Document pB5K68D13oaqZkXb8RE9eGjEj

PRODUCT AREA: . X* m -,, CLOSING REPORT ADDENDUM #1 AR226-2734 FINE POWDER / DISPERSION AUTHOR TL MAYLE - B168, WW SCION- CRD P 14-1286 TANO. T-465S REV. 2 PAGE I O F 12 ST ACCOUNTING: MTE K! MDV OPERATION:______T j S I H B S H B H i l A ----_______________ COST OF TEST:---------N7----- PRODUCT: `-PROCESS WASTE O ISIFS AL ... AMT OF PRODUCT:------------- N/A----- ISSUE DATE:_______ 9 / 2 6 / 9 7 ________ ;____________ REF. TA'S :__________ N/A -----------------.-- PURPOSE: TO SEPARATE AND PROPERLY DISPOSE OF C-8 CONTAMINATED PROCESS WASTE AND NON-C-8 WASTE- REASON FOR ADDENDUM: IN THE INITIAL CLOSINGREPORT THE RECOMMENDATIONS WERE INADVERTENTLY LISTED AS CONCLUSIONS. THIS ADDENDUM NOW INCORPORATES THE PROPER CONCLUSIONS. SUMMARY: ATTACHED. DISPOSITION OF PRODUCT: N /A PSM/FOS FOLLOW-UP: (Ref. FQS Manual, Procedure 11, A tt 1, "Checklist for Managing Changes") Are any of the recommendations from this TA being commercially implemented? Yes 3 No . If yes applies to only SOME of the recommendations, list them below for tracking purposes. Date TA Completed Date CR tVritten: CR Submitted By: CR465 5K2-ADD l.DOC jpoiDpanjr Sanitized Does not contain TSCA CBl DUPONT^eeeei 'OLYMERS AJl^flHMAxeas CONCLUSIONS: SEE ATTACHED. CLOSING REPO RT T-4655 (A DD END UM *1) REVISION NO.: 2 PAGE 2 OF 12 DATE ISSUED: 9/26/97 RECOMMENDATIONS): SEE ATTACHED. DISCUSSION: SEE ATTACHED. ANALYSIS OF CHANCE: SEE A TTA C H E D . Environmental Im pact (Optional): N /A W aste Impact (Optional): N/A Effect on Advertising Claims (Optional): N /A Enemy Effect/Utilities Effect (Optional): N/A Cost Accounting (Optional): N/A P atent Situation (Optional): N/A Attachments (Optional): N/A SUMMARY: On January 1 ,1996, waste disposal ceased at the DuPont Letart Landfill This landfill was die primary waste disposal point for t h e n o n - R C RA waste.' This waste was generally made up of waste containing C-8 and waste not containing C-8. Corporate Management elected to dispose of C-8 contaminated waste in a contained landfill. A hazardous waste landfill in Emelle, Alabama was selected as the disposal point for the C-8 contaminated waste. Waste not contaminated with C-8 would be disposed in the DuPont Dry Run Landfill In order to effectively implement th^ e new landfill requirements, a team was developed which was made up of representatives from the various^pm pjA reas. The primary products of the team were Determining what waste in each area needed to be sent to the Emelle Landfill and what waste was acceptable for the Dry Run Landfill, Developing procedures/practices for packaging C-8 contaminated waste and packaging waste not contaminated with C-8, and Developing a system for tracking each areas' costs associated with solid waste disposal at the Emelle Landfill. CR4655R2-ADDl.DOC Company Sanitized. Does not contain TSCA CBI 9/26/97 ``D U FO N TnB B P O L Y M E R S A il^ p n tS lV re as CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.: 2 PAGE 3 OF 12 DATE ISSUED: 9/26/97 'Various samples of process waste were tested and evaluated for C-8 levels to determine which waste needed <.obe disposed at the Emelle Landfill and which waste could be disposed at the Dry Run Landfill Tables for each area were constructed which listed the waste and the required disposal p o in t This information was then incorporated into the BTO Waste Disposal M anual A general procedure was written for all areas for packaging C-8 contaminated waste and for packaging waste not contaminated with C-8. Any area specific requirements were included in the procedures for the specific area. Initially the areas were not diligent in complying with the procedures; therefore, the procedures were modified to require drum inspection and inspection sign-off within each area. Cost accounting for waste sent to the Emelle Landfill is based on a user-pay system. Loadsheets break-down shipments by building number/area, and these loadsheets are then used to distribute the invoiced disposal costs for parh load. In 1996, j^ H H B d i s p o s a l charges for the Emelle Landfill were approximately ^ Fine Powder/Dispersioris portion of this was approximately The ground water and surface water at the Dry Rim Landfill are tested for C-8 levels on an annual basis. Testing has been completed only once sinceJpHfcS^began using this landfill; therefore, no conclusions have been drawn from this test data. CONCLUSIONS: The drum packaging procedures an d /o r practices developed in this TA do not ensure that all drums from all areas will be at least 90% full and have no free liquid when they arrive at the Emelle Landfill ' The accounting system developed for tracking Emelle Landfill costs on an area-by-area basis is acceptable. RECOMMENDATIONS: Continue to use the waste packaging/inspection process outlined in this TA and incorporate the procedures into the Fine Powder/Dispersion operating procedures. Resp. Include as part of the procedures the requirement to wear a Comfo II respirator _with GMAH cartridge when adding absorbent to the waste drums. 9 H W H I b y : 12/31/97 Change Waste Disposal Manual for Fine Powder/Dispersion wastes to include all required drum labeling information for Emelle and Dry Run Drums. Also verify with the Site Environmental Group that empty Triton containers can be disposed in Dry Run Landfill. r ^12/31/97 CR4635R2-ADD1.DOC Company Sanitized. Does not contain TSCA CB1 9/26/97 dupontj&b b m polymhrs A ll M B Areas CLOSING REPORT TA 655 (ADDENDUM #1) REVISION NO.: 2 PAGE 4 OF 12 _______________ DATE ISSUED: 9/26/97 DISCUSSION: S jrporate Management elected to dispose of C-8 contaminated wastes in contained landfills. For ashington Works, the Emelle Treatment Facility in Emelle, Alabama was chosen as the disposal : C-8 contaminated wastes. The landfill at the Emelle Facility has a double liner and leachate collection system. The facility is a permitted secure hazardous waste treatment, storage and disposal facility. To detexxnine the wastes that needed to be sent to Emelle for disposal (C-8 contaminated wastes), sample testing and process experience were utilized. The Washington Works Environmental Group had no defined quantitative limit for C-8 levels in waste to be disposed at Dry Run. The Environmental Group a n d H | H Representatives did define process "dividing points" for C-8 versus non C-8 material. Attachment No. 1 summarizes test data and defines process dividing points. Since C-8 is used extensively in the Fine Powder/Dispersion process, no process scrap from this area will be disposed in the Dry Rim Landfill without conducting C-8 testing and obtaining approval from the Environmental Group. Using this information, waste tables were generated for each area which list the disposal point for the area's wastes. The waste tables for Fine Powder/Dispersion are in Attachment No. 2. This information was incorporated into the BTO Waste Disposal Manual No. 30 in mid-1996. Review of this information for Fine Powder Dispersion shows that the tables do not contain all of the drum labeling requirements for Emelle and Dry Run wastes. In addition, the manual indicates that empty Triton containers can be disposed at Dry Run, whereas the TA waste tables indicate that these containers must be disposed at the Emelle Landfill. La order to implement the change in disposal practices, procedures were written for packaging and labeling of Emelle and Dry Run wastes. Properly packaged drums (Le. at least 90% full and no free liquids) is a requirement in order for the drums to be landfilled. The Emelle Facility inspects each drum, and if the drum is not properly filled, the deficiency is corrected at Emelle for an additional charge. Initially, the procedures were written such that the areas packaged and labeled the waste, and the warehouse personnel inspected the drums for packaging/labeling deficiencies. This approach was unsuccessful as some areas were not diligent in following the procedures. As a result, the waste drum inventory destined for Emelle occasionally built to over 500 drums as the drums were held waiting on deficiency corrections. In an effort to improve the packaging/labeling process, the procedures were modified to require inspection by the areas. Prior to moving material to the drum storage area, each area was required to inspect individual drams for proper packaging and labeling. Once this was completed, a date inspected label was attached to the dram and initialed. If drums were moved to the storage area without the label, file warehouse notified the area or moved the drums hack to the area until the problem was corrected. This appears to have been only partially successful; some drums still contain free liquid and are not at least 90% full when they arrive at the Emelle Landfill. It is believed that drums less than 90% full can be attributed to settling during transit and/ or inadequate filling of absorbent Drums with free liquid may be partially attributed to separation during transit, however, limited dewatering capabilities in the areas has been cited as the more likely cause. Gravity separation has generally been used to dewater the waste, and it is recognized that this process is not always effective for some types of waste. The number of drams that needed additional filling/ dewatering at Emelle in 1996 was typically less than 20% (18 drums) of each shipment. For the first 3 months of 1997, this number increased to 25%-30% (22-26 drums). No recommendations have been made regarding improvements to the dewatering/packaging facilities used within the areas. Each area will have the ability to monitor Emelle disposal costs and the area can make improvements to their processes if viable. For Fine Powder/Dispersion, drums prepared for Emelle should be periodically audited to ensure that drums are being packaged according to the procedures. CR465JR2-ADD1.DOC Company Sanitized. Does not contain TSA CBI 9/2SS7 DUPONT P POLYMERS A l l f p i R Areas CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.; 2 PAGE 5 OF 12 DATE ISSUED: 9/26/97 Review of the drum preparation process has also shown that respiratory protection will be required for packaging the Emelle waste. It has been noted by area operators that the absorbent used to top-off drums generates dust when poured into the drums. In order to provide adequate protection from the dust components, a Comfo II (or approved equivalent) with GMAH cartridges will be required to be worn by the operator when filling drums with absorbent This requirement will be included as part of the operating direction update. The cost accounting system for the Emelle Landfill costs was developed based on a "user pay" philosophy. Warehouse personnel tabulate drum information on loadsheets as the trailer is loaded for shipment to Emelle (Attachment No. 3). This loadsheet is forwarded to the Accounting Group and is used to distribute the Emelle Landfill invoice costs for the shipment. A typical Emelle invoice is shown in Attachment 4. The drum and cost data are tabulated by the Accounting Group on a spreadsheet (Attachment No. 5). The current disposal costs (per unit) for the Emelle Landfill are listed in Attachment No. 6. The base disposal cost per drum isMMThis is the cost that is charged if the drummed waste is properly packaged (Le. no free liquids and at least 90% full). If a drum has free liquid, the waste in the drum is "solidified" at Emelle at a cost of $165/ drum. If a drum is less than 90% full, absorbent is added at a cost ofjjPHj^per drum. During 1996, Fine Powder/Dispersion disposed o fjijH ^d ru m s gnd fijjfeiaper rolls at Emelle for approximately \It is estimated that the paper rolls accounted for this total [ As noted previously in this closing report,|||BBH^non-C-8 solid waste disposal in the Dry Run Landfill began in January, 1996. The C-8 levels at me Dry Run Landfill are monitored in the ground water and irface water (leachate) on a yearly basis. Ground water tests completed in April 1996 showed C-8 levels of -10 ppb. Likewise, tests completed in June of 1995 showed C-8 levels of 9-10 ppb. Studies have shown that ground water moves only about 2 feet per year at Dry Run; therefore, ground water testing for C-8 levels is likely to be inconclusive for many years. On the other hand, surface water tests should be able to provide some indication within a few years as to whether or not th^jlHHHBjwaste is significantly increasing the C-8 levels at Dry Run. In April of 1996, surface water testing showed C-8 levels of 86 ppb, compared to levels of 53 ppb shown in June of 1995. It is unknown if this change in surface water C-8 levels is statistically significant. The Washington Works Environmental Group does not believe these results currently warrant any changes in the waste flow stream to Dry Rim Landfill As such, no recommendations have been made at this time regarding^BjPHBPjjsvaste disposal practices at the Dry Run Landfill Analysis of Change: As noted in the discussion of this closing report, additional respiratory protection will be required when adding absorbent to the drums. No other new safety or health issues were observed that were a result of running this TA. CR4655R2-ADD1.DOC Company Sanitized. Does not contain TSCA CBl 9/26/97 D U P O N T ^ p B n ^ i POLYMERS Areas " CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.; 2 PAGE 6 OF 12 DATE ISSUED: 9/26/97 , ' ATTACHMENT 1 INTEROFFICE MEMORANDUM Data: From: Dept: T*X No: 05--Dec-199S ll:29aa CRAIG K DILLON DILLONCX Fluoroproducts 304-853--4972 TO: Distribution List Subject: Heating Notas -- C-8 at Dry Run A meeting was held on Noveaber 30 to discuss the acceptable C-3 levels for waste that is proposed to be landfilled at Dry Run ._ Those in ^attendance weraf " anted data on v a r i o u s M n _ _ _|or C-8 levels. Details bodiro. SS5538 page 123 reference extraction d a t a ' T u m i s h Susaary of the data is as follows: waste samples that ware extracted ~ tracted ara recorded in tlso provided as ty Analytical Lab on bio-cake. SAHELS DESCRIPTION 150-1 Fmt :=/der Trench Scrap -- undried POLYMER HATER EXTRACTION C-8 LEVEL EXTRACTED C-8 LEVEL ___ EEH___ _______ PPM**_______ 59 0.44 150-2 Granular Vacuum System Scrap - dry ` 2 0.03 150-3 PFA from Process K test dryer.- dry 11 0.04 150-4 FEP-4100 froa Line 3 - dry 7 0.04 150-5 1 ppm blank - 1.04 NA Bio-cake sample (Quality Analytical) 0.5- 0.004 J j H H K not:ad that the extraction method used by Quality Analytical differed rroa the sethod used by Doughty. Based on the extraction of the bio--cake, Weber indicated that approximately 7 pounds per year of c-8 is currently landfilled at Dry Run due to bio-caka. Based on the test results, the group agreed that Granular scrap can be landfilled at Dry Run. In addition, any melted scrap PPA or PEP can be landfilled at Dry Run. For PFA, this would be scrap material generated at the exit side of the extruder and beyond (generally cubes) . For FEP, this would be scrap material generated at the exit aide of the humid heat treater and beyond (generally slabs, shred, cubes). It was the consensus of the group that the potential landfill amounts of these scrap materials would not significantly impact C-8 levels at Dry Run. * For Fine Powder/Dispars ion, no process scrap will be allowed at Dry Run. This was based on the test results and also on process configuration. There is concern that the process configuration would not allow for distinct CR4555R2-ADDi.Doc Company Sanitized. Does not contain TSCA CBI 9/25/97 DU ILYMERS AIL CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.: 2 PAGE 7 OF 12 DATE ISSUED: 9/26/97 separation of C -8 and non-C-8 scrap. If a large amount of finished rin,, Povdar/Disporaion aust be disposed, then this material should be tested tor- C -a and h a n d l e ^ o n an individual basis. It was also the consensus of the group thatB0I^MP)continua to drive the sale of all scrap to reduce the need for landfilling. . Concern was also raised regarding a list of materials that W M B } intends to landfill at Dry Run. This list was submitted to the Environmental Groun for review. A meeting is planned for December 6 between * K n v i r o n ^ t a i ^ j f l o d i T t o discuss the list. A copy of this list (for discussion) will be made available to the group after the meeting. Please let m e know if I have left out a n y items or if I have misinterpreted anything discussed at the meeting. Thank-you for participating.' Craig * DuPont Registered Trademark * * Detection limit of test is 0.1-1.0 ppm CR4653R2-ADD1.DOC Company Sanitized Does not contain TSCA CBI 9/26/97 DUPOK I^ P -- 'POLYMERS Ali^BBRArcas CLOSING REPORT T-4655 (ADDENDUM #\) REVISION NO.; 2 PAGE 8 OF 12 __________________ DATE ISSUED: 9/2S/97 , ATTACHMENT 2 -- rm c r uniiUBwruraye n a ro w 'vha& ic ia u l e -- ACCEPTABLE WASTE FOR DRY RUM LANDFILL 1-- ---------------------------------WASTE DESCRIPTION GENERALPAPERTRASH. CARDBOARD. PPE EST. YEARLY SPECIAL PREPARATION QUANTITY REQUIREMENTS CONTAINER FOR DISPOSAL NO GLASS GENERALPLANTTRASH DUMPSTER WATERWASHANYRAW MATERIALUEVERPAK3.EMPTY LEVERPAK3 SHOULDTHENBE MOVEDTOTM EBpaaAlM paoT Cl ROUTINEPICKUP WILLBE MA0E8YPSS. P*3 WHO. ` CRUSHPRIORTO LANDFILLING FINE POWDER/DiSPERSSON WASTE TABLE WASTE FOR EMELLE LANDFILL WASTE DESCRIPTION EST. YEARLY SPECIAL PREPARATION ^QUANTITY X , REQUIREMENTS SCRAP WAX AND POLYMER BLEND TANKS WASTE N O FR E E UQUIDS WAX DECANTER W ASTE NO FR E E UQUIDS CONTAINER FOR DISPOSAL RED 55-GALLON STEEL DRUM RED 55-GALLON STEEL DRUM SCRAP POLYMER FROM COAGULATORS. SUMPS. SCREENS -- N O F R E E UQUIDS PLASTIC UNED RED 5 5 . GALLON ST EE L DRUM SCRAP POLYMER FROM DRYERS, PAPER BREAKS, CLEANINGS EMPTY TRITON CONTAINERS SUPERNATE TANK BOTTOMS DISPERSION COAGULUM. PACKQUT FILTERS, DECANTER CLEANINGS, TANK CLEANINGS USED FP DRYER PAPER H4V SYSTEM FILTERS 1 in-- , --- mam* ONE-WAY TOTES EMPTY/FULL SAMPLE BOTTLES/BAGS CONTAINING POLYMERRH5PERSION __ " NONE NONE NO F R E E UQUIDS REO S5-GAULON STEEL DRUM RED 55-GALLON STEEL DRUM RED 55-GALLON STEEL DRUM NO F R E E UQUIOS RED 55-GALLON STEEL ORUM NONE LCAO ROLLS ON BOX TRAILER . NONE BULK FIBRE PA C K S O R RED 55-GALLON DRUMS W ATER W A SH TO SUPERNATE SUM P T O REMOVE HEELS. T O T E S M UST THEN B E PALLETIZED ANO STRAPPED - CRUSHED NONE RED 55-GALLON STEEL DRUMS DISPERSION DRUM U N ER 3 1 mm REM OVE UNER FROM LEVERPAK3. NO FREE UQUIDS RED 55-GALLON STEEL RUMS CR465R2-ADD1.DOC Company Sanitized. Does not contain TSCA CBI 9/26/97 mm POLYMERS CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.: 2 PAGE 9 OF 12 _________________ DATE ISSUED: 9/26/97 ATTACHMENT 3 EMELLE LOADSHEET (Scamp! only) LOADING DATE: ____________ . ORDER *: __________ SEAL#: Building & AREA B22 RESEARCH LAB B23 BEAD FACILITY L3 B162 FINE POWDER/DISPERSION (DRUMS) B162 FINE POWDER/DISPERSION (#OF PAPER ROLLS) B163 FEP B164 GRANULAR B177. B162M MONOMERS B180 TELOMERS B21 L- J ............ " NUMBER OF DRUMS - - Note: FORWARD COMPLETED SHEET TO TH E PRODUCT ANALYST IN B170 Form Approval: ____________________ Oat _ _ _ _ _ _ _ _ _ *DuPontRa^tnd Tndanaric CR4635R2-ADDI.DOC .Company Sanitized. Does not contain TSCA CBI 9/26/97 A U p B fig Areas POLYMERS 001741 -1 6 m ATTACHMENT 4 CLOSING REPORT T-4655 (ADDENDUM #1) REVISION NO.: 2 PAGE 10 OF 12 DATE ISSUED: 9/26/97 ' IIV M i SERVICE PROVIDED BY: WELLE DISPOSAL FACILITY DUPONT (PAKERSDUR6 MVT --A TT* ACCOUNTS PAYABLE PO BOX 4909 BEAUMONT DC 7 7 7 0 4 -0 0 9 C q o jj-3 n ;ro 4 970319 BEFEREIKE NO." PROFILE DESC / I T QUANTITY RATE 0000829971-01 0 C -X 12494 FLUOROPOLYMER D P S T & L W STE ORW SOLID n \m m m ODER SERVICES SOLIDIFIES DRUMS WrmSsS<B9Mt m BULK SOLIS PO# OR CQKTRACTf HOM-HAZARDOUS ADEN HOHITORINS FEE WV TONS SUMTER COUNTY FEE VY 55 GAL SVC BATE SUBTOTAL 1CCQUNTE ' trYViENT CHECK. C'iiZHdJ VI m 2smr ' ' I ' t tut ' r->C^1Tn0iw n u a a rta s a-*xatxB aa, tLrriwimao.nXB a^ Q aa Q RB4TT TO A o o rass CHEMICAL KASTE XAKAfiEKXT.IMC P.O.BOX 840606 DALLAS, DC 75284-0606 y e wwprrjTP wuto aiieiuccei O W O ttA L vote* PLEAS* PAY TWS AMOUNT CR4fiJ5R2-ADDl.DOC Company Sanitized. Does not contain TSCA CBI 9/26/97