United States
Environmental Protection
Agency
OH.ce of
Solid Waste ana
Emergency Response
PA
DIRECTIVE NUMBER: 9443.03(84)
TITLE: Listing of Agents GB, VX, and HX
APPROVAL DATE: e-4-84
EFFECTIVE DATE: 6-4-84
ORIGINATING OFFICE: office of solid waste
(2 FINAL
D DRAFT
LEVEL OF DRAFT
DA — Signed by AA or OAA
D B — Signed by Office Director
DC — Review & Comment
REFERENCE (other documents):
OS WER OS WER OS WER
VE DIRECTIVE DIRECTIVE Dl
-------
PART 261 SUBPART C - CHARACTERISTICS
DOC: 9443.03(84)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Listed Wastes
40 CFR 261.33(a)(4)(5), 261.11(a)(2)
Listing of Agents GB, VX, and HX
Jon P. Yeagley, Chief, State Program Section
Matthew A. Straus, Acting Chief, Waste Identification Branch
#9443.03(84)
6-4-84
According to the definition of §261.23(a)(/j), the properties of the agents
GB, VX, and HD should be considered hazardous due to their reactive nature.
When these agents are mixed with water, they generate toxic gases, vapors, or
fumes in a quantity sufficient to present a danger to human health or the
environment. The gases of concern are for GB, emissions of hydrogen flouride;
for HD, emissions of hydrogen chloride; and for VX, emissions of bis-ethyl
methyl phosphoric acid and bio-S-methyl phosphonodithiolate. Mustard gas could
meet the criteria in §261.23(a)(5) due to emissions of sulfides.
While these wastes are not specifically listed, EPA does plan to develop
listings for all three agents. These listings will probably be developed under
the criteria of §261.ll(a)(2) and result in the designation of the wastes as
Acute Hazardous Waste.
-------
9443.03 (84
JUN X1984-'.
- - ' £
TboalA Army Depot £
Matthew A. Straus, Acting Chief ' £
its Identification Branch, (W-5C2B) ?
Jon P. Teagley,-Chief 2
State Ptcgfams Section, (8*Wi1) 5-
We have reviewed your submissions related to the Chemical Agents Munitions C
Disposal System facility. Our preliminary assessment of the properties of 3-
agents GB (isopropyl methyl phosphonofluoridata), VX (Ethyl-S-diiacorcpyl ^
aminoathyl methyl phosphonothiooate), and HD (Bis-2-chloroethyl sulfide) ^
lead us to conclude that the wastes should be considered hazardous due to ,*]
their reactive nature. WhiLa the wastes are not specifically listed at £
this tias, we believe them to be reactive according to the definition of £
S261.23(a)(4) — namely, when mixed with water, they generate toxic gases, Qj
vapors, or fuses in a quantity sufficient to present a danger to hunmn health i
or the environment. The gases of concern in each case are as follows: for $
GB, emissions of hydrogen flouride which has a TLV of 3 ppm in air; for HD, - \
emissions of hydrogen chloride which has a TLV of 5 ppm; and for VX, emissions f
of diethyl methyl phosphorate, bis-ethyl methyl phosphonic acid and bia-S- £
(diisopropyl amino ethyl) methyl phcaphonodlthiolate. In the case of VX, «
the emitted gases are indicated as toxic decomposition products that would \
be emitted upon addition of VX to water. (The reference for these anticipated £
emissions is the Amy's, field manual on military chemistry.) Sufficient £
quantities of any of theme chemical agents, when mixed with water, would »
be expected to emit gases at levels of concern and, thus, exhibit the "*
characteristic of reactivity. In addition, mustard gas could meet the
criteria in f261.23(a)(5), due to emissions of sulfides.
With respect to our ultimate plans via-a-vis these wastes, we do expect
to develop listings for all three agents. These listings would probably be
developed under the criteria of S261,ll(a)(2) and result in the designation
of the wastes as Acute Hazardous Waste. Unfortunately, other priorities
and a general dearth of available information will hinder our efforts and
may result in the passage of considerable time before these listings are
finalized. We are not overly concerned about this delay, however, since
the State's letter suggests that these wastes are being nmnagefl in a manner
consistent with their ail i isii toxidty. In addition, as we have stated above,
the wastes are currently regulated, nevertheless, it would be useful to our
efforts If your group or the State agency could submit information on the
wastes and the corresponding treatment and disposal options under discussion.
^
Do not hesitate to call Ben Smith (^S&A) of my staff if you require
further information.
cc. Julia Bussey (T-2-2) Region EC
------- |