Document xzZjRKoy1QQZO1qQqj3D349EG
PRODUCT AEEA: DUPON ^
CLOSING REPORT
AR226-2734
ADDENDUM #1 ^ FINE POWDER / DISPERSION
AUTHOR TLMAYLE-B168,WW SCION-CROP 14-1286
^ye^svs^______
TANO. T-4655 OPERATION: PRODUCT: _ ISSUE DATE:.
EEV. 2
PAGE 1 OF 12
&
ROCESS WASTE DISPOSAL
9/26/97
ST ACCOUNTING:
MTE
COST OF TEST:
AMT OF PRODUCT:,
REF. TA'S: _______N/A
E3 MDV Q
N/A 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 CLOSING REPORT 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, Att 1, "Checklist for Managing Changes")
Are any of the recommendations from this TA being commercially implemented? D Yes E! No
If yes applies to only SOME of the recommendations, list them below for tracking purposes.
Date TA Completed:_ Date CR Written: CR Submitted. By:
_
CS.465 SKI-ADD l.DOC
RESPONSIBILITY FOR FOLLOW-UP:
2/01/97
Approvals:
4/16/97
i^.'^^ C.K. DILLON. ^
Authorization:
S^mpssnySanitized. Does noiconiam TSCA CBl
OLYMERS
CONCLUSIONS:
SEE ATTACHED.
CLOSING REPORT T-4655 (ADDENDUM 51)
REVISION NO.: : PAGE 2 OF 12
DATE ISSUED: 9/26/97
RECOMMENDATIONS):
SEE ATTACHED.
DISCUSSION:
SEE ATTACHED.
ANALYSIS OF CHAN'GE: SEE ATTACHED.
Environmental Impact (Optional):
N/A
Waste Impact (Optional): N/A.
Effect on Advertising Claims (Optional): Energy tffect/lltilities Effect (Optional):
N/A.
N/A
Cost Accounting (Optional): N/A
Patent Situation (Optional): N/A Attachments (Optional): N/A
SUMMARY;
On January 1,1996, waste disposal ceased at the DuPont Letart Landfill- This landfill was the primary waste
theflf^BTO disposal point for
non-RCRA
waste.
This waste was generally made up of waste
r^HRj 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 me C-8 contaminated waste. Waste not contaminated with C-8 would be disposed in
the DuPont Dry Run Landfill. In order to effectively implement these new landfill requirements, a team was developed which was made up of representatives from the variousy^UbJAreas. 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.
OU655R2-ADDI.DOC
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CLOSING REPORT T-+655 (ADDENDUM #1) REVISION NO.: 2 PAGE 3 OF 12
ISSUED: 9/26/97
_____________DATE
'Various samples of process -waste were tested and evaluated for C-8 levels to determine which waste needed
1.0 be disposed at the Emelle Landfill and which waste co-uld be disposed at the Dry Run Landfill- Tables for each area were constructed which listed the waste and the required disposal point This information was then incorporated into the BTO Waste Disposal Manual.
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 acco-unting for waste sent to the Emelle Landfill is based on a user-pay system. Loadsheets break-down shipments by building number/area, andjhese loadsheets are then used to distribute the invoiced disposal
costs for each load. In 1996, ^|ilHH|disposal charges for the Emelle Land-Ell were approximately
ll^C^Fine Powder/Dispersion's portion of this was appioximateh^l(BBBH(^
The ground water and surface water at the Dry Run Landfill are tested for C-8 levels on an annual basis. Testing has been completed only once since^lUkBjbegan using this landfill; therefore, no conclusions have been drawn from. this test data.
CONCLUSIONS:
The drum. packaging procedures and/or 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 fee waste drums. gBJ------i----ilg by: 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 Crouuthat empty Triton containers can be disposed in Dry Run Landfill. i12/31/97
CR.463iR2-ADDl.rx3C
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'OLYMERS
CLOSING REPORT -M655 (ADDENDUM #l) REVISION NO.: 2
PAGE 4 OF 12
DATE ISSUED: 9/26/97
prscirssroN:
ISCorporate Management elected to dispose of C-8 containinated wastes in contained landfills. For ^Washington Works, the Emelle Treatment Facility in Emelle, Alabama -was chosen as the disposal
lo_ca_t_ion for 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 determine 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
and^fm| quantitative limit for C-8 levels in waste to be disposed at Dry Run. The Environmental Group
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 Run 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 mat 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.
In order to implement the change in disposal practices, procedures were written for packaging and labeling of Emelle and Dry Run wastes. Properly packaged drums (ie. at least 90% full and no free liquids) is a requirement in order for the drums to be landfiUed. The Emelle Facility inspects each drum, and it 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 me 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 drums for proper packaging and labeling. Once this was completed, a date inspected label was attached to
the drum and initialed. If drums were moved to the storage area without the label, the warehouse notified
the area or moved the drums back to the area until the problem was corrected. This appears to have been only partially successful; some drums still contain tree 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 drums 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.
CR.465502-ADDI.DOC
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POLYMERS
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 fining drums wife 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. is^--UThis is the cost that is charged if the drummed waste is properly packaged (i.e. no free
^mSl^ 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 oqJI^per drum. During 1996, Fine Powder/Dispersion disposed ofpBlfidruins gndjUHpaper rolls at Emelle for approximately
It is estimated that the paper rolls accounted for pDBftpf this total Jpi--------BIH^B------H^
As noted previously in mis closing report/Yl------^non-C-Ssolid waste disposal in me Dry Run Landfill
began in January, 1996. The C-8 levels at the 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 thep----Rnvaste 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 Run LandfilL As such, no recommendations have been made at this time regardingRlfWwaste 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.
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CR4555R2-ADDLDOC
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DUPONTI^--------PIIOLYMERS
kAreas
CLOSING REPORT T-t655 (ADDENDUM #1) REVISION NO.; 2 PAGE 6 OP 12
DATE ISSUED: 9/26/97
ATTACHMENT 1
IMTEROF?TCB MEKORAMOUH
Data:
Froa,;
Dept; Tel MO:
05-Dec-1395 ll:29aa
CBAIG K DILLOH DILLOHCK
?luoroproducts 304-853-4972
TO; Distribution List
Subject: Mealing Holes -- c-8 at Dry Run
^A1--ne--a--tinPgMGawsats*
held that
on
is
Hoveabar proposed
30
to
to
be
discuss the acceptable
landfilled at Dry Run.
CT-3hoslee vinis
for
(anted data an various) lfor C-a levels*. DetaJ Ho. BS6S38 pagw 123 N------1
r*frnc xtraction data-rumisi SujDMiry of the data is as follows:
vast* axpl-- that Mr xtracta th^. saMplas jxtract^d ar racordad in
_byJ-Qu[al^li^t--y --An--acljyatliscoalpLraobviodnilbaios-cak*.
OBSCHTPTTO^
Pint; --jrfder Trench Scrap -- undried
POLYMER
C-a LEVBL
PPH
59
WiTSR BXTSACTIOM
BXTSACT2D C-a LS7KL ______PPM*<
0 .44
Granular Vacuur System Scrap - dry '
2
0.08
PPA fron Process K test dryer-- dry
11
?EP-4100 froa Line 3 - dry
7
0 .04 0.04
1 ppa blank
1-04
Bio-caSce sanple (Quality Analytical) 0.5-1.0
0 .004
Jnotad that the extraction aethod used by Quality Analytical differed Ero the nathod used by Doughty. Based on the extraction of the'bio-caka, Weber indicated that approxiBataly 7 pounds per year of c-a is currently landfilled at Dry Run due to bio-cafca-
Based on the teat results, tha group agreed that Granular scrap can b
landfilled at Dry Run. In addition, any xelted acrap EPA or rSB can be
iTOdfilled at Dry Run. 7or PPA, this would b crap satarial genaratad at
the exit aide of the extruder and beyond (generally cubes) . Tor TSP, this
would be scrap aterial generated at the exit side of the huid heat traater
and beyond
group that
(generally slabs, shred, cubes). the potential landfill-amounts of
It vas the consensus of the
these scrap Materials auld
not
significantly iapact C-8 levels at Dry Run.
For fine Powder/Dispersion, no process scrap Mill be allored 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
CR4655R2-ADD l.DOC
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OLYMERS
CLOSING REPORT T-4655 (ADDEM3UM #1) REVISION NO.: 2 PAGE 7 OF 12
DATE ISSUED: 9/26/97
separation of C-8 Povdar/Dispersion
and non-C-a crap. xf aust ba disposed, then
at hliasr gsea taexroi auln ts hoCo uflidn ibseh et eda tainda sor
C-a and handled on_an individual basis. group that|B------)continua to drive tha
It was also
aala of ail
tha consensus of the
scrap to raduce t&a
need ror landrilling.
lit Concern was
to landfill
also raixad
at tey yam.
regarding a liat o wtwsials tluittip----Rft] intends
VttiM 1I1; & autaBitted to tl Bmrtronaental crouo
for review. A KeetioQ i olazuied for Oecexber 6 between
*
BnvlronaentalXrerloiiyteo disco--ion) wizi be Bade
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till*
(tor
the acting.
Please let *e Imow
anything diacuased
if
at
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left
eting
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any ank-
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* Dupont Kegiatered Tradeaarfc
** Detection liait of test i 0.1-1-0 pp
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CLOSING REPORT T-1655 (ADDENDUM #1) REVISION NO.: 2 PAGE 8 OF 12
_____ DATE ISSUED: 9/26/97
ATTACHMENT 2
TCTCTuotfUEfum.afenaiUN wA^ie IAHLJ:
ACCEPTABLE WASTE FOR DRY RUM LANDF1LL
WASTE DESCRIPTION
GENERAL PAPER TRASH. CAKOBOKWO. PPE
LA
J55
Hi
S
i
S
5
-
SSLwj
-'J
EST. YEARLY QUANTTTY
~----^
-
SPECIAL PREPARATION REQUIREMENTS
NO GLASS
WATER WASH ANY RAW MATERIAL UEVERPAIQ. EMPTY LEVERPAXS SHOULD THEN BE MOVED TO THEf------ei 84
CONTAINER FOR DISPOSAL
GENERAL. PLANT TRASH
ROUTINE PICX4JP WILL BE
MAoeaYpM. piawaj.
'
CRUSHPRIORTO LANOF1UJNO
RNE POWDER/DISPERSION WASTE TABLE WASTE FOR EM6LLE LANDRLL
WASTE DESCRIPTION
EST. YEARLY SPECIAL PREPARATION
^QUANTITY <s,
REQUIREMENTS
CONTAINER FOR DISPOSAL
TANKS WASTE
WAX oecAweR WASTE
^vSS^
w
>
NO FREE LIQUIDS NO FREE LIQUIDS
DRUM
RED 5&GAU.ON STEEL DRUM
SCRAP POWUEK FROM COAGULATORS. SUMPS. SCREENS
----
NO FREE UQUIDS
PLASTIC LINED RED 5S. GALLON STEEL DRUM
SCRAP POLYMER FROM DRYERS. PAPER BREAK3, CLEANINGS
EMPTY nUTON CONTAINERS
SUPERMATE TANK BOTTOMS
QISPERS10N COAGUUJM, PACXOUT FILTERS. OeCANTER CLEAN1NQ3. TANK CLEANINGS
------
-^
--------^
NONE NONE NO FREE UQUIDS NO FREE UQUIOS
REO S5-GAU.OM STEEL DRUM
RED 56-GAU.ON STEEL DRUM
RED5&GAU.ON STEEL ORUM
RED 35-GALLON STEEL DRUM
USEO FP DRYER PAPER HtVWaTEMFB.TERS
ONE-WAY TOTES
EMPTY/FUU. SAMPIE BOTTtESfflAGS CONTAINING
POlfMeWlMSPERSION
----M --
-
NONE
NONE
WATER WASH TO SUPERNATE SUMP TO REMOVE HEELS. TOTES MUST THEN BE CRUSHED
LOAD ROLLS ON BOX TRAILER
BULK FIBRE PACKS OR RED SB-GALLON DRUMS
PALLET1ZEO AND STRAPPED
NONE
RED SS-SALLON STEEL DRUMS
D1SPEH3K3M DRUM UNER3
---- L
REMOVE UNER FROM LEVERPAK3. NO FREE LIQUIDS
RED 3SGAU.ON STEEL DRUMS
CR4655R2-ADD1JDOC
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DUgpNTjp------JPIOLYMERS
CLOSING REPORT T-4655 (ADDENDUM i?l) REVISION NO.: 2 PAGE 9 OF 12
DATE ISSUED: 9/26/97
LOADING DATE:
ATTACHMENT 3
EMELLE LOADSHEET
(ExainpK only) .ORDER fc
SEAL:
Building & AREA
NUMBER OF
DRUMS
B22 RESEARCH LAB
B23 BEAD FACILITY
-
8184^1----------\
L
^
B162 FINE POWDER/DISPERSION (DRUMS) B162 FINE POWDER/DISPERSION ftOF PAPER ROLLS)
B163 FEP
B164 GRANULAR
B177. B162M MONOMERS
B180TELOMERS
1 ill II113----------------------------
Note: FORWARD COMPLETED SHEET TO THE PRODUCT ANALYST IN B170
FomiApprovat OuPont R^rtmd Tnctenrt
OBta:
CK.46S5Kl-ADm.DOC
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DUTONTJy----Hg) POLYMERS
ATTACHMENT 4
CLOSING REPORT T-4655 (ADDENDUM #1)
REVISION NO.; 2 PAGE 10 OF 12
____
DATE ISSUED: 9/26/97
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CR4655R2-ADD1.DOC
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9/26/97
