirements are specified in Section22.35. If the alarm is confirmed by
DAAMS, appropriate corrective measures are taken as specified in Attachment 3,
(TOCDF LQCP). When it is believed that the area has been cleaned, the area monitor
will determine if the corrective measure was adequate. If results are less than the alarm
level set point, normal operations may commence.
The Control Room (CON) shall monitor the CAL ACAMS alarms and shall notifu
Monitoring per the requirements of Paragraph22.12.2. If the CAL has an alarm, neat
agent operations at the CAL shall be suspended. If the alarm causes TOCDF to fail to
meet LCO requirements, waste feed shall cease for all furnaces at TOCDF.
All ACAMS alarms, which have co-located DAAMS, require analysis of the DAAMS
tube(s). In addition, all alarms at the common stack will require that the DAAMS tubes
be pulled and analyzed on all operating furnace ducts. The analytical results of the
DAAMS tubes, pulled due to an ACAMS alarm, shall be reported to the CON. The CAL
will maintain the official record of all DAAMS results.
Attachrnent 22 - Page l4
O
22.13
22.13.1
22.14
22.t4.1
22.15
22.15.1
22.1 5.1 .1
22.15.2
22.15.2.1
22,15.3
22.t5.3.1
22.15.4
22.t5.4.1
22.16
22.16.1
22.1 6.1 .1
TOCDFo'*'H:"#x,,'.,;;
CONTROL LIMITS FOR ACAMS
AIl ACAMS that monitor the common stack and any VX ACAMS located in the ducts
shall be challenged every 4 hours plus or minus 30 minutes in accordance with TE-LOP-
524. All other duct ACAMS shall be challenged daily. The ACAMS challenge results
are collected electronically for all plant ACAMS connected to PDARS. The data for the
CAL ACAMS and ACAMS not connected to PDARS are recorded manually and then
archived. These data are used to assess the performance of individual units and the
performance of the overall monitoring system. The TOCDF LQCP details the pass/fail
criteria. The performance of th6 ACAMS is tracked daily and any ACAMS that falls into
the fail category is corrected or replaced.
MONITOR/IVIONITORING LOCATIONS
The monitors within the TOCDF site were placed in locations to maintain minimum
distances to the actual sampling point while keeping the equipment out of hazardous
areas. For the actual monitoring locations at TOCDF, see Appendix A and the associated
drawings.
MONITORING PLAI\
List of Monitors
Appendix A outlines the monitoring stations for operations of the TOCDF site except for
the perimeter monitors. The perimeter monitoring is the responsibility of CAMDS.
LIMITING CONDITIONS OF OPERATION (LCOs)
The monitors identified for a given campaign must be operating at all times and are
considered to be Limiting Conditions of Operations (LCOs). In the event that a monitor
is not capable of operating, immediate corrective actions will be taken. (See Paragraph
22.1s.3).
Temporary Changes
Temporary changes may be made to the requirements of this plan by following the
normal TOCDF procedures, which provide proper approvals and documentation. This
will allow for adding to, reducing the number of, or changing the configuration of agent
monitors on a temporary basis. The Permittee shall notiff the Executive Secretary orally
of any reduced monitoring applicable to this Attachment prior to implementation.
Additional Support
Occasionally support from DCD or CAMDS is required for additional monitoring
support. This may include the use of Real Time Analytical Platform (RTAPs) for
increased area monitoring, or an upset condition, and the operation of DAiAlv{S station
GPLOOI.
MONITORING STRATEGY
Worker Population Limit (WPL) Monitoring
Worker Population Limit (WPL) monitoring will be performed with DAAMS. The WPL
monitoring is conducted daily for all work areas where chemical agent is present without
secondary vapor containment and workers are not required to wear respirator protebtion.
Also, the Category C areas where agent is not present are monitored on a monthly basis.
Attachrnent 22 - Page l5
22.16.2
22.16.2.1
22.16.2.2
22.16.2.3.
22.16.4
22.16.4.1
22.16.5
TOCDF
Agent Monitoring Plan
Short Term Exposure Limit (STEL) and Vapor Screening Limit (VSL) Monitoring
VSL monitoring will be performed at all workplace locations as specified in Appendix A.
DAAMS will be used to confirm a VSL exceedance, except for bagged items incoming
air will be minimized to prevent dilution of sample when clearing bagged items. The
filter stacks use the VSL monitoring limit on the ACAMS itsell but any confirmed
release will be reported in a concentration (mg/m3).
STEL and VSL are equivalent in terms of concentration values, but are different in that
STEL is based on a 15 minute time-weighted average and that VSL is independent of
time.
Source Emission Limit (SEL)
SEL is a ceiling value that serves as a source emission limit, and not as a health standard.
It is used for monitoring the furnace ducts, and common stacks. Staggered ACAMS
which monitor continuously are required on the cofirmon stack for each agent being
processed. DAAMS are used as confirmation for any ACAMS alarms above the alarm
level. A Waste Feed Cutoff for all incinerators/furnaces is initiated when an alarm at or
above the alarm level is exceeded at the common stack. The incinerator/furnace ducts
shall be monitored with ACAMS and DAAMS for any agent being processed. When the
primary ACAMS are undergoing calibration or maintenance a standby ACAMS shall be
monitoring the ducts for the agent being processed.
AEL LEVELS
Attachrn ent 22 - Page I 6
22.16.6
22.16.6.0
22.16.6.1
22.17
22.19.1
22,17.1
22.17 .1 .1
TOCDF
Agent Monito.ing Plan
October 2009
G-agents mg/m'VX mg/m3 H-agents mdm3
STEL
(15-Minutes)
0.0001 0.00001 0.003
WPL'
(12-Hours)
0.00002 0.0000006 0.00027
WPL2
(B-Hours)
0.00003 0.000001 0.0004
WPL2
(4-Hours)
0.00006 0.000002 0.0008
SEL 0.0003 0.0003 0.03
IDLH
(30-Minutes)
0.1 0.003 0.7
VSL 0.0001 0.00001 0.003
Notes:
' The l2-hour WPL monitoring level will be used for routine historical
monitoring and for areas where munitions are stored outside of secondary
containment (UPA).
'The S-hour monitoring level will be used for LSS air monitoring
irregardless of actual sample time. The 4-hour monitoring level is used only
for VX if the detection limit can not be achieve due to interferences
Monitoring Cessation
Confirmation monitoring may be suspended once agent has been confirmed to be present
(NRT-only monitoring will be required to verify effectiveness of corrective actions).
Once corrective actions have been resolved, confirmation monitoring shall be re-
instituted. Any ACAMS alarm, without co-located DAAMS, is assumed to be agent.
Agent specific monitoring may be halted if no corresponding waste is inside the facility
boundaries. Once an agent waste enters the facility boundaries, monitoring must be
reinstated for that agent in locations specified in Appendix A. This condition does not
apply to the TIVAC [Area 10 (Igloos 1631 and 1632) (and Ci\L)] stack.
MONITORING EQUIPMENT
The following is a discourse of the types of equipment used for agent monitoring: '
ACAMS
The ACAMS is a near-real-time monitor system with the ability to detect and report the
concentration levels of chemical agent in the air at either low levels or high levels
depending on its monitoring configuration. The ACAMS is configured for the
appropriate detection level and the current agent(s) locations. The ACAMS is equipped
with remote, audible, and visible alarm systems. The ACAMS samples air during a
Attachm ent 22 - Page I 7
TOCDF
dgent Monitoring Plan
preset sample period. Agent present in the sample air stream is collected on a solid
sorbent bed during the sample period for gas chromatographic (GC) analysis. The results
of the GC analysis of the sampled air are displayed on the front panel of the instrument.
A permanent record of the chromatogram and the agent concentration is recorded on a
strip-chart. The ACAMS produces an audible and visible alarm when the agent
concentration level is at or above the preset alarm level. The PDARS records the alarm
time and agent concentration. In the case of the common stack and furnace duct
ACAMS; the chromatogram is also recorded by the PDARS. The ACAMS are used to
detect process upsets and are located in areas where concentrations ofagents are of
concern or where rapid response is required to allow personnel to work in lower levels of
protective dress.
22.17.1.3 Process areas where high concentrations of agents are possible, a Low-Volume Sampler
(LVS) may be utilized. The LVX operates in a toxic or process area by drawing air
through the LVS, retaining a l-ml sample. It then sends that 1-ml sample to the ACAMS,
which analyzes it and reports the actual agent concentration of the area being sampled.
This process is necessary to prevent saturating the ACAMS.
22.17.2 DAAMS
22.17.2.1 An additional monitoring system used is the DAAMS. DAAMS involve passing sampled
air through a sorbent bed where any agent would be collected. The sample periods are
determined by P&A study results and will be in the range of three minutes to twelve
hours. DAAMS analysis is performed using a Class 1 quantitative method. However,
when DAAMS are used in conjunction with an ACAMS, the results are used to confirm
or refute the presence of agent. If an ACAMS is not monitoring correctly, the DAAMS
tubes become the primary monitor and must be collected andanalyzed. DAAMS
samples provide independent confirmation of positive ACAMS readings and a historical
record of monitoring, in areas not monitored by ACAMS, at the WPL and GPL locations.
22.17.2.t.1 DAAMS tubes shall use a bar code system to track the specific station and agent of each
tube. All confirmed DAAMS results, greater than the reporting limit (RL), shall be
reported to the control room immediately. All confirmed sub-Rl levels shall be tracked
and trended by the laboratory.
22.17.2.1.2 NOxFilters
In order to retain chemical agent Mustard on the DAAMS tube, NO; pre-filters shall be
required for Mustard sample collection. The NOx pre-filters used on the inlet to the
DAAMS tube and shall be used during the entire time of aspiration of the DAAMS
sample. NOx pre-filters will be tested by visually inspecting the nitrogen oxides pre-filter
for cracks, packing separation, and other physical defects. All Mustard sample line
challenges shall be completed through the NO1 filter. Mustard pre-filters are not
required for ACAMS due to the short duration of the sample time.
22.17.2.1.3 NOx pre-filters shall be replaced on the common stack and duct monitoring
instrumentation daily (24 hours + 4 hours). All other NO1 pre-filters shall be replaced at
a frequency not to exceed 14 days.
22.17.3 Sample Lines.
22.17 .3 .l The agent sampling lines are heated to aid in the transmission of the sample. Appendices
C&D show the configuration of the sampling assembly. They consist of Teflon sample
line with self-regulating heat tape. Sample lines for stations MED 904V and MED 904G
are not required to be heated. These ACAMS and DAAMS sample lines shall be
challenged at the end of the sample line every 60 days * 3 days. All other ACAM
Attachm ent 22 - Page l8
22.1'7.3.2
22.17 .3.3
22,17.4
22,17.4.1
22.17.4.2
22.IJ.4.3
22.17.5
22.17 .5.1
22.t7 .5.2
TOCDF
Agent Monitoring Plan
challenges for these stations (MED 904V and MED 904G) may be performed at the
ACAMS. Other sample lines may not be heat traced as long as all challenges are
performed at the end of the sample line. In these cases the line is challenged with agent
to prove transmission of the agent down the sample line.
All sample lines must be challenged and demonstrate transmission efficiency prior to the
commencement of operations. After the completion of the initial sample line challenge,
all non-toxic sample lines must be challenged at least every 60 days * 3 days.
Samples lines in toxic areas are challenged during campaign changeover.
Sample Lines (Suffixed with "S")
Monitoring stations whose station number is suffixed by an "S" (spool) are to be used for
special or short term monitoring only. The purpose of the "S" stations is to allow
monitoring in specific locations that do not have a regularly assigned ACAMS. The
station equipment consists of a sample line only.
When the monitoring is performed, an adjacent ACAMS will be connected to the "S"
sample line. In some cases the lines are arranged on a spool to allow it to be reeled out
and moved to the point that needs sampling. The ACAMS that are used in conjunction
with the "S" sample lines have switches (or PDARS software) that designates the station
in use. The purpose of the switch is to identify the correct monitoring location to
PDARS. This causes the ACAMS data to be cataloged to the correct sampling point and
therefore provide accurate traceability of monitoring results.
During the time the ACAMS is connected to the spool sample line, the DAAMS that
was associated with the original ACAMS becomes the primary monitor for that location.
This means that the DAAMS tubes must be analyzed, rather than serving the function of
being confirmation DAAMS that only get analyzed in the event of an ACAMS alarm.
Additionally, if the ACAMS alarms while corurected to the spool, there are no DAAMS
tubes to serve the confirmation function. If there are readings on the ACAMS while it is
in the spool mode, it must be assumed to be agent. For "S" designated stations at Area
10, the DAAMS will follow the ACAMS when spooled.
Silver tr'luoride Pads
There are six styles or types of /V/G conversion pad assemblies for use with VX ACAMS
and DAAMS stations when TOCDF is processing VX waste. They are designed to place
the conversion pads in the sample stream such that the pads are exposed to the sample
stream and be capable of converting a quantifiable amount of VX to the G-analog of VX.
Without the conversion, the monitoring equipment will not detect VX. All assemblies
will contain at least two V/G Conversion pads held in place close to the sample input
path. Additional pads do not aid or hinder the conversion efficiency. A detailed
description of each type is located in TE-LOP-528,Y|G Conversion Pad Assembly.
In order for VX to transfer down a monitoring sample line, the compound must be
converted to a more volatile compound; G-analog which is a derivative of VX that
closely resembles GB. To facilitate this conversion, two silver fluoride impregnated
pads, or V /G pads are used.
The stack and duct ACAMS/DAAMS conversion pads shall be replaced every 4 hours
plus or minus 30 minutes. The pads shall be challenged before replacement, so that the
conversion pads that have been in service are part ofthe challenge to ensure adequate
22,17 .5.3
Attachm ent 22 - Page I 9
22.17 .5.4
22.17 .5.5
22.t7 .5.6
22.17 .5.7
22.17.5.8
22.17 .5.9
22.18
22.1 8.1
22.1.8,2
22.18.2.1
22.19.3
22.1 8.3. I
TOCDF
Agent Monitoring Plan
transfer. If the pads challenge is outside 75-125% recovery, qualification of data is
required.
During VX secondary waste processing, the toxic area ACAMS conversion pads shall be
changed each time a toxic entry team enters into an area monitored by the toxic area
ACAMS. One exception to this requirement would be if the team re-enters an area and
the conversion pads had been previously changed during their entry.
During VX secondary waste processing, all non-toxic area VSL ACAMS and DAAMS
conversion pads shall be changed daily. The ACAMS are challenged daily. The sample
line is challenged at the distal end at a minimum of every 60 days + 3 days.
The Filter midbed, and Filter Vestibule ACAMS may be challenged at the ACAMS
instead of the distal end of the sample probe if the agent concentration was below 1.0
VSL for each agent reading. The conversion pads must be changed at a minimum of
every 28 days for agent readings less than 1.0 VSL and weekly if each agent reading
were at or above 1.0 VSL for VX.
Test data must be submitted and approved by the Executive Secretary to reduce
monitoring requirements presented above.
All DAAMS conversion pad assemblies shall have the same corresponding change-out
frequency at the monitoring levels specific in22.17.5.3 through 22.17.5.6.
For VX LSS DAAMS Stations, the conversion pads must be changed at a minimum of
every 28 days for agent readings less than 1.0 WPL. The LSS stations are decertified for
use when an agent reading reaches 1.0 WPL or above (22.16.5). If agent is detected at or
above 1.0 WPL see Section 22.21 and22.16.5. Additional requirements for the Life
Support System are defined in paragraph 22.21.
STACK CONFIGT]RATION
Agent monitoring of the furnace stack effluent consists of ACAMS and DAAMS.
ACAMS
There are three ACAMS assigned to monitor the common stack for each agent being
processed.). Two of the ACAMS for each agent are on line constantly. Their operating
cycles are staggered to allow one unit to be in the analysis mode while the other is
sampling, this gives continuous monitoring of the common stack. DAAMS analysis is
used for alarm confirmation. The third ACAMS serves as a standby unit when one of the
other units is off-line for challenging or corrective action. The three ACAMS for each
agent are linked to the PDARS individually. An alarm is sounded in the CON if the
ACAMS cycling does not provide 100% monitoring of the common stack for each agent.
If this occurs, an AWFCO is initiated and DAAMS analysis is required for the period the
ACAMS was not staggered sampling the common Stack.
DAAMS
There are three DAAMS tubes aspirating at all times on each DAAMS manifold. They
are the A tube, a B confirmation tube, and a C contingency tube. A fourth tube, which is
a QP, is also aspirated in accordance with the TOCDF LQCP. The sampling equipment
is designed such that a sample is being collected constantly, even when a set of tubes is
Attachm ent 22 - Page 20
22.18.4
22.1 8.4. 1
22,19
22,19.1
22.t9.1 .1
22,19.2
22.r9.2.t
22,19.3
22.19.3.1
TOCDF
Agent Monitoring Plan
October 2009
being replaced. The stack and furnace duct DAAMS will have a "no-flow" audible alarm
to warn operators when the DAAMS is not operating.
Dilution Air Flow Controllers
Both the ACAMS and DAAMS use dilution airflow controllers. They are designated as
the ACAMS Dilution Air Flow Controller (ADAFC), which is shown in Appendix G and
the DAAMS Dilution Air Flow Controller (DDAFC), which is shown in Appendices E
and F. The purpose of the dilution flow controllers is to inject dry air into the sample
stream to prevent the liquid in the sample from condensing in the sampling equipment,
keeping the sample above the dew point. The dilution flow controllers are designed such
that the flow control device has a feedback signal to a flow meter. This feedback signal
causes the ratio of the sample flow to stay constant once the two are locked together.
Therefore, the unit compensates for any intemrptions in the sample flow and maintains
the correct ratio. The agent concentration in the DAAMS tubes is calculated using the
volume of sample air, not the dilution air. The same theory of operation holds true with
the ACAMS. The ACAMS are calibrated disregarding the quantity of dilution air. The
dilution air can be considered a carrier for the sample. The agent concentration is based
on the volume of the sample. Additionally, the ACAMS has software that allows it to
calculate agent concentrations even when there is a change in the sample flow rate. Since
the flow ratio is controlled by the dilution flow controller and the ACAMS can
compensate for flow changes, the two units in conjunction give accurate agent readings
even when there are sample flow rate changes.
FTJRNACE STACK AND DUCT MONITORING
Calibrating, Challenging, or Servicing
The ACAMS at monitoring duct locations PAS 702 (DFS), PAS 703 (MPF), PAS 704
(LICI), and PAS 705 (LICZ) may be taken off-line during waste feed to challenge,
calibrate, or service for up to one hour each operating day, midnight to midnight,
provided at least two staggered ACAMS monitoring for each agent being processed in
the common stack are on-line. A standby ACAMS is located at each duct location to
avoid exceeding the one-hour limit.
Suspended Monitoring (Furnace Ducts Only)
Monitoring of the furnace ducts leading to the common stack may be suspended, if all
three of the following requirements are met. First, agent feed has been suspended with
the furnace and afterburner continuing at operating temperature for a minimum of one
hour following the end of agent feed. Second, a confirmed agent reading at or above the
alarm set point is absent for a 24-hour period and Standard Operating Procedures (SOPs)
are in place identifying procedures for fumace operation and isolation of contaminated
hardware within the furnace system. Third, the Chemical Materials Agency (CMA) Site
Project Manager or designee approves procedures isolating contaminated materials (e.g.
piping, etc.) from the respective furnace and its PAS. The third condition may not be
applicable if there are no contaminated materials in the fumace system (including the
input airlock to the MPF). Fumace duct monitoring will resume 24 hours before the
agent gun is installed in a LIC, or before waste feed commences in the DFS or MPF.
Suspended Common Stack Monitoring
Common stack monitoring will not be suspended without CMA TOCDF Site Project
Manager or designee and the Executive Secretary approval.
Attachrn ent 22 - Page 2l
22.20
22.20.1
22.20.2
22.21
22.21.1
22.22
22.22.1
22.23.
22.23.1
TOCDF
Agent Monitoring Plan
MONITORING FOR AGENT FROM PAST CAMPAIGNS
Monitoring in Category A and B areas, including LSS Air Monitoring, for past agent
contamination may be discontinued when the airborne agent contamination for that area
is less than 1.0 VSL over a24-hovr period, at a minimum temperature of 70o F, with the
ventilation system operating at the approved flow rates. A confirmed agent reading at or
above 1.0 VSL requires that the area must undergo additional decontamination. LSS
hose monitoring for past agent may be discontinued if the hoses are less than 1.0 WPL.
Monitoring in Category C areas for past agent campaign contamination may be
discontinued when the Category C areahas been less than 0.5 WPl(t2-hour) 15, each agent
being discontinued over a24-how period, , with the adjacent A& B area ventilation
systems operating at the approved flow rates at a minimum temperature of 70oF.
Monitoring data shall be submitted to the Executive Secretary for approval prior to
discontinuation of any agent monitor in a C area.
LIFE SUPPORT SYSTEM (LSS) AIR HOSE MONITORING
The Life Support System (LSS) air hoses are monitored using DAAMS samples. All of
the hoses on a given air manifold are sampled with two DAAMS tubes. The TOCDF
Safety Department evaluates all LSS air analytical data daily for determining the
certification for each LSS air station. The LSS air stations will be decertified for use
when agent is confirmed at or greater than 0.00003 mg/m3 for G agents, 0.000001 mg/m'
for VX, and 0.0004 mg/m3 for H series agent.
ACAMS DATA COLLECTION
Plant ACAMS are integrated into the PDARS. The PDARS stores all readings taken by
each ACAMS to a temporary computer file. From this file, a computer is able to compile
trends from each ACAMS for up to 72 hours and, upon demand, display these trends to
graphics screens in the Control Room and the MSB. Various automated reports are used
to observe these trends to be used as a management tool to make improvements and
determine the level of readiness of the overall ACAMS system. This temporary file is
compressed to an archival file that becomes the permanent record of agent readings.
From the archival file, the computer is able to trend each connected ACAMS for any
desired time period. Results of all ACAMS challenges are electronically recorded and,
additionally, they are manually recorded in the ACAMS logbook (see Section 22.10.1 for
any potential exceptions to manually recorded logbooks) at each instrument. These
results provide a basis for statistical analysis to assess performance and for reporting to
regulatory agencies. The CAL and other areas in the plant as noted in Appendix A do not
have PDARS, therefore, the ACAMS chart recorder and instrument log are used to record
readings and QC data that are then archived.
DAAMS SYSTEM
The DAAMS sampling system is capable of collecting agent GB, GA and VX by use of
Chromosorb and HD with Tenax sorbent beds. The sample is then analyzed using
GC/pPD or with MSD analysis techniques. The total volume of air sampled is calculated
from the sampling time and the sample flow rate. Desorption of the DAAMS tube into a
GC/F'PD for analysis provides the total mass of agent collected. The average air
concentration of agent is then calculated from this data. By increasing the sample time or
Attachm ent 22 - Page 22
22.24
22.24.1
22,25
22.25.1
22.26
22.26.1
22.27
22.27.1
22.28
22.28.1
22.29
22.29.1
TMf,F'
Agerf NftnitcingPlal
October 2009
flow rate, the average concentration sensitivity can be increased. DAAMS stations shall
report agent concentration at or above their calculated reporting limit for the agent of
interest. The lowest calibration standard used for analysis must be at or below the
reporting limit.
BACKT]P EQTIIPMENT
The function of the ACAMS is to rapidly detect agent. Should a needed instrument fail
the first response is to troubleshoot and repair it in place. Should the estimated repair
time be excessive (as determined by the CON) the ACAMS will be replaced with an
ACAMS fromthe contingency stock.
MAINTENANCE
The Monitoring Technicians and Instrument Technicians have completed mandatory
ACAMS training at the Chemical DemilitarizationTraining Facility (CDTF) and are
qualified to maintain and operate ACAMS. The manufacturer's manuals and LOPs
provide necessary guidance.
START UP OF'MONITORING
Agent monitoring in the TOCDF plant and the CAL will be initiated in each area as
needed. A Monitoring Plan for each campaign must have approval from the CMA
TOCDF Site Project Manager or Designee. The monitoring identified in the "campaign
specific" plan will be started in sufficient time to allow baseline data collection. The
operational readiness review (ORR) for the campaign shall include review of the plan and
the baseline data. The information in this plan is the basis for all campaign specific
plans.
SPECTAL ON-SITE CONTAINER (ONC) MONTTORTNG
Special monitoring shall be required whenever an On-Site Container (ONC) or over
pack-containing agent has remained in the Container Handling Building (CHB) for more
than seven days. The interior of the ONC or over pack will be monitored with a DAAMS
or ACAMS. The determination of which to use is based on equipment availability and
how fast the results are needed.
ACAMS ALARM HORN
There are cases where ACAMS have an alarm in the Control Room but there is no 1ocal
alarm. This is a safety measure. There are areas that have frequent alarms but it does not
mean that the workers in the area must mask. It is important that the workers do not
become accustomed to ignoring ACAMS alarms. Some examples are: Toxic Area
ACAMS and airlock ACAMS. In all of these cases an alarm does not indicate that the
people in the location of the ACAMS need to mask. ACAMS that have the hom
disconnected must have a sign at the ACAMS indicating such.
ACAMS ALARM LEVEL
The set point for the ACAMS agent alarms is specified in the monitoring station tables
(Attachment A). Due to the design characteristics of the ACAMS and the software that
operates the alarm, there may be slight variations in the actual alarm level for each
ACAMS.
Attachm ent 22 - Page 23
22,30
22.30.1
22.31
22.3 1 .1
22.32
22.32.1
22.32.2
22.32.3
22.32.4
22.32.5
22.32.6
22.32.7
22.32.8
22.33
22.33.7
22.34
-22.34.1
TOCDF
Agent Monitoring Plan
October 2009
PORTABLE ACAMS and DAAMS MONITORING TRAILERS
There are a minimum of two Portable Monitoring Trailers housing ACAMS and DAAMS
at TOCDF. They are for special short-term monitoring to support short-term activities.
CARBON FILTERS ON ACAMS
In special circumstances, an ACAMS purpose is not to provide monitoring on a
continuous basis (e.g. ACAMS for monitoring ONCs, and ACAMS for monitoring
charcoal change-out at the Filter Farm.) When these types of ACAMS are operating but
not sampling the area for which they are intended, a charcoal filter may be installed at the
ACAMS.
MPF DISCHARGE AIRLOCK (MPr DAL) ACAMS and DAAMS
The ACAMS for the MPF Discharge Airlock samples filtered air except when monitoring
the discharge airlock. Low-temperature monitoring protocol requires the DAL to be
cooled to less than 600o F prior to agent monitoring for GB and VX wastes or 700o F for
mustard wastes, munitions, and bulk containers. High-temperature monitoring is defined
as greater than or equal to 700'F for mustard munitions and bulk containers.
All secondary wastes that are processed are monitored via low-temperature monitoring.
During monitoring, if the ACAMS alarms, the item is moved back into Zone 3 for
additional processing time for a minimum of 15 minutes.
The Permittee has the option to perform low-temperature monitoring instead of high
temperature monitoring on any munitions or bulk container.
If processing VX secondary waste the V/G conversion pad assernblies for both the
ACAMS and DAAMS will be changed prior to monitoring each tray. Sample line
challenges will be performed at 1.0 VSL at a minimum of once every l2-hour operating
shift, within four hours from the start of the shift while processing for both ACAMS and
DA]A]VIS.
Reserved.
Reserved.
MPF DAL maintenance of the sampling systems shall follow the procedure in
Attachment 3 (Sampling, Analytical and QA/QC Procedures) for the ACAMS and
DAAMS systems.
ACAMS and DAAMS AT EQUIPMENT IIYDRAULIC MODULE
The ACAMS and DAAMS at the Equipment Hydraulic Module (EHM) Station #EHM
354, only monitors the EHM when personnel are inside the EHM. An alarm light is
installed inside the EHM for personnel safety. If the ACAMS and DAAMS are offline or
are online but not sampling air from the EHM, the alarm light shall be on. Personnel
shall be denied entry into the EHM until the ACAMS and DAAMS are online sampling
air from the EHM.
FUGITTVE EMISSIONS MONITORING
If a leak is discovered in any equipment in an agent processing area at TOCDF, that leak
shall be monitored for agent using an ACAMS. The method used for this monitoring will
be a modified Method 27 from4O CFR, Part 60 using an ACAMS for agent.
Attachm ent 22 - Page 24
TOCDF
Agent Monitoring Plan
October 2009
Method Requirements TOCDF Capabilities Mitigation/
Justification
A portable or area instrument will be used to
monitor leaks for Volatile Organic
Compounds (VOCs)
The area ACAMS will be used or
a portable monitor that is
configured for the specific VOC
(agent).
N/A
The VOC instrument detector shall respond
to the compounds being processed, and both
the linear response range and measurable
range of the instrument shall encompass the
leak concentration.
The ACAMS meets this criterior,
being calibrated with the
compound of interest.
N/A
The scale of the instrument meter shall be
readable to +l- 2.5oA of the specified leak
definition concentration when performing a
no detectable emission survey.
The ACAMS meter readout is
digital, so the concentration is
displayed with easy to read
nurnbers.
N/A
The instrument shall be equipped with an
electrically driven pump to insure that a
sample is provided to the detector at a
constant flow rate. The rate will be 0.10 to
3.0 LPM, measured at the probe tip.
The ACAMS complies with this
requirement, with a norrnal flow
rate of 0.40 to 1.OLPM.
N/A
The instruments shall be intrinsically safe, os
defined by U.S.A. standards for use in any
explosive atmospheres that may be
encountered in its use.
The ACAMS sample line meets
this requirement since the
ACAMS unit is not inside the
explosive environment.
N/A
The instrument shall be equipped with a
probe or probe extension for sampling not to
exceed % tnch outside diameter, with a single
opening for admission of a sample.
The ACAMS meets this
requirement % tnch outside
diameter is the standard for
ACAMS sample lines and probes.
N/A
The instrument response factors for the VOC
to be measured shall be less than 10. The
response factor is the ratio of the known
concentration of a VOC compound to the
observed meter reading when measured
using an instrument calibrated with the
specifi ed reference compound.
The ACAMS meets this criterion.N/A
The instrument response time shall be equal
to or less than 30 seconds, with all sampling
equipment connected and operating.
The ACAMS does not meet this
criterion. But, this is a special
application, sampling for a
specific compound.
The ACAMS is
the best available
technology for
agent sampling.
Since the ACAMS
must collect a
sample before
analysis, the 5-
minute response
time is as fast as
TOCDF can get,
while still
Attachrnent 22 - Page 25
Method Requirements TOCDF Capabilities Mitigation/
Justification
maintaining
accurate results.
The calibration precision must be equal to or
less than 1 0 percent of the calibration gas
value.
The ACAMS meets this criterioo,
except that the ACAMS uses a
liquid calibration standard. By
TOCDF procedure the calibration
challenge must be +l- l0 % of the
target value.
N/A
22,35
22,35.1
22.35.1 .1
22.35.2
22.35.2.1
22.35.3
22.35.3.1
22.3s.3.2
22.35.4
22.35.4.1
TOCDF
Agent Monito.ing Plan
October 2009
NOTE
The challenge, calibration and operation of the ACAMS will comply with TOCDF
Laboratory Operating Procedure (LOP) 524 in Attachment 3 (Sampling and
Analytical Procedures) and this Attachment.
ALARM RESPONSE REQUIREMENTS
Common StackAlarm for Mustard. VX or GB
If the ACAMS alarms at or above 0.2 SEL for any agent a RCRA Automatic Waste Feed
Cut-Off (AWFCO) shall be initiated for all fumaces/incinerators. Monitoring personnel
shall be deployed. DAAMS tubes shall be pulled andanalyzed on the stack and ducts of
all operating fumaces/incinerators. Alarm levels for agents from past campaigns are
listed in Appendix A.
Duct (MPF/DFS/LICItLlcz) Alarms for Mustard, VX or GB
If the ACAMS alarms at or above 0.2 SEL for GB or Mustard or 0.5 SEL for VX, a
RCRrA,r{WFCO for that furnace/incinerator shall be initiated. Monitoring personnel shall
be deployed to investigate the alarm. The duct DAAMS tubes shall be pulled and
analyzed ifany alarm at or above the alarm set point for the agents being processed.
IfVAC Stack Alarm for Mustard, VX or GB
If the ACAMS, monitoring the TIVAC stack, alarms at or above the agent alarm set point
the. Monitoring personnel shall be deployed. DAAMS tubes shall be pulled and
analyzed.
If agent is confirmed, no additional agent may be brought into the plant without
Executive Secretary approval.
Workplace Monitoring for Mustard, VX and GB (Categories C and D Areas)
If the ACAMS indicates (in CON) that the agent level is at or above the action level of
0.2 VSL then the CON shall notify Monitoring and Monitoring shall respond and verify
ACAMS operation and pull DAAMS tubes. If the ACAMS alarm level is at or above the
alarm set point (Appendix A), then the DAAMS tubes shall be pulled andanalyzed.
Attachm ent 22 - Page 26
TOCDF
Agent Monitoring Plan
October 2009
APPENDIX A
AGENT MONITORINGPLAI\
FORMUSTARD MUNITIONS AND BT]LK CONTAINERS
AND
GB, Mustard and VX SECONDARY WASTE
Attachrn ent 22 - Page 27
TOCDF
\Bent Monitoring Plan
AGENT MONITORING PLAI\
Explanation of Column Titles
Station Number
The station number was assigned by Monitoring in accordance with the Monitoring Station
Numbering Sheet. This is the number used by PDARS. The letters are used to identiSr the area
monitored, i.e., AL for Airlock, OBS for Observation Corridor. The numbers are specific to the
geographic location being monitored. This number cannot be reassigned to any other location
due to the restraints caused by the 4}-year record-keeping requirement. When an S suffixes a
station nurnber, it indicates that the sample line is movable to various sample points. The S
indicates spool. A G suffix to a station number indicates that the station monitors for GB, when a
station is suffixed with a V, it indicates the station monitors for VX, and station numbers suffixed
with an H monitor for Mustard agents.
ACAMS/DAAMS Tag Number
This nurnber identifies the tag number for the ACAMS or DAAMS specific to that station
number. If an ACAMS or DAAMS is removed for repair and a new ACAMS or DAAMS is
installed at that station, the tag number will stay with the new ACAMS or DAAMS. This is to
prevent the need to update the Monitoring Plan each time maintenance is required. Temporary
DAAMS are installed with an assigned sample number instead of a tag number. Monitoring will
track the ACAMS or DAAMS being repaired using the unit's serial number.
Unit Location
This designates the detector's physical location by room, floor plan number, and the drawing
number (from the attached Monitoring Plan drawings).
Area Monitored
This designates the geographic location being monitored by room and floor plan number.
Power Type
UPS - Battery backup used on ACAMS. DAAMS using the same station number will be
connected to UPS.
SPS - Commercial power backed up by an emergency generator. DAAMS only (and possibly
DAAMS located on a cart with an ACAMS and DAAMS, but with its own station number) will
use the Secondary Power (Distribution) System (SPS), or UPS if available. The heat trace cable
for all sample lines are on SPS power.
Sample Point Hazard Category
A through E, with "A" being a room where liquid agent is likely to be present to rrErr where no
agent will be found. See Terminology Section for complete definition.
Monitoring Level
Indicates the purpose of the ACAMS or DAAMS stations and corresponding monitoring level or
sensitivity of the monitor. If VSL is listed, the purpose of the ACAMS is to monitor
equipment/waste/personnel contamination levels. When ECL is listed, the location is being
monitored at a more sensitive level than required by CMA direction. In other words, if ECLA/SL
is listed, the monitors are in the VSL mode but are more sensitive than required by the
Programmatic Monitoring Concept Plan for that monitoring location. The agent concentrations
for each monitoring level are specified in Attachment22, Appendix A.
Attachrn ent 22 - Page 28
TOCDF
A.gent Monitoring Plan
October 2009
Alarm Level
The alarm level at the ACAMS station is the same as it is in the Control Room. The alarm level
shown is in terms of the monitoring level shown in the previous column. The alarm levels are set
below threshold levels to allow action to be taken to avoid exceeding threshold levels. The alarm
level starts a specific course of actions. The specific requirements are identified in Section22.35
(Alarm Response Requirements). An alarm located in toxic areas, filter mid-beds, inside ONCs
or other closed containers do not require the contingency procedures to be implemented.
Sample Line Length
Lengths of the sample lines are listed with an accuracy of t20Yo.
DAAMS Mode
The mode is an indication of the purpose of the DAAMS. Examples are:
ACAMS Confirmation: The DAAMS is used to confirm an ACAMS reading in the event of an
alarm.
Historical: The DAAMS is used in an area that is unlikely to have agent contamination and is to
provide evidence at least monthly that there hasn't been any detectable concentration in that area.
Primary DAAMS: In this case the DAAMS is the only agent monitor, in cases such as LSS air
monitoring.
Comments
Additional information as needed.
Attachrn ent 22 - Page 29
Fzrd
l=
.
lZoU
rnrI
]Foz
\ntr
lFoz
c{C!
r!Foz
A
,-
,
<
rJ
r
4.
t
{O
e
.
t
??
H
EJ
*
O
3a
=
2
r.
1
ea3s
a1>g
{E
z
z
-Z>g
4Z
-(
J
-t
aA
\<
(

E
-/
.

1-
q
{E
l-
l
aZ>g
{g
l-
l
aA>g
{E
aA
\<
E
z{E
E(
aZ>=
{E
z
aA>g
{E
fr
l

E
d
26

s
t
=A

$
Or
]
a\o
tn\o
\n\o
o(nN
6[n.t
bo\
b\o
(o\n
\f
,
c!
O
bca
TE
N
v?O
rn
(n
v?O
\o
v?O
\ni
\ni
u?o
V?O
v?O
IzI'F
/

J
-
;i
At
=
v
\
3-
-r

lE
{
ZJ
o=2
Jo-
.Ja
Ja
Ja
I0r>]=a
JOrJa
-lO{>Ja
J0-
.
,}
=a
JO-
'
.)a
Jo<Ja
Ja
JOrJa
rd
\l
tE
Z
!
=
TR
E
U
(-
)
z
z
o
o
a
o
U
U
z
U
ri
H
ac.
.
aC-
,
.D
aO.
H
aO-
.
.-
aO"
atu
aO-
.
aO-
,
r)
aO.)
a0-
'
,D
aO-
.
.D
+L
EZ
$F

d
lE
d
.3
s
r!?RV
c.
r
UO
2c
,
D
U=
ZN
\.
/

61
)d
,
U=
Zc
!
V
ol
<t
o
q>
)d
aCo
l-
tZ'
b
-o
\
-E?c
,
r!
aAt
nYO
Zr
o
Do
,
f,
Z
[!
*
rt
r

(:
l
f.
6
FO
\
A-
.
fi
i
Ps
aa
-Pa-
'
gr
>
*e
BH
=
t!

Y
c.
l
fr
-
,

il

"l
fr
,
z
=
Eg
,
=
ri
z&
=sI&
=siz.
r\

z:
t
h
v
I
rr
l
A\
v
:d
Z
F-

d
E
=E
E
fr
t!
NcoV,
-
j
UO
Q
<c
)
Y
gH
K
AY

t
DA8f
;I
OU
I!
Nc,
o
v-
l
It
a
O
Vv
A<q
Y
2s
r
y
)c
tr
j
IOU
t!
Nco
v_
.
j
Uo
P
<C
]
Y
3t
K
L
v
r
H3
U
fJ
.
]

F(
()
U
(.
A
dn
r
O
co
?
FT
o
o
(r
\
O
N
Fo
o
A
-:
(
I!
O
rr
.
t

X
rF
1

\J
Vl(TM*
t
n
nA
o
\/
vF-
Y
r8
f
r
in
O
r!
iB5
lJ
.
l

t-
r
()
U&lPs
p
cn
T
Y
r
\O
O
O
to
q6e
Ur
l
rr
.
l

o
tr
lon
*F
i
t+
(

I
8s
P
a-
a
es
r
y
6e
U"
l
ts
o
cAUIo\,l
-1
5
^*

ol

Q
5s
r
y
II
Fa
coUo\I
s-
-
{-
X
c-
,
.

eJ

Y
=r
K
v
tcO
caUo\I
,\
-t
-
q
Jdq
?
)r
K
v
IoO
-E?<
4
q:
E
-A
.
==
o
t
r
l
!
:
<x
?
c
s
2
6
^1
,

oo

f:
-

)
:E
U
n
o
z
O
U
Or
!
t<
tl
J=Z
-D
g+
r
33
@e{
Z
z
ca
.t
f-$
.f
,
.t
\o$
\.
)e\
NN
z
N
3+
r
{3
ooe{
O.NN
O.@N
co
f-
oo
f-
$f-
f-f-
\nN
N
ON
NN
F+
t
a
.tOmU
f-caU
mf-mU
N\.
)mU
ca
\.
)mU
\n\nmU
A\o[nmO
caC\
C-
,
.
$Oc\
O-
,
.D
a-tND
\nONO.D
OeoObo
cdOr?o
()g
tu
t
r
o
\
os
o
ii

a.

o
5
:.
t
F.
=

o)
E€
.r
r

!l
5,
R
E0)b0
caobo
cr
3A.INN0)Ocd
Frzrd=a=aoU
4t
s?q
R

H
g*
i
z
sIJ
.
IFoz
SHFoz
Trr
.
lFoz
Sr!Foz
\oNtl
lFoz
2r
d
eaT3
z
aZ>=
*z-U
z
z
z
z
&EilO-
&ilO.
z
z
rd
E
d
26

s
t
=E

$
aJ
OO
\n@
i^
,N
\nN
-rn
.f
,
i^
)e{
6OO
N
6
f-
Of-
Of-
TE
N
(nO
v.
)O
vr
)Ovr
)
O
rnO
z
rni
z
z
z
vr
)O
\r
|
(Jz:il
i
Al
=
v\H-
r.
r

lt
zr
orla
Ja
JF<
tsJo
JaJ=UIJ
.
]
JUr!
Ja
J0.
,
.>
Ja
JOr
ts
Jp.
JAr
Ja
Ja
rd
-t
-E
Z
!
?
?R
E
U
Z
U
cat
ei
m?
z
me
z
z
z
m
ri
H
aC.D
a
aD
aA.)
aO-
,
nrr
.
l
-i
loq
z=
c
E]&
aC.D
nI!
-&OE
z6
/
r!c,
orr
.
l
-&CE
z=
o
rr
.
lc
oIJ
.
]
F&
o=
1
z=
o
E]&
aF-
tD
ap.
.D
E?
<x

l]
ra
Y

nr
e=
&
"3
9
>d
I
+T
^-
N
J=
4il
Q&
o
LL
I

A
--
r
tr
.
l

Y
ol
p:
=
Eg
*
CO
.Fa+E:a&
I
>,
i
E=
d,
vJc,?UI!
&t=
R
L)

o-
r

N
ZA
2
't
v>)

FJ
mVJ&Utr
.
l
sx
+
5A
n
v
)-
]
?*5E
3
F
f!
l
a
,t
l
I
J
a
l
H
r
V
aA
eR
s
Vr
o
o
t
Jo
c
n
He
=
hR
=NV.
6
JO4,
>
<d
k=
=NVr
o
JO4>
<c
.
+t
r\

Z
+t
V
1f
r
'
t
r-
\

V
Y'
]
Z
in

=
Fr

d*
z
a
s
;J
Y
=
iE
l
tr
c\
FU
s
3+
l-
l
r

-(

/i

-r
'-
-
.
1

O
l-
.
1

O
=q
i
l
A
Hn
E
t
N
U"
2
A
HI
-)

-tO
CAUIC.I
-r
'
i

5
,t

6l
Y
5s
T
oI
-{
C{UIO.I
-i
5
^*

cl

?
5s
r
y
nlt-
/
NUIO.I
.-
f
,
=
-l
-
!
,
dq
?
38
r
y
olv
N(J
IO.I
,\
-4
-
\
J
,'
,
r
*

Cl

?
5s
T
oI5
\f
,UIOlI
j
S
5
a,
,
*

ol

?
5s
r
y
ojv
NUIO,I
.<
r

;-
-f
-
l
Jdq
?
DI
K
\/
l
cI
F{
IJ
caUIoI
-i
5dq
'
"
>^
K
v
Iol
-t
IUI
*O
.
l*
r

!
cx
=
f\
\
J
\
/
vo
l
o
:'
a
A
^
t
m5
&
cd
-l
v
$oIo\I
+-
<
;l
o
-\
rr

Cr
l

Y
5s
r
y
eI
-fv
\f
,UI
cqax
5
UX
?
r/
r
A
o
o
mS
q
r
ci
=v
.f
,UI
&qQX
5
UX
?
r.
z
f
A
o
o
mS
q
t
ci
jv
A
++
-
I
1+
-
=3
z
f-N
z
z
z
rr
.
lJc0F&cO-
z
r!JtrF&oc"
r!JmF&cO.
r!JmF&oC-
,
,
{z
z
2+
h
{i
c!N
f-N
NCON
ct
)
oo$
\oC!
eo
z
f-C.
l
CO
z
Z
z
f-(n
f--t
F+
r
a
a\nc\c-)
f-c\O.D
ooONUtr
.
l
C!J
Ic\J
CONaaJ
$NJ
\oNaaJ
f-NaU)J
ooc!aaJ
NNJ
NNNJ
GE
5€
{-
,

U
.F
(

!)
tr
(
)
Oa
Eb0
3zri
r-a13aoU
=rI
]Foz
=r!Foz
O(
n
tr
J
7
)
N
UE
r
q
?P
5
d-
z
Sr!Foz
Sr!Foz
f-
6
f-E]Foz
f-I!Fcz
Srr
.
lFoz
(nNrr
.
lFoz
a
7\
-t
=ao3s
z
z
z
-Z>g
{E
-Z>g
{E
aA>g
{E
aZ>r
{g
ilc,O.
z
-Z>g
4Z
-(
J
r.
I

E
d
26

s
z
4,
2

q!
aJ
f-
6f-
of-
f-\o
z
cac!
b\o
o\
o\
N
\nco
='
l
Ii
N
O$
O$
v?O
(n
z
z
\ni
(/
)
i
\n
z
(r
)
i
rni
(JzI&i
t
AE
H
v\Fr
-
r-

lE
l
ZJ
otiz
Ja
Ja
Ja
JO.>Ja
J0.
'
.
Je-
'
r
JO"J0
Ja
Ja
JO-
.
Ja
Jo<)a
rd
t-E
Z
!
?
?R
E
U
mi
o
z
z
U
m
U
z
mi
U
ri
H
ac.
.
)-
aO.
iD
aO-
,
.
aF.
.
.
cfr
l
FCOE
z,
-
c
E]&
orr
.
l
F&OE
ze
I!
il
aC.
'
,D
aO-
,
.-
ao-
,
,
orI
]
FCo=
z-
c
Ir
ld
aCr
ap.
'
.D
+t
,^
\E4
<x

J
rg
Y

0r
q=

il
o3
S
<
e'
t
=NV.
o
jo4,
>
<e
hR=(
\
Vr
o
JOg><e
{o
t
=NV.
o
JOg><d
eaeA
il
1ER
Z<
.
e&
&fi
f
r
:
I:
>
X
?x
>
a-

&
aJ
+t
,.

OO
et
s
B3
)
Mr
=
u
l
?a
)
Fa
En
l
Or
l
t
.
r
JC
:
IH
E
rr
.
lzcJQZ
i-
m
\JV)
E-
,
.o
rI
JAP
YfUz
z
IE
:
\J
UEf
i
3o\
o
rr
.

R
nZ
i
:<
O
4C?
d4
O8I
ZO=E
SHUo
\
sq
o
EE
uU
=
3i
z
F
dU
=E
A
9
tUI
&qax
5
UX
?
l/
:
A
o
o
aS
q
t
oi
jA\J
$UI
&qax
5
ux
?
l/
r
A
o
o
mS
q
l
OO
I
t-
,
1
v
.tUI
&qQX
5
ux
?
r.
z
f
A
o
o
mS
q
t
OA
I
Ff
IJ
No
s+
or
Y
(Kgd
I
e\
loI
co
I
il
8
E
E]
-
Y
r<
A
o
o
=x
q
c?F{
IJ
c
-r
H
O
r-
X
C,
R
E
E
fr
:
;

P
j
x:
5
;-\J

o-
C\oI
CoI
d3
E
[T
J
-
Y
>R
r
y
oTF{
\J
oI
cA
I
a2<Y
nO
O
C{!oI
oI
cA
I
a?
rr

OO
-c
\
!aI
3n
c.
o
T
2?
3
=
>>
q
*C
C
la?5
-f
,
I
cl
x
q
ox
=
ui
5
A
I
Av
aF>
T
qr
d
c
I
F{v
$mI
cl
x
q
a\
/
-(J
N
a
Uo
.
-
Al
av
QEE
B
I
F(v
A
-+
{
-
<r

++
-
33
z
z
z
.f
,O
r!JmF&o
r!JcoFcoO"
caO
\oC!
cn
\oNea
L!JaFcco-
,
,
z
caooeA
a
++
_
t+
L.<
Y
YF
CAooca
caooca
Inca$
ooNco
z
Z
O,
caco
c.
r
.A
z
CACO
f-
F+
r
a
NNNJ
aNc!NJ
coNNJ
-f
,
\Ndr!z
\n(nc!aV)J
\o\nNaaJ
F-
\aNat:
-o
oo
\nC\
(-
)U
\oNUU
\n\oNaaJ
NcAzt-
cacoamo
e!
co0)bo
cd
p.
.
.
tc!6l
/
*r
l
0)
()cd
tJ
.
'
.

tr

o\
RS
S
E
l'
!
x-
o
{:
O
.F
a

Ll
Fb
;oEobo
cacaooo
Cd
C.
'
,
INc!oOcd
t'
rzE{
t5aFtzoU
Nc!
.t
s=tqFoz
SIJ
.
]Foz
=dESrr
lFoz
SIJ
.
]Foz
Srr
.
lFcz
5{srI
]Foz
SI!Foz
=d8SIJ
]Foz
Ea
a
,-
.
,
1

I-

n
r!
3
8
=E
?
SIJ
.
]Foz
=d8Sr!Foz
2a
a
JFL,
]

^<

E
d5
e
3H
a
3r
d
za3s
&=.
1z&o.
,
,
&z&
c,-zil
&z&O-
&zco.
,
,
&!'
ra&O.
z
Lr'&ilO-
z
Fd
E
d
28

s
t
34

$
aJ
\nea
f-oo
FI
oo
O
6O
6O
\o
\o
OO
6O@
6Ooo
O
dH
JH
Z
z
z
z
z
z
z
z
U?Ou?
z
z
v?OV?
()zItl
J
-
;i
At
.
r
.
v\Fr
-
-F
tzt
ctra
JR-
,
,
JF-
,
.
J4.
'
.B
Jo.
'
.
ts
J0.
.>
Ja.
.
Jo"
Jp.
.
JaJUtr
l
JorB
JorB
JaJUrr
.
l
ri'!

Ii
E
v
!
?
E
R
E
U
U
z
z
z
z
z
z
ma
z
z
ri
H
aD
ot!
F&o=z6
L!&
otr
.
l
-do=ze
IJ
.
]&
otr
.
l
F&c=
z-
c
r!&
crJ
.
l
F&c=
z,
-
c
I!&
nE-
l
F&c=ze
r!&
oIJ
.
]
*&CE
z6
/
rI
]
c,
,
oI!
?c
,
z-
q
tr
.
lc
aO-
,
arr
.
l
-&o=
z=
c
r!&
otr
.
l
F&OEze
tr
.
l&
aD
FA
<x

J
r.
l

Y
0r
/,
=

d
o3
t
L:
r
i
oe
X
ot
(
u.
'
UD
O
E=
CnMJ
<
I
Oq
t
.
d
(J
n
N
t-
,

O
Ur
)
e
\<
.

(,
)z
.
J
>8
,
&,
-
&=

4
Oq
t
.
o
Ul
n
N
,-
O
A
fr
<
a
if
r
'
&n5"
*
Ut
6
c
'
l
,-
O
A
?<
a
'>
4
.
&OoUK
9
4
*
H
&Co9q
t
s
er
n
c
O
z
c^8{
B
U\
n
N
>_

O
Ur
)
e\
<
(
,
)1
J
C
,^
,
ts
e
U
\r
l

e'
l
,-
O
A
=e
3
Cou5
Z,
A
<-
(z,
&Co9{
?
fr
n
c
o
JO
&Co96
3
fr

n
c.
-
l
JO
z.
l-
,
q
''

co
/,
oU-
<
Ha
+t
r\

Z
+t
\/

I
ri
,-
\
\
VYJ
z
rl

0.
.
F
d,
5q
X
r-
l

ts
tr
$mI
cx
q
ox
=
ui
-
I
av
@F>
q
ed
o
fv
\f
,mI
c,
q
QX
5
UX
?
A:
o
o
mX
c
.
t
-
v
Co
l-
rlv
-f
,mI
cqcs
=
UK
+
.n
A
o
o
mS
q
t
ci
I
t-\J
.f
,
c,
4
ca
=
UH
+
a
A
ob
m6
q
l
Co
j
$I
il
,
7an
5
UN
?
A
A
oo
m5
r
y
ci
f
$
&+
ca
=
ux
+
a
A
ob
00
5
q
|
CO
jAIJ
CAcIO.I
-i
5
,a
*
N
Q
5s
r
y
cj\-
/
coo!O,I
-r
$
5
dq
?
5s
K
v
InjO
coL)I
,o
o
fr
r9\
5
ux
q
:r
l
A
o
o
00
5
q
r
ci
lv
$I
&T
ca
=
ux
q
ca
;
.
@
mS
q
l
ci
f\-
-
l
\f
,
&+
oa
=
UK
+
:"
,
e
A
o
b
mS
q
t
ci
ft/
wc0
I
cqQX
5
QX
?
A:
o
o
mS
q
l
Co
=\-
/
A
-.
.
-
-
-f
r
r3
$rn
r!Jc0F&c
I!JcaF&c
E]JmF&cO.
r!JmF&ce.
,
.
r!JcaF&cO-
,
r
tr
.
lJFAFdo
tr
.
lJmFcoF-
,
,
z
r!JEF&cO-
,
r
rr
.
lJmF&o
z
g+
r
{3
Z
z
Z
Z
z
z
z
z
NNca
z
z
O,Nca
F+
r
a
co
cAamc
\nCOaaJ
\ncaaaJ
\ocoaaJ
O,
cAaaJ
O,
cAaaJ
$COaaJ
\f
,
caaaJ
f-cazD
Ioo
cAaoJ
@caaaJ
Ncac,
()r!
qE
8.
R
Ebo
Fzf.
l
l-a-eoU
Ea
a
EJ

f-
(

A
r.
.
r

i
E
dE
e
3E
a
El2A
.
.
i-
<

Ir
l

l-
{
JE
l
r
r

,^
HI
f
;
i
l
>:

z=
*p
2
z
r!3E
a
Eg
E
4t
n
a
cn
c
4
<
3;
N
O.
'
.

Z
co
<U
U
ui
<
t
!
=rr
.
lFoz
:r!Foz
="U\nr!Foz
a0I!&(,r!E]
o<n
a
7\
rr

ti
E
i
ao33
z
z
z
z
z
z
z
z
-Z>g
{6
z
aZ>=
qE
z
ri
Ed
2a

s
-=
Z
(
:
.
!
ar
]
6oo
@
6Ooo
6oo
t-
\o
f-\o
f-\o
(n
f-
6co
6oo
At
tn
b\n
TE
N
v,
'
)Ou'
l
O.+OO$Oo.+
o
O
l.
nO
O{O$OO$
o{OO.+O.f
,
ur
.
loU?
v?O
v?O
\r
)
rn
(,zI',

J
Ft

;i
O1
3
F-
-i

lt
Zt
]
o!iz
JaJUrr
.
l
JaJUHJo
JUI!
JUr!
JaJUH
JaJUrr
l
'!Jn
Ja-]Ut!
J-
{Jo
JaJUr!
JP-
.
.
tsJo
Ja
Jo.
.Ja
Ja
H-!

ll
E
Z
!
?
TR
E
U
a
U
m
m
m
rE
H
aO-
,
.
t-
acrD
aor
aO-
,
,
ac.
.3
aO-
'
r
aO-
,
,
H
aa<
f,
aOi
ao.
.D
aO.-
ac.
.
.D
E?
<x

J
ra
Y

0<
E=

&
"e
g
-t
\
Er
N
l-
.E
ol
ol"
cr
)
do
;i

I
LJ

<<
ti
1
M
c\
3-
.
C0

o.
t
;r
"
cf
)
do
;i

I
L.
/

r<
1i
l
4
M
s{
"c
o
d,
OHE
N
I
'-
r
tr
q
"c
o
do
,i

I
LJ

r=
tJ
]
a
I!JUE-
,
'r
$
\J
IU=
XcF
r!JU0-
,
-r
$
Ul
L)

-,
XoF
rr
.
lJUQ-
,
--
.
)
$
OT
L)

-,
XoF
5r
o
Hc
O9s
(,

=3
Af
r
,
3.

o\
LJ

eO
U*
Vr
o
.r
OE><e
zc
t.

F
YQ
Z
HI
,
{
E
r*
r

)-
{JoU
H
EE
&
mr
-
gIR.
i
?&
uu
x
3i
?
i-
r

d*
=3
8
fr
$mI
&qax
5
ux
?
/l
A
o
o
oS
q
r
ci
I
F(
\J
.f
,mI
&qQX
5
ux
?
rg
]
A
o
o
aS
q
r
OA
TF{\-
/
$mI
&qQX
5
UN
?
r/
l
A
o
o
aS
q
t
ci
Y-l\J
ilcx
\J

61
1
aAm5
o
$UI
c,
q
^c
\
r
<u=
8
a
)
"5
mx
q
l
o-
a
Tt<v
\f
,UI
c,
qQS
5
U]
O
.r
.
A
"
5
mS
q
l
Oo
TF<
v
.tUI
&qQs
5
(J
l
o
cn
A
"
5
mS
q
l
ci
Tt-
l
NoI
cA
I
04
3
E
El
-
Y
>o
=
6t

')oJ
-f
,UI
cqQS
5
TI
\
v-
q
J
.,
r
.
A
o
5
mS
q
r
oA
6loT
o(
3
E
[.
t
l
-
Y
.<

-l
.

oo
z?
V
s
1
'
C-
.
1

'
,'o
N?
dqQS
5
Ul
o
a
A.
5
mS
q
l
Co
CaUI
&qQs
5
r\
\
A
\.
/
-
u
.r
,
A
"
5
a6
q
r
oi
g+
r
33
z
z
z
z
z
z
z
\.
)Nco
z
z
P+
r
{3
\n
c\
f-ca
Noo
.f
,
Noo
\f
,
coN$
r\c$
-fN-f
,
\cN
\oco
O,
cAca
-f
,
O.
.f
,
F+
r
a
c\
cO&()r!
Fca&Qr!
Nc\
cac,Ui!
aFJ
.NNendUt!
O'
.
$caXcF
O'
$CAXcF
cO.
-tcoXcF
\nca0tJ
-o
\ncoJ
cOtnc.
)Uo
-t
rncoz;!r!
l.
n
\ncazrq
.f
,
caObo
(d
o.
.}o
()cd
IL
t
r
O
\
8f
;
8
P
H-
d
x-
o
vP(
J
.-

JJ
8A
Eou0
Frzt{r-aEIeoU
At
+Zn{s
tr
J

>t
<
3?
l'
ne!
tr
.
lFoz
Nc'
l€=r!Foz
cCSIJ
.
]Foz
=€SIJ
]Foz
Srr
.
lFoz
Srr
.
lFoz
SIJ
.
]Foz
str
lFoz
SIJ
.
]Foz
:I!Foz
2r
d
aaXQ
l,
r
A
-
z
z
aZ>g
*Z-(
J
&E&F-
,
&t<a&O-
z
rd
E
d
26

s
-
\z

q!
g.

fF
I
O
O
6$N
$N
Oc{
e!
\o
i^
,N
bN
o\
Nco
6\nco
1F

N
JH
\a
rn
\ni
u"
lO
z
z
z
z
z
z
z
\o
()Ztrr
t
l

J
-
;i
At
l
v\
i-
r

?-
-r

l.
I
l
ZJ
c=a
Ja
Ja
JOrJa
JAJ0
JF<B
JA
JFr
JF-
'
,
ts
Jp.
'
.
ts
J0-
,B
JF-
,
.
ts
Ja
ri
rl
-E
Z
!
?
1P

E
U
U
U
z
z
z
z
z
z
z
Z
ri
H
aF-
'
.
aFr
acr
aOr)
orr
.
l
f-
,

d
bEze
tr
.
l&
Rrr
.
l
?&CE
z=
q
IJ
.
]&
cI!
Fi
lOE
z,
-
q
tr
.
l
c,
cr!
?&OEze
r!c,
or!
3d
,
cqz-
o
tr
.
l
d,
or!
FCCE
Z=
C
tr
.
l
c,
ar!
F&CE
z,
-
o
r!d,
ao.D
+t
E1
<x

I
tr
]
Y

0r
(=

d
o6
g
N$Ii
o
x
o:

tJ
t
aQ
^
tJ
-

,-
l
ue
g
cn
€
{
mo
O$
AraF
0(

or
C.
t
OTu3
A
,-
t
ma
oi
l
o4

o.
r
c$OT
u3
A-
,
c0
e
oe
Hr
o
E:
r
Er
"
X
rc
N
Z2
a
Dz
J
2c
/
,
<T
s
EI
,
n
F>
3
&
PE
,
E:
A
<d
)*
1

co
X=
m
Yr
O
r
u!
,
n
Za
a
D>
J
;a

R,
.
=
-r

Lr
/
E:
A
KJ
V
a:
3
fr
)
+t
r\

z
+t
\/

I
ri
A\
VYJ
Z
rl

0-
=
F
du
5e
X
ri
-
lr
CaUI
&qas
5
Ul
o
a
A
"5
ca
S
q
l
cA
TF(
cAUI
cqOq
r
=
rr
V
=
V_
I
J
a
A
i
mS
q
l
cA
I
t-
{
v
coUI
&q9s
5
T\
N
ru
-
\
-
'
Ja
A
"5
mS
q
t
co
I-\J
caU!
&q
9s
5
(J
l
o
:.
,
n
A
i
tr
5
q
r
Co
Jv
$a
Z\
nP-
=
vN
=
lY
-
9
l*
r
l
tZR
K
Av
t
\-
/

A
\=
u
2,
7
=IJ
$n
=la(
nP-
=
vs
5
Zd
K

vr
\J4i
5
$UI
d?
A-
-
<Xc
{
"
9t

-
\-
/
.r
,
A
.
5
mS
q
l
oi
T-f
caUI
il
99R
5
U_
O
a
A
*
mS
q
r
ci
=
.f
,o
=lzr
n8n
*
lV
t
.
\
)
H
I
I
ZA
K

vt
\,
.
/

A.
<<

lJ
2,
7
5
cAUI
cY9R
5
L/
_
O
rl
A
i
aS
q
t
oi
f\J
coUI
d,
q
Oq
r
=
rr
V
X
v-
\
Ja
A
i
mS
q
r
Co
T-a\-
/
.f
,c
\<
tar
aP-
=
\-
/

C\
l

:i
il
-
(
JZd
K
Av
t
\JlF
r

l-
J
ZT
5
A
$+
-
<r

-i
+
-
33
z
z
co
o\
f-co
fr
.
l
Jc0F&oA
rI
JJcoF&cO-
,
r!JmF&cO-
,
rI
.
]JmF&oO-
,
.
Ir
lJa0Fr'
,oO-
r!JmF&cO.
IJ
.
]JmF&cO-
Z
A
.+
L
-
-+
+
-
i3
O.
-t
\oN
oo
{z
z
z
Z
z
Z
z
z
-t\t
.o
F+
r
a
al'
nrncor!
\o\ncoaoa
o\
(nCAamc
o\
tncaamc
I\ocoaaJ
=\ocAaaJ
CA
\ocaaaJ
\o\oCOaaJ
oo
\ocoaaJ
o\
\oeaaaJ
t-coaaJ
\cr-
-
CAZo
\ncaOb0
Cd
O.
'
.
I
c.
lNoocd
qE
8x
Ebo
Frzri
ts
rztlzoU
SHFoz
=I!Foz
=r!Foz
3t
s
lY
q
s

H
H*
8
2
ozr-

o{
'e
{
rI
]Foz
A
t-
t
\<

>J
<
4q{o
o
q
U$
r
r
:
JH
5
i4
=
i3
F
l
4axe
-
aZ
<,
t
8
{g
aZ
.<
E
Z
t-
<
*Z-U
cdO-
,
.
z
z
z
-Z>g
{g
z
-Z
.<
.

E
Z)
-
{E
a1
<,
{

E
Z
t-
,
{E
z
rd
E
d
2a

s
z
-z

qt
aJ
6oo
6Oca
iN
6o\
oOO,
6o\
\n
f-
O
bO
[^
)
tf
,
N
oOO
=jTE
N
ur
)O
(nO
z
(no
O$oo\f
,OO.+
O.+\OO.+$
v'
)O
rni
z
rr
)
i
(n
V'
'
!O
()z:,N
J
AE
i
v\
Ll
-
i;
r
d
ZJ
o=a
JF-
'
.Ja
JC-
'
.
Ja
J0<
JaJUIJ
.
]
J0JUr!FJo
JaJ(Jr!
>T
{Jo
Jo<Ja
Ja
JO-
'
,
JAJo
J0.
'
.EJa
Ja
H7-t
-E
Z
!
?
?R
E
U
U
U
z
U
z
Z
()
U
z
ri
n
V)A
V)
O-
,
l
or!
F&o=
z=
q
r!
il
,
ao-
,
,
ao-
,
'
.
a0.
.
aO.
,
,D
aO-
,
rD
aO-
,3
0O-D
aO.
,
,D
aD
A\

+t
Ei
<x

J
et
Y

nr
(=

&
"3
9
Lf
r
2e
o
Oo
t
OT
0(
3
Z-ga
,A
<i
l
2F
(Ad
o
\/
:
-
+nc
n
Y
ES
K
E
ci
A
rz
:

o
Il-v
r'
"os
a
U]
A
cn
A
a
m5
J
o
FnUi
-)

C\
ooe=
O-
,
.

Z
>d
,
Fr
n
UO
-c
\oom:
O-
'
.

Z
>/
,
5s
"-
-
r

C\
o=
Q=
.
tu
z
\<
r

,
z,
-
4
F(

r-
XR
\.
/

r
u3
A-
,
c0
z
q;

c,
ct
r
ox
Uo
'
UD
O
EE
0(

r-
*O5q
rt

Or
4.
,mz
gc
,
Cc
o
*.
O5q
rl

Or
VO
a,
-
c0
z
or
'
.
O(

o,
Eq
u8
[/
)

-,
,
mz
gc
67

ot
O
oq
Ui
ur
)

o
EE
+t
,\

z
+t
\J
i
r
i
}t
\
VYJ
z
ti
O
.
-
7
P
fr
-t
Y
H
il
-&
$c
=lz,

ra
)
P-
=
vN
>
1
^/
-
(
J2A
K
a\
v
r
vHI
JzT
=\J
$U
=r
l2r
n
I
?c
o
-
U
C.
l

:i
tl
-
l
)
r*
{
.
1
lu
zq
K
A:
z
l
\Jz.
T
5
coUI
&qQs
5
I\
\
Iv,
-
u
a
A
o5
aS
q
t
co
I
-{
V
cOUI
.o
o
&lQ\
5
ux
?
r/
l
A
o
o
mS
q
t
OO
fv
caUI
&T
9\
5
UX
q
:r
l
A
o
o
mS
q
t
oo
lA\J
caUI
cT9\
5
ex
?
A:
o
o
tr
5
q
l
CO
J\-
/
NUI
.o
o
Xl9\
5
UX
?
:.
,
r
A
i
mS
q
t
oi
lO
C!U!
cTQ\
5
ux
?
:/
r
A
o
o
mS
q
t
Oo
Tt-
c!U!
d,
T
9\
5
ux
?
A:
o
o
mS
q
l
co
t,
v
ca
I
d,
T
ca
=
ux
q
ry
'
)
A
,
o
o
mS
q
r
Oo
I
-(
v
-f
,
I
d,
TQe
5
vq
?
aA
,
@
ca
S
q
l
Oa
!
F{v
NI
C,
T
Q9
5
us
?
AA
.
o
o
mS
q
t
Oo
fv
A
++
-
t<

't
+
:3
\n
f-co
oo
'\
oco
I!JmF&c0-
,
z
z
z
.f
,
z
@eo
o
rn
.f
,
z
a*
.
I
-t
+
-
i3
\oco
cO$ca
z
Nf-
.
\o\c.f
,
f-cAca
\f
,
-t
z
ca
rn
rn
F+
r
a
f-f-cozcz
oo
f-CAzo
o\
f-COaaJ
NO.tUo
c\
l
.tUDo
IC!
-f
,U)o
\f
,O.f
,amo
a.f
,$aao
$-f
,aEo
f-O-f
,amo
ooO-f
,amo
aooO-f
,acao
\oca()bo
CBo.I?o
()c0
tJ
"

tr

o\
GI
A
ua
=
P
H'
d
E€
.
F(

+_
)
8.
q
Eob0
f-caooo
00
O-
.
.
INN6)
trL)
CO
t-
lzria=aoU
sr!Foz
TI!Foz
=€Sr!Foz
Str
lFoz
=€SHFoz
\nNslFoz
=tr
.
lFoz
f-€Nr!Foz
O\
n
EJ
L
A
N
UE
r
r
t
?P
5
m-
z
3r
d
aa
I3
&cO-
&=adO-
-Z>g
{E
z
z
z
z
z
z
HE
d
2a

s
i
5E

$
OJ
Nco
rn
tn
Nco
Nco
O
ra
f-
\af-
tnf-
@
6OO
6\o
TE
N
z
z
z
z
z
\ni
v?
O$
O\f
,
\nO
v?O
[r
)
IzI'F
/
.

J
-
;.
i
A
tE
'
vF
\
ir
-
Fr
l

tE
a
ZJ
or-a
JO.
r
J0<
J0r
ts
JO-
.
.B
JA-
,
,B
J0<BJa
Ja
-]
(r
)JQIJ
.
]
Ja
Ja
Ja
Ja
rd
\L
rE
A
!
?
?R
E
U
z
z
z
z
z
U
ca
z
z
ri
H
oIJ
.
]
-dOEze
I!&
Rrr
.
l
-do=
z=
c
rr
.
1
il
orr
.
l
-&c=ze
rr
.
l&
oIJ
.
]
Fi
l
c=
z=
o
E]
il
ctq
3CCE
z=
o
E]
il
ao<)
aC.D
ac.
.D
aF-
,
aC-
'
,D
aO-
,
aC-
'
,)
E?
<x

J
r-
i

Y
nr
&=
d
"3
S
hi
s
Vr
o
o
l
Jo
v
r
ia
=
=s
r
E
.<
,

cn
=4
,
l=
r
Q
.<
,

cn
ga
,
mo
o
<K
H
Vr
o
"
o
Jo
c
a
4
>
ul
mo
o
<K
t
s
Vr
o
c
o
Jo
y
r
ia
3
F\
o
'-
-
r

c\
7)

O,
Er
o
BE
=
r\
-
<:
-
=NV.
o
JO4><e
=
l\
-
<:
=NV.
o
JO<c
tu
=
=NV.
o
JO<&
i:
r
=
=NV.
o
JOg><e
1:

r-
YC
\
V6
iC
ov
Zt
)
<o
rq

4-
d<
r
av
+t
r\

z
+t
\J

I
ri
.^
\

\
V
YJ
Z
Ll
p
r
=
t.
.

dU
5q
X
)i
-
lL
caoI
&T
9s
5
\J

o.
r

Q
:.
z
r
A
o
A
mS
q
r
CC
i5
cAcI
&TQs
5
l/

c.
.
r

Q
a
A
o5
mS
q
r
CA
t
F{
\J
cacI
&TQs
5
uq
r
?
AA
o
o
mS
q
r
oi
TFrv
caoI
&T
9s
5
uo
r
?
:.
,
a
A
o
o
mS
q
r
CO
f\J
caoI
&T9s
5
wq
?
./
l
A
o
o
mS
q
r
CA
j\J
COUI
cZ
\
?
cx
=
ui
-
I
Ae
@EE
A
I
Fa
s
NOJ"
5
Jtr!
P
5
=x
"
ss
f
f
i
sc
1-

t-
in
l
\J
.f
,
NO
J"
5
Jrur
P
E
}K
E
s3
K
si
l-
a'a
j
\J
-f
,
NO
J"
5
Jr
tl

P
E
=N
"
cn
K
-1

r'
,

I
So
lH

t<
'o
l
v
.t
Nn
J"
5
JrEH
B
cn
K
="
c
F-A-
:
v
cAUI
&Ta\
5
ux
?
a:
,
o
o
mS
q
r
ci
fv
wU!
c?
A-
-
rXN
e
v-
!
.
J
.,
r
A
"
5
eS
q
l
ci
-:
\J
0
-+
+
-
=
.+
+
-
33
tI
.
]JmF&cO-
,
r
tl
lJmFdoA
rr
.
lJEFdotu
I!JmF&co-
EJJmF&cO-
oo
\f
,
z
z
Z
Z
z
z
E+
r
{3
z
z
z
Z
z
$
ca
.t
CO
\oco
ca
\oca
-t
\nC\
co
(nco
F+
h
a
raN$aaJ
.f
,N.taV)
-]
$N$aaJ
\nC{
\f
,aaJ
(nN.taaJ
f-N.f
,
I!O-o
ooN-tJ
@N$J
aooC!
-tJ
O.C!
.tJ
ca
.f
,J
\n\tJ
qE
8.
R
Ebo
FrZf-
lattzoU
=r!Foz
\nc\
rr
.
lFoz
A
,-
1
<
FJ
<
4$
{n
o
l
U
$
rr
,
:
il
8
8
>Y
z
s?
.
=HFoz
TtI
]Foz
i9
F
1
eax9
l'
r
A
-
z
az
='
.
8
a
t-
l
*Z-(
J
z
z
a>
<.
Q
!
4A
z
z
z
z
z
r-
l
aA>g
{6
{z
ri
Ed
2E

s
i
=A

$
aJ
6\o
\n.+
a\
.+
i^
,
t-
-
?.
1c!
O
oo
bO
O
bO
c{
(/
)
ca
TE
N
v?O
(nO
\niO
U?O
\nO
\ni
v?Our
.
l
v"
)O
\ni
\ni
v?O
\ni
()zIiJ
-
;i
AE
I
v\,-
-
'i

Fl
Zt
]
c=a
Ja
Jtu>Ja>
FlaJUrr
l
Ja
JO.BJa
Ja
JaJUtr
.
l
Ja
Ja
Ja
JO-
,
.BJa
JOrJa
t-
l
\HE
Z
!
?
1R

E
U
z
U
Q
z
mt
ca
m
m
U
m
ri
H
aCr-
ap.
.
C'
)
O-
'
.
aAD
ac.
.
.
aFr
a-
ao-
,
,D
aA-
,
f
aO-
r)
ao<
f,
aF-
'
.D
EA
<x

l]
ra
Y

or
d=
d
o6
S
ll
NM
za
)
<o
-E]
E
U
T
JJ

cr
l
o-

\
+-
(
=s
<a
a-
&r
o
c$CT
u3
A-
,mz
Ci
l
\o$
<l
rdI
6
zd,
c!
<T
r<
N
Z-
<F.
<
ad,
C,

-,
cc
{
OT
u3
a-mz
gd
&t
<
cNOT
()
3
A-
,mz
6d
fr
,
v
,
C-
U\
n
3=
2d
oOo
o
O'
-
zS
c-
<
af
r
,
c
oo
INc
oo
INz,d,
&q
o1

$
CTu3
(,

,=
-
{
QZ
od
,
to
€
=
!-
{
V+<c
:t
L
r\

Z
+t
v
I
rr
t
A\
VYJ
z
!O
.
i
i
F
d,

B
5a
X
r{
-
rL
$UI
c,
?
9x
E
V-
va
A
"5
mS
q
r
oA
I
F{
v
NI
&q9e
5
Ul
o
a
A
"5
mS
q
l
OO
I
F<
!J
.o<I
&qQ=
5
UJ
O
:.
,
n
A
i
e6
q
l
Oo
?5
$UI
&?
9x
E
\-
,

-
\.
/
a
A
"5
mS
q
t
oi
YF(A\J
-f
,o!
c?
Aal
-Xo
.
t
?
V-
r
\
J
a
A
"5
co
S
q
l
Oo
T-l!,
-tcI
&?
A-
.
-
Xo
.
t
Q
vr
<
l
Ja
A
"5
mS
q
l
Co
T-(
v
$oI-
d.
!Q!
5
\J
-
o
a
A
i
mS
q
l
Co
I
1-
{
v
-f
,mI
&?
9!
5
L)
_
O
a
A
"5
mS
q
t
oi
T!_
r
\-
/
.to!
&?
9!
5
L.
]
_
O
a
A
"5
mS
q
t
cA
l\J
\f
,mI
d,
?
9!
5
(J
_
O
a
A
"5
mS
q
l
cA
T!-
<
v
ca
I
d,
q
Co
p
=
u=
5
a
A
"5
mS
q
l
CO
Tt-
r
v
CO
ZC
\
8s
a
rV
-
l
)
)'
l
r

I
-A
O
O
4X
o
.
r
^v
t
\J
AaT
FIA\J
g+
r
i3
z
\oO
z
z
\o
z
z
z
z
z
oo
z
P+
t
{3
-too
cO
\o
oo
c.
)N
\o\o
\o\o
co
O,
(n
f-\o$
\oCO
N
.f
,
ta
)
F
:t
t
a
&cU\n\f
,J
[n.f
,amo
c!
(nwam
co
\a\f
,F
-f
,
\n-f
,ac0o
a\f
,
(n$ac0o
\n(n
\f
,z3z
\o
\a
)
.f
,UI!n
\o\.
)
.f
,Ur!c
(,
\o\n.tUr!o
t-
-
\n-tzo
oo
l.
n
-f
,J
@cO()ao
(dor?o
()cd
tJ
.
,

tr

O\
os
a
r)

o-

q,
F
r.
t
F.
F

o)
x-
o
EO
.r
<

!t
8.
R
Eob0
O.
CAObo
Cd
O-
'
,
!NN0)Od
t-
tzri-zFTZoU
c{
c\
I
rr
.
lFoz
=r!Foz
=E]Fcz
tJ
-
'
,
0.
,
,
gz.c>FC
t2FzI!
t!Foz
=r!Foz
=r!Fcz
lL!Fcz
a
7\
:
lE
l
eo1e
/a
a
-t
az>g
ig
tr
{
aZ
{g
H
aZ>g
{g
aZ>g
{E
3a
ig
aZ>g
4Z-U
-(
aA
.<
,
r

E
Z
r-
t
4t
\
?5
aZ
=,
.
8
A
t-
l
4t
u
?3
-(
J
z
z
z
&-'
rzc,C.
rd
E
d
26

s
I
=A

$
aJ
6(n
\n
\n
\nca
st
60$
[nco
(nco
o\
6Oo\
6OO.
6t
*
E
N
jF
l
\n
v?
I.
)
[n
[n
v.
lO
(.
)
-i
[n
r.
)
rn
to
z
()zIiJ
-
;i
At
t
Y\--
;r

Id
zt
ot-a
Ja
Ja
Ja
JO.
.
rBJa
JtuBJa
J0-
.BJa
Ja
Ja
Ja
Ja
Ja
JO-
,
.>
H\-E
A
!
?
TR
E
U
U
U
U
m
U
m
m
o
z
ri
H
a
aC-
,)
ao-
,
,
aC-
,
,
aC.D
aO.D
aF-
,
,3
ac<
aA
aF.
.
aA.D
oI!
F&ct
r
z,
-
o
r!&
+L
F1
<x

J
et
Y

nr
E=

d
o6
S
El

r-
d)

?1
J*
>d
,
F
Ir
l

r-
4ToS
>d
,
F
tJ
.
l

t-
-
d-
'<T
oS>e
F
6\f
,
IJ
-

r
Or

"t
>:4&
zt
n
.-
-
O
\
AOC-
<
<<
z
4n
#u<+2z
o
r+
{
o>r
<

t-
r

O\
UU
=
a)

r
A\
Al
-
]

',
r-
i
5
Z.
(,F
f-
r

O\
UU
=
a)

I
A\
nl
J
-
r
r.
-
.

!
E
g<
d
z
az.
rr
l

O
E
o.
t
<,
-
T
-r

A
Cr
l
2n
-
,
I-

IJ
J
'(
,
>
o&
m
arr
l

O
tr
S
<-

r
EB
S
,(
r
>
o&
m
azrr
l

O
E
o.
t
=a
s
t
()
>
c&
m
).
os9
<
i,
a
;
=>
3
t-
(

F/
a-
+t
7\

z
+t
l/

)
ri
^-
r

\
v
YJ
Z
rl
F
.
-
F
d,
5q
X
iJ
-9
$Q!
c?
A-
-Xo
r
?
Vr

-
\-
/
.r
,
A
"
5
mS
q
t
co
f
.f
,
(-
)
I
c,
?
A-
-
'
Xo
t
?
\-
/

-
\-
/
a
A.
5
mS
c
J
ci
l-
(
I
-<
$UI
c,
?
/,
\
-
-
Yo
r
Q
V-
(
J
lr
,
A
"
5
mS
q
l
ci
f
cao
\-
i
Iz-
I
\J
^
^
-
/^

\J
.
,
v$
=
tV
-
!
)
L!
.
1
Ao
o
ZX
6
l
Av
l
\-
/
r=

IJ
2T
Fr
\-
-
l
caU
=rZ,

-r
I
\J
-
-
l-
r

n
)(
t\
/

-
\J
2E
r
Av
l
\J
N
r=zT
=\J
CAU
Z.

Fr
,A
.
l
(J
-
r.
-
r

n
){
F/
-
\
J
li
.
l
,j
.
m
ZX
c
.
t
A:
y
t
\Jr<

L.
l
zT
5
co
=lz,

c!
Q*
=
v$
=
l^
U
:
V
r*
r

I
Am
zX
c
.
r
I
VA
\-
<

u
zT
=\J
CA
-rZN
I
L/
^
^
-
cs
e
lV
t
9
l*
r

t
ZE
K
/\
v
t
\J
A
=r

lJ
Z,
T
5
.f
,o
zr
n?-
=
vN
x
lY
-
V
l+
{
.
1ZE
K
Av
t
\J
A
=<

IJ
zT
5
.<
ro
-lZl
nQ-
i
vN
=
l\
/

-
lJ
ZA
K
9-
d
zT
5
-tU
t<
IZt
n
I
\J

t-
\J

C!

:<
^.
/

-
qJ
2d
K
/\
\
J
t
\Jr-
r

t-
l
ZT
=\-
/
coo
Z\
NR-
=
vN
>
<
fV

-
q,
H
.
I
Ao
o
Z.
X
6
l
I
\J
A
\<

LJ
aT
=!J
A
-l
r
-
!l

-r
+
-
a
rr
jvjn
\c
ooN[n
o\
-f
,
(n
f-\o
oo
cA
\oCO
f-.f
,
z
z
z
t!-lEFd"cO-
,
r
A
++
-
-
-+
+
-
{3
\o\n
rnF-$
(n\oca
r-
.
oo
-f
,
ooooN
\o\oca
..
f
,C!
co
oo
\o-f
,
-tCAao
z
Fr

+t
U)
O,
[n\f
,J
O,
(n-tJ
(,O,
\n$,-
l
\o$tJ
-z
cO\o\f
,zcz
\n\o$lJ
-
oo
\o-f
,J
moo
\o.tJ
O,
\c$zF
O.
\o$F
oO.
\csf
,
\=
r2,F
Ot-
-
-taaJ
qE
EX
Eoo
Frztr
l=aoU
\nc\
r!Foz
=IJ
.
]Foz
=€NHFoz
rr
.
1F<

\n
i-
r

C\
O
rr
.
l
I!
F
(,
0
0z
m
c\
l
c!HFoZ
=€Sr!Foz
=€SrI
]Foz
=€Sr!Foz
a
7\
tr

F{
33
z
z
z
z
az
{E
-Z
<<
E43
z
aA
\<
,
r

E
Z
t-
t
{g
&EilO-
.
tr
]

E
d
2a

s
?
=a

$
al
b.f
,
b.+
ic$
b.f
,
ca6l
Os
\o
\f
,
^\n$
c!
Faca
caco
O
dF
l
JR
v?O
o.+
$
v?
(>
tn
\ni
\ni
z
(ni
z
z
z
(JzIil
i
li
E
l
v
L'
3-
-i

l=
ZJ
o
Ja
Ja
Ja
Ja
J0<)a
Jo.
,
.Ja
Ja
JF.
(
Jo<BJa
Jor
ts
JOr
J0r
El

7
'l
EE
Z
!
3
?R
E
U
m
U
U
o
U
z
z
z
ri
H
ao<
H
aC.
,
.D
aC-D
(r
)P.
H
aO-
'
,3
aO-
,
.D
aO-
'
.)
ac.
.D
aO-
,
.D
orr
.
l
?i
l
cqze
r!c
otr
.
l
F&OEze
fr
.
ld
oI!
?&o=ze
IJ
.
]d
+t
EE
<x

t]
ri
Y

Ri
E=

d
o3
s
ll
39
V.
o
JO
39
V.
o
.r
O4><c
FEV.
o
JO4>
<r
'
,
=Amt
r
=F
{V.
o
).
]
O*><d
cp
oLUo
.
c/
D

o
P>
l)
*
d=c:U\
o
UD
O
E=
ke
::
-
Vr
o
iO
d#
c<?=>8
&r
n
A.
/
l

-<
OT
r)

O,
v
\J
A-
(mz
o&
tQ

sr
t!
mY=
;
E>
=
<e
CQ
w
tS
m
,t
\
o
XI
c
n
e>
3
Ec
o
i9
n
Y8
;
E>
=
<e
u*
I
3i

,-
F
d,
=3
8
tu
$UI
dYQR
5
L'
-
O
a
A
"5
mS
q
t
oi
I
-rAIJ
.+UI
il
9QR
5
\,
_
O
a
A
"5
mS
q
t
Oo
lv
$UI
cYQp
5
U-
o
a
A
"5
m5
q
'
Co
iFfv
-tUI
c,
9
QR
5
L/
:
O
a
A
":
ca
6
q
t
oi
iF{v
\f
,UI
il
9QR
5
tr
-
o
a
A
"5
co
S
q
r
cd
jv
-f
,UI
&9Qn
E
(J
:
O
a
A
"5
mS
q
r
Co
T-r
v
\f
,UI
&9
9R
5
(r
-
o
a
A
"5
mS
q
l
OO
f
co
I
&qQ5
5
,INv-
1
,
a
A
"5
c0
5
q
l
ci
J\/
ComI
&?
/\

(a
)

-{
Yr
-
O
(J
-
,
O
cn
i
-
C0
o
c
J
Co
jv
$mI
vTUo
t
X
a\
O
)
{
V-
\
,dq
K
-l
v
t
I
Ff
v
-f
,
vqRs
l
Y-
o
l-
1

I
--
'
a.
z

rO

Y
=O
o
o
eI
Ffv
$q
VT
Uo
t
!
c:
5
EE
*
T+_
(
\-
,
E
:$
t
33
z
z
z
z
N\o
oo
\o
z
rn\o(n
f-
E]JmFiloO.
rr
.
lJaF&oCr
t!JmF&oC.
'
,
A
++
-
-
-+
+
-
q3
\n\o
f-\oco
f-\oca
-t
\o
C\
\o
oo
\o
\oooca
z
z
z
z
F<

+t
a
f--f
,J
F$J
aF-f
,J
Nt-
-
.tJ
ca
f--taEc
-f
,
f-$amo
|.
n
f--tJ
\of-$tJ
-
n-
.
.z
\.
)
|.
namo
>l
-
,
t\n\naaJ
-f
,
[n
|'
naaJ
(a\n
l'
naaJ
(>wobo
63
F-
'
.
!6l:(OocO
tJ
.

tr

o\
RS
8
E
l'
!
xp
+:
O
.
t<

+-
)
5,
R
Eobo
.f
,()oo
c0
o<
INNotrL)
ad
FzHr=
ral=aoU
=€sI!Foz
=€SIJ
.
]Foz
f-d8Str
lFoz
a
F.
r
7,
2
It
B
-
4Ucn
=
rr
l
11
At
^<v
a7?$
-
u(
.
)
<U
J
\nNIJ
.
]Foz
=IJ
.
]Foz
a
r\
rr

l=
1A33
&HzdO.
&dO-
aZ
<-
E
Z,
i
4t
u
26
-U
€E4z
-(
J
z
a4
.<
E
/,

t-
t
{g
z
z
z
z
z
f.
l

E
E
26

5
al
Oca
6Oea
f-ca
6l
tn\o
O
Orn
OO
\n\n
\o\n
O\o
\o
19

N
JH
z
z
v?O
z
\ni
(nO
l'
n
(n
(nOv?
vlOV?
\nO
O.+
(JzI'F
l

J
-
;i
AE
I
V\--
i-
t

ld
ZJ
o=2
Jo-
,
,
JO.B
JO.
'
,
Ja
JO.B
JO"BJa
JC'
)
JorJa
Ja
JaJUt!
JaJUH
Ja
Ja
rd
r-E
e
!
?
?R
E
U
z
{z
U
z
U
z
U
z
ae
tra
Ei
H
RIJ
.
]
Fi
l
o=ze
rr
.
lc
orr
.
l
-&o=
Z=
o
tr
.
lc
ac.
,
.
f
ott
l
F&o=
z=
c
IJ
.
]
d,
aO-
,D
aO.D
aO.
a)
a)
ao-)
ao-
,
.
ac.
.
+L
,-
\Ei
<x

J
ra
Y

t
q=

&
.3
9
=ra-
tr
=Qv
t!
E
r
=l
\
Ow"
1
c
a
5-
.
v
l
*
2>
)
=Q.
t
t!
E
l
=l
\
O
v"
1
o
a
-i
a
fr
=
r
f
*
2,
-
l
-d
>\
o
ZZC-
,
=,
2
A?
/
Er
*
Y!
\
oZ2
n
D>
J
2c
fr
\
OE!
Ar
ca
9>
J0
4
UJ
HE
Ar
".
r

!
9>
Jo
Z
c\UJ
=r

\n
*r
n
t-
-.
O
(-
)

-,
-z
r-
l

@
*l
nor
!
(J

.<
-Z
3g
Vr
o
JO
FE
V-
6
JO4><e
+t
r\

Z
+t
\J

I
rr
l
.q
\
vYJ
z
il
O
.
-
F
d
B
z
3
fr
rY
l
\
L1

rr
(
Er
.f
,m
VS
5
U:
E
o.
A
o
o
J-
q
l
C,
A
E U
.t
-c
a
I
\J

-.
=tv*
5
U:
E
O.
A
o
o
J-
q
l
d^
-5
cA
A
t-
i
I
\r
^
t
-
cE
e
lY
-
9
|*
t
.
l
-
,.
f
.

oO
4X
o
l
/\
v
l
\-
/

A
Z,
T
5
.+oI
,-
&lO.
n
E
_V
L/
-
O
cn
A
d
c0
5
q
t
ci
:
C!U
=rZ-CJ
\J

\n

><
J
\.
)
;A
K
/\
v
t
\JrF
l

lJ
ZT
5
N(-
)
Z,

Fr
^l
\-
/

H
\-
/

\n

><
^,
/

-
(-
,
2q
K
Ar
Y
l
\J<-
r

t-
.
,
1
aT
Fa
\J
N
z-
I
\J
-
a\
J
-V\
c
=
-l
J
Zd
K
Av
l
\-
/

A
\=
"

lJ
zT
5
C\
t
r=
r

I
2.

-r
I
\J
^
-
A\
J
\/
\
o
=
tv
-
v;d
K
^v
l
\J
A
-.

IJ
ZT
Fr
caU
r<
l
At
-
Al
(J
-
-
v\
n
x
tJ

-
\-
)
2E
n
/\
v
t
\JZ,
T
5
CA
Z-
r
I
\J
-ct
s
a
*-
(
JZA
K
Av
r
\J
A
=I
JZT
5
$oI-
Cr
ct
n
=
H
V
U-
O
cn
A
"
5
m5
q
'
a!UA
I-\J
soI
C,
T
c(
n
=
-
v
\J
-
O
a
A.
5
eS
q
t
OA
f\-
J
3+
r
r3
r!JmFcc
IJ
.
]JmF&cO-
,
oo
[n
Li
lJcaFo
f-Ne\
Z
\oNN
Z
z
Z
z
z
V)

++
-
H
-+
+
-
{3
Z
z
@CO
z
f-
.NN
f-NN
\cNN
\cNN
oo
\n$
$N
ooco
F+
r
a
oo
rnrnaaJ
oo
\n[naaJ
\o
|.
nzc
'L\o\naaJ
N\o(nUJ
aN\o
l-
nUJ
cO\o\nUJ
aco
\o[n(-
)J
\f
,
\o\nUJ
\n\o(nUJ
\c\o(nJ
\o\o\nJ
qE
8x
Eoo
o
t'
tzrd
tzllzo(,
=€e!
IJ
]Foz
|.
nNr!Foz
a!.
Iz(E
o
.
l
?H
H
gi
2
a
SrI
]Foz
SIJ
.
]Foz
=€Sr!Foz
a
7\
Hl
=aa3s
z
z
z
z
z
-Z
\<
E
/,

-t
{g
z
ddo-
,
,
&dC-
rd
E
d
2E

s
t
=A

$
al
O\o
bf-
\n
Oc\
6N
6O\o
\o
N
Ooo
6Ooo
arn
f-
lE

N
JH
O\f
,
rn
rnO
v?Ov'
)
v?Ov'
)
v'
)O
vr
)
z
z
z
z
(Jz:FI
J
Fr

;.
i
Al
r
l
Y\,-
!E
l
ZJ
o=a
;Ja
Ja
Ja
JaJUIJ
.
]
JaJUI!
JFr>)a
JUrr
l
JFr
Jpr
JOr
Ja
r{
'r

ts
l
E
Z
!
i
1R

E
U
m
mn
mi
et
U
z
z
z
z
ri
I
ao-
H
aO-
.
rD
aR.
,
aO.D
aO-
,3
aA
ao.
.
.
oIJ
.
]
F&CE
z=
o
rr
.
l&
or!
-&OE
z6
/
rr
.
l&
cI!
F&oqze
IJ
.
]&
ao.
.)
+t
A\E1
<X
.
l
ra
Y

or
l=
do3
S
=\
ZH
ui
=+<d
LC
JO*><c
FE
v6
JO
z@5*
(J

.<
8f
r
,
Ew
t=Vr
iE

uz
i
k
=
5_
a
U
n
g!
.
r
;
t-
.

F:

F(

/1

F{
^,
/
-
)
l
\
J
lE.
z
I
U
S
-'
O
<
Z
3E
a
=
A,

c\
(J

\o
Y-
tVr
o
.r
OE>
<&
3g
Vr
o
JO4><i
l
\o
d,
a
F/
A0c
(J
nz1
hr
=<Z,
>
&
&Co9q
+
A
t6

ce
r
JO
&Oo
9i
l
S
At
n
c
a
JO
l-z,
XX
Ir
.
l

I
FS
-'
l

;
tt
r\

z
+t
Yl
z
r-
l

0.

-
F
d
B
5q
X
ra
E
lr
$oI
CTC.
r
,
=
7\
-
V
\J
_
O
a
A
"5
mS
q
l
Oo
J
$nI
&!C\
n
=
-
\J
-
O
cn
A
"
5
ca
S
q
l
Ca
T-{
v
c\
l
I
,t
n
ty
tc.
.
n
5
U=
?
:t
r
l
A
o
o
m5
N
co
T5
CA
=rZ,

r-
I
U^
F
<oE
e
fV
-
\
J
)-
a
.
lzq
K
Av
l
v=4T
Ff
ca
Z-
r
I
\J
^
-
.
c6
?
tv
-
v
l+
{

I
4X
o
t
!
\J
AZT
-f
ca
-lZ
,-
r
AIVa
-
l
rA

\J
v\
o
r
r
rl
-
q
,
2A
K
Av
t
\-
.
/

A.
ZT
F{\,
$nI
dTQ!
5
U-
,
o
.,
e
A
.
5
mS
q
l
OA
I
F(
v
$cI
,_
il
lo(
n
=
F(
v
\,
/

-,

o
:y
r
A
"
5
tr
5
q
r
OA
I
Fiv
$I
&T
9x
5
UN
?
AA
,
o
o
mS
q
l
oi
TF{v
-f
,
&+
Cc
a
=
UH
E
V)
j
.
o
o
mS
q
t
oi
i-fAIJ
.f
,
Z?OT
\<
t
!
-
.
t
z.

c/
D

.o

e
&)
o
t
Y
H9
p
r
y
'-
l

O
Ht-lJ
-

t
coN
2+
t
e
ri
3r
z
z
z
z
z
\oco
z
rr
.
lJmF&oO.
rI
]JaF&oo-
,
,
r!JmF&oo-
,
,
\oN
a+
L
-
-+
+
-
i3
oo
cO
caN
ca
\n
CAca
caco
.tcO
\ocO$
z
z
z
z
F+
r
a
a\o\ornJ
f-\o\nJ
oo
\o[nUtr
lo
o\
\o\nJ
ao\
\o(nJ
f-\.
)J
f-\nJ
Nf-\naaJ
;ICA
f-\naaJ
cO
f-\naaJ
\oJII
N$C)oodO-
,p()63
IL

tr
O
\
i-
1
E
5
E
l'
?HP
{:
O
.F
r

!l
8x
Eobo
ca$Obo
cdAINc!0)L)Cd
Fzri
!ra=aoU
uB

o>
Zi
-
Z
X
"
-
.,
i
l
2
9
?
C
H
-
Od
Z
t
t
)
1
1

A
>P
-
F
E
&o-
lJ
-

?
m=
A\
Oz)<t
r
Fa
&of:
.
,
,

IE
>9mc
,
OYzt
<
fr
.
.
.
Fa
&oIJ
.
.

O
>g
tr
oo:
ZJ
<
rr
.
'
(
Fa
tr
.
lFoz
3€r!Foz
ElFoz
HFoz
Er
d
eo3s
FaJ<
-Z>g
q6
-Z>g
{E
&z&O-
,
.
\<
r
a4
<,
t
8
',

t-
<
4t
u
26
-(
J
-Z<E
z-{E
HE
H
^Z>g
{6
tr
]

E
d
2E

s
?
=a

$
al
i\o
\nf-
bO
O
6f-
f-
\o$
i^
,
\a
o\
co
\oN
TE
N
z
z
(nO
v'
)O
\.
)
\oi
\n
(r
)
i
(n
v?O
ozIil
F
l
OF
L/
-
ir

fr
l
ZJ
c=a
JA.
rB
Ja
Ja
Ja
Ja
Ja
Ja
Ja
Ja
Ja
t{
7
't
-E
Z
!
?
?P
E
U
U
z
z
z
z
z
Z
z
z
z
?1
.

A
5E
1

0.
Ei
E
aci
ac.
,
.D
V)
aO-
'
,
aC-D
ao.D
aF-
'
.D
ao.
.
.-
ac.
.
H
aO.D
+t
=z
<x

J
cl
Y

n
tr
=

d
o3
s
li
\ZH
tl
Hg
s
"
-
oa
c
-
,
(,
0
<
T
a?
p
S
mY
Z
c
,
>2
,
?
&
XY
tr
.
l

u
-$
ii
l
IL
'I
.XX
t!

L/
'r
FAa
IJ
-
,
XV
r!

(J
-SJ;
fJ
-
,
,
XH
t!

L/
FS
-l

d
tL
xv
I!
U
'r
FAa
tL
o'
\Fr
O
O
:t
r
z
t
J
q
rg
E
r-
,

Ir
l

E
'r
a
Z
I!
o\OIc
B
rH
r
g'
.?=r
-
<
>
E
O.=E
l
r-
{

&
x5
a
fi
8
i
FZ
Jr
!
tJ
.
'
.
ooF{
n
o
E
Z
rr
.
l
il
8
8
e
fr
l

=
't
a
Z
lL
.
+t
r\

z
+t
\/

I
ri
Y'
.
]
z
tr
o
-
k
i
F
d,
,
z
R
s
>r
i
c
i
Er
$
l.
<

?
or
n
rc
r
.l
-
a-El
8
U-
f
"
5
cn
B
q
t
mA
c=
5
$
Z?OT
=.
E
l
-
$
z
cl
D

.r
"

o
d.

D
i-
i

?
HB
p
r
y
r.
'
l

C
--
u.

I
caN
ca
z?OT
.<

[.
]

.f
,
Z,
U
D
c
o
Q
c,
>
q
r
Y
H8
p
r
y
FI
O
r:
.
T
CAN
ca
z?OT
=t
!
-
.
t
z'
v
o
c
n
P
MJ
q
I
Y
Hg
s
r
y
JO
tr
T
caN
&ci-

CO
3a
3HFDFO
X:
E
rl
Jz
&ol-

eO
Z-C\
n
yr
-
CH
F:
)
FC
X:
E
r!z
rr
.
t

S
al
,
)-
I
\J

=+
tl
-
A
+.

aa

\-
/
\,
A
zn
:
cp
K
<i
(
lZ,
O
I
l-
(
I
tr
s
r!

>t
aL
l
I
)-
r
I
\J
+
H-
:
.J
J

a-
\

\J
-
\
,
A
zq
:
cp
K
=<
(
lzo
f
l-
t
I
tr
R
-'
.
$
vlo
\.
/
F(
jI=
s
rr
.
f

N
?
fr
p
r
y
FO
JT
tr
R
zq
CT=H
;
E
;L
i
f
o
.
t
Y
59
p
n
r4
f

I
JCtr
i
l
g+
t
i3
\oco
\o
CA
f-.t
-t
\oco
\oca
l.
n
o\
oo
l.
n
O"
(n
o\
\o
-f
,
l.
nc!
\nca
\o
a
-+
{
_
t+
LZ
ri
ir
z
Z
\nca
cO
o\
(.
)
co
z
z
O.
O'
.
O.
O,
oo
F+
r
a
\or-
O
|.
^
<r
^
z,
'
r
F
m\oJtr
-
,
U\oJt!
n\oJtJ
-
Utr
.
l
\oJfJ
-
'
,
Ofr
\oJLJ
-
c\
\oJlJ
-
ca
\oJtJ
-
,
O.
\oJtL
e{N\oJtJ
<
GE
8,
q
Eoo
FzHts
lztr
lzoU
IT
IFoZ
c\
ldrI
]Foz
rI
.
]Foz
N€rqFoz
I!Foz
rJ
.
lFoz
HFoz
IJ
.
]Foz
tr
.
lFcz
3r
d
zo3s
-Z>g
*z-
(-
)
ea
4
*z
a
-u
Q
-Z>=
*z
-(
J
ri
a1>g
*z
-(
J
-Z{g
aZ{g
-Z
\<
f
t
!
,,

>l
{E
3a
4
4Z
A
-u
t
-Z>=
{g
-Z>g
{E
rd
E
d
26

s
t
=A

$
aJ
\nco
O,
co
\n.+
\n+
a\
co
\o
io$
o\
ca
\oN
i^
,
ca
dr
d
l3
v?O
v?O
(ni
(ni
v?O
v?O
rni
(n
v?O
rnO
UzI,i
J
-
;i
Al
t
v\ti

a,
tr

tt
zl
ottz
Ja
JC'
)
Ja
Ja
Ja
Ja
Jcr
'
)
Ja
Ja
Ja
ri
7
-t
-E
Z
!
?
i
R
E
U
z
z
z
z
z
z
z
z
z
z
ri
H
aO-
,
'
rD
ao.D
aO-
,
,
V)
o<
aC-
'
,
aO.
,
r
ao.
,
.D
aO-
,
.
aA
ao.
.D
+h
,-
\
->
zBE
<x

-]
cl
Y

or
Et
r

d
.3
s
LE
(
oo;o
f
i
XH
E
H
-a5-
>
E
&O
r:
l
o&OD
,-
,

A
*3Er
u
t-
,

Z
J
IJ
.
]
fJ
-
,
f--'
.
O

O
lZ
t
t
)
t8
E
r-
,
.

tr
l

E
lt
a
Z
t
f-OIo
n
XH
E
E
|
:
-iHF
r
<
r
JaE
f-=
rr
.
l
h<
&
*x
A
LT
]

\J

A
fr
8
5
Fl
z
Fl

I!
tJ
.
.
.
\ol-
(
o
o
E
zt
r
)
il
8
8
t-
1

[r
.
l

=
't
a
Z
E
\oFr
n
A
:E
H
t
X
rH
r
E
:
-iFF
\
<
1z
tr
\o=r
!
&
*x
t
s
[r
]

\J

a
AV
fi
x
d
FZ
Jr
!
tJ
.
[n'-
c
o
]I
z
L
L
)
il
g
E
t_

t!
=
;c
n
Z
E
rIc
B
rH
8
it
r
=
E
uZ
x
3i
z
=g
E
\f
,
z?
^-
Yr
sr
!
-
+
7
a
co

?
;r
i
f
,
q
l
Y
il
?
p
K
't
f
r
a
JO
It

I
r+
r

cON
I
\f
,O
oo
?
Oo
o
F.
NEA
Y
X+
U
rr
.
l

"a

-!
rNEp
I
\nr-
-
$
z?Oa
Sf
!
-
.
+
=C
,
n
=
FJ
-
.
.

J
(\
l

Y
tP
p
K
J-

o
tr
3
c!
z?OTEB
F
+
il
P
p
K
:
JOE*
l\

.t
bU
t<
jHE
E
tr
.
t

Cl

y
fr
p
r
y
FC
JT
tr
R
zq
CT
HIf
N
Y
t?
p
K
E
JOE;
zq
Ol
=H
s
E
;r
=
)
o
l
Y
I8
p
r
y
tr
3
\O
n
O\
J
Fr
l
Is
x
fr
J

qr

Y
ff
i
p
r
y
FO
'l
-
I
7c
o
r*
.
N
cr
l
Z?
CT=B
s
i
;I
f
N
Y
tP
p
x
't
f
r
r
JO
-atJ
.
,
,

"AN
z?
CT=H
$
i
I]
O
Y
t?
p
K
*
JOE3
E+
r
33
f-|'
nc!
\oca
\o
(aN
f-Oca
N\o
\ocoN
ooca
ca
\o
O,
cOc!
a
.+
L
=
-+
+
-
q3
O,
oo
O.
oo
oo@
oooo
oooo
\o
\o
\o
\ooo
\ooo
F+
r
a
CON\oJfJ
<
O,
c!
\oJlJ
-
c!
ca
\cJLJ
-
caca
\o.]
tJ
.
,
.
O,
CO
\oJlJ
.
,
.
c{
-t
'\
oJfJ
-
'
,
CO$\oJtL
tl
.O,$\oJIL
c!
(.
)
\oJtJ
-
CALn
\cJIJ
.
.f
,
.+ooo
Cd
O.
r
Ic\froo
tr
.

tr

O\
os
a
f)

O-

q,
Ep
I
E€
.
t<

t-
)
5,
R
Eo)bo
(n-f
,ouo
63
O.
'
.
IC\NO()
Fztd=arl
raoU
rr
.
IFoz
rr
.
lFoz
r!Foz
r!Foz
ElFoz
IJ
.
]Foz
rr
1Foz
r!Foz
HFoz
;Foz
A
rr
r-

ir
ao33
5B
3
<6
4
U
-Z>g
{6
E
a1>=
4Z-U
ea
4
{E
E
-Z
<{
E
*3
aZ
<E
Z
t-
l
{E
HE
E
-Z
\<
E
Z,
-
{g
-Z>g
4Z
-(
J
3E
H
ri
Ed
2a

s
i
3A

$
aJ
a.
co
\oco
l.
n
-t
o\
CA
\o
\n\.
)
a.
eA
bN
i^
,
cA
aca
lE

N
JH
V?O
\n
l.
n
\a
\n
\ni
tn
\nO
(n
vr
lO
()zEdi
l
Al
=
V\
tr
-
lr
l

tl
zr
o=a
Ja
Ja
Ja
Ja
Ja
Ja
Ja
JC'
)
Ja
J0
r{
?
\EE
A
!
?
?R
E
U
z
Z
z
z
z
z
z
z
z
z
ri
H
aC-
,
.D
a)
aD
a)
ao-
,
,)
aC-
'
,
aC-
a
aA
aO.-
+t
,AE4
<x

J
eY

er
il
=

d,
o3
S
-
lr
r
P
rr
.
l
il
il
H
E
fr
E
d
FZ
I
tl
r
$-Q
a
EZ
n
il
8
8
r-

Ir
.
l

E
lr
r
r
2
E
-f
,;o
R
x#
E
-F
=
E
\f
,=r
!
rr
<

I
xx
d
,
[-
r
J

\J

n
,/
\
\
J
r'
.
Y
J
g.
]

L.
l

U
FZ
Jr
!
E
caO'-
o
o
EZ
r
r
l
r8
E
r-
,
.

El

=
lr
c
z
r
2
E
co
tr
.
l
A
:E

IJ

rr
.
l
r#
8
H
I
l
,l
1-
-
!aIJ
-
.
.
=u
l
&
x5
a
fr
8
i
F1

Z
r.
-
l

El
N-'
'
c
o
EZ
I
A
il
8
8
=H
=
tr
-
,
,
c\
lIo
B
rH
8
it
r
=
E
c!=E
l
r+
r

&
*,
x
Z
rr
r
x
o
HE
i
F1

Z
FJ

fr
l
tJ
.
,
,
+t
r\

z
+t
\J

I
ri
,A
'
\
V
YJ
z
r-
J

a.

-
F
d
B
5e
X
rf

El
lr
(n

91
OI
J
Fi
jHs
s
Er
N
?
fr
p
r
y
FO
"l
-
I
i:

co
rr
r

N
z?OT
>H
s
S
:E
5
i
.
i

?
iE
p
r
y
ET
ca
Z?
CT=H
s
E
;I
D
O
]
Y
il
9
p
K
t*
a

!
JO7T
r+
'

coN
\f
,
n
o
\-
/
-r
JIs
s
rr
l
N
Q
fr
p
r
y
FO
l-
I
;:

CN
l+
r

c!
z?CT>H
n
S
-ID
N
Y
t?
p
K
J)
*
r

i
tr
3
N
z?CT=E
a
+
59
s
K
r+
r
-
t
JOE3
cn
n
O
L.
'
r<
l
In
s
rr
.
r

N
?
fr
p
r
y
FO
l-
Ea
Itr
s
z?CT=H
n
i
J.
.
;
)
q
I
Y
il
9
S
K
't
+
l
l
JNE3
N
Z?
OT
=B
s
E
;t
D
O
I
Y
TP
p
K
JOtr
;
N
c\
-O\
J
Fr

-:
Is
E
lr
.
l

o.
t

c?
fi
p
r
y
FN
Ji
=c
a
l+
r

6l
g+
r
33
O.Oco
$\o
\oN
cA
(n\o
N.tN
co
\c\o
\n.f
,
6l
Nca
2+
r
Z
rr
r
{r
\ooo
f-oo
f-oo
t-
-
oo
N$
N$
N-f
,
NCO
NCA
Nco
F+
r
a
o\
\n\oJtJ
-
,
.
C\
\o\oJrL
cO\o\oJU-
O.
\o\oJtt
Nf-\oJfr
.
ca
f-\oJfJ
r
o\
f-\oJfJ
-
,
.
Noo
\oJt!
cooo
\oJtJ
.
.
o@\oJtJ
.
,
.
qE
8,
R
Ebo
Frzri
r-aoU
;Foz
HFoz
;Foz
os
Z
?r
'

Fr
l-

El
F
2
C
F.
r
$
H
m
5
RY
F
4
,
't
-
F
r
OC
7&
>
3H
?
E
EE
s
s
'f

;.
7

F{
&m
tr
R
"
-
qz
-
n
R<
b
Q,

1z
Fo
7)

f-
=r!Foz
=€$r!Foz
&O
,-
,
tL

tr
r
HS
3H
2r
d
1a3e
-Z>=
{g
aZ>g
{E
AE
H
z
z
z
aZ>g
{E
5E
e
x{

3
-Z>g
{g
aZ
\<
E
',

t-
l
{g
-Z>g
{E
rd
E
d
2u

s
t
=A

$
al
icca
i^
)
.+
o\
co
Oc\
ON
N
oo
6oo
i^
)
f-
[n
f-
O\o
TE
N
u?O
rnO
\n
o'
!O
otO
o!O
z
z
qO
e!O
qO
(,zI'"
/

J
5F
--
lE
dZ'
.
]
o=a
Ja
Ja
J0
Jr!a
JrI
]a
Jr!a
Jr!a
JrI
.
]a
Jtaa
Jrr
la
JrI
.
]a
H,HF
H
s
z
z
z
z
z
z
z
z
z
z
z
ri
H
ao<
ao.
oo.
.
ao.
aC-
,
.
aO-
'
,
:)
aC.
,
rD
aF.
,
.D
aO"
:)
ao.
'
.
aorD
B?
<x

t]
r.
l

Y
nr
E=

d
o3
g
5'-
,
.
o

o
EZ
L
t
)
il
8
8
r-
,
,

tr
.
l

E
'r
a
Z
E
OIc
t
il
H
8
it
r
=
tr
=
rr
.
l
r-
r

d
*x
B
LT
J

\J

N
.A
\
J
fi
x
d
FZ
l.
-
l

t!
rL
6*
S
E?
P
Z.

ll
U&
Z=ov
Y
E?
P
A1
4Ud
3v
S
E?
*
al
-Ci
r
>
UC
3u
s
E?
S
z,

t-
Ci
r
>
U&
3u
S
E?
P
z,

t-
U&
FU)oatJ
.c
FUoatJ
-o
FUDntJ
.
'
.
Or
lr
{z
r\

Z
+t
\/

1
ri
3i
3
F
d*
=g
x
z?
CT=H
n
i
;i
i

D
o.
t

Y
il
9
p
x
-r
f
a
'
IJA
iY
l*
r

coN
zq
CT=A
a
g
xH
s
*
E
JOE;
r-
l
OU
Fr
l
I
.J
-

+
il
4
3
fi
p
r
y
FC
'l

:<
I
tr
R
cn
rr
.
l

?
?T
)-
c
n
C'
o
=
tT
'
,
.

$
Y
Zp
K
OA
ts
\o
v
ca
r,
l
?
a-
I
)
-
Cn
Cl
o
?
T'
.
.

.f
,

Y
2e
n
CA
-\o
v
ca
IJ
.
]

?
a-
-l)-
c
.
)
Or
o
?
,r
.
\
f
,
Y
;p
n
OA
\o
v
co
r!
?
a-
I
J-
c
o
A.
r
a
O
\/
v'r
$
Y
;p
K
CA
.
H\oO
ca
rr
.
l

?
a-
I
J,
.
c
o
9s
B
J)
rzp
K
OA
\o\-
/
H?
2T
J
..
r

Cr
)
^i
F
{
O
vv+N
Y
2s
n
CA
\o
\J
r,
.
?
a-
I
J
..
r

Cr
)
O\
o
?
FN
Y
Zp
K
OA
\o
v
IJ
.
]

?
A'
:
I
J
.a

(f
l
Ai
A
O
Vv
AFN
Y
l*
(

!
^;
\
zp
i
l
CA
-\o
v
E+
h
33
f-\o
oo
.f
,
c\
l
caca
z
z
z
O,N
\f
,
ca
\ncA
F-
\n\n
\oco
2+
r
{3
O,
O.
O,
O'
,
c!
tnNC\
CONN
z
z
CAoo
\f
,
(nao
It
-
\o
F+
t
a
FLNo\
\oJtu
cao\oJE
o\o\
\oJt!
.
.
(,
f-aO-
omr-
-an-
,
(,Uf-aO.
Qof-a
(,
I!
f-a
Nf-a
mNOf-a
ca
f-a
\o$obo
cd
O.
,
.
I
c!C\
/
a-
,

I
OO
fr
.
,
.

tr

o\
GI
A
5E
=
I
g'
J
F.
F

o
x.
o
{:
O
.F
(

!l
E,
R
Eobo
tt
-
.f
,obo
cgR.INNOOd
Fzrdr-
rar-aoU
&ofJ
.
.
.>Em<
n8
zt
\
Fa
F(
)
=H

/,
6
r,
r

l1
l

O
f:
.

>
Fm
t
u
&
i
l
2\
3
8
"
t<
<

l-
zE
8x
l\
-
>H

F{
Ee
>
H
3*
z
a-
&o,
-
,
It6s3r
&O,
-
,
tJ
-

Fr
r
,t
CQ
o
I
l\
.
o:
^
22<d
F
gB
r
r
EF
5
k
>4
.
-
^
Za
.
r
F
H3
E
*
FU
r
-
i5

b
()
U7,
-
F
s
S3
'
b
;
E8
$
E
&A
A\
OEt
s
r
-
\
t-
{
>nE?
E
v€
z
TR
=tr
.
lFoz
2
rr
l
eaxe
l,
r
A
E
a1<,
8
z,

>-
<
4t
u
?3
-U
-Z>g
*Z-(
J
aZ
=<
E
z-{E
a4{g
3a1Z
-(
J
l-
l
aA>y
4
tr
r
?g
^Z>g
{g
2
z
z
^Z
=EZA{g
i\

I
Ei
{d
2a

s
35
8

$
-\o
\o
\o
\n
rn
-orn
6O(n
Oe!
6\o
o.f
,
6\o
ttzi*
E
N
JR
qO
c'
l

n
il

ll
9)
eJ

rn
il
l
l
9)
qO
c!
c.
lO
c\
oJO
qO
e{
z
Uz!il
:
i
Al
=
v\2a
ir

fr
]
ZJ
o=2
JLI
]a
Jrr
la
JEla
Jrr
la
Jr!a
Jrr
.
la
JE]a
JIJ
]a
Jr!a
Jrr
la
Jrqa
E]rl
rE
A
!
?
TS
E
U
z
z
z
z
z
Z
z
z
z
z
z
ri
H
aO-
aO.
aF.
'
,
a0-
'
,)
aOrD
OA-
aO-
'
.D
aO-
,
,
aC-
'
,D
aC-
.
.)
aC.D
E?
<X

J
r-
l

Y
0.
C=

&
"3
9
-
lJ
r
FUDctuo.
,
.z
FU)eIJ
-
,
,
a<
t<z
FU=atJ
-
,
.
0.
.
FUDcUJ
FU)cUJ
F(-
)ac!UJ
FUDoNUJ
5v
S
=?
*
Zl
-cu
>
U&
6"
$
E?
*
-,

la
ot

>
UC
5v
$
EY
*
Z
t-
t
Or
n
>
Ui
l
5v
$
E?
T
.2
,

t-
Ct
r
>
U&
+t
r\

z
+t
\J

I
r\
,A
\
V
YJ
z
iO
.
-
z
3
f,
.Y
H
i-fr
r
r!
?
a-
I
J
.f
\

CO
O€
?
>r
t

6l

Y
2p
r
CA,-
\o
\J
I!
?
a-
I
J
."
-
'

Cl
^
)
C\
o
?
:E
C
I
Y
zp
K
9A
\o
\J
L,
r
?
a-
I
J
.n

Cr
)
Ai
A
O
vvFN
Y
2p
n
OA
\o
v
r!
?
a-
!
J
..
7
.
r

Ca
l
^:
A
O
\J
v
,
<
ts
c
{
Y
2p
r
CA
\o
v
El
?
a-
-lJ
.n

ci
)
cu
=
C\
t
Y
2p
n
CA
\o
v
rr
.
l

?
a-
J
."
r

cO
C\
o
=
Fn
C
{
Y
2s
K
CA
\o
A!J
tr
.
l

?
?T
J*
c
o
cu
=
:E
C
I
Y
zp
K
CA
\o
A!-
J
ca
,'
I

q
a-
I
>J

_,

cO
Ct
o
?
H-
f
,
Y
2p
n
CA
H
\o
v
ca
r!
?
a-
t
J
-
cl
^
)
C.
.
o
P
+r
$
Y
Zp
n
CA
rl
\o
v
ca
I!
?
v)
-
I
J-
C
.
)
Ai
a
O
v
v
s
rr
.
l

!J
"L
)
r
ZP
K
OA
-
-ZT
\o
v
co
I!
?
a-
-tJ-
c
o
Ct
o
?
tT
'
t
Y
2p
n
CA
HH
\o
\J
9+
t
33
O.
ln(n
NF-
CO
oo
(nrn
O.NN
ca
t-
-
co
ooNe!
\f
,
f-cO
z
z
z
N\oca
A+
L
=
'+
I
-
{3
|-
n
\nCA
oo$cr
)
O,
.f
,
co
co
\o
\o[.
)
CO
$co
f-\nCA
caco
N.aco
cocaca
z
F+
r
a
!0co
f-aO-
.
.
UUca[\

.-
ct
'
l

?
4&
io
UccoO;>
f,
5
\tOf-aC-
'
,
m\f
,
f-0a.
\n
[*
-aF"
m\nOf-V)
O-
,
.
\o
f-aCr
c0
\o
f-aO-
,
.
U\of-aO-
,
.
c\o
f-aO-
.
qE
8.
R
Eb0
3Zt.
I=2r=aoU
=€.+rqFoz
2E?i
e
EH
E
i3
()
U
Zr
-
Fs
a
R
SH

b
E8
$
iB
-
dao\
Et
s
>oB1
=s
il
R
\o€\f
,arr
.
lFoZ
o\HFoz
O\
l
EIolzl
=€o\
rr
.
lFoz
Id8o\
I!Foz
a
,\
r-

lt
a
ao1g
l,
r
A
Et
-Z
<'
(

E
A=
t
*Z-
(-
)
z
z
z
aA
.<
E
z,
i
iE
a4
.<
E
z,

-t
{E
{lzl
*t
3a
{g
nt
E
l
*
H
l
-Z
<<
E
Z.
J*Z-U
aZ
<.
8
Zt
-qE
rd
E
d
2E

s
Z
-Z

cJ
A
)-
l
\o
a\nca
i\nca
^\neA
ocoN
^cr
^
)
6l
alolol
-l
blOI
-l
a
bl
ol
-.
1
GO
.
=r
Ii
N
z
o!O
6lO
c{O
z
z
ol$I
il
ol
.q
lol
\o
ol
u?
l
ol
\n
v?O
UzI&:
i
AE
t
r
l
v\tr
l
-
Fr
r

lE
a
Zl
]
ol=a
Jtr
.
la
Jrr
la
Jr!a
JE]
rJ
r
)
JIJ
.
]
(r
)
JEla
JIal>l
JIal>I
Ja
JI
o.
lldl>l
Ja
Ja
ri
?
\tE
Z
T
?
tP
E
U
z
Z
z
z
z
Z
UI
(J
I
()
()
!
Q
U
ri
H
a
a:)
ao.
a)
aO.D
aC-
al3l
al
o-
l
)l
a
al3l
aO.3
af,
+t
H>
,ee
<x

F]
ra
Y

or
e=
d
o3
g
ll
5v
S
=?
*
z,

t-
l
Oi
r
>
UC
z=cv
v
EY
p
z.

l-
Cm
>
UC
5"
S
=?
*
z.

l-
Oi
r
>
(-
)
&
5v
$
=?
p
z,

t-
Ci
r
>
U&
6v
$
=?
p
z.

l-
Oc
n
E
U&
5v
s
=?
*
Z.

ld
Om
>
Ud
"i
l
ol
EI
E
I
=
E|
H
I
i
I
,\
o
=J

6q
,i

I
\J

C\
E=
LL
l

=-
,
.<
2
4^
/
Hl

:l
rl

Ol
?l

1
el

3l
8l

dl
>t

=l
$l3ol
;ltr
l
(B
l
-\
o
t-
l

6q
l-
l/

c\
lr
l

.-
>a
.\
o
-.
1

cO
4-
i
,t

r
\J

C{
o=
!!

.=
,
>a
:t
t
r\

z
+t
V
I
rr
1
A\
\
r
/YJ
z
:-
l

O-

Li
F
d,

B
5e
X
i-Ir
ea
Er
+
a-
I
J-
c
.
r
C.
.
o
?
-r
.

$
e-
Ip
r
OA
-\o
\J
ca
I!
?
a-
I
j-
e
q
6r
a
O
vY
-
-+

l-
J
I-
\
l
,^

CO
ZF
l
q
r
OA
H-
z.

I
\c
v
ce
EJ
?
(t
)

*
t
J-
6
a
,
Cs
Q
'r
-
!
+
Y
2p
n
CA
H\o
v
ea
t!
?
a-
I
J-
(
r
)
Oo
P
.r
$
Y
Zp
n
CA
EZT
\o\-
/
ca
IJ
.
]

?
a-
I
J,
c
,
-
)
9s
8
..
I
.

lr
zp
K
OA
\o
\J
c.
)
Er
q
a-
I
J-
c
.
)
9s
8
Jl
lzp
K
CA
\oO
olul
.,
H
l

=t
?l

ul

Hl
EI
E
I
H
I
zl
-
l
ot>I
at
,'

Hl

=l
Et
E
t
H
l
Zl
-
l
ol>l
4
r\
CYOT
,\
o
o
o
-c
o
O
l-
^?"
i
J
(-
)
o
N
H!-
leo
I!
T
\<
$
Z.

Fr
cl
rr
l
I
IE
I
,r
A
l
?l

ol
al
z
l
il
8
1
>t

itzlol>l
oo
l
ol"lmIqlql
$l
'-
l
6?9.
;
-C
Q
O
J
-'
O
<c
\
.
5
(-
)

o
c.
l
-F
{
lOO
tr
l

T
Z.

-.
r<
r

$
-?

r\
cYOT
^,
/

\O

oO
-c
r
)
O
'l
-
a
>-
a

\J
<c
\
"
5
UC
C
I
--
.

I
oc
I!
T
Z,

-r
P+
r
33
ca
\oco
Z
z
Z
f-f-t.
)
oc
f-\n
f-
lol
oo
!
oo
l
ol
rc
l
co
\.
)
\f
,
;l
f-f-cA
\o
f-ca
2+
r
{3
z
e!
ca
.f
,
caca$
$cO.f
,
z
z
3a
"l
.
lzl
a
>l

>l
II

3I
O.O,
ca
3a
\oc!
$co
F+
r
a
r!
\cOt-
-a
f-f-aO-
mf-f-a
Uf-f-aC-
.
r
of-t-
-aO.
IT
I
f-r-a
3l
JI
c0
l
.+
l
-l
.f
,o\aIJ
.
]z
VI
$l
-l
\f
,o\orI
]
O-f
,o\oL!
o\
l
ol
r!
l>l
g\
lEI>l
o\
l
OI
rr
t
l
>l
oo
\f
,C)bo
63A-!C.
l
NC)oCd
tt

tr
O
\
UE
=
P
H'
d
E€
.F
(

IJ
EX
E0)oo
o\$obo
cooiINNo()cd
3zri-zr-eoU
()
>
zi
l
ca

xo
rr
.
t

z
z
(-

v
F-
)
2s
3
Hg
(,
>
-A
E

=
Hu
3
r
,
23
S

e
HP
-
C{Nrr
.
IFoz
NNI!Foz
oh

e>
i;
L
f
r
E

3l
>
P
t-
.
.
5
2f
f
s
96
s
Ei
2
2F
s
96
n
ai
9
2f
;
s
9t
p
ai
e
o<
-
\n

d,
Hf
i
22
^2Hf
i
22
^9E32;
EE
d
aa33
-Z>g
{E
-Z>g
{6
&cO.
Fat
J-
l
&=zilO-
E{
aA>g
{g
^Z>g
*Z
tJ
t-
(
aZ>=
{6
Fl

E
d
26

s
i
=A

$
al
6\n
rn
6f-
f-
6O
N
N
c!
\n\o
i^
)
\o
h\o
TE
N
\ni
v?O
z
z
z
z
z
z
(ni
\aO
\r
)
i
ozI'F
l
.

J
-
;i
t.
E
J
\J
iF-
lr
(

tl
ZJ
cts
l
z,
JF-
'
.BJa
JO-
,BJV)
Jo<
JF.
.B
Jo<
ts
Jo<
J0.
,
,
JO-
'
,
ts
Ja
Ja
Jo
hl
?
'l
-E
Z
!
?
?8
E
U
o
c
o
c
o
o
o
o
z
z
z
rE
H
ao.
.
aO.
,
,D
aC-
,
.
aO-
.D
aF<a
aa
aA-
,a
ac.
,
,a
a3
ao.
l
aD
+h
Hl
zee
<x

']
ra
Y

er
c=

d
o3
S
-
Fr
a-
lnr
i
oc
o<
()
E
l
zco<
?i
l58
C)
a
EScc
c<
or
!
zc
c<
?c58
C)
a
Fa<F
:
XX
[!
-
6la
Fa<F
:
>J
<

-
il
E
Na
aCUcz
8E
Zl
-YZ
f-
r

L.
/
b>
U
il?A.
'
,
ts
p
f
i
.<
r
n
E
U
&O-
,
.
Bp
f
i
*<
r
n
E
U
?C-
'
,
ts
H
f
i
<'
,

cn

E
z>
<
U
F
&Q
u
33
3
rr
.

Xa
F
&?
u
33
3
f:
-
,
,

X
7)
F&2
u
Hi
?
='
l
.
.
.
F
f:
-
.

X
cn
I!
+t
r\

Z
+t
\J

4
rt
rq
\
VYJ
z
rl

O.

'i
z
3
1
-t

Y
;-
i
fr
a-
l
*or
i
4
Od
-
c<
i
U
rr
.
:

3
5?
*
F
C.

A
r-
r

A
lJ
bE
f
UC
N
.
:
E#
4
cc
+
c<
i
Uf
r
f
S
5?
t
?&
A
5P
=
um
.
:
?E
:
bv
o
l
..
A
O
I
VZ
a
c4
i
r
r
q
=F
n
Aa
a
-s
3
?i
:
I
VZ
o
o
gu
r
E-
a
ft
n
a
Ei

c'
)
cD

-+

.f
,
o;
m
cE
-
,
.
c<
i
Ur
,
r
8
6?
*
?C
,
A
Lr

,a
,

t-
.
1
oE
f
u(
,
,
]
coUml
Ar
4c
t
gt
?
Ao
o
i<

6l
9A
C{
CAU
m,
,
A!Z.
g
gl
?
Am
;;

c!
?AZ=
C{
coU
,Y
\

I
aa
z,
qut
?
/1
o
o
;J

C\
aA
'7

lJc\
(?
T
ZOEH
q
\J

'-
r

oO
FX
o
t
2Y
,

A
cT
<r

\f
,
a$
()
T
ZOEB
q
(J
r
o
o
iH
l
oT
r=
.

.<
f
a$
()
T
ZOEH
q
\J

-)

oO
FX
o
l
zf
l
4
oT
\<
<

\r
z$
3+=3
CO
\oN
oo
.f
,
f-ca
ONca
rr
.
1JmF&co-
,
,
CA$$
Noo
(n
\oco
.f
,
.t$
f-F-N
f-\oca
A
-.
'
+
-
ll
l

'+
+
-
{3
cO\oN
f-ca
z
z
z
Z
Z
Z
caO.
co
F-
f-N
-fcA
F+
r
a
\oOO,
caO-
,
.
\oO,mz
NO,
(r
)
N5aB
f-5g>
io
\no\mo
(,
tnO'
.ma>,
[nO.mar<z
;o\JO
zl.
nO,JU
I(nO,JU
Gf
i
H-
o
..
.
Y

'o
.
tr

.l
-
)
8x
Eooo
FzHlr
lzoU
ao0.
.oz
NN€=r!Foz
a&on.oz
ozr-
N
'e
!
rr
.
lFoZ
a&oo.
.oz
a
r\
H
lE
l
zo3e
&dO.
&zdO.
.
cC-
&l-
rzcO.
&!.
rz&C-
az>g
{E
-Z>=
{E
&r-zdO-
-Z>g
4Z
tJ
rd
E
d
26

s
i
=A

s
al
6[n
brn
\n
tn
[n
O\n
6caN
Fa
c.
l
tac{
i^
)
eo
(ncO
tnc{
6|.
nN
tne!
19

N
l3
z
z
z
z
z
z
z
z
z
\ni
z
v'
)O
z
|.
ni
()zI'r
l
.

J
5F
tr
-
l-
l

lJ
{
ZJ
cr-a
Ja
Ja
Ja
Ja
Ja
Ja
-la
Ja
Ja
JOrJa
JO-
,
.>
Jo.
,
,Ja
Ja.
lB
JOiBJa
ri\l
iE
e
!
?
E
P
E
U
z
Z
z
z
z
z
z
z
z
o
o
o
o
e
ri
H
aC-D
a
ac<D
ac"3
aC"
a
aP-
,
,
aor
:)
atu
aA.
'
,
aD
aO-
,
.)
ao"3
ao.D
E?
<x

-]
ra
Y

0r
e=
d
.3
s
tt
!n
=
*L
:
J
"
EE
+
\
-(

1.
.
{
l-
l

q<

-
i.
z
L
!o
-
,
.
EE
i
r
t-
l

)-
a
r-
l

q<

rr
i,
e
L
In
=
*H
-EE
(
I
l-
r
)-
{

\.
r
i
zt
u
oo

/1

c\
MH
=
El

o
_'
f-
r
n
F
'r
H
l
|-
l

r-
.

l-
{
-
l-
r
IJ
-
,

Z
lJ
-
,
oo

/1

c\
,
-
A
MU
.
I
Y
lr
l

6
-r
t-
,
A
F
'r
H
\
=r

l-
i
{
I!

Zt
u
oo

tl

c!
dr
!
Y
r!
m
f
t-
l
n
F
'r
H
l
!
r-
.
=r
tJ
-

zf
u
oo
n
e
o
0(

Ir
.
l

=
El

m
_.
F-
,
,

n
ts
'r
H
l
>J
-
t-
(

!'
'
a
Ir
-
,

A
fu
to
A
c
o
,
-
A
F(
r
!
=
lr
l

Q
-,
tn
l
)-
J
H
H
-t
s
!
H
tJ
-

Z
lJ
-
,
\O
n
e
o
o(

rr
.
l

:
El

6
-r
qA
i
!
r-
r

)-
.
-r
F
H
lJ
-
,

Z
lJ
,
a{-a-
'<e
c
m3e
a-<d
,
o
N*t
n
a-
Z=
r
:>
zuc
N*f
naa
\<
3A\
=Bt
c\+f

\n
a=
=rZ\
<Ba
+t
r\

Z
+t
v
I
r:
1
,-
\
\
vYJ
z
iO
r
-
7
3
fi
tJ
:
d
l-
a

El
tr
f>
l

-
Yr
ZOEH
q
\J

'-
r

OO
FX
o
t
2Y
,

A
cT
<<

\d
:
2,

\f
,
()
T
ZOEH
q
\J

'-
-
\

oo
=s
j
oT
-S2$
ri
-YrZOEB
q
\J

-)

OO
FX
o
t
zf
l
4
cT
=i

.<
f
2.
f
,
,tVr
ZO
f-
'
!

r'

r
(\
*d
=
\-
/

'-
r

OO
FX
o
t
2Y
,

A
oT
\-
s
Z,

.f
,
()
T
ZOEH
q
\J

-r

oO
FX
o
l
zf
l
A
cT
<r

.<
f
2,

.t
UT
ZOEB
q
(J

-r

oo
FX
o
.
l
2Y
,

A
cT
!-
r

.<
f
2,

.f
,
()
T
ZOEH
q
LJ
-
r
m
FX
o
t
ZY
,

A
cT
\-
s
z$
()
T
ZO
r'
r

(\
tV

l+
{

r-
!
\a
-
i
LJ
r
o
o
f-
'
,

X
c.
t
zH
d
cT
=r

.<
f
Z.
t
()
T
ZO
ts

r,
r

(\
*f
r
=
\-
/

-
oo
FX
o
.
l
zf
l
A
oT
r-
r

S
z$
I
f-
O
-r
N
3t
*aETQa
LJ
r
$-t
I
f-
O
-.

O'
l
1l
*@pqQa
ur
$$
I
l-
-

61
rO
O
C
o.
t
(J
n
\J
;
-t
-f
,
I
f-
O
-N
gl
*@Eq
co
LJ
t
.f
,
-f
,
I
f-
O
-N
1l

,/
t

OO
Aq
9a
L.
/

t$$
a
++
-
-
-+
+
-
=3
\n.t
.+
\oco
.t
oo
f-c{
\o.f
,$
f-cA
\f
,
ooc\
f--f
,
.f
,
ooea
.f
,
Ot
f-c{
f-\o6l
$(n$
(n
\f
,
\n\n.t
o\
\oco
a+
L
=
rt
r
{3
z
z
z
z
z
z
z
Z
z
f-\oN
z
tnO.
an
z
rn
\f
,
co
t<

+t
a
c\
\nO\JU
(,Nr.
)O.JU
N\noJU
ca
\nO.JU
()CA
(nO.JU
CA
\no\JU
-f
,
(no'
\JU
(,
-f
,
\no\JU
-t
tnO,JU
-f
,
f-o\J(-
)
-ff-o\J()
ooo\JU
(,ooo\JU
ooo\JU
[nobo
cd
O.
'
,
IC!C\C)C)d.
fr
.

tr

O\
os
e
r)

o-

q,
Er
?E€
.t
<

!)
8,
q
EObo
tnobo
cg
O-
,
.
INNoOCO
Frzfr
]
tr
lzts
tzoU
F-
p
H#
22
aon.
.oz
c!
9
il
^
<
Fi22
r-
p
Hf
i
22
a&cC-
,
.oz
DF
22
nZa^f
-

n
tf
)

Fi

a'
l*
r
Eo
bz
z
oep
,
1r
-

3
\r
)

!-
{

A.
Po5z
z
Oq4x
EEOZ
z
2Hao3e
-Z>g
*Z-(
J
!'
r
aA
Zr
i{a
-Z>g
{g
F{
aeqa
aZ{e
*Z\U
z
z
z
r{
E
d
2E

s
?
3A

$
al
.
]
_333
6Oc!
N
\nca
\n
\nco
O
TE
N
q
(ni
|.
nO
N
to
tno
cl
(n
v?O
()zI'F
/

J
-
;i
At
=
v\,-
i-
r

fd
zt
o=a
JC.Ja
Jo.
tsJa
JA.B)ct
)
JC.
'
.)a
J!.
,
.BJa
Jo.
.Ja
Ja
Ja
Ja
H?
-l
HE
Z
!
?
TS
E
U
U
U
U
U
Q
U
z
z
z
rE
e
aCr
ao.
.
aF-
,
,D
ao-
,
,
aPrD
a
a:)
aF-
'
,3
aC.3
A+
t
E1
<x

J
rr
]
Y

Fr
4=
d
o6
S
F{

-!
AF
tt
co<=
J-
,
pE
?=
J
!-
{
pE
?=
l-
,pE
ea
\<
rzilJU
:cod,J(-
)
:c,JU
f-&c
^o
-Ua
f-co
^O
-
5a
r-
l
Fr
C&c
ga
+t
r\

z
+t
\J

-4

rr
r
.^
VYl
z
iO
r
-
r.
.

d
B
5q
X
ti

t{
tr
I
f-
O
,-
N
-O
gl
^.
/
t

Q
Hq
co
\J
I
s-f
,
F\
I&K5eu+
-+
I
f-

cr
t
rO
O
d
o.
t
OA
L/
5
.t$
I
l'
-

o,
t
rO
O
C
ol
OA
u=
$$
I
c-

cr
t
rO
O
C
o'
t
CAUT
.f
,
-f
,
!
r-

c{
rO
O
CNOA
I
\f
,$
I
t-
-

Noo
d,

C\I$$
I
f-
N
oo
C,

c!I
\f
,
-f
,
IN
c?
A@S?

ol
(J
i
I
.t$
E+
h
33
F-N
Nf-N
\n$
-t
f-c\
(n
f-c!
Nrn$
z
z
z
2+
t
q3
f-N
Nco
\oo'
\
cA
$f-N
O'
.
co
f-O.
co
O.
ca
ooaa
ooO'
.
co
F+
r
0
I@o\JU
NooO,
JU
caooo\JU
()
-f
,
ooO.
-]U
rnooO,JU
\oooO,J(J
a()
f-ooO.JU
V)
ooooOt
JU
aO,@O'
,
JU
GE
8.
R
Eoo
azo-3Fla()z-toFr
l-
(zoa-
\
YF{Fdt
Fzrdr-aoU
caNI!Foz
83
i
l
Z
O
H
ag
z
CONElFoz
caNI!Foz
coc!
rr
.
lFoz
coNE]Foz
cac!
rr
lFoz
RX
Fl

rr
.
l
H
f-
{
obZZ
a
7\
:I
l4033
ae$Z
\U
ae
{a
J
a
=.
1
?#
i
l
?a
i
IJ
E
J
a=
*?a
i
l
\_
/

E
aa
{a
ae
{a
aZ{a
a4{a
ri
Ed
za
s
t
=A
$
aJ
i^
,
o\
i^
,O,
ON
ca
bN
Oc\
\a\o
O
IE
"
(n
v?O
\ni
\.
)
i
v?O
\n
U?O
U?O
ozIil
:
l
A
Ii
E
{
v\3-
Fr
(

El
Zt
]
o=a
Ja
Ja
JO-
.Ja
JcrBJa
JC-
'
,
tsJa
JO.
.
.
tsJa
JO-
.BJ
.a
Jo<Ja
E]rHE
Z
!?
T
R
E9
z
z
U
U
c0
m
U
U
ri
H
aO.
aAD
aOr)
aP-
,
aO.
aO-
0O-
,
aO-
,D
It
Fi
<x
J
et
Y
e
r
d=
d
o3
s
-
tL
FV
i
l
FF
r
=a
d
io
'
&tr
l

A-
FV
D
t3
t
?'
a

il
Fi

9a
co

fu

H
E3
=
i
o
oH
N
9a
co

A
r=
i
E3
=
{
o
cH
cO
EJ
3?
(r
,
CA
tl
l
={
(,
co
W
\O

:E

f:
Fr
l
'
V
F
o
&:
co
a
iz
?
t-
{

a
tq
BA
5
-r
+
(
A
?H
q
:*
U
o=
z
Ar
!
uU
I
3
iz
=3
8
V?E

H
,
LJ
r
h

r
fr
a
=
=
t-

r/

i
OO
Jl
+
{
t
tr
E
"
a
A
rt

N
V?7

il
L,
(
.
r
h
r
'a
e
-
Y
-
.o
-
A
fr
a
=
=
)-
J

)+
r

I
E
P
"a

e
rd

N
x
E?
2
;
e?
3
3
dE
=
3
>)
t
N
.tm
N|
.
/
j
.
T
t
r
co

\<

\J
:
e7
,
5
R?
3
3
\J

-.
\

M
JA
:
]
-
i
ot
E
=
)r
N6t
'.
f
o
*Ase
Z
E
R?
3
3
V=
\

M
J|
,
'
-
)
Y
o*
6
=
-
I
-t
NN
-f
,o
-a
e7
,
5
R?
3
3
V=
\

M
JA
:
I
Y
cR
6
3
>)
!
Nc{
-a

X
s?
2
5
R?
3
3
V=
\

M
Jr
/
l
'
l
?
UR
6
9
>)
l
N
-a

X
E=
Z
E
P?
3
3
v
-r
\

t-
r

M
Jl
/
l
-
)
:
ii
o
-
=
o
v
i'
-
i

lr
l
i-
i

>)

IN
a
.+
+
_
=+
L33
o\F-
|'
n
oo
\n
caoo
\n
f-N\o
O,
co
\o
-f
,
\o
-f
,
\o
\f
,
\o
a
.+
L
5
.+
L
{3
f-ca
-f
,
ooca
-f
,
\f
,
.f
,
C\
f-$
tnoo
-f
,
\ooo-t
t-oo
\f
,
f-oo$
F+
r
a
ZIJ
.
]F
mOzrr
.
lF
$zt!F
[nNzrqF
Ooozr!F
ooZr!F
Ioozrr
.
lF
aOooOzr!F
c!
\oObo
cdO.I
c\6l
/
-r
lC)o
./
IL

tr
O
\
ct
!

a
i.
i
8
5
5
r.
t
F.
F

o
Fi
A
,^

r!
{:
O
.F
a

U
8x
Eooo
ca
[.
)0)bo
INNO()CS
OzoF{Fr
t-
(aUzl-
ltoFr
l-
{zo=a/-
\
YF,
'
(
rd&
EtzH=a-2oU
coNtl
lFcz
caNt!Foz
ca
$
c{
N
tI
]

t!
FFoc
zz
ca

.f
,
NN
tr
.
l

t!
FFcozz
RX
!q

r!
F
f-
r
cbzz
coNi
\
Fr

El
F-obZZ
co

..
f
,
NN
rr
.
l

tr
.
l
FFcozz
ca
$
c{

c\
lr
.
l

fr
.
l
FFoozz
a
7\
tr
(

lE
ao33
a#Z
\U
a{a
zi
;$Z
\U
aZ$z
\U
aZ
ia
a#Z
:U
a4
Zr
i
4
fr
-
'
.
?6
-(
J
a{a
F]
E
E
2U
5
I
=A
s
AJ
i,
l
\o
O
i^
r
oo
\n
\noo
\noo
dt
{
4
>N
JH
U?O
(n
ar
?O
rnO
\nO
l.
n
\n
\nO
()zIil
i
A
IJ
E
I
V\,-
i-
t

ti
Zt
]
cEra
JO-
,
.BJa
JA-
'
.BJV)
JOiBJa
-]
A-
'
,BJa
Jp.
.>JV)
JCrJa
JABJa
Jo.
.
-]a
qe
-
e
-H
3
U
U
U
U
U
U
U
U
ri
H
aC-
,
a
a)
o)
aO.3
ao-
H
aC*D
a)
+t
Fi
sF
d
4=
&
"3
9
li
fzi
tl
€i
1

X
_7
VoE
q
32
i
EF
U
op
,
q
cc
a
iz
?
-
a
t-
r
]
co
t
1
&
\o

a
f,
--
Ac*
o
3V
d
oY
z
z-

t!
aOE
J
a*
|-
t
CE
D
^F
A
Y
r-
,
/

A
E9
i
=Z
3
tr
.
l
co
V
\o
,
r
r
x
-:
-
r
\
-
/
=c
\.
/
J

l
ac
a
JA
-r

a
tr
-
]
ca
n
E
,
?a
O
rr
-
'
,

O
f-
<

I
\-
/d
-a
Z
cn
V
\O

FT
r

t:
-
\-
/
\J
J

.]
ac
&
-l
A
-
a
IJ
.
l
ca
O
&
\o

a
3
-acF
c
35
d
9c
Z
aE
l
:f
h
7\

z
+t
\J

1
ri
,-
\
\
V
Y
Jz
i
0r
=
F
d,
7
3
fr
,J

Y;
A
ri
-
tr
r
.f
,o
Fr
A
is?
2
=
i?
=
=
V-
\
MJ:
/
l
-
r
Y
cq
E
=
--
)
t
NN
a$
r
v
R?
N
d
V
rr

I
J
ci

l/
Oo
-
Z
=
Dn
5
I
ao

r-
.
s5
a$
4-
R?
N
X
Vr
h
lJ
a
v
OO
-
Z
=
-lao

r-
i
:5
m
aS
<l
Y
8?
N
+
Jo
D
S
/
OO
-
A
=
rf
,
^
5
-co
Js5
m
-f
,o
a
cn
s
U

I
R?
3
3
V-
-
\
-
M
J:
,
-
)
?
cq
6
=
I
IC!N
\f
,o
-v
)se
=
E
R?
3
3
\/
=\

M
J.
r
'
]
-
?
CR
E
s
-r
'
I
C\N
"\
oo
-
a
i
E=
*
x
Lr
/
E
l
iP
*
s
\J
=
-
EJ
t
-
J
5m
Noo
Fi

a
d
E=
*
x
L/
r
H
l
xP
*
=
\-
i
=
H
-)
l
5m
2+
r
Z
zr
3i
N-f
,
\o
Nf-
NF-
N-t
\o
CO$\o
ca-t
\o
NNt-
NNt-
-
E+
r
i3
oooo$
\o\n
\o(n
oo@-f
,
c\@$
Ot
oo$
C!
\o(n
N\o\n
F+
r
a
oozrr
.
lF
oozIJ
.
JF
aooZIJ
.
]F
aoozr!F
QNoozE]F
acC\
ooztr
.
lF
Noozr!F
aNoozr!F
qE
8.
R
Ebo
\
0zo-3FlaUzl-
ltcFrHzcEIz.-
.
vt-
{FCt
Fztr
l
!lzt-aoU
coe!
IJ
.
]Foz
RN
Fr

rr
.
l
F
F-
r
obzz
coc\€(naE]Foz
od
,

9R
F
P
,.
.
t

5
€
d3
3
3
E
I
ii
=
6
2
=IJ
.
]Foz
9d

9R
F
I!

.,

=
€
3
kY

-'
"
;

\f
,
F3
3
3
8
$
at
r

a2
cac\€(nr!Fcz
a7
\
iE
E
l
Za
XQaa
l-
{
ae
{a
ae
{a
ts
(
ae
{a
aZ$Z
:U
az
{a
lr
t
ae$Z
:U
ri
Ed
26
s
I
=A
$
AJ
rnoo
\n
\n\o
\n\o
i^
,
\o
i^
)
\o
(a\o
=r
el
F
l
JH
V?O
\nO
\n
|.
n
\nO
\r
)
V?O
oZd
:-
l
At
t
v\Fr
f
:
-r

i=
ZJ
or-a
JPr
tsJa
JOrJa
Ja
Ja
Ja
JU)
Ja
Fl-r

hl
E
Z
!?
?
R
EU
U
O
z
Z
z
z
z
ri
H
aC-
,
.
a
ao.
aA-
'
.D
ac.
,
.
aF.
.
ao<D
+t
AF1
<x
J
et
Y
o
r
E=
d
"3
s
=\
ZF
lJ
r
co
V
\o
'
r
.
t
:
-<

l-
(

V
io
Ed
d
'-
J
A
E
F.

A
fq
ca
n
C
{
.
:z
a
c+
o
t-

'l
\Ju
"a
Z
EJ
OU
oc
JFo3
tr
J
OU
co
JF
(,
D
IT
J
CU
cc
JF
tr
]
OU
co
JF
I!
OU
co
JFOD
+t
r\

Z
+t
V
I
rr
l
Y
Jz
i
!r
=
Fr

d,
7
31
J
.<

;r
\
it
s
r
fr
I
;q
o

'|
:e
z
=
P?
3
3
\J

.-
\

M
J|
/
]
-
?
UR
E
g
>)
t
N
o
-AE?
2
5
R?
3
3
CE
B
E
>)
r
N
c!
Ha
u
g
e7
,
5
^U
C
?
v-
-
\
H
o
o
J.
,
D
]
()
=
m
=
H)
r
C\
c!
N
-a
u
p?
2
5
^U
O
?
\-
/

--
\

OO
dE
B
+
Nc\
_a

u
eo
\
<
(
)

I
9
e7

5
8!
3
3
UE
B
i
-v
)

U
E?
2
5
8!
3
3
iE
B
=
Jr
N
co
-A

?
g?
2
j
^U
O
?
5{
j
$
dE
B
*
)t'c
\
N
P+
i3
$\f
,
\o
\f
,$\o
o\
f-
O.
f-
f-
f-
coNf-
a
.+
r
-
rt
+
-
{3
O,
.f
,
C.$
C.$
O.
-t
Nc\
.f
,
NO.
.+
ca
\o(n
F+
t
V)
Noozr!F
aNooOztr
.
lF
(,
coooOztJ
JF
acCAoozE]F
CAoozr!F
ac.
)
oozr!F
caooOzI!F
ilC)bo
CUi?o
^/
tL
.
.

tr

O\
ns
8
F
:.

1
F.
=

o)
L{
A
A;
Y
i3
0
.F
i

!)
53
Eob0
\n\nObo
cd
R<INNo()d
Ozo-FrFr
(nt)zl-
{tAvt.
{
l-
lzAv-ea-
\vFlFdt
Fzrdrie=aoU
o
c,

9
R
F
F
:.
/

5'
U
H3
7
:
r
i
l
x
4'

Y7
AF

*9
-
rr
J
Z
cAc!
I!Fcz
coc!HFoz
eaNHFoz
cac!E]Foz
caNIr
lFcz
cAe!
I!FoZ
coc\
l
tr
.
1Foz
A
7r
Fr

lI
,
.
10
is
/.
\
A
-
=M+Z
\U
J
oo
<
Z
FT

U
E=
A
zv
o
t-
{

)-
l

l-
Ai
H
J
3E
H
zq
oEi
E
J
Z
FT

U
u
*a
zq
o
Ei
H
4
tr
.
.
?3
-U
<{
&
zi
i{a
H
aa{a
F(
aa
\<
,
(

&
A
r-
(
4
IJ
.
'
.
?6
-U
F]
E
d
?a
s
-
-Z

qt
al
i^
,
\o
\o
\o
\o
co
ca
ca
dE
{
.l
q
rn
(nO
v?O
\n
rn
\ni
\n
(n
()ZIil
:
i
Er
l
v\2a
;r

kl
ZJ
Cl=
r2
Ja
JABIa
JFrBJa
JABJa
Jp-
.Ja
JF-
'
,Ja
JP-
,
,BJa
JABJa
H-t

l<
E
=
!?
?
R
EU
z
c
o
c
U
U
U
U
ri
n
ao-)
an-
,
.D
a
a
a)
aO-
.D
aD
ao-
,
,
+t
Ei
eY
o
-
q=

d
"3
t
l<
\ZN
LL
r!
OU
cc
JFo)
-a
)-
.
,
1

\=
{
2r
g
r
2p
A
Z
vUU
E'
l

z
\r'
HF
d
FL
;
A
68
?
e
Nco
tr
J
3?
()
Nca
I!
u
NCA
I!
3*
U
NB:
E
X
.VFA
o
&:
oc
A
iz
?
+t
r\

Z
+t
V
1
fl
.
l
,^
\
\
VY
Jz
-l

O-
-
5
qX
rJ
E
lJ
-
$
-A

?
E?
2
5
^U
O
?
5{
-
-
r
S
iE
E
=
-J
l
C\C!
F$ZU

M
E
32
=
H
;i

\./
ia
a
?
(,
F
J
N
*,
2

5
i
49
0
=
uc
\
F.
+
z
(,

co
E
32
=
\-
/
i9
c
?
I-
J
F
J
C
\
1,
2

5
i
UN
F\
n
zo

m
5Z
-
9

|
o-

*'
Z

-
iF
E
T
\J
t
-
J
C
\
d,
=
=
o
o
UN
F.
+
z
o
m
p
=2
=
-
\-
/
i9
a
?
UT
*
J
N
l,
z

5
i
UN
F\
f
,
Z
U
M
p
32
i
Hi
-
\
J
i9
c
?
(,
F
J
C
\
12

5:
39
m
=
UN
F.
f
,
Z
U
ao
p
=2
=
dE
=
=
l,
Z

5
i
H
UN
F$Z
U
CO
E
=2
=
t*

i_

\J
i9
o
?
(J
F
J
N
lZ

5:
UC
!
A
-+
+
-
Er

-i
{
i
i3
coNf-
(n$\o
\o.t
\o
-tNf-
r-
-$\o
oo
-f
,
\o
Nf-
o\
.t
\o
2+
L
q3
co
\o
ta
)
z
Z
Z
caO'
-t
-tc\$
C!
f-
.<
f
,
(nO,
-t
F+
t
a
acoooZr!F
()$ooztr
.
lF
.f
,
oozr!F
.f
,@ZEIF
(,
(noozI!F
\noozE]F
rnNZr!F
(,
\ooozr!F
GE
5.
R
Eb0
azc-El
FraL)z-/,cFr
l-
lzoE{et-
\Vt-
{FI
]
t
FrzF{
l-
reEraoU
CO

\+
N
ci
t
IJ
T

E]
F
F-
(
ob
ZZ
cOc!
IJ
.
]Foz
Cf
)

!+
Ni
i
I!

rr
l
H?cbzz
caNIJ
.
]Foz
RN
F]

E]
F
F-
,
obzz
cANrr
.
lFoz
eac\
IJ
.
]Foz
caNIJ
.
lFoz
a
7\
-
lr
l
ao1e
l,
r
A
-
ae
{a
ae
{a
aZ4t
r?6
:U
aa{a
=&a;+Z
-U
{a
{a
z.{a
HEd
za
s
-
\z

q!
al
ca
ca
co
i^
,
ca
i^
)
co
(nca
1E
*
'r
q
rn
\n
[n
\o
(ni
rr
)
\n
v?O
r)zI,i
J
-;
iAE
T
Y\
,d
-
'i

ri
ZJ
orlz
JC.
'
,BJa
']A-
,BJa
JO-
.Ja
JO.
rJa
JO-
'
.BJa
JorJa
Jo.
.Ja
J0rBJa
H7
\HE
Z
!?
?
P
EU
U
U
U
U
U
U
U
U
ri
H
aO-
,3
ac.
lD
ac.
.D
ac-
,
,3
aAr
aCr
aC.
,
r
aF-
'
,
+t
Fi
<x
J
ra
Y
o
<
4=
d
o3
g
c{

rq
co
E
,
\O
i
Y
-r
a
a
co
o
o
/)
J
JU
()
Z
-
tJ
.
l
:Elv
C
d,

u
ac
a
LJ

,7

EJ
o&
&
B?
c\

rJ
'
]
co
E
,
\O
-
Y
Fr

aa
oo
c
o
a
J
JU(,
z
IJ
.
]
c!co

\l
9F
U
oE
q
cc
a
dz
?
c.
r

a
rr
'
l
BA
5
-aOr
l
O
3R
d
o=
z
ar
!
N3'
,
'
.
X
-(
-
V
|.
.
o
Ed
d
F.
l
A
-
Nel
r
W9F
U
=o
Ed
d
FI
A
-
c\co
V
9F
U
8r
3
r-
.
1

A
>-
1
r\

2+
r
Y
JZ
=1

O.

i,
i
5
qX
i-
lh
F$z
(,

m
P
?Z
E
dP
3
3
12
5
=
z9
m
=
UN
utZ$
Pr
-)
d
\
J
JA
-
.
2=
N
i
l
F
4
o
I
Z
(J

Z
=
UF
-
z:
J
H^)
vA
l+
'
l
F$Z
o
o
E
fr
?
J
i9
a
?
UF
J
N
rz
=

i
uc
\
F\
n
zo

m
51
9

|
O-

rl

Z
=
dP
=
=
Zg
=
i
UN
F\
oZe

m
O
7I

I
c-

d,
Z

=
d8
=
=
C=
=
o
o
UN
F$Z
c:

m
E
fr
2
8
d8
3
R
4Z
=

i
UN
F.
+
Z
()

FA
E
32
8
dP
3
3
;Z
=

E
UN
Fr
n
ZO

M
5
z
e
I
-
c'
'
,

d.

Z
=
dP
=
=
C,
=
=
o
o
,6
d
4
UN
A
-+
L
t{

'+
t
-
I3
O.
-f
,
\o
\n\o
\n\o
InNF-
tnNf-
rn\o
Nrn
\o
\oNf-
A*
.
t
-+
a
-
i3
\nO.
-f
,
\oO.+
\oO,
-f
,
.t
\o\n
$\orn
f-O,
-f
,
ooO,
\f
,
\n\c\n
F+
r
a
a()
\ooozE]F
\cooZIJ
.
]F
a\oooOzIJ
.
]F
\oooZI!F
a\ooozt!F
(,
f-ooOzIJ
.
]F
f-oozrr
.
lF
J.
f-ooOztI
.
]F
\oV)C)bodO.!?o
()d
lL

qo
\
R#
8
F
:.
i
F.
=

()
X-
o
EO
.r
i

!)
5.
R
EObo
f-\nobo
cdOrtNc!O()03
azof-
(
-Fr
(t
)
(,zlr
l&AvFrHzAv=Vt-
{Fit
3ztia=aoU
caNIJ
.
]Fcz
caNr!FCZ
cAc{r!Foz
coc{
rr
.
lFoz
cac!
r!Foz
caNr!Foz
cAc!
IJ
.
]Foz
caNrI
]Foz
a7
\
!r

l=
do1g
AZ
.
-
z
Z
z
z
z
z
z
z
ri
Ed
zu
s
t
=A
$
al
-f-
b\o
f-
\o\o
f-
ic\o
a.$
O.
$
dr
d
e
>N
JH
(n
\nO
v?O
v?O
l.
n
(nO
(n
.QO
()ZIil
:
i
Al
r
v\F-
-E
lZJ
ot-Z
Ja
Ja
Ja
Ja
Ja
Ja
Ja
Ja
H'r
-E
Z
!?
?
P
EU
m
m
m
m
m
m
m
m
rE
H
aCr
a
aO-
,
.D
a)
aO-
,
.
aC-
'
.
aO.
.
.
aP-
'
,
+t
Ei
<x
l
EI
Y
F
r
l=
i
l
"3
9
tl
l&=ac
t-
VOU
-(
o
aJo?
r!&;a
_(
v
OU
Fr
c
aJo?
tr
.
l&;o
FT
V
O(
J
Fr
O
aJo?
IJ
.
]&e{;o
8E
F,
f

C
aJa?
+t
r\

z
lt
\.
/

I
ri
,-
\
\
V
Y
Jz
=l

0i
-
z
31
-r

-H
i-tL
ca
!I
'
,
r

,
-
rr
'
l

tI
J

O
aF
n
S
\J
F
^
o
o
lE
\
\
-
/
t
Ud
U
Q
a.
\
c\
ca
!:
i
n

r
-
rr
t

IJ
J

O
eF
n
S
\J
F

oo
'l
'
-
\
J
r
U
-o

u
e
a"
\
c!
ca
-
rY
l

LL
,
l

o
aF
a
=
\J
F

oo
''
l

'-
1

V
r
U
d
U
3
a"
\
c\
Ca
g:
'
a

!
H
rr
l

IJ
I

O
PF
A
S
\J

l-

oo
I
'-
-
-
\

\-
/

r
6
-c

u
3
-a

"lC!
ca
!:
'
a

t
-
tr
l

LL
,
l

O
aF
a
S
\J
F

oo
t,
_
_
\
v
l
U
-o

u
3
Ha

"\C!
ca
U2
H
j
-
rr
l

tL
l

O
aF
l
=
(J

t-
-

A
oo
l-
-
\
\
J
t
6
"c

u
AN
co
il
i
n

,
s*
f
r
=
PF
A
S
\-
/

t-

oO
lr
-
\
J
rU5
U
3
Ha

"\N
sa

T
s*
f
f
i
8
eE
a
=
\J

l-

oo
iB
U
d
a"
\
A
-+
+
-
=
'+
I
3?
^t
-
l-
i
Z
z
z
z
Z
z
z
z
P+
h
i3
O.O.$
o\O,$
rn
\n
\c\c\n
\o\o
r.
a
)
r.
a
)
l'
n
F+
r
a
OoooozE]F
aUoo@OZtr
.
lF
ooooztr
.
lF
aoooozt!F
oooozr!F
aoooozI!F
()O,
oozr!F
a(,O.
oozrI
.
]F
qE
5.
R
E
azoHFrFr0oz-tcFr
l-
(zclla,a
f
\vF(
rdt
FzfE
l=e=aoU
caNr!Foz
caNr!Foz
cONrr
.
lFoz
cONIJ
.
]Foz
caNrr
.
lFoz
caNI!Foz
cANr!Foz
caNaIJ
.
]Foz
u)

7\
tr
l
=aa3e
z
z
z
z
-l
ae
{a
aZ
Z{a
z
HEd
26
s
aJ
o\$
o\$
o\
.+
O,$
6N
O\
'N
a\N
i^
)$
EJ
IE
"
v.
)O
v?O
v?O
\n
rn
(n
U?O
[n
oztdi
Al
E
l
v\2a
i<

tr
l
ZJ
otz
Ja
Ja
Ja
Ia
JorBJV)
Jn'
.
ts
l-a
Jn.
.Ja
Ja
rd
''
l

lr
l
E
Z
!3
?
8
EU
E
e
tr
m
ma
mt
mt
cat
ri
n
a0rD
aO-
.
.
ao<D
aFrD
ac<
aC-
.3
ao.
'
.D
aa-
,
,
,-
\

+t
Fi
et
Y
t
r
t
I
&
"3
s
IJ
.
]&e!;o
st
r-
(

O
aJ
tr
.
l&N=ao
8E
F{
O
aJo?
28
ia
u
J
M
xu
4
2
&c
2B
ia
E
J
&
xg

*?
&c
2n
!
:
v
ia
E
J
&
AH

4?
&e
I!
OUz
48
=a
E
l
A
&
*E
*
?
n
A
+t
r\

z
+t
V
I
ri
.^
\
vY
Jz
i
o"
i
i
Fc
z
B
=g
*
tL
cO
!:
'
a

r
et
f
r
E
eF
e
S
\J
F

OO
.l
\
.
/
!US
U
A
a"
\
N
ca
ll
i

,
s*
f
f
i
8
PE
A
S
\.
/

r<

oo
dB
U
d
.@
c
\
e{
t-
X
g3

nJ
qi
a
s
9
i,
u
:
U?

*j
Fi

tf
J

lr
l

O
qE
a
S
g
i,
u
:
il

2
c,

j
:r
'
l
t
!
o
8E
A
3
d6
u
e
Z.
i
N
EH

fr
E
eF
a
S
\J

t-

oo
1^
/
\
/
r
05
u
3
Z.
i
N
U2
*
l
H
tI
l

tI
J

O
-
3E
s
:
ZI
C!
U?

4l
-r

Ir
'
!

EJ

O
^;

Z
?
Xr
,
-
t
N
16
/
V
t
US
U
E
z"
\
C!
A
+.
-
-
-r
+
j3
z
z
z
z
co
(a
\o
$(n
\o
f-Nf-
z
a
_l
L
-
-+
+
-
{3
C!
(n
N\n
F\o(n
f-\o\n
ca(n
$(n
oo
\o\n
\n(n
F
:t
h
U)
O,
ooOzIJ
.
]F
ao\
oozIT
IF
O.
oozIJ
.
]F
ao\@zIJ
.
1F
(,o\zE]F
O,ztr
.
lF
O.zuF
Uo.
\zL!F
oo
[nobodo<
Ic{c{
lOO63
tr
.
,

tr

O\
os
a
f
)
O,

(J
E
i'
!
E€
.r
<

g
8x
EC)oo
O,
\.
)Obo
cd
F-
.
.
INNOoc0
lalzlo
l-lF
<
t<
lF
.
l
laI
r.
l
lz
IHItlo
lF
r
lF
r
lzlot>
lc
I
r-
l
l<
I
t"
l
Itt<
Fzrd-e=aoU
caNaIJ
.
]Foz
c.
)Narr
.
lFoz
CAc!€aHFoz
h?
i
l
/\
-

6l
l-
l

O\

-
Z
o
a
*x
H
a
E
2
caNdEaI!Foz
cr
tN:aHFoz
€o.
i
NJc
a
AN
E]Foz
€NN\
f
,
o(
\
;€
fq

ca
FNoz
9F
I
eo1e
lr
A-
z
z
{a
$z
:U
aE
At
i{a
ts
(
aA*Z-U
!l
aa
r<
r

&
z,

ii
4
tr
.
'
,
?6
:U
a{a
HEd
26
s
Z
\Z

q!
AJ
rn
.f
,
\n\f
,
[.
)O,
i^
,O,
i^
,
oo
i^
,
oo
(no\
\nO,
dr
d
JH
\nO
(ai
rnO
r.
)
i
V?O
v?O
\.
)
rn
(,zI,i
J
-;
iA
LT
I
v\
l-
-
i;

t{
zl
o=a
Ja
Ja
Ja
Ja
Ja
Ja
Jo.
.Ja
JArJa
HQH
i-
B
3
mt
ma
z
z
z
z
z
z
Ei
t
aO-
,
.D
aF-
,
,)
aA-
'
,-
aF.
.
an.
,
.D
aC-
,D
aO-
.
.D
acr
+h
Fi
<x
'
]
fr
l

Y
Fr
1=
i
l
"3
9
ru
(,
U
z
e,
9
!
-:
.
r
;
.
E
l

9C
.
7
Fr

d,
a
a
XU
.
1

,a
d.

=
n
tc
/
E]
9
?,

..
-
)
z.

x
b
i-
i

-
-
,E
i

()
C
TF
l
d
.
a
a
XU
'
i
r
a
i
-^
a,
\-
H\EV
i
l
F
r-
r
oa
d
?c
d,Ev
B
r3
5
?m
&rHv
P
,
t-
a
oi
n
C
?
o.
'
.
dEv
B
il
3
r
?
i;

il
&i
l
!I
.
r
H
|1
J
-J

t-
{
Ff
u
O
1z

'i
-
{
=3
cl
e
\
r!
F
.
.
o
HD
-
TE
f
i
=a
0
E
+t
r\

Z
+f
v
I
rt
,-
\

V
Y
Jz
ri

0.

i-
i
F
d,

B
z
31
-t

\<
^
\
bJ
H
tl
-?
U?
c
,
j
eH
Z
=
d6
u
d
z"
i
t-
,

t
U?

*l
-
IJ
.
l

tq

O
>-
,
SB
g
x
rz

I
Vr?7

E
FY
O

t
A=
7
t
-
t*
c,

)
x
5
!r
.
l

a
5
"i
t-
*
H
9
6
ll
*
{
.
E
E
-n

=
oJ

"\
-7
,
C
\
t
Vf?E

D
FY
O

t
at
z
=
c,
5
x
5
!r
.
r

a
=
.i
t-
^
/
-
o
o
TH
B
+
O-
1

c{
?t
r

N
Vr?7

il
FY
(
,
I
A=
7
F
r
t-
.
]
-

a1
&5
x
5
Fr
.
@
5
"
i
t-
*
i
o
o
il
H
B
+
o
F.
l

c\
Fr
f
,
,
c
!
YR

il
FY
U

t
(r
)
=
7
F
{
lJ
r

F<
&5
X
5
Fr
.
a
=
"
\
t-
*
'
;
o
o
IH
E
+
O
'-
l

c\
=t
r

N
V(?E

D
FY
O

I
a:
-
'
7
-
ll
i
&5
X
5
ir
.
r

a
5
.\
IE
B
+
O!

C\
F'
r

i:

c{
Ya

il
lr
-
\
.
/
f
-
!
i
tZ
=
c(
5
x
5
Fr
.
@
5
.
\
=E
B
+
O
'-
.
1

c\
-r
}
7
6
1
A
++
-
Ft

-r
{
r
33
z
z
\n[n\o
\o\n\o
r-
-
(n\o
oo
\a\o
o|'
.
)
\o
o\
tn\o
A
-+
L
=
-+
+
-
2
rt
jV?J
\orn
O'
.
\o(n
r-
-
(n
oo
\n
O.
rn
rn
t.
)
rn
F+
r
a
O.zE]F
O.Ztr
lF
c{O.ZE]F
mNO,Zr!F
(,
cAO.Ozr!F
omcoO.zLi
lF
(,
-f
,ozr!F
ao$o\Ztr
.
lF
qE
8x
Eb0
azcl-
lE(
E-
tar)zl-
l&oFl-
lzo!lea-
\vF{F{t
Fzri=ar-aoU
€NNJ"
.
)
A
C.
l
rJ
]Foz
€ix
t_
r

"l
g
ER
z
€NN-i

(r
)
|,
c
{
rr
lFoz
€C{C{

.t
a(
\
;€
tr
l

ca
FNoz
coNE]Foz
coe{ElFoz
coNr!Foz
cae!
r!Foz
eANI!Foz
a
7\
rr

li
E
i
aa3s
az
<{
&
ai
i
4E?a
aa
{a
Z*Z:U
aE
*Z-U
JU&oFalL
JUaoFa
-]UcoF2
aU
aU
HEd
zl
s
Z
\Z

q!
al
[^
)
f-
\n[.
-
(n
f-
\n
f-
\n
b|'
n
rn
i^
t
.+
i^
,
$
tlz,
iTE
"
\nO
rnO
\ni
(n
v?O
v)O
rn
\ni
rni
()zIil
i
LE
{
Y\
ti
-
lr
l

l=
ZJ
cr-a
JorJa
Jp.Ja
Jo<
tsJa
JO.
rJa
Jo<B
JOrB
JO-
.B
Ja
Ja
EE
I
\EE
A
!?
T
R
EU
z
z
z
z
o
o
o
m
a
ri
H
aO-
'
,D
aO-
.
ac-
,
,)
ac.
.)
aC-
,)
ac.
.
:)
aA.-
aC.
'
,
aO-
.
,
a?
<x
J
tr
l

Y
er
(=

d
o3
s
nf
r
ta
J
J!
-F
tJ
-
,

o
3z
F
{
?g
cl
c
{
r!
A
o
FD
F
(
J\
,
/
&
E
U
tl
?c
a
E
il
i
l
FF
(J
.
I
-
FL
L
O
3z
!
<
?g
&i
l
F.
I

H
F1
J
-J

e!
:-

lJ
-
,

o
3z
F
{
?g
ca

fr
l
E*
oad?
c
ca

fr
l
ea
.
y
'
:?
(-
'
)

A
d?
o
ca

ul
E*
-)
A
o
ca
M
OU
;3
A*aHOm
ca
V
OUa3
A^
/
aHCm
r\

Z
+t
v
I
rf
l
3
iz
Fi

d
=
=3
8
fr
V/SF
o
q
l+
r
&5
x
5
Fr
.
4
5
"
\
t.
l

^/

;-
i

oo
TH
E
+
O
)-
.
1

c\
?t
r

N
Vr?E

E
FY
O

I
lJ
i
&D
x
5
Fr
.
o
5
.
\
t:
^
/
I
o
o
TH
B
+
O
)-
1

c{
F(

t:

cr
l
V(?E

il
FY
(
)
I
Af
7
-
lf
r
d,
5

ii

5
Fr
.
@
S
c
i
t-
f
J
-
9
6
TH
B
+
OF
J

C!
t*

;:

c\
Vr?E

E
l-

Vf
'
l
r
c,
f
x
5
Fr

a
5
c\
t-

f\
/

;.
-

OO
il
H
B
+
O>
J

C\
-r

i;
'

C\
C!o
3,
\O

F(
-?Xc
{
(J

oo
d+
Nc!
cao
3r
\O
-
^?Xc
{
\J
o
o
id
NN
$o
CA
r
co
l
\O

-.
P3
Yo
o
(r
o
NN
c'
l

in

r
gf
i
f
r
E
8E
a
3
Jd
,
Y
-
i
cc
\
-
/
c
zI
F-
,

X
U?

*-
fr
l

LL
J
;-
-

v
sH
8
+
uo
\
-
/
c
zI
E+
r
33
\o\o
\o\o
Noo
\n
Noo
[n
\o\o
N\o\o
ooNf-
CAz
Z
E+
r
{3
N\n
c\
t
\n
\f
,
.f
,
$.f
,
Z
Z
Z
ca
[n
-t
rn
F+
r
a
$o\zrr
lF
a-f
,o\OzLI
JF
cazHF
acaOZLL
]F
U(no\zHF
(nC,ZE]F
(nO.zrI
JF
(,
\oO.ZrI
]F
\oo\Zrr
lF
\oObo
cdAIc\c{C)oCO
O
tr
.
,

tr

O\
os
a
Uo
.
=
I
10
'
J
F.
F

o
x'
o
Y+,

(J
.r
t

!)
8x
E()bo
\oObo
cd
O.
(
INNC)
()ed
azc-33aUzl-
(toFr
l-
lzo=aa-
\
Vt-
t
Fdt
FzE]
t-zr-aoU
cONrr
.
lFoz
CONI!Foz
cANrr
.
lFoz
eaNIJ
.
]Foz
a
7\
-t
Eao3e
aU
aU
azU
(nU
ri
Ed
2a
5
i
=A
s
al
l'
n
.t
O.f
,
$
$
lE
s
JH
\n
|'
.
)
rn
v?O
()zI'^
/

J
-;
iAt
=
v\
l-
a
IE
]
ZJ
ctr
lz
Ja
Ja
Ja
Ja
H-'
r

H
E
Z
!?
?
R
EU
m
mi
ma
mi
*a15

El
R
.
E
iE
aD
aD
aD
aF.
,
,D
EE
<x
'
]
ra
Y
F
<
il
=
i
l
"3
9
tl
co
V
OUJ3
A*
aHOm
ca
V
OU
:cX;
l
a*ai
:
ca
V
OU
:oXJ
ana=
ca
V
OU
-,
o
XJ
AF
/
aH
:[
h
r\

z
+t
\J

I
rl
1
AVY
Jz
rJ

0.
=
F
d,
,
za
s
,
Y=
:i

-i
tr
U
21
-
-
tJ
.
l

[l

O
g
EE
+
()
o
\
r
n
-(
z

I
(n
U?

4l
-i

tr
l

uJ

O
aF
3
=
(r
F
^
o
o
1^
/
V
l
65
u
a
-'
'

Z
.iN
\o
U?
H
j
-
I'
r
)

[J

O
aF
3
=
(J
F
^
o
o
)t
\
/
V
l
OS
U
Q
z"
\
c\
t
\o
S
24
j
F{

fJ
.
l

l4

e
AF
f
r
X
(J
t
-
A
o
o
d6
5
d
z"
\
A
.+
L
=
-f
r
33
Z
z
z
z
2+
r
Z
rt
EI
r-
-
r{
o
(n(n
\o
\a
)
F-
\n
F+
r
a
\oo\zI!F
Uf-o.
\zrr
.
lF
f-O.zrI
]F
f-O.zrr
.
lF
Gf
i
5€
{-
)

I
.-

!t
5.
R
Eoo
TOCDF
Agent Monitoring Plan
October 2009
AGENT MONITORING PLAI\ NOTES
1 . See Paragraph2z.8 for filter monitoring protocol.
2. This station consists of a sample line that may temporarily be connected to a nearby ACAMS (as
directed by the CON, to monitor any location within the range of the spool).
3. PMB 906 and PMB 911 use the same ACAMS. The ACAMS normally monitors the PMB 906
location but upon request, the ACAMS and DAAMS can be switched to monitor PMB 911.
4. Used as a backup to the primary PAS (701, 706,707) DAAMS when tubes are being pulled or
maintenance is being performed on primary DAAMS.
s. This ACAMS is not in use at all times. It is for special purposes only. When it is not in use it will
have a carbon filter at the ACAMS, with the sample line disconnected.
6. Reserved
7. CYC 258H and CYC 260H use the same ACAMS/DAAMS equipment. They usually monitor
station CYC 260H but on request the sample line can be switched to monitor CYC 258H.
8. Reserved
9. These ACAMS and DAAMS can be switched to monitor three different locations.
1o. The ACAMS and DAAMS (confirmation) at the MPF Discharge Airlock (AL 468) samples
filtered air except when monitoring the discharge airlock.
1 1. Reserved
12. All LSS air DAAMS locations need to be sampled for agents inside the facility. The reporting
level is 0.5 WPL.
13. Reserved
t +. This ACAMS sample line has a valve allowing it to monitor in three different locations. The
sample custody enclosure area, the airlock to the sample enclosure area, and to sniff gloves in the
glove box. This is an ACAMS only station.
1s. This ACAMS is located outside the CAL in a monitoring building. A remote alarm and
malfunction light is in the CAL to alert personnel if the ACAMS alarms or goes into malfunction.
'l 6. Reserved
17. These stations are required in process, downstream and adjacent areas when contaminated
material is present from a past agent campaign. These stations are required when the agent waste
enters the facility boundaries per condition22.16.6.l.
18. DAAMS shall be collected on this station immediately following any ACAMS alarm.
1e. The fourth mid-bed VX DAAMS or 3'd midbed GB DAAMS must be pulled and analyzed when
FIL 601 ACAMS alarms. WPL samples must be collected on a daily basis for these stations.
20. Reserved
21. Access to these areas is limited and controlled. Due to this condition, V/G pads will be changed
every 28 days or upon entry.
22. WPL samples must be collected and analyzed on a daily basis at this station.
23. ACAMS/DAAMS monitors the agent contaminating the secondary waste and past agent
Attachm ent 22 - Page 62
TOCDF
^t*'til"#?tto'#
campaigns until the Area 10 Igloo Carbon Filtration System carbon has been replaced.
z+. When spooled, the DAAMS will follow the location monitored by the ACAMS for Area l0
monitors.
2s. These stations are monitoring to Extended Range VSL parameters.
Hazard Level:
STEL Short Term Exposure Limit
SEL
WPL
ECL
Source Emission Limit.
Worker Population Limit
Engineering Control Level
IDLH Immediately Dangerous to Life and Health
VSL Vapor Screening Limit
See AR 385-61 for a complete definition of the Hazard Level designations
Attachm ent 22 - Page 63
TOCDF
Agent Monitoring Plan
October 2009
APPENDIX B
DRAWINGS OF AIR MONITORING LOCATIONS
Attachm ent 22 - Page 64
qE
8,
R
Eoo
5lol
;i
er
f
liol
:lol
-t

9'Z
zQ
z
i
rr
.
t
O

._
a
.'
=

os
;
U
3u

?b
*
r
?3

Ef
i
3
1z

bE

AF
<
:r

?
UH

-s
e
f
r
>.
<

',
-
=
-
r
n
g
P-

iu
E
=
=
q
4X

d
--
,
8

o#

:
-f
,

r.
r

?*

qo

2
iE
s

3
n;

1e
U
,-
^

33
-

E
EH

3-
*

=
li
o
c
:
d
t
=
f
r
<
S
.
=
5?
g
f
;
i
=
H
i
E
=
Z;

c'
l
p
;

+
tl
]
brov
)
Lr
J

f
Ju
t!
f-OEC
I
ib
R
TC
/\
lr
hg
F
>o
a
o
-<
)
F(
.
o
lr
)
/\

F
:=
o
hr
>
i
-E
?
I-1

g1
,
p
(n
n
)
=$
6
o.
>

\-
J
o-
c
E
Xo
5=
0a
;
yO3p
Ot
r
)
or0.
6
zo9>2U
7-
-
l-

Ll
Li

uJ
c)
I
a
-.
t

-
<r
l-

uJ
tJ

lr
J
O-
a
d)JI
.^
s
6
o-

>
\-
-
J
>o
<
ro
--
-
t

-
{-
F
Il
-
J
UJ

Lr
l
a-
a
o@U)U
C
#
o@
P'
n
-
".
:

z3
;Q
5

-
'=

#
(m
)
El
f
O

r-
Y
rt
s
>
(
J
+b€|
.
)
1
P-
il

to
t
-
:
J
oO
oJ;>
u
I
(r
<
I-
-
_
*-
-
[
Q
rltl
1
.t
i
-<.
(!
-.
t

-
l(
-F
l-
r
J
IJ

UJ
OI
n@
:
UJE.F2otr
J
inoFal
tr
JG,oLr
J
tt!EUI
t!TFt!oV1F-J
l4
l
I-ozotr
J
rnaoz_otr
JuFztr
.
J
(,
IIl:t!atr
jwft4
J
tDoFulJtJgoJiJrF
utdTFoIOlr
loFFxt!ZoLr
JF(Jo_-
l
LJu
fo(l
,
loIJ
c{
lr
)oU)
()Lr
)
IaaJ
c{
!J
)
Iavt)
\n\oObo
C€
c<
I
c{C\OOcd
vl5LIZ-
o52o
aatJO
\c(A
J
>rog
\:
!AL
toQE
azoOo--
JFzIJ==E.Foz
5UJ
I,
J
rf
l
xE'tooI
I-J
m>9
tpE=
iL
t
r
$'
<
;
=
r
i5
&
\
,c
o

\
,/
j
>g
t<
-I
6\

il
i
I
;a

--
.
1

i
I
:;
\
9
,

,
i
\Y
l
l

I
ll
i
il
l
:=
t
ci
.*91

Y
'_
Op3E1
il=O
u
ro
E
=E,O
(,
:

C,
()
a
=m
oa
(
)
\
r.
*Il4
J
lr
J
@re
tJ
.
,
,

tr

O\
os
a
r)

o-

(,
F
r.
t
F.
F

0)
xs
{:
O
.-

{-
)
5,
q
Eobo
\o\oobo
cd
p.
'
.
IC!
c!
/
-r
lC)
tr()
cO
O;
-
a
u,
)
>l
J
u]
L
'
L
-J
rr!
dmo
oE
tr
JrFr,

ri
O
tr
.
l
E.
!a
o
FF>z=o
IJI
tr
J
Fc
l
oozt
-
o>a
td

uJ
ct
s
il
a*2E?,
uJ
f
t
u<
:lJiaa
EP
4
i2
N
o-
9
nl
.
r
+
3
-4
2
.
;
a
oT
.
=
u
Z
Fi
i

-
(n
L
l
)
=E

-P

iE
g
fl
t
-

t!

X"
Yr
-
t
:
o
^
+
Bg
B
q
E
X
u.

Jl
g

.4

Y^
f1
L
_
v
Y
'.
/
1
t
-

uJ

zt
Fu
I
r
E
E
FE

?r
s
i
ss

E
HP
;^
?

t3

q
3g
Y'
,

V.

Vl
,

lr
J

OJ
rl
u
J
E
t-

lr

UJ
I
-
)

UJ

Ju
bu
F
S
E
i
s
Z;
c
.
i
r
;
+
c\
IN
JF?
i,
-
r
F
Lr
l
lr
,

I
dt
n
|nnrvp8
)
=EE<
N{rF
or

i,
o
()
L
J
rs
r
n

55
c,
[
-
6
0

6g

\-
J
@pe=
@
E
?*
&
P=[
i.
J

P
"a
h
14
>(
L
E>@p
JF<L
l
F
tr
J
l4
i

=
ou
r
-OH
lr
JkJa
to==f
i
@
E.
C}
le
l
FUJ
IJraLJ
tJa
rt
:
-\
=
d)
--
.
J

+
(L
i
F[
1UT
C\
A
(>
l?,
tr
l
tr
l

nag
u
ez
^
i'
Q
E
o|
-

rr
ZE
,
>l
o
ca
>
u
>,

c.
l
tl
-
'
JM
IJ
O
-
/:
e
o
rJ
.
.
Y

n
e8
@
*J:0
a
E
l.ri
Jo
O
tr
-
l

Cl
r{
:Ftdl"
Jr(nL.
)
LJ
t,
z.IFo
rf
)
()rl=rtL
I
art
lt
)nI
:Elr
J
oEoFF=2
8"
9
:Y;i
t
r
>F<a<tet
r
HE
?
vtz;,IJ:lt-
(-
,@C\eIO
,l
l
l
ul
-Bl
t
l
p
Yr
,oo'
O
o
a
>c
D
(Y
O
lj
9
rnd.
(L
(
i
Ll
r

ll
d]

--
e

il
I

ii
;l
l
*
-
l
-
i
l

oi

t
tL
-

ii
l

t=
l
-
!
qE
8,
q
Ebo
atJ
l-
.
-oz_lv
.
tJ
-z
lr
J(9uoFtdH6oF
AE
r,
r

td
-t
LFU
J
()
o
r
.
z-
'@5
:
f-\oobo
cdO.tc!NOocd
:C)
Ib,
_
?'
a
;L
!
[l
-
1l
6F
tr
_
nr
o
oz
_
o
oGoFIg"
g
UI

E.
!q
tt

E
{h
^EV'=.
D
<ot=
lr
E3
-J
u
<
lr
l
F
hj
lr
J

-
o(
n
(!
u
r-
r

*
;*
O

;q
i
/d
'
Ii6r(Y
l
ll
E.uiFk<nvt
J
fr
"

tr

O\
os
a
r)

o-

(,
E
i'
!
x-
o
j5
0
.r
<

!)
8,
R
Eobo
oo
\o(.
)bo
cdO.tc!c{tro()Cd
IIIt-
-
I
n
cr
r
oo
.

CF
.I

EU
-
tU
I
&.

ov
t
raorJ
l
ICLG-
(A
)
-
(\

5\
-
/
()
r
?
:(fIb-
OA
-l
,
l>=
LJ
-
__
_
1

J-
6F
M.
mO
aZ
P
JL<
i.
r
IH
6.
J
.
t
=Es
nBg
=o
a.o
EE

(D
r-N
U.
1
o<=>E=
uC
*m
t-
-
l

d-
Il
=
::
,
TL
f)
\
)o(oIoil
,L
-
lf
f
i
1
l;
5
H
oLr
J
FozIVlr
J2la
J
Iv.oF-
-
tJli
l
ano
AE
Lr
l

uJ
.L
!
ta
l
oo
!
Z;
;;
6
6A
o\oOGI
t<0)po{-
)()o
t-
roo0)oo
(,Ib+oa
-[
J>=
l'
-
]

rr
-
r
-J
lr!
d
pQO>
ti
)
tr
lF()Z
(\Fl4
JUJ
Ial-
r
j
Lda
NFLr
J
Ld
Ia
(Do,C'
I
aaJouh
o\
\oooo
COINN0)oCd
a
FJ
l-
r
J

L!

E
F
r,
i

I
CU
J
tn
(
r
L
O
s-
o
g
q
Z?
E
dF
*
-
[-
]
*
o(f{oo-
(\
1
3*
Il
r
o#
oox.zO-JrI@Lr
J
tr
J
ff
i
B
o!n
E
=E,o
o.
t
c
)
o
a
>G
)
EO
ro
__
_
.
r
-
-t
alr
l
)
u-
r
=(
(
)
)
O
\-
J
L)
IJo
)FUa
oFaC!
;ooF
z
>c
oa
>
6lq)I
I
!Rq
{t
-
'
.
>
>
\-
\
/
tt
-
l'
-NNtr
oN
ooVJotz
.
t-zoU
ocu.c()
/=
\
\r

t/
I
o,
--
.
t

-
(rFI
!
lr
J

f,
l
UI
tn
@
(o
_l
-
:-
l
r
j
U
r.
r
oi
a
6l
)
+
-.
9AV
r.
)@ra
t
Ivlvt
-l
0(o,f
)IU)o_)
6tlr
)*Ia(Do
(o
'o3()
lr
J6
ql(ottIF
L'
tnFoZJEtJzr.
J(,v.ot!t-
lr
JLJ
ItioFELl
LL
tr
jE.;
+N6LI
lr
,
O
IL
t
r
O
\
R#
8
5
r.
t
F.
F

c)
LT
A
AJ
v+J

(J
.
r<

+-
)
8x
Eob0
,_
n
H
2g
#
Qr
H
EI
E'
E
3
_
=o
HE
;
P{
n
ac
d
E
UJ

l'
l

,
ci
5
-*
1
3
c!

o:
fr
>iao|
(
J
o
vl
E8
EE

s
r
-Q
3f

'(
m
)
o-

z
\-
,
=o
-

=
oa
f

=
Yo
r
Lr
_
_
J
C)
F
<
._

)p
7
nlI
r
>u
Z
l,
,
O
L
L
l
*i

o(
)
f
__
-
r
ll

I,
[J
-

r
ff
i
-
U
l
c(
/
)
u
Lr
-
Of-0)bo
CdO.I}o
()CO
@-
o8
ll

-
tt+t
ll

al
-
i
-
ll

rr

.l
ll

;t
r
@*
q
;t
tr
f-l*J
C)
E[
T
fi

;E
3i
@
',
oOr
(
J

n
o.
"
(
O
)
>@
-
(}
a
o
s5T:
f
d@ot
r
o
=
lr
l
u>
ru
b
;bo)
(
J
()
a
>Gni
o
tz

r3
3
H
s
]V
1
1
0
f-()uo
CB
p<
IC\Noocd
bIb-OA
-l
,
l>=
lr
l
-
r
-
lr
61

Flmo
oa
UJac)LEf&F>
--
.
r

O
fo>(
r
5c,ar
/
1
(o
l
\t
ooE.
tE6tL
ooE.oo
ooEzoJ-
ntr
JFozdTLUJzl4
JoEoFIl
,
lr
J=ao
ln
vUJ

lr
J
,t
!
Lr
l
oEZr
fi
f
i
E€
.F
(

U
8x
Eobo
ooI()c.
l
IQIo
Ftr
J
t!raLJ
l!lt
'
l
tr
.

tr

O\
os
a
(J
A
=
I
g'
J
F.
F

o
x.
o
l:

O
.F
a

U
8x
Eob0
tr
Oou
J
E.
(I
)
o
FF>z
:l
o
=
UJ
IU
J
F(
D
f
nF9m
o
z>
F3{
r
:-
.

tr
-
.
I
2o
z
tr
-
l

ll
J
;;
e
l!

Ok
>(
J
E
*=
9
H
HH
s
;
u)
?

3E
E
u
F
"E
r
5E

i;
3
Z;

c.
i
oozJ
-
o>c
l
TI
J

I!

UJ
<(

(!
t
(
r
is
f
,
"Q
i
lr
J

E
ut
0
a

<
))
-

Vl
-E
I
T9
?
E<
cr
UU
C
3

S8
O

/r
\
LA
Z
-
6
O

nU

V
9Z

r3
3
H
S
tH
r
l
o
c!
f-C)oo
coO"?o
()CO
o$t=h
:
t
3tt..
'
a
"
t
-
l
qJ
NS<
IJ
ur
{
-JhJ
I
F
m:
f
OO
2a
=q
p{[
h-

fr
J
lr
J
.
L
d
at
)
Ii
oNcO(
r
NO
;oooE8
A\\
/

.l
lnrPtr
J
lr
J
6
r3
3
H
S
ES
Z
l
Z
O
C
-
S
S
1
F.ilI
Y,
^
I
d(
<
)
=t
NH
E
,1
,

j,
5
-o
.
r
,
>F

-
r"

I:
oi
?
JF<k
F
U.
I
l4
J

I
ou
l
o(Jtndlo
a
_ue8
-tBr
t-
d
IIT
@
aL6?tr
lr
J
@p(\
l'Y
(o
J
O(
r
=E
ol!F>
l<o=E,
E
.,
S
z'
a
6lrF]
lo(\Br
a
=
\_
_
y
is
il
o?2
sl
-1

N
aL_
-
r-
l

u'
l
aE
a
"N
Ji
-
(
ir
J
-
Ia
J
JT
f
L/
l
O*
ol

oi
rO
rr
'
)

(Jz
>f
tr
>
Oe:E
@
Go
-
eE
=
**
rU-
=
kg
t
s
(J
E3q
?
-
ut
,
fr
e
2
=<
c
=o
(
J
E;
UEi
t
UI6GI
rtc
()
Fr
)I
.J
loJ
tr
Ooi.
I
tt
7a
o,o+U'
an)
t,Nta
tovl
J
lr
l
l,
)
IaoJ
ti
l
nc
-
-
-
-
r
vg
-
s
s
r
E:HI
T

"
II
t
r
>
z
ll

(\

-.
il
]

s
-
fl
=
<
:
I
Oa

tr
J
lt
Jt
-
<r
l
]
F
Lr
-
.
]
ll
J
T
OA
3a
/&*t
?
ieg
r<
ra
qE
E.
q
Ebo
ca
f-obodc.
.
tc!c!oo5)
LL
JU.
<lrt-
-uoZ-
@(nLIMaVoOZ:)n\-
tLr)
t-
L
lVt-
)
[J
:r-
INN-LJ_J
L_
_
lmO
oEu.
No
g{
J
fo
dl
(
!oO
>o>bd8
,Ii!Eia
F
l-
-
lr
l
o
r
o
l
t
r
.
{
,

(.
)

I
.-
.
l
rn
r
l
r
a
r
r
r
r
B
r

ZJ

I
I
r+
l
-
r
r
r
o

=5

>i
l
".
,
"
'
r
'
#
'
F
-
-
-
(
|
%
;{
o
9Z

rl
l
s
lV
l
l
0
oN-e
a-
Lu
t
36
13*
EH
a
t?
le
r
E-
-
-
-
l
t
lr
J
IT()
F=
lr
J

^L
-
O
i
,.

Ot
r
l
^a
o
A
PF
F
E
.
uZ
?
?r

."
Y
-T

lr
J
l
/
^i

(E
r
l
.
!
il
o

^F
a
l
X-

Io
o
;<

q9
^
ou

61
1
r
;
2n

<(
D
t
E
F
F
1a
)
^
z-

>(
r
;
!{
x

<Z
'
E
YH

mQ
,
.
r
.
lr
.
l

E
<o

ul
(
E
<
3E

1z
E
t(
)

uJ
t
r
j
<
aq

I9
?
.:6l

,.
)
aI
alr
.
.
iFoz)trUJz[Jo'
6tr
JFoz
@
Ol
()

tr
i
TJ
or
Q
OF
a
>t
!
t>
Uo)FzLl:)Foz
(f
,oI@NI13Io
tJ
.

tr

o\
cd
^
ii
r
s
5
:.
i
F.
F

c)
x-
o
iJ

'o
'F

{-
)
t.
R
EObo
.f
,
f-obo
63O.?o
ocO
td
ry
'
Fz
f-
r
l

O
E
Er

=
tl
b
!.
{

O
a'
a
i
*o

=
EE
t
z.

=
l*
23
e

p
g:
U
oH

k
2A
r
5i
,

+
f
g
r
?x
.

e
o[
H
rr
i
l
,
r

-
9a
a
4e
E

5
:s
a:

i3
[

s
*e
!,
r
H

52
?
&

_,
P
l-

t,

>l
4
J
t
E

I
-J
g
OE

<t
D
F

[n

<z
Z-

$!

r/
)

+
ao
F
--
:

lr
zi
tl

-
O
re
u
=5
A
tr
t
-
E

i
,^
z

(,
=3
H
E
i-
e
i
s
g?
r
E
E!
=
3
d-
(
/
)
E
H5
=
8
ga
i
z
=F
g
E
,:
f
i
r
,
:
"
,-

=u
r
--
i
L
a
O
r
4.
<
a
)
-
,.
r
;
a\
()L/
raooId)(\
I+T3-iH
fDoIaC
(JoIaI
ooIa(L
zotrFa
oIaTL
qE
5x
Ebo
|'
n
f-
obodO-
.
.
INN0)o
N;
NXN\
hN
5=
^
S?
J=
<
t
.
(-
)
-
.
,
ei

:E
g
f
r

z
4u

tr

6*
Q
F
g.
t
>
d
r
i
_
_
_
r

z
I
z!

*>
d
<
t
'

r-
r
r
o
;:
=

3i
:
+

{E
h6
,
.
,

.
>=
F

aG
1
=2

'!

-5
,
a
2

?,
,
E=
E

zi
r
e

=F
33

L
"2
"
6
1
f
,
2

d!
t
-
*=
:
:
s

*E
P
t

=!
^
::
2
;
g
;
[
H
E

==
!I
5
I
i
l
E
:
i
?
?
i
?
g;
;
H
=
E

i=
5
E

iE
-;

g.
a9
F
ll
r
fr
o
o
=e
p
gE
E
=
.^
z

(J
=9
H
E
or
r
*
=f
r
?
"
g?
>
g
-+
*
E
Y
r-
,
^

0i
tL

:'
'

tJ
,
,
3E
=
8
ga
f
r
z
EH
E
S
u
r/
)

!!
.
2L
l
--
l
t
,
O
I
.
<<
m
F
(o
Lr
-
.
1u<a
01
r
.
.
[i
=
t-
-
r)
--

L-
l
ir

)
*L
J
r-
l
rl
ii
FL
JAQ
-JAT
IxX
,
,L
J
lt
l
l
_*6a)
>

u
=4
+UJFoLUJ
Lr
JUI
;l
Ol
F
i;
{t
tPU
(J)o-O!
o_F
,
H5
i7

--
r

cn
s=
-^
l
a
Ir
c
;
"
=
.,
t
r
3
o
!=
o
I
T,
r
}
C
J
]
_J
-
O
+.
-
o
F
er
3
6
t
!
b,
I
t
i
l
l
_
-i
A
F
5
=
EE
:
u
:
[
f
;
:'
-

.q
)
F

=
ta
i
=
H
b
*
1c
2
H

I
i-
=
=
c(
f
>
'
i
l
o
a
o
CO
-
-
0
(
O
m
>
UIzI()oJFzUJ
:)
tFtJ
lz
.+oOI@C\
IoI
rnC\
I
EEE
m(f
,
rO)L
()()(oIJL
o(oIJl!
ro(I
)
I
-J
t-
r.
/
)
(.
oJL
e{
r.(o.l
l-
zaFC
)
<z
Fa
Nlr
)@_l
lr
-
31
3
[
3[
3
O)
(o
(.
o
I)
ii
rL

tr
O
\
os
a
uo
<
=
P
H'
i
x-
o
{Y
'
o
.-

!)
8x
EObo
il4
III
-i

tr
eo
F
;L
T
-
fr
d
o
E9
E
EE
E
,
,^
z

(J
E3
u
;
5*
*
]
F
tz
o
6
zt
!
1g?
>
g
..
{
-
5i
=
#
il
-
t
n
E
H>
=
*
"
(f
l

r,
l

v
9a
l
i
=B
6
E
]u
r
u
f
l!
o
_

(J
1,

H,
,
,
-l
t
n
o
f
((
n
-
d
YoooooJz.
:l
TH).
'
m?

o
,,
E

z.
mF?
=_
'
=

Hg
o
o:

3
<k
e;
H

22
.-

-
e
=+
3q

;
ga

E;
=:

+;
E

Ig
=x
d
.
,
H
o
I
Y.
.
1
G
a
a
f;
s
i
?
e
e
--
.
t
C

F
LJ

{,
-
33

u
EE

3F
a.

ao

f,

-f
r

<f
i
H:
n
a
i
E
i
E
Z
-
cl
r
i
t

+
f_
_
n
UJ
(J
gE
ILEi
,
aa
UJ
oc
l-
_
-
-
_
*
i

j
\o
f-
obo
CO
o.
.
I?O
oc0
uu
o
S

AN
o
3
60
r
-
9
6

tl
u
i-
i?
-Pe5
'F
at
AC'
I
F
2a
oa

rJ.
^L-
J
IbOF-
I
}r
-
Lr
J

g
lr
r
d>
mrO
j
Y(JooeoJz:f
o
A=
Y(J
oo=aE?>3
e,
z
:f
o\OONt<C)
,.
o
o{-
)oo
t-
roo0)bo
3?e
l
E
2
53
$
z
E
l=

fr
t
o
H
i=
,

;i
a
E
p
-
fr
;
;
E
,

iF

E:
I
*
==

::
e

21
E
H
:
;
in
f
i
:
r
I
a
g
:
E
u
is
n

E
fi
;

1e

Ua
=
e
Z
g;
;
*
g
:
H
I
E
I
I
H
I
Z-

Nr
e

$
d
v)GoFHaut
-
il
oI?
(oooImNIoIN
tt!IForotr
Joxtr
Jzolr
lOo)
vl={ooUJEo=ozUJtEFId
f-f-obo
6d
F<
IolN0)
tr()
cO
.-I
,-
-
.
'
-Lt
]
__
_
_
l
L1
_
]ma
o;x
F
3;
E
F
=H
E
H
u)
F
ozs?
E
F
=6
6
\
E2
>
t
n
f\
t
r
o
\
os
a
U0
.
.
=
g
.H
'
d
E€
.-

!)
5x
Eobo
CILr
J_l
LL
Imo*
g
-
18
z
fr
d
.
-
uP

ie
u
ei
,

38
H

=
2e

.^
Z
-

O
=E

E:
t
*
Ei
A
4
7
;
ff
i

r:
i
e
4.
=

Yl
o
6
=
fi
E
=
H
I
5
iE

i?
i
l
8
+d
t(rF
I
zF
o
=
=
Ho
L
!E
=
=
=E

E
Hn
ul

E
{E
=;

bJ

=\
P;
-

d
HE
=x

e
--
,
H
aV

uJ

1S
lg
n

3
ao
33
i
;

EH
a.

6o
d

P
=f
f
rr
r

tz
z

i
Jl
r
=
=H
B

A
dH
I
;
e'
,
,
i

'i
t1
2

CL
=H>5
)
@f-obo
Cd
O.
,
.
c{Notr()
cB
tn(fo3szf
i
yo
I-

r-
Aa
c,
'-
-
l
T-
aa
cn

ul
iEg?
!'
u
.
t
2-
L
ta
l

=
>:
9t
u
Z.

bJ
3A
aE

th
au
Fn=(
r
r
lr
J
o>
N
(D
==
rr
t
I
'-,:
tnzotro=f==o()
t-
o0
a
oo
=(
L6&
_
AH
CI
ooa
:<()FaFol=xil
n-
1
1
1
0
1
TJoEoFU'
(otrer
d
:J
g
o
>u
l
o.
=
L!
xe
Yc
t
N=oE
2
>=
tr
J{t-zo
li
;t
ii]rl
il
ii
i
il!t
ld
l
l
I
(n
d

I
l2
*
l
lH
?

i
|
6l
=+
ln

I
z.
>

I
uJ
(
r

l
.
>o

I
I
_l
Ft
rJ
>

I
>o
.

t
n
30

|
2
?e
:l
|
:

le
-

gE

i
il
Fr
-
.*r6
=t
j
)
>L
J
oa
o
o\
f-Obo
cd
o<
INNOOc'
3
GE
8,
q
I
o
,
;d
.
2
*
.-
1
9
z
fr
o
o
pa

Fg
H
i;

*E
s
,
e
Zr

,^
Z

C]
qE

=3
H
E
fr
i

O-
r
f
,
-z
e

zg
z
z
??

er
i
r
o
o#

Er
*
=
E
ct

ct

-
co
l
r
t

-
?=

na
Z
=
3E

=H
E
H
iE
'
n
t
s
;
e
-a

-'
i
m
o
r
<2

<<
(
,
F
*r
;
6tE/
Ikr
Et-
I
z
]-
-
e
;
=
l'
i

o
uJ
3
zz
F
=3
;-

=
t
='
*

tr
t

O
#)

<.
l
m
;T

*<

?a
Z.
<

-F
m6

tr
J

4<
=
=
d
,*
,
9
z
(D
=
=E
e
i
H
tJ
o
a
L

l^
J

=
m
il
e
e
!

I
aa
)!
-

F
lr
J
3"
Q
.
,

r
EH
m
oo
d

P
=f
f
lr
J

^Z
Z

i
Jt
!
r-

<L
J
l

=
Jt
l
]
'n

i_
6
6

6
<(
r
lnzoFF
H
ai
?
^i
l
l"
r
l

g
Zr

$o--
9i

=t
-o

o<
o_

>t
r
J
I
rI
-(
J

*O
o<

zr
F
lr
J

uJ
=
C-
}
F
=c
)

.<
x
YF

uJ
2
.
az
.
.
F
(r
.
-
rx

c]
F.
u
t

o
Lr
-
r
uz

e\
<\
O

(.
)
-u
J

xo
Ft

>)
-1
(
J

JL
!
rf
)

JU
-
ct

N
UJ
tu

(!
>f
-AF-

tn
t'
/
l

t
)
OE
B-

(L
E{t6T
iE
=
l
t
fz
,

rr
'
r
u
o
l
s

_-
]
f_

."
*
r
*

--
-
l
I
t
It

>
NI
I
Qs
lj
i
sa
n
<a
/
tJIro
,ooI(,
r)
Ee8
>I
r,Ero
!c'(
,
7t
Erd
50f?
ti
r)
rO?8>r
poooIr,6oo!
,.
>
I
YG
a
r
,
oo
.
c
ol
o
r
d
,
cc
i
oo
(
)
3q
9Lx2Ot
J
F(
,
tJ
.
,

tr

O\
os
a
r)

o.

(J
E
l'
?5€
{-
,

(J
.F
(

Ll
8.
R
Eooo
HE
E

fo
=
=5
:
=
HE

q=
s
u
e6

sE
E
,
3
qf
r

=E
H
x
6
.d
,

u*
;
E
3
fr
:
=
;
[

:3
=
;
3
oH
I
i

FE
;;
E
i
=

ar
=
u
.
E
EE
E
E

EE
j
F
5
H
U
rH
i
E

i[
;
=
.4
,
-
N

|O

rrIo?{
ooG)b0
COo-!?o
()C€
IIl
E2o,iTI
uJJl
l
J
!P
c
.
:
dE
6r
,
oo
i
r
.
_
IIIlt#u
zIFFa
/
azIFooJFz.
t!=:lEFa
oOIN00IaINC\
t
t
Lr
.
l
.
2
E
rr
-
t
n
O
F
<2
#
z
ln
)
ZT
o
o
a
.
r
N
OL
r
J
=

@
Z-

a\
=*
g
=
*

:;

=
"'
n
)
*

-
Yd

:
?=
p
E
S

ae

P
?-
=
=
:

2e

k
-
o
or
.
.
l
9

eU

L,
{
Fr
=
*
E

i#

4
*s
"
=
8

z-

B
i:
e
;
=

[+

5
EP
;
=
q

3=

=
:i
*
E
H

or

P
H?
8
8
6

95

3
Fm
J
<
(
J

<r
!

a
ti

+
,f
i
qE
8.
R
Eb0
9
-f
*
e
|
,r
Z^
Z
Ll
o
n
r.
r

O
>,
^

[J
ff

-
o-
Y
t
<<

-=
-
s*
-

gF
g
=
-t
z
6
g
26
-
2
=i
r

;E
(
D
a
E;
2
2
>
3
OO

.^
.A

I(
'
r
-
Y
29

-+
5
t
=
iE

t;
*
s
4.
7

\p
=
o
=
€;

=E
H
E
?3

EH
;
d
iE

i.
6
i
<z

<<
c
o
F
'-
:

c.
j
aobo
cd
O-
,
.
INN0)
()
l\
)
TOCDF
Agent Monito.ing Plan
October 2009
APPENDIX C
HEATED SAMPLE LINE ASSEMBLY DRAWING
Attachm ent 22 - Page 82
qE
8.
R
F,
caooobo
cdC.INNoOCd
ZEFFV)Fu{O(.
/
'
)={rf
(/
)z{O{
t,
IElrl*
l<l-
IBla
zu:)FLJe.UJJ(L={.A
-=Et
r
I
tr
t
E
uuzzuuEE
v)

v,
zz
LJ

l4
J
(A

IA
V'

1A
=-
(J
<
{a
l4
l
13

ar
7

V,
z-
z
J(
J
<

(J

FF
l!
<
A

I
(J
(
J
r
rr

*
:;
\
LJ

dd
\
NN
-4

?
)
E:
a
e
o
6
n-
P

*P

2-

hE
H
t
r
I
U
U
I
F<
o
o
e
ff
i

ff
i

2,
*

hH
H
t
r
;
gh
'

$h
\

;:
#

=f
r
=
=
Z
Il

ll

I
>1
1

O
FF

sH
@
O
x
ll

ll

rn
H
T
t
*
*
f
t

9o
s
s
,
.
J
ll

t[
]
=
f
t
J
i
:

EE
E
E
a
ll

-]

(r
a
a
-

s{
=
{
{
=
ll

ll

h\
o
x
o
\
n
o
t\

ll

r.
X
-
o
G
l
Hl
l

di
T
t
i
i
ll
l
l

'
u
ta

vt
.
A

1A

t/
,
JI
l
l

-I
Z
=
-
-
I
I
>(
J
|
J
(
J
U
(
J
I
I
F<
{
<
€
<
U
zclF*.A.At'
lJ.tLJzJIJJC-]A
Fztr
t
:E.AUt)laEav1-L)
ooI@NIaIo
_Jmtr
Jaa
(n
<
E
tr
.
t
*=
o
--
J
)'
s
>o
-
{=?;otJ
-
JFL!
I
Il=IEli
l
l*
IHl<l-
IEIEla
lr
J

(U
)o_
u
=F<E
t/
)

Z
zulFtr
JuIJ-J0-=U'
I-FF
f,
l
H
pa
]
t-
z<t
r
t
H
lr
J
>F
(
J
{<
<uu
u
FF
E
E
I
UJ
|J
l
z
|
u
-
l
rl
L
r
J
J
=&
(
f
FZ
t!
<
FE
]
ua
tr
J
f
,
t
n
(L
I
J
C
I
(L
r
e
J
l-
[
J
at
A
=
tl
z
t-
z
J
o
O
tr
l
4
*
O
lr
J
(
Y
-
C
x
j
-
r
-
-I
J
F
U
J
<
L
J
<t
T
J
F
U
J
E
-
>U
.
t
/
1

13
)
A
bOEI
FbLN
uzF
Z
l/
1
EI
H
HX
FI
J
{vuF
14
,
tr
J

F
z<UJ
J
(L
L
(]
z
t-
z
J
c
l
(A

El
4
*
t
A
tr
J
(
Y
-
e
F
F
-L
J
F
L
J
<
t
r
j
<l
4
l
F
u
J
r
]
I
>
uv
'
t
a

)t
A
bOEFoCU
d8z*
t
/H
=
\
,*
*\
\
/
*
-lef
f
i
tt
#
@r
o
m

''
t
\
-
.
+9
u,
=
z=
.A
L
(.
/
,

H
-
tr
J

-)

r.
r
F
<g

=
EU
J
L
I
.
=-
.
^

EH
J
IJ

V'

LN
d.

UJ
E

eE
2
?d
;

Es
lJ

u-
<

i:
i
u,

jA
A

E
r-
d.

A'
'

"
,^
o
6
gv
t
u

^t

,
.
r!

,t
E

H=
HE
u
l

-E
Fl
r
r
r
4
-
tr
l

Fc
l
f
!{

,,
4
t
-

a-
r
i
.-
-
-
d

j-
z

1,
3
.
n
A
LV
I
Q

-
fi
u
.
r
*
tr

H
==
=
T

EH
i
l
-
a
c4
L
'
o
E
]

,,
-
-
r:
l

<u
o

"i
.
a
Z;

ni

a;
EF
TOCDF
Agent Monitoring Plan
October 2009
APPENDIX D
IIEATED SAMPLE LINE PARTS DRAWING
Attachm ent 22 - Page 84
qE
8,
q
E
..
n
EE
I
ir
i

I
i
Es
E

I=

i
:
.
I
'
L6
.
eI
I

g!
.
.

E=
:
il
E

li
i

g
ii
:
i
:;

Er
!

Et
r

==
i
l
eh

3#

d
It
;
r
EF

ei
C

EI
aI
*
;
l
l
i

H;
r
l
Su
l
l
i
E
r
i

H
si
E
=l

,:
;

;
aE
l

E=
E
,,
i
i
:
I:
I
,i
i
i
(nooobo
cOOrINNood
TOCDF
Agent Monito.ing Plan
October 2009
APPENDIX E
D AAMS DILUTION AIR FLOW CONTROLLERS
Attachrn ent 22 - Page 86
qE
8,
q
Eb0
f-@C)oo
cO
tu
INNC)ocd
Er.
l
I
EI
l=
l
l*
l
l=
l
Ir
J
l
l=
l
-oJl!
t!
,

J
J.
<CL
F
=o<FL/
,
l!oDI
a
Eo
l-
*(
J
(_
)

=
<t
o
F
6S
s-
2
-o
j-
<--
-
uo
r{
C
cL
-
-r
d
x
€,
,
r

A
-d

--
l

u
-i
l
^
=4#3
t
n:
l
rI
I
i
Ei
i
l
"3
1
TOCDF
Agent Monitoring Plan
October 2009
APPENDIX F
DAAMS STACK SAMPLING ASSEMBLY
Attachrn ent 22 - Page 88
TOCDF
Agent Monitoring Plan
October 2009
SAMPLE IN
(FROM STACK)
DILUTION AIR
TO STACK
DILUTION AIR
FROM SOURCE
EXHAUST
DAAMS
SEQUENCER
SYSTEM
SAMPLE DILUTION
DAAMS OUT
DILUTION AI R
FLOW CONTROLLER
tN
TO PUMP
INLET
SAMPLE PUMP
OUTLET
Attachm ent 22 - Page 89
TOCDF
Agent Monitoring Plan
October 2009
APPBNDIX G
ACAMS STACK SAMPLING ASSEMBLY
Attachm ent 22 - Page 90
TOCDF
Agent Monitoring Plan
October 2009
SAMPLE IN
(FROM STACK)
TO ACAMS
ACAMS
DILUTION AIR
FLOW CONTROLLER
TO PUMP
IN LET
SAMPLE PUMP
OUTLET
EXHAUST
DILUTION AIR
TO STACK
DILUTION AIR
FROM SOURCE
ACAMS
MONITOR
Attachm ent 22 - Page 9l
TOCDF
Agent Monito.ing Plan
October,20Q9
a-
O
APPENDIXH
ACAMSIDAAMS VX SAMPLING PROBE CONFIGT]RATION
Attachm ent 22 - Page 92
v,v,(,--E
$l
:1=l
.
.
HI
E
(r
1
,
.
,
<l
-
-
Jfr
i
cf
,
l
o(
l
o-
l
w
aHq
-
8*
E
6-
2

J
-9
8
<f
'
-
=o
(
J
Ee
il
/
/Y
\
A
EI
-l
-dcr
t
l
=l

u'
)
u-
i
l

H
€t

;
JEt
l
ol
cE
l
cL
l
J
_.
.
-
.
4
,-
t
-.
-
J
Y(JFzF
(
J
Oo
=
==
3
=6cl
d
(J
U
(
.
,
U.
.
(
tA

<.
=
==
i
-
<E
=
.<
=
l
!
Ou)-
9
UU
<
<<
6
G
)<
:
l

x
ct

>>
>
fr8l
t

rr
IJ
J
oc
i
c
D
oI

-
IU
U
*a
r
l
A
.Jta
r

l!

u
Gr

cr
t
rt
l
c
f

c,
tr
l

tE

E
vt

o-

rL
\5
.
-
,
(J
.a(.
3
'1
"
1
(_
-

i
'.
i
ao-=CtvtE,
IJzoU
-:
a>D
^
J
FG
J
J
uJ
]
9*
-
.<
F
J?-
9
Vl

tn
t-
=
v
,
(J

(=

l,
f-
{6F
<(
,
r!
F
z
(r
v
:
s
=v
)
r
-
cE

t1

-
=J
t
r
'a

Z.
6-
O
=s
-
*2
f
r
(,

tE
f=
*
lA
Z
A
-U
=g!
/
)
<
=642
2
ou
c
l
UE
F
-(
J
<
l-

./
,

Far
,
=)
OU
r
r
J
U-
>-
F
F
Jv
)
-r(:
,

r/
t

O
vt
lr
l

l4
J

E
;'
E
tL
t
s
<
v1

-
Oa

r.
J
t!
-
E
rr
r
F

U)
r^
l
=

g
H
v'
l
u

F
F{
,
-

3
-
t-
l
r

o
-I
F

<
L
LJ
T
zl
-
:

d
;
=
I
=d
-e
E=>=<
)
-L
J
ED
aEoCE&(.
,=Ga
-Bd=
f;
>E$
6c
)
taUCE=z(5U)
ct
Fz!EVl

.l
r

Z
cl
G
Fl
l
J
O
(,
U
f
r
-2
-
F(
r
<
vt
2
a
)
t-
O
EC
]
F
U2!3
r
4e
<
(,
C
l
c
Z(
J
.
J
t
-oi
tn
EI
L.
J

=
o=r
=
Ai
)
G
,

.t
'<

Q
C:
,

tJ
.
l
*1
t
j
E

El
ii

o-

G,
8,
c
L
FU
(
9
rt
,

=
oG-
t
2
$_
r
-=
;
=
3=
=
[
I
t5
,
r
,

o
-=
t-
o
-V
l
a6

.o
bb

-t
ug

<
lJ
'
t
PF
=

=
r;
=

(J
f,
o
-
(,
E
62+-CIoL5q)s<914
,
ItI:0E,
(O5ooIoEI]r!GHt5U3r!ar
o!6DctoIoEI
ILJEEL6tr
J=
zo;=EE(JUC:UF
GIoooI
BO
90EIE-
.
t-
/
l
tIE3
oz
zJ
Er
i
=
EE
s
g
5=
:
E
=I
E
s
Ef
i
;
E
FE
!
T
tt
r
*
z
O
3r
.
r
6g
G,
lr
,
(D
ro3
,r
:
6"
1
hHe6
=
3o
.J

,1
,
(\
ror*
,
I
.i
!
"
ov
ir=
!UJ
ftE,
()
al
,
u.
l
>r
o
6-
(J
lzb8
qE
5,
q
Eoo
cao\Obo
(op.
.
tNN0)oCB
TOCDF
Agent Monitoring Plan
October 2009
APPENDIX I
GB SAMPLE PROBE FORAIRLOCKS
Attachment 22 -Page 94
TOCDF
Agent Monitoring Plan
October 2009
iijr
'-*
lA" -,]' ",f -
i
I
I
rffii $t$. I r
$"*,\iFf- l,\Ifi {E$.$F- fiRjij"L"lilG, iltJiiL
N0 r'i 5
!.. ,rft'r1y[- {rrii,ltl rJtl']t'.tllr U [f;iiLl{ ,i0 lr.L&l t*l#L['$ FSEI ,lE rrii [rl'Lt txfitfitl tlt[Tll;ltid-
I. ?$ A*fit;\f, *{hff # tr{ f p1,i,;g rt";:f,1fi.[ rlil,!f f{.nr{E0 !I LH;-,tlilC [:l ;'H to';- {lr1( l-{ ili{
rtcuttH{ rJ{tDr.
t. :i,r[ t/{'. I prtff i,iflF.ti'ritul 5{ F{fr.}tEil r:ll r "4-s{l.i F{:lft.!.,; f rt t"1u:]- irtEF, $u-str.tG ;ul
$trf fir{-Li,$f nrls i..r[ *c-'rti Fi.rn;lt rlLl !{ $firr.[] $l l lr.tl:f,-tr;.i il-:ix rE 4L$ id
*TJLLE${[ IB rr$1 r..Ilslsl i$ Lvi[F{ rs!{r,{tf .
{, ttr,i^i 0nlLLi0 111 :tri l,c.'!}$ilt t,qslt'1-1i u rFrS['r rt t] tti'rtrf L,t!13 tiBl ltrlftIl:{rri.r{
;iE !rl.|ll.. lm llh:{. iil{ i.icliS {J5l N S-dL$ftt,I lil [Lsr [.( laEti lil s.li:l lhi{uF. i^{ lit't!,tl'
wlts* frlllr rtii]*]lf qrl.]ilmc H{ il-;lllt( ii}t'
S{rtt$la Ft+'ir lEt flrrlschl
:.g36*tflir J tu ltrnt ,\lcnr(errnq P!6
,e$ L II. Eturlrc* El
rr,Ir j"I
,.Il.iir 1ffi 'ii-g-;i1i ',,',.i
*I
\/hv.l
I tEE W.ft I t
*:*tlf,L [ft[, Pfiffif ,']"Lumti,
'il [ il{ Lt}[.sHffilfrlf tlLtilff, ,,ilH, I i
f- I, rJ4J.l' *e
slrfi<tIlI
Attachment 22 - Page 95
TOCDF
Agent Monitoring Plan
Decernb er 2006
2004
APPENDIX J
\rX MPF Discharge Airlock Air Cooled Sampling Probe for ACAMS and DAAMS
Attachment 22 - Page 96
?7

7
J-
#
.
J
=
tli
.
+
(q\
**
!

H,

;
;r
!
E
i

E!

il
gI
;
!
e

ti

3r
#H
i

I!
,

ii
,
F$
i
l
i
l
i
H
I
I
I
s+
m

il
i
i
i
H
i
l
i
rr
i
l
ir
i
i
li

-i
ii
i
i
l
i
Tooele CneurcAl Aceur DrsposAL Fecrlry
(roGDF)
ATTAGHMENT 22A
ATLIC
ACENT MONITORI NG Pmru
95% DESIGN FITIAL .
,201q99
a!.'. a -
1 Nov 2009 95% Desisn Final JR CTS
B Sep 2009 Fina! submitted at 95% desisn JR CTS
A 8118120 Release as Deliverable JR ".CTS
REV.DATE REASON FOR REVISION BY CHECK EGS
Area 10 Liquid Incinerator
Project
Specification No.
Rev.
1
AttachmentZZA - Page I
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
This page blank
Attachm ent 22A - Page 2
Attachment22A ATLIC Agent Monito.ing Plan November 2009
Rev I
APPROVALS:
O
b*A
For Jim Rorie
Originator
Chris Scurlock
Checker
W
Robert Comstock
Approver
David deLesdernier
Manager
November 2009
DATE
November 2009
DATE
November 2009
DATE
November 2009
DATE
Attachm ent 22A - Page 3
Attachm ent 22A ATLIC Agent Monito.ing Plan November 2009
Rev I
This page blank
Attachment 22A - Page 4
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev 1
TABLE OF CONTENTS
LIST OF ACRONYMS AND TERMINOLOGY........... ...,.,7+7
22A.1 rNTRODUCTrON........... L*t
22A.2 POLICY/GOALS OF MONITORING OPERATIONS............ ..................123{+
22A.2.2 PerimeterMonitoring........ ....12+++
22A.2.3 ATLIC StationNumLering and Locations..... . L3++
22A.2.4 Summarized Requirements ...!l3}+
22A.4.1 Monitoring Manager...... l33lS
22A.4.2 Monitoring Operations Supervisor.... .........143lts
22A.4.3 Monitoring Tiam Leader..................... --l4g+t
224,5 OBJECTTVES OF THE MONITORING PLAN...... ,.,.,,.,...,..14*T
22A.6 AGENT MoMTORTNG ACTTVTTTES ................ I4A+3224.7 ATLIC MONITORING ACTIVITIES................ ...................143{3
22A,8 ' CATEGORIES OF ATLIC AREAS........ -143+I22A.8.1 Toxic and Process Areas........... ...:;......;,........ .................1&l
22A.8.2 Toxic Process Area Airlocks ................ ................i..r: lE+4
22A.8.3 Outside of Toxic Process Areas.........,. ......153+4
224.85 ATLIC SupportAreas........... 1l_3{422A.9 FrLTERMONrTORING.................. U-3{4224.10 SAMPLTNG PARAMETERS................ ........Iffi
22A.11 DATA HANDLTNG .................15115
224.12 QUALTTY CONTROL.. ...........16_3{s
22A.13 NOTTFTCATIONPROCEDURES .-n3i6
22A.14 CONTROL LTMTTS FOR ACAMS .................. .................1E3++
22A.15 MONTTOR/MONTTORING LOCATIONS ...............:.. 1E-31+224.16 MONITORTNG PLAN ........1E3+7
22A.162 Limiting Conditions of Operation (LCOs)......... 1L3+?
224.16.3 Temporary Changes....... ......1L3{+
221.17 MONTTORTNG STRATEGY.................. ......M1+
22A.17.1 Worker Population Limit (WPL) Monitoring.. .......1111{+
22A.17.2 Short Term Exposure Limit (STEL) and Vapor Screening Limit (VSL) Monitoring... ......199*7
22A.17.3 Source Emission Limit (SEL). ...................19:H*
,,?,r,t"^,$ii+L:Hi",ffi#J::::: :::: .'.::....:....:.:::.:,,,..''......'.'.....'........'.....'.....:':.:.:.:,::::':::.:..L4
224.18.2 MINICAMS .............:.......
22A.18.5 Sample Lines (Suffrxed with "S') ......:.............-............ Lgis
22A,l8.6SilverFluoridePads_VtoGPads.............
22A.18.7 EDT l,2-ethanedithiol rut224.19 STACK CONFIGURATION.............. ...........223+*
22A.I},I ACAMSA4INICAMS......... .,W+
Attachm ent 22A - Page 5
Attachm ent 22A ATLIC Agent Monitoring Plan
EG-zzA-I-1002
EG-ZZA-r-1003
EG-ZZA-r-1004
EG-22A-r-1005
EG-2ZA-r-1006
EG-2ZA-r-1007
EG-Z2A-r-1008
EG-ZZA-I-1009
EG-zzA-I-1010
EG-22A-r-1011
EG-22A-I-t012
EG-22A-I-1013 4
EG-Z2A-I-1014
EG-2zA-r-l0ls
EG-2ZA-I-1016
EG-22A-I-1017
EG-2ZA-I-1018
Interior Sample Probe Assy, GA DAAMS only or ACAMS only
Interior Sample Probe Assy, Lewisite DAAMS only
Interior Sample Probe Assy, ACAMS d DAAMS
Interior Sample Probe Assy, ACAMS WStream Selector (Glove Box)
Interior Sample Probe Assy, MINICAMS WStream Selector (Glove Box)
Interior Sample Probe Assy,IIIIINICAMS Only
Interior Sample Probe Assy, MINICAMS (Exhaust Stack)
Exterior Sample Probe Assy, MINICAMS (Filter Stack)
Exterior Sample Probe Assy, ACAMS/DAAMS (Filter Stack)
Exterior Sample Probe Assy, ACAMS/ dStream Selector, (Filter Bank)
Exterior Sample Probe Assy, Dual DAAMS (Filter Bank)
IGLOO Monitoring Room Sample Probe Assemblies
Interior Sample Probe Assy, Dual MINICAMS Only
Exterior Sample Probe Assy, MINICAMS/DAAMS/SIream Selector (Filter Bank)
Exterior Sample Probe Assy, Dual MIMCAMS (Filter Stack)
Interior Sample Probe Assy. ACAMS only
Interirir Sample Probe Assy. MINICAMS only
November 2009
Rev I
22A.20 EXHAUST STACKMONITORING .,.,.,.,.,.,23#
22A.20.1 Suspended Exhaust Stack Monitoring .............. LrZ?
22A.21 MONTTORTNG FORAGENT FROM PAST CAMPAIGNS .................ruD
22A.22 ACAMS and MINICAMS DATA COLLECTION ............23*2
22A.23 DAAMS SYSTEM , .W
22A.24 BACKUP EQUTPMENT ..........W1
22A.25 MAINTENANCE............... W22A,26 START UP OF MONITORING ,.,.,.....,.,.,.,.,.2#I
22A.27 ACAMS andMINICAMS ALARM HORN 42*
22A.28 ACAMS and MINICAMS ALARM LEVEL 25?PH.
22A.29 PORTABLE ACAMS, MINICAMS and DAAMS MONITORING TRAILERS................... .......L*4
22A30 CARBONFILTERS ONACAMS andMIMCAMS.................. ......UIr4
22A.31 FUGTTTVE EMISSIONS MONITORING................. ...ruA
22A.32 ALARM RESPONSE REQTTTREMENTS.......... ...............L*5
22A.32.1 Exhaust Stack Alarm for GA or L ............. L3#
22A.32.2 Filter Stack Alarm for GA or L....... ...........L+26
22A.32-3 Workplace Monitoring for GA and L (Category C and D Areas)...... ..L+26
REFERENCES
Drawinss of Air Monitorine Locations:
EG-22A-G-1000, Sheet I thru 6 Title: Instrument Locations Plans-General Arrangement-
MINICAMS/ACAMS/DAAMS
ACAMS/DAAMS Heated Sample Line Assembly Drawing
Probe Assembly Drawinss:
Exhaust Stack Penetration Drawines:
EG-22A-S-1036, Sheet 1 thru 5, Exhaust Stack Penetrations
APPENDICES
A Agent Monitoring Plan Details
Attachment22A - Page 6
Attachm ent 22A ATLIC Agent Monitoting Plan
LIST OF ACRONYMS AND TERMINOLOGY
Acronyms
ACAMS........... Automatic Continuous Air Monitoring System
AEL................. Airbome Exposure Limit
AL ................... Alarm Level
NL .................. Airlock
AMP ................ Agent Monitoring Plan
ATLIC Area 10 Liquid Incinerator
AWFCO Automatic Waste Feed Cutoff
CAL................. Chemical Assessment Laboratory
CAMDS........... Chemical Agent Munitions Disposal System
CDC................. Centers for Disease Control and Prevention, Dept of Health and Human Services
CDRL .............. Contract Data Requirements List
CFR' ................ Code of Federal Regulations
CMA................ Chemical Materials Agency
CON ................ Control Room
COR................. Corridor
CPA................. Conversion Pad Assembly
CWM............... Chemical Warfare material
DAAMS Depot Area Air Monitoring System
DCD ................ Deseret Chemical Depot
DPE ................. Demilit aization Protective Ensemble
ECL ................. Engineering Control Level
GA................... Nerve Agent GA, Tabun
GC/FPD........... Gas Chromatograph / Flame Photometric Detector
GC/MSD ......... Gas Chromatograph / Mass Spectrometer Detector
GFP ................. Govemment Furnished Property
GPL ................. General Population Limit
HIST................ Historical
HVAC Heating, Ventilation, and Air Conditioning
IDLH Immediately Dangerous to Life or Health
L ...................... Lewisite
LCO................. Limiting Condition of Operation
LOP ................. Laboratory Operating Procedure
LMQAP........... Laboratory and Monitoring Quality Assurance Plan
LQCP............... Laboratory Quality Control Plan, TOCDF Site Plan
LVS ................. Low-Volume Sampler
MCP ......:......... Monitoring Concept Plan
MINICAMS* .. Miniature Continuous Air Monitoring System
MSB ................ Monitor Support Building
MSD' Mass Spectroscopy Detection
NRT................. Near Real-Time
OBS ................. Observation Corridor
ORR................. Operational Readiness Review
P&A................. Precision and Accuracy
PAS ................. Pollution Abatement System
PPE .................. Personnel Protective Equipment
QA................... Quality Assurance
QC ................... Quality Control
November 2009
Rev I
Attachm ent 22A - Page 7
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
QM .................. Quality Managernent
QP.................... Field Quality Control Samples
RCRA.............. Resource Conservation and Recovery Act
RDTE Research Development Test and Evaluation
RL.................... Reporting Limit
RTAP............... Real Time Anallical Platform
SAF ................. Site Analytical Facility
SEL.................. Source Emission Limit
SOP ................. Standard Operating Procedure
SPS .................. Secondary Power (Distribution) System
STEL Short-Term Exposure Limit
TOCDF............ Tooele Chemical Agent Disposal Facility
UPS ................. Unintemrptible Power Supply
VOC ................ Volatile Organic Compound
VSL ................. Vapor Screening Limit
WAP................ Waste Analysis Plan
WPL ................ Worker Population Limit
Z ...................... A generic designation of an applicable monitoring level such as STEL, WPL, VSL, GPL or
SEL.
Attachmentz2{ - Page 8
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
Terminology
Action Level - A pre-determined set point that triggers a specified action.
AEL: Airborne exposure limit is the allowable concentration in the air for workplace and general population
exposures. AELs include worker population limits (WPLs), short-term exposure limits (STELs), Vapor
Screening Limit (VSL;, immediately dangerous to life or health values (IDLHs), and general population
limits (GPLs).
Alarm Level (AL): Alarm Level at which the ACAMS or MINICAMS (Near-Real Time) monitor will
alarm to alert personnel of a potential upset conditions. All sampling and analytical monitors must, at a
minimum, measure within +25% of the true concentration 95o/o of the time. Alarm levels are defined in
Attachment 22A, Appendix A.
Baseline (Initial): Before each individual agent campaign the monitoring system is operated in the
configuration in which it will be us'ed during the campaign. This is known as baseline operations. The
purpose for the baseline is to provide evidence that the whole system will perform within required tolerances
and requirements, and to document the configuration of the system at the time of the baseline. Once a
system is baselined,
configu{.ation confrol based on thp precision and accuracy study. at the start of the initial baseline study.
Category A Area: Ttre toxic processing area supported by the cascade ventilation system designated for
probable liquid and vapor agent contamination (for example, TOX area, LIC room).
Category B Area:. The toxic processing area supported by the cascade ventilation system designated for
possible vapor agent contamination only.
CategoryCArea:ThenontoxicworkareaadjacenttoCategoryAor@
supported by the cascade ventilation system designated for possible low-level vapor agent contamination (for
example, observation corridors).
Category D Area: The nontoxic work area designation for areas considered uncontaminated.
Category E Area: The area designated for a positive pressure, filtered air environment (for example,
Control Room).
Distal End: Location where the air sample enters into the sampling system.
ECL: Engineering Control Level (ECL) is used to indicate that the sensitivity of the ACAMS or
MINICAMS at this location has been changed to provide representative readings in agent contaminated areas
that are higher than the VSLand lower than IDLH monitoring.
Engineerlng Control or Under Engineering Control: When the environment in a room or area is under
negative atmospheric pressure and the evacuated air is processed to remove contamination, the area or room
is considered to be "under engineering control." An example is a munitions processing room that is expected
to be contaminated with agent. The room is maintained under negative pressure to prevent agent leakage out
of the room. The air that is evacuated from the room is filtered through carbon to remove the agent.
GA: Nerve agent GA (Tabun).
GPL: General Population Limit: The allowable time-weighted average concentration for the general
population that represents the maximum concentration to which the general population may be exposed 24
hours per day,7 days a week, for a 7}-year lifetime. The limit applies to the entire population, including all
AttachrnentzzA - Page 9
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev I
ages and medical conditions. For G-agents, the GPL is 1 x 10-6 -g/-' as a24 hour TWA. For L, the GPL
is 3 x 10-3 ^glnf asaT2hourTWA.
IDLH: Immediately Dangerous to Life or Health (IDLH): The maximum concentration from which, in the
event of a respirator failure, one could escape within 30 minutes without a respirator and without
experiencing any escape impairing (for example, severe eye irritation) or irreversible health effects. DLH
levels are 0.1mg/m3 for G-agents. For L,0.36 mg/m3.
Interferent: An interferent is a chemical compound that will cause an Automatic Continuous Air
Monitoring System (ACAMS), Miniature Continuous Air Monitoring System (MINICAMS), DepotA4d
Depot Area Air Monitoring System (DAAMS) to false alarm or malfunction in such a way that they could
not detect agent. There are some interferents that mask agent so it is not detectable, including some paints,
lubricants, and even some foods. The DAAMS analysis is better at discriminating between agent and an
interferent than the ACAMS and/or MINICAMS. For this reason, DAAMS are paired with A€AA{S
aIACAMS anilor MINrcAMS at many locations for the purpose of confirming or denying alarms.
L: Lewisite, or (chlorovinyl dichloroarsine).
Neat Agent: Neat agent is agent that has not been diluted since manufacture or preparation. It may not be
"pure" but it is as manufactured. Once it is diluted, it is no longer considered neat.
QP: Quality Plant sample: The quantitative result obtained from challenging an
ACAMSA{IMCAMS/DAAMS or sample line with a solutionprepared ata known concentration.
RDTE Dilute Solutions: RDTE Dilute Solutions are
withhezardeu+industrial eherr:eals (aeidq ba^es; er selvente); and are defined by the agqrt eeneentretien
+n@hey are as follows:
Agent
G-agents
Lewisite
Maximum Total Ouantity
20.0 mg
50.0 mg
Maximum Concentration
2.0 mg/ml
5.0 mg/ml
SEL: Source Emission Limit. SEL is a ceilingvalue that serves as a source emission limit, and not as a
health standard. It is used for monitoring the exhaust stack. The SEL provides an early indication of upset
conditions, and must be accurately measurable in a timely manner. Modeling of worst -case credible
conditions at each installation must confirm that the general population limit (GPL) monitoring level is not
exceeded at the installation boundary as a consequence ofreleases at or below the SEL. The SEL value for
G-agents is 0.0003 mg/m3 and, for L is 0.03 mg/m3. It is not expected to use a dilution control device for
analysis of the exhaust gas,gg as the gas will be cooled to 40"F after leaving the scrubber to remove
moisture, and then reheated to -200'F.
STF.L: Short Term Exposure Limit is the maximum concentration to which unprotected chemical workers
may be exposed to for up to 15 minutes continuously. For G-agents, the STEL is 1 x 104 mdm' four times
daily. For L, the STEL is 3 x l0-3 mglm3, one time daily.
STEL Concentration: A concentration equivalent to the STEL value but without time weighting (i.e., a one-
cycle reading of a Near-Real Time monitor).
VSL: Vapor Screening Limit. A vapor concentration term that is independent of time. It may be used to
define the level to which an item is monitored to determine the agent contamination level, or altemately, the
readout of an NRT monitor. For G-agents, the VSL is 1 x 104 mg/m3. For L, the VSL is 3 x 10-3 mg/m3.
Attachm ent 22A - Page l0
o
Attachm ent 22 A ATLIC Agent Monitoring Plan November 2009
Rev 1
WPL: Worker Population Limits. The average allowable concentration that an unmasked worker could be
exposed to for an 8 to 12 hour workday 40 hours per week for 30 years without adverse effects. The WPL
foi C,q,lf has been adjusted to reflect a l2-hour work shift. The l2-hour WPL for G-agents is 2 x 10-5 mghrf ,
andLis3xl0-3mg/#.
Zz A gerreri,Lc designation of an applicable monitoring level such as STEL, WPL, VSL, GPL or SEL.
Attachmentzz{-PageII
Attachm ent 22AATLIC Agent Monitoring Plan November 2009
Rev I
22A.1
22A.1 .l
AGENT MONITORING PLAII
INTRODUCTION
The ATLIC will use a Liquid lncinerator system (LIC) that disposes chemical agents GA,
Lewisite and Spent Decontamination Solution (SDS) through high-temperature incineration.
Unlike TOCDF, it is not expected to use a dilution control device for analysis of the exhaust
gas, as the gas will be cooled to 40'F after leaving the scrubber to remove moisture, and then
reheated to -200"F. Filter bank monitoring will be performed by sequencing Near Real Time
Monitors (NRT) through the Mid-bed One position. DAAMS monitoring will be performed
at the Mid-bed One and Two positions. For GA monitoring, ACAMS will be used with co-
located DAAMS for confirmation and historical analyses where called for. Silver fluoride
pads or V to G pads will be placed in the sample stream for GA ACAMS and DAAMS to
cause a reactionthal+sults!fu! rgg$ in a species with a narower chromatographic peak.
For Lewisite, MIMCAMS will be used
located DAAMS for confirmation and historical analysis where called for. A supply of 1,2-
ethanedithiol (EDT) will be used for Lewisite monitoring with a MINICAMS. The EDT will
be introduced to the distal end of the sample line to react with the Lewisite to form a
derivative that is more stable and transportable.
POLICY/GOALS OF MONITORING OPERATIONS
Purpose
This Monitoring Plan contains monitoring requirements for GA and Lewisite, bulk
processing, and provides identification of monitoring devices and sampling locations. The
monitors are used to provide agent detection and measurement to aid in providing worker
and general population protection, and to indicate ATLIC operations are in control. ACAMS
will be used to monitor for GA agent and MINICAMS will be used to monitor for L.
This plan reflects the monitoring for each processing area when it is being used for agent
work. When agent work in a given area is suspended, the monitoring for that area may be
suspended as stated in Paragraphs Wi\,9, 22A.++1U.3,22A11-5- e*22A.20 or
22A.21., R€fore eampaigns ottl€r t ing
@.
The primary purpose of Monitoring is to have near real-time and historical analytical data to
limit/prevent and document exposure of personnel to chemical warfare agents and protect
the environment from the introduction of agents. Agent monitoring is also performed for
process control purposes to identify upset conditions in the processes and to measure agent
concentrations in toxic areas which allow management to make decisions on protective
clothing requirements for entries into toxic areas.
Perimeter Monitoring
Monitoring of the perimeter of the Deseret Chemical Depot (DCD) is conducted by Deseret
Chemical Depot (DCD) personnel. Perimeter monitoring provides evidence and documents
whether there is any chemical agent migration outside of DCD.
ATLIC Station Numbering and Locations
This Monitoring Plan provides a table of locations and station numbers (Appendix A)+r)
for agent monitors associated with ATLIC.
22/^.2
224.2.1
224.2.1 .1
224.2.1 .2
224.2.2
224.2.2.1
22A..2.3
224.2.3.1
Attachm ent 22A - Page 12
t.
Attachm ent ZZAATLIC Agent Monitoring Plan
22A,2.4
22A.2.4.1
22A.2.4.2
22A.2.4.3
November 2009
Rev I
Summarized Requirements
Monitoring Operations monitors for GA and Lewisite bulk containers, processing and
secondary waste. There are three configurations that monitor for GA employed at ATLIC:
ACAMS only, ACAMS with coJocated DAAMS, and DAAMS only. ACAMS -only
stations primarily are used in toxic areas to provide information to management for
protective clothing determination for entries into toxic areas. ACAMS with co-located
DAAMS serve two purposes: 1) the ACAMS is the primary monitor, which quantifies the
amount of agent present. Concurrently, ACAMS provide an early warning system to facility
personnel of a potential agent release at or above the alarm set points in Attachment 22d,
Appendix A. The co-located DAAMS are used to confirm or deny the presence of agent. 2)
DAAMS tubes are also analyzed from these stations on a monthly rotational basis to monitor
areas at the WPL. Responses to ACAMS alarms are IAW Section 22A.31.
There are fe*th1gq configurations that monitor for L employed at the ATLIC: MINICAMS
only; MINICAMS with co-locatedDAAMS; ; and
DAAMS only. MINICAMS -only stations primarily are used in toxic areas to provide
information to management for protective clothing determination for entries into toxic areas.
MINICAMS with co-located DAAMS serve two purlroses: l) the MINICAMS is the
primary monitor. which quantifies the amount of aeent present. Concurrently. MINICAMS
provide an early wamins system to facility personnel of a potential agent release at or above
the alarm set noints in Attachment 22A. Apoendix A. The co-located DAAMS are used to
confirm or deny the oresence of aeent. 2)- the DAAMS from these stations are analyzed on a
monthly rotational basis to monitor areas at the WPL.ffi
Responses to MINICAMS alarms are
IAW Section22A.31.
DAAMS-only stations for GA and L are used for historical purposes to monitor areas at the
WPL. The DAAMS historical tubes are not connected to an alarm. Historical DAAMS are
located in areas not expecting to have agent.
RESPONSIBILITIES
The Monitoring group supports the ATLIC by operating and maintaining monitoring
equipment and routinely collecting liquid and solid samples in and aroundthe ATLIC.
Monitoring personnel may designate the sampling duties to a trained sample technician. The
Monitoring Department utilizes a variety of monitoring equipment. Much of the equipment
is Government Furnished Property (GFP), which is augmented by equipment, and supplies
that are obtained from commercial vendors. Liquid and solid samples will be delivered to
the Chemical Assessment Laboratory (CAL) or Site Analytical Facility (SAF) for analysis.
The analytical department personnel are responsible for performing the analysis or
transferring the samples requiring analysis to a Utah certified subcontractor laboratory.
Laboratory Quality Control personnel are responsible for inspecting and auditing all
Laboratory (analytical and monitoring) operations.
COORDINATION
There are several levels of coordination performed by the Monitoring Department. Other
than normal working relationships within the ATLIC and at the CAL or SAF, there are three
- supervisory levels.
Monitoring Manager
The Monitoring Manager coordinates additions or deletions to the workload such as new
sampling or monitoring requirements. S/he will be the control point for any changes in
Attachm ent 22A - Page l3
o
22/^.3
22A.3.1
22A.4
,
G.: l4
22A.4,1
224.4.1 .1
:'
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev 1
22A,4.2
22A.4.2.1
monitoring or sampling parameters such as changes of sampling times or sample flows.
Monitoring Operations Supervisor
The Monitoring Operations Supervisor works directly for the Monitoring Manager and
coordinates the work load with the Team Leaders of all shifts. The supervisor will
coordinate the timing of special monitoring and sampling operations with the Operations
Supervisor and Facility Shift Manager.
Monitoring Team Leader
The Monitoring Team Leader for each shift will coordinate the timing of routine monitoring
and sampling operations with the Control Center personnel. This coordination is specified in
the applicable Laboratory Operating Procedutes (LOPls). The Team Leader or designated
certified monitoring technician and at least one team member will respond to all ACAMS
and/or MINICAMS alarms in accordance with approved monitoring procedures and will be
in direct contact with the Control Center.
OBJECTTVES OF THE MONITORING PLAN
The Monitoring Plan provides identification of monitoring devices and sampling locations.
The monitors are used to provide agent detection and measurements to aid in providing
worker and general protection, and to indicate facility operations are in control.
AGENT MONITORING ACTIVITIES
Monitoring activities are structured to support toxic operations. Maintenance and QC
activities for ACAMS and/or MINICAMS are scheduled during times that do not interfere
with operations. This is done by obtaining permission from the Control Center before any
monitor or sampling device is taken out of service. The DAAMS for GA an#gnd
lv{S{ICAA4$ferL isafq used for the collection of samples of agent for confirmation of
ACAMS for GA for L alarms. DAAMS are the primary
monitoring in areas not monitored with ACAMS or MINICAMS. The monitors listed in the
Appendices must be operational when performing the operations they support except when
off-line for challenging and corrective actions, as documented in approved procedures or if
monitoring has been suspended in accordance with this plan.
ATLIC MONITORING ACTTYITIES
ln the demilitarization area,hazard category classifications and personnel occupancy are the
factors used to determine monitoring activities. When monitoring is conducted for personnel
protection or to assess potential personnel exposure it must be sufficient to identiff, verify,
and quantify the agent. VSL and WPL monitoring is performed in areas where workers may
have a potential exposure to chemical warfare agent. Selected "C" hazard category areas of
the facility have WPL monitoring conducted on a daily basis for all work areas where
chemical agent is present without secondary vapor containment and workers are not required
to wear respirator protection, while other "C" hazard category areas have WPL monitoring
conducted on a monthly basis in accordance with this plan.
CATEGORIES OF ATLIC AREAS
Toxic and Process Areas
These areas are potentially contaminated as a result of the presence of uncontained liquid
agent or agent vapor. This area is monitored using an ACAMS and/or MINICAMS. The
agent concentrations determine the Personnel Protective Equipment (PPE) that is required
for personnel entry. At times, the monitoring may be enhanced to allow the PPE for specific
224.4.3
224.4.3.1
22A..5
224.5.1
22A^.6
224.6.1
22/^.7
22A.7.1
22A..8
22A.8.1
224.8.1 .1
AttachmentzzA - Page 14
o
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
22A,8.2
22A.8.2.1
toxic areas to be reduced to enhance worker mobility. This requires Safety
Manager/Designee or Temporary Change approval. This could include changing the
ACAMS and/or MINICAMS to a more sensitive detection level or adding DAAMS in order
to confrm or deny an ACAMS fur MINICAMS @
Iv{S{I€AA4$alarm. Toxic Area ACAMS and/or MINICAMS are used to quantifu potential
exposure ofpersonnel.
Toxic Process Area Airlocks
Airlocks serve as access/egress points between contaminated areas and clean work areas. To
limit the transfer of agent from "toxic" areas to "work areas", under normal conditions, items
and personnel are cleared through an airlock. Procedures govem egress through airlocks to
prevent items or personnel from exiting toxic areas until they have been monitored by an
ACAMS and/or MINICAMS. Agent readings must be less than the level set by egress
procedures to clear items and personnel from the airlock.
Outside of Toxic Process Areas
The Processing Bay is an area where agent vapor is not normally expected, but a potential
exists for lowJevel vapor contamination. This area is considered as "under engineering
control" and is monitored at the VSL and WPL level daily.
The Observation corridor is considered to be "under engineering controls" and is monitored
at the VSL daily and at the WPL level at least monthly.
Work Areas
At the ATLIC, there are many work areas where toxic operations are not conducted. These
area3 are not "under engineering control" and have little or no potential for vapor
contamination. These areas are not monitored for agent. Examples of work areas include the
Generator Room, Central Decon Room, and Acid Feed supply building.
ATLIC Support Areas
The Control Center, and Entry Support areas require WPL monitoring. This is a safety
requirement to verify that workers have not carried contamination into these areas.
FILTER MONITORING
Multiple Bank Carbon Filter units provide negative pressure ventilation for potentially
contaminated areas throughout the enclosure. A description of the ATLIC ventilation carbon
.filters is located in Attachment 5 (Inspection Plan). Filter monitoring is performed at the
VSL and WPL levels in order to detect evidence of filter degradation in order to allow
changing of the filter media before there is a possilility of an agent leak to the atmosphere.
The ATLIC filter stack shall be monitored with ACAMS and/or MINICAMS and DAAMS
-for an1, agents being processed in the furnace. Additionally, on the Filter stack, only
DAAMS tubes shall be required to monitor for agents from past campaigns, if the
contaminated charcoal has been removed after the completion date of the campaign. If the
first two filters are not changed out after an agent campaign, then the Filter stack shall be
monitored with ACAMS and/or MINICAMS and DAAMS for agents from these past
campaigns. Filter stack DAAMS samples, shall be collected and analyzed every 12 hours. ln
addition, Filter Stack DAAMS tubes shall be collected andanalyzed if an associated
ACAMS and/oT MINICAMS go€sgq into an alarm.
ffi
The ATLIC filter mid-bed locations shall be monitored continuously with DAAMS for any
agents being processed (filter online or offline). Filter mid-bed locations will be monitored
using single point sampling. Sample stream switches shall be used to oycle an ACAMS
22A,8.3
224.8.3.1
224.8.3.2
22A.8.4
22A.8.4,1
?2A.8.5
224.8.5. 1
22A.9
224.9.1
224.9. 1.1
224.9.1 .2
Attachm ent 22A - Page l5
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev 1
224.9.1 .3
224.9.1 .4
224.9.2
and/or MINICAMS around the three filters at the mid-bed 1 position (between the first and
second beds), for any agents being processed (filter online or offline). Locations of the mid-
bed ACAMS and/or MINICAMS and DAAMS tubes are specified in Attachment 22A,
Appendix A. DAAMS tubes monitoring the mid-bed shall be arnlyzed daily and if the mid-
bed ACAMS and/or MINICAMS goes into alarm.
@
tubes shall be eelleeted and enalyzC every 12 hetm,Reserved
eserved
If a confirmed ACAMS and/or MIMCAMS agent reading on the mid-beds reaches {VSL
for any agent being monitored, the change-out of the filters shall commence as specified in
Module X. Exception to this is after the first mid-bed. If agent readings confirm the presence
of agent between the first mid-bed and second mid-bed, monitoring will be discontinued in
this location and the ACAMS and./or MINICAMS will be relocated between the second mid-
bed and third mid-bed
SAMPLING PARAMETERS
The operational control limits for sampling parameters such as sample flow rate and duration
of sample time are under configuration control and documented in precision and accuracy
studies before "Base Line" monitoring is performed and can only be changed by the
Monitoring Manager following approved procedures.
DATA IIAIIDLING
Monitoring parameters, such as flow rates and sample collection start and end times are
recorded and accompany the sample to the laboratory. Comments pertaining to equipment
malfunction (such as failure to sequence) are currently recorded in logbooks at each station.
Sample problems are also annotated with pertinent information. This information is used to
identiff the need for corrective action to prevent recurring deficiencies. The corrective
action may consist of such things as additional training or changing the types of preventive
maintenance for particular tlpes of equipment. All raw data from ACAMS and
MINICAMS, including calibrations and challenges, (except as noted in the Table in
Appendix A) are gathered on the Facility Control System in the Control Center and
maintained in a database. The ACAMS and MINICAMS strip-chart is used to evaluate
agent concentration and alarm cycle time.
QUALITY CONTROL
ATLIC QM (Quality Management) Program
Confidence in sampling methods that characterize actual ambient concentrations of agent in
a given matrix is of utmost importance. An extensive QA Program is required to ensure the
quality of monitoring data is adequate for its intended use. The programmatic Laboratory
and Monitoring Quality Assurance Plan (LMQAP) and the Monitoring Concept Plan (MCP)
are guidance documents for all laboratories supporting agent demilitarization operations.
TOCDF Laboratory Quality Control Plan (LQCP) will be incorporated for the ATLIC. The
TOCDF Laboratory Quality Control Plan (LQCP) and the ATLIC Agent Monitoring Plan
(AMP) were prepared in accordance with the requirements of the LMQAP and MCP. The
22/^.10
224.10.1
22A.ll
224.1 1.1
22A..12
22/'^.12.1
224.12.1 .l
Attachm ent 22A - Page l6
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
22A.12.2
22A.12.2.1
TOCDF LQCP and ATLIC AMP (Attachment22A) must be at least as stringent as the
programmatic guidance.
Failure To Monitor
All of the monitoring identified in this plan must be operating and in control during
processing in a given area or it will be considered a "Missed Monitoring" and will be
reported as such. The following are exceptions:
During campaign changeover transition periods when monitors are being changed to a new
agent campaign.
When a Temporary Change has been approved (see Paragraph22L.15l6.3).
If the ACAMS or MINICAMS is offline for more than one and a half hours, the DAAMS
becomes the primary monitor and therefore must be analyzed. This does not apply to the
Filter stack or exhaust stack.
If mitigating measures have been taken to secure an area and processing has ceased, then
monitoring at that station will not be considered a "missed monitoring." This does not apply
to the Filter stack or exhaust stack.
,NOTIFICATION
PROCEDT]RES
The Fagility Control System in the Control Center collects data from each ACAMS and
MINICAMS and stores the readings in a temporary computer file. A computer in the
Control Center uses this file to access agent readings from each ACAMS and MINICAMS.
The ACAMS and MINICAMS shall alarm at each location when detected agent
concentrations meet or exceed the alarm set points. ACAMS and MINICAMS that monitor
toxic areas under engineering control may not have a local alarm. (See Section 22A.26) Thrs
is because the ACAMS and MINICAMS would be constantly in alarm.
In the event of an ACAMS or MINICAMS alarming at or above the alarm level, outside of
engineering controls, or in category "C" areas or at the SAF Laboratory, the Control Center
will notify the Monitoring Team Leader or designee. The Team Leader or designated
certified monitoring technician along with one other Monitoring person will respond by
going to the location of the ACAMS or MINICAMS that is in alarm. Monitoring personnel
evaluate alarms by observing the chromatogram and troubleshooting for malfunctions,
verifying the alarm level set point, challenging an ACAMS or MINICAMS with an agent
standard to ensure that it is operating correctly, and collecting the associated GADAAMS
tubes for analysis.
The Alarm Response Requirements are specified in Section22A.W. If the alarm is
confirmed by DAAMSffi, appropriate corrective measures are
taken as specified in Attachment 3, (LQCP). When it is believed that the area has been -
cleaned, the area monitor will determine if the corrective measure was adequate. If results
are less than the alarm level set point, normal operations may commence.
The Control Center shall be notified if the SAF Laboratory ACAMS or MINICAMS alarms
and shall notify Monitoring per the requirements of Paragraph22A.ll!3.2. If the SAF
Laboratory has an alarm, neat agent operations at the SAF Laboratory shall be suspended. If
the alarm causes ATLIC to fail to meet LCO requirements, waste feed shall cease for all
furnace at the ATLIC.
All ACAMS and/or MINICAMS alarms for GA:lrf!.L, which have coJocated DAAMS,
require analysis of the DAAMS tube(s). The analytical results of the DAAMS tubes, pulled
due to an ACAMS and/or MINICAMS alarm, shall be reported to the Control Center. The
224.12.2.2
22A.12.2.3
22A.12.2.4
224.12.2.5
22A.13
22A.13.1
(.*
224.13.2
224.1 3.3
224.13.4
Attachm ent 22A - Page 17
Attachm ent 22 A ATLIC Agent Monitoring Plan November 2009
Rev I
22A.14
22A.14.7
Laboratory will maintain the official record of all DAAMS results. lr{SII€AJv{S.(trith*
CONTROL LIMITS FOR ACAMS
All ACAMS and MINICAMS that monitorthe exhaust stack shall be challenged every 4
hours plus or minus 30 minutes in accordance with TE-LOP-524. The ACAMS and
MIMCAMS challenge results are collected electronically for all ACAMS and MINICAMS
connected to Facility Control System. The data for the ACAMS and MINICAMS not
connected to the Facility Control System are recorded manually and then archived. These
data are used to assess the performance of individual units and the performance of the
overall monitoring system. The LQCP details the pass/fail criteria. The performance of the
ACAMS or MIMCAMS is tracked daily and any ACAMS or MIMCAMS that falls into the
fail category is corrected or replaced.
MONITORiIVIONITORING LOCATIONS
The monitors within the ATLIC site were placed in locations to maintain minimum distances
to the actual sampling point while keeping the equipment out of hazardous areas. For the
actual monitoring locations at the ATLIC, see Appendix A and the associated drawings.
MONITORING PLAN
List of Monitors
Appendix A outlines the monitoring stations for operations of the ATLIC.
Limiting Conditions of Operation (LCOs)
The monitors identified for a given campaign must be operating at all times and are
considered to be Limiting Condition of Operation (LCO). In the event that a monitor is not
capable of operating, immediate corrective actions will be taken. (See Paragraph
22A.+5!3.3).
Temporary Changes
Temporary changes may be made to the requirements of this plan by following the normal
procedures, which provide proper approvals and documentation. This will allow for adding
to, reducing the number of or changing the configuration of agent monitors on a temporary
basis. The Permittee shall notiff the Executive Secretary orally of any reduced monitoring
applicable to this Attachment prior to implementation.
Additional Support
Occasionally support from DCD, or other TOCDF facilities is required for additional
monitoring rrpp* This may include the use of a Real Time An-alytical Platform (RTAP)
or monitoring trailer for increased monitoring of an area, or for an upset condition.
MONITORING STRATEGY
Worker Population Limit (WPL) Monitoring
Worker Population Limit (WPL) monitoring will be performed with DAAMS. The WPL
monitoring is conducted daily for all work areas where chemical agent is present without
secondary vapor containment and workers are not required to wear respirator protection.
22I.15
22A.15.1
22A.16
22A.16.1
224.1 6.1 .1
22/^.16,2
22A.t6.2.1
224.16.3
224.16.3.1
22A16.4
224.16.4.1
22/^.17
22A.17.1
224.17 .l .r
Attachm ent 221^ - Page I 8
Attachm ent 22A ATLIC Agent Monitoring Plan
224.17.2
224.17.2.1
224.17.2.2
224.17 .2.3.
22/'^.17.3
224.I"/ .3.1
22A.17.4
November 2009
Rev I
Also, the Category C areas where agent is not present are monitored on a monthly basis.
WPL monitoring will be required for the first five days of agent processing.
Short Term Exposure Limit (STEL) and Vapor Screening Limit (VSL) Monitoring
VSL monitoring will be performed at all workplace locations as specified in Appendix A
DAAMS for GA aruLL ill be used to
confirm or deny a VSL exceedance. lncoming air will be minimized to prevent dilution of
sample when clearing bagged items. The filter stacks use the VSL monitoring limit on the
ACAMS and/or MIMCAMS itself, but any confirmed release will be reported in a
concentration (mg/m3).
STEL and VSL are equivalent in terms of concentration values, but are different in that
STEL is based on a 15 minute time-weighted average and that VSL is independent of time.
Source Emission Limit (SEL)
SEL is a ceiling value that serves as a source emission limit, and not as a health standard. It
is used for monitoring the incinerator exhaust stack. Staggered ACAMS and/or MIMCAMS
which monitor continuously are required on the exhaust stack for each agent being
processed. DAAMS for GA aOtd.L are used
as confirmation for any ACAMS (GA) or MINICAMS (L) alarm above the alarm level. A
Waste Feed Cutoff for allthe incineratorffirrnaee is initiated when an alarm at or above the
alarm level is exceeded at the exhaust stack.
AEL Levels
G-agents mg/m3 L mg/m3
STEL
(15-Minutes)
0.0001 0.003
WPL'
(12-Hours)
0.00002 0.003
WPL
(8-Hours)
0.00003 0.003
WPL
(4-Hours)
0.00006 0.003
SEL 0.0003 0.03
IDLH
(30-Minutes)
0.1 0.36
VSL 0.0001 0.003
Notes:
' The 12-hour WPL monitoring level will be used for routine historical
monitoring and for areas where munitions are stored outside of secondary
contairunent.
Attachm ent 22A - Page I 9
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev 1
224.17.5
224.17 .5.1
Monitoring Cessation
Confirmation monitoring may be suspended once agent has been confirmed to be present
(NRT-only monitoring will be required to veriff effectiveness of corrective actions). Once
corrective actions have been resolved, confirmation monitoring shall be re-instituted. Any
ACAMS or MINICAMS alarm, without co-located DAAMS for GA and LtrI4S{I€AA{$
fert, is assumed to be agent.
Agent specific monitoring may be halted if no corresponding waste is inside the ATLIC
boundaries. Once an agent waste enters the ATLIC boundaries, monitoring must be
reinstated for that agent in locations specified in Appendix A. This condition does not apply
to the Filter stack.
MONITORING EQUIPMENT
The following is a discourse of the tlpes of equipment used for agent monitoring:
ACAMS
The ACAMS is a near-real-time monitor system with the ability to detect and report the
concentration levels of 'GA' chemical agent in the air at either low levels or high levels
depending on its monitoring configuration. The ACAMS is configured for the appropriate
detection level and the current agent(s) locations. The ACAMS is equipped with remote,
audible, and visible alarm systems. The ACAMS samples air during a preset sample period.
Agent present in the sample air stream is collected on a solid sorbent bed dwing the sample
period for gas chromatographic (GC) analysis. The results of the GC analysis of the
sampled air are displayed on the front panel of the instrument. A permanent record of the
chromatogram and the agent concentration is recorded on a strip-chart. The ACAMS
produces an audible and visible alarm when the agent concentration level is at or above the
preset alarm level. The Facility Control System records the alarm time and agent
concentration. The ACAMS are used to detect process upsets and are located in areas
where concentrations ofagents are ofconcern or where rapid response is required to allow
personnel to work in lower levels of protective dress.
In process areas where high concentrations of agents are possible, a Low-Volume Sampler
(LVS) may be utilized. The LVS operates in a process area by drawing air through the LVS,
retaining a l-ml sample. It then sends that l-ml sample to the ACAMS, which analyzes it
and reports the actual agent concentration of the area being sampled. This process is
necessary to prevent saturating the ACAMS.
MINICAMS
The MINICAMS is a near-real time air monitor system with the ability to detect and report
the concentration levels of 'L' chemical agent in the air at either low levels or high levels
depending on its monitoring configuration. The MINICAMS is configured for the
appropriate detection level at the specified agent(s) sample locations. The MINICAMS is
equipped with remote, audible, and visible alarm systems. The MINICAMS samples air
during a preset sample period. Agent present in the sample air stream is collected on a solid
sorbent bed during the sample period for gas chromatographic (GC) analysis. The results of
the GC analysis of the sampled air are displayed on the front panel of the instrument. A
permanent record of the chromatogram and the agent concentration is recorded on a strip-
chart. The MINICAMS produces an audible and visible alarm when the agent concentration
level is at or above the preset alarm level. The MNICAMS records the alarm time and agent
22A.17 .5.2
22/^.18
22A.18.1.
224.1 8.1.1
22/'^.18.2
Attachm ent 22A - Page 20
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev 1
224.18.3
22A.1 8.3.1
concentration. The MINICAMS are used to detect process upsets and are located in areas
where concentrations of agents are of concem or where rapid response is required to allow
personnel to work in lower levels of protective dress.
In process areas where high concentrations of agents are possible, a Low-Volume Sampler
(LVS) may be utilized. The LVS operates in a process area by drawing air through the LVS,
retaining a l-ml sample. Itthen sends that l-ml sample to the MINICAMS, which analyzes it
and reports the actual agent concentration of the area being sampled. This process is
necessary to prevent saturating the MINICAMS.
DAAMS
An additional monitoring system used is the DAAMS. DAAMS involve passing sampled air
through a sorbent bed where any agent is being collected. The sample periods are
determined by P&A study results and are in the range of three minutes to twelve hours.
DAAMS analysis is performed using a Class 1 quantitative method. However, when
DAAMS are used in conjunction with an ACAMS for GA anilor MINICAMS for L, the
results are used to confirm or refute the presence of agent. If an ACAMS or MINICAMS is
not monitoring correctly and has associated DAAMS, the DAAMS tubes become the
primary monitor and must be collected andanalyzed. DAAMS samples provide independent
confirmation of positive ACAMS and/or MINICAMS readings and a historical record of
monitoring, in areas not monitored by ACAMS or MNICAMS, at the WPL and GPL
locations.
DAAMS tubes shall use a labeling system to track the specific station and agent of each
tube. All confirmed DAAMS results, greater than the reporting limit (RL), shall be reported
to the Control Center immediately. All confirmed sub-Rl levels shall be tracked and
trended by the laboratory.
Sample Lines
The agent sampling lines are heated to aid in the transmission of the sample. Appendices
C&D show the configuration of the sampling assembly. They consist of Teflon sample lines
with self-regulating heat tape. These ACAMS, MINICAMS and DAAMS sample lines shall
be challenged at the distal end of the sample line every 60 days + 3 days. Other sample lines
may not be heat traced as long as all challenges are performed at the end of the sample line.
In these cases the line is challenged with agent to prove transmission of the agent down the
sample line.
All sample lines must be challenged and demonstrate transmission efficiency prior to the
corirmencement of operations. After the completion of the initial sample line challenge, all
non-toxic sample lines must be challenged at least every 60 days + 3 days.
Sample lines in toxic areas are challenged during campaign changeover.
Sample Lines (Suffixed with "S")
Monitoring stations whose station number is suffixed by an "S" (spool) are to be used for
special or short term monitoring only. The purpose of the "S" stations is to allow monitoring
in specific locations that do not have a regularly assigned ACAMS or MIMCAMS. The
station equipment consists of a sample line only.
When the monitoring is performed, an adjacent ACAMS or MINICAMS will be connected
to the "S" sample line. In some cases the lines are arranged on a spool to allow them to be
reeled out and moved to the point that needs sampling. The ACAMS and MINICAMS that
areusedinconjunctionwiththe..S,,samplelineshave@designate
the station in use. The purpose of the switch is to identify the correct monitoring location to
224.18.3.2
224.18.4
224.1 8.4.1
224.18.4'.2
22A.1 8.4.3
22A.18.5
224.1 8.5.1
ol
224.19.5.2
Attachm ent 22A - Page 2l
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev I
224.1 8.5.3
the Facility Control System. This causes the ACAMS or MINICAMS data to be cataloged
to the correct sampling point and therefore provide accurate traceability of monitoring
results.
During the time the ACAMS or MINICAMS is connected to the spool sample line, the
DAAMS that was associated with the original ACAMS or MINICAMS becomes the primary
monitor for that location. This means that the DAAMS tubes must be ar:r.lyzed, rather than
serving the function of being confirmation DAAMS that only get analyzed in the event of an
ACAMS alarm. Additionally, if the ACAMS and/or MINICAMS alarms while connected to
the spool, there are no DAAJVIS tubes to serve the confirmation function. If there are
readings on the ACAMS or MINICAMS while it is in the spool mode, it must be assumed to
be agent.
Silver Fluoride Pads - V to G Pads
Silver fluoride pad assemblies, or V to G pads*re-qq used with GA ACAMS and
DAAMS stations when ATLIC is processing GA waste. They are designed to place the
silver fluoride pads in the sample stream such that the pads are exposed to the sample
stream. Silver Fluoride pads for GA are used to cause a chemical reaction that result in a
species with a narrower chromatographic peak. All assemblies will contain at least two silver
fluoride pads held in place. Additional pads do not aid or hinder the efficiency. A detailed
description of each type is located in TE-LOP-529,Y|G Conversion Pad Assembly.
ACAMS silver fluoride pads shall be replaced as needed by indicating factors such as
chromatography and/or challenge results. The pads shall be challenged before replacement,
so that the silver fluoride pads that have been in service are part ofthe challenge to ensure
adequate transfer. If the pads challenge is outside 75-125% recovery, qualification of data is
required.
EDT l,2-ethanedithiol
EDT gas (a 200 ppm mix of EDT in N2) is used with L MINICAMS stations and will be
introduced at the distal end of the L sample lines to react with the L to form an L- derivative
that is more volatile and easily transported.
STACK CONT'IGURATION
Agent monitoring of the exhaust stack (PAS) effluent consists of ACAMS, MINICAMS and
DAAMS.
ACAMS/IVIINICAMS
There are three ACAMS assigned to monitor the exhaust stack for GA agent being
processed. Two of the ACAMS for GA agent are on line constantly. Their operating cycles
are staggered to allow one unit to be in the analysis mode while the other is sampling. This
results in continuous monitoring of the exhaust stack. DAAMS analysis is used for alarm
confirmation. The third ACAMS serves as a standby unit when one of the other units is off-
line for challenging or corrective action. The three ACAMS for GA agent are linked to the
Facility Control System individually.
There are sirlhree MINICAMS assigned to monitor the exhaust stack for L agent being
processed. F€{x-Two MINICAMS for L agent are on line constantly. Their operating cycles
are staggered to allow trvryunits to be in the analysis mode while the othertnre-erelg
sampling. This results in continuous monitoring of the exhaust stack. DAAMS analysis is
used for alarm confirmation. The third MINICAMS serves as a standby unit whan one of the
22A..18.6
224.1 8.6.1
224.18.6.2
22A.18.7
224.1 8.7.1
224.19
224.19.1
224.19.1.1
224.19.1 .2
Attachm ent 22A - Page 22
o
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
224.19.1 .3
other units is off-line for challenging or corrective action. The three MINICAMS for L agent
are linked to the Facility Control System individually.
with Cifferent eelrrrms rer alarm een{kmetion. Twe MINI€^&{S ^orve es standby urdts
when twe ef the etha tndtsare eff line fer ehallenging er eerreetive astie* The sfut
.
An alarm is sounded in the €€SFFacility Control Center if the ACAMS or MINICAMS
cycling does not provide 100% monitoring of the exhaust stack for each agent. If this
occurs, an AWFCO is initiated and DAAMS analysis is required for the period the ACAMS
or MINICAMS was not staggered sampling the exhaust Stack.
DAAMS
There are three DAAMS tubes aspirating at all times on each DAAMS manifold for GA and
two DAAMS tubes aspirating at all times for Lewisite. They are the A tube, a B
confirmation tube, and a C contingency tube-.fqgG.A. The], are the A tube and B tube for
Lewisite. A fourth tube for GA and third for Lewisite, which is a QP, is also aspirated in
accordance with the LQCP. The sampling equipment is designed such that a sample is being
collected constantly, even whbn a set of tubes is being replaced. The stack DAAMS will
have a "no-flow" audible alarm to warn operators when the DAAMS is not operating.
EXHAUST STACK MONITORING
Suspended Exhaust Stack Monitoring
Exhaust stack monitoring will not be suspended without CMA Site Project Manager or
designee and the Executive Secretary approval.
MONITORING FOR AGENT FROM PAST CAMPAIGNS
Monitoring in Category A and B areas, for past agent contamination may be discontinued
when the airborne agent contamination for that area is less than 1.0 VSL over a 24-how
period, at a minimum temperature of 70o F, with the ventilation system operating at the
approved flow rates. A confirmed agent reading at or above 1.0 VSL requires that the area
must undergo additional decontamination.
Monitoring in Category C areas for past agent campaign contamination may be discontinued
when the Category C areahas been less than 0.5 WPL(t2-no*) for each agent being
discontinued over a 24-hotr period, , with the adjacent A& B area ventilation systems
operating at the approved flow rates at a minimum temperature of 70oF. Monitoring data
shall be submitted to the Executive Secretary for approval prior to discontinuation of a4y
agent monitor in a C area.
ACAMS and MINICAMS DATA COLLECTION
ATLIC ACAMS and MINICAMS are integrated into the Facility Control System. The
Facility Control System stores all readings taken by each ACAMS or MIMCAMS to a
temporary computer file. From this file, a computer is able to compile trends from each
ACAMS or MINICAMS for up to 72 hours and, upon demand, display these trends to
graphics screens in the Control Center. Various automated reports are used to observe these
trends to be used as a management tool to make improvements and determine the level of
readiness of the overall ACAMS or MINICAMS system. This temporary file is compressed
to an archival file that becomes the permanent record of agent readings. From the archival
file, the computer is able to trend each connected ACAMS or MINICAMS for any desired
22A.19.2
224.19.2.1
22A.20
22A.20.1
22A.20.1.1
22A.21
22A,21 .1
22A.21 .2
22I^.22
22A.22.1
Attachm ent 22A - Page 23
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
22I.23
224.23.1
time period. Results of all ACAMS or MINICAMS challenges are electronically recorded
and, ad4itionally, they are manually recorded in the ACAMS or MINICAMS logbook (see
Section 22A.1{11.1for any potential exceptions to manually recorded logbooks) at each
instrurnent. These results provide a basis for statistical analysis to assess performance and
for reporting to regulatory agencies. Some areas in the ATLIC as noted in Appendix A do
not have Facility Control System, therefore, the ACAMS or MINICAMS chart recorder and
instrument log are used to record readings and QC data that are then archived.
DAAMS SYSTEM
The DAAMS sampling system is capable of collecting agent GA by use of Chromosorb and
L with Tenax sorbent beds. The sample is then analyzed using GCIFPD, MSD, LCMS or
with LCICPMS analysis techniques. The total volume of air sampled is calculated from the
sampling time and the sample flow rate. Desorption of the DAAMS tube into a GCIFPD for
analysis provides the total mass of agent collected. The average air concentration of agent is
then calculated from this data. By increasing the sample time or flow rate, the average
concentration sensitivity can be increased. DAAMS stations shall report agent concentration
at or above their calculated reporting limit for the agent of interest. The lowest calibration
standard used for analysis must be at or below the reporting limit.
BACKT]P EQUIPMENT
The function of the ACAMS or MINICAMS is to rapidly detect agent. Should a needed
instrument fail, the first response is to troubleshoot and repair it in place. Should the
estimated repair time be excessive (as determined by the Control Center) the ACAMS or
MINICAMS will be replaced with an ACAMS or MINICAMS from the contingency stock.
MAINTENAI\CE
The Monitoring Technicians and lnstrument Technicians have completed mandatory
ACAMS and MINICAMS training at the Chemical DemilitarizationTraining Facility
(CDTF) or TOCDF and are qualified to maintain and operate ACAMS and MINICAMS.
The manufacturers' manuals and LOPs provide necessary guidance.
START UP OF MONTTORTNG
.dgent monitoring in the ATLIC will be initiated in each area as needed. A Monitoring Plan
for each campaign must have approval from the CMA Site Project Manager or Designee.
The monitoring identified in the "campaign specific" plan will be started in sufficient time to
allow baseline data collection. The operational readiness review (ORR) for the campaign
shall include review of the plan and the baseline data. The information in this plan is the
basis for all campaign specific plans.
ACAMS and MINICAMS ALARM HORN
There are cases where ACAMS or MINICAMS have an alarm in the Control Center but
there is no local alarm. This is a safety measure. There are areas that have frequent alarms
but it does not mean that the workers in the area must mask. It is important that the workers
do not become accustomed to ignoring ACAMS and MINICAMS alarms. Some examples
are: Toxic Area ACAMS and MINICAMS and airlock ACAMS and MINICAMS. ln all of
these cases an alarm does not indicate that the people in the location of the ACAMS or
22A.24
224.24.1
224.25
224.25.1
224.26
224.26.1
224.27
224.27.1
Attachrn ent 22A - Page 24
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev 1
22A.28
224.28.t
MINICAMS need to mask. ACAMS and MINICAMS that have the horn disconnected must
have a sign at the ACAMS oTMINICAMS indicating such.
ACAMS and MINICAMS ALARM LEVEL
The set point for the ACAMS and MINICAMS agent alarms is specified in the monitoring
station tables (Attachment A). Due to the design characteristics of the ACAMS or
MINICAMS and the software that operates the alarm, there may be slight variations in the
actual alarm level for each ACAMS and MINICAMS.
PORTABLE ACAMS, MINICAMS and DAAMS MONITORING TRAILERS
There are a minimum of two Portable Monitoring Trailers housing ACAMS and/or
MINICAMS and DAAMS at TOCDF. They are for special short-term monitoring to support
short-term activities.
CARBON FILTERS ON ACAMS and MINICAMS
In special circumstances, an ACAMS or MINICAMS purpose is not to provide monitoring
on a continuous basis but for a specific need such as for monitoring charcoal change-out at
the Filter Farm. When these types of ACAMS or MINICAMS are operating but not
sampling the area for which they are intended, a charcoal filter may be installed at the
ACAMS oT MINICAMS.
22A.29
224.29.1
22A^.30
22A.30.1
224.31,
224.3 1.1
F'UGITTVE EMISSIONS MONITORINC
If a leak is discovered in any equipment in an agent processing area at the ATLIC, that leak
shall be monitored for agent using an ACAMS or MINICAMS. The method used for this
monitoring will be a modified Method 21 from 40 CFR, Part 60 using an ACAMS or
MINICAMS for agent.
Method Requirements ATLIC Facility Capabilities Mitigation/
Justification
A portable or area instrument will be used to
monitor leaks for Volatile Organic
Compounds (VOCs)
The area ACAMS or MINICAMS
will be used or a portable monitor
that is configured for the specific
VOC (agent).
N/A
The VOC instrument detector shall respond
to the compounds being processed, and both
the linear response range and measurable
range of the instrument shall encompass the
leak concentration.
The f,Q414S and MINICAMS
meet this criterion, their being
calibrated with the compound of
interest.
N/A
The scale of the instrument meter shall be
readable to +l- 2.5% of the specified leak
definition concentration when perfonning a
no detectable emission survey.
The ACAMS and MINICAMS
meter readout is digital, so the
concentration is displayed with
easy to read numbers.
N/A
The instrument shall be equipped with an
electrically driven pump to insure that a
sample is provided to the detector at a
The ACAMS and MINICAMS
comply with this requirement,
with a noffnal flow rate of 0.40 to
N/A
Attachm ent 22A - Page 25
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev I
constant flow rate. The rate will be 0.10 to
3.0 LPM, measured at the probe tip.
1.OLPM.
The instruments shall be intrinsically safe, os
defined by U.S.A. standards for use in any
explosive atmospheres that may be
encountered in its use.
TheACAMS andMINICAMS
sample line meets this
requirement since the ACAMS
and MINICAMS unit is not inside
the explosive environment.
N/A
The instrument shall be equipped with a
probe or probe extension for sampling not to
exceed t/o rnch outside diameter, with a single
opening for admission of a sample.
The ACAMS and MINICAMS
meets this requirement % rnch
outside diameter is the standard
for ACAMS sample lines and
probes.
N/A
The instrument response factors for the VOC
to be measured shall be less than 10. The
response factor is the ratio of the known
concentration of a VOC compound to the
observed meter reading when measured
using an instrument calibrated with the
specifi ed reference compound.
The ACAMS and MINICAMS
meet this criterioll.N/A
The instrument response time shall be equal
to or less than 30 seconds, with all sampling
equipment connected and operatirrg.
The ACAMS and MINICAMS do
not meet this criterion. But, this
is a special application and has
been approved
The ACAX{S and
MINICAMS are
the best avarlable
technology for
agent sampling.
Since the ACAMS
andMINICAMS
must collect a
sample before
analysis, the 5-15
minute response
time is as fast as
the analysis can be
iln, while still
maintaining
accurate results.
The calibration precision must be equal to or
less than 10 percent of the calibration gas
value.
The ACAMS and MINICAMS
meet this criterior, except that the
ACAMS and MINICAMS uses a
liquid calibration standard. By
TOCDF procedure the calibration
challenge must be +l- 10 % of the
target value.
N/A
NOTE
The challenge, calibration and operation of the ACAMS or MINICAMS will comply
Attachm ent 22A - Page 26
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
22A.32
221^.32.1
with Laboratory Operating Procedure (LOP) S2{inAttachment 3 (Sampling and
Analytical Procedures) and this Attachment.
ALARM RESPONSE REQI]IREMENTS
Exhaust Stack Alarm for GA or L
If the ACAMS alarms at or above 0.+ZSEL for GA or 0.42for L agent a RCRA Automatic
Waste Feed Cut-Off (AWFCO) shall be initiated for the f,maee#incinerators. Monitoring
personnel shall be deployed. DAAMS tubes that support GA ACAMS and/or L
MINICAMS shall be pulled andanalyzed on the stack.
Filter Stack Alarm for GA or L
If the ACAMS or MINICAMS, moriitoring the Filter stack, alarms at or above the agent
alarm set point then Monitoring personnel shall be deployed. DAAMS tubes that support GA
ACAMS and/or L MINICAMS shall be pulled arrd analyzed. ffi
If agent is confirmed, no additional agent may be brought into the ATLIC without Executive
Secretary approval.
Workplace Monitoring for GA and L (Category C and D Areas)
If the ACAMS or MIMCAMS indicates (in Control Center) that the agent level is+tlg a! or
above the action level of 0.2 VSL for GA and O.+ZVSL for L then the Control Center shall
notiff Monitoring @i4g shall respond and verify ACAMS or
MINICAMS operation and pull DAAMS tubes. If the ACAMS or MINICAMS is at or
above the alarm level (Appendix A), then the DAAMS tubes that support GA ACAMS
and/or L MINICAMS shall be pulled and analyzed.
224.32.2
22A.32.3
Attachm ent 22A - Page 27
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
APPENDIXA
ATLIC
AGENT MONITORING PLAII DETAIL
Attachrn ent 22A - Page 28
Attachm ent 22A ATLIC Agent Monitoring Plan November 2009
Rev I
AGENT MONITORING PLAII
Explanation of Column Titles
Station Number
The station number was assigned by Monitoring in accordance with the Monitoring Station
Numbering Sheet. This is the number used by the Facility Control System. The numbers are
specific to the geographic location being monitored. This number cannot be reassigned to any
other location due to the restraints caused by the 4O-year record-keeping requirement. When an S
suffixes a station number, it indicates that the sample line is movable to various sample points.
The S indicates spool. A K suffix to a station nurnber indicates that the station monitors for GA,
when a station is suffixed with an L, it indicates the station monitors for Lewisite.
ACAMSiLINICAMS/DAAMS Tag Number
This nurnber identifies the tag number for the ACAMS, MINICAMS or DAAMS specific to that
station number. If an ACAMS, MINICAMS or DAAMS is removed for repair and a new
ACAMS, MINICAMS or DAAMS is installed at that station, the tag nurnber will stay with the
new ACAMS, MINICAMS or DAAMS. This is to prevent the need to update the Monitoring
Plan each time maintenance is required. Temporary DAAMS are installed with an assigned
sample number instead of a tag number. Monitoring will track the ACAMS, MINICAMS or
DAAMS being repaired using the unit's serial number.
Unit Location
This designates the detector's physical location by room, floor plan number, and the drawing
number (from the attached Monitoring Plan drawings).
Area Monitored
This designates the geographic location being monitored by room and floor plan number.
Power Type
UPS - Battery backup used on ACAMS and MINICAMS. DAAMS using the same station
number will be connected to UPS.
. Essential Power - Commercial power backed up by an emergency generator. All heat trace will
use the essential power.
Secondary Power (Distribution) System (SPS) - The secondary power system refers to the
standard power supply. Items such as cabinet and pump ventilation fans are connected to the SPS
Sample Point Hazard Category
A through E, with "A" being a room where liquid agent is likely to be present to ,Err where no
agent will be found. See Terminology Section for complete definition.
Monitoring Level
lndicates the purpose of the ACAMS, MINICAMS or DAAMS stations and corresponding
monitoring level or sensitivity of the monitor. If VSL is listed, the purpose of the ACAMS or
MINICAMS is to monitor equipment/waste/personnel contamination levels. When ECL is listed,
the location is being monitored at a more sensitive level than required by CMA direction. In
other words, if ECLNSL is listed, the monitors are in the VSL mode but are more sensitive than
Attachment22A - Page29
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev 1
required by the Programmatic Monitoring Concept Plan for that monitoring location. The agent
concentrations for each monitoring level are specified in Attachment 22A, Appendix A.
Alarm Level
The alarm level at the ACAMS or MINICAMS station is the same as it is in the Control Center.
The alarm level shown is in terms of the monitoring level shown in the previous column. The
alarm levels are set below threshold levels to allow action to be taken to avoid exceeding
threshold levels. The alarm level starts a specific course of actions. The specific requirements
are identified in Section 22A.31(Alarm Response Requirements). An alarm located in toxic
areas, filter mid-beds, or other closed containers do not require the contingency procedures to be
implemented.
Sample Line Length
Lengths of the sample lines are listed with an accuracy of r20%.
DAAMS Mode
The mode is an indication of the purpose of the DAAMS. Examples are:
ACAMS Confirmation: The DAAMS is used to confirm an ACAMS reading in the event of an
agent alarm. Additionally the station with a monitoring level of VSLAVPL will have the DAAMS
tubes analyzed at the WPL at least monthly to provide evidence that there isn't an agent
concentration in the area below the detectible range of the ACAMS.
Historical: Historical monitoring is performed to measure very low concentrations of airbome
analytes, where contamination is unlikely or workers are operating without personal protective
equipment (PPE). Sampling is accomplished by the collection of an air sample over an extended
period of time (usually the duration of a workday) and subsequent analysis is conducted offline at
the laboratory. Historical monitoring is designed to trigger activities to investigate the source of
contamination that may be found below the alarm level of the Near Real Time (NRT) monitor.
Primary DAAMS: In this case the DAAMS is the only agent monitor.
Comments
Additional information as needed.
The table that follows provides monitoring details sorted by Station Number (Table 1).
Attachrnent22A - Page 30
eo0)oo
cdO.INN0)ocd
Fzt-
t
r-aaoU
-Jsu
O@
>O
U
t-
-
bo
x
'5
vFo
tr
o
o
.g
R
<E
-J
-9
u
oo
o
>OUr
-
bo
x
.E
VE<
t<

oo
!l
o
=f
-{
_}
_
*l9moo
o
>OUr
-
oo
X
5VF<
La

oo
Qo
=f
-<>
coE]Foz
ra
J
o
r)
OO
\
>OUr
-
bo
X
EM
tr
o
\
OO
+)

l'
\
-
<>
aJ
-9
U
OO
\
hOUr
-
bo
X
E<
Eo
,
OO
+)

l\
-
<E
a
7\
rr

l=
aa19
Aa
z
z
z
&EzoUazU
gz&t!
'
,zcUa-z(J
z
z
HE
g
H
O\n
\n
Otn
O\n
o(o
Ota
Ol'
r
)
E,
.
t
TE
N
or
l
tf
)O
c!
l
t,
O.{
f'
.
l
l
tt
)
i
z
z
ot
l
$O
or
l$i
(JzI'F
/
.

J
5t
s
tr
-
ti

rd
zj
o
Jrr
la
Jtt
1a
Jr!a
JHa
JIJ
.
]a
Jr!a
Jrr
.
la
H\HEA
!
!
z
z
z
z
z
z
z
ri
H
V)
A-
'
,
aO.
.D
aD
aF.
.
aR-
,
,D
aO-
,
,
aR.
r
+h
Rz
<x

l]
rd
Y

Fr
l=
&o3
s
ll
-vocdA
-l
3_
>
-E
c
Xrr
l
&OcdA-
,
ar
-H
&
X
IJ
.
]
.5
4
oeda-a*=>
\v

F/
xr!
-VOedAt
r2+
.
.
)z
-H
&
xI!
}4()dA-
.Q-=>
\t
Vxtr
l
()
cr
3a-3_
>
.E
F
4
xr!
}4()a-Q-=>
i:
c
xE]
r\

2:
$
h
:d
Z
t-
t

d
E
=g
E
tr
rn
bo
q
.E
o
l-

q)
-
I
_O
c
{
^
)
.-
F
t
-
!
-
F
6.
1

-
:e
I
=
:!
,
c
\
o.
U
IJ
.
]
(n
bo
q
.!
v
l-
O
I
-C
a
'
1
.;

)-

-r

-
E
5.
1

-
(-
r
a
V
-
>i
,
i
=
a
N-
o'
O
El
(n
bo
q
CA
alFVO
Oe
o
U-
.
;-

)<

F(

r-
r
c
=-
j
.
F
.
o
x\
J
-
aO-
,
,

Otr
l
\n
bo
q
.E
o
l^ts
vO
Ot
.
o
+J
.r
<
)
<
-
-
tr

X-
f

F{
O
X(
J
_
J
aNc'
'
.

OI!
[n
oo
q
C-
\
:v
tOO
Oc
o
U.-
F
F
F
(
g
ii
-
t
-
o
x(
J
-
>E

4,
t
ac'
,

()r!
\n
uo
q
-I-
.J
v
LO
I
_O
c
.
)
.;

F
-t

-r
I
X
or
'
r
-
:e
I
=
a
N*
o.
U
rr
.
l
oo
q
.E
o
LO
I
_O
c
r
^
)
.-

)-

t-

1-
(
I
H
Or
n
-
lr
a
V
-
ae-
.

U
E+
r
33
Z
z
Z
t-
-
oo
\o
oooo
\o
z
z
aE
X
I
co
.f
,
[n
-t$\n
rn.f
,
[n
z
Z
N.f
,
ca$
Fr

Tt
a
voo
f-zI!F
Vmoo
-E
-zI!F
vQooOf-ztr
.
lF
vcooOf-ztr
lF
VrI
]
oo
f-zr!F
Jof-zr!F
Jmo\
-E
-zrr
lF
ffz
Lo-oEIJze-o
!I{-
,o{-
,@-c
lEo+,
Loa\o
II
(t
rPooE'
)
?b
'=o.t
sF-o=Fo
I-c
loF
sC-
,
.bo
L.=z.oo0QJFN6loo6d
t-zrd
lraEoU
ca
J
gF
a
()
o
\
>O
U)

r-
uo
X
9<
tr
o
,
o<
>
<>
dt
Ll
r+oz,
e{
r
dr+oZ
caI!Foz
et
r*oZ,
2
rr
l
za
igAa
z
$Z
$z
$Z
z
z
z
'$

ef
i
,
*
O\n
ff
tn
ff
o\n
<D
t,
t
)
o\
o\
OO
or
l
r+i
no
z
q(D
z
-to
O$\a[r
)O
O.+\nnO
\n
ozIdF
l
OF
l-
a
ii
HZJ
oFre
Jt!a
rIri
l
ch
Jrr
la
d
Jrr
.
la
dUD
JUEIJa
JUI!Ja
Ja
fr
t

-
''
r

H.
EE
U
!
a
P
E
u
l-
(
a
Z
$Z
z
*
z
$Z
m
ri
e
aC.D
(h$
aAD
(h$
aAD
(hd.$
aD
aO-
.
a
E?
sF

d
Ht
r

d
o6
gEI
]
It
j4
()CdA-
,
a-=>=*
xE]
$*
.yocCA-
,
Q.
'=>
-H

od
XI!
$*
.\
z
ocdA-
.Q-=z
-E

F(
XtI
J
JT,$
*
**
'S
rf
-
e.
,
E
Ex
tr
.
l
{5EE
m.t
\
r
)
{
'-
'
r'
E
--
-
H
rq
7\

z:
f
E
l/

4
ri
3d

E
t.

dU
=3
*
fr
bo
q
cA
't
r
5
I
_O
c
o
.;
F
-
r
r
(
tr

=-
!
-
(
sp
Y
=
r/
f
N
-
r
Ag
)
I!
gs
t
*
$i
l
rn
bo
qE8
O
Oc
o
gd
.-

)<

-t

-<
tr

E-
l
.
-
,
se
Y
;
a
(\
-
AO
H
gs
f
i
*
$i
l
lf
i
bo
q
tr
A
Y
LOO
Oc
o
!)
.F
r
F
-
-
H
or
i
-
:P
I
E
ac.
.
(
)
r!
gs
$
*
$i
l
$
bo
.
4
tr
lH
\-
/
t-
V
(J
+J
V
V
.t
s

l-

F.

t-
{
Ch
t
-
(J

ra
,:

oY
<
,
zd
,
<
3
5
$-
FO
E]
.f
,
bo
.
@
-lL.
.;

\J
t-
;^
v\.
,
,

-
^
{-
)
v
v
.F

l-

F.

Fr
t-
.
5
RC
:
>;
d
a
X
N-
L,
/

I
FO
rr
.
l
.f
,
bo
.
4
I
E
\J
L;^
v
(.
/
{-
l
Y
Y
.F
a

l-

-r

F{
Lr
Hr
-
A
(J

TF
l
Y
Vg
>
il
,
4
,
-
x
N-
\J
IFU
IJ
.
]
E+
h
33
Z
$Z
o\
oo
\o
$Z
Oo\
\o
$z
Z
z
z
;E
X
I
\f
,
\f
,
t,
f
)$
z
$
z
H.s
f-C\
\n
O.
C.
l
rnC.
l
(n
tr

:t
h
a
JUo\
f-zrqF
d<Dr*
Jno\O
--
-
E
-
zrI
]F
dR
JIJ
.
]
o\
f-
-
Zrr
lF
dChor*
Ye!
f-zrJ
]
t.
l
JFf-zr!F
v{e{Nf-zrr
lF
tr
tr
*s
c{
caouo
cd
0.
,
.
INNOoc0
O\

F{
\-
,

,t
'
l
ri
l
c)€l.
ioozcd
o<boLooOJboUJFNe{oFoCd
caca()bo
CdAINNotrOCO
F(zrq
tlzlr
lzoU
(n

\o
Ir
.
l

f!
FFooZZ
$$ooZZ
l.
r
}

\o
lr
.
l

fr
.
l
FFoozz
.t
tr
.
IFoZ
\f
,
r!Foz
i3
r
d
zo3s
z
*
az>g
{g
z
z
z
z
E=
E
H
OO
OO
I+
OO
Ot
O.+
ooo\
ooo\
Oo\
=j*
E
or
r3
no
-qO
-t6
v'
lO
v?O
=q
{\nrn
O$tnnO
O{\r
)
\n
Iztc4
F
l
OF
L/
a
ti

kl
Z
r-
l
o>
Ja
Jo<Ja
rIs
JR-
tsJa
Ja
Ja
JcJUHJa
Fr
rJoJUIJ
]Ja
rc
l
JI3rUrr
lJa
r-
l
-
\-EF
H
i
m
U
Lt
)
U
z
z
mt
rE
a
ac-
,
,
ao<
ch$
aa<D
aO-
,
.D
aO.
ac.
.
.
aO.D
c/
)
P.
,
,D
B?
<x

J
rr
j
Y

nr
Ht
r

d
o6
g
tl
caJY
?F;
rr
l
moo
E
'D

-,
,
st
,
ot-
.
Fr
$*
odmoo
B
'6

-.
.
ga
ot<
o.
'
.
a(.
)x.
f
,
oo
(D

-,
>>
O^
)
(,
oC)x$oo
O
t-
r
>2
O^
)
U
\o
X=
()

-,
,
FE
il
\o
X=C-
,
FA
&
o\
o3
d
r\

z:
$
h
:d
3
H
d,
zg
a
H
t-
{
FE
(
-f
,
bo
.
O
e1

I
!.
.F

v
t-ii
v
(J
{-
)
v
v
.F

I<

F.

!-
f
tr
h
!
-
A
(J
T
i
zE
,
t
=
x
N-
\J
rFO
rr
.
l
co
bo
|
@
F1

t
HA
./

\J
Lia
vu
o\
f
,
.-

l<

-
!-
i
tr
t
i
t
<
S
E9
=
,
z/
,
<
3
o
6r
H
o
c.
l
Eo

.lvIJ
.
]
$s
i
l
*
s*
ca
uo
.
4
I
HA
.H

\J
l-I
-5
.
t
.F
.

l<

-
t-
r
Ct
r
S
Eq
=
.
z/
,
<
3
O
6t
H
oNsd
r!
caa
cd
Om8
o
OI
)

-,

O
cl
F
<
AV
r
rqs
i
Eo
t
a-
o
IJ
.
]
COa
c3
O
nn
o
-o
<
f
bf
)

-
.i
Et
-
a\
r
/
/s<
i
Y
e.
t
c'
u
r!
-f
,
Pq
ts
i
.H

\-
/
L;^
v
l.
,
'
+)
a
v
v
.F

)<

F.

Ff
il
i
t
-
(,

ri
v^
V
-
>i
l
,
t
1
x
N-
\J
IF(
,
rI
]
-f
,
bo
.
O
I
ts
r
.-

v
t-xv
(J
{-
)
v
v
.-

l<

F{

!<
Ct
:
r
r
A(
J
r
a
:
oY
=
,
z&
<
3
5
$-
FO
r!
-t
bo
.
4
t<

I
|'
r
.l

v
!o
L,
,
i)
v
v
.
ri

I<

!-
{

t<
C!
r
-
A
(J
r
h
va
V
s5
$-
F(
,
r!
E{
r
3:

3
z
O@\o
O.
f-\o
z
z
z
z
z
aE
a
=
ooC\
CA
$
o\Nrn
ca
rn
Nco
caco
\.
)
-f
,
cO
f-ea
\n
F
:t
E
a
JC!
e{F-zIL
IF
aJt.
tNf-zrl
.
]F
(hd!A
)c[
r{
.
av\nc{
f-ztr
.
lF
av\oNf-zII
]F
aJ\oNf-zrr
lF
Vf-Nf-zrr
lF
Jf-Nf-zI!F
vooc!
f-ztqF
$
O.

F{
ffzsO-
.
.uo
.EooC)oo
()JFC\C\oocd
$ea0)bo
cdAIoi
C.
l
()tr()d
FrzHr=a=a0[J
tr+*
el
r
Lf
i+*
\nrI
]Foz
E
rr
l
ea3B
z
ilEzoUaU
UI
xlzl
>
l
=l

sl
$I
|
*<
r
il
$Z
&EzoUaU
JUiloFaF
fr
l

E
$'
,
.
E

*,

H.
<
rr
{

tE
l

't
l
l.
r
'
r
F
I
Oo\
O
$
Oo
Oeo
s
co
OcO
O$\nn
no
n.o
\nO
=qO
so
v?O
z
()zIdF
l
OF
Lt

,)
ii

r{
Zl
]
o\-aI'
.
i

"
ts
l
*(
lJIol
-l
:lJUr!)a
JF.
.BJa
d*
J0.Ja
J0.
,
.
tsJa
d*
J0.BJa
JF.
.
lr
l
:
-
\BEE
U
T
?R
E
U
m
U
(,
U
o
a
o
o
rg
a
aD
aD
Ch$
aP-
.
aD
(h$
a-
aAD
B3
tF

d
g
tr

d
"6
9
Ir
r
o\
c-
l

3
5;
d
5=ge
tl
Xo
o
S?
O
fr
z
o-
bo
L\J+)
v
.F

)H

-(
H.^
F
(
vL<

(i

<{
zd
3
x
r+
{
oF
tt
oG't$,
1
bo
l-o+-
,

v
.F

ld

Fl
H;^
.
-
H(
J
=
r
z&
3
oF
sb
6?

F
-\J
F
{
Fa

U-
,
.
EE
<
E
'F
E

x
tr
o
tr
.
l

U
r\

z:
$
h
tr

&
B
3
3r
\f
,
bo
.
4
-lE
.F

v
t-
v
iJ

-o
o
.F

l-

Fr

F{
l;
.
L:
t
t^
(J
r
h
J
OY
=
r
z&
<
3
X
ot
-
oq
FO
I!
tf
,
oo
r
4
I
H
.H

\J
t-
:^
v
(J
iJ
a
v
v
.F
.

L<

F.

Fl
E!
1
t
-
A
(,

rF
1
.:

OY
.
<
t
z&
<
f
;
x
N-
\J
IF(
,
rI
.
]
.f
,
uo
.
4
I
.H

\/
t-AV
tJ

-!
.

.^
,
!r
-
.
v
v
.-
)
-
F
(
-
l-
H:
.
-
(J

TF
1
vt
-
V
->i
l
4
,
4
x
N-
\-
/

I
FU
fr
l
$
bo
.
4
dlH
.-

\J
!o
IJ
.{
r
l
)
v
v
.F
l
i
F
.
-
tr
L:
!
-se
?
=
xoq
FO
rI
]
.f
,
bo
.
4
Fl
I
!
.;r

!J
L^v(,
{.
J
Y
V
.F
a

I<

Fa

t-
E
6.
1

-
vr
a
r
V
-
>
il
,
4
,
-
5
$-
FU
rr
.
l
rn
bo
qE8
I
_O
c
r
)
.;
F
-
.
-
.
E
6.
1

-
:E
T
;
ac"
g
)
r!
P
:r
h
33
z
c\
l
oo
\o
$Z
oo
\o
$oo
\o
caoo
\o
(noo
\o
EE
=

t
f-ca
(nca
$
\nca
\n
ooca
ch
c'
t
)+
o\
co
\n
z
Fi

+t
a
J@Nf-zHF
Jo\Nf-zHF
dchcT$tr
vo\Nf-zfr
,
lF
-lcA
-E
-
Zr!F
dt
vcO
f-ZHF
YcaC-zrJ
]F
O\

t-
{
FP
,
o,otroozcdo.c0Lo6)boUJFNNO()
cO
(ncaooo
03Ortc!NOocd
Frzr{=a=aoU
(n
rr
.
lFoz
f-

[/
^
t
fr
l

[r
.
l
FFoozz
t\

\n
r!

EJ
FFoozz
$r
$
*
*
$r
$
*
*
\nr!Foz
2r
d
3A
Aa
JU&oFarr
r
JU&oFaF
JU&cFaJ-
.
-p$o+Lh
rJ
.*
*$o+hrJ
r
il
JU&cFaF
gs
,
a

H
Oca
O.+
Otf
,
<D+
o+
oo
r=
\
a,

ri
4
E
*
JH
z
z
z
*
*
z
(JZdiOF
Ll
a
il
Hz;
or-a
Jp.
J0.
ts
JCr
rI*
JI*
JO-
,
iB
rd
!EE
A
T
?
?8
E
U
a
o
o
o
a
o
o
ri
H
aA.
o,D
a
(t
t
a
l-
(

*1
o-
r
a<
o7a
cd

.r
L-
-
.
.
r
o,
J
c.
,
,
(hcL*
(h*
ac.
'
.
B?
JF

d
C=
&
"5

gI'
I
r
:F*S
DUr

F(
-'
r

J
Ft
EA

U
'-
,
,
H=
d
>
.t
r

Ij

lY
tr
o
r!
.
u
Cdot-
.
L<EtdJtr
.
,
,aA.
(0OL<h
'o
dJILa
$
$$
bt<

i-
l

0,
)
o
6
h=
f
\
?1

tr

L)
\-
.
/

tr

?
_,
-
(^
)
.

(J
a
.5

r-
r

ts
J
tr

)
9,
d
E'
S
f
i
(
U
uU
x
3i
z
i.
.

d
B
=g
A
tr
|'
n
oo
q
Lr
't
r
-
O
Oe
n
.l
-
)
.-

F
-
F(
E
5.
1

-
(J
A
V
-
>E
,
i
-
a
c{

r+
{
p.
(
'
rr
.
l
cAa
.9
o
c
d
X
OO
E5
=
\
7h
:
.
-
v
\J

o,
l
-
c
bO
Y

=,
,
EE
X
A
C,
n
n
()
rr
l
COa
Ja
c
d
1,
,

ll
t
)

,^
85
E
x
/h
i
l
v\.
/

o)

,A

-
c
bO
Y

=i
€E
x
a
C,
n
n
(,r!
9.
n
)a
!A
lHf
=
=
Or
r
.
l
T
=
rh
.U
L
t
o
tr
Y
\
<
E
HS
A
-q

Q.

c{
u'
i
d
rr
:

t!
(n

+.
l-

-t
*
33
\ooo
\o
c{
ea
f-
caca
t-
-
$
$
t-
-
\o\o
lE
A
I
z
z
Z
n-Z.
Z
Fr

:t
h
a
Jco
f-zr!F
MNcA
f-zI!F
J<tNeo
-E
-zI!F
xcf
i*
$
M-f
,
c.
)
t-
-ZrI
jF
*,+
fr
,
r+
ffozqC-
,
.bo
't
r
o.=OooUJFNc!o()d
t'
rzH=aHeoQ
\n
rr
.
1Fo'z
\nrr
lFo7
(nrI
]Foz
F{

\n
rI

E]
FFoozz
ts++oo
ZZ
,
-.

\n
f!

fr
.
l
FFoozz
-<

(O
El

fr
.
l
FFoozz
-r

fO
fr
.
l

f!
FFoozz
-<

tf
)
EI

fr
l
FFoozz
2F
I
zo33
JU&oFa>.
l
r
JU&oFat
J-
.
JUcoFaF
fi
'
E
I
4<
r
il
-Z
<,
t
8
/,

t-
t
{E
JU&cFa>J
<
JUc,oFO>J
<
JU&oFaFf
<
E=
,
E
t
Ooo
\nca
rnca
OO
E-+
oO
OO
aO
oO
z
z
z
-qO
qo
.QO
z
z
z
()zti.
l

J
5B
u-
ii

nE
l
ZA
oEra
JA.
JAB
JR-
,
.
ts
Ja
J]h*
Ja
Jo.
JO.
ts
JFr
ts
B-HH
B
s
o
o
o
z
*
z
z
z
z
ri
H
ac-
,
,-
a
ac<
aD
(h$
aF.D
a4.
'
.D
aO-
,D
aF.
.
.D
n2
*F

d
tr
t
r

d
"5

gFr
i
gt
s
o
,
6
6
!=
U
E
-"
=
6.

(.
,
)
'r
a

.5

-
F(
EF
E
A
U
l-&H

e
A
\I
'
H.
)
Ft
H
A6A
o
>'
5

9
E,
S
,
n
rr
]
tsE.
E

E
L'
<

J
-t
H
A
F;
A
9r
Q
>'
5

!i
E,
S
f
i
rI
J
F(
Or-

A0
O!
='
o
tJ
-

\<
-<
$$
OE
F'
(

O
r-
,

O
Ot=
'(
,
rr
.
{

>
-.

(\
'
l
OE
t-
O
pO0)
t
=E
l!
>
-.

Gl
o.
o
F.

0J
p0
Ol='
o
tL
>
1<
o
r-
(

*
gE
ii
>
r\

z
+t
V
-4

rl
r
A\
\
Vxd
7
F
&
B
?
3
fr
Yi
a
tr
9.
n
3A
LA
Io
oo
9-
^
at

v
-
v
A
,\
-
!
J
-
{
vL
-
(J
u
.
t
T
q
r
-
[t
]
o
tr
Y
S
E
HS
E
-?

p"
N
U.
E
.
I
i-
r

V
rI

rr
r
co
bo
.
4
.t
Lr
.-

lJ
t-i^
\
/
jJ

-o
\
f
,
'F
(

Li

F{

Fr
Ct
s
!
r
r-

(,

rF
'
'
l
:
or
/
=
,
2r
'
,
4
3
a
NH
ec
\
l
-r
OO

rAvtl
.
l
co
bo
|
4
stLr
.-

!.
/
l-;\
v
\J

A
-.
7
5)
:

Y\
l
.F

l-

F.

Fa
tr
H
t
-
S
Eq
=
.
zc
4
i
o
c\

t+
(
oc
!
r-
t
bO

r'
rvIJ
.
]
\c
co
.
@
I
L.
.F
.

\J
L.
v
E
Ot
n
'=

E-
-
E
sq
=
ii

(-
.
1

-
j3
N
=.
r
IJ
.

(J
rI
.
]
$s
i
l
*
tr
*
\o
bo
.
4
(<
l
ts
A
.F
.

\J
t-i\
v.I
j

Ot
)
.;
E
-
-
.
H=
t
r
S
Eg
=
.
2,
r
'
.
<
f
r
E
N-
Ed
El
\o
bo
.
4
(<
l
H
.r
r

\J
L<
\/
.l
J

-C
t
r
l
.F

L
!-
a

F.
tr
F
r
-
S
Eq
=
.
2r
'
,
<
f
r
E
N-
=ltL
(
J
r!
\o
bo
.
@
(1

!
HA
.
t<

\.
,
L
v
Y
O\
N
.-
E
-
-
.
tr
L
t
1
3
s
Eq
\
<
<
ae
<
3
ii

6r
+5
NEd
I!
\o
oo
.
4
(1

I
x
.F
T

\J
L
\/
jJ

O(
n
.n

F-
'
*
s,

?=
h'

e!
.5

c{
Ed
I!
P+
h
33
@\o\o
[.
-
\o
c!
f-\o
c!o\
\o
$Z
o\
\o
(n
f-
\o
f-
\nOf-
aE
.
A

I
z
Z
z
oo
\f
,
$
O.
.+Ln
z
z
z
Fr

:S
t
V)
J.f
,
ca
f-zrr
.
lF
M\oca
f-zrI
.
]F
J\oCA
f-zIr
lF
alJ+f-zrr
lF
$
alV+f-zE]F
vc\
.t
f-zI!F
JN$F-zrr
.
lF
vca$f-zlr
lF
fi
\ocaC)bo
cOO.I
6l
/
ot
loF()cd
O\

t-
{
T&
,
oE0)ozcd
o<bo
3<oozG)boUJFC.
l
C.
lo()cd
f-caobo
cdAINNo()c0
FzfE
l
!ral=aoU
r-
<

l.
f
)
El

r!
FFoozz
t-
r

\n
tJ
.
]

!I
]
f-
Fbc
ZZ
$$oo
Z,

Z,
-<

\f
)
fr
l

Ir
.
l
FFoozz
-.

\n
tr
.
l

t!
FFoozz
td

\n
rr
.
l

rr
.
l
FFoozz
Fr

\.
)
Ir
l

tr
l
FFoozz
r-
<

(f
)
E]

E]
FFoc
zz
-r

tf
^
)
Ir
t

r!
FFooZZ
EH
ao33
JUil
,oFa:J
-
{
--
LZ
a&IJ
.
,zoUazU
JUcoFarJ
r
JU&oFaF
JUoFaFJ
-
(
JU&cFaJ-
{
t=
l
=
l
EE
g
H
OO
OO
<Do+
OO
OO
OO
O
OO
OO
E(

't
aF
{TE
N
z
nO
qo
\ni
z
z
z
z
=tO
()zIdi
l
At
=
v\f-
a
i.
i

EI
zr
o\aa
JO-
.
.B
Ja
JI
Lh*
Ja
JOr
JOr
ts
JR.
r
Ja.
.
.
ts
Ja
rd
\BEH
i
i
Z
z
z
z
z
Z
z
z
ri
H
(r
)
c.
.
.D
aF.
UDCLs
ac-
,3
a-
aO-
.
.-
a)
aD
aO.
.
r
EE
<x

J
ra
Y

F.
tr
t
r

d
oe
g
Lr
r
-.

6)
v:
JC)
H
=[
i
ii
>
NF
To-
o
F(
O
l<
ps+
$$
N"
r
O6
F(

0)
p!s+
ii
>
61
1

N
o.
6
Fr
Or€s+
ii
>
Nc
!
o.
o
F(
O
!-
Os+
NO
Y=
F-
oOH
=
"d
i
N0
)
--
o0)
-
={
i
Li
>
Og
r-
(

O
r-
,

.o
s+
ii
>
r\

z
+t
V
I
ri
3i
z
F
d*
ZE
E
f*
\o
bo
.
4
t4

I
HA
.r
<

\J
t-;^
\
/
TJ

Ot
n
.;
-
E
-
,
-
I-
=
br
i
-
;
or
/
=
,
.
EN
-rt!
U
I!
\o
i'
3
u
Ot
n
''
a

tr

F{

Fr
=E

s,
r
:
?a
(
<
a
{:
NEd
H
$s
i
l
r
ff
*
\o
H3
L
v
iJ

ot
n
,=

E
-.

-,
,
HX
I
-
s
tg
=
.
,
z/
,
<
f
;
g
N-
=t
lJ
-

(J
tr
.
l
\o
oo
.
4
t4

I
F
.
F.

\.,
/
t-;\

\.
/
.Y

O(
N
.-
E
-
t
-
r
tr
h
r
-
s;
9

>
x-
l
&
.5

c!
Ed
rI
]
\o
bo
.
4
r1

t
HA
.F
.

\J
LAV
.l
J

O
(n
'-
C
F
r
F
t
=
5.
l
F
(
FE
I
S
EN
;-

|
I!
(
J
t!
\o
bo
.
4
t-
!
F
.t
s

\J
t-
\/
}3

OT
N
.;
<

tr

-.

H
!
8o
:
a
.(
<
f
r
E
s-
-lt:
-

t7EJ
\o
bo
.
d
(1

I
H
.F

\J
t<
v
.Y

O(
n
.r
r

tr

-
Fi
I<
l
r
!
-
^
(,

rF
r
;
oY
<
,
2,
r
'
,
<
f
r
g
N-
-ltr
-

(Jt!
\o
bo
.
4
(-
l-
.
t<

\.
/
t-
\/
-l
J

O
tn
.;

F-
-
H:
t
-
^
(,

rF
l
:
or
/
=
,
z,
c
.
<
f
r
E
N-
-lE(
f
r!
a*
.
It

.l
+
.
l3
\o
f-
$o\
\o
Y.z
co6\o
I*
-
t'
-
oo
f-
[-
-
f-
oo
f-
.f
,
f-
;E
x
I
z
oo
t
ch*
o\$l.
n
Z
Z
Z
z
oo-t
F.

:S
t
a
Jc.
)
$f-Ztl
lF
al
J$$t*
-zE1F
rId$
alV$$f-zrr
lF
v\n.f
,
f-zrr
.
lF
J\n.f
,
f-ztr
.
lF
v\o-t
f-zti
lF
J\o$f-zrr
lF
al
-]
f--f
,
f-ztL
IF
*,
r.
d
l+
O.

F{
ffzsO.bo
tr
.=ozoboUJFNNo()63
Fzrd=le!{aop
$$
_{

(n
fr
.
l

tr
.
l
FF
,
.
oozz
_{

tn
IJ
.
]

tI
.
]
FFoozz
F.

(n
Ir
.
l

f!
FFoozz
-t

tf
i
fr
l

fr
l
FFoozz
r<

1.
f
)
t!

tr
l
FFoozz
5v
>,
O
qFEz
cd

TL
I
+r
7
l
a
l-
'
3Hea33
$Z
&Ezo(JaU
JU&OFaF
JU&oFat
J-
r
JU&cFaF
JUdoFaJ-
r
dtrzoUaU
r'
.EzoUaU
==
=
t
o<D+
OO
oO
OO
OO
o
Oo
aO
OO
EJ
IE
"
so
v?O
z
z
z
z
\.
)O
no
\nO
()zdi
l
Er
l
\J

L'
ua
ii
Hzr
oE
d*
Ja
JAB
JC.>
JAB
Ja<>
Ja
Ja
Ja
rd
E
dz

!
r
?R
E
U
*
z
z
z
z
z
z
z
z
rE
a
(h$
ac.
.
F:
\
ao.D
ao.
,
,D
ac.
.D
ac.
aO-
ao.D
ao.
.
A*Fi
#F

d
gt
r

d
"5

gIr
r
$$
ce
-
or
c
Fr
Or-
0
Or
='
o
fr
.

>
co
N
o.
o
F{
Or<
O
Ot
.=
E
tL
,

>
d)

c\
o.
o
Fr
OL<
m
Ot
=E
co
O
Fr
Xga
r<

(.
)
ii
>
C.
)
O
\J
A
--
o
.g
E
ii
>
-\
z()
c'
3atrC)
tJ
.
}4()daLo
fJ
.
)4ocB0LrC)
tJ
.
z\

I
+r
g
t,
E
zE

7
$,
t
r
tr
i
l
\o
bo
r
/
l
!
l.
a
A
.
F.

\-
/
t-jr
\

\/
.Y

Ot
n
'i
<
E
-
r
-
r
tr
h
r
r
se
?
=
.u

N-
Ed
H
\o
E'
3
13

Ot
n
.-
E
-
.
-
r
5
s.
?
:
2r
'
,
<
f
r
E
N-
Ed
rI
.
]
\c
i'
3
-!
J

Ot
.-
E
-
.
-
r
E
5.
1

-
E
oY
=
ae
<
f
r
E
N-
Ed
I!
\o
E,
3
.1
3

O
ln
.;
C
-
.
-
r
=
5.
,
r
-
;
oY
=
,
zd
,
<
f
r
E
N-
Ed
H
\o
bo
.
4
-!
.F
T

\J
l-
v
Y
Ot
n
.-
E
r
-
-
,
tr
!
r
-
L
(J

rF
t
=&
I
;
ii

N-
.5

6l
Ed
r!
\c
bo
.
O
I
HA
.F

lJ
t-
v
.Y

O(
r
l
.F
.

E
-r

-r
(r

Li
g
8c
:
2,
r
'
,
<
f
r
E
NH
Ed
rr
.
l
\o
H3
-l
J

O
rn
';
E
-
r
F
{
FL
-:t
-s
t9
=
zd
,
<
f
r
E
N-
Ed
r!
\o
i'
3
u
or
n
'l

tr

r-
{

F4
sE
t
=
g
N-
Ed
IJ
]
E+
r
33
ca
f-
o\
f-
6t
f-
f-
Nf-
(no\
\o
f-o\
\o
\oo\
\o
aE
X
g
ch$
o\
.t
\n
z
z
z
Z
ca
[a(n
-f
,
r
$rr
)
ta
)
F<

+t
a
J]$
alMf-\t
-E
-zrr
.
lF
Voo
.f
,
f-zrqF
Joo
.f
,
f-zrr
.
lF
vo\
.+f-zrr
lF
JO,
\f
,
f-zt!F
VO\nf-zE]F
Jrf-zIJ
.
]F
vmO\nt-ztl
lF
*,
r+
ooca0)oo
cdAINc\C)ocd
aF
lT&
6Eoozc0o.o0
l-oozC)boUJFNNoocO
Frzrdr-aEoU
Nrr
.
lFoz
ff
i
[$
*
2
r.
l
zo19Oa
$Z
$Z
==
l
'
;
oO
I+
I+
|Q
r
\
aF
{
nO
so
so
(,z:'^
/

J
FI

;i
oE
3
g-
a
ii

rd
z;
oa
Ja
J]d*
**
H-EE
T
i
i
i
=
-
a
z
*
ri
a
aD
C,
hdl
ch$
E?
#F

d
gt
r

d
ot
g
II
J()cdat{o
tJ
-
.
.
t+P
(h$4
Js#$r+
r\

2
+r
:d
3
t-
t

dt
vg
E
fr
\o
bo
.
4
(1

I
-
.F
v
t<
v
Y
Ot
.
n
'F
C
-
(
-
gH
l
-
S
Eq
=
.
z,
e
l
<
f
r
E
N-
Ed
tr
.
l
$s
i
l
*
n$
3+
h
33
ooo\
\o
*
*z
lE
a
:
\n\n
\o
t,
r
/
'
h+
$t,
r
t
)+
Fr

:t
h
o
JmO\n
f-
-
zrr
.
lF
r!U)*r.
t
ddtt
t*
*,+
$
o\
coobo
COFrI6l
c\oOcd
sO-ooL.=oOb0UJFC{No()
cO ffoz
Attachment22A ATLIC Agent Monitoring Plan November 2009
Rev I
: , AGENT MONITORING PLAN NOTES
1. See Paragraph22A.S for filter monitoring protocol.
2. ine
3. Used as a backup to the primary TEN (708,709) DAAMS when tubes are being pulled or
maintenance is being performed on primary DAAMS.
4. These ACAMSA{INICAMS andDA"qA'{$can be switched to monitor three different locations.
O
5. WPL samples must be collected andanalyzed on a daily basis at this station.
6. The ACAMS, MINICAMS and DAAMS may be switched to monitor Vestibule 101.
7. Facility UPS not available will install individual UPS for each station.
Hazard Level:
STEL Short Term Exposure Limit
SEL Source Emission Limit.
WPL Worker Population Limit
ECL Engineering Control Level
IDLH Immediately Dangerous to Lite and Health
VSL Vapor Screening Limit
Attachm ent 22A - Page 40