Paper to be presented at the Department of Homeland Security R&D Partnership Conference;
Boston, MA; April 27-28, 2005.

U.S. EPA R&D Program for Disposal of Building Decontamination Residue

P. M. Lemieux
U.S. Environmental Protection Agency
Office of Research and Development
National Homeland Security Research Center
Research Triangle Park, NC 27711


In the event of a terrorist attack on buildings, transportation hubs, or other structures where
chemical or biological agents are used, significant quantities of building decontamination residue
(BDR) can be generated during cleanup and restoration activities. This BDR primarily consists
of porous materials formerly contained within the building, and although it has undergone
decontamination, current sampling limitations prevent assurances that no remaining traces of the
contamination agent is present in the BDR. In addition, the BDR could contain residual
decontamination chemicals and decomposition by-products from the contaminating agent. The
completion of the restoration process requires that the BDR be sent for ultimate disposal. Likely
disposal options include high temperature thermal incineration, landfilling, and steam
autoclaving. This paper describes the U.S. EPA's current program to 1) consolidate available
information and lessons learned for BDR disposal into technical guidance for responders,
permitting agencies, and the disposal industry; and 2) perform experimental research to help
close existing data gaps.


Because of the anthrax attacks on various government and news media buildings in 2001, the
EPA created a new organization within its Office of Research and Development, the National
Homeland Security Research Center (NHSRC). NHSRC provides R&D support to the Agency
and other parts of the federal government to address issues related to the EPA's responsibilities
under Homeland Security Presidential Directives (HSPDs) 7, 8, 9, and 10 (1, 2, 3, 4):

	HSPD 7: Critical Infrastructure Identification, Prioritization, and Protection - Specifically
designates EPA as the agency responsible for infrastructure protection activities for the
nation's drinking water and wastewater systems.

	HSPD 8: National Preparedness - Establishes policies to strengthen the preparedness to
prevent and respond to threatened or actual domestic terrorist attacks, major disasters, and
other emergencies by establishing mechanisms for improved delivery of federal preparedness
assistance to state and local governments.

	HSPD 9: Defense of United States Agriculture and Food - EPA is to develop a robust,
comprehensive surveillance and monitoring program to provide early warning in the event of
a terrorist attack using biological, chemical, or radiological contaminants. HSPD 9 also
directs EPA to develop a nationwide laboratory network to support the routine monitoring
and response requirements of the surveillance program.

	HSPD 10: Biodefense for the 21st Century - Provides directives to further strengthen the
Biodefense Program through threat awareness, prevention and protection, surveillance and
detection, and response and recovery.


The work related to restoration of buildings is being performed in NHSRC's Decontamination
and Consequence Management Division (DCMD, formerly the Safe Buildings Program) located
in Research Triangle Park, NC.

After a building has gone through decontamination activities following a terrorist attack with
chemical warfare (CW), biological warfare (BW) agents, or toxic industrial chemicals (TICs),
there will be a significant amount of residual material and waste to be disposed. This material is
termed "building decontamination residue" (BDR). Although it is likely that the BDR to be
disposed of will have already been decontaminated, the possibility exists for trace levels of the
toxic contaminants or their by-products, to be present in absorbent and/or porous material such
as carpet, fabric, ceiling tiles, office partitions, furniture, and personal protective equipment
(PPE) and other materials used during cleanup activities. There could also be wastes from the
decontamination process itself, such as scrubber slurries or activated carbon from scrubbers used
to remove fumigants such as chlorine dioxide (CIO2) from the buildings. In addition, there may
be additional contaminated materials such as carbon adsorption beds and high-efficiency
particulate arrestant (HEPA) filters from the building's heating, ventilation, and air conditioning
(HVAC) system. It is likely that much of this material will be disposed of in landfills or high-
temperature thermal incineration facilities, such as medical/pathological waste incinerators,
municipal waste combustors, and hazardous waste combustors.

Disposal is the final step in the restoration process, after the initial response and decontamination
activities have taken place. However, issues related to disposal are inextricably linked with the
entire process that came before, including:

	Impact of event containment activities on waste quantities and level of contamination

	Impact of decontamination technologies on waste quantities and characteristics

	Impact of tradeoffs between decontamination costs and disposal costs

	Impact of decontamination effectiveness and residual contamination levels on waste
classification for transportation and disposal

In May 2003, a workshop was held in Cincinnati, OH, which brought together various
stakeholders to discuss issues related to BDR disposal (5). In response to this workshop, DCMD
initiated a research program to 1) consolidate available information and lessons learned for BDR
disposal into guidance for responders, permitting agencies, and the disposal industry; and 2)
perform experimental research to help close existing data gaps.

This research program is moving forward under the assumption that the disposal of all the BDR
will be done in accordance with existing regulations. This would include: proper transportation
to the disposal site as defined in U.S. Department of Transportation (DOT) rules; proper
packaging and handling of the materials as per the Occupational Safety and Health Association
(OSHA), and the operational permits of the disposal facilities as governed by RCRA and the
Clean Air Act.

The primary clients for this program will be: 1) emergency response authorities who have to
decide the most appropriate decontamination methods and disposal of the resulting residues; 2)
state and local permitting agencies, who have to make decisions about which facilities will be
allowed to dispose of the materials; and 3) the waste management industry, that needs to safely
dispose of BDR without affecting the operation of its facilities and without violating any of its
environmental permits.


The issues related to disposal of BDR are being investigated using experimental and theoretical
approaches as well as by gathering available information from publicly available sources. The
goal of this effort is to develop a comprehensive decision-support tool from which the available
technical information can be used to help relevant parties plan for disposal activities, evaluate
alternatives, and make preliminary decisions during the crisis management phases of a response
activity, and to aid in the decision-making process in the consequence management phase of the
response activity.

The information needed to plan and carry out disposal activities, and anticipated sources for that
information are listed in Table 1. Some of the information can be found in parts of the U.S.
Environmental Protection Agency such as the Office of Solid Waste (OSW) or the Office of Air
Quality Planning and Standards (OAQPS). Other government agencies such as DOT,
Department of Defense (DoD), the Centers for Disease Control (CDC), or the National Institute
of Occupational Safety and Health (NIOSH) may have some of the information. Other valuable
information sources may include industrial stakeholder groups such as the Integrated Waste
Services Association (IWSA), the National Solid Waste Management Association (NSWMA), or
the Coalition for Responsible Waste Incineration (CRWI), groups of state regulators such as the
Association of State and Territorial Solid Waste Management Officials (ASTSWMO), or
professional organizations such as the American Society of Mechanical Engineers (ASME) or
the Air and Waste Management Association (AWMA), or the Solid Waste Association of North
America (SWANA). Some information is available by adapting methods that are used in similar
situations (e.g., Superfund cleanups, asbestos remediation, oil spill cleanups). Some of the
critical information is not available from any source. This information will be developed
through an experimental and theoretical approach.

Table 1. Information needed for disposal activities and likely sources of that information



Regional capacity/locations of disposal facilities


Incinerator design/operation criteria


Landfill design/operation criteria


Transportation and packaging


Environmental regulatory issues


Worker safety issues


Thermal destruction behavior of CW/BW contaminants in

DoD, Experiments, modeling

Landfill behavior of CW/BW contaminants bound in BDR

Experiments, modeling

Performance of autoclaves on contaminated BDR



The next sections of this paper will discuss in detail the various activities that are being
undertaken in the DCMD waste disposal program.


Figure 1 shows a diagram of the various elements of the waste disposal program and how they
interact with each other.

Figure 1. Diagram of DCMD Waste Disposal Program Elements.

Online Decision Support Tool

As an emergency response activity unfolds, the responders will be confronted with decisions that
will impact the cost and timing of the restoration of the building to normal operation, perhaps in
a significant manner. Unnecessary delays and excess expenses in the disposal process are not in
the best interests of the contaminated site, the various stakeholders, the government, or the
public. This program is developing an online decision support tool (DST) in partnership with
industry, state and local government, and federal agencies.

Data has been collected from the open literature, from state and federal regulatory agencies, and
from landfill and incinerator industry stakeholder groups, to develop technical guidance for
disposal of BDR and related residues. This project addresses the following issues:

Estimati on of BDR quantities and characteristi cs

Available disposal options and capacity for the different categories of BDR on a
geographical basis (currently limited to incinerators and landfills)

Contact info for the potential disposal facilities
Expected behavior of the B DR in the selected facility


On-site preprocessing of BDR to make the material more amenable for disposal in a given

Packaging to minimize risk to workers handling the BDR, to the disposal facility workers,
and to people along the transportation route to the disposal facility, and to minimize potential
for contaminating the disposal facility
Issues related to transporting the BDR

Minimum and optimum time and temperature requirements needed to destroy contaminants
to ensure an adequate margin of safety to the public and to disposal personnel
Characteristics of residues formed during the incineration process, and requirements for their
safe disposal

Fate and transport of these materials in a landfill environment
Permit implications for facilities disposing of these materials

The information is available in a web-based application (access granted upon request to NHSRC)
that will be centrally updated as new information becomes available, and old information (such
as contact information for key personnel) changes.

Experimental Efforts

Some of the information needed to complete the decision support tool is not currently available.
This includes information such as the behavior of CW/BW agents bound on BDR in a landfill or
incinerator environment. Table 2 lists the various components of BDR material that will be
examined during this R&D program and the agent surrogates/simulants that will be used in the
event that it is not practical or possible to perform experiments with live agents. Contaminants
will consist of various toxic industrial chemicals (TICs) to be used as simulants for CW agents,
and spores such as Geobacillus stearothermophilus, an organism that is commonly used to verify
performance of autoclaves for steam sterilization, will be used as BW agent simulants.

Table 2. Potential Substrates and Contaminants to be Tested

BDR Substrates

CW agent simulants

BW agent simulants



Dimethyl methyl

bacillus subtilis

Monochl orob enzene

Ceiling tiles

phosphonate (DMMP)




Chloroethyl ethylsulfide



Particle board

Ethylene glycol

Activated carbon

Landfill survivability/persistence and fate/transport studies

The fate and transport of BW and CW agents in landfill environments is not well established. A
theoretical and experimental program is ongoing to evaluate movement and
survivability/persistence of biological and chemical agents in the landfill environment.

Modeling is being performed using equilibrium bounding calculations to help guide
experimental designs. Initial experiments will examine whether BW agents are inactivated or if
they exhibit growth in leachate, and to assess the potential for transport of BW and CW agents
into landfill gas. The leachate survivability/persistence studies are being performed using live


agents at a DoD facility, whereas the fate and transport studies will be performed using surrogate
materials. These studies will answer the following questions:

What is the likely mode of transport (air, waste, leachate) for chemical and biological agents
within/from a landfill;

How well will the landfill environment reduce the survival time/persistence of active agents

and protect against survival of active agents;

Can BW and CW agents be transported into landfill gas?

Bench-scale thermal treatment studies

The thermal destruction of building materials contaminated with CW and BW agents is
complicated by matrix effects associated with the contaminant and the material on which it is
bound. It is important to know the relative difficulty of destroying these toxic agents when bound
on different materials to assure that minimum solid phase residence times will be achieved and
so that residual solids (such as fly ash and bottom ash) and gaseous emissions leaving the system
are free of contaminants. To provide guidance on minimum solid phase residence times, a
fundamental knowledge must be gained of the combustion behavior of CW and BW agents
bound on common building materials, and the desorption behavior of CW agents and TICs from
building materials and filter media such as activated carbon.

Bench-scale research is being conducted using laboratory reactors to examine the destruction of
surrogate biological agents (6) and the adsorption/desorption of surrogate chemical agents (7)
that are present on or within several common building materials including carpeting, furniture
and drapery fabrics, ceiling tiles, and wallboard. The effects of substrate material, time-
temperature profiles, and furnace conditions are being investigated.

The results from these studies will be used to evaluate incineration technologies for
appropriateness for disposal of contaminated building materials, and to generate information for
modeling of the incineration process.

Pilot-scale incineration studies

Pilot-scale testing is being performed to provide scale-up from the bench-scale testing and to
investigate issues related to operational difficulties that might result from burning larger
quantities of building decontamination residues. The pilot-scale testing will be performed in the
EPA's rotary kiln incinerator simulator (RKIS), a rotary kiln equipped with a secondary
combustion chamber (SCC), each with a nominal firing rate of 73 kW (250,000 Btu/hr). The
RKIS is capable of burning a variety of solid and liquid materials. Emphasis will be placed on
minimum time/temperature environments required to assure adequate destruction of the
contaminants, so that technical guidance may be given to facilities and permitting entities
regarding proper incineration of waste materials recovered from building decontamination
activities. This research will also examine the impact on air emissions from combustion of BDR.

Initial pilot-scale testing thus far has focused on issues related to combustion of carpeting,
particularly on the potential impacts of carpet combustion on air permits granted under the Clean
Air Act (8), and on destruction of spores bound in carpeting (9).

Modeling of BDR in Incineration Systems

In order to minimize problems associated with thermal destruction of CB-contaminated BDR,
modeling will be performed to examine potential incinerator failure modes (defined as non-


standard operating conditions that result in incomplete combustion and excess emissions) that
might arise. This modeling, using an approach developed for the U.S. Army chemical
demilitarization program (10), couples computational fluid dynamics (CFD) with complex
chemical kinetics to predict concentration distributions of contaminants and their combustion
byproducts within the incinerator. Two common incinerator designs will initially be modeled: a
modular starved-air incinerator design similar to that used for medical waste incineration; and a
rotary kiln incinerator similar to those used for hazardous waste combustion. The bench- and
pilot-scale experimental studies will be used to help develop the pieces of the model and to
calibrate the models. Initial comparisons between model results and experimental results (9)
have been promising (11).

Sampling and analytical methods development

Since the mobility of biological contaminants within landfills and thermal treatment devices has
not been well explored, it is critical that sampling and analytical methods be available to
determine efficacy of destruction and permanence of land disposal. Preliminary sampling and
analytical methods (12) for some microorganisms have been developed for potential use on
medical waste incinerator stack gases and ash residues, but these methods have not been
validated, and have not been tested for some of the primary biological warfare (BW) agents of
concern (e.g., anthrax). This project will adapt and expand upon existing sampling and
analytical methods for BW agents in combustor stacks and ash residues.

The primary goals of this project are:

Investigate relevant sampling/analytical measurements issues such as sample collection
efficiency, stability, preservation, etc;

Investigate/determine potential method detection limits;

Develop a draft procedure suitable for field-testing.

Field Test at a Commercial Autoclave

Autoclaves are commonly used to perform steam sterilization of medical equipment and to
dispose of regulated medical waste. It is unknown however, whether the standard practices for
steam sterilization (121 C for 15 minutes) are sufficient to kill pathogens bound inside porous
materials like BDR. This project will test the performance of a commercial autoclave while
processing BDR materials (carpet, ceiling tile, wallboard) packaged using various methods.
Thermocouples will be used to measure the temperature of the BDR inside the autoclave and
biological indicator strips containing Geobacillus stearothermophilus spores placed inside the
bundles of BDR will be used to verify sterilization levels.


The U.S. EPA's NHSRC initiated an R&D program to address issues related to disposal of
residue resulting from decontamination of buildings after a terrorist attack with chem./bio agents
or TICs. The target audience for this program will be: 1) the emergency response personnel who
have to make decisions about decontamination methods and disposal of the resulting residues; 2)
state and local permitting agencies, who have to make the decisions about which facilities will be
allowed to dispose of the materials; and 3) the waste management industry, that needs to be able
to safely dispose of the building decontamination residues without affecting the operation of its
facilities and without violating any of its environmental permits.



1.	Homeland Security Presidential Directive Number 7, Critical Infrastructure Identification.
Prioritization, and Protection,

2.	Homeland Security Presidential Directive Number 8, National Preparedness.

3.	Homeland Security Presidential Directive Number 9, Defense of United States Agriculture and

4.	Homeland Security Presidential Directive Number 10, Biodefense for the 21st Century.

5.	U.S. EPA, Report on the Homeland Security Workshop on Transport and Disposal of Wastes
From Facilities Contaminated With Chemical or Biological Agents. EPA/600/R-04/065,
November 2003.

6.	Lee, C.W., Wood, J.P., Betancourt, D., Linak, W.P., Lemieux, P.M., Novak, J., "Study of
Thermal Destruction of Surrogate Bio-contaminants Adsorbed on Building Materials," submitted
- Air and Waste Management Association's 98th Annual Conference & Exhibition; Minneapolis,
MN, June 21-24, 2005.

7.	Serre, S.D., Lee, C.W., Lemieux, P.M., "Disposal of Residues from Building Decontamination
Activities: Desorption of Chloro-Ethyl Ethyl Sulfide (CEES) and Dimethyl-Methyl Phosphonate
(DMMP) from Building Materials," submitted - Air and Waste Management Association's 98th
Annual Conference & Exhibition; Minneapolis, MN, June 21-24, 2005.

8.	Lemieux, P.; Stewart, E.; Realff, M.; Mulholland, J.A. (2004), "Emissions Study of Co-firing
Waste Carpet in a Rotary Kiln," Journal of Environmental Management, Vol. 70, pp. 27-33.

9.	Lemieux, P., "Pilot-Scale Combustion of Building Decontamination Residue," submitted - Air
and Waste Management Association's 98th Annual Conference & Exhibition, Minneapolis, MN,
June 21-24, 2005.

10.	Denison, M.K., Montgomery, C.J., Sarofim, A.F., Bockelie, M.J., Magee, R., Gouldin, F.,
McGill, G., "Detailed Computational Modeling of Military Incinerators," presented at the 20th
International Conference On Incineration and Thermal Treatment Technologies, Philadelphia,
PA, May, 2001.

11.	Denison, M., Montgomery, C., Zhao, W., Bockelie, M., Sarofim, A., Lemieux, P.,

"Advanced Modeling of Incineration of Building Decontamination Residue," submitted - Air
and Waste Management Association's 98th Annual Conference & Exhibition; Minneapolis, MN,
June 21-24, 2005.

12.	Segall, R.R., G.C. Blanschan, W.G. DeWees, K.M. Hendry, K.E. Leese, LG. Williams, F.
Curtis, R.T. Shigara, and L.J. Romesberg, "Development and Evaluation of a Method to
Determine Indicator Microorganisms in Air Emissions and Residue from Medical Waste
Incinerators," J. Air Waste Manage. Assoc. 41: 1454-1460, 1991.