UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 8
1595 Wynkoop Street
DENVER, CO 80202-1129
Phone 800-227-8917
http://www.epa.gov/region08

Ref: 8ENF-AT

Colonel Frederick D. Pellissier, Commander

Deseret Chemical Depot
ATTN: AMSCM-OPDC-RM
11500 Stark Road
Stockton, Utah 84071-0250
Re: Response to Request to Modify the Scope
of the TOCDF Metal Parts Furnace (MPF)
Exhaust Gas Mercury (Hg) Monitoring to
Include Munitions Processing
Dear Colonel Pellissier:
This letter approves your July 16, 2007, request to modify the scope of the Tooele
Chemical Agent Disposal Facility (TOCDF) metal parts furnace (MPF) exhaust gas mercury
(Hg) monitoring to include munitions processing. EPA approved TOCDFs original Alternative
Monitoring Request (AMR) titled Manual Mercury Emission Measurements during Mustard
Agent Processing in the Metal Parts Furnace (MPF) on April 27, 2006 (Enclosure 1). EPA
approved the AMR under the authority retained by EPA for major AMRs in the National
Emission Standard for Hazardous Air Pollutants for Hazardous Waste Combustion (HWC) found
at 40 CFR 63.1214(c)(3). EPA approval of the original AMR was based on nine conditions. The
first condition of the approval pertained to the Scope of the Request and indicated that: This
approval shall apply only to the Baseline Processing phase of the TOCDF Mustard campaign
which restricts processing to only those [ton containers] TCs in which the level of Hg in the
liquid phase is less than 1 ppm.
Results obtained from the ongoing sampling and solid heel depth measurements of TCs
conducted in the Deseret Chemical Depot (DCD) chemical storage area and confirmation of the
TC liquid/solid mustard Hg correlation have caused a change in the original envisioned
munitions processing sequence relative to the timing of the installation and operation of Hg
pollution abatement systems (PAS) equipment. The revised sequence now calls for the
processing of the TCs, munitions, and secondary waste identified below before the installation
and operation of the new Hg PAS equipment. The change in processing sequence will allow for
additional time to design and install the Hg PAS and continued demilitarization of the DCD
stockpile while the equipment is being designed, installed and systemized.

TOCDF requests that the Scope of the Request of the original AMR be modified to
include the processing of low-Hg TCs (less than 1 ppm, or the Practical Quantification Limit
(PQL), in the liquid phase, whichever is less) that may have been pre-treated by the removal of a
portion of the TCs solid heel, 155 mm H Projectiles, low-Hg 4.2 HT Mortars, and secondary
waste which generally consist of agent contaminated wastes that are generated as a result of the
demilitarization process, examples of which are discarded process equipment and personnel
protective equipment. No other changes to EPAs original conditions of approval were
requested.
An enclosure to the July 2007 letter contains additional information about the additional
TCs, munitions, and secondary waste TOCDF would like to include in the Scope of the Request.
TOCDF believes that the additional TCs, munitions, and secondary waste have similar mercury
levels as the TCs approved in the original AMR and can be processed without exceeding the
emissions levels found at 40 CFR 63 Subpart EEE (Subpart EEE). Specifically, the enclosure
indicates that:
For TC's that have had a portion of the solid heel removed, a second criterion of the
baseline processing is that the TCs received at the TOCDF must have a high probability
of being able to be drained to a heel weight of equal to or less than the MPF charge
weight limit of 630 pounds, which is the charge weight established by results of the MPF
Mustard Agent Trial Burn/Comprehensive Performance Test (ATB/CPT). Results
obtained from the heel depth measurement show a much larger percentage of TCs having
solid heels too deep and heavy to allow for processing without a portion of the heel being
removed. TOCDF will be installing solid-heel removal equipment and will render the
larger-heel tons treatable by enabling a portion of the heel to be removed and thus lower
the TC weight to below 630 pounds.
The 155 mm H projectiles contain liquid mustard and solid mustard breakdown product
fraction. Based on process knowledge and sampling and analysis performed to date, the
155mm Projectiles do not have Hg contamination. Analysis of solid and liquid samples
collected from individual projectiles show consistently low concentration of metals in
both the liquid and solid phases. Hg results for both liquid and solid mustard phase were
reported at less than the analytical method's PQL which was approximately 0.5 ppm.
Therefore, 155 mm projectiles are not expected to contain Hg.
The 4.2 HT Mortars contain a mixture of Mustard (H) and Bis[2(2chloroethylthio)ethyl]ether (T) at approximately 6 to 4 weight rations, respectively. Of
the 4.2" HT Mortars that were sampled, 16% contained a film that adheres to the interior
of the emptied mortar. The amount of film per mortar comprised 2% of the initial HT fill
weight of 5.8 lbs. The mortars will be drained and the liquid portions fired in the liquid
incinerators (LICs). The drained mortars, some containing the un-drainable film, will be
fed to the MPF. Analysis of the liquid HT showed an average Hg concentration less than
the PQL. Analysis of the film that adheres to the interior of the emptied mortar showed
the presence of Hg. TOCDF does not anticipate having to limit the MPF 4.2 HT Mortar
2

processing rate because of the low incidence of film containing mortars and because of
the minimal amount of film found in the mortars. TOCDF intends to "ramp-up" the HT
mortar feed rate to ensure the validity of the contention that the occurrence and amount of
Hg containing film is sufficiently small as to not cause the Hg emission limit to be
exceeded.
Secondary waste is generated during demilitarizing of the chemical stockpile and
generally consists of agent contaminated wastes that are generated as a result of
demilitarization process (e.g., discarded process equipment and personnel protective
equipment). The ability to process the Secondary Waste in the MPF was allowed by
performance of the Secondary Waste Demonstration/Comprehensive Performance Test
(SWDR/CPT). To provide further assurance that the metal emission limits will not be
exceeded during the processing of Secondary Waste, conditions were included into
environmental permits prohibiting the placement of wastes containing regulated metals
within the MPF PCC at the same time as DPE Suits.
The Relative Accuracy Test Audit Report (AMR for Mercury Exhaust) dated
March 14, 2007, demonstrated that the original AMR accurately measures Hg emissions. The
report also indicates that the average Hg concentrations during the test were less than or equal to
52.88 g/dscm (4-hour average). These levels are below the Hg emission standard of 130
g/dscm (12-hour rolling average) as required by Subpart EEE.
Based on the information above, EPA believes that TOCDF can process the additional
TCs, munitions, and secondary waste and maintain compliance with Subpart EEE standards.
EPA approves modifying the Scope of the Request to include the processing of the above TCs,
munitions, and secondary waste.
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 Subpart EEE. If
you have any questions or concerns, please feel free to contact Laurie Ostrand of my staff at
(303) 312-6437.
Sincerely,

Martin Hestmark, Director

Technical Enforcement Program

Enclosure

cc:

Joe Randolph, UDAQ

Deb Ng
Division of Solid and Hazardous Waste
P.O. Box 144880
Salt Lake City, UT 84114-4880
Carol Smith, 8ENF-AT
Mike Owens, 8P-AR
Thaddeus A. Ryba, Jr.
CMA TOCDF
Site Project Manager
11620 Stark Road
Stockton, Utah 84071-9712
Gary W. McCloskey
EG&G Defense Materials, Inc.
General Manager TOCDF
11600 Stark Road
Stockton, Utah 84071