University of Massachusetts
Environmental Health and Safety
N414 Morrill Science
Box 35710
Amherst, MA 01003-5710

January 3, 2001

Anna Stern

Department of Environmental Protection

7^th Floor, Division of Hazardous Waste

1 Winter Street

Boston, Mass. 02108

Dear Ms. Stern:

The University of Massachusetts at Amherst operates a teaching and research facility as a "Large Quantity Generator" of hazardous waste. Our EPA ID number is MAD000844670 with a facility address of, Environmental Health and Safety, N414 Morrill Science Center, University of Mass., Amherst, Mass. 01003. We currently have a contract for services for off-site disposal of hazardous waste with three vendors, Triumvirate Environmental, Safety Kleen Inc., and Clean Harbors Inc.

We are requesting an emergency license to treat four (4) separate compounds under the provisions of 310 CMR 30.861. The compounds are;

One 500 gm container of sodium amide in a glass container with a Bakelite screw top lid

One 25 gm container of benzoyl peroxide in a polyethylene container with a polyethylene screw top lid

One 100 gram container of 1- fluoro-2,4-dinitrobenzene in a polyethylene container with a polyethylene screw top lid

One 500 ml container of tert.-butoxycarbonyl azide in a glass container with a Bakelite screw cap lid

All compounds are forbidden from transportation by DOT in their current physical condition. We request permission to treat to render less hazardous and then ship as hazardous waste to an appropriate TSDF.

Physical Properties: White to olive green solid; mp 210 ^o C. Reacts violently with water, with the formation of sodium hydroxide and ammonia.

When exposed to the atmosphere, sodium amide rapidly takes up moisture and carbon dioxide. When exposed to only limited amounts, as in imperfectly sealed containers, products are formed that render the resulting mixture highly explosive. The formation of oxidation products is accompanied by the development of a yellow or brownish color. If such a change is noticed, the substance should be destroyed at once. This is conveniently accomplished by covering with excess benzene, toluene, or kerosene and slowly adding dilute ethanol with stirring

Destruction Method: Wear eye protection, nitrile rubber gloves, and laboratory coat. Work in fume hood. Cover the sodium amide with toluene or kerosene and add 95% ethanol slowly with stirring, When reaction is complete, place the solution in a separate labeled container for disposal by incineration as hazardous waste.

We propose the above method to deactivate this compound. We will use the less volatile toluene with drip-wise addition of 95% ethanol to control the rate of reaction. Temperature will also be monitored and an ice slurry mix can be used to slow the reaction if needed. The final compound will be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF

Reaction for Waste Disposal:

Physical Properties: White granulated crystals, normally supplied moistened with about 30% water; mp 103-106⁰C. Sparingly sol. in water or alcohol; sol in benzene, chloroform, ether.

Destruction Method: Wear nitrile rubber gloves, laboratory coat, and eye protection. Work in the fume hood behind a safety shield. Wet the dry benzoyl peroxide with deionized water allow complete saturation to excess. The compound can be further destroyed by adding a 10% sodium hydroxide solution while stirring (10 ml for each 1 g of peroxide) for 24 hours. The resulting sodium benzoate may be disposed as non-hazardous.

We propose to hydrate this compound to at least 50% with water. This compound will then be packaged and labeled for shipment by Triumvirate Environmental to a permitted TSDF

Reactions for Waste Disposal:

_{sodium benzoate salt}

Physical Properties: Pale yellow crystals manufactured from ether, mp 26^oC, bp 137^OC. Soluble in benzene, ether, propylene glycol.

Destruction Method: working in a fume hood with safety glasses, lab coat, and nitrile gloves add benzene to excess. Mix diluted compound into slurry of sodium carbonate or bentonite. Package resulting slurry as hazardous waste for off-site disposal by incineration.

We propose to hydrate this compound to at least 50% with water. The resulting mixture will be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF.

Physical Properties: Clear liquid, avoid elevated temperatures. May be shock or friction sensitive. Boiling point 73^oC specific gravity 1.034. soluble in most common solvents, methylene chloride, toluene, ethyl acetate.

Destruction Method: While working in a fume hood with appropriate safety glasses, lab coat, and gloves dilute contents to excess with methylene chloride. Package diluted compound as hazardous waste for off-site disposal by incineration.

We propose to dilute this compound with 90% methylene chloride. The resulting mixture will then be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF

All containers are currently stored in an explosion proof refrigerator in Environmental Health and Safety's Laboratory. This laboratory, Room 19 Graduate Research Tower, is located in the basement of the Chemistry Research Building. The lab contains two fully functional variable air volume chemical fume hoods. Once opened all containers will be moved into one of these hoods and all stabilization work will take place in this location.

Prudent laboratory practices will be exercised relative to the nature of the compounds we are stabilizing. Safety glass's, lab coats, protective gloves will be worn at all times. When prudent, work will be conducted behind a safety blast shield.

The EH&S laboratory is connected to five high pressure research chambers. These chambers were designed specifically for high energy research and remote applications. The compounds in question will be removed one at a time from the refrigerator and carried in secondary containment a total of 30 feet to the first chamber. A remote opening device is located in this chamber and can be operated from the remote control location. Visual observation of the operation can be maintained through a lexan viewing portal from outside the chamber. Once opened each container will be packaged in secondary containment and carried 30 feet to the fume hood were stabilization will take place. A second container will not be started until treatment is complete on the previous container.
Both technicians will be in full bunker gear with SCBA. Only one technician will be in the "Hot Zone" reactives room with the remote opening device at any given time the second technician will stay in the "Cold Zone" fully suited as backup for primary team member. The Entry Team Leader will constantly monitor operations in the "Hot Zone" stationed at the bullet proof viewing station and will be prepared to activate backup personnel if warranted. Activation of the remote opening device would only occur once all personel are clear of the Hot and Warm Zone. A Photo Ionization Detector will be set up to constantly monitor air in the "Hot Zone" . Any indication of excess hydrocarbons at or below 10% of the LEL would necessitate immediate cessation of all operations. Air inside this chamber can be exhausted by remote activation of explosion proof exhaust fan. Reentry would not be allowed until authorized by the Project Supervisor. the Project Supervisor can at any time halt all operations and can activate the campus HAZWOPER Team including UMASS Police and Amherst Fire Department.

The following seven personnel will be committed to and involved with different phases of this operation as designated. In addition will be any UMASS Police or Amherst Fire department personnel as required by their respective chiefs.

James Fox. Overall Project Supervisor:

Current Position:
Manager, Hazardous Waste Management Services, Environmental Health and Safety, University of Massachusetts Amherst, MA 01007

Responsibilities:
Primarily responsible for Hazardous Waste Management (RCRA), with secondary and consultative responsibilities for SARA, CERCLA, NPDES, OSHA (Haz-Mat response), EPCRA, NRC (waste segment), TOSCA (PCBs), UST, Title V, NESHAP, WWT, biohazardous, and others.

Education:
M.S., Environmental Science/Engineering, University of Texas.
B.S. (cum laude), Environmental Science, minor in Chemistry, University of Massachusetts. Numerous post-graduate, specialized courses related to field.

Professional Memberships:
American Institute of Chemical Engineers
Massachusetts Licensed Site Professional Association
Air and Waste Management Association

Dr. Valerie Steinberg Ph.D. CIH "Chemical and Biological Safety Officer" UMASS/Amherst. Responsible for Project Review and Prior Approval as required by UMASS Laboratory Safety Policy

James Field "Hazardous Waste Officer" UMASS/Amherst. Remote control operation and Entry Team Leader

Responsibilities:
Primary responsibilities for hazardous waste management with focus on hazard determination, source reduction, day to day management of the hazardous waste program. Secondary responsibilities include operation and training for emergency response and preparedness of our on site HAZWOPER team. Schedule and write up monthly training programs and drills that include the Amherst Fire Department, local EMS including Hospital ER staff and the State's Hazmat Team. Manage a team of four graduate Ph.D. Chemistry students who work in our lab specializing in unknown analysis and reactive's handling and treatment.

Education:
University of Mass/Amherst
Numerous specialized class's pertaining to Emergency Response, Hazardous Materials, Handling of Reactive Compounds
Certified OSHA HAZWOPER 1910.120 Incident Command, Technical Specialist, and Operations Level
Certificates of training from many sources including
National Fire Academy, Mass State Fire Academy, Mass State Police Academy, US Air Force, National Terrorism Institute, Industrial Risk Insurers, Kemper High Hazard Research Laboratory.
Twenty years experience in emergency response and hazardous waste spill cleanup.

Allen Juskiewicz "Hazardous Waste Technician" UMASS/Amherst
Member of UMASS HAZWOPER Team Will be primary member of two team members who will be suited up in Personal protective equipment to place items to be opened in the remote opening device
Certified OSHA HAZWOPER 1910.120 Technical Specialist and Operations Level. Extensive experience in emergency response

Donald Erickson "Fire and Safety Officer" UMASS/Amherst
Member of UMASS HAZWOPER Team. Second team member suited up in personal protective equipment to backup primary member.
Certified OSHA HAZWOPER 1910.120 Technical Specialist and operations Level
Captain on the Amherst Fire Department Call force. Extensive experience in emergency response

Balwant Chohen Ph.D. candidate specializing in inorganic chemistry at UMASS/Amherst. Balwant has technical oversight of physical chemistry data responsible for literature review of compounds and actual treatment procedures we will use

Michael Ingle Ph.D. candidate specializing in organomettalic chemistry at UMASS/Amherst will assist Balwant as an organic and reactives specialist.

 Sodium Amide- We propose to deactivate this compound by first immersing in toluene and will then treat with drip-wise addition of 95% ethanol. As ammonia is evolved we will control the rate of reaction by both the addition rate and by monitoring the temperature. An ice slurry mix can be used to slow the reaction if needed. The final compound will be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF

Benzoyl Peroxide - We propose to hydrate this compound to at least 50% with water. This compound will then be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF

1-Fluoro-2,4-Dinitrobenzene- We propose to hydrate this compound to at least 50% with water. The resulting mixture will be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF.

Tert.-Butoxycarbonyl Azide- We propose to dilute this compound with 90% methylene chloride. The resulting mixture will then be packaged and labeled by Triumvirate Environmental for disposal at a permitted TSDF.

As a large quantity generator of "Hazardous Waste" the University has an active contingency plan. EH&S trains and operates an OSHA compliant HAZWOPER team. Members of this team with appropriate protective clothing will be present for this operation. Our team members are in direct radio contact with, Umass Police Emergency Dispatch, Amherst Fire Department Dispatch, Environmental Health and Safety base station. The Amherst Fire Department will be invited to participate. All members will be prepared to activate any portion of our contingency plan.

After stabilization all compounds will be packaged and labeled according to Federal DOT and RCRA requirements. These containers will be transported to our less than 90 day storage area and will be lab packed by Triumvirate Environmental Inc. For disposal off-site at a permitted TSDF.