Complete Permit application Vol 1_Rev_1_6-8-18-2 PART 2.pdf

AaronMann Text Box Figure V-5

Container Handling System Process Flow Diagram

Figure V-6

Slurry Preparation and Recirculation System Arrangement mleigh Highlight

Figure V-7

Diagram of Tank System Piping and Instrumentation

Figure V-8

Schematic of Secondary Containment System

FIGURE V-9

WADF Aerial Photo

Legend

Building

2000 ft N

N © 2018 Google

© 2018 Google

© 2018 Google

Figure V-10

AERIAL PHOTOGRAPH OF WADF SHOWING LOCATION OF BUILDING

117-4/BEDS

Building 117-4 – Front View

Amanda Text Box Building 117-4 - Rear View

Figure V-11 Building 117-4 – Rear View Building 117-4 (Rear) and East Incinerator

East Incinerator [Note: Components designated with asterisk (*) will be replaced]

RCRA PART A AND B APPLICATION

MAIN BASE

HAWTHORNE ARMY DEPOT

HAWTHORNE, NEVADA

March 2018 – Revision 1, June 8, 2018 W-1

SECTION W WASTE FEED CHARACTERISTICS FOR BEDS

WASTE FEED CHARACTERISTICS FOR BEDS (40 CFR 270.14(b)(2) & (3) and 270.62(b)(2)(i))

INTRODUCTION

The United States Army plans to renovate and operate BEDS located in the WADF Building 117-4 at the HWAD. BEDS is designed to safely destroy a diverse group of energetic materials emerging from demilitarization operations in an environmentally acceptable manner. Most materials to be treated at

BEDS are considered RCRA hazardous waste due to material reactivity (EPA Waste Code D003).

Some may also be hazardous because of lead toxicity (EPA Waste Code D008) resulting from the presence of lead carbonate in formulation. BEDS will allow the Army to reduce the utilization of open burn/open detonation (OB/OD) to destroy energetic material.

Waste Feed Characteristics and General Information

Waste Feed Types

Wastes to be treated at BEDS will include bulk propellants in the form of fine powders, grains, extrusions, sticks, rolls, and other shapes. Propellants may be single based (nitrocellulose only) or multi-based (nitrocellulose with nitroglycerine and/or nitroguanidine). Later, additional propellants currently loaded in munitions may be added as feedstock after demilitarization. Small quantities of secondary explosives that have no recycle value, such as Explosive D, might also be processed. Section

V, Table V-1 is a representative list of energetics that may be processed at BEDS. This list includes both energetics that are inventoried at the site and some that are not currently at HWAD but could be processed by the system.

Waste Feed Composition

Waste feed compositions are presented in column two of Section V, Table V-1. These compositions are obtained from the Munitions Items Disposition Action System (MIDAS) database for various items in lieu of actual analysis of each material. MIDAS provides parts and composition data for nearly

20,000 components in 6,500 munitions items.

March 2018 – Revision 1, June 8, 2018 W-2

Waste Feed Rate

The feed rate of propellant to the BEDS facility is expected to be 550 pounds per hour, regardless of the propellant being processed. Material and energy balances have been developed for 24 representative propellants. Other anticipated propellants are similar in nature. The incinerator and pollution abatement system are predicted to successfully process each anticipated feedstock in a manner such that the Maximum Achievable Control Technology (MACT) emissions standards are met.

Propellant will be fed as a slurry consisting of 25-weight-percent propellant (maximum) and 75-weight-percent water, resulting in a slurry feed rate of 2,200 pounds per hour. BEDS is expected to operate 24 hours/day, 7 days/week for 3 to 6 week intervals. The annual operating hours will be no more than 3,120 hours as limited by the air permit.

Feed Rate Control System

Propellant slurries will be mixed in a batch process. Propellant material will be weighed for each batch. Water will be measured using a flow meter. A densitometer will be used to verify that the slurry density is approximately a 3:1 liquid-to-solid ratio in the Slurry Mix Tank. Each slurry batch will be transferred to the Slurry Feed Tank. A second densitometer will verify that the 3:1 liquid-to-solid ratio is maintained during feed of the slurry to the incinerator. A metering pump will control the flow of slurry to the incinerator at a consistent rate.

Regulatory Emission Limits

As of September 30, 1999, the CFR was revised to avoid duplicative requirements under RCRA and the CAA by transitioning the RCRA requirements under 40 CFR 270.19 and 40 CFR 270.62 to the

CAA under 40 CFR Part 63 Subpart EEE, which is also known as the MACT rule. BEDS PAS is designed to meet or exceed the U.S. Environmental Protection Agency’s (EPA’s) National Air

Emission Standards for Hazardous Air Pollutants from Hazardous Waste Combustors given in 40 CFR

Part 63 Subpart EEE. Air emissions will be regulated under a CAA Permit (see Appendix CC) administered by the NDEP. Since the waste feed rate will be constant for all propellants, the

Comprehensive Performance Test Plan (CPTP) of the CAA Permit will include a trial burn using the propellant with the ―worst emission profile. A copy of the CPTP is also given in Appendix U of this

RCRA Permit.

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Waste Analysis Plan for Beds

Waste analysis for BEDS will be conducted in accordance with the Waste Analysis Plan for the

Hawthorne Facility, as detailed Appendix B.

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SECTION X CLOSURE PLAN FOR BEDS

CLOSURE PERFORMANCE STANDARD [40 CFR 264.111 and 264.112]

As closure of the active hazardous waste treatment unit at HWAD is not contemplated at this time, detailed sampling and analysis plans have not been prepared. The closure performance standard will be determined at such time that closure of the hazardous waste management unit at HWAD is contemplated. The closure performance standard will be defined to ensure the following:

The need for continuing maintenance (i.e., post-closure maintenance) will be minimized.

The closure activities will control, minimize, or eliminate, to the extent necessary to protect human health and the environment, post-closure escape of hazardous waste, hazardous constituents, leachate, contaminated runoff, or hazardous waste decomposition products to the ground or surface waters or to the atmosphere.

The closure activities will comply with the provisions of 40 CFR Part 264 Subpart G.

The closure performance standard will be defined and proposed by HWAD and will be submitted to the USEPA and NDEP for approval before implementation of the closure plan.

A copy of This Closure Plan will be kept at HWAD until closure is completed and certified. If changes in operating plans or facility design affect the closure plan, this plan will be amended in accordance with the provisions of 40 CFR 264.112. HWAD will be responsible for expanding upon and updating the facility's copies of closure plans when revisions are necessary due to changes in the operations, facility design, and schedule. The USEPA Region IX and NDEP will be notified at least 45 days prior to the date closure activities are scheduled to begin. All closure activities will be completed within 180 days after the closing units receive the final volume of waste for treatment.

Within 60 days of completion of closure activities, the owner/operator and an independent registered

Professional Engineer will certify that closure of the facilities was completed in accordance with the specification contained in the approved Closure Plan. This certification will be forwarded to the

Regional Administrator, USEPA.

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CLOSURE OF BULK ENERGETICS DEMILITARIZATION SYSTEM (BEDS) [40 CFR 264.351]

BEDS will treat hazardous waste and contaminated materials generated at HWAD through thermal treatment. Closure activities for BEDS must, therefore, meet the requirements for closing hazardous waste incinerators. The closure of BEDS will meet closure performance standards and will be implemented in accordance with the approved closure plan. Any inventories of wastes will be removed and disposed of in accordance with the approved plan. BEDS includes equipment and structures;

removal and/or decontamination of the equipment and structures will meet the closure performance standards, and be implemented in accordance with the approved closure plan. See Closure Plan for a description of planned closure activities, including inventory removal and removal and/or decontamination of equipment and structures.

Partial Closure Activities [40 CFR 264.112(b)]

Partial closure is not anticipated for the HWAD BEDS at this time. If future circumstances require

HWAD to close a portion of the BEDS unit, or close the unit for a period of time, revisions in the closure plan will be submitted to the appropriate regulatory agencies within the required time limit.

CLOSURE PLAN [40 CFR 270.14(b)(13)]

This closure plan has been prepared for the BEDS. The plan is designed to meet the performance standard of 40 CFR 264.111 as follows:

1. Minimizes the need for further post-closure maintenance.

2. Controls, minimizes or eliminates, to the extent necessary to prevent threats to human health and the environment, post-closure escape of hazardous waste, hazardous waste constituents, leachate, contaminated rainfall, or waste decomposition products to the ground or surface waters or to the atmosphere.

The Closure Plan for BEDS includes the following:

1. Necessary steps to completely close the facility at the end of its intended operating life.

2. An estimate of the maximum inventory of wastes in treatment at any time during the life of the facility.

3. A description of the steps needed to decontaminate facility equipment during closure.

4. An estimate of the expected year of closure and a schedule for final closure which includes the total time required to close the facility.

Within ninety (90) days after receiving the final volume of hazardous wastes, the facility will treat or

March 2018 – Revision 1, June 8, 2018 X-3 remove from the site, all hazardous wastes in accordance with the approved closure plan. Because the installation is a federal facility, no closure cost estimates or financial assurance mechanisms are necessary according to 40 CFR 264.140(c).

Copies of the Closure Plan are maintained at the installation. If any operational changes occur that will affect the Closure Plan, an amendment to the plan will be submitted to the NDEP and EPA.

Bulk Energetics Demilitarization System (BEDS) Description

BEDS is designed to safely destroy energetic materiel emerging from demilitarization operations in an environmentally acceptable and safe manner. Primary feedstock will be bulk propellants in the form of fine powders, grains, extrusions, sticks, rolls, and other shapes. Propellants may be single-based

(nitrocellulose only) or multi-based (nitrocellulose with nitroglycerine and/or nitro guanidine).

Additional propellants that are currently loaded in munitions which might later be demilitarized could also be included as feedstock. Small quantities of secondary explosives that have no recycle value, such as Explosive D, might also be processed. This feedstock will be referred to throughout this document by the general term of propellant. These materials are considered RCRA hazardous waste due to the explosive (reactive) components. Some materials may also be considered hazardous due to metal content, such as lead. This system is designed to meet the MACT emissions criteria of the US-

EPA’s Hazardous Waste Combustor standards for incinerators. A simplified flow diagram of the BEDS process is shown in Section V, Figure V-1.

BEDS consists of a slurry feed system, rotary kiln, combustion chamber, and air pollution-control equipment.

Slurry Feed System

The slurry feed system is used to reduce the size of propellant and prepare a water-based slurry for feeding to the rotary kiln.

Solid propellant loaded in specially designed drums is delivered to Building 117-4. Energetic material is weighed and then moved into the slurry preparation area through an airlock. In each step of the solids handling in the slurry preparation area, a water spray is used to wet these solids so as to avoid

March 2018 – Revision 1, June 8, 2018 X-4 accidentally detonating the propellant. Drum contents are fed into the feed hopper which is equipped with vibratory means for uniformly feeding energetic solids onto a conveyor through a bottom opening.

The conveyor moves energetic solids through a metal detection device wherein any tramp metal can be detected. If metal is detected, the conveyor is stopped and the metal is manually removed. Propellant is conveyed into a wet grinder at a controlled rate. In the wet grinder, the energetic material is ground in the presence of water. Resulting solids have a maximum dimension of 0.1 of an inch or less.

Ground particles of energetic material, water used during grinding, and additional water as required to develop a mixture of three-parts water to one-part explosive (by weight) are directed into the slurry mixing tank where agitation and recirculation are provided to keep these particles in suspension. A hydroclone provides particle-free liquid for recycle to the balance of the system as needed (including sprays in the dump hopper, the vibratory conveyor, the grinder hopper, and the grinder).

This suspension is then pumped to the slurry feed tank and subsequently pumped through a slurry feed line. Flow through the feed line is maintained in the turbulent range to ensure particles remain in suspension. In addition, the slurry is constantly re-circulated through the loop and back to the tank to prevent solids from settling. A pump pulls a slip-stream from the slurry feed line and discharges it to the rotary kiln.

Rotary Kiln

The rotary kiln is a refractory-lined rotary furnace. It is approximately 5.5 feet in internal diameter and

11-feet long. The kiln has a single burner assembly at the discharge end of the kiln, which is the opposite end from where the wastes are fed. A low-sulfur Diesel Fuel No. 2 Burner is used during the combustion of waste material to sustain the operation temperature. Fuel consumption varies with the specific waste material to be processed. When a high heat content material is incinerated, less oil may be required. At maximum firing, fuel consumption may be increased up to 15 million British thermal units per hour. The burner is equipped with all accessory equipment necessary for the burner operation.

A flame sensor detects the presence of flame by sensing ultraviolet light emissions and acts as a flame-failure safety device. The control system will not allow wastes to be fed to the rotary kiln unless this sensor detects a flame from the burner.

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The kiln is supported and rotated by rollers at a variable speed (0.5-6.0 revolutions per minute). Ash drops from the discharge end of the kiln to an ash gate, for intermittent removal if needed. Gases leaving the kiln are ducted to the combustion chamber.

Combustion Chamber Description

The combustion chamber provides final combustion of kiln exhaust gases. This chamber is capable of heating exhaust gases up to 2000°F, providing approximately two seconds of residence time, and achieving highly turbulent flow to ensure good mixing for effective destruction of waste gases. The combustion chamber is constructed of carbon steel and internally insulated with a refractory liner.

Normal exhaust temperature will be 1800°F; maximum expected temperature is 2000°F.

A forced-draft fan supplies air to fuel-oil burners in the combustion chamber. The combustion chamber burners are equipped with an UV-flame sensor to monitor ignition and assure a flame is present before waste is fed. Additional combustion air is provided by the combustion air blower, as needed.

Pollution Abatement System

A PAS completes the pollution control function of the combustion chamber. Exhaust gases from the combustion chamber are routed to the evaporative cooler where gases are quenched from approximately 1800°F to approximately 350°-400°F with injected water. Temperature of the exhaust gas from the evaporative cooler is maintained by controlling the flow of quench-water. Only enough water is added to cool the stream. No liquid water is carried in the gas stream. Just downstream of the evaporative cooler, hydrated lime will be continuously fed into the gas stream to react with HCl or

SO2 gases to form calcium salts. An excess stoichiometric ratio will be used to ensure that a high percentage of HCl, SO2, and other acid gases are removed. If the evaporative cooler exit temperature exceeds the high-temperature limit, an automatic waste feed cutoff to the rotary kiln will be activated, assuring protection of the equipment.

The next stage of the air pollution control system is the baghouse. The baghouse is designed so that all bags operate in parallel. Injected lime is carried over to the baghouse in gas stream. Particulate matter is collected on the fabric filter bags to achieve a highly efficient removal of solids, including fly ash, reaction products, and reagent. Although the primary function of the baghouse is to remove

March 2018 – Revision 1, June 8, 2018 X-6 particulates, an additional acid scrubbing action takes place there. Unreacted reagent collecting on the bags reacts with any un-reacted HCl or SO2 in the evaporative cooler effluent gases.

A pulse-jet cleaning system operating on compressed air cleans the bags. Dust composed of reaction products, fly ash, and un-reacted reagent, is collected in the bottom section of the baghouse. Manually-operated valves transfer collected dust to the collection containers for ultimate disposal. Nonhazardous waste will be disposed on-site at a permitted landfill or equivalent, and hazardous waste will be sent off-site for disposal at a permitted hazardous waste landfill.

The baghouse is sized to accommodate the full flow of quenched flue gas. The baghouse will only be bypassed in the event that evaporative cooler exit gas exceeds maximum operating temperature of approximately 450°F. An interlock shall be provided to activate automatic waste feed cutoff if the bypass valve is opened. Emissions released during bypass operations will be minimal, since waste feed is stopped and the facility goes into shutdown mode to correct the conditions which resulted in opening the bypass valve.

The baghouse exhaust duct includes a bag leak detector capable of sensing less than 0.001 grains of particulates per cubic foot of flue gas. This bag leak detector includes a prewired output signal that will be used in the controls system to warn the operator of a leak in a fabric filter bag.

An induced draft fan provides the system draft control, using a variable frequency drive to modulate fan speed based on a pressure signal at the rotary kiln exhaust gas manifold duct. The induced draft fan discharges all gases to an adjacent exhaust stack, which contains a gas sampling system to provide continuous analysis for particulates, carbon monoxide (CO), oxygen (O2), sulfur dioxide (SO2), and oxides of nitrogen (NOx).

BEDS Hazardous Waste Inventory

Waste materials are not stored at BEDS. Propellants are stored in appropriate buildings at the installation. When the decision to destroy propellants is made, propellants are moved from the storage area to the BEDS facility. Once propellants are removed from the storage magazine, they are considered a hazardous waste. The maximum amount of material allowed on-site at one time at

March 2018 – Revision 1, June 8, 2018 X-7

Building 117-4 is the equivalent of 5,000 pounds of Hazard Class 1.1 Material.

Operating BEDS will generate one major waste stream: the collection of waste from the baghouse (see

Section V, Figure V-1). Baghouse wastes will be produced at a rate of approximately 24 pounds per ton of propellant slurry processed and collected in drums from the bottom of the baghouse. These wastes include the carryover ash from the rotary kiln and combustion chamber, calcium salts from the reaction of acidic gases (such as SO2 and HCL with hydrated lime), unreacted lime, and trace amounts of solids from the evaporative cooler. Negligible sources of waste will be heavier ash from the rotary kiln (collected in drums from the downstream side of the rotary kiln), and evaporative cooler wastes.

Each waste stream will be sampled and analyzed pursuant to the Waste Analysis Plan, which is detailed in Appendix B. These wastes will be disposed in compliance with state and federal regulations. It is not anticipated that BEDS will generate any liquid waste streams.

BEDS Closure Procedures Performance Standards

BEDS components will be decontaminated to the "XXX" (3X) condition, see Department of Army

Pamphlet 385-64 and AMC Regulation 385-10 (Appendix T). The 3X condition is a military standard which indicates that equipment or facilities have been examined and decontaminated by approved procedures and that no contamination can be detected by appropriate instruments, test solutions, or visual inspection. Facilities classified as 3X are considered safe for the intended government use.

Department of Defense Manual DOD 4145.26-M "Contractors’ Safety Manual for Ammunition and

Explosives" also prescribes policies and procedures relating to the decontamination and disposal of contaminated items.

Decontamination of Surfaces, Structures, and Components Slurry Feed System

All wet grinders, tanks, pumps, hoppers, piping, and components will be steam cleaned and flushed of processing residue. The flush residue and all excess solids and materials from the cleanout of the equipment will be collected and analyzed, if necessary, to determine if it is a hazardous waste.

The feed conveyors will be dry-brushed to remove any large quantities of contamination that may exist.

The brushings will be collected and analyzed, if necessary, to determine if they are hazardous. Any waste from the decontamination of the slurry feed system will be containerized.

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Rotary Kiln, Combustion Chamber, and Off Gas Ductwork/Piping

The rotary kiln is a refractory lined furnace with parts made of carbon steel. The discharge end of the kiln at the ash gate may contain a residue of ash. A layer of particulate from the process will cover all refractory and may contain metals from propellant processing.

The combustion chamber is constructed of carbon steel and the internally insulated with a refractory liner. The refractory liner will be covered by a layer of particulate from the processing operation which may contain metals that are the same as those contained in the processed propellants.

The off-gas ductwork/piping is expected to contain contaminants similar to those found in the rotary kiln and combustion chamber.

Decontamination will occur by removing all refractory and residue from within the kiln, combustion chamber, and ductwork/piping and properly containerizing the residue. The kiln and combustion chamber will then be disassembled and placed upon containment liners for physically and manually removing remaining residue that may be in sections of the vessels. If residue and containment liners are characterized as hazardous waste, these will be containerized and managed as such.

Pollution Abatement System

The pollution abatement system is comprised of an evaporative cooler, lime hopper, venturi, baghouse, induced draft fan, stack, and associated pumps, compressors, and piping. Filter bags will be removed from the baghouse and containerized. Any remaining dust in the baghouse and downstream ductwork will be removed and containerized. The interior surfaces of equipment will be decontaminated by detergent/water rinse. Gates and other ancillary devices will be vacuumed. Further decontamination, such as scrubbing, solvent rinse, etc., will depend upon analysis of the samples.

All equipment will be dry brushed or cleaned on the exterior surface. Brushings and cleaning wipes will be collected and tested for toxic residue.

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Disposal

If determined by generator knowledge or testing to be hazardous, debris, wastewater, and other contaminated residues or materials will be disposed as hazardous waste at an off-site, permitted hazardous waste disposal facility. All filter bags from the baghouse and contaminated refractory from the kiln and chamber, and contaminated off-gas piping will be containerized and disposed as hazardous waste, if required. Any equipment which is difficult or too time consuming to decontaminate adequately, will also be disposed as hazardous waste, if required. Any soil that contains hazardous constituents or is shown to contain contamination will be treated as hazardous waste if it exceeds the applicable RCRA limits.

All residues that are hazardous waste will be placed in DOT approved drums and must be removed from the incinerator area within 72 hours after the drum has been filled. Full drums of hazardous waste must be stored at the installation in a temporary or permitted storage facility prior to disposal, if not shipped directly to a permitted off-site treatment, storage, or disposal facility. Wastewater may be accumulated in tanks or tank trucks during decontamination prior to disposal. If hazardous, it too will be managed as hazardous waste.

Prior to any materials being disposed as nonhazardous waste or sold as scrap metal, these materials must be certified decontaminated by analyses.

Submission of Sampling and Analysis Plan

Brushings, rinse water, and rust will be tested to determine if these are hazardous in accordance with

40 CFR § 261, Appendices II and III and EPA Report No. SW-846. Samples will be analyzed for metals from propellants destroyed in the incinerator using TCLP.

After decontamination operations, equipment, floors, and walls will be sampled and analyzed for possible contamination. A wipe sampling technique will be used to determine the surface concentration of metals remaining on BEDS components and surrounding areas.

The wipe sampling technique involves wiping selected measured areas on the surface area to be sampled with Kimwipe tissues (or equivalent) wetted with distilled water. The proposed sampling

March 2018 – Revision 1, June 8, 2018 X-10 protocol will generally conform to EPA Standard Operating Procedure No. 2011 for wipe samples presented in the Compendium of Environmental Response Team Waste Sampling Procedures

(EPA/540/P-91/008) January 1991, or other applicable guidance, as appropriate. Each wipe sample location will be thoroughly wiped with one Kimwipe to remove all residues within the specific measured area to be sampled. Each individual Kimwipe will be placed in a separate container and transported to the laboratory for analysis.

The laboratory will determine the total metal content of the Kimwipe in each sample bag. Sample metal contents will be divided by the corresponding total wipe area to determine the area metal concentration for the surface which has been sampled.

Soil boring samples, 2 feet in depth, will be collected at 10-foot intervals at the BEDS. Samples will be taken at the edge of equipment support structures (e.g., concrete slab, footer). Then, samples will be taken around the entire BEDS building concrete pads perimeter and extend outwards for a minimum of 50 feet, or up to other installation buildings. Analyses will be conducted for reactivity and toxicity

(TCLP).

Background soil-boring samples will be collected from multiple locations and depths. Background levels will be determined by averaging the analyses of nearby unaffected soil samples from the multiple locations and depths, eliminating analytical results which are found to be significantly different.

In the event that all background samples show a parameter to be non-detectable, the decontamination objective shall then be less than, or equal to, two times the detection limit for that parameter. However, in the event that only some background samples indicate a parameter to be non-detectable, concentration of the parameter in those samples will be assumed to be equal to one-half the detection limit. If necessary, the potential contaminated area will be tested at greater depths and farther distances to determine the nature and extent of contamination.

If the groundwater is found to be contaminated during soil sampling, a sampling and analysis plan will be submitted to the EPA. This plan would include procedures and techniques for sample collection, sample presentation and shipment, analytical procedures, and chain of custody control.

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Sampling and Analysis Plan

This sampling plan has been developed for the Resource Conservation and Recovery Act (RCRA) closure activities for the Bulk Energetics Demilitarization System (BEDS) located at the Hawthorne

Army Depot (HWAD) in Hawthorne, Nevada. The plan describes the sampling and analysis activities required to complete closure of the BEDS unit. The closure plan requires equipment and surface sampling and analysis to demonstrate that decontamination procedures were effective. This plan describes the sampling strategies for the closure project, provides detailed procedures for sampling, and establishes quality assurance (QA) and quality control (QC) procedures.

Plan Organization

This sampling plan has been prepared generally following the United States Environmental Protection

Agency’s (USEPA’s) Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-

846) Chapter Nine, Sampling Plan. The plan will serve as an essential guidance by which the closure samples will be collected and handled. The plan defines all aspects of QA/QC procedures and establishes sampling and analytical quality indicators that will demonstrate achievement of the sampling objectives.

Sampling Objectives

During the closure activities, sampling will be performed to verify that the closure performance standards have been achieved. The performance standards have been developed to control, minimize, or eliminate, to the extent necessary to prevent threats to human health and the environment, post-closure escape of hazardous waste, hazardous waste constituents, leachate, contaminated rainfall, or waste decomposition products to the ground or surface waters or to the atmosphere.

This sampling plan addresses the sampling requirements for closure. The following performance standards will be achieved for closure:

The exterior of all APC equipment that is located outdoors will be cleaned to the point that no hazardous residue is indicated.

all process equipment, will be sealed or protected to prevent the infiltration of rainwater and contamination of runoff.

The walls and floors of the primary BEDS building will be cleaned such that no visible residue remains on them. The building will then be closed in place.

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Sampling will be used to verify that cleaning procedures were effective for the exterior of the APC equipment that is located outdoors and for the walls and floors of the BEDS building. The closure plan specifies that wipe sampling will be performed. Wipe samples will be collected and analyzed to verify that the equipment and surfaces are free of hazardous residues. Comparison of wipe sample analytical results to an unused wipe media sample (blank) will be used to determine the presence or absence of contamination.

Sampling Design

A judgmental sampling design has been chosen for the closure sampling activities. This sampling design is described in USEPA’s Guidance on Choosing a Sampling Design for Environmental Data

Collection, December 2002. Judgmental sampling refers to the selection of sample locations based on professional judgment alone, without any type of randomization. Judgmental sampling was chosen based on the following criteria:

Relatively small-scale features or conditions are under investigation;

There is reliable historical and physical knowledge about the feature or condition under investigation; and

The objective of the investigation is to screen an area(s) for the presence or absence of contamination at levels of concern.

In judgmental sampling, the selection of sampling units (i.e., the number and location of samples) is based on knowledge of the feature or condition under investigation and on professional judgment. This method is appropriate for the closure sampling because the current condition of the equipment and area is known and the sampling is only being used to indicate possible contamination after cleaning.

This sampling plan addresses wipe sampling for the exterior of the BEDS equipment and for the walls and floors of the BEDS building. For sampling purposes, the BEDS equipment has been separated into two regions: the interior process equipment, and the APC equipment that is located outdoors (the

Combustion Chamber, Evaporation Cooler, and Baghouse). The two interior walls closest to the BEDS equipment will be sampled, and the floor in the vicinity of the BEDS equipment will be sampled.

Sample locations will be chosen based on visual observations and process knowledge. Any visibly stained areas on equipment, walls, and floor will be chosen as sampling locations. In the absence of such visual indication, process knowledge will be used to select locations most likely to have been

March 2018 – Revision 1, June 8, 2018 X-13 contaminated during unit operation. Table X-1 summarizes the sampling locations and defines the number of samples to be taken for each location.

Sampling Procedures

The sampling procedures for this project will conform to the following ASTM standards:

D6966–08, Standard Practice for Collection of Settled Dust Samples Using Wipe Sampling Methods for Subsequent Determination of Metals; and

D6661–10, Standard Practice for Field Collection of Organic Compounds from Surfaces Using Wipe Sampling.

Copies of the referenced procedures are provided in Appendix W. An overview of each procedure is provided herein. This section is only intended to provide a basic overview of the standards. The actual standards in the appendix should be referenced when performing the sampling.

March 2018 – Revision 1, June 8, 2018 X-14

TABLE X-1: SAMPLE LOCATIONS AND NUMBER OF SAMPLES

SAMPLE LOCATION

NUMBER OF SAMPLES

NOTES

METALS

(INCLUDING

MERCURY)

ORGANICS

(EXPLOSIVES)

BEDS process equipment 3 3 Samples should be distributed over the surface of the BEDS process equipment, with preference given to those areas most likely to be contaminated (via visual indication or process knowledge).

Dump Hopper 2 2 Samples should be distributed over the surface of the Dump Hopper.

BEDS feed conveyors 2 2 Samples should be distributed over the surface of the feed conveyors.

Grinder 2 2 Samples should be distributed over the surface of the Grinder.

Mix Tank 2 2 Samples should be distributed over the surface of the Mix Tank.

Feed Tank 2 2 Samples should be distributed over the surface of the Feed Tank.

Rotary Kiln 2 2 Samples should be distributed over the surfaces of the Rotary Kiln.

Combustion Chamber 2 2 Samples should be distributed over the surfaces of the Combustion Chamber.

Evaporation Cooler 2 2 Samples should be distributed over the surface of the Evaporation Cooler.

Baghouse 4 4 Samples should be distributed over the surface of the baghouse.

Building walls 6 6 Samples should be distributed over surface of the two walls closest to BEDS equipment.

Building floor 3 3 Samples should be distributed over the surface of the floor surrounding and under the BEDS equipment

Field duplicates 2 2 Collected immediately adjacent to one of the samples at two designated locations. The baghouse and the building floor have been chosen as the field duplicate sampling locations.

Blanks 3 3 Carried to site, unopened, labeled as blank in field.

Total Number of Samples to Be Analyzed

37 37

Notes: When collecting wipe samples of equipment or building surfaces, preference should be placed on sampling areas with stains or other indications of possible contamination. Absence such evidence, select areas most likely to be contaminated based on process knowledge. If no such areas can be identified, distribute the samples randomly over the surface of the item to be sampled.

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Wipe Sampling for Metals Determination

The procedures of ASTM Standard D6966–08 Section 7 are summarized in Table X-2. Each sampling area will be defined as a 10 centimeter (cm) by 10 cm square. A template will be developed prior to sampling to ensure uniform sample areas.

TABLE X-2: WIPE SAMPLING PROCEDURE FOR METALS DETERMINATION

STEP PROCEDURE

1 Don a pair of clean, powderless, plastic gloves

2 Carefully place a clean template on the surface to be sampled. Tape the outside edge of the template and outline it with a Sharpie® marker to indicate the position of the template and make sure it does not move.

Clean the outside of the wipe container to ensure that the wipe does not become contaminated with dust.

4 Remove the wipe from its container, and inspect the wipe.

5 Using an open flat hand with the fingers together, place the wipe on the surface to be sampled.

Wipe the selected surface area, side to side, in an overlapping “S” or “Z” pattern. Wipe the surface so that the entire selected surface area is covered.

6 Inspect wipe for significant shape change or tearing. If any significant changes noted, restart sampling procedures with a different type of wipe at a new sampling location.

7 Fold the wipe in half with the collected dust side folded inward and repeat the wiping procedure (step 5) within the selected sampling area using an up and down overlapping “S” or “Z” pattern at right angles to the first wiping.

8 Fold the wipe in half again with the collected dust side folded inward and repeat the wiping procedure (step 5) one more time, concentrating on collecting settled dust from edges and corners within the selected surface area.

Fold the wipe again with the collected dust side folded inward and insert the wipe into a sample container.

10 Label the sample container, identify the sample location, record dimensions of sampling area.

11 Discard gloves.

Wipe Sampling for Organics Determination

The procedures of ASTM Standard D6661–10 Section 7 are summarized in Table X-3. Each sampling area will be defined as a 10-cm by 10-cm square. A template will be developed prior to sampling to ensure uniform sample areas.

Blank Samples

The objective of the sampling activities is to verify that cleaning procedures were effective for the exterior of the APC equipment and for the walls and floors of the BEDS building. In order to determine the presence or absence of contamination, blank samples must be analyzed to provide a point of comparison.

March 2018 – Revision 1, June 8, 2018 X-16

TABLE X-3: WIPE SAMPLING PROCEDURE FOR ORGANICS DETERMINATION

STEP PROCEDURE

1 Don a pair of clean, powderless, plastic gloves

2 Carefully place a clean template on the surface to be sampled. Tape the outside edge of the template and outline it with a Sharpie® marker to indicate the position of the template and make sure it does not move.

Clean the outside of the wipe container to ensure that the wipe does not become contaminated with dust.

4 Remove the wipe from its container, and inspect the wipe.

5 Wipe the entire surface to be sampled using firm strokes by pressing with the fingertips. Wipe vertically and then horizontally to ensure there is complete coverage in both directions with minimal overlap of the previous stroke.

Fold the wipe with the sampled side inward, place it in the sample container, and cap the container.

7 Label the sample container, identify the sample location, record dimensions of sampling area.

8 Discard gloves.

Unused wipe media samples will be used as the blanks for this sampling program. ASTM Method

D6966–08 requires that field blanks field are collected at a minimum frequency of five percent, with a minimum number of three samples for each batch. A total of 37 samples will be collected for this sampling event. Three blank samples will be collected.

Blank samples will travel to the site with the other sample media. The containers will not be opened.

The blank containers will be labeled onsite and shipped to the laboratory with the collected surface samples.

Field Duplicate Samples

A field duplicate will be collected for two sampling locations, an outside location and an inside location. The sampling locations chosen for the field duplicates are the baghouse and the building floor.

For each chosen sampling location, one duplicate sample will be collected. The duplicate sample will be collected immediately adjacent to one of the regular samples for that location.

Other Miscellaneous Samples

Other miscellaneous samples will be collected as necessary to satisfy sampling conditions of other permits or to determine the method of proper disposal. Details on this sampling and the required analyses can be found in the source permits.

March 2018 – Revision 1, June 8, 2018 X-17

Sampling Equipment

The following equipment will be required for the sampling:

• Disposable, powderless, plastic gloves;

• Plastic or cardboard templates for metals sampling;

• Stainless steel, aluminum, disposable heavy-duty aluminum foil or other inert material templates for organics sampling;

• Adhesive tape to secure templates;

• Cleaning cloths to clean templates and other equipment between samples;

• Pre-wetted sampling wipes (material and solution to be selected by laboratory);

• Rigid, sealable sample containers; and

• Preprinted labels, sample log forms, and chain of custody forms.

Analytical Procedures

The analytical methods to be used for this sampling effort are detailed in Table X-4. The table presents the referenced analytical method and sample preparation method.

TABLE X-4: SAMPLE PREPARATION AND ANALYSIS PROCEDURES

PARAMETER PREPARATION/ANALYTICAL METHOD

Metals (except mercury) SW‐846 Method 6010B

Mercury SW‐846 Method 7470A or 7471A

Organics (explosives) SW‐846 Method 8330

Table X-5 specifies the target analytes for each analytical method.

Quality Assurance and Quality Control

The HWAD is committed to ensuring that the data generated during this project are scientifically valid, defensible, complete, and of known precision and accuracy. This section discusses the QA procedures that will be in place for sample collection and handling. In addition, QC objectives for the analytical methods are established.

March 2018 – Revision 1, June 8, 2018 X-18

TABLE X-5: TARGET ANALYTES

ANALYTE CAS NO. ANALYTE CAS NO.

SW‐846 Method 6010B (Metals)

Arsenic 7440–38–2 Lead 7439–92–1

Barium 7440–38–2 Selenium 7782–49–2

Cadmium 7440–43–9 Silver 7440–22–4

Chromium 7440–47–3

SW‐846 Method 7470A or 7471A (Mercury)

Mercury 7439‐97‐6

SW‐846 Method 8330 (Explosives)

4‐Amino‐2,6‐dinitrotoluene (4‐Am‐DNT) 19406‐51‐0 Nitrobenzene (NB) 98‐95‐3

2‐Amino‐4,6‐dinitrotoluene (2‐Am‐DNT) 35572‐78‐2 2‐Nitrotoluene (2‐NT) 88‐72‐2

1,3‐Dinitrobenzene (1,3‐DNB) 99‐65‐0 3‐Nitrotoluene (3‐NT) 99‐08‐1

2,4‐Dinitrotoluene (2,4‐DNT) 121‐14‐2 4‐Nitrotoluene (4‐NT) 99‐99‐0

2,6‐Dinitrotoluene (2,6‐DNT) 606‐20‐2 Octahydro‐1,3,5,7‐ tetranitro‐1,3,5,7‐ tetrazocine (HMX)

2691‐41‐0

Hexahydro‐1,3,5‐trinitro‐ 1,3,5‐triazine (RDX) 121‐82‐4

1,3,5‐Trinitrobenzene

(1,3,5‐TNB) 99‐35‐4

Methyl‐2,4,6‐ trinitrophenylnitramine (Tetryl)

479‐45‐8 2,4,6‐Trinitrotoluene

(2,4,6‐TNT)

118‐96‐7

Sample Identification

The sampling contractor will be responsible for ensuring that sample tracking documentation procedures are followed for the field sampling efforts. Documentation of all sample collection activities will be recorded on pre-printed data collection forms and sample labels. Table X-6 provides a summary of sample documentation requirements.

TABLE X-6: SAMPLE DOCUMENTATION REQUIREMENTS

DOCUMENT REQUIRED INFORMATION

Sample identification label Time and date of sampling

Description of sample (equipment name, location, etc.)

Unique identifier for sample

Target analytes (metals or organics)

Sampler’s name

Sample data forms List of all samples taken

Time and date of sampling

Description of sample (equipment name, location, etc.)

Unique identifier for sample

Sampling technique (ASTM Standard D6966–08 or D6661–10)

Target analytes (metals or organics)

Sampler’s name

March 2018 – Revision 1, June 8, 2018 X-19

Chain of Custody

An essential part of any sampling and analysis program is ensuring the integrity of the sample from collection to data reporting. The possession and handling of samples should be traceable from the time of collection through analysis and final disposition. chain of custody procedures will be used to ensure the integrity of the samples by tracking possession from the time of collection to delivery to the laboratory. The custody of all samples is tracked using chain of custody forms. The following procedures will be employed: All samples will be properly labeled. Labels will be affixed to the sample container. Sample labels will be completed using waterproof ink.

A chain of custody form will accompany all samples. When transferring the possession of samples, the individuals relinquishing and receiving the sample(s) will sign, date, and note the time on the form.

This form will document sample custody transfer from the sampler, often through at least one other person, to the laboratory.

The chain of custody form will specify the preservation requirements and the preparation and analysis methods to be used for each sample, as well as any additional information related to the sample.

Authorized personnel will maintain chain of custody for all samples. The history of each sample and its handling will be documented from the time it is collected through all transfers of custody, until it is relinquished to the laboratory. The laboratory will then maintain internal custody according to the laboratory’s procedures. A sample will be considered to be in a person’s custody if:

It is in one’s actual physical possession;

It is in one’s view, after being in one’s physical possession;

It is in one’s physical possession and locked or otherwise sealed so tampering will be evident; or It is kept in a secure area, restricted to authorized personnel only.

Sample Handling

Samples will be collected, transported, and stored in new, unused containers, such as glass jars, which are constructed of materials inert to the analytical matrix. Only containers that allow airtight seals, such as containers with Teflon-lined lids, will be used.

Table X-7 outlines the holding times for the analytical parameters for wipe samples. All sample holding

March 2018 – Revision 1, June 8, 2018 X-20 times will be consistent with the requirements of the method(s), or an equivalent method, if the prescribed method does not specify a holding time. The holding times begin on the day of sample collection, not on the day that samples arrive at the laboratory. Samples are typically hand-delivered or shipped via overnight mail to the contract laboratory.

TABLE X-7: SAMPLE HOLDING TIME REQUIREMENTS

PARAMETER

HOLDING TIME FROM SAMPLE TO

EXTRACTION

HOLDING TIME FROM

EXTRACTION TO ANALYSIS

Metals (except mercury) 180 days 180 days

Mercury 28 days 28 days

Organics (explosives) 14 days 40 days

Quality Control Parameters

QC objectives include precision, accuracy, representativeness, comparability, and completeness.

Typical QC parameters include matrix spike (MS) and MS duplicate (MSD) samples, laboratory control sample (LCS) and LCS duplicate (LCSD) samples, surrogates, and duplicates. Table X – 8 provides the project specific QC procedures for assessing accuracy and precision. The table lists the parameter of analysis, QC parameter, QC procedure, frequency at which accuracy and precision are determined, and objective.

TABLE X-8: QUALITY CONTROL OBJECTIVES

ANALYTICAL

PARAMETERS

QC PARAMETER QC PROCEDURE FREQUENCY OBJECTIVE 1

Metals (except mercury)

Accuracy LCS 1 per batch 80‐120% recovery

Precision Field duplicate 1 per chosen sampling location 2

<25% RPD

Mercury Accuracy LCS 1 per batch 80‐120% recovery

Precision Field duplicate 1 per chosen sampling location 2

<25% RPD

Organics (explosives) Accuracy Surrogates Every sample 50‐130% recovery 3

Accuracy MS 1 per batch 50‐130% recovery 3

Precision Surrogates Calculate RSD for batch

<35% RSD of recovery

Precision MSD 1 per batch <50% RPD 3,4

Precision Field duplicate 1 per chosen sampling location 2

<20% RPD 3

RPD refers to relative percent difference. RSD refers to relative standard deviation.

The chosen sampling locations for the field duplicates are the baghouse and building floor.

Limits specified are generally applicable. Actual limits are determined by the laboratory and are compound specific.

If the concentrations are less than five times the reporting limit, the laboratory will be unable to control these limits.

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Precision

Precision is a measure of the reproducibility of results under a given set of conditions. It is expressed in terms of the distribution, or scatter, of replicate measurement results, calculated as the relative standard deviation (RSD) or, for duplicates, as relative percent difference (RPD). RPD and RSD values are calculated using the following equations:

Where X1 and X2 represent each of the duplicate results.

Blanks

Blanks will be collected for the sampling event. Blanks will be used to evaluate the effects of contamination on results and also to define background levels for target analytes.

Table X-9 provides the type and acceptance criteria for each stack gas blank to be analyzed. All of these blanks, as well as the laboratory method blanks for the waste samples, provide critical information on the potential contamination that may occur in test program samples. The results of blank analyses can prove very useful when attempting to understand anomalies in data, or generally higher than expected test results.

Detection Limits

The sampling program will rely on comparisons to background concentrations (i.e., blanks) to assess contamination. Analytical results are expected to be at or below detection limits. Therefore, it is imperative that consistent detection limits be achieved across all samples.

March 2018 – Revision 1, June 8, 2018 X-22

TABLE X-9: BLANK ANALYSIS OBJECTIVES

ANALYTICAL

PARAMETERS

BLANK TYPE FREQUENCY…