UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGIONS

1595 Wynkoop Street

DENVER, CO 80202-1129
Phone 800-227-8917
http:/twww.epa.gov/region08

JUN 022008
Ref: ENF-AT
Colonel Frederick D. Pellissier, Commander
Deseret Chemical Depot
11500 Stark Road
Stockton, Utah 84071-0250
Re: Response to Alternative Monitoring Request
(AMR) to Waive Metal, Ash and Chlorine Feed
Rate Operating Parameter Limits for the
Deactivation Furnace System (DFS) at the Tooele
Chemical Agent Disposal Facility (TOCDF)
Dear Colonel PeIlissier:
This letter responds to your April 21> 2008 letter requesting approval from the Utah
Department of Environmental Quality to waive the requirement to establish, and subsequently
monitor, a 12-hour rolling average (HRA)feed rate for mercury, ash, semi- and low-volatile
metals, and chlorine required by 40 CFR 63.1209(1), (m), (n), and (0), respectively, at the
Deactivation Furnace System (DFS). As an alternative, Tooele Chemical Agent Disposal
Facility (TOCDF) requests to establish, morutor, and comply with a I-hour waste feed rate. This
feed rate will be limited by an automatic waste feed cut-off (A\VFCO). Justification for the
request is as follows:
-The AMR is for destruction of the energetic components (bursters and fuzes) from 4.2
inch (") HD mortars, HT mortars, and the minimal amounts of process generated waste
such as agent contaminated rags and small metal parts that are fed throughout DFS
operations. The TOCDF RCRA Permit limits the number of combined 4.2" mortar
fuzelburster pairs that can be fed to the DFS to 2741hour, as well as the amount of
process generated waste that can be fed to the DFS. All the mortar fuzes and bursters are
homogeneous in regard to Propellant Explosive and Pyrotechnic (PEP) composition and
PEP weight Calculating and complying with individual 12-HRA feed rates for mercury,
ash, semi- and low-volatile metals, and chlorine is redundant because the calculation and
compliance would be back-calculated based on the feed rate of the fuze and burster pairs .
The TOCDF incinerator process control is Programmable Logic Controller (PLe)
based. This control equipment has limited capabilities with regard to numerical
calculations. Establishing individual feed rates for mercury, ash, semi- and low-volatile
metals, and chlorine requires the PLC to conduct extensive calculations; something it was
not designed to do. Establishing a I-hour waste feed rate, rather than individual feed

rates for mercury, ash, semi- and low-volatile metals, and chlorine, is more manageable

for the PLC.

During the processing of the 4.2" Mortar campaigns, the DFS will only process the
bursters and fuzes removed from the mortars. Each burster is comprised of0.141bs of
tetryl encased in a steel tube which weighs 0,4 Ibs. Each fuze contains an additional
0.00041bs oftetryl and 0.00041bs oflead azide, which is 71% lead by weight (or 0.0003
Ibs oflead). The fuzes are made of brass or aluminum and weigh a total of 1,4 lbs. The
brass and steel portions of the bursters and fuzes do not melt in the furnace but rather
leave the back end of the DFS in tact. The only thing destroyed in the DFS is the
explosive components. TOCDF indicates that the feed rate is limited by an AWFCO.
Our understanding is that if the DFS exceeds the feed rate limit, the waste feed is
automatically cut off since a feed gate counts the burster/fuze pairs per hour. The
information from the counter is transmitted to the data acquisition system (DAS).
TOCDF is required to maintain records of waste processed .
The 4.2" HD and HT bursters and fuzes contain minimal amounts (amounts equal to the
analytical method detection limit) of low-volatile metals (LVM), mercury, and chlorine.
The feed rate of semi 7volatile metals (SVM), at 274 burster/fuzes pair, is expected to be
0.1 Iblhr. The ash feed rate of274 burster/fuze pairs per hour is expected to be 11.9 Ib/hr.
A DFS performance test was conducted in July 2003 during the DFS VX Agent Trial

Burn (ATB). The wastes fed during that trial burn consisted ofM55 VX rockets and their
fiberglass shipping and firing tUbes. The M55 VX rockets and their fiberglass shipping
and firing tubes incinerated in the July 2003 DFS VX ATB contained more than 10 times
the anl0unt of PEP and ash (lbslhr), 50 times the amount ofSVM (lbs/hr), and 2,000
times the LVM (lblhr) than the expected 4.2" HD, and HT burster/fuze pairs that will be
fed to the DFS. In both the July 2003 ATB and the impending 4.2" HD and HT
burster/fuze pairs incineration, the mercury' and chlorine levels were (are) minimal (based
on the analytical method detection limit). During the July 2003 DFS VX ATB the ash,
SVM, LVM, mercury and chlorine emission limits in 40 CFR 63.1219 were met. (Note
that the explosive portion of the M55 VX rockets is different than the 4.2" HTIHD
mortars. The rockets contained 60% RDX, 39.5 % TNT, 0.5% calcium silicate. Each
rocket also contained 19.2 pounds of propellant comprised of two percent by weight lead
stearate. The 4.2" mortars contain tetryL)
.TOCDF expects to begin feeding 4.2" burster/fuze pairs to the DFS in early December
2008. The processing of the 4.2" HD and HT mortar burster/fuze pairs in the DFS is
expected to be completed by April 2010. Once these mortar booser/fuze pairs are
destroyed. the DFS will be shutdown and dismantled.

eA DFS Comprehensive Performance Test (CPT) is scheduled to be conducted in the

first quarter 2009. The CPT will use 4.2" HT Mortar fuzes and bursters as waste feed.

EPA approves TOCDF's request to waive the requirement to establish, and subsequently
monitor a 12-HRA feed rate for mercury, ash, semi- and low-volatile metals, and chlorine
required by 40 CFR 63.1209(1), (m), (n), and (0), respectively, at the DFS. EPA's approval is
limited to when burster and fuze pairs from 4.2" HD mortars, HT mortars, and minimal amounts
of process generated waste such as agent contaminated rags and small metal parts are fed to the
DFS. Additionally, EPA's approval is based on a waste feed rate to the DFS of combined 4.2"
mortar burster/fuze pairs of 2741hour, as well as the RCRA Pennit limits for process generated
waste, and TOCDF's commitment to monitor and comply with those limits.
Please note that the approval made above is subject to further review if there is reason to
believe that an alternative monitoring requirement fails to provide an equivalent or better
assurance of compliance with the relevant emission standard in 40 CFR Part 63 Subpan EEE. If
you have any questions or concerns, please feel free to contact Laurie Ostrand of my staff at
(303) 312-6437.
Sincerely,
/-)~' Jt...
(...A;r1'ttt,.--.
.

!.

Director
Technical Enforcement Prograrri

cc:

Joe Randolph
Utah Division of Air Quality
P.O. Box 144820

Salt Lake City, Utah 84114-4820

DebNg
Division of Solid and Hazardous Waste
P.O. Box 144880

Salt Lake City, UT 84114-4880

Carol Smith

EPA Region 8

Mail Code 8ENF-AT

159:5 Wynkoop St.

Denver, CO 80202-1129

Mike Owens

EPA Region 8

Mail Code 8P-AR

1595 Wynkoop St.

Denver, CO 80202-1129