Paper to be presented at AWMA Symposium on Air Quality Measurements and Technology, May
9-11, 2006, RTP, NC.

EPA'S HOMELAND SECURITY WASTE DISPOSAL RESEARCH: STATUS UPDATE

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

ABSTRACT

Significant quantities of waste are generated during building decontamination operations
performed after terrorist attacks involving biological weapons, chemical weapons, or toxic
industrial chemicals. These waste streams may include aqueous solutions, furniture, ceiling tiles,
wall hangings, carpeting, and personal protective equipment from the cleanup crews, and may be
contaminated with residual agents at varying, possibly unknown, levels. The safe disposal of
these materials involves a combination of careful packaging, transportation, treatment, and
disposal. This paper gives a status update on the U.S. Environmental Protection Agency's
program of laboratory-, bench-, and pilot-scale research and development of guidance documents
directed at the safe disposal of building decontamination waste.

INTRODUCTION

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]:

After a building or contaminated area 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 "decontamination residue" (DR). Although it is likely that the
DR 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. It is also possible that some
of the DR was removed from the contaminated site prior to being decontaminated. 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 buildings.
In addition, there may be additional contaminated materials such as carbon adsorption beds and
high-efficiency particulate arrestant (HEPA) filters from a 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.

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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; and

•	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 DR disposal [5] from buildings. In response to this
workshop, DCMD initiated a research program [6] to 1) consolidate available information and
lessons learned for DR 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 of the DR
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
Administration (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 DR without affecting the operation of its facilities and without violating any of its
environmental permits.

The issues related to disposal of DR 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 is summarized 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

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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

Information

Source

Regional capacity/locations of disposal facilities

EPA/OSW, EPA/OAQPS,
ASTSWMO, IWSA, NSWMA,
SWANA

Incinerator design/operation criteria

ASME, AWMA, CRWI,
IWSA, EPA/O SW,
EPA/OAQPS

Landfill design/operation criteria

EPA/O SW, NSWMA, SWANA

Transportation and packaging

DOT, CDC

Environmental regulatory issues

EPA/O SW, EPA/OAQPS,
ASTSWMO

Worker safety issues

CDC, NIOSH

Thermal destruction behavior of CW/BW contaminants in DR

DoD, Experiments, modeling

Landfill behavior of CW/BW contaminants bound in DR

Experiments, modeling

Performance of autoclaves on contaminated DR

Experiments

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

PROGRAM DETAILS

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

Estimation of DR quantities and characteristics;

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

Contact info for the potential disposal facilities;

Expected behavior of the DR in the selected facility;

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

Packaging to minimize risk to workers handling the DR, 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 DR;

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; and
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,
including information such as the behavior of CW/BW agents bound on DR in a landfill or
incinerator environment. Table 2 lists the various components of DR 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

DR Substrates

CW agent simulants

BW agent simulants

TICs

Brick

Dimethyl methyl

Bacillus subtilis

Monochl orob enzene

Concrete

phosphonate (DMMP)

Geobacillus

Malathion

Carpeting
Ceiling tiles
Wallboard

Chloroethyl ethylsulfide
(CEES)

Ethylene glycol

stearothermophilus



Particle board







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

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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 [7] and the adsorption/desorption of surrogate chemical agents [8]
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 DR.

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 [9], and on destruction of spores bound in carpeting [10],

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Modeling of DR in Incineration Systems

In order to minimize problems associated with thermal destruction of CB-contaminated DR,
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 [11], 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 [10]
have been promising [12],

Sampling and analytical methods development

Since the releases of biological contaminants from 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 [13]
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; and

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 DR. This project [14] tested the performance of a commercial autoclave while
processing DR materials (carpet, ceiling tile, wallboard) packaged using various methods.
Thermocouples were used to measure the temperature of the DR inside the autoclave and
biological indicator strips containing Geobacillus stearothermophilus spores placed inside the
bundles of DR were used to verify sterilization levels. It was found that porous building
materials are difficult to disinfect in an autoclave using standard autoclaving practices. It
appeared that the steam condensed in the cold materials when the materials were initially
exposed to the autoclave conditions, and the resulting condensate in the pores inhibited steam
penetration. Longer exposure times were required to assure no growth in the biological
indicators. Multiple sequential autoclave cycles were particularly effective at assuring no growth
in the biological indicators, suggesting that the evacuation cycle in the autoclave's second cycle
pulled the condensate out of the pores of the building materials and enabled effective steam

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penetration into the materials in the second cycle, because they were pre-heated during the first
cycle, and condensate did not fill the pores during the second cycle.

SUMMARY

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.

REFERENCES

[1]	Homeland Security Presidential Directive Number 7, Critical Infrastructure Identification.
Prioritization, and Protection, http://www.whitehouse.gov/news/releases/2003/12/20031217-
5.html

[2]	Homeland Security Presidential Directive Number 8, National Preparedness.
http://www.whitehouse.gov/news/releases/2003/12/20031217-6.html

[3]	Homeland Security Presidential Directive Number 9, Defense of United States Agriculture
and Food, http://www.whitehouse.gov/news/releases/2004/02/20040203-2.html

[4]	Homeland Security Presidential Directive Number 10, Biodefense for the 21st Century.
http://www.whitehouse.gov/news/releases/2004/04/20040428-6.html

[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]	Lemieux, P. (2004), "EPA Safe Buildings Program: Update on Building Decontamination
Waste Disposal Area," EM, Vol. 29-33.

[7]	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.

[8]	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.

[9]	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.

[10]	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.

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[11]	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.

[12]	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.

[13]	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.

[14]	Sieber, R.; Osborne, A. (2005), Destruction of Spores on Building Decontamination
Residue in a Commercial Autoclave, EPA/600/R-05/081 May 2005.

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