United States
Environmental Protection
Agency
Report on the Homeland
Security Workshop on
Transport and Disposal of
Wastes from Facilities
Contaminated with
Chemical or Biological Agents
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EPA/600/R-04/065
November 2003
Report on the Homeland Security
Workshop on Transport and Disposal of
Wastes From Facilities Contaminated With
Chemical or Biological Agents
by:
John Wilhemi
Eastern Research Group, Inc.
Lexington, MA 02421
Fran Kremer
U.S. Environmental Protection Agency
Office of Research and Development
National Risk Management Research Laboratory
Cincinnati, OH 45268
68-W-98-217
Project Officer
Vincent Gallardo
Land Remediation and Pollution Control Division
National Risk Management Research Laboratory
Cincinnati, Ohio 45268
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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Notice
The U.S. Environmental Protection Agency through its Office of Research and Development funded
this report under Contract Number 68-W-98-217 to Eastern Research Group, Inc. (ERG) as a general
record of discussion for the "Homeland Security Workshop on Transport and Disposal of Wastes
From Facilities Contaminated With Chemical or Biological Agents." This report captures the main
points of scheduled presentations and summarizes discussions among the workshop panelists, but
it does not contain a verbatim transcript of all issues discussed. EPA will use the information
presented during the workshop to address waste management challenges posed by materials
contaminated with chemical or biological agents. This report is not EPA guidance and should not
be viewed as such. It has been subjected to the Agency's peer and administrative review and has
been approved for publication as an EPA document.
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Foreword
The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation's
land, air, and water resources. Under a mandate of national environmental laws, the Agency strives
to formulate and implement actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life. To meet this mandate, EPA's research
program is providing data and technical support for solving environmental problems today and
building a science knowledge base necessary to manage our ecological resources wisely, understand
how pollutants affect our health, and prevent or reduce environmental risks in the future.
The National Risk Management Research Laboratory is the Agency's center for investigation of
technological and management approaches for preventing and reducing risks from pollution that
threatens human health and the environment. The focus of the Laboratory's research program is on
methods and their cost-effectiveness for prevention and control of pollution to air, land, water, and
subsurface resources; protection of water quality in public water systems; remediation of
contaminated sites, sediments and ground water; prevention and control of indoor air pollution; and
restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster
technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL's
research provides solutions to environmental problems by: developing and promoting technologies
that protect and improve the environment; advancing scientific and engineering information to
support regulatory and policy decisions; and providing the technical support and information transfer
to ensure implementation of environmental regulations and strategies at the national, state, and
community levels.
This publication has been produced as part of the Laboratory's strategic long-term research plan.
It is published and made available by EPA's Office of Research and Development to assist the user
community and to link researchers with their clients.
Hugh W. McKinnon, Director
National Risk Management Research Laboratory
in
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Acknowledgements
Appreciation is given to all those at the workshop who's participation and open discussion provided
the context for this report. The workshop was developed by Fran Kremer with support from a
number of individuals and organizations including: from U.S. EPA, David Carson, Wendy Davis-
Hoover, Paul Lemieux, Kristina Meson, Martin Powell, Frank Schaefer, and Susan Thorneloe; from
the Edgewood Chemical Biological Center Robert Eckhaus and William White; John Skinner from
the Solid Waste Association of North America; Maria Zannes from Integrated Waste Services
Association. Special thanks to Kate Schalk who coordinated the meeting logistics, and to our
reviewers, Harold Dye with the Maryland Department of the Environment, Alan Woodard, New
York State Department of Environmental Conservation, and Steve Levy, Office of Solid Waste and
Emergency Response.
IV
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Table of Contents
Summary 1
I. Classes of Chemical and Biological Agents 4
A. What do we know? 4
B. What research or information needs were identified? 7
C. What information resources are currently available on this matter? 8
II. Detection 9
A. What do we know? 9
B. What research or information needs were identified? 10
C. What information resources are currently available on this matter? 11
III. Effectiveness of Decontamination 12
A. What do we know? 12
B. What research or information needs were identified? 13
C. What information resources are currently available on this matter? 15
IV. Triaging of Waste 16
A. What do we know? 16
B. What research or information needs were identified? 18
C. What information resources are currently available on this matter? 19
V. Storing, Handling, and Transporting Wastes 20
A. What do we know? 20
B. What research or information needs were identified? 23
C. What information resources are currently available on this matter? 24
VI. Disposing of Wastes in Landfills 26
A. What do we know? 26
B. What research or information needs were identified? 28
C. What information resources are currently available on this matter? 29
VII. Incineration 30
A. What do we know? 30
B. What research or information needs were identified? 34
C. What information resources are currently available on this matter? 35
VIII. List of Participants 37
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List of Abbreviations
CDC Centers for Disease Control and Prevention
DHS Department of Health Services
DOT U.S. Department of Transportation
EPA U.S. Environmental Protection Agency
HWI hazardous waste incinerator
LRN Laboratory Response Network
MWI municipal waste incinerator
NIOSH National Institute for Occupational Safety and Health
NYSDEC New York State Department of Environmental Conservation
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Summary
This report summarizes discussions from the "Homeland Security Workshop on Transport and
Disposal of Wastes From Facilities Contaminated With Chemical or Biological Agents." The
workshop was held on May 28-30, 2003, in Cincinnati, Ohio, and its objectives were to:
• Document the current understanding of the challenges faced when handling, storing,
transporting, and disposing of wastes from public and private facilities contaminated with
chemical and biological agents.
• Identify research needs and opportunities for improving coordination between federal, state,
and local government agencies and other stakeholders in order to fill gaps in the current
understanding of these waste management challenges.
The workshop panelists included representatives from federal agencies (e.g., the Environmental
Protection Agency, the Department of Defense, the Department of Transportation, and the Centers
for Disease Control and Prevention), state agencies, local agencies, academia, and waste
management companies. During the workshop, panelists gave presentations on specific topics,
including the waste management challenges posed by the World Trade Center disaster and the
anthrax contamination of office buildings in New York City and Washington, D.C. Following each
presentation, the workshop panelists engaged in free-flowing discussions to elaborate upon the issues
presented.
This initial report summarizes discussions on the following seven topics: classes of chemical and
biological agents; detection; effectiveness of decontamination; triaging of wastes; handling, storage,
and transport of wastes; landfilling; and incineration. For each topic, this initial report outlines the
current state of knowledge, identifies associated research needs, and lists action items identified
during the discussions. The technical content of this report is based entirely on discussions at the
workshop.
Although the workshop addressed seven individual topics, some cross-cutting themes emerged
during the panelists' discussions. Examples of common themes include the following:
• Panelists noted that EPA's future work on handling wastes contaminated with chemical and
biological agents should be sensitive to the fact that specific waste management challenges
vary considerably with the type of agent (e.g., chemical versus biological) and type of waste
(e.g., wastewater, personal protective equipment, building debris). Thus, a single set of
guidelines that applies to all possible agents and waste streams might not be feasible. Several
panelists recommended that EPA consider radiological contaminants and animal diseases in
its ongoing work, whether by developing specific guidance documents on these issues or
referring stakeholders to other resources for further information.
• The absence of widely accepted standards for effectively decontaminating biological agents
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was discussed throughout the workshop. Incinerator and landfill operators, for instance, had
reservations about receiving wastes that are not certified as being uncontaminated. But, for
most biological agents, no firm research—or even a standardized analytical method—is
available to answer the question, "how clean is safe?" Until this issue is resolved, some
panelists feared that all wastes generated from buildings containing certain biological agents
(particularly the persistent ones) might have to be handled as if they were contaminated.
A number of panelists suggested that the Federal Government maintain the needed
infrastructure for transport and disposal of these wastes. This infrastructure would include
equipment to transport materials ( e.g. trucks, barges) and disposal sites/equipment (e.g.
secure landfills, incinerators) that would be in strategic locations around the country. The
disposal options/sites would be pre-determined based on an evaluation of available sites/
equipment (see below) and a vulnerabilty assessment.
Multiple panelists emphasized the need for state and local agencies to include waste
management in their emergency response plans and mock terrorist attack drills. Such efforts
may result in response workers seeking out information resources already available; these
resources and documentation prepared during mock terrorist attack drills can prove
invaluable should an actual event occur in the future. The panelists identified several ways
that EPA can assist state and local agencies with their emergency planning efforts. The
panelists said that EPA can prepare case studies, checklists, or guidance documents to inform
these agencies of specific challenges in managing wastes that contain chemical or biological
agents. Such documents should draw on the lessons learned from previous experiences
managing wastes from terrorist attacks, and should emphasize the need for effective
communications between multiple agencies. Finally, panelists suggested that EPA convene
another workshop to help prepare practical information resources for state and local agencies.
Panelists indicated that EPA can develop databases with relevant information (e.g., location,
operating data, capacity, transportation routes) on landfills and incineration facilities across
the country. Having a system linked to a mapping application would allow users to readily
identify waste management facilities that can handle wastes from emergency events.
An issue raised throughout the workshop was the need to consider public perception of risks
and other sensitivities when deciding how to manage wastes containing chemical or
biological agents. Many panelists said that EPA and other agencies will likely need to
balance scientific judgments against public acceptability of waste management decisions.
The panelists encouraged EPA to strive for pragmatic and protective solutions, which might
not necessarily be solutions that achieve zero risks. As an example of a potential sensitivity,
a panelist noted that people might be offended by using the term "waste" when referring to
debris (and possibly human remains) from sites where human life has been lost or severely
affected by an event.
Another cross-cutting theme was the need for training to ensure the safety of all workers who
might handle wastes containing chemical and biological agents. These workers include
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decontamination crews, transporters, and employees of waste management facilities.
Panelists suggested that existing courses on handling contaminated and decontaminated
wastes be identified and new courses be developed and offered, possibly by EPA with
assistance from OSHA and DOT. Panelists encouraged EPA and other agencies to consider
who should develop and offer training courses on chemical and biological agents, what
parties should fund the training, and when and how often employees should receive training.
Throughout the workshop, panelists noted that EPA and other agencies might need to
establish permit variance procedures for transporters and disposal facilities handling wastes
potentially contaminated with chemical and biological agents in emergency situations. The
procedures should include tracking, monitoring, reporting, handling and disposal
requirements, and include additional testing required for specific wastes dependent on
disposal methods.
Owners and operators of waste management facilities expressed concern throughout the
workshop about potential liability issues associated with managing wastes that possibly
contain chemical and biological agents. These panelists encouraged EPA to consider these
liability concerns in future work involving this waste management issue. The owners and
operators expressed specific concern regarding the need to protect facility assets and to
address unanticipated harm to employees and the surrounding community, damages resulting
from permit violations related to disposal of bioterrorism waste, and remuneration for
financial losses directly and indirectly associated with processing wastes containing chemical
and biological agents.
One decision-making approach that many panelists supported was to encourage state and
local agencies to first identify the available waste management options (e.g., incinerators and
landfills) and then "work backwards" to determine what types of wastes these facilities can
handle. Several panelists supported this concept of "working backwards" because arelatively
small number of waste management options are available, even though a large number of
waste streams could be generated in buildings contaminated with chemical or biological
agents.
Recognizing that many public and private sector parties have relevant experience on most
of the workshop topics, the panelists recommended that EPA continue to involve many
stakeholders when evaluating waste management challenges. Panelists suggested that
representatives from the following parties, in addition to the parties represented at the current
workshop, might offer useful insights for the ongoing work: the United States Department
of Agriculture, the National Institute for Occupational Safety and Health, the Occupational
Safety and Health Administration, the Federal Emergency Management Agency, law
enforcement agencies, analytical laboratories, and experts in risk communication and public
perception of risk.
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I. Classes of Chemical and Biological Agents
A. What do we know?
The workshop panelists discussed many types of chemical and biological agents that could be
encountered in future waste management scenarios. The following list describes how the agents were
classified into two general classes (chemical and biological), each having numerous sub-categories
of agents. The list documents relevant features of each agent, such as their availability, toxicity,
relevant chemical and physical properties, and persistence. It was noted during the discussion that
the potential use of chemical and biological agents is an emerging threat and that novel agents may
be used in the future that have not been considered in past threat assessments.
• Chemical agents. These classes of potential chemical agents were identified during the
workshop:
• Industrial chemicals. An extremely broad range of industrial toxic chemicals are
manufactured, stored, and transported throughout the United States, often in large
quantities. Examples include fuels, flammable chemicals, oxidizers, acids (e.g.,
hydrogen cyanide), bases, and pesticides. The workshop panelists did not go into
detail on waste management challenges posed by releases of industrial chemicals, but
several noted that federal regulations already require larger industrial facilities to
have detailed emergency response plans that evaluate the potential off-site
consequences of uncontrolled releases.
• Vesicants. The workshop panelists discussed two types of vesicants (blistering
agents): mustards and Lewisite. The information that was presented on these
materials follows:
The workshop panelists noted that mustard agents are relatively easy to synthesize
from readily available precursors. On the other hand, thepanelists characterized these
agents as having moderate toxicity with a relatively low likelihood of mortality
resulting from exposures, assuming that exposed individuals seek medical care. The
main challenge identified for cleanup is the persistence and limited water solubility
of these compounds. As an example of this challenge, panelists noted that
incineration efficiently destroys mustard agents, but the agents' limited solubility
complicates efforts to collect them from locations where they might be released.
Mustard agents can, however, be readily oxidized using chlorine bleach.
Lewisite is an organic arsenic compound that causes immediate pain after exposure,
rather than delayed effects. Beyond the initial reaction, the arsenic within Lewisite
might contribute to additional adverse health effects, depending upon the dose.
Lewisite was not produced extensively in the United States; far larger quantities were
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produced in Europe and the former Soviet Union. Lewisite can be produced easily
by those with access to arsenic trichloride. Lewisite is rapidly hydrolyzed, which
would greatly facilitate any cleanup efforts.
• Nerve agents. Several nerve agents were identified. The common link between these
agents is their ability to inhibit acetylcholinesterase—this inhibition can ultimately
result in serious effects, such as respiratory collapse and death. Two general types of
nerve agents were presented.
First, several "G Agents" were described. These agents include GA, GB (also known
as Sarin), GD, and GF. They share many molecular structures: all have a phosphorus-
oxygen double bond, most have a phosphorus-carbon bond, and most have a
phosphorus-fluorine bond at the heart of their structure. Some of the G Agents,
particularly GA, are relatively easy to synthesize from reagents that are widely
available.
Second, several "V Agents" were described, including Amiton and VX. The
distinguishing feature of the V Agents is their phosphorus-sulfur bond at the heart of
the chemical structure. The two types of nerve agents differ in several important
regards. The V Agents, for instance, are less likely to be encountered because they
are far more difficult to synthesize than are the G Agents. Further, the V Agents are
far less volatile than the G Agents, but both agents can be dispersed in a manner that
could present an inhalation hazard.
Regarding decontamination and waste management, workshop panelists noted that
the nerve agents are relatively persistent, except when exposed to water. Hydrolysis
destroys these agents and typically (though not always) forms byproducts that are
relatively non-toxic. These nerve agents can be efficiently destroyed in incinerators.
• Glycolates. The workshop panelists briefly discussed glycolates. These chemicals,
which are typically solids, have toxic effects opposite to those of nerve agents.
Glycolates can have transient incapacitating effects, but these chemicals are believed
to be of limited concern because they are less toxic than other agents.
Biological agents. These classes of potential biological agents were identified during the
workshop:
• Pathogenic bacteria. In general, bacteria are either grown in cultures or present in a
dormant state (e.g., spores). Vegetative bacteria die rapidly in the environment due
to dehydration and exposure to ultraviolet radiation. Dormant bacteria, on the other
hand, can persist in the environment for long periods of time, even under adverse
conditions. This distinction presents specific challenges for managing wastes that
contain spores. Bacterial pathogens of concern include: Bacillus antrhacis (anthrax),
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Yersiniapestis (plague), Francisells tularensis (tularemia), and Burkholderia mallei
(glanders).
• Viruses. Viruses are far more difficult to weaponize, because they require a host
organism or host cells to survive. Viruses identified as being of concern include
Variola major (smallpox), Venezuelan equine encephalitis virus, Ebola virus, and
many possible others.
• Toxins. There are a wide range of substances regarded as toxins. According to the
literature, at one end of the range are the bacterial toxins, which are chemicals that
are formed by bacteria. The toxins are not living organisms, but they are often
classified as biological agents because living organisms produce them. Production
of the toxins requires culturing, harvesting, purification, and formulation. Most
bacterial toxins are solids and would have to be formulated in a manner to facilitate
widespread dispersal. Examples of toxins identified during the workshop include
botulinal toxin, staphylococcal enterotoxin, abrin, and many others. Some of these
have previously been stockpiled for weapons purposes and targeted assassination
attempts. Given the limited availability of many of these toxins, however, the
likelihood that they would be used in a large attack is believed to be low.
In the middle of the range of toxins are snake poisons, insect venoms, plant alkaloids,
and other substances, such as ricin, batrachotoxin, and curare, which have been used
as weapons. At the other end of the range are small molecules such as potassium
fiuoroacetate synthesized by chemical processes or hydrogen cyanide, which occurs
in hundreds of plant and animal species. Further, a panelist noted that large scale
production processes for biologically active peptides, bioregulators (e.g., histamines),
and similar substances is an area rich in potential for weapons.
• Other biological agents. The panelists also identified other agents that may be
encountered in future events and related waste management scenarios. These
included prions (which are associated with chronic wasting diseases), agents
genetically engineered to avoid detection, and infectious agents that affect livestock
(e.g., hoof-and-mouth disease). Some of these agents maypresentunique challenges.
Prions, for instance, are highly persistent and difficult to destroy, even by
incinerators. As another example, an outbreak of hoof-and-mouth disease can lead
to an extremely large volume of animal carcasses that need to be managed. The
panelists recommended that EPA consider such agents in its ongoing homeland
security efforts.
When discussing the chemical and biological agents, panelists noted that contaminated buildings will
contain an extremely broad range of wastes. Generally speaking, such sites will contain building
materials and debris, personal protective equipment from the cleanup crew, and decontamination
wastes (e.g., wastewater). The specific waste components found at a given site depend on the type
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of building affected. However, responders should expect to handle many classes of materials
including, but not limited to, furniture (wood, metal, upholstered), carpet, floor and ceiling tiles,
wallboard and paneling, fixtures, computers and electronic equipment, paper items, and putrescible
wastes (e.g., food items).
B. What research or information needs were identified?
The workshop panelists identified several information gaps, along with associated research needs
or action items to fill them:
• Several panelists indicated that planning for waste management events is difficult without
a better sense of the threats realistically posed by specific agents. For instance, planning
activities would be greatly facilitated if planners knew which agents are most likely to be
encountered, whether a specific agent is more likely to be used in a localized manner (e.g.,
to contaminate an office) or in a widespread manner (e.g., to contaminate a city block), and
what volumes of wastes are expected to be generated. With better threat assessment
information, local and state agencies can proceed with their emergency planning accordingly.
Panelists suggested that EPA might be able to obtain information on specific threats by
coordinating with other federal agencies, such as the Department of Defense and the
Department of Homeland Security.
• Several panelists said that state agencies, local agencies, first responders, and other
stakeholders would benefit from having agent-specific fact sheets that answer many of the
general questions that arose during the discussions, such as:
How likely is it that terrorists have access to an agent?
What are the agent's relevant chemical and physical properties?
For biological agents, what is the infective dose?
What is the agent's anticipated fate and transport behavior in the environment?
How persistent is the agent?
Will the agent adhere to building materials or vaporize and disperse?
What are the preferred decontamination methods?
How will the agent behave in a landfill?
Is the agent effectively treated by incineration?
Can the agent be dispersed via different environmental pathways (e.g., carried on
clothing, survive in a water treatment system)?
Are there potential vectors or reservoirs of infection of concern?
Similarly, other panelists suggested that EPA, with assistance from CDC, develop guidance
that lists all agents and decontamination procedures available, to the best of their knowledge.
The guidance may take the form of a matrix, and would be added to as information becomes
available. A computer-based document maybe preferable, with guarded access if necessary.
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• A specific research opportunity discussed during this session was using surrogate agents to
study the fate and transport of selected chemical and biological agents. For instance, the fate
and transport of anthrax spores in landfills can be studied using simulations involving other
Bacillus species bacteria. Section VLB revisits this issue.
• Several panelists asked EPA if its evaluation should be broadened to include waste
management issues for radiological contaminants, such as those that might be released from
a "dirty bomb" incident. EPA representatives responded that the Agency is discussing this
matter internally and the scope of its effort might indeed be broadened to include radiological
contaminants.
C. What information resources are currently available on this matter?
The workshop panelists identified several sources of information about the available chemical and
biological agents:
• Many industrial facilities have already prepared detailed emergency plans and consequence
scenarios that address large-scale releases of industrial chemicals. These plans should be
available from state and federal offices responsible for managing reports submitted under the
Emergency Planning and Community Right-to-Know Act.
• Profiles of selected biological and chemical agents are available from different sources. For
instance, the Centers for Disease Control and Prevention (CDC) maintains a "Public Health
Emergency Preparedness and Response" Web site (http://www.bt.cdc.gov) that has detailed
information on selected chemical and biological agents. Further, speakers at the workshop
showed examples of tables copied from publications that document relevant information
(e.g., infective dose, persistence of organism, incubation period) on numerous biological or
anti-microbial agents.
• A panelist noted that various parties have developed "response awareness courses" that
might be a valuable resource on the types of events that may occur in the future. Specific
references to preferred courses were not provided.
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II. Detection
A. What do we know?
The workshop panelists discussed many technical and logistical challenges associated with
identifying chemical and biological agents in environmental samples. This discussion focused largely
on analyzing samples for biological agents, due to the additional information needed from laboratory
analysis. Specifically, for chemical agents, laboratory analyses need only detect the presence and
amounts of the agent of concern; for biological agents, on the other hand, the analyses not only need
to detect the agent, but must assess whether the agent is still living, viable, or active and whether it
poses a risk to public health.
The panelists identified many problems emergency responders might encounter when trying to detect
the presence and viability of biological agents. For instance, environmental samples suspected of
containing biological agents cannot be handled or shipped as one would handle most types of
environmental samples. Further, relatively few laboratories have the licensing, equipment, and
capability not only to analyze samples for biological agents but also to decontaminate or destroy the
samples after they have been analyzed. Due to the high costs associated with gaining this expertise,
many laboratories likely maynot be capable of conducting these analyses in the future. Additionally,
in times of heightened concern regarding bio-terrorism, the few licensed laboratories in a given area
are often inundated with requests to analyze samples. Given this situation, the panelists highly
recommended that state and local agencies, as part of their emergency planning, identify in advance
analytical laboratories that can analyze samples that may contain biological agents.
As well as voicing concerns about simply identifying candidate laboratories, the panelists said that
analytical results are often difficult to interpret. With no standard analytical methods for many
biological agents, laboratories have been using various and different methods to detect them, which
can lead to widely variable sampling results. Specific challenges identified include how to interpret
analytical results in the absence of quantitative information on infective doses or detection limits,
how to interpret analytical results that indicate the presence, but not the viability, of a biological
agent, and how to interpret surface concentrations without knowing the associated exposure doses.
Since some biological agents (e.g.,Bacillus antrhacis, Francisella tularensis) canbe naturally found
in environmental samples in the absence of bio-terrorism attacks, the issue of "background" levels
of contamination may be important for certain agents. The limitations of environmental sampling
notwithstanding, the panelists noted that sampling for anthrax proved to be a valuable contribution
to the decontamination efforts and epidemiological investigations, primarily because anthrax spores
are so persistent in the environment.
When discussing detection of biological agents, the panelists briefly reviewed the Laboratory
Response Network (LRN). CDC established this network to help laboratories use consistent and
reliable methodologies when analyzing certain types of samples for biological agents. Though the
LRN program has indeed helped to ensure that analytical results are of high quality and reproducible
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across multiple laboratories, the program has limitations. For instance, relatively few laboratories
are LRN-certified and only a subset of these can analyze samples for certain biological agents.
Further, the LRN-certified laboratories are primarily accustomed to analyzing clinical samples—they
are still developing procedures for analyzing environmental samples or samples of building
materials. Finally, few, if any, of the LRN registered laboratories can analyze environmental samples
for all classes of microorganisms (viruses, bacteria, and protozoa). This means that only a few
laboratories have the necessary licensing and infrastructure (e.g., the ability to destroy samples) to
analyze environmental samples for biological agents.
Another limiting factor identified was additional regulatory requirements under the recently
promulgated "Select Agent Program." This program was established by the Public Health Security
and Bioterrorism Preparedness and Response Act of 2002. The Select Agent Program further
regulates the possession, use, and transfer of selected organisms, which again limits the number of
laboratories with the necessary registration and capacity for analyzing samples for certain biological
agents. Further complicating matters is the possibility—or probability—that samples requiring
analysis for biological agents will be of a forensic nature, meaning that the analytical laboratory
might have to coordinate efforts with appropriate law enforcement or intelligence agencies.
B. What research or information needs were identified?
The workshop panelists identified several information gaps, along with research needs or action
items to fill them:
• State agencies, local agencies, and other parties responsible for emergency response and
waste management need information on the challenges posed by analyzing samples for
biological agents, such as identifying licensed analytical laboratories, shipping samples safely
and in accordance with Department of Transportation (DOT) regulations, knowing how to
interpret positive and negative detection results, being prepared to communicate analytical
results to the public, and realizing that it can take days before reliable and definitive
analytical results are obtained for some samples. By identifying these challenges and
presenting possible solutions, EPA can help all stakeholders be better prepared to analyze
environmental samples during emergency situations. The Federal Government should
consider the development of an environmental response laboratory network to manage
environmental samples. Laboratories are in place for clinical analysis for emergency
circumstances for these agents but analagous laboratories do not exist to manage
environmental samples.
• Workshop panelists said that there is no or limited information available on analytical
methods for some biological agents, especially for analyzing environmental samples.
Research can help develop methods for analyzing environmental samples and samples of
building materials for biological agents. Where possible, analytical methods should be able
to detect biological agents down to the level of the infective dose. Additionally, procedures
shouldbe developed to specifyhowto analyze samples containing multiple classes of agents
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(e.g., chemical, biological, and radiological agents), given that few laboratories can handle
such mixtures. Such procedures could address, for instance, how to process environmental
samples that contain human tissues, which might contain blood-borne pathogens.
• Some panelists expressed concern that re-engineering of biological agents might eventually
render them undetectable by current laboratory analytical methods. They suggested that
research on the analytical methods should consider nuances associated with detecting
weaponized forms of biological agents.
C. What information resources are currently available on this matter?
The panelists identified several sources of information on detecting chemical and biological agents.
The resources identified during the workshop are discussed below. (This should not be viewed as
a comprehensive account of all available resources.)
• Multiple federal agencies have jointly developed the Bio Watch program, which is conducting
air filter sampling in several cities to detect bio-terrorism attacks before morbidity or
mortality is observed. Information on the sampling and analytical methodologies used should
be available from EPA and CDC—two of the agencies sponsoring this network.
• The National Institute for Occupational Safety and Health (NIOSH) has published health
hazard evaluations for the anthrax investigations at selected postal facilities. These reports
include information on comparability of anthrax sampling and analytical methods.
• One panelist noted that CDC's Web page for the Select Agent Program lists links to
information resources on many related topics (e.g., transportation concerns, occupational
safety and health issues). These links are found at: http://www.cdc.gov/od/sap/addres.htm.
• The LRN should make information available on preferred sampling and analytical methods
for certain biological agents, as well as lists of the laboratories that are currently certified to
analyze samples potentially contaminated with such agents.
• The panelists noted that sampling and analytical methods for chemical agents should be
available from Department of Defense installations engaged in related demilitarization
activities. They did not cite specific publications that document these methods.
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III. Effectiveness of Decontamination
A. What do we know?
The workshop panelists discussed available decontamination technologies for various chemical and
biological agents. The discussion addressed specific experiences of decontaminating wastes from
the anthrax incidents of 2001 and ongoing research on the effectiveness of existing and emerging
decontamination methods.
Many different decontamination methods were identified during this session, including measures to
separate or inactivate chemical and biological agents. These included using disinfectants, filtration,
vacuuming, heat inactivation, incineration, ultraviolet radiation, and ionizing radiation. The approach
used for a given scenario depends on the specific needs for the application. Specific types of
disinfectants and fumigants include bleach, peroxides, ozone, and ethylene oxide. The panelists
identified the strengths and limitations of the different methods. For instance, they agreed that
ethylene oxide sterilization can decontaminate various materials effectively, but that using ethylene
oxide to decontaminate buildings is impractical due to other hazards that ethylene oxide poses (e.g.,
toxicity, risk of explosions). Giving another example, a panelist noted that enzymatic
decontamination has shown promise for destroying "G Agents," but further research is needed to
demonstrate the overall utility of this technology. Though many decontamination technologies were
reviewed, several panelists noted that bleach-based products continue to be the most widely available
decontamination technology and have proven generally effective against both chemical and
biological agents, given sufficient contact time.
The panelists identified many factors that responders to chemical or biological attacks must consider
when selecting appropriate decontamination methodologies. These factors include, but are not
limited to, the following:
• What is the chemical or biological agent of concern? The type of agent present is a critical
consideration when one selects decontamination methods, for several reasons. Although
researchers are striving to have decontamination technologies apply to broad ranges of
agents, some technologies (e.g., enzymatic decontamination) have demonstrated
effectiveness for only certain specific agents. Further, operational details for a given
decontamination technology, such as minimum contact times needed, may also depend on
the agent present.
• What types of materials are contaminated? The optimal decontamination technology for
a given application generally depends on the material that is potentially contaminated. For
instance, the optimal technology for decontaminating wastewater may differ from the optimal
technology for decontaminating building materials. Further, the porosity of the contaminated
materials affects decontamination decisions, because more porous materials (e.g., ceiling
tiles) are much harder to decontaminate effectively than less porous materials (e.g., concrete).
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The intended end use of contaminated material is yet another consideration: if the object to
be decontaminated must be preserved for future use, some decontamination methodologies
might be preferred over others.
• How wide an area is contaminated? The appropriate decontamination strategy also
depends on the size of the contaminated area. If a chemical or biological agent exists only
in a small area (e.g., within one room), then spot decontamination methods may be
appropriate; however, spot decontamination is not feasible for contamination over broad
areas. The extent of the contaminated area also may affect the decision on whether to conduct
decontamination activities on site or at a remote location.
• Does the decontamination method create additional wastes? Most decontamination
technologies leave residues that must either be cleaned or naturally dissipate, typically by off-
gassing. The wastes formed by different decontamination technologies could be a limiting
factor in some cases. For instance, though some decontamination foams have shown promise
in terms of effectiveness of decontamination, they leave residues that have to be rinsed and
the resulting wastewater must be collected and handled accordingly.
In addition to these general concerns, participants discussed many specific issues that arose in the
decontamination of office buildings and postal facilities where anthrax was found. For instance,
decontamination efforts at some sites were complicated by the fact that employees caused cross-
contamination by moving items within and removing items from contaminated areas before first
responders arrived. Further, cleanup officials at some sites had difficulties finding waste
management companies willing to dispose of decontaminated materials—aperception issue that was
revisited multiple times at the workshop (see Sections VI and VII).
B. What research or information needs were identified?
When discussing decontamination methods, workshop panelists identified several information gaps,
along with research needs or action items to fill them:
• A central issue to the debate on the effectiveness of decontamination is deciding "how clean
is safe?" Answers to this question will determine how effectively buildings must be
decontaminated before they can be used again and how effectively building contents must
be decontaminated before they can be handled as non-infectious waste. The workshop
panelists noted that the Department of Defense should already have information on the
effectiveness of decontamination for chemical agents, but indicated that the issue is largely
unresolved for biological agents in environmental or residential settings. Some panelists
believed that enough clinical and toxicological data might be available to support
establishing cleanup levels for some biological agents; other panelists said that further
research on related matters (e.g., detection methods, infective levels for surface
contamination, number of samples needed to characterize contamination in a building) must
be resolved before scientists can develop defensible decontamination criteria for many
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biological agents. Panelists emphasized that reliable decontamination criteria must be
developed such that site managers can assure the public and waste management companies
that a building or its contents have been decontaminated effectively. Without such criteria,
concern over potential exposures to biological agents might lead to requests for enormous
volumes of building materials to be managed as waste.
The workshop panelists again said that state agencies, local agencies, and other parties
responsible for emergency response and waste management need information on the
challenges posed by decontamination. They suggested that EPA or other agencies prepare
informational materials on the pros and cons of selected decontamination methodologies for
specific scenarios. These materials could, for instance, specify the composition of
disinfectant and minimum contact time required to achieve adequate deactivation for
different agents and materials. Panelists also indicated that informational materials should
document how long specific biological agents remain viable in the environment. Parties
responsible for decontamination would benefit from knowing the different types of wastes
that they might encounter; these waste streams might include building materials, personal
protective equipment, office materials, construction and demolition debris, furniture, human
cadavers, and animal carcasses.
Several panelists suggested that EPA consider publishing case studies to guide first
responders and other stakeholders on the technical issues associated with decontamination
and the broader waste management issues associated with materials containing chemical and
biological agents. One suggestion was to prepare a case study that addresses the most
difficult decontamination challenges, such as how to decontaminate buildings containing
highly persistent biological agents (e.g., anthrax spores). The case study could address all
issues relevant to decontamination, including setting up staging areas, identifying best
practices to avoid cross-contamination, listing materials that would likely need to be
decontaminated, and identifying residues (e.g., wastewater) that might be generated and how
these residues should be handled. Panelists suggested basing a case study on anthrax, because
the methods used to decontaminate anthrax spores are believed to work effectively for other
biological agents.
Further research and literature reviews should be conducted to document general
specifications for effective decontamination and evaluate how effectiveness varies with
disinfectant concentration, contact time, temperature, residence time in autoclaves, the effect
of a mixture of agents, and other parameters. Several specific research needs were identified,
such as examining how decontamination effectiveness varies with the porosity of the
contaminated material, further evaluating enzymatic decontamination methods (particularly
for G agents), assessing whether ionizing radiation can effectively decontaminate large items
(e.g., couches) that are difficult to handle otherwise, and examining whether engineered or
weaponized biological agents are more difficult to decontaminate than the agents in their
natural forms.
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C. What information resources are currently available on this matter?
The panelists identified several sources of information on the effectiveness of decontamination
methods. The resources identified during the workshop are discussed below. (This should not be
viewed as a comprehensive account of all available resources.)
• Multiple panelists noted that the Department of Defense has already researched laboratory
analytical methods and effectiveness of decontamination for multiple chemical agents. More
detailed information on this topic should be available from installations engaged in related
demilitarization activities.
• CDC has compiled information on agent-specific decontamination methodologies on its bio-
terrorism Web site: www.bt.cdc.gov.
• One panelist referred to publications by the State and Territorial Association on Alternative
Treatment Technologies for further information on effectiveness of decontamination, with
the most relevant publication being "Technical Assistance Manual: State Regulatory
Oversight of Medical Waste Treatment Technologies" (EPRI Report TR-112222, 1998).
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IV. Triaging Waste
A. What do we know?
The workshop panelists raised several issues related to triaging wastes at sites contaminated with
chemical or biological agents. Triaging, for purposes of this workshop, was defined as the initial
characterization and management of wastes that occurs at the site where wastes are generated and
the associated decision process for managing the handling, storage, transport and disposal of wastes.
The discussion was based largely on lessons learned from triaging wastes generated during the World
Trade Center disaster and at buildings that received mail contaminated with anthrax spores. Though
these events had considerably different waste management challenges in terms of the nature and
volume of wastes generated, the parties who managed these sites identified many common
experiences that can be applied to other sites with wastes containing chemical or biological agents.
The panelists listed numerous activities associated with triaging wastes on site. Such activities
include establishing site security, restricting site access, constructing staging areas to avoid cross-
contamination, implementing health and safety measures for first responders, characterizing and
defining waste streams, deciding whether wastes need to be decontaminated on site, properly
packaging wastes, and storing wastes safely before shipping them off site. Though the panelists
recognized that the type of triaging activities needed for a given site ultimately depends on site-
specific conditions, they identified some general categories of wastes that may need to be considered
for triaging activities. One such class of wastes is items and materials that will be disposed of or
destroyed after being decontaminated, such as spentpersonal protective equipment, wastewater from
decontamination, and debris (e.g., carpet, furniture, ceiling tiles). Another is wastes that may include
items (e.g., personal property, human remains) that might need to be returned to family members,
provided the materials can be properly decontaminated. Yet another is wastes that will likely include
materials of a forensic nature, which law enforcement officials might need to examine before the
materials leave the site. Finally, the appropriate timing and options to store, dispose, transport and
dispose of wastes depends upon the identifying the risk associated with each available scenario.
Several panelists said that triaging wastes can be complicated by the fact that some wastes from
buildings contaminated with chemical and biological agents can be difficult to classify according to
existing waste management and transportation regulations. As an example, panelists noted that no
explicit guidance describes precisely how much decontamination is needed to have a waste that once
was classified as hazardous or infectious become municipal waste or construction and demolition
debris. Panelists noted that response workers to the buildings contaminated with anthrax spores
needed to refer directly to regulatory agencies to determine whether decontaminated building
materials should be classified as municipal waste, medical waste, or perhaps "special waste" (a term
used in some states' waste management regulations). These distinctions can be critical: the waste
classification generally dictates the available waste management and transportation options, which,
in turn, can affect how wastes are triaged. Some panelists suggested that regulatory agencies should
be prepared to classify wastes from buildings contaminated with biological agents, possibly by
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issuing variances, exemptions, or special permits.1
The panelists who triaged wastes from the World Trade Center disaster and the buildings
contaminated with anthrax spores identified several factors that affected how they triaged wastes.
These include current regulations for storing and transporting wastes, existing infrastructure for
handling wastes on site, the available waste disposal and treatment options, and external pressure
to complete site cleanup activities expeditiously to help affected areas quickly return to "normalcy."
Suspecting that the same factors will likely weigh heavily in most future waste management
challenges, the panelists emphasized the importance of local agencies and emergency responders
being prepared to address the waste triaging challenges. The following general themes emerged from
these discussions:
• The need to coordinate efforts among all parties. The panelists who worked on the World
Trade Center disaster and the buildings contaminated with anthrax spores strongly believed
that continual, effective communication between all stakeholders is a critical element to
handling wastes containing chemical or biological agents. The stakeholders identified during
this discussion include local emergency responders, local government officials, waste
management companies, state environmental agencies, and federal agencies with expertise
on specific technical issues. Federal agencies mentioned during this discussion included
CDC, EPA, DOT, the Department of Defense, and the Department of Agriculture. Further,
involving law enforcement entities may be helpful as they will likely need some of the
debris associated with future attacks.
• The need to plan thoroughly and in advance of events. Panelists emphasized that
thorough advanced planning for emergency events can greatly mitigate the challenges posed
by managing wastes containing chemical or biological agents. Specific matters that local and
state agencies should research and resolve before complex waste management issues arise
include making lists of contacts for key stakeholders; identifying all waste management
companies in a jurisdiction that are approved, capable, and willing to receive wastes that
might contain chemical or biological agents; becoming familiar with applicable state and
federal regulations for classifying, storing, transporting, and disposing of these wastes;
working with local emergency responders to identify and set up needed perimeter security
to control public exposure and ensure environmental health and safety; developing plans for
dust suppression controls to contain and manage contamination; ensuring that adequate
personal protective equipment is readily available to first responders; and identifying public
and private contractors that have the equipment and capability to help triage and transport
wastes. Several panelists strongly recommended that local and state agencies incorporate
waste triaging and management into their emergency response drills and mock events. Some
The terminology used in this paragraph is meant to illustrate the general concern panelists expressed about
the ambiguities of existing regulations and the fact that wastes from bioterrorism events do not fall neatly into the
waste classifications. The paragraph is not meant to be a technical review of all existing EPA and DOT regulations
for waste management and transportation, respectively.
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panelists indicated that EPA can assist with these planning efforts in various ways. For
instance, a panelist suggested that EPA consider developing a database that documents
relevant information (e.g., location, operating data, capacity, transportation routes) on waste
management facilities that agencies can access as needed. Interfacing such a database with
an electronic mapping application would facilitate rapid identification of waste management
facilities near sites of emergency events.
• Basing waste triaging plans on available waste management options. Recognizing that
relatively few options are available for managing wastes from buildings contaminated with
chemical and biological agents (e.g., disposal, incineration, selected alternative treatment
technologies), several panelists suggested that the specific waste management options should
dictate the triaging strategies. For instance, if decontaminated building debris from a site is
to be incinerated, the dimensions of the incinerator inlet should determine how wastes need
to be sorted and sized on site. For this reason, several panelists recommended that parties
responsible for managing wastes first identify the available waste management options, then
work backwards to develop triage plans accordingly.
B. What research or information needs were identified?
When discussing triaging wastes, workshop panelists identified several information gaps, along with
the research needs or action items to fill them:
• Few information resources have been developed to address the unique challenges posed by
managing wastes containing chemical and bio logical agents; thus, EPA can assist responders
to future events by developing general guidance documents on how to triage wastes
effectively. Panelists suggested that these documents answer specific questions that have
already been asked at the World Trade Center and anthrax sites, such as:
When is it preferable to store wastes temporarily on site?
How should wastes be packaged?
What chain of custody must be followed if law enforcement parties are involved?
What regulations affect storage and transportation of wastes for different scenarios
(e.g., storage incidental to transportation versus storage for other purposes)?
How are certain types of wastes classified under these regulations?
Are there any minimum specifications for constructing staging areas?
What waste management options are preferred for specific agents?
Can personal property and human remains be returned to families?
Guidance to stakeholders could also identify best practices for several general issues, such
as handling wastes with a mixture of agents, coordinating with other stakeholders, and
effective planning. Also, guidance is needed at the federal level to assess what materials
should be used for forensic evidence and what can be returned to families. Such guidance
should list references to other information resources on topics (e.g., forensics, transportation,
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health and safety) that other federal agencies typically address.
• Panelists said that local agencies and emergency responders can obtain practical information
on how to triage building wastes by reviewing specific case studies or by incorporating waste
management into their emergency response drills. The panelists noted that EPA can help by
developing case studies and by encouraging stakeholders to involve environmental officials
in future drills. Case studies should clearly establish agency roles in emergency operations
for different agents of concern. EPA can also assist by developing a database that documents
important information (e.g., capacity, location, transportation routes) on the universe of
facilities that could potentially manage wastes from sites attacked with chemical or biological
agents.
• The panelists suggested specific topics that EPA can investigate for additional insights into
effective waste triaging strategies. One panelist, for instance, recommended that EPA consult
with Japanese officials to learn how they triaged wastes in cleaning the Tokyo subway station
where Sarin was released.
C. What information resources are currently available on this matter?
The panelists identified several sources of information on triaging wastes that might contain
chemical or biological agents. The resources identified during the workshop are discussed below.
(This should not be viewed as a comprehensive account of all available resources.)
• The Federal Emergency Management Agency Publication 325 ("Debris Management
Guide") provides guidance on how to triage large volumes of wastes, primarily from natural
disasters. The document is available online at www.fema.gov/rrr/pa/dmgtoc.shtm.
• The United States Army Corps of Engineers has developed guidance on removing debris
containing chemical, biological, or radiological agents.
• A panelist noted that the Department of Energy has a Web site dedicated to waste
management (www.em.doe.gov/em30/). The Web site focuses on managing radioactive
wastes, but the concepts presented on the site could pertain to waste management challenges
for building decontamination debris.
• In developing a triage, it is critical to incorporate the need for the timing for recovery and
occupancy of residences and businesses. This is important in restoring normalcy to the
impacted area and assisting in it's economic recovery.
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V. Storing, Handling, and Transporting Wastes
A. What do we know?
The workshop panelists discussed numerous topics related to storing, handling, and transporting
wastes from buildings contaminated with chemical and biological agents. Experiences with these
issues were based largely on the waste management challenges faced at buildings that were
contaminated with anthrax spores in 2001. The discussions for this topic area focused primarily on
six specific issues:
• Temporary on-site storage of wastes. The workshop panelists identified several factors that
will determine whether wastes should be stored temporarily at sites contaminated with
chemical or biological agents. Generally speaking, prolonged on-site waste storage increases
the likelihood that building occupants, trespassers, or others might inadvertently or
intentionally release chemical or biological agents. Similarly, prolonged storage of vector-
borne agents (e.g., plague) would raise concerns about rodents, dogs, or other animals
spreading agents from wastes to local communities. Given these concerns, the panelists
emphasized the need to have all wastes properly containerized (see the next bulleted item),
stored in secure locations, and promptly sent to waste management facilities when possible.
Several panelists noted that the need for on-site waste storage will likely depend on site-
specific conditions. For example, when the American Media Inc. office building in Florida
was contaminated with anthrax spores, on-site waste storage was a sensible option because
the entire building was shut down. For the media sites in New York City, on the other hand,
on-site waste storage was not preferred because the affected skyscrapers remained open for
business. Another consideration is the capacity of the disposal or incineration facilities that
will receive the waste streams: on-site waste storage might be necessary when these facilities
have limited capacity to handle waste streams containing chemical and biological agents.
Given that most contaminated building scenarios will require some on-site waste storage, the
panelists identified additional factors for site coordinators to consider. For instance,
constructing staging areas or exclusion zones may be necessary to prevent cross-
contamination of biological agents. Representatives from EPA's Environmental Response
Team indicated that they already have procedures and emergency response kits that help with
these construction tasks. Other panelists noted that some states might require permits for on-
site storage areas.
• Containerization. The workshop panelists discussed the containers that should be used for
handling wastes from building contamination sites. The panelists generally agreed that
Containerization must occur on site, in order to prevent cross-contamination and to protect
the workers who later handle wastes. Federal and state transportation regulations would
likely dictate the finer details of waste Containerization. For example, DOT regulations
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specifically address packaging issues (e.g., selecting appropriate containers, labeling,
placarding) for shipments of hazardous materials (see 49 CFR 173,178-180), but the extent
to which these regulations apply depend on the type of waste being managed. DOT has
guidance on packaging and transport for chemical/biological wastes. These are a
modification of procedures for medical wastes. Infectious agents, including regulated
medical waste, typically require triple packaging that can withstand a 30-foot drop or being
impaled by a steel rod. An issue that is not resolved, however, is exactly how waste providers
should determine whether decontaminated items are infectious—an important consideration
because items that are not classified as infectious can be shipped as municipal solid waste
or construction and demolition debris (unless state regulations dictate otherwise). The
panelists reiterated that further research is needed on the effectiveness of decontamination,
b ecause the current regulatory framework does not provide obj ective criteria for determining
when wastes contain infectious agents.
The panelists identified many different types of containers that are used to ship packaged
wastes. These include open containers (e.g., dump trucks covered with tarps) and closed
containers (e.g., trailers). Although non-hazardous wastes that are no longer infectious could
technically be shipped in open containers, at least according to federal transportation
regulations, panelists noted that most states would likely require wastes from sites containing
biological agents—including decontaminated wastes—to be packaged and shipped in closed
containers. This should be planned in advance and coordinated among DOT, CDC, and DHS.
One panelist noted that use of "macro-encapsulation" containers might be a viable option
for some sites. These containers, made from high-density polyethylene plastic, are sealed
after being loaded with wastes. The entire containers are then disposed of in landfills; there
is no need to open them or handle their contents.
Handling. The workshop panelists generally agreed waste handling should be minimal in
order to prevent chemical and biological agents in wastes from entering the environment. To
minimize handling and avoid cross-contamination, all size reduction and packaging of wastes
should occur at the site where waste is generated, so that haulers and employees of waste
management companies do not become exposed to the agents. Further, appropriate
technologies for moving wastes at landfills or incinerators depend on the nature of the waste
being shipped. Landfill operators, for instance, generally should not use handling techniques
(e.g., tipping, using steam shovels) that can breach containers of infectious waste. It was also
noted that procedures need to be in place for respectful management of contaminated
cadavers to minimize worker and public exposure.
Transportation modes. The panelists said that wastes from most building contamination
sites will likely be shipped via truck, rail, or barge. The most appropriate and efficient
transportation mode will vary from one location to the next—it will depend on the proximity
of the waste site and eventual waste management location to railroads and barge stations,
existing infrastructure, equipment availability on short notice, public acceptance, and overall
project costs. Because the safety and security of shipping wastes containing chemical or
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biological agents may be an overriding concern, the need for escorts and dealing with the
potential for spills must also be considered. It was noted that in general, though, there is
inadequate transportation infrastructure for major events.
The panelists suspected that shipping containerized waste in enclosed trucks will probably
be the most efficient transportation mode for most locations, though exceptions clearly occur.
For instance, barge transport was a logical and economical choice for shipping wastes
generated during the World Trade Center disaster, because New York City already had the
necessary infrastructure to support this transportation mode and a permitted landfill with
capacity and barge access. In this case, hauling wastes in trucks was not desirable given that
trucks would have to travel through densely populated and highly congested areas. State and
local agencies ultimately should be able to determine the most appropriate transportation
modes within their jurisdictions based on the available waste management sites and the
existing road, rail, and barge infrastructure. Cost-benefit analyses can help determine whether
investing in certain transportation modes (e.g., constructing transfer stations) is worthwhile.
Transportation regulations and requirements. Noting that existing regulations will largely
dictate how on-site coordinators transport wastes, workshop panelists emphasized the need
to become familiar with DOT regulations and those of state transportation authorities. As
noted previously, the applicability of DOT's hazardous materials regulations depends
primarily on how the on-site coordinator characterizes wastes. However, experiences from
transporting debris from the anthrax-contaminated buildings indicate that, for specific
responses to bioterrorism events, states sometimes implemented more stringent shipping
requirements than DOT does. (Some questions remained about whether states truly had the
authority to do so.) Generally speaking, specific requirements that might apply for a given
scenario include driver training, registration, tracking, identifying transportation routes,
decontaminating containers, the need for police escorts, and limiting waste shipments to
vehicles dedicated entirely to transporting regulated medical waste or hazardous waste.
Panelists who worked on these sites strongly recommended that on-site coordinators work
directly with DOT and state officials to learn exactly what regulations apply, and whether
exemptions for emergency situations can be issued. DOT can issue letters of interpretation
or guidance documents to address specific challenges that future waste management
scenarios raise. Throughout this discussion, several workshop panelists emphasized the need
to track wastes containing chemical and biological agents from the origin, through storage,
to the ultimate waste disposal or incineration facility. To emphasize concerns about tracking,
one panelist noted that failure to account for where wastes containing chemical or biological
agents presents an opportunity for terrorists to retrieve these agents and use them for future
attacks.
Worker and public safety. Panelists noted that transporting wastes containing chemical and
biological agents poses health risks not only to transporters, but also to residents who live
along transportation routes. A DOT representative indicated that DOT's worker training
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requirements (49 CFR 172, Subpart H) are limited to topics such as security, safety, and
general awareness of hazards; some transporters might also be required to have written safety
and security plans. Other panelists noted that EPA and OSHA might have additional training
requirements for waste transporters, but these requirements were not discussed further.
During this discussion, some panelists asked under what circumstances, if any, should
transporters be immunized against agents, receive prophylactic therapy, or enter medical
monitoring programs. Panelists were unaware of any specific requirements that address these
issues and suggested that employers in such cases consult with clinicians for further insights.
B. What research or information needs were identified?
Workshop panelists identified several information gaps regarding handling, storing, and transporting
wastes, along with research needs or action items for filling these gaps:
• On-site coordinators for buildings contaminated with chemical and bio logical agents would
benefit greatly from having clear guidance or other information materials on waste storage,
handling, and transportation. Examples of resources that can be developed include concise
summaries of DOT regulations, review of US DA regulations (for "foreign waste" categories)
checklists for on-site coordinators, case studies for selected building contamination
scenarios, and training or outreach materials for transporters. Another suggestion was to
standardize sizing and packaging of wastes to minimize handling, meet DOT regulations, and
accommodate disposal sites. A panelist suggested that a matrix be developed to determine
"what wastes fit where" and how such waste must be sized and packaged for acceptance at
a given facility; such a matrix should recognize the possibility of using unconventional
packaging types (e.g., a mobile material packaging unit might be most appropriate for some
waste management scenarios). Vulnerability analysis should be conducted on the
transportation options.
• As in other areas discussed, multiple panelists strongly encouraged that future guidance
documents urge state and local agencies to plan in advance for how they will handle the
technical challenges of storing, handling, and transporting wastes that might contain
chemical or biological agents. Agencies can accomplish this by incorporating waste storage,
handling, and transportation directly into future emergency response drills andmock terrorist
attacks, such that first responders and on-site coordinators can determine whether they are
prepared to handle these wastes. Additionally, state and local agencies can plan in advance
by identifying preferred transportation modes, locating waste management facilities that are
willing to accept wastes, and listing points of contact at state and federal transportation,
environmental, and health agencies. Panelists noted that EPA can assist in these efforts
possibly by developing an electronic database with information (e.g., location, capacity,
transportation routes) on waste management facilities across the country. Some panelists
suggested that parties responsible for emergency planning identify, in advance, any
equipment (e.g., waste containers) that might be needed to respond to future events.
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• Several panelists reiterated that waste storage and transportation challenges would benefit
from further research on decontamination effectiveness for biological agents. Specifically,
panelists said that waste generators need objective criteria to determine whether or not a
waste should be considered infectious—a distinction that strongly influences the applicable
DOT regulations. On another note, one panelist recommended that EPA or other agencies
consider researching how effectively staging areas or exclusion zones truly contain biological
agents, given past experiences that found such areas to be not entirely effective.
• The panelists raised additional issues for EPA and other agencies to consider, such as
whether generators, transporters, and waste management companies will be liable for
inadvertent releases of chemical and biological agents; the extent to which environmental
monitoring is necessary at transfer stations and staging areas; and whether government
agencies should consider investing in infrastructure for waste transportation. Another action
item raised was how to handle large volumes of body parts and human cadavers that are
potentially contaminated with biological agents. Several panelists were concerned about this
issue given that body parts and human cadavers, even if they contain infectious agents, are
not considered regulatory medical waste or hazardous waste in most jurisdictions. These
panelists suggested that an inter-agency effort, perhaps including DOT, the Department of
Homeland Security, and the Department of Health and Human Services, is needed to address
this issue.
• A number of panelists indicated that the Federal Government may need to provide the needed
infrastructure for containing and transporting wastes to effectively manage major events.
This would include an evaluation of the needed capacity and locational requirements.
C. What information resources are currently available on this matter?
The panelists identified several sources of information on handling, storing, and transporting wastes
from buildings contaminated with chemical or biological agents. The resources identified during the
workshop are discussed. (This should not be viewed as a comprehensive account of all available
resources.)
• DOT has many information resources on transporting wastes. The information ranges from
the original hazardous material transport regulations (primarily in 49 CFR 171-180) to
statistics on accidental releases from different types of containers and transportation modes.
Further information can be obtained on these issues by visiting the DOT Web site on
hazardous material transportation (http://hazmat.dot.gov), by contacting the agency's hotline
(800-467-4922 or 202-366-4488), or by submitting questions via electronic mail
(infocntr@rspa.dot.gov). A specific DOT guidance document of interest is "Guidelines for
Transporting Anthrax and Anthrax-Contaminated Objects and Materials." This is available
online at: http://hazmat.dot.gov/guide_anthrax.htm.
• The New York State Department of Environmental Conservation (NYSDEC) developed a
guidance document to help generators and transporters understand the regulatory framework
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for storing, handling, and transporting wastes from biohazard incidents. The document
("New York State Department of Environmental Conservation Program Policy for the
Handling, Storage, Transport, Treatment and Disposal of Waste Generated from a Biohazard
Incident") is not yet available on the agency's Web site, but a draft copy of the document has
been forwarded to EPA. Such draft document has been modified in format and scope since
the May 2003 meeting in Cincinnati and will likely undergo additional changes before it is
finalized for distribution.
Several panelists indicated that the Department of Defense likely has prepared internal
guidance on storage, handling, and transportation of wastes containing chemical agents for
the installations engaged in demilitarization activities.
Virginia has regulations in place on use of barges and ships and has identified standards for
containers.
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VI. Disposing of Wastes in Landfills
A. What do we know?
Discussions on landfills began with a brief review of the different types of disposal sites. Workshop
panelists suspected that wastes from contaminated buildings, if accepted by landfills, would likely
end up in either construction and demolition landfills, municipal solid waste landfills, or hazardous
waste landfills. Each type of landfill has different regulatory requirements, which largely dictate
whether the landfills have liners, leachate collection systems, daily covers, mandatory worker safety
training, or the need to preserve the integrity of containerized wastes. These factors might affect
future decisions on what kinds of wastes can be disposed of in the different types of landfills.
Another factor that might influence future waste management decisions is the available capacity of
the different landfills. Data presented by the panelists indicated that every state has multiple
municipal solid waste landfills and construction and demolition landfills. These landfills have widely
varying capacities, but many of them may not be able to handle large volumes of wastes generated
during terrorist attacks. The larger landfills are more likely to have the equipment and personnel
needed to manage wastes from such events, assuming the landfill operators are willing to accept
these wastes—an important issue discussed in greater detail below. Unlike the construction and
demolition landfills and municipal solid waste landfills, few hazardous waste landfills are currently
operating, possibly fewer than 25 nationwide. Though the hazardous waste landfills may have the
necessary infrastructure to handle wastes from terrorist attacks, they might not be a reason able waste
disposal option for areas without nearby landfills.
In terms of capacity alone, landfills appear to be far more capab le than incinerators at managing large
volumes of waste over short time frames. However, past experiences have suggested that landfill
operators are extremely hesitant, if not completely unwilling, to accept wastes that might be
contaminated with biological agents. The landfill operators at the workshop stated that scientific
issues still need to be resolved before they feel comfortable disposing of wastes that contain, or
might contain, biological agents. Operators expressed concern about risking their assets and
assuming other liabilities simply by processing a single waste stream, even if the waste involved has
already been decontaminated in autoclaves. Thus, on-site coordinators might have difficulty
identifying landfills willing to accept wastes that might contain biological agents, due to perceived
risks and liabilities. Specific concerns raised by landfill operators follow:
• Unresolved scientific issues. Noting that scientists have not developed widely accepted
decontamination criteria, landfill operators who attended the workshop expressed concern
about disposing of wastes potentially contaminated with biological agents. This concern will
likely remain until scientists develop (and regulators adopt) specific guidance on the
effectiveness of decontamination. Landfill operators also noted that only very limited
scientific information is currently available on the fate of chemical and biological agents in
landfill environments and whether these agents might eventually be released in leachate or
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to the air. Another concern was that chemical or biological agents might contaminate landfill
equipment or otherwise damage landfill assets. The next section of this report lists specific
researchneeds that panelists identified to address these and other unresolved scientific issues.
• Absence of guidance or clear regulatory framework. The landfill operators at the
workshop emphasized that operating permits typically dictate the types of wastes (usually by
waste codes) that landfills are allowed to receive. However, waste codes have not been
developed to classify building debris or spent personal protective equipment possibly
contaminated with chemical or biological agents. As long as regulations and agency guidance
documents do not specify when landfills can accept and dispose of these types of wastes, the
operators suspected that most landfills will continue to refuse wastes that might be
contaminated with biological agents. As the next section describes, the workshop panelists
o ffered many suggestions for EPA to consider when developing guidance for landfills on this
issue. Such guidance should acknowledge that waste management regulations vary from one
state to the next.
• Other issues. The panelists identified many other concerns that landfill operators have
expressed about disposing of special wastes at their facilities. First, several panelists
wondered how they can ensure that wastes from terrorist incidents do not endanger their
workers, including haulers, equipment operators, environmental monitoring personnel, and
others with site access. Panelists asked, for instance, if landfills would need to implement
additional health and safety training, medical monitoring, or vaccination programs, or to
require employees to receive prophylactic therapies. Second, operators asked if landfills that
receive special wastes will need to monitor the air, groundwater, or leachate for chemical and
biological agents. Finally, the panelists raised many additional issues that EPA and landfill
operators might need to consider, such as liability concerns, public perception, and the need
for vector control. One panelist noted that legal issues may require negotiations and
provisions proposed to Congress to address industry's concern regarding liability in the event
of a terrorist attack that requires private firms to assist with the public disaster.
In this discussion, panelists suggested three options for EPA to consider when developing guidance
on disposing of wastes from buildings contaminated with chemical or biological agents. First, several
panelists suggested the possibility of constructing "mono-fills" to handle special waste streams at
existing landfill sites. Landfill operators could isolate the wastes of concern in these mono-fills,
which can either serve as temporary storage areas or as permanent disposal sites. Second, some
panelists said that EPA might be able to coordinate special waste disposal activities with the
Department of Defense: many states have military installations that not only have active landfills,
but also have security measures to prevent unauthorized access. Third, several panelists suggested
that EPA consider evaluating the feasibility of temporary waste storage options using "macro-
encapsulation units." This technology has been used to dispose of decontaminated furniture from an
office building that received an anthrax-tainted letter. In that case, the furniture items and other
materials were placed into a macro-encapsulation unit, which was filled with cement kiln dust and
then sealed. Use of the high-pH cement kiln dust is believed to render the macro-encapsulation unit
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unsuitable for microbial growth. Some panelists indicated that macro-encapsulation units, which
have capacities of approximately 20 tons, could be useful when temporary storage of wastes is
needed.
B. What research or information needs were identified?
Workshop panelists identified several information gaps regarding disposing of wastes in landfills,
and noted research needs or action items for filling these gaps. They discussed the following issues:
• Several panelists recommended that EPA develop data, whether modeled or experimental,
that characterize the fate of selected biological and chemical agents in landfills. One
suggestion was to perform bounding calculations to assess the fate of chemical agents in
landfills; these calculations could be based on conservative transport assumptions and the
agents' relevant chemical and physical properties (e.g., vapor pressure, solubility, octanol-
water partition coefficient). The calculations can provide insights, for example, on whether
disposing of wastes containing chemical agents would produce unacceptable air
concentrations at the landfill surface.
• Other panelists recommended that EPA conduct experiments to simulate the movement of
chemical or biological agents through landfill environments. One suggestion was that
researchers use lysimeters filled with waste to determine whether agents in the waste will
enter leachate or air. Such experiments could investigate contaminant mobility for many
landfill conditions and waste matrixes. Another suggestion for experimental research was to
evaluate whether biological agents would remain viable in the pH conditions typically found
in different types of landfills. Similarly, panelists suggested that EPA examine whether
biological agents remain viable under the high pH conditions present in macro-encapsulation
units filled with wastes and cement kiln dust. Finally, one panelist suggested that
experimental research can eventually consider the fate of chemical and biological agents in
test cells at select landfills.
• The panelists identified many other unresolved scientific issues, such as whether chemical
or biological agents might damage landfill liners, leachate collection systems, and gas
recovery systems and how waste generators can demonstrate that their waste streams are
decontaminated. The panelists did not identify specific research projects that can address
these information gaps.
• Panelists said that landfill operators would benefit greatly from EPA preparing a protocol or
guidance document that addresses technical issues associated with disposing of special
wastes. Specific issues such a document could address include: what wastes may and may
not be accepted, when wastes must be containerized, under what circumstances temporary
storage of wastes is preferred, under what circumstances segregating wastes into a mono-fill
is preferred, what minimum landfill design features are needed to receive special wastes,
what additional environmental monitoring is needed, and whether landfill operators will be
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held liable for disposing of wastes according to these guidelines. Once these and other related
issues are addressed in an authoritative document written by EPA, waste management
decisions might be less complicated to address. Some panelists indicated that EPA might
need to have its eventual guidance documents subject to peer review, possibly by
independent panels or by bodies like the National Academy of Sciences. Other panelists
noted that guidance documents should acknowledge that waste management regulations can
vary from one state to the next.
• The Federal Government may need to pre-determine potential landfill sites that would be
available to dispose of chemical/biological agents. This assessment should include location,
security, and capacity issues. This assessment should include existing facilities as well as
new facilities that would offer more security and/or the ability to be operated as a mono fill.
• Several panelists suggested that EPA consider developing a dynamic database that
periodically tracks landfill capacity (in active cells) for different types of landfills around the
country, including those on military installations. This database could be accessed by parties
responsible for disposing of wastes that contain chemical or biological agents.
• S ome panelists recommended that EPA review the literature and consult with other agencies
about existing information on the fate of biological agents in landfills. One panelist, for
instance, indicated that modeling studies conducted by environmental agencies in the United
Kingdom have already examined the environmental fate of prions. Panelists cautioned EPA
about using literature on the fate of biological agents in soils, because landfills and soils are
considerably different environments.
C. What information resources are currently available on this matter?
The panelists identified several sources of information on disposing of wastes from buildings
contaminated with chemical or biological agents into landfills. The resources identified during the
workshop are discussed. (This should not be viewed as a comprehensive account of all available
resources.)
• One document cited at the workshop is the National Response Team's 2002 draft-final
document titled "Technical Assistance for Anthrax Response." The document is available
from NRT's Web site (http://www.nrt.org). It addresses a wide range of technical issues for
anthrax, including sampling and analysis, decontamination, storage, and disposal.
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VII. Incineration
A. What do we know?
Incineration technologies were discussed extensively, especially considering that many potential
waste streams from terrorist attacks might not be allowed in, or accepted by, landfills. Based on
experiences from weapons demilitarization operations and management of wastes from anthrax-
contaminated buildings, panelists generally accepted that incineration is a viable option for treating
wastes that might contain chemical or biological agents. But the panelists, particularly the
representatives from incineration facilities, listed several scientific, technical, and public perception
issues that need to be resolved or considered to ensure that wastes are incinerated properly and in
a manner that does not harm the environment, compromise worker safety, or damage the assets at
incineration facilities.
The panelists identified five general types of thermal treatment technologies that might be used to
treat wastes containing biological and chemical agents. This discussion addressed the typical sizes,
capacities, and other relevant features of the technologies:
• Hazardous waste incinerators (HWIs). The panelists reviewed various hazardous waste
incineration technologies, but focused on fixed hearth and rotary kiln incinerators as the most
likely candidates to manage wastes containing biological and chemical agents.2 A panelist
noted that 7 fixed hearth and 37 rotary kiln HWIs currently operate in the United States,
though many of them are dedicated to specific waste streams at industrial facilities or are
located at military installations. Advantages of using HWIs include the fact that regulations
already require these incinerators to have waste tracking mechanisms and employee safety
training programs. Possible disadvantages include the fact that most HWIs are located in
relatively remote areas, the limited capacities of HWIs, and size limitations. For perspective
on typical waste processing capacities, one panelist noted that the three rotary kiln HWIs he
contacted before the workshop could process between 50 and 175 tons of hazardous waste
per day. Typically, the sizing for the feed stream is the rough dimensions of a drum.
• "Waste-to-energy" facilities. The panelists said that municipal solid waste incinerators
might be able to handle wastes containing chemical and biological agents. Panelists noted
several potential advantages to these facilities: when compared to HWIs, the waste-to-energy
facilities tend to be closer to urban centers, where terrorist attacks on buildings would most
likely occur; they generally have much larger processing capacities than HWIs; and they are
believed to have more flexibility to implement specific engineering changes (e.g., altering
The panelists acknowledged that other types of facilities, such as cement kilns, boilers, and industrial
furnaces, combust hazardous wastes. They did not discuss such facilities in detail, because these facilities typically
require homogeneous waste streams and likely would not be able to process the wide range of wastes that would
probably be generated in a building contamination scenario. One panelist said that cement kilns might be able to treat
contaminated carpets, but this issue was not discussed extensively.
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the feed inlets) in order to accommodate special wastes.
Potential disadvantages included public perception associated with incinerating special
wastes near population centers and permit restrictions for these facilities. Another limitation
is the fact that, while waste-to-energy facilities are designed to receive and process many
thousands of tons of waste per week, they are not particularly suited for large bulky items.
Processing larger items can cause operational upsets (e.g., plugging the feed chute or ash
discharger) and can complicate efforts to homogenize wastes, which is needed to achieve
optimum combustion conditions. The need to homogenize wastes raised further concern that
doing so can generate dusts in the pit area, where workers might be exposed to chemical and
biological agents. Another possible limitation associated with waste-to-energy facilities is
the fact that many facilities are municipally owned and privately operated and have business
and financial relationships with their client communities. As a result, some owners and
operators might not be able to offer or make available their waste-to-energy facilities for
wastes from terrorist attacks.
The panelists did not indicate exactly how many waste-to-energy facilities operate in the
United States, though they noted that the number is likely far greater than the number of
HWIs.
Medical waste incinerators (M WIs). Participants noted that MWIs likely could handle, and
would be allowed to process, certain types of wastes containing chemical or biological
agents, even though they are permitted to handle wastes primarily from clinical and research
settings. Regulators might need to issue permit modifications or exemptions for MWIs to
process these wastes. One panelist noted that an estimated 115 MWIs currently operate in
the United States, including 22 commercial MWIs. The processing capacity for these
incinerators is generally 1 ton of waste per hour. The most notable limitation for MWIs is the
size of the waste that can be processed: one panelist pointed out that the typical hopper size
for most MWIs is 3 feet by 5 feet by 5 feet.
Autoclaves. Panelists briefly reviewed information on autoclaves, which sterilize wastes
using steam, heat, and pressure. Autoclaves range in size from bench-top devices to large
commercial operations. These commercial facilities can process up to 96 tons of waste per
day, and some have waste inlet openings up to 8 feet in diameter. Potential advantages of
using commercial autoclaves to sterilize waste include the ease with which processing
conditions can be altered for specific waste streams, the ability to process large waste items,
and the fact that these facilities often have testing requirements for spore destruction.
Potential disadvantages include worker safety issues (which already have been documented
for an autoclave where elevated mercury exposures occurred) and the issue of disposing of
decontaminated wastes.
Alternative treatment technologies. The panelists identified several other technologies that
might hold promise for future waste management challenges. Specific suggestions include
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plasma treatment technologies, ionizing radiation, and thermal microwave technologies. The
panelists did not discuss these technologies in detail (except for the potential use of plasma
technologies to treat large numbers of human cadavers following a bio-terrorism attack) and
indicated that the performance of these technologies has yet to be verified.
The panelists identified many technical challenges that need to be resolved for incinerating wastes
containing chemical and biological agents, regardless of the type of incinerator being considered.
Discussions focused on considerations for the incinerator operators and the waste generators:
• Challenges faced by incinerator operators. The panelists listed many potential challenges
that incinerator operators face when receiving wastes that potentially contain chemical or
biological agents. For instance, operators said that further research is necessary to determine
optimal operating conditions (e.g., temperature, residence time) for adequate treatment of
wastes; several operators added that the optimal conditions will likely depend on the specific
chemical or biological agent of concern and the type of waste being treated (e.g., office
materials, personal protective equipment, animal carcasses). Further, operators need guidance
on proper waste handling procedures,3 approaches to handling process upsets and pressure
excursions, and how incinerator residues (e.g., ash, baghouse dusts) should be managed. The
operators also indicated that processing wastes not specifically identified in their operating
permits would require permit modifications, exemptions, or variances. The operators
expressed concern about whether trial burns would be required and whether building wastes
might contain chlorine, metals, and other constituents in amounts that would cause
incinerators to exceed their permitted emission limits or cause corrosion of the equipment
in the case of chlorinated disinfectants. Some incineration facilities, operators said, might
require capital investment (e.g., a dedicated conveyor system) to address the unique
challenges posed by processing wastes containing chemical or biological agents.
The incinerator operators also expressed concern about protecting their business assets,
including their employees and equipment. Specific concerns about worker safety echoed
those raised earlier in the workshop: Under what circumstances should workers be
vaccinated, issued prophylactic therapy, or tracked by medical monitoring programs? What
process upsets and other operating conditions might cause incinerators to release untreated
wastes into the workplace air? Is supplemental training needed before facilities receive
wastes containing chemical or biological agents? The panelists generally agreed that proper
sizing and packaging of wastes at the site of contaminated buildings will help alleviate, but
not eliminate, worker safety concerns at incineration facilities. Another approach proposed
to addressing worker safety issues is having environmental, health, or safety agencies provide
There was some dissent on this matter. One panelist noted that operators of medical waste incinerators are
already trained in the proper management and handling of infectious and highly hazardous substances and wondered
why further training is considered necessary. On the other hand, several panelists added that incinerator operators
and facility personnel might require special training on chemical and biological agents to address the "fear of the
unknown" and to ensure that all facility personnel are comfortable handling materials potentially contaminated with
chemical and biological agents.
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on-site operators for the time when special wastes are processed. An incinerator operator
took exception to this suggestion, noting that incinerator operators are already extensively
trained and experienced with the specific equipment and technologies used at their facilities.
This panelist suggested that outside agencies should work cooperatively with site operators
and personnel, rather than presume that they can or should take over operations at a given
facility.
During this discussion, incinerator operators wondered if EPA could assist (whether directly
or financially) with developing training courses specific to handling chemical and biological
agents. These operators emphasized that workers should be trained on any unique hazards
posed by chemical and biological agents before an event occurs, such that workers can be
educated and prepared to handle wastes in the future.
In addition to worker safety issues, the incinerator operators asked about protection of their
equipment, which often times represents an investment of millions of dollars. Some
operators, for example, might be hesitant to jeopardize the ongoing operation of their
incinerators by processing a single waste stream from a terrorist event that might contaminate
or corrode their equipment. The operators recommended that EPA consider these liability
concerns, possibly by indemnifying facilities that properly process wastes containing
chemical or biological agents from unforeseen damages that might result or otherwise
assuring operators that a financial mechanism is in place to reimburse facilities for damages
caused by or long-term costs associated with managing waste streams containing chemical
or biological agents. Another panelist noted that liability concerns might be addressed by
provisions proposed to Congress.
Finally, many panelists noted that public perception issues might be extremely difficult to
address for incineration facilities. Some operators suspected that activists and community
members would likely protest if wastes containing chemical or biological agents are treated
by incinerators in their cities. Panelists suspected that strong pub lie opposition to incineration
could be a significant obstacle to managing wastes, especially for the waste-to-energy
facilities, which tend to be located in or near densely populated urban settings.
Considerations for the "generators" of wastes.4 The workshop panelists also noted that
the generators of wastes containing chemical and biological agents should be made aware
of specific challenges that incinerator operators face. For instance, the generator should
identify the size limitations of the incinerator that will receive the waste before shipping
materials off site, so that wastes can be packaged accordingly. The generator also should
determine the maximum throughput that the incinerator can handle, so that the waste stream
does not overwhelm the incinerator's operations. Finally, the generators need to be aware of
specific packaging and labeling requirements; some incinerators, for example, might require
"Generator," in this section, is meant to refer to the party that collects the waste at the site of an incident
and ships the packaged waste to the incinerator. This will likely be a local or state agency.
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that each waste item have a label specifying the heat content, volatility, and composition (at
least of chlorine and metals) of the waste material. Most of these issues can be resolved
during planning for terrorist attack scenarios.
The workshop panelists raised several additional waste management options or scenarios for EPA
to consider. First, they debated whether mobile incineration units would be viable options for
processing wastes from buildings contaminated with chemical and biological agents. While the
mobility of these units is clearly an advantage, panelists were concerned about the need for obtaining
operating permits on short notice, the destruction efficiencies that the mobile units can achieve,
whether public perception will preclude the use of mobile incinerators in urban settings, and the
limited capacity and inlet size restrictions for the existing mobile incineration units. Second, some
panelists wondered if a combination of waste management technologies (e.g., disinfecting wastes
in an autoclave, disposal of disinfected wastes in a landfill) might be preferred for certain types of
wastes. Third, some panelists said that EPA should be aware that some incinerators that are currently
closed can be brought back online, if necessary, with relatively low capital investment. Finally, the
panelists discussed the unique challenges of handling human cadavers or body parts that are
contaminated with biological agents. As noted previously, the panelists indicated that multiple
agencies might need to coordinate efforts to ensure that contingency plans are in place to handle
large numbers of potentially contaminated cadavers.
B. What research or information needs were identified?
Workshop panelists identified several information gaps for incinerating wastes from buildings
contaminated with chemical and biological agents, and noted associated research needs or action
items for filling these gaps. The following issues were discussed:
• Several panelists identified opportunities for scientific research into ensuring that
incineration facilities properly destroy wastes. For instance, some panelists indicated that
bench-scale and pilot-scale experiments using surrogate agents could characterize the
minimum residence time and temperature needed to properly treat chemical and biological
agents bound to different matrixes. Such research could range from examining fundamental
heat transfer and mass transfer behavior that can be incorporated into computational models
to conducting trial burns that examine destruction efficiencies and residue content for more
challenging waste streams (e.g., rolled-up carpet soaked in water). Other waste sources that
may present problems for incineration include animal carcasses, wastewater from
decontamination and radioactive wastes. A concern was also raised about the combustion
products produced, e.g. disinfectant dosages resulting in significant dioxin formation and
metals from electronics. One panelist noted that EPA is already conducting some research
on these incinerator performance issues, and another panelist indicated that EPA has already
conducted modeling of full-scale medical waste incinerators for spore destruction.
• For the benefit of the state and local agencies that might be faced with waste management
challenges in the future, EPA could develop an inventory of different types of incinerators
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and throughput capacity across the United States, including HWIs, MWIs, waste-to-energy
facilities, and commercial autoclaves. Panelists suggested that such an inventory can identify
the locations, capacities, types of units, inlet size restrictions, accessibility by rail car, and
other features of incineration facilities. The inventory should include all types of incinerators
that might receive wastes containing chemical and biological agents, including incinerators
at military installations and "captive" incinerators at industrial facilities that typicallyprocess
only those wastes generated on site. When reviewing the existing infrastructure, EPA can
also identify engineering challenges that prevent incinerators from accepting wastes (e.g.,
inlet size restrictions) and determine how these challenges might be addressed.
• Several panelists noted that state and local agencies should consider the available
incineration capacity when developing plans for how to handle wastes contained with
chemical and biological agents. These agencies should identify a number of issues including
which incinerators are willing and able to accept wastes containing chemical and biological
agents, what types and sizes of wastes they can process, how wastes should be packaged
before being sent to the incinerator. This recommendation is consistent with a general theme
expressed throughout the workshop: very few waste management options are available for
wastes generated when buildings are contaminated with chemical or biological agents.
Recognizing this, several panelists recommended that the state and local agencies first
identify the limited number and type of facilities that are willing and capable to receive the
wastes, and "work backwards" to specify what types of wastes should be sent to the
identified facilities.
• A number of panelists indicated that operator training is needed to handle these types wastes.
This should be built on training that exists for operators.
• S ome panelists indicated that EPA could continue to examine the effectiveness of alternative
treatment technologies (e.g., plasma, ionizing radiation, thermal micro wave). These panelists
noted that EPA has already published specifications for verifying the effectiveness of new
technologies for treating medical waste, as has the State and Territorial Association on
Alternative Treatment Technologies.
C. What information resources are currently available on this matter?
The panelists identified several sources of information on incinerating wastes from buildings
contaminated with chemical or biological agents. The main resources identified during the workshop
are discussed below. (This should not be viewed as a comprehensive account of all available
resources.)
• The Integrated Waste Services Association has prepared a report documenting the locations,
capacities, and other information about selected waste-to-energy facilities across the United
States. This report—The 2002IWSA Directory ofWaste-to-Energy Plants—is available on
the association's Web page: http://www.wte.org.
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Several panelists noted that the Department of Defense should have information available
on incineration of chemical agents, particularly from installations that are in the process of
obtaining operating permits for demilitarization activities. The incinerators at these sites
might be the most appropriate destination of wastes from terrorist attacks involving chemical
agents, assuming they can handle the types of wastes that must be disposed of or treated.
One panelist encouraged EPA to obtain and review a testing protocol recently used to
evaluate a technology's effectiveness for deactivating prions. Testing was conducted by the
USDA for a technology developed by a company named Waste Reduction by Waste
Reduction.
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VIII. List of Participants
The following pages list the panelists who participated in the workshop. The list does not include
those who were invited to participate but could not attend the workshop.
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SEPA
United States
Environmental Protection Agency
Office of Research and Development
Homeland Security Workshop on Transport and
Disposal of Wastes from Facilities Contaminated
with Chemical/Biological Agents
Marriott Kingsgate Conference Center
Cincinnati, OH
May 28-30, 2003
Workshop Participants List
Morton Barlaz
Professor
Department of Civil Engineering
North Carolina State University
Box 7908
Raleigh, NC 27695
919-515-7676
Fax: 919-515-7908
Email: barlaz@eos.ncsu.edu
Ernest Bennett
Vice President
Montenay Power Corp.
Rt8 Box 757
Lake City, FL 32055
386-755-2264
Fax: 386-754-5975
Email: ebenett@bellsouth.net
Mark Brlckhouse
Team Leader
Edgewood Chemical Biological Center
ATTN: AMSSB-RRT-PD
Aberdeen Proving Ground, MD 21010-5424
410-436-8479
Fax:410-436-7203
Email: mark.brickhouse@sbccom.apgea.army.mil
JoAnn Camacho
Environmental Engineer
Environmental Response Team
U.S. Environmental Protection Agency
2890 Woodbridge Avenue
Edison, NJ 08837
732-906-6916
Email: joann.camacho@epa.gov
David Carson
National Risk Management Research
Laboratory (NRMRL)
U.S. Environmental Protection Agency
26 West Martin Luther King Drive (CHL)
Cincinnati, OH 45268
513-569-7527
Email: carson.david@epa.gov
Greg Cekander
Vice President,
Environmental Management Group
Waste Management Inc. (WMI)
1001 Fannin Street
Suite 4000
Houston, TX 77002
713-328-7332
Fax: 713-328-7411
Email: gcekander@wm.com
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David Cleverly
Environmental Scientist
National Center for Environmental Assessment
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW (8623D)
Washington, DC 20460
202-564-3238
Fax: 202-565-0076
Email: cleverly.david@epa.gov
Wendy Davis-Hoover
Research Microbiologist
Remediation and Containment Branch
U.S. Environmental Protection Agency
5995 Center Hill Avenue (CHL)
Cincinnati, OH 45215
513-569-7206
Fax: 513-569-7879
Email: davis-hoover.wendy@epa.gov
Robert Eckhaus
Chemical Engineer
Homeland Defense Business Unit
Edgewood Chemical Biological Center
ATTN:AMSSB-REN-HD
BLDG E3320
Aberdeen Proving Ground, MD 21010-5424
410-436-5981
Fax: 410-436-3207
Email: robert.eckhaus@sbccom.apgea.army.mil
Eileen Edmonson
Transportation Regulations Specialist
Office of Hazardous Materials Standards
Research and Special Programs Administration
400-7th Street, SW (DHM-12)
Room 8430
Washington, DC 20590
202-366-4481
Fax: 202-366-3012
Email: eileen.edmonson@rspa.dot.gov
John Ely
Director, Office of Waste Programs
Virginia Department of Environmental Quality
P.O. Box 10009
Richmond, VA 23240
804-698-4249
Fax: 804-698-4327
Email: jeely@deq.state.va.us
Mark Galgano
National Tech Transfer Center/Commerce
Services Corporation
698 East Washington Street
Medina, OH 44256
330-721-9139
Fax: 330-721-9139
Email: galganom@cscventures.com
Greg Gesell
Principal Environmental Engineer
American Ref-fuel Company
2827 Skylark Street
Fremont, NE 68025
402-721-5971
Fax: 402-721-7874
Email: greg.gesell@ref-fuel.com
Gary Hater
Senior Director, BioSites Program Center
Waste Management, Inc.
2956 Montana Avenue
Cincinnati, OH 45211
513-389-7370
Fax: 513-389-7374
Email: ghater@wm.com
Beth Hurley
Vice President, Health and Safety
Covanta Energy, Inc.
40 Lane Road
Fairfield, NJ 07007
973-882-7245
Fax: 973-882-4153
Email: bhurley@covantaenergy.com
Melvin Keener
Executive Director
Coalition for Responsible Waste Incineration
(CRWI)
1752 North Street NW
Suite 800
Washington, DC 20036
202-452-1241
Fax: 202-887-8044
Email: crwi@erols.com
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Philip Koga
Supervisory Biologist Senior Team Leader,
Biosciences
Edgewood Chemical Biological Center
BldgE3150 (AMSSB-RRT-B)
Aberdeen Proving Ground, MD 21010-5424
410-436-6632
Fax: 410-436-2081
Email: philip.koga@us.army.mil
Fran Kremer
National Risk Management Research Laboratory
(NRMRL)
U.S. Environmental Protection Agency
26 West Martin Luther King Drive (481)
Cincinnati, OH 45268
513-569-7346
Fax: 513-569-7620
Email: kremer.fran@epa.gov
Paul Lemieux
Chemical Engineer
National Homeland Security Research Center
(NHSRC)
U.S. Environmental Protection Agency
109 TW Alexander Drive (E305-01)
Research Triangle Park, NC 27711
919-541-0962
Fax: 919-541-0554
Email: lemieux.paul@epa.gov
Steven Levy
Environmental Engineer
Office of Solid Waste
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (5306W)
Washington, DC 20460
703-308-7267
Fax: 703-308-8686
Email: levy.steve@epa.gov
Mary Ann Marrocolo
Director
Recovery and Mitigation Division
New York City Office of Emergency Management
11 Water Street
Brooklyn, NY 11201
718-422-4835
Fax: 718-422-4871
Email: mmarroco@oem.nyc.gov
Dennis McGowan
Chief of Operations
Fulton County Medica Examiner
430 Poyor Street
Atlanta, GA 30312
404-730-4417
Fax: 404-730-6990
Email: mcchief@bellsouth.net
Kristina Meson
Generator and Recycling Branch
Office of Solid Waste
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (5304W)
Washington, DC 20460
703-308-8488
Fax: 703-308-0514
Email: meson.kristina@epa.gov
Robert Olexsey
Director
Land Remediation and Pollution Control
Division
U.S. Environmental Protection Agency
26 West Martin Luther King Drive (481)
Cincinnati, OH 45268
513-569-7861
Fax: 513-569-7620
Email: olexsey.bob@epa.gov
Martin Powell
Regional Counter Terrorism Programs
Coordinator
U.S. Environmental Protection Agency
1060 Chapline Street
Wheeling, WV 26003
304-234-0252
Fax: 304-234-0259
Email: powell.martin@epa.gov
Frank Schaefer
Microbiologist
Biohazard Assessment Research Branch
Microbiological and Chemical Exposure
Assessment Research Division/NERL
U.S. Environmental Protection Agency
26 West Martin Luther King Drive (MC 320)
Cincinnati, OH 45268
513-569-7222
Fax: 513-569-7117
Email: schaefer.frank@epa.gov
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Howard Schmidt
Atmospheric Scientist
Lockheed Martin/RE AC
2890 Woodbridge Avenue, Bldg. 209
Edison, NJ 08837
732-321-4280
Fax: 732-494-4021
Email: howard.d.schmidt@lmco.com
John Skinner
Executive Director and CEO
Solid Waste Association of North America
1100 Wayne Avenue
Suite 700
Silver Spring, MD 20910
301-585-2898
Fax: 301-589-7060
Email: jskinner@swana.org
Susan Thorneloe
Senior Chemical Engineer
Air Pollution Prevention and Control Division
National Risk Management Research Laboratory
(NRMRL)
U.S. Environmental Protection Agency
109 TW Alexander Drive (E305-02)
Research Triangle Park, NC 27711
919-541-2709
Fax: 919-541-7885
Email: thorneloe.susan@epa.gov
Greg Vogt
Project Director
SCS Engineers
11260 Roger Bacon Drive
Reston, VA20190
703-471-6150
Fax: 703-471-6676
Email: gvogt@scseng.com
Richard Watson
Chief Engineer
Delaware Solid Waste Authority
P.O. Box 455
Dover, DE 19903
302-739-5361
Fax: 302-739-7287
Email: rpw@dswa.com
Angela Weber
Industrial Hygienist
Environmental Health Services
Division of Emergency and Environmental
Health Services
Center for Disease Control (CDC)
4770 Buford Highway (F-28)
Atlanta, GA 30321
770-488-7533
F: 770-488-7310
Email: amw1@cdc.gov
William White
Research Chemist
Threat Agent Team
Edgewood Chemical Biological Center
5183 Blackhawk Road (AMSSB-RRT-PC)
Aberdeen Proving Ground, MD 21010
410-436-3058
Fax: 410-436-2330
Email: wewhite@apgea.army.mil
Alan Woodard
Environmental Program Specialist
Solid and Hazardous Materials
New York State Department of Environmental
Conservation
625 Broadway
Albany, NY 12233
518-402-8706
Fax: 518-402-8681
Email: agwoodar@gw.dec.state.ny.us
Contract Support
KateSchalk
Vice President, Conference Services
ERG
110 Hartwell Avenue
Lexington, MA 02421
781-674-7324
Fax: 781-674-2906
Email: kate.schalk@erg.com
JohnWilhelmi
Chemical Engineer
ERG
110 Hartwell Avenue
Lexington, MA 02421
781-674-7312
Fax: 781-674-2851
Email: john.wilhelmi@erg.com
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