EPA/600/R-04/065 

November 2003 

Report on the Homeland Security 

Workshop on Transport and Disposal of 

Wastes From Facilities Contaminated With 

Chemical or Biological Agents 

by:


John Wilhemi


Eastern Research Group, Inc.


Lexington, MA 02421


Fran Kremer


U.S. Environmental Protection Agency


Office of Research and Development


National Risk Management Research Laboratory


Cincinnati, OH 45268


68-W-98-217


Project Officer 


Vincent Gallardo


Land Remediation and Pollution Control Division


National Risk Management Research Laboratory


Cincinnati, Ohio 45268


National Risk Management Research Laboratory


Office of Research and Development


U.S. Environmental Protection Agency


Cincinnati, Ohio 45268

Notice 

The U.S. Environmental Protection Agency through its Office of Research and Development funded 

this report under Contract Number 68-W-98-217 to Eastern Research Group, Inc. (ERG) as a general 

record of discussion for the “Homeland Security Workshop on Transport and Disposal of Wastes 

From Facilities Contaminated With Chemical or Biological Agents.” This report captures the main 

points of scheduled presentations and summarizes discussions among the workshop panelists, but 

it does not contain a verbatim transcript of all issues discussed. EPA will use the information 

presented during the workshop to address waste management challenges posed by materials 

contaminated with chemical or biological agents. This report is not EPA guidance and should not 

be viewed as such. It has been subjected to the Agency’s peer and administrative review and has 

been approved for publication as an EPA document. 

ii 
Foreword 

The U.S. Environmental Protection Agency is charged by Congress with protecting the Nation’s 

land, air, and water resources. Under a mandate of national environmental laws, the Agency strives 

to formulate and implement actions leading to a compatible balance between human activities and 

the ability of natural systems to support and nurture life. To meet this mandate, EPA’s research 

program is providing data and technical support for solving environmental problems today and 

building a science knowledge base necessary to manage our ecological resources wisely, understand 

how pollutants affect our health, and prevent or reduce environmental risks in the future. 

The National Risk Management Research Laboratory is the Agency’s center for investigation of 

technological and management approaches for preventing and reducing risks from pollution that 

threatens human health and the environment. The focus of the Laboratory’s research program is on 

methods and their cost-effectiveness for prevention and control of pollution to air, land, water, and 

subsurface resources; protection of water quality in public water systems; remediation of 

contaminated sites, sediments and ground water; prevention and control of indoor air pollution; and 

restoration of ecosystems. NRMRL collaborates with both public and private sector partners to foster 

technologies that reduce the cost of compliance and to anticipate emerging problems. NRMRL’s 

research provides solutions to environmental problems by: developing and promoting technologies 

that protect and improve the environment; advancing scientific and engineering information to 

support regulatory and policy decisions; and providing the technical support and information transfer 

to ensure implementation of environmental regulations and strategies at the national, state, and 

community levels. 

This publication has been produced as part of the Laboratory’s strategic long-term research plan. 

It is published and made available by EPA’s Office of Research and Development to assist the user 

community and to link researchers with their clients. 

Hugh W. McKinnon, Director 

National Risk Management Research Laboratory 

iii 
Acknowledgements 

Appreciation is given to all those at the workshop who’s participation and open discussion provided 

the context for this report. The workshop was developed by Fran Kremer with support from a 

number of individuals and organizations including: from U.S. EPA, David Carson, Wendy DavisHoover, Paul Lemieux, Kristina Meson, Martin Powell, Frank Schaefer, and Susan Thorneloe; from 

the Edgewood Chemical Biological Center Robert Eckhaus and William White; John Skinner from 

the Solid Waste Association of North America; Maria Zannes from Integrated Waste Services 

Association. Special thanks to Kate Schalk who coordinated the meeting logistics, and to our 

reviewers, Harold Dye with the Maryland Department of the Environment, Alan Woodard, New 

York State Department of Environmental Conservation, and Steve Levy, Office of Solid Waste and 

Emergency Response. 

iv 
Table of Contents 

Summary ....................................................... 1 


I. Classes of Chemical and Biological Agents ................................. 4 


A. What do we know? ............................................... 4 


B. What research or information needs were identified? .................... 7 


C. What information resources are currently available on this matter? ......... 8 


II. Detection ....................................................... 9 


A. What do we know? ............................................... 9 


B. What research or information needs were identified? ................... 10


C. What information resources are currently available on this matter? ........ 11


III. Effectiveness of Decontamination ....................................... 12


A. What do we know? .............................................. 12


B. What research or information needs were identified? ................... 13


C. What information resources are currently available on this matter? ........ 15


IV. Triaging of Waste .................................................... 16


A. What do we know? .............................................. 16


B. What research or information needs were identified? ................... 18


C. What information resources are currently available on this matter? ........ 19


V. Storing, Handling, and Transporting Wastes ............................. 20


A. What do we know? .............................................. 20


B. What research or information needs were identified? ................... 23


C. What information resources are currently available on this matter? ........ 24


VI. Disposing of Wastes in Landfills ........................................ 26


A. What do we know? .............................................. 26


B. What research or information needs were identified? ................... 28


C. What information resources are currently available on this matter? ........ 29


VII. Incineration ...................................................... 30


A. What do we know? .............................................. 30


B. What research or information needs were identified? ................... 34


C. What information resources are currently available on this matter? ........ 35


VIII. List of Participants ................................................... 37


v 
List of Abbreviations 

CDC Centers for Disease Control and Prevention 

DHS Department of Health Services 

DOT U.S. Department of Transportation 

EPA U.S. Environmental Protection Agency 

HWI hazardous waste incinerator 

LRN Laboratory Response Network 

MWI municipal waste incinerator 

NIOSH National Institute for Occupational Safety and Health 

NYSDEC New York State Department of Environmental Conservation 

vi 
Summary 

This report summarizes discussions from the “Homeland Security Workshop on Transport and 

Disposal of Wastes From Facilities Contaminated With Chemical or Biological Agents.” The 

workshop was held on May 28–30, 2003, in Cincinnati, Ohio, and its objectives were to: 

# Document the current understanding of the challenges faced when handling, storing, 

transporting, and disposing of wastes from public and private facilities contaminated with 

chemical and biological agents. 

# Identify research needs and opportunities for improving coordination between federal, state, 

and local government agencies and other stakeholders in order to fill gaps in the current 

understanding of these waste management challenges. 

The workshop panelists included representatives from federal agencies (e.g., the Environmental 

Protection Agency, the Department of Defense, the Department of Transportation, and the Centers 

for Disease Control and Prevention), state agencies, local agencies, academia, and waste 

management companies. During the workshop, panelists gave presentations on specific topics, 

including the waste management challenges posed by the World Trade Center disaster and the 

anthrax contamination of office buildings in New York City and Washington, D.C. Following each 

presentation, the workshop panelists engaged in free-flowing discussions to elaborate upon the issues 

presented. 

This initial report summarizes discussions on the following seven topics: classes of chemical and 

biological agents; detection; effectiveness of decontamination; triaging of wastes; handling, storage, 

and transport of wastes; landfilling; and incineration. For each topic, this initial report outlines the 

current state of knowledge, identifies associated research needs, and lists action items identified 

during the discussions. The technical content of this report is based entirely on discussions at the 

workshop. 

Although the workshop addressed seven individual topics, some cross-cutting themes emerged 

during the panelists’ discussions. Examples of common themes include the following: 

#	 Panelists noted that EPA’s future work on handling wastes contaminated with chemical and 

biological agents should be sensitive to the fact that specific waste management challenges 

vary considerably with the type of agent (e.g., chemical versus biological) and type of waste 

(e.g., wastewater, personal protective equipment, building debris). Thus, a single set of 

guidelines that applies to all possible agents and waste streams might not be feasible. Several 

panelists recommended that EPA consider radiological contaminants and animal diseases in 

its ongoing work, whether by developing specific guidance documents on these issues or 

referring stakeholders to other resources for further information. 

#	 The absence of widely accepted standards for effectively decontaminating biological agents 

1

was discussed throughout the workshop. Incinerator and landfill operators, for instance, had 

reservations about receiving wastes that are not certified as being uncontaminated. But, for 

most biological agents, no firm research—or even a standardized analytical method—is 

available to answer the question, “how clean is safe?” Until this issue is resolved, some 

panelists feared that all wastes generated from buildings containing certain biological agents 

(particularly the persistent ones) might have to be handled as if they were contaminated. 

#	 A number of panelists suggested that the Federal Government maintain the needed 

infrastructure for transport and disposal of these wastes. This infrastructure would include 

equipment to transport materials ( e.g. trucks, barges) and disposal sites/equipment (e.g. 

secure landfills, incinerators) that would be in strategic locations around the country. The 

disposal options/sites would be pre-determined based on an evaluation of available sites/ 

equipment (see below) and a vulnerabilty assessment. 

#	 Multiple panelists emphasized the need for state and local agencies to include waste 

management in their emergency response plans and mock terrorist attack drills. Such efforts 

may result in response workers seeking out information resources already available; these 

resources and documentation prepared during mock terrorist attack drills can prove 

invaluable should an actual event occur in the future. The panelists identified several ways 

that EPA can assist state and local agencies with their emergency planning efforts. The 

panelists said that EPA can prepare case studies, checklists, or guidance documents to inform 

these agencies of specific challenges in managing wastes that contain chemical or biological 

agents. Such documents should draw on the lessons learned from previous experiences 

managing wastes from terrorist attacks, and should emphasize the need for effective 

communications between multiple agencies. Finally, panelists suggested that EPA convene 

another workshop to help prepare practical information resources for state and local agencies. 

#	 Panelists indicated that EPA can develop databases with relevant information (e.g., location, 

operating data, capacity, transportation routes) on landfills and incineration facilities across 

the country. Having a system linked to a mapping application would allow users to readily 

identify waste management facilities that can handle wastes from emergency events. 

#	 An issue raised throughout the workshop was the need to consider public perception of risks 

and other sensitivities when deciding how to manage wastes containing chemical or 

biological agents. Many panelists said that EPA and other agencies will likely need to 

balance scientific judgments against public acceptability of waste management decisions. 

The panelists encouraged EPA to strive for pragmatic and protective solutions, which might 

not necessarily be solutions that achieve zero risks. As an example of a potential sensitivity, 

a panelist noted that people might be offended by using the term “waste” when referring to 

debris (and possibly human remains) from sites where human life has been lost or severely 

affected by an event. 

#	 Another cross-cutting theme was the need for training to ensure the safety of all workers who 

might handle wastes containing chemical and biological agents. These workers include 

2

decontamination crews, transporters, and employees of waste management facilities. 

Panelists suggested that existing courses on handling contaminated and decontaminated 

wastes be identified and new courses be developed and offered, possibly by EPA with 

assistance from OSHA and DOT. Panelists encouraged EPA and other agencies to consider 

who should develop and offer training courses on chemical and biological agents, what 

parties should fund the training, and when and how often employees should receive training. 

#	 Throughout the workshop, panelists noted that EPA and other agencies might need to 

establish permit variance procedures for transporters and disposal facilities handling wastes 

potentially contaminated with chemical and biological agents in emergency situations. The 

procedures should include tracking, monitoring, reporting, handling and disposal 

requirements, and include additional testing required for specific wastes dependent on 

disposal methods. 

#	 Owners and operators of waste management facilities expressed concern throughout the 

workshop about potential liability issues associated with managing wastes that possibly 

contain chemical and biological agents. These panelists encouraged EPA to consider these 

liability concerns in future work involving this waste management issue. The owners and 

operators expressed specific concern regarding the need to protect facility assets and to 

address unanticipated harm to employees and the surrounding community, damages resulting 

from permit violations related to disposal of bioterrorism waste, and remuneration for 

financial losses directly and indirectly associated with processing wastes containing chemical 

and biological agents. 

#	 One decision-making approach that many panelists supported was to encourage state and 

local agencies to first identify the available waste management options (e.g., incinerators and 

landfills) and then “work backwards” to determine what types of wastes these facilities can 

handle. Several panelists supported this concept of “working backwards” because a relatively 

small number of waste management options are available, even though a large number of 

waste streams could be generated in buildings contaminated with chemical or biological 

agents. 

#	 Recognizing that many public and private sector parties have relevant experience on most 

of the workshop topics, the panelists recommended that EPA continue to involve many 

stakeholders when evaluating waste management challenges. Panelists suggested that 

representatives from the following parties, in addition to the parties represented at the current 

workshop, might offer useful insights for the ongoing work: the United States Department 

of Agriculture, the National Institute for Occupational Safety and Health, the Occupational 

Safety and Health Administration, the Federal Emergency Management Agency, law 

enforcement agencies, analytical laboratories, and experts in risk communication and public 

perception of risk. 

3

I. Classes of Chemical and Biological Agents

A. What do we know? 

The workshop panelists discussed many types of chemical and biological agents that could be 

encountered in future waste management scenarios. The following list describes how the agents were 

classified into two general classes (chemical and biological), each having numerous sub-categories 

of agents. The list documents relevant features of each agent, such as their availability, toxicity, 

relevant chemical and physical properties, and persistence. It was noted during the discussion that 

the potential use of chemical and biological agents is an emerging threat and that novel agents may 

be used in the future that have not been considered in past threat assessments. 

#	 Chemical agents. These classes of potential chemical agents were identified during the 

workshop: 

•	 Industrial chemicals. An extremely broad range of industrial toxic chemicals are 

manufactured, stored, and transported throughout the United States, often in large 

quantities. Examples include fuels, flammable chemicals, oxidizers, acids (e.g., 

hydrogen cyanide), bases, and pesticides. The workshop panelists did not go into 

detail on waste management challenges posed by releases of industrial chemicals, but 

several noted that federal regulations already require larger industrial facilities to 

have detailed emergency response plans that evaluate the potential off-site 

consequences of uncontrolled releases. 

•	 Vesicants. The workshop panelists discussed two types of vesicants (blistering 

agents): mustards and Lewisite. The information that was presented on these 

materials follows: 

The workshop panelists noted that mustard agents are relatively easy to synthesize 

from readily available precursors. On the other hand, the panelists characterized these 

agents as having moderate toxicity with a relatively low likelihood of mortality 

resulting from exposures, assuming that exposed individuals seek medical care. The 

main challenge identified for cleanup is the persistence and limited water solubility 

of these compounds. As an example of this challenge, panelists noted that 

incineration efficiently destroys mustard agents, but the agents’ limited solubility 

complicates efforts to collect them from locations where they might be released. 

Mustard agents can, however, be readily oxidized using chlorine bleach. 

Lewisite is an organic arsenic compound that causes immediate pain after exposure, 

rather than delayed effects. Beyond the initial reaction, the arsenic within Lewisite 

might contribute to additional adverse health effects, depending upon the dose. 

Lewisite was not produced extensively in the United States; far larger quantities were 

4

produced in Europe and the former Soviet Union. Lewisite can be produced easily 

by those with access to arsenic trichloride. Lewisite is rapidly hydrolyzed, which 

would greatly facilitate any cleanup efforts. 

•	 Nerve agents. Several nerve agents were identified. The common link between these 

agents is their ability to inhibit acetylcholinesterase—this inhibition can ultimately 

result in serious effects, such as respiratory collapse and death. Two general types of 

nerve agents were presented. 

First, several “G Agents” were described. These agents include GA, GB (also known 

as Sarin), GD, and GF. They share many molecular structures: all have a phosphorusoxygen double bond, most have a phosphorus-carbon bond, and most have a 

phosphorus-fluorine bond at the heart of their structure. Some of the G Agents, 

particularly GA, are relatively easy to synthesize from reagents that are widely 

available. 

Second, several “V Agents” were described, including Amiton and VX. The 

distinguishing feature of the V Agents is their phosphorus-sulfur bond at the heart of 

the chemical structure. The two types of nerve agents differ in several important 

regards. The V Agents, for instance, are less likely to be encountered because they 

are far more difficult to synthesize than are the G Agents. Further, the V Agents are 

far less volatile than the G Agents, but both agents can be dispersed in a manner that 

could present an inhalation hazard. 

Regarding decontamination and waste management, workshop panelists noted that 

the nerve agents are relatively persistent, except when exposed to water. Hydrolysis 

destroys these agents and typically (though not always) forms byproducts that are 

relatively non-toxic. These nerve agents can be efficiently destroyed in incinerators. 

•	 Glycolates. The workshop panelists briefly discussed glycolates. These chemicals, 

which are typically solids, have toxic effects opposite to those of nerve agents. 

Glycolates can have transient incapacitating effects, but these chemicals are believed 

to be of limited concern because they are less toxic than other agents. 

#	 Biological agents. These classes of potential biological agents were identified during the 

workshop: 

•	 Pathogenic bacteria. In general, bacteria are either grown in cultures or present in a 

dormant state (e.g., spores). Vegetative bacteria die rapidly in the environment due 

to dehydration and exposure to ultraviolet radiation. Dormant bacteria, on the other 

hand, can persist in the environment for long periods of time, even under adverse 

conditions. This distinction presents specific challenges for managing wastes that 

contain spores. Bacterial pathogens of concern include: Bacillus antrhacis (anthrax), 

5

Yersinia pestis (plague), Francisells tularensis (tularemia), and Burkholderia mallei 

(glanders). 

•	 Viruses. Viruses are far more difficult to weaponize, because they require a host 

organism or host cells to survive. Viruses identified as being of concern include 

Variola major (smallpox), Venezuelan equine encephalitis virus, Ebola virus, and 

many possible others. 

•	 Toxins. There are a wide range of substances regarded as toxins. According to the 

literature, at one end of the range are the bacterial toxins, which are chemicals that 

are formed by bacteria. The toxins are not living organisms, but they are often 

classified as biological agents because living organisms produce them. Production 

of the toxins requires culturing, harvesting, purification, and formulation. Most 

bacterial toxins are solids and would have to be formulated in a manner to facilitate 

widespread dispersal. Examples of toxins identified during the workshop include 

botulinal toxin, staphylococcal enterotoxin, abrin, and many others. Some of these 

have previously been stockpiled for weapons purposes and targeted assassination 

attempts. Given the limited availability of many of these toxins, however, the 

likelihood that they would be used in a large attack is believed to be low. 

In the middle of the range of toxins are snake poisons, insect venoms, plant alkaloids, 

and other substances, such as ricin, batrachotoxin, and curare, which have been used 

as weapons. At the other end of the range are small molecules such as potassium 

fluoroacetate synthesized by chemical processes or hydrogen cyanide, which occurs 

in hundreds of plant and animal species. Further, a panelist noted that large scale 

production processes for biologically active peptides, bioregulators (e.g., histamines), 

and similar substances is an area rich in potential for weapons. 

•	 Other biological agents. The panelists also identified other agents that may be 

encountered in future events and related waste management scenarios. These 

included prions (which are associated with chronic wasting diseases), agents 

genetically engineered to avoid detection, and infectious agents that affect livestock 

(e.g., hoof-and-mouth disease). Some of these agents may present unique challenges. 

Prions, for instance, are highly persistent and difficult to destroy, even by 

incinerators. As another example, an outbreak of hoof-and-mouth disease can lead 

to an extremely large volume of animal carcasses that need to be managed. The 

panelists recommended that EPA consider such agents in its ongoing homeland 

security efforts. 

When discussing the chemical and biological agents, panelists noted that contaminated buildings will 

contain an extremely broad range of wastes. Generally speaking, such sites will contain building 

materials and debris, personal protective equipment from the cleanup crew, and decontamination 

wastes (e.g., wastewater). The specific waste components found at a given site depend on the type 

6

of building affected. However, responders should expect to handle many classes of materials 

including, but not limited to, furniture (wood, metal, upholstered), carpet, floor and ceiling tiles, 

wallboard and paneling, fixtures, computers and electronic equipment, paper items, and putrescible 

wastes (e.g., food items). 

B. What research or information needs were identified? 

The workshop panelists identified several information gaps, along with associated research needs 

or action items to fill them: 

#	 Several panelists indicated that planning for waste management events is difficult without 

a better sense of the threats realistically posed by specific agents. For instance, planning 

activities would be greatly facilitated if planners knew which agents are most likely to be 

encountered, whether a specific agent is more likely to be used in a localized manner (e.g., 

to contaminate an office) or in a widespread manner (e.g., to contaminate a city block), and 

what volumes of wastes are expected to be generated. With better threat assessment 

information, local and state agencies can proceed with their emergency planning accordingly. 

Panelists suggested that EPA might be able to obtain information on specific threats by 

coordinating with other federal agencies, such as the Department of Defense and the 

Department of Homeland Security. 

#	 Several panelists said that state agencies, local agencies, first responders, and other 

stakeholders would benefit from having agent-specific fact sheets that answer many of the 

general questions that arose during the discussions, such as: 

How likely is it that terrorists have access to an agent?


What are the agent’s relevant chemical and physical properties?


For biological agents, what is the infective dose?


What is the agent’s anticipated fate and transport behavior in the environment?


How persistent is the agent?


Will the agent adhere to building materials or vaporize and disperse?


What are the preferred decontamination methods?


How will the agent behave in a landfill?


Is the agent effectively treated by incineration?


Can the agent be dispersed via different environmental pathways (e.g., carried on


clothing, survive in a water treatment system)? 

Are there potential vectors or reservoirs of infection of concern? 

Similarly, other panelists suggested that EPA, with assistance from CDC, develop guidance 

that lists all agents and decontamination procedures available, to the best of their knowledge. 

The guidance may take the form of a matrix, and would be added to as information becomes 

available. A computer-based document may be preferable, with guarded access if necessary. 

7

# A specific research opportunity discussed during this session was using surrogate agents to 

study the fate and transport of selected chemical and biological agents. For instance, the fate 

and transport of anthrax spores in landfills can be studied using simulations involving other 

Bacillus species bacteria. Section VI.B revisits this issue. 

# Several panelists asked EPA if its evaluation should be broadened to include waste 

management issues for radiological contaminants, such as those that might be released from 

a “dirty bomb” incident. EPA representatives responded that the Agency is discussing this 

matter internally and the scope of its effort might indeed be broadened to include radiological 

contaminants. 

C. What information resources are currently available on this matter? 

The workshop panelists identified several sources of information about the available chemical and 

biological agents: 

#	 Many industrial facilities have already prepared detailed emergency plans and consequence 

scenarios that address large-scale releases of industrial chemicals. These plans should be 

available from state and federal offices responsible for managing reports submitted under the 

Emergency Planning and Community Right-to-Know Act. 

#	 Profiles of selected biological and chemical agents are available from different sources. For 

instance, the Centers for Disease Control and Prevention (CDC) maintains a “Public Health 

Emergency Preparedness and Response” Web site (http://www.bt.cdc.gov) that has detailed 

information on selected chemical and biological agents. Further, speakers at the workshop 

showed examples of tables copied from publications that document relevant information 

(e.g., infective dose, persistence of organism, incubation period) on numerous biological or 

anti-microbial agents. 

#	 A panelist noted that various parties have developed “response awareness courses” that 

might be a valuable resource on the types of events that may occur in the future. Specific 

references to preferred courses were not provided. 

8

II. Detection

A. What do we know? 

The workshop panelists discussed many technical and logistical challenges associated with 

identifying chemical and biological agents in environmental samples. This discussion focused largely 

on analyzing samples for biological agents, due to the additional information needed from laboratory 

analysis. Specifically, for chemical agents, laboratory analyses need only detect the presence and 

amounts of the agent of concern; for biological agents, on the other hand, the analyses not only need 

to detect the agent, but must assess whether the agent is still living, viable, or active and whether it 

poses a risk to public health. 

The panelists identified many problems emergency responders might encounter when trying to detect 

the presence and viability of biological agents. For instance, environmental samples suspected of 

containing biological agents cannot be handled or shipped as one would handle most types of 

environmental samples. Further, relatively few laboratories have the licensing, equipment, and 

capability not only to analyze samples for biological agents but also to decontaminate or destroy the 

samples after they have been analyzed. Due to the high costs associated with gaining this expertise, 

many laboratories likely may not be capable of conducting these analyses in the future. Additionally, 

in times of heightened concern regarding bio-terrorism, the few licensed laboratories in a given area 

are often inundated with requests to analyze samples. Given this situation, the panelists highly 

recommended that state and local agencies, as part of their emergency planning, identify in advance 

analytical laboratories that can analyze samples that may contain biological agents. 

As well as voicing concerns about simply identifying candidate laboratories, the panelists said that 

analytical results are often difficult to interpret. With no standard analytical methods for many 

biological agents, laboratories have been using various and different methods to detect them, which 

can lead to widely variable sampling results. Specific challenges identified include how to interpret 

analytical results in the absence of quantitative information on infective doses or detection limits, 

how to interpret analytical results that indicate the presence, but not the viability, of a biological 

agent, and how to interpret surface concentrations without knowing the associated exposure doses. 

Since some biological agents (e.g., Bacillus antrhacis, Francisella tularensis) can be naturally found 

in environmental samples in the absence of bio-terrorism attacks, the issue of “background” levels 

of contamination may be important for certain agents. The limitations of environmental sampling 

notwithstanding, the panelists noted that sampling for anthrax proved to be a valuable contribution 

to the decontamination efforts and epidemiological investigations, primarily because anthrax spores 

are so persistent in the environment. 

When discussing detection of biological agents, the panelists briefly reviewed the Laboratory 

Response Network (LRN). CDC established this network to help laboratories use consistent and 

reliable methodologies when analyzing certain types of samples for biological agents. Though the 

LRN program has indeed helped to ensure that analytical results are of high quality and reproducible 

9

across multiple laboratories, the program has limitations. For instance, relatively few laboratories 

are LRN-certified and only a subset of these can analyze samples for certain biological agents. 

Further, the LRN-certified laboratories are primarilyaccustomed to analyzing clinical samples—they 

are still developing procedures for analyzing environmental samples or samples of building 

materials. Finally, few, if any, of the LRN registered laboratories can analyze environmental samples 

for all classes of microorganisms (viruses, bacteria, and protozoa). This means that only a few 

laboratories have the necessary licensing and infrastructure (e.g., the ability to destroy samples) to 

analyze environmental samples for biological agents. 

Another limiting factor identified was additional regulatory requirements under the recently 

promulgated “Select Agent Program.” This program was established by the Public Health Security 

and Bioterrorism Preparedness and Response Act of 2002. The Select Agent Program further 

regulates the possession, use, and transfer of selected organisms, which again limits the number of 

laboratories with the necessary registration and capacity for analyzing samples for certain biological 

agents. Further complicating matters is the possibility—or probability—that samples requiring 

analysis for biological agents will be of a forensic nature, meaning that the analytical laboratory 

might have to coordinate efforts with appropriate law enforcement or intelligence agencies. 

B. What research or information needs were identified? 

The workshop panelists identified several information gaps, along with research needs or action 

items to fill them: 

#	 State agencies, local agencies, and other parties responsible for emergency response and 

waste management need information on the challenges posed by analyzing samples for 

biological agents, such as identifying licensed analytical laboratories, shipping samples safely 

and in accordance with Department of Transportation (DOT) regulations, knowing how to 

interpret positive and negative detection results, being prepared to communicate analytical 

results to the public, and realizing that it can take days before reliable and definitive 

analytical results are obtained for some samples. By identifying these challenges and 

presenting possible solutions, EPA can help all stakeholders be better prepared to analyze 

environmental samples during emergency situations. The Federal Government should 

consider the development of an environmental response laboratory network to manage 

environmental samples. Laboratories are in place for clinical analysis for emergency 

circumstances for these agents but analagous laboratories do not exist to manage 

environmental samples. 

#	 Workshop panelists said that there is no or limited information available on analytical 

methods for some biological agents, especially for analyzing environmental samples. 

Research can help develop methods for analyzing environmental samples and samples of 

building materials for biological agents. Where possible, analytical methods should be able 

to detect biological agents down to the level of the infective dose. Additionally, procedures 

should be developed to specify how to analyze samples containing multiple classes of agents 

10

(e.g., chemical, biological, and radiological agents), given that few laboratories can handle 

such mixtures. Such procedures could address, for instance, how to process environmental 

samples that contain human tissues, which might contain blood-borne pathogens. 

#	 Some panelists expressed concern that re-engineering of biological agents might eventually 

render them undetectable by current laboratory analytical methods. They suggested that 

research on the analytical methods should consider nuances associated with detecting 

weaponized forms of biological agents. 

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on detecting chemical and biological agents. 

The resources identified during the workshop are discussed below. (This should not be viewed as 

a comprehensive account of all available resources.) 

#	 Multiple federal agencies have jointly developed the BioWatch program, which is conducting 

air filter sampling in several cities to detect bio-terrorism attacks before morbidity or 

mortality is observed. Information on the sampling and analytical methodologies used should 

be available from EPA and CDC—two of the agencies sponsoring this network. 

#	 The National Institute for Occupational Safety and Health (NIOSH) has published health 

hazard evaluations for the anthrax investigations at selected postal facilities. These reports 

include information on comparability of anthrax sampling and analytical methods. 

#	 One panelist noted that CDC’s Web page for the Select Agent Program lists links to 

information resources on many related topics (e.g., transportation concerns, occupational 

safety and health issues). These links are found at: http://www.cdc.gov/od/sap/addres.htm. 

#	 The LRN should make information available on preferred sampling and analytical methods 

for certain biological agents, as well as lists of the laboratories that are currently certified to 

analyze samples potentially contaminated with such agents. 

#	 The panelists noted that sampling and analytical methods for chemical agents should be 

available from Department of Defense installations engaged in related demilitarization 

activities. They did not cite specific publications that document these methods. 

11

III. Effectiveness of Decontamination

A. What do we know? 

The workshop panelists discussed available decontamination technologies for various chemical and 

biological agents. The discussion addressed specific experiences of decontaminating wastes from 

the anthrax incidents of 2001 and ongoing research on the effectiveness of existing and emerging 

decontamination methods. 

Many different decontamination methods were identified during this session, including measures to 

separate or inactivate chemical and biological agents. These included using disinfectants, filtration, 

vacuuming, heat inactivation, incineration, ultraviolet radiation, and ionizing radiation. The approach 

used for a given scenario depends on the specific needs for the application. Specific types of 

disinfectants and fumigants include bleach, peroxides, ozone, and ethylene oxide. The panelists 

identified the strengths and limitations of the different methods. For instance, they agreed that 

ethylene oxide sterilization can decontaminate various materials effectively, but that using ethylene 

oxide to decontaminate buildings is impractical due to other hazards that ethylene oxide poses (e.g., 

toxicity, risk of explosions). Giving another example, a panelist noted that enzymatic 

decontamination has shown promise for destroying “G Agents,” but further research is needed to 

demonstrate the overall utility of this technology. Though many decontamination technologies were 

reviewed, several panelists noted that bleach-based products continue to be the most widely available 

decontamination technology and have proven generally effective against both chemical and 

biological agents, given sufficient contact time. 

The panelists identified many factors that responders to chemical or biological attacks must consider 

when selecting appropriate decontamination methodologies. These factors include, but are not 

limited to, the following: 

#	 What is the chemical or biological agent of concern? The type of agent present is a critical 

consideration when one selects decontamination methods, for several reasons. Although 

researchers are striving to have decontamination technologies apply to broad ranges of 

agents, some technologies (e.g., enzymatic decontamination) have demonstrated 

effectiveness for only certain specific agents. Further, operational details for a given 

decontamination technology, such as minimum contact times needed, may also depend on 

the agent present. 

#	 What types of materials are contaminated? The optimal decontamination technology for 

a given application generally depends on the material that is potentially contaminated. For 

instance, the optimal technology for decontaminating wastewater may differ from the optimal 

technology for decontaminating building materials. Further, the porosity of the contaminated 

materials affects decontamination decisions, because more porous materials (e.g., ceiling 

tiles) are much harder to decontaminate effectively than less porous materials (e.g., concrete). 

12

The intended end use of contaminated material is yet another consideration: if the object to 

be decontaminated must be preserved for future use, some decontamination methodologies 

might be preferred over others. 

#	 How wide an area is contaminated? The appropriate decontamination strategy also 

depends on the size of the contaminated area. If a chemical or biological agent exists only 

in a small area (e.g., within one room), then spot decontamination methods may be 

appropriate; however, spot decontamination is not feasible for contamination over broad 

areas. The extent of the contaminated area also may affect the decision on whether to conduct 

decontamination activities on site or at a remote location. 

#	 Does the decontamination method create additional wastes? Most decontamination 

technologies leave residues that must either be cleaned or naturally dissipate, typically by offgassing. The wastes formed by different decontamination technologies could be a limiting 

factor in some cases. For instance, though some decontamination foams have shown promise 

in terms of effectiveness of decontamination, they leave residues that have to be rinsed and 

the resulting wastewater must be collected and handled accordingly. 

In addition to these general concerns, participants discussed many specific issues that arose in the 

decontamination of office buildings and postal facilities where anthrax was found. For instance, 

decontamination efforts at some sites were complicated by the fact that employees caused crosscontamination by moving items within and removing items from contaminated areas before first 

responders arrived. Further, cleanup officials at some sites had difficulties finding waste 

management companies willing to dispose of decontaminated materials—a perception issue that was 

revisited multiple times at the workshop (see Sections VI and VII). 

B. What research or information needs were identified? 

When discussing decontamination methods, workshop panelists identified several information gaps, 

along with research needs or action items to fill them: 

#	 A central issue to the debate on the effectiveness of decontamination is deciding “how clean 

is safe?” Answers to this question will determine how effectively buildings must be 

decontaminated before they can be used again and how effectively building contents must 

be decontaminated before they can be handled as non-infectious waste. The workshop 

panelists noted that the Department of Defense should already have information on the 

effectiveness of decontamination for chemical agents, but indicated that the issue is largely 

unresolved for biological agents in environmental or residential settings. Some panelists 

believed that enough clinical and toxicological data might be available to support 

establishing cleanup levels for some biological agents; other panelists said that further 

research on related matters (e.g., detection methods, infective levels for surface 

contamination, number of samples needed to characterize contamination in a building) must 

be resolved before scientists can develop defensible decontamination criteria for many 

13

biological agents. Panelists emphasized that reliable decontamination criteria must be 

developed such that site managers can assure the public and waste management companies 

that a building or its contents have been decontaminated effectively. Without such criteria, 

concern over potential exposures to biological agents might lead to requests for enormous 

volumes of building materials to be managed as waste. 

#	 The workshop panelists again said that state agencies, local agencies, and other parties 

responsible for emergency response and waste management need information on the 

challenges posed by decontamination. They suggested that EPA or other agencies prepare 

informational materials on the pros and cons of selected decontamination methodologies for 

specific scenarios. These materials could, for instance, specify the composition of 

disinfectant and minimum contact time required to achieve adequate deactivation for 

different agents and materials. Panelists also indicated that informational materials should 

document how long specific biological agents remain viable in the environment. Parties 

responsible for decontamination would benefit from knowing the different types of wastes 

that they might encounter; these waste streams might include building materials, personal 

protective equipment, office materials, construction and demolition debris, furniture, human 

cadavers, and animal carcasses. 

#	 Several panelists suggested that EPA consider publishing case studies to guide first 

responders and other stakeholders on the technical issues associated with decontamination 

and the broader waste management issues associated with materials containing chemical and 

biological agents. One suggestion was to prepare a case study that addresses the most 

difficult decontamination challenges, such as how to decontaminate buildings containing 

highly persistent biological agents (e.g., anthrax spores). The case study could address all 

issues relevant to decontamination, including setting up staging areas, identifying best 

practices to avoid cross-contamination, listing materials that would likely need to be 

decontaminated, and identifying residues (e.g., wastewater) that might be generated and how 

these residues should be handled. Panelists suggested basing a case study on anthrax, because 

the methods used to decontaminate anthrax spores are believed to work effectively for other 

biological agents. 

#	 Further research and literature reviews should be conducted to document general 

specifications for effective decontamination and evaluate how effectiveness varies with 

disinfectant concentration, contact time, temperature, residence time in autoclaves, the effect 

of a mixture of agents, and other parameters. Several specific research needs were identified, 

such as examining how decontamination effectiveness varies with the porosity of the 

contaminated material, further evaluating enzymatic decontamination methods (particularly 

for G agents), assessing whether ionizing radiation can effectively decontaminate large items 

(e.g., couches) that are difficult to handle otherwise, and examining whether engineered or 

weaponized biological agents are more difficult to decontaminate than the agents in their 

natural forms. 

14

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on the effectiveness of decontamination 

methods. The resources identified during the workshop are discussed below. (This should not be 

viewed as a comprehensive account of all available resources.) 

# Multiple panelists noted that the Department of Defense has already researched laboratory 

analytical methods and effectiveness of decontamination for multiple chemical agents. More 

detailed information on this topic should be available from installations engaged in related 

demilitarization activities. 

# CDC has compiled information on agent-specific decontamination methodologies on its bioterrorism Web site: www.bt.cdc.gov. 

# One panelist referred to publications by the State and Territorial Association on Alternative 

Treatment Technologies for further information on effectiveness of decontamination, with 

the most relevant publication being “Technical Assistance Manual: State Regulatory 

Oversight of Medical Waste Treatment Technologies” (EPRI Report TR-112222, 1998). 

15

IV. Triaging Waste

A. What do we know? 

The workshop panelists raised several issues related to triaging wastes at sites contaminated with 

chemical or biological agents. Triaging, for purposes of this workshop, was defined as the initial 

characterization and management of wastes that occurs at the site where wastes are generated and 

the associated decision process for managing the handling, storage, transport and disposal of wastes. 

The discussion was based largely on lessons learned from triaging wastes generated during the World 

Trade Center disaster and at buildings that received mail contaminated with anthrax spores. Though 

these events had considerably different waste management challenges in terms of the nature and 

volume of wastes generated, the parties who managed these sites identified many common 

experiences that can be applied to other sites with wastes containing chemical or biological agents. 

The panelists listed numerous activities associated with triaging wastes on site. Such activities 

include establishing site security, restricting site access, constructing staging areas to avoid crosscontamination, implementing health and safety measures for first responders, characterizing and 

defining waste streams, deciding whether wastes need to be decontaminated on site, properly 

packaging wastes, and storing wastes safely before shipping them off site. Though the panelists 

recognized that the type of triaging activities needed for a given site ultimately depends on sitespecific conditions, they identified some general categories of wastes that may need to be considered 

for triaging activities. One such class of wastes is items and materials that will be disposed of or 

destroyed after being decontaminated, such as spent personal protective equipment, wastewater from 

decontamination, and debris (e.g., carpet, furniture, ceiling tiles). Another is wastes that may include 

items (e.g., personal property, human remains) that might need to be returned to family members, 

provided the materials can be properly decontaminated. Yet another is wastes that will likely include 

materials of a forensic nature, which law enforcement officials might need to examine before the 

materials leave the site. Finally, the appropriate timing and options to store, dispose, transport and 

dispose of wastes depends upon the identifying the risk associated with each available scenario. 

Several panelists said that triaging wastes can be complicated by the fact that some wastes from 

buildings contaminated with chemical and biological agents can be difficult to classify according to 

existing waste management and transportation regulations. As an example, panelists noted that no 

explicit guidance describes precisely how much decontamination is needed to have a waste that once 

was classified as hazardous or infectious become municipal waste or construction and demolition 

debris. Panelists noted that response workers to the buildings contaminated with anthrax spores 

needed to refer directly to regulatory agencies to determine whether decontaminated building 

materials should be classified as municipal waste, medical waste, or perhaps “special waste” (a term 

used in some states’ waste management regulations). These distinctions can be critical: the waste 

classification generally dictates the available waste management and transportation options, which, 

in turn, can affect how wastes are triaged. Some panelists suggested that regulatory agencies should 

be prepared to classify wastes from buildings contaminated with biological agents, possibly by 

16

issuing variances, exemptions, or special permits.1 

The panelists who triaged wastes from the World Trade Center disaster and the buildings 

contaminated with anthrax spores identified several factors that affected how they triaged wastes. 

These include current regulations for storing and transporting wastes, existing infrastructure for 

handling wastes on site, the available waste disposal and treatment options, and external pressure 

to complete site cleanup activities expeditiously to help affected areas quickly return to “normalcy.” 

Suspecting that the same factors will likely weigh heavily in most future waste management 

challenges, the panelists emphasized the importance of local agencies and emergency responders 

being prepared to address the waste triaging challenges. The following general themes emerged from 

these discussions: 

#	 The need to coordinate efforts among all parties. The panelists who worked on the World 

Trade Center disaster and the buildings contaminated with anthrax spores strongly believed 

that continual, effective communication between all stakeholders is a critical element to 

handling wastes containing chemical or biological agents. The stakeholders identified during 

this discussion include local emergency responders, local government officials, waste 

management companies, state environmental agencies, and federal agencies with expertise 

on specific technical issues. Federal agencies mentioned during this discussion included 

CDC, EPA, DOT, the Department of Defense, and the Department of Agriculture. Further, 

involving law enforcement entities may be helpful as they will likely need some of the 

debris associated with future attacks. 

#	 The need to plan thoroughly and in advance of events. Panelists emphasized that 

thorough advanced planning for emergency events can greatly mitigate the challenges posed 

by managing wastes containing chemical or biological agents. Specific matters that local and 

state agencies should research and resolve before complex waste management issues arise 

include making lists of contacts for key stakeholders; identifying all waste management 

companies in a jurisdiction that are approved, capable, and willing to receive wastes that 

might contain chemical or biological agents; becoming familiar with applicable state and 

federal regulations for classifying, storing, transporting, and disposing of these wastes; 

working with local emergency responders to identify and set up needed perimeter security 

to control public exposure and ensure environmental health and safety; developing plans for 

dust suppression controls to contain and manage contamination; ensuring that adequate 

personal protective equipment is readily available to first responders; and identifying public 

and private contractors that have the equipment and capability to help triage and transport 

wastes. Several panelists strongly recommended that local and state agencies incorporate 

waste triaging and management into their emergency response drills and mock events. Some 

1

 The terminology used in this paragraph is meant to illustrate the general concern panelists expressed about 

the ambiguities of existing regulations and the fact that wastes from bioterrorism events do not fall neatly into the 

waste classifications. The paragraph is not meant to be a technical review of all existing EPA and D OT regulations 

for wa ste ma nage men t and tra nspo rtation, re spec tively. 

17 
panelists indicated that EPA can assist with these planning efforts in various ways. For 

instance, a panelist suggested that EPA consider developing a database that documents 

relevant information (e.g., location, operating data, capacity, transportation routes) on waste 

management facilities that agencies can access as needed. Interfacing such a database with 

an electronic mapping application would facilitate rapid identification of waste management 

facilities near sites of emergency events. 

#	 Basing waste triaging plans on available waste management options. Recognizing that 

relatively few options are available for managing wastes from buildings contaminated with 

chemical and biological agents (e.g., disposal, incineration, selected alternative treatment 

technologies), several panelists suggested that the specific waste management options should 

dictate the triaging strategies. For instance, if decontaminated building debris from a site is 

to be incinerated, the dimensions of the incinerator inlet should determine how wastes need 

to be sorted and sized on site. For this reason, several panelists recommended that parties 

responsible for managing wastes first identify the available waste management options, then 

work backwards to develop triage plans accordingly. 

B. What research or information needs were identified? 

When discussing triaging wastes, workshop panelists identified several information gaps, along with 

the research needs or action items to fill them: 

#	 Few information resources have been developed to address the unique challenges posed by 

managing wastes containing chemical and biological agents; thus, EPA can assist responders 

to future events by developing general guidance documents on how to triage wastes 

effectively. Panelists suggested that these documents answer specific questions that have 

already been asked at the World Trade Center and anthrax sites, such as: 

When is it preferable to store wastes temporarily on site?


How should wastes be packaged?


What chain of custody must be followed if law enforcement parties are involved?


What regulations affect storage and transportation of wastes for different scenarios


(e.g., storage incidental to transportation versus storage for other purposes)? 

How are certain types of wastes classified under these regulations? 

Are there any minimum specifications for constructing staging areas? 

What waste management options are preferred for specific agents? 

Can personal property and human remains be returned to families? 

Guidance to stakeholders could also identify best practices for several general issues, such 

as handling wastes with a mixture of agents, coordinating with other stakeholders, and 

effective planning. Also, guidance is needed at the federal level to assess what materials 

should be used for forensic evidence and what can be returned to families. Such guidance 

should list references to other information resources on topics (e.g., forensics, transportation, 

18

health and safety) that other federal agencies typically address. 

#	 Panelists said that local agencies and emergency responders can obtain practical information 

on how to triage building wastes by reviewing specific case studies or by incorporating waste 

management into their emergency response drills. The panelists noted that EPA can help by 

developing case studies and by encouraging stakeholders to involve environmental officials 

in future drills. Case studies should clearly establish agency roles in emergency operations 

for different agents of concern. EPA can also assist by developing a database that documents 

important information (e.g., capacity, location, transportation routes) on the universe of 

facilities that could potentially manage wastes from sites attacked with chemical or biological 

agents. 

#	 The panelists suggested specific topics that EPA can investigate for additional insights into 

effective waste triaging strategies. One panelist, for instance, recommended that EPA consult 

with Japanese officials to learn how they triaged wastes in cleaning the Tokyo subway station 

where Sarin was released. 

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on triaging wastes that might contain 

chemical or biological agents. The resources identified during the workshop are discussed below. 

(This should not be viewed as a comprehensive account of all available resources.) 

#	 The Federal Emergency Management Agency Publication 325 (“Debris Management 

Guide”) provides guidance on how to triage large volumes of wastes, primarily from natural 

disasters. The document is available online at www.fema.gov/rrr/pa/dmgtoc.shtm. 

#	 The United States Army Corps of Engineers has developed guidance on removing debris 

containing chemical, biological, or radiological agents. 

#	 A panelist noted that the Department of Energy has a Web site dedicated to waste 

management (www.em.doe.gov/em30/). The Web site focuses on managing radioactive 

wastes, but the concepts presented on the site could pertain to waste management challenges 

for building decontamination debris. 

#	 In developing a triage, it is critical to incorporate the need for the timing for recovery and 

occupancy of residences and businesses. This is important in restoring normalcy to the 

impacted area and assisting in it’s economic recovery. 

19

V. Storing, Handling, and Transporting Wastes

A. What do we know? 

The workshop panelists discussed numerous topics related to storing, handling, and transporting 

wastes from buildings contaminated with chemical and biological agents. Experiences with these 

issues were based largely on the waste management challenges faced at buildings that were 

contaminated with anthrax spores in 2001. The discussions for this topic area focused primarily on 

six specific issues: 

#	 Temporary on-site storage of wastes. The workshop panelists identified several factors that 

will determine whether wastes should be stored temporarily at sites contaminated with 

chemical or biological agents. Generally speaking, prolonged on-site waste storage increases 

the likelihood that building occupants, trespassers, or others might inadvertently or 

intentionally release chemical or biological agents. Similarly, prolonged storage of vectorborne agents (e.g., plague) would raise concerns about rodents, dogs, or other animals 

spreading agents from wastes to local communities. Given these concerns, the panelists 

emphasized the need to have all wastes properly containerized (see the next bulleted item), 

stored in secure locations, and promptly sent to waste management facilities when possible. 

Several panelists noted that the need for on-site waste storage will likely depend on sitespecific conditions. For example, when the American Media Inc. office building in Florida 

was contaminated with anthrax spores, on-site waste storage was a sensible option because 

the entire building was shut down. For the media sites in New York City, on the other hand, 

on-site waste storage was not preferred because the affected skyscrapers remained open for 

business. Another consideration is the capacity of the disposal or incineration facilities that 

will receive the waste streams: on-site waste storage might be necessary when these facilities 

have limited capacity to handle waste streams containing chemical and biological agents. 

Given that most contaminated building scenarios will require some on-site waste storage, the 

panelists identified additional factors for site coordinators to consider. For instance, 

constructing staging areas or exclusion zones may be necessary to prevent crosscontamination of biological agents. Representatives from EPA’s Environmental Response 

Team indicated that they already have procedures and emergency response kits that help with 

these construction tasks. Other panelists noted that some states might require permits for onsite storage areas. 

#	 Containerization. The workshop panelists discussed the containers that should be used for 

handling wastes from building contamination sites. The panelists generally agreed that 

containerization must occur on site, in order to prevent cross-contamination and to protect 

the workers who later handle wastes. Federal and state transportation regulations would 

likely dictate the finer details of waste containerization. For example, DOT regulations 

20

specifically address packaging issues (e.g., selecting appropriate containers, labeling, 

placarding) for shipments of hazardous materials (see 49 CFR 173, 178–180), but the extent 

to which these regulations apply depend on the type of waste being managed. DOT has 

guidance on packaging and transport for chemical/biological wastes. These are a 

modification of procedures for medical wastes. Infectious agents, including regulated 

medical waste, typically require triple packaging that can withstand a 30-foot drop or being 

impaled by a steel rod. An issue that is not resolved, however, is exactly how waste providers 

should determine whether decontaminated items are infectious—an important consideration 

because items that are not classified as infectious can be shipped as municipal solid waste 

or construction and demolition debris (unless state regulations dictate otherwise). The 

panelists reiterated that further research is needed on the effectiveness of decontamination, 

because the current regulatory framework does not provide objective criteria for determining 

when wastes contain infectious agents. 

The panelists identified many different types of containers that are used to ship packaged 

wastes. These include open containers (e.g., dump trucks covered with tarps) and closed 

containers (e.g., trailers). Although non-hazardous wastes that are no longer infectious could 

technically be shipped in open containers, at least according to federal transportation 

regulations, panelists noted that most states would likely require wastes from sites containing 

biological agents—including decontaminated wastes—to be packaged and shipped in closed 

containers. This should be planned in advance and coordinated among DOT, CDC, and DHS.

 One panelist noted that use of “macro-encapsulation” containers might be a viable option 

for some sites. These containers, made from high-density polyethylene plastic, are sealed 

after being loaded with wastes. The entire containers are then disposed of in landfills; there 

is no need to open them or handle their contents. 

#	 Handling. The workshop panelists generally agreed waste handling should be minimal in 

order to prevent chemical and biological agents in wastes from entering the environment. To 

minimize handling and avoid cross-contamination, all size reduction and packaging of wastes 

should occur at the site where waste is generated, so that haulers and employees of waste 

management companies do not become exposed to the agents. Further, appropriate 

technologies for moving wastes at landfills or incinerators depend on the nature of the waste 

being shipped. Landfill operators, for instance, generally should not use handling techniques 

(e.g., tipping, using steam shovels) that can breach containers of infectious waste. It was also 

noted that procedures need to be in place for respectful management of contaminated 

cadavers to minimize worker and public exposure. 

#	 Transportation modes. The panelists said that wastes from most building contamination 

sites will likely be shipped via truck, rail, or barge. The most appropriate and efficient 

transportation mode will vary from one location to the next—it will depend on the proximity 

of the waste site and eventual waste management location to railroads and barge stations, 

existing infrastructure, equipment availability on short notice, public acceptance, and overall 

project costs. Because the safety and security of shipping wastes containing chemical or 

21

biological agents may be an overriding concern, the need for escorts and dealing with the 

potential for spills must also be considered. It was noted that in general, though, there is 

inadequate transportation infrastructure for major events. 

The panelists suspected that shipping containerized waste in enclosed trucks will probably 

be the most efficient transportation mode for most locations, though exceptions clearly occur. 

For instance, barge transport was a logical and economical choice for shipping wastes 

generated during the World Trade Center disaster, because New York City already had the 

necessary infrastructure to support this transportation mode and a permitted landfill with 

capacity and barge access. In this case, hauling wastes in trucks was not desirable given that 

trucks would have to travel through densely populated and highly congested areas. State and 

local agencies ultimately should be able to determine the most appropriate transportation 

modes within their jurisdictions based on the available waste management sites and the 

existing road, rail, and barge infrastructure. Cost-benefit analyses can help determine whether 

investing in certain transportation modes (e.g., constructing transfer stations) is worthwhile. 

#	 Transportation regulations and requirements. Noting that existing regulations will largely 

dictate how on-site coordinators transport wastes, workshop panelists emphasized the need 

to become familiar with DOT regulations and those of state transportation authorities. As 

noted previously, the applicability of DOT’s hazardous materials regulations depends 

primarily on how the on-site coordinator characterizes wastes. However, experiences from 

transporting debris from the anthrax-contaminated buildings indicate that, for specific 

responses to bioterrorism events, states sometimes implemented more stringent shipping 

requirements than DOT does. (Some questions remained about whether states truly had the 

authority to do so.) Generally speaking, specific requirements that might apply for a given 

scenario include driver training, registration, tracking, identifying transportation routes, 

decontaminating containers, the need for police escorts, and limiting waste shipments to 

vehicles dedicated entirely to transporting regulated medical waste or hazardous waste. 

Panelists who worked on these sites strongly recommended that on-site coordinators work 

directly with DOT and state officials to learn exactly what regulations apply, and whether 

exemptions for emergency situations can be issued. DOT can issue letters of interpretation 

or guidance documents to address specific challenges that future waste management 

scenarios raise. Throughout this discussion, several workshop panelists emphasized the need 

to track wastes containing chemical and biological agents from the origin, through storage, 

to the ultimate waste disposal or incineration facility. To emphasize concerns about tracking, 

one panelist noted that failure to account for where wastes containing chemical or biological 

agents presents an opportunity for terrorists to retrieve these agents and use them for future 

attacks. 

#	 Worker and public safety. Panelists noted that transporting wastes containing chemical and 

biological agents poses health risks not only to transporters, but also to residents who live 

along transportation routes. A DOT representative indicated that DOT’s worker training 

22

requirements (49 CFR 172, Subpart H) are limited to topics such as security, safety, and 

general awareness of hazards; some transporters might also be required to have written safety 

and security plans. Other panelists noted that EPA and OSHA might have additional training 

requirements for waste transporters, but these requirements were not discussed further. 

During this discussion, some panelists asked under what circumstances, if any, should 

transporters be immunized against agents, receive prophylactic therapy, or enter medical 

monitoring programs. Panelists were unaware of any specific requirements that address these 

issues and suggested that employers in such cases consult with clinicians for further insights. 

B. What research or information needs were identified? 

Workshop panelists identified several information gaps regarding handling, storing, and transporting 

wastes, along with research needs or action items for filling these gaps: 

#	 On-site coordinators for buildings contaminated with chemical and biological agents would 

benefit greatly from having clear guidance or other information materials on waste storage, 

handling, and transportation. Examples of resources that can be developed include concise 

summaries of DOT regulations, review of USDA regulations (for “foreign waste” categories) 

checklists for on-site coordinators, case studies for selected building contamination 

scenarios, and training or outreach materials for transporters. Another suggestion was to 

standardize sizing and packaging of wastes to minimize handling, meet DOT regulations, and 

accommodate disposal sites. A panelist suggested that a matrix be developed to determine 

“what wastes fit where” and how such waste must be sized and packaged for acceptance at 

a given facility; such a matrix should recognize the possibility of using unconventional 

packaging types (e.g., a mobile material packaging unit might be most appropriate for some 

waste management scenarios). Vulnerability analysis should be conducted on the 

transportation options. 

#	 As in other areas discussed, multiple panelists strongly encouraged that future guidance 

documents urge state and local agencies to plan in advance for how they will handle the 

technical challenges of storing, handling, and transporting wastes that might contain 

chemical or biological agents. Agencies can accomplish this by incorporating waste storage, 

handling, and transportation directly into future emergency response drills and mock terrorist 

attacks, such that first responders and on-site coordinators can determine whether they are 

prepared to handle these wastes. Additionally, state and local agencies can plan in advance 

by identifying preferred transportation modes, locating waste management facilities that are 

willing to accept wastes, and listing points of contact at state and federal transportation, 

environmental, and health agencies. Panelists noted that EPA can assist in these efforts 

possibly by developing an electronic database with information (e.g., location, capacity, 

transportation routes) on waste management facilities across the country. Some panelists 

suggested that parties responsible for emergency planning identify, in advance, any 

equipment (e.g., waste containers) that might be needed to respond to future events. 

23

#	 Several panelists reiterated that waste storage and transportation challenges would benefit 

from further research on decontamination effectiveness for biological agents. Specifically, 

panelists said that waste generators need objective criteria to determine whether or not a 

waste should be considered infectious—a distinction that strongly influences the applicable 

DOT regulations. On another note, one panelist recommended that EPA or other agencies 

consider researching how effectively staging areas or exclusion zones truly contain biological 

agents, given past experiences that found such areas to be not entirely effective. 

#	 The panelists raised additional issues for EPA and other agencies to consider, such as 

whether generators, transporters, and waste management companies will be liable for 

inadvertent releases of chemical and biological agents; the extent to which environmental 

monitoring is necessary at transfer stations and staging areas; and whether government 

agencies should consider investing in infrastructure for waste transportation. Another action 

item raised was how to handle large volumes of body parts and human cadavers that are 

potentially contaminated with biological agents. Several panelists were concerned about this 

issue given that body parts and human cadavers, even if they contain infectious agents, are 

not considered regulatory medical waste or hazardous waste in most jurisdictions. These 

panelists suggested that an inter-agency effort, perhaps including DOT, the Department of 

Homeland Security, and the Department of Health and Human Services, is needed to address 

this issue. 

#	 A number of panelists indicated that the Federal Government may need to provide the needed 

infrastructure for containing and transporting wastes to effectively manage major events. 

This would include an evaluation of the needed capacity and locational requirements. 

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on handling, storing, and transporting wastes 

from buildings contaminated with chemical or biological agents. The resources identified during the 

workshop are discussed. (This should not be viewed as a comprehensive account of all available 

resources.) 

#	 DOT has many information resources on transporting wastes. The information ranges from 

the original hazardous material transport regulations (primarily in 49 CFR 171–180) to 

statistics on accidental releases from different types of containers and transportation modes. 

Further information can be obtained on these issues by visiting the DOT Web site on 

hazardous material transportation (http://hazmat.dot.gov), by contacting the agency’s hotline 

(800-467-4922 or 202-366-4488), or by submitting questions via electronic mail 

(infocntr@rspa.dot.gov). A specific DOT guidance document of interest is “Guidelines for 

Transporting Anthrax and Anthrax-Contaminated Objects and Materials.” This is available 

online at: http://hazmat.dot.gov/guide_anthrax.htm. 

#	 The New York State Department of Environmental Conservation (NYSDEC) developed a 

guidance document to help generators and transporters understand the regulatory framework 

24

for storing, handling, and transporting wastes from biohazard incidents. The document 

(“New York State Department of Environmental Conservation Program Policy for the 

Handling, Storage, Transport, Treatment and Disposal of Waste Generated from a Biohazard 

Incident”) is not yet available on the agency’s Web site, but a draft copy of the document has 

been forwarded to EPA. Such draft document has been modified in format and scope since 

the May 2003 meeting in Cincinnati and will likely undergo additional changes before it is 

finalized for distribution. 

#	 Several panelists indicated that the Department of Defense likely has prepared internal 

guidance on storage, handling, and transportation of wastes containing chemical agents for 

the installations engaged in demilitarization activities. 

#	 Virginia has regulations in place on use of barges and ships and has identified standards for 

containers. 

25

VI. Disposing of Wastes in Landfills 

A. What do we know? 

Discussions on landfills began with a brief review of the different types of disposal sites. Workshop 

panelists suspected that wastes from contaminated buildings, if accepted by landfills, would likely 

end up in either construction and demolition landfills, municipal solid waste landfills, or hazardous 

waste landfills. Each type of landfill has different regulatory requirements, which largely dictate 

whether the landfills have liners, leachate collection systems, daily covers, mandatory worker safety 

training, or the need to preserve the integrity of containerized wastes. These factors might affect 

future decisions on what kinds of wastes can be disposed of in the different types of landfills. 

Another factor that might influence future waste management decisions is the available capacity of 

the different landfills. Data presented by the panelists indicated that every state has multiple 

municipal solid waste landfills and construction and demolition landfills. These landfills have widely 

varying capacities, but many of them may not be able to handle large volumes of wastes generated 

during terrorist attacks. The larger landfills are more likely to have the equipment and personnel 

needed to manage wastes from such events, assuming the landfill operators are willing to accept 

these wastes—an important issue discussed in greater detail below. Unlike the construction and 

demolition landfills and municipal solid waste landfills, few hazardous waste landfills are currently 

operating, possibly fewer than 25 nationwide. Though the hazardous waste landfills may have the 

necessary infrastructure to handle wastes from terrorist attacks, they might not be a reasonable waste 

disposal option for areas without nearby landfills. 

In terms of capacity alone, landfills appear to be far more capable than incinerators at managing large 

volumes of waste over short time frames. However, past experiences have suggested that landfill 

operators are extremely hesitant, if not completely unwilling, to accept wastes that might be 

contaminated with biological agents. The landfill operators at the workshop stated that scientific 

issues still need to be resolved before they feel comfortable disposing of wastes that contain, or 

might contain, biological agents. Operators expressed concern about risking their assets and 

assuming other liabilities simply by processing a single waste stream, even if the waste involved has 

already been decontaminated in autoclaves. Thus, on-site coordinators might have difficulty 

identifying landfills willing to accept wastes that might contain biological agents, due to perceived 

risks and liabilities. Specific concerns raised by landfill operators follow: 

#	 Unresolved scientific issues. Noting that scientists have not developed widely accepted 

decontamination criteria, landfill operators who attended the workshop expressed concern 

about disposing of wastes potentially contaminated with biological agents. This concern will 

likely remain until scientists develop (and regulators adopt) specific guidance on the 

effectiveness of decontamination. Landfill operators also noted that only very limited 

scientific information is currently available on the fate of chemical and biological agents in 

landfill environments and whether these agents might eventually be released in leachate or 

26

to the air. Another concern was that chemical or biological agents might contaminate landfill 

equipment or otherwise damage landfill assets. The next section of this report lists specific 

research needs that panelists identified to address these and other unresolved scientific issues. 

#	 Absence of guidance or clear regulatory framework. The landfill operators at the 

workshop emphasized that operating permits typically dictate the types of wastes (usually by 

waste codes) that landfills are allowed to receive. However, waste codes have not been 

developed to classify building debris or spent personal protective equipment possibly 

contaminated with chemical or biological agents. As long as regulations and agency guidance 

documents do not specify when landfills can accept and dispose of these types of wastes, the 

operators suspected that most landfills will continue to refuse wastes that might be 

contaminated with biological agents. As the next section describes, the workshop panelists 

offered many suggestions for EPA to consider when developing guidance for landfills on this 

issue. Such guidance should acknowledge that waste management regulations vary from one 

state to the next. 

#	 Other issues. The panelists identified many other concerns that landfill operators have 

expressed about disposing of special wastes at their facilities. First, several panelists 

wondered how they can ensure that wastes from terrorist incidents do not endanger their 

workers, including haulers, equipment operators, environmental monitoring personnel, and 

others with site access. Panelists asked, for instance, if landfills would need to implement 

additional health and safety training, medical monitoring, or vaccination programs, or to 

require employees to receive prophylactic therapies. Second, operators asked if landfills that 

receive special wastes will need to monitor the air, groundwater, or leachate for chemical and 

biological agents. Finally, the panelists raised many additional issues that EPA and landfill 

operators might need to consider, such as liability concerns, public perception, and the need 

for vector control. One panelist noted that legal issues may require negotiations and 

provisions proposed to Congress to address industry’s concern regarding liability in the event 

of a terrorist attack that requires private firms to assist with the public disaster. 

In this discussion, panelists suggested three options for EPA to consider when developing guidance 

on disposing of wastes from buildings contaminated with chemical or biological agents. First, several 

panelists suggested the possibility of constructing “mono-fills” to handle special waste streams at 

existing landfill sites. Landfill operators could isolate the wastes of concern in these mono-fills, 

which can either serve as temporary storage areas or as permanent disposal sites. Second, some 

panelists said that EPA might be able to coordinate special waste disposal activities with the 

Department of Defense: many states have military installations that not only have active landfills, 

but also have security measures to prevent unauthorized access. Third, several panelists suggested 

that EPA consider evaluating the feasibility of temporary waste storage options using “macroencapsulation units.” This technology has been used to dispose of decontaminated furniture from an 

office building that received an anthrax-tainted letter. In that case, the furniture items and other 

materials were placed into a macro-encapsulation unit, which was filled with cement kiln dust and 

then sealed. Use of the high-pH cement kiln dust is believed to render the macro-encapsulation unit 

27

unsuitable for microbial growth. Some panelists indicated that macro-encapsulation units, which 

have capacities of approximately 20 tons, could be useful when temporary storage of wastes is 

needed. 

B. What research or information needs were identified? 

Workshop panelists identified several information gaps regarding disposing of wastes in landfills, 

and noted research needs or action items for filling these gaps. They discussed the following issues: 

#	 Several panelists recommended that EPA develop data, whether modeled or experimental, 

that characterize the fate of selected biological and chemical agents in landfills. One 

suggestion was to perform bounding calculations to assess the fate of chemical agents in 

landfills; these calculations could be based on conservative transport assumptions and the 

agents’ relevant chemical and physical properties (e.g., vapor pressure, solubility, octanolwater partition coefficient). The calculations can provide insights, for example, on whether 

disposing of wastes containing chemical agents would produce unacceptable air 

concentrations at the landfill surface. 

#	 Other panelists recommended that EPA conduct experiments to simulate the movement of 

chemical or biological agents through landfill environments. One suggestion was that 

researchers use lysimeters filled with waste to determine whether agents in the waste will 

enter leachate or air. Such experiments could investigate contaminant mobility for many 

landfill conditions and waste matrixes. Another suggestion for experimental research was to 

evaluate whether biological agents would remain viable in the pH conditions typically found 

in different types of landfills. Similarly, panelists suggested that EPA examine whether 

biological agents remain viable under the high pH conditions present in macro-encapsulation 

units filled with wastes and cement kiln dust. Finally, one panelist suggested that 

experimental research can eventually consider the fate of chemical and biological agents in 

test cells at select landfills. 

#	 The panelists identified many other unresolved scientific issues, such as whether chemical 

or biological agents might damage landfill liners, leachate collection systems, and gas 

recovery systems and how waste generators can demonstrate that their waste streams are 

decontaminated. The panelists did not identify specific research projects that can address 

these information gaps. 

#	 Panelists said that landfill operators would benefit greatly from EPA preparing a protocol or 

guidance document that addresses technical issues associated with disposing of special 

wastes. Specific issues such a document could address include: what wastes may and may 

not be accepted, when wastes must be containerized, under what circumstances temporary 

storage of wastes is preferred, under what circumstances segregating wastes into a mono-fill 

is preferred, what minimum landfill design features are needed to receive special wastes, 

what additional environmental monitoring is needed, and whether landfill operators will be 

28

held liable for disposing of wastes according to these guidelines. Once these and other related 

issues are addressed in an authoritative document written by EPA, waste management 

decisions might be less complicated to address. Some panelists indicated that EPA might 

need to have its eventual guidance documents subject to peer review, possibly by 

independent panels or by bodies like the National Academy of Sciences. Other panelists 

noted that guidance documents should acknowledge that waste management regulations can 

vary from one state to the next. 

#	 The Federal Government may need to pre-determine potential landfill sites that would be 

available to dispose of chemical/biological agents. This assessment should include location, 

security, and capacity issues. This assessment should include existing facilities as well as 

new facilities that would offer more security and/or the ability to be operated as a monofill. 

#	 Several panelists suggested that EPA consider developing a dynamic database that 

periodically tracks landfill capacity (in active cells) for different types of landfills around the 

country, including those on military installations. This database could be accessed by parties 

responsible for disposing of wastes that contain chemical or biological agents. 

#	 Some panelists recommended that EPA review the literature and consult with other agencies 

about existing information on the fate of biological agents in landfills. One panelist, for 

instance, indicated that modeling studies conducted by environmental agencies in the United 

Kingdom have already examined the environmental fate of prions. Panelists cautioned EPA 

about using literature on the fate of biological agents in soils, because landfills and soils are 

considerably different environments. 

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on disposing of wastes from buildings 

contaminated with chemical or biological agents into landfills. The resources identified during the 

workshop are discussed. (This should not be viewed as a comprehensive account of all available 

resources.) 

#	 One document cited at the workshop is the National Response Team’s 2002 draft-final 

document titled “Technical Assistance for Anthrax Response.” The document is available 

from NRT’s Web site (http://www.nrt.org). It addresses a wide range of technical issues for 

anthrax, including sampling and analysis, decontamination, storage, and disposal. 

29

VII. Incineration

A. What do we know? 

Incineration technologies were discussed extensively, especially considering that many potential 

waste streams from terrorist attacks might not be allowed in, or accepted by, landfills. Based on 

experiences from weapons demilitarization operations and management of wastes from anthraxcontaminated buildings, panelists generally accepted that incineration is a viable option for treating 

wastes that might contain chemical or biological agents. But the panelists, particularly the 

representatives from incineration facilities, listed several scientific, technical, and public perception 

issues that need to be resolved or considered to ensure that wastes are incinerated properly and in 

a manner that does not harm the environment, compromise worker safety, or damage the assets at 

incineration facilities. 

The panelists identified five general types of thermal treatment technologies that might be used to 

treat wastes containing biological and chemical agents. This discussion addressed the typical sizes, 

capacities, and other relevant features of the technologies: 

#	 Hazardous waste incinerators (HWIs). The panelists reviewed various hazardous waste 

incineration technologies, but focused on fixed hearth and rotary kiln incinerators as the most 

likely candidates to manage wastes containing biological and chemical agents.2

 A panelist 

noted that 7 fixed hearth and 37 rotary kiln HWIs currently operate in the United States, 

though many of them are dedicated to specific waste streams at industrial facilities or are 

located at military installations. Advantages of using HWIs include the fact that regulations 

already require these incinerators to have waste tracking mechanisms and employee safety 

training programs. Possible disadvantages include the fact that most HWIs are located in 

relatively remote areas, the limited capacities of HWIs, and size limitations. For perspective 

on typical waste processing capacities, one panelist noted that the three rotary kiln HWIs he 

contacted before the workshop could process between 50 and 175 tons of hazardous waste 

per day. Typically, the sizing for the feed stream is the rough dimensions of a drum. 

#	 “Waste-to-energy” facilities. The panelists said that municipal solid waste incinerators 

might be able to handle wastes containing chemical and biological agents. Panelists noted 

several potential advantages to these facilities: when compared to HWIs, the waste-to-energy 

facilities tend to be closer to urban centers, where terrorist attacks on buildings would most 

likely occur; they generally have much larger processing capacities than HWIs; and they are 

believed to have more flexibility to implement specific engineering changes (e.g., altering 

2

 The panelists acknowledged that other types of facilities, such as cement kilns, boilers, and industrial 

furnaces, combu st hazardous wastes. They did not disc uss such facilities in detail, beca use these facilities typically 

require hom ogeneous waste streams and likely wou ld not be ab le to pr ocess the wid e rang e of wa stes that wo uld 

probably be generated in a building contamination scenario. One panelist said that cement kilns might be able to treat 

contamina ted ca rpets, b ut this issue was not discussed ex tensively. 

30 
the feed inlets) in order to accommodate special wastes. 

Potential disadvantages included public perception associated with incinerating special 

wastes near population centers and permit restrictions for these facilities. Another limitation 

is the fact that, while waste-to-energy facilities are designed to receive and process many 

thousands of tons of waste per week, they are not particularly suited for large bulky items. 

Processing larger items can cause operational upsets (e.g., plugging the feed chute or ash 

discharger) and can complicate efforts to homogenize wastes, which is needed to achieve 

optimum combustion conditions. The need to homogenize wastes raised further concern that 

doing so can generate dusts in the pit area, where workers might be exposed to chemical and 

biological agents. Another possible limitation associated with waste-to-energy facilities is 

the fact that many facilities are municipally owned and privately operated and have business 

and financial relationships with their client communities. As a result, some owners and 

operators might not be able to offer or make available their waste-to-energy facilities for 

wastes from terrorist attacks. 

The panelists did not indicate exactly how many waste-to-energy facilities operate in the 

United States, though they noted that the number is likely far greater than the number of 

HWIs. 

#	 Medical waste incinerators (MWIs). Participants noted that MWIs likely could handle, and 

would be allowed to process, certain types of wastes containing chemical or biological 

agents, even though they are permitted to handle wastes primarily from clinical and research 

settings. Regulators might need to issue permit modifications or exemptions for MWIs to 

process these wastes. One panelist noted that an estimated 115 MWIs currently operate in 

the United States, including 22 commercial MWIs. The processing capacity for these 

incinerators is generally 1 ton of waste per hour. The most notable limitation for MWIs is the 

size of the waste that can be processed: one panelist pointed out that the typical hopper size 

for most MWIs is 3 feet by 5 feet by 5 feet. 

#	 Autoclaves. Panelists briefly reviewed information on autoclaves, which sterilize wastes 

using steam, heat, and pressure. Autoclaves range in size from bench-top devices to large 

commercial operations. These commercial facilities can process up to 96 tons of waste per 

day, and some have waste inlet openings up to 8 feet in diameter. Potential advantages of 

using commercial autoclaves to sterilize waste include the ease with which processing 

conditions can be altered for specific waste streams, the ability to process large waste items, 

and the fact that these facilities often have testing requirements for spore destruction. 

Potential disadvantages include worker safety issues (which already have been documented 

for an autoclave where elevated mercury exposures occurred) and the issue of disposing of 

decontaminated wastes. 

#	 Alternative treatment technologies. The panelists identified several other technologies that 

might hold promise for future waste management challenges. Specific suggestions include 

31

plasma treatment technologies, ionizing radiation, and thermal microwave technologies. The 

panelists did not discuss these technologies in detail (except for the potential use of plasma 

technologies to treat large numbers of human cadavers following a bio-terrorism attack) and 

indicated that the performance of these technologies has yet to be verified. 

The panelists identified many technical challenges that need to be resolved for incinerating wastes 

containing chemical and biological agents, regardless of the type of incinerator being considered. 

Discussions focused on considerations for the incinerator operators and the waste generators: 

#	 Challenges faced by incinerator operators. The panelists listed many potential challenges 

that incinerator operators face when receiving wastes that potentially contain chemical or 

biological agents. For instance, operators said that further research is necessary to determine 

optimal operating conditions (e.g., temperature, residence time) for adequate treatment of 

wastes; several operators added that the optimal conditions will likely depend on the specific 

chemical or biological agent of concern and the type of waste being treated (e.g., office 

materials, personal protective equipment, animal carcasses). Further, operators need guidance 

on proper waste handling procedures,3

 approaches to handling process upsets and pressure 

excursions, and how incinerator residues (e.g., ash, baghouse dusts) should be managed. The 

operators also indicated that processing wastes not specifically identified in their operating 

permits would require permit modifications, exemptions, or variances. The operators 

expressed concern about whether trial burns would be required and whether building wastes 

might contain chlorine, metals, and other constituents in amounts that would cause 

incinerators to exceed their permitted emission limits or cause corrosion of the equipment 

in the case of chlorinated disinfectants. Some incineration facilities, operators said, might 

require capital investment (e.g., a dedicated conveyor system) to address the unique 

challenges posed by processing wastes containing chemical or biological agents. 

The incinerator operators also expressed concern about protecting their business assets, 

including their employees and equipment. Specific concerns about worker safety echoed 

those raised earlier in the workshop: Under what circumstances should workers be 

vaccinated, issued prophylactic therapy, or tracked by medical monitoring programs? What 

process upsets and other operating conditions might cause incinerators to release untreated 

wastes into the workplace air? Is supplemental training needed before facilities receive 

wastes containing chemical or biological agents? The panelists generally agreed that proper 

sizing and packaging of wastes at the site of contaminated buildings will help alleviate, but 

not eliminate, worker safety concerns at incineration facilities. Another approach proposed 

to addressing worker safetyissues is having environmental, health, or safety agencies provide 

3

 There was some dissent on this matter. One panelist noted that operators of medical waste incinerators are 

already trained in the proper management and handling of infectious and highly hazardous substances and wondered 

why further training is considered necessary. On the other hand, several panelists added that incinerator operators 

and facility personnel might require special training on chemical and biological agents to address the “fear of the 

unkno wn” a nd to ensure that all facility pe rsonn el are c omfo rtable hand ling ma terials po tentially co ntamin ated w ith 

chemical an d biolog ical agents. 

32 
on-site operators for the time when special wastes are processed. An incinerator operator 

took exception to this suggestion, noting that incinerator operators are already extensively 

trained and experienced with the specific equipment and technologies used at their facilities. 

This panelist suggested that outside agencies should work cooperatively with site operators 

and personnel, rather than presume that they can or should take over operations at a given 

facility. 

During this discussion, incinerator operators wondered if EPA could assist (whether directly 

or financially) with developing training courses specific to handling chemical and biological 

agents. These operators emphasized that workers should be trained on any unique hazards 

posed by chemical and biological agents before an event occurs, such that workers can be 

educated and prepared to handle wastes in the future. 

In addition to worker safety issues, the incinerator operators asked about protection of their 

equipment, which often times represents an investment of millions of dollars. Some 

operators, for example, might be hesitant to jeopardize the ongoing operation of their 

incinerators by processing a single waste stream from a terrorist event that might contaminate 

or corrode their equipment. The operators recommended that EPA consider these liability 

concerns, possibly by indemnifying facilities that properly process wastes containing 

chemical or biological agents from unforeseen damages that might result or otherwise 

assuring operators that a financial mechanism is in place to reimburse facilities for damages 

caused by or long-term costs associated with managing waste streams containing chemical 

or biological agents. Another panelist noted that liability concerns might be addressed by 

provisions proposed to Congress. 

Finally, many panelists noted that public perception issues might be extremely difficult to 

address for incineration facilities. Some operators suspected that activists and community 

members would likely protest if wastes containing chemical or biological agents are treated 

by incinerators in their cities. Panelists suspected that strong public opposition to incineration 

could be a significant obstacle to managing wastes, especially for the waste-to-energy 

facilities, which tend to be located in or near densely populated urban settings. 

#	 Considerations for the “generators” of wastes.4 The workshop panelists also noted that 

the generators of wastes containing chemical and biological agents should be made aware 

of specific challenges that incinerator operators face. For instance, the generator should 

identify the size limitations of the incinerator that will receive the waste before shipping 

materials off site, so that wastes can be packaged accordingly. The generator also should 

determine the maximum throughput that the incinerator can handle, so that the waste stream 

does not overwhelm the incinerator’s operations. Finally, the generators need to be aware of 

specific packaging and labeling requirements; some incinerators, for example, might require 

4

 “Generator,” in this section, is meant to refer to the party that collects the waste at the site of an incident 

and ships the pack aged waste to the incine rator. T his will likely be a loca l or state a genc y. 

33 
that each waste item have a label specifying the heat content, volatility, and composition (at 

least of chlorine and metals) of the waste material. Most of these issues can be resolved 

during planning for terrorist attack scenarios. 

The workshop panelists raised several additional waste management options or scenarios for EPA 

to consider. First, they debated whether mobile incineration units would be viable options for 

processing wastes from buildings contaminated with chemical and biological agents. While the 

mobility of these units is clearly an advantage, panelists were concerned about the need for obtaining 

operating permits on short notice, the destruction efficiencies that the mobile units can achieve, 

whether public perception will preclude the use of mobile incinerators in urban settings, and the 

limited capacity and inlet size restrictions for the existing mobile incineration units. Second, some 

panelists wondered if a combination of waste management technologies (e.g., disinfecting wastes 

in an autoclave, disposal of disinfected wastes in a landfill) might be preferred for certain types of 

wastes. Third, some panelists said that EPA should be aware that some incinerators that are currently 

closed can be brought back online, if necessary, with relatively low capital investment. Finally, the 

panelists discussed the unique challenges of handling human cadavers or body parts that are 

contaminated with biological agents. As noted previously, the panelists indicated that multiple 

agencies might need to coordinate efforts to ensure that contingency plans are in place to handle 

large numbers of potentially contaminated cadavers. 

B. What research or information needs were identified? 

Workshop panelists identified several information gaps for incinerating wastes from buildings 

contaminated with chemical and biological agents, and noted associated research needs or action 

items for filling these gaps. The following issues were discussed: 

#	 Several panelists identified opportunities for scientific research into ensuring that 

incineration facilities properly destroy wastes. For instance, some panelists indicated that 

bench-scale and pilot-scale experiments using surrogate agents could characterize the 

minimum residence time and temperature needed to properly treat chemical and biological 

agents bound to different matrixes. Such research could range from examining fundamental 

heat transfer and mass transfer behavior that can be incorporated into computational models 

to conducting trial burns that examine destruction efficiencies and residue content for more 

challenging waste streams (e.g., rolled-up carpet soaked in water). Other waste sources that 

may present problems for incineration include animal carcasses, wastewater from 

decontamination and radioactive wastes. A concern was also raised about the combustion 

products produced, e.g. disinfectant dosages resulting in significant dioxin formation and 

metals from electronics. One panelist noted that EPA is already conducting some research 

on these incinerator performance issues, and another panelist indicated that EPA has already 

conducted modeling of full-scale medical waste incinerators for spore destruction. 

#	 For the benefit of the state and local agencies that might be faced with waste management 

challenges in the future, EPA could develop an inventory of different types of incinerators 

34

and throughput capacity across the United States, including HWIs, MWIs, waste-to-energy 

facilities, and commercial autoclaves. Panelists suggested that such an inventory can identify 

the locations, capacities, types of units, inlet size restrictions, accessibility by rail car, and 

other features of incineration facilities. The inventory should include all types of incinerators 

that might receive wastes containing chemical and biological agents, including incinerators 

at military installations and “captive” incinerators at industrial facilities that typically process 

only those wastes generated on site. When reviewing the existing infrastructure, EPA can 

also identify engineering challenges that prevent incinerators from accepting wastes (e.g., 

inlet size restrictions) and determine how these challenges might be addressed. 

#	 Several panelists noted that state and local agencies should consider the available 

incineration capacity when developing plans for how to handle wastes contained with 

chemical and biological agents. These agencies should identify a number of issues including 

which incinerators are willing and able to accept wastes containing chemical and biological 

agents, what types and sizes of wastes they can process, how wastes should be packaged 

before being sent to the incinerator. This recommendation is consistent with a general theme 

expressed throughout the workshop: very few waste management options are available for 

wastes generated when buildings are contaminated with chemical or biological agents. 

Recognizing this, several panelists recommended that the state and local agencies first 

identify the limited number and type of facilities that are willing and capable to receive the 

wastes, and “work backwards” to specify what types of wastes should be sent to the 

identified facilities. 

#	 A number of panelists indicated that operator training is needed to handle these types wastes. 

This should be built on training that exists for operators. 

#	 Some panelists indicated that EPA could continue to examine the effectiveness of alternative 

treatment technologies (e.g., plasma, ionizing radiation, thermal microwave). These panelists 

noted that EPA has already published specifications for verifying the effectiveness of new 

technologies for treating medical waste, as has the State and Territorial Association on 

Alternative Treatment Technologies. 

C. What information resources are currently available on this matter? 

The panelists identified several sources of information on incinerating wastes from buildings 

contaminated with chemical or biological agents. The main resources identified during the workshop 

are discussed below. (This should not be viewed as a comprehensive account of all available 

resources.) 

#	 The Integrated Waste Services Association has prepared a report documenting the locations, 

capacities, and other information about selected waste-to-energy facilities across the United 

States. This report—The 2002 IWSA Directory of Waste-to-Energy Plants—is available on 

the association’s Web page: http://www.wte.org. 

35

#	 Several panelists noted that the Department of Defense should have information available 

on incineration of chemical agents, particularly from installations that are in the process of 

obtaining operating permits for demilitarization activities. The incinerators at these sites 

might be the most appropriate destination of wastes from terrorist attacks involving chemical 

agents, assuming they can handle the types of wastes that must be disposed of or treated. 

#	 One panelist encouraged EPA to obtain and review a testing protocol recently used to 

evaluate a technology’s effectiveness for deactivating prions. Testing was conducted by the 

USDA for a technology developed by a company named Waste Reduction by Waste 

Reduction. 

36

VIII. List of Participants

The following pages list the panelists who participated in the workshop. The list does not include 

those who were invited to participate but could not attend the workshop. 

37

United States 

Environmental Protection Agency 

Office of Research and Development 

Homeland Security Workshop on Transport and 

Disposal of Wastes from Facilities Contaminated 

with Chemical/Biological Agents 

Marriott Kingsgate Conference Center 

Cincinnati, OH 

May 28-30, 2003 

Workshop Participants List 

Morton Barlaz JoAnn Camacho 

Professor 

Department of Civil Engineering 

North Carolina State University 

Box 7908 

Raleigh, NC 27695 

919-515-7676 

Fax: 919-515-7908 

Email: barlaz@eos.ncsu.edu 

Environmental Engineer 

Environmental Response Team 

U.S. Environmental Protection Agency 

2890 Woodbridge Avenue 

Edison, NJ 08837 

732-906-6916 

Email: joann.camacho@epa.gov 

David Carson 

Ernest Bennett National Risk Man agem ent R esea rch 

Vice President Laboratory (NRMRL) 

Montenay Power Corp. U.S. Environmental Protection Agency 

Rt 8 Box 757 26 West Martin Luther King Drive (CHL) 

Lake City, FL 32055 Cincinnati, OH 45268 

386-755-2264 513-569-7527 

Fax: 386-754-5975 Email: carson.david@epa.gov 

Email: ebenett@bellsouth.net 

Mark Brickhouse 

Team Leader 

Edgewood Chemical Biological Center 

ATTN: AMSSB-RRT-PD 

Aberdeen Proving Ground, MD 21010-5424 

410-436-8479 

Fax: 410-436-7203 

Email: mark.brickhouse@sbccom.apgea.army.mil 

Greg Cekander 

Vice President, 

Environmental Management Group 

Waste Management Inc. (WMI) 

1001 Fannin Street 

Suite 4000 

Houston, TX 77002 

713-328-7332 

Fax: 713-328-7411 

Email: gcekander@wm.com 

38

David Cleverly 

Environmental Scientist 

National Center for Environmental Assessment 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW (8623D) 

Washington, DC 20460 

202-564-3238 

Fax: 202-565-0076 

Email: cleverly.david@epa.gov 

Wendy Davis-Hoover 

Research Microbiologist 

Remediation and Containment Branch 

U.S. Environmental Protection Agency

5995 Center Hill Avenue (CHL) 

Cincinnati, OH 45215 

513-569-7206 

Fax: 513-569-7879 

Email: davis-hoover.wendy@epa.gov 

Robert Eckhaus 

Chemical Engineer 

Homeland Defense Business Unit 

Edgewood Chemical Biological Center 

ATTN: AMSSB-REN-HD 

BLDG E3320 

Aberdeen Proving Ground, MD 21010-5424 

410-436-5981 

Fax: 410-436-3207 

Email: robert.eckhaus@sbccom.apgea.army.mil 

Eileen Edmonson 

Transportation Regulations Specialist 

Office of Hazardous Materials Standards 

Research and Special Programs Administration 

400-7th Street, SW (DHM-12) 

Room 8430 

Washington, DC 20590 

202-366-4481 

Fax: 202-366-3012 

Email: eileen.edmonson@rspa.dot.gov 

John Ely 

Director, Office of Waste Programs 

Virginia Department of Environmental Quality 

P.O. Box 10009 

Richmond, VA 23240 

804-698-4249 

Fax: 804-698-4327 

Email: jeely@deq.state.va.us 

Mark Galgano 

National Tech Transfer Center/Commerce 

Services Corporation 

698 East Washington Street 

Medina, OH 44256 

330-721-9139 

Fax: 330-721-9139 

Email: galganom@cscventures.com 

Greg Gesell 

Principal Environmental Engineer 

American Ref-fuel Company 

2827 Skylark Street 

Fremont, NE 68025 

402-721-5971 

Fax: 402-721-7874 

Email: greg.gesell@ref-fuel.com 

Gary Hater 

Senior Director, BioSites Program Center 

Waste Management, Inc. 

2956 Montana Avenue 

Cincinnati, OH 45211 

513-389-7370 

Fax: 513-389-7374 

Email: ghater@wm.com 

Beth Hurley 

Vice President, Health and Safety 

Covanta Energy, Inc. 

40 Lane Road 

Fairfield, NJ 07007 

973-882-7245 

Fax: 973-882-4153 

Email: bhurley@covantaenergy.com 

Melvin Keener 

Executive Director 

Coalition for Responsible W aste Incineration 

(CRWI) 

1752 North Street NW 

Suite 800 

Washington, DC 20036 

202-452-1241 

Fax: 202-887-8044 

Email: crwi@erols.com 

39

Philip Koga 

Supervisory Biologist Senior Team Leader, 

Biosciences 

Edgewood Chemical Biological Center 

Bldg E3150 (AMSSB-RRT-B) 

Aberdeen Proving Ground, MD 21010-5424 

410-436-6632 

Fax: 410-436-2081 

Email: philip.koga@us.army.mil 

Fran Kremer 

National Risk Management Research Laboratory 

(NRMRL) 

U.S. Environmental Protection Agency

26 West Martin Luther King Drive (481) 

Cincinnati, OH 45268 

513-569-7346 

Fax: 513-569-7620 

Email: kremer.fran@epa.gov 

Paul Lemieux 

Chemical Engineer 

National Homeland Security Research Center 

(NHSRC) 

U.S. Environmental Protection Agency

109 TW Alexander Drive (E305-01) 

Research Triangle Park, NC 27711 

919-541-0962 

Fax: 919-541-0554 

Email: lemieux.paul@epa.gov 

Steven Levy 

Environmental Engineer 

Office of Solid W aste 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (5306W) 

Washington, DC 20460 

703-308-7267 

Fax: 703-308-8686 

Email: levy.steve@epa.gov 

MaryAnn M arrocolo 

Director 

Recovery and Mitigation Division 

New York City Office of Emergency Management 

11 Water Street 

Brooklyn, NY 11201 

718-422-4835 

Fax: 718-422-4871 

Email: mmarroco@oem.nyc.gov 

Dennis McGow an 

Chief of Operations 

Fulton County Medica Examiner 

430 Poyor Street 

Atlanta, GA 30312 

404-730-4417 

Fax: 404-730-6990 

Email: mcchief@bellsouth.net 

Kristina Meson 

Generator and Recycling Branch 

Office of Solid W aste 

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (5304W) 

Washington, DC 20460 

703-308-8488 

Fax: 703-308-0514 

Email: meson.kristina@epa.gov 

Robert Olexsey 

Director 

Land Remediation and Pollution Control 

Division 

U.S. Environmental Protection Agency

26 West Martin Luther King Drive (481) 

Cincinnati, OH 45268 

513-569-7861 

Fax: 513-569-7620 

Email: olexsey.bob@epa.gov 

Martin Powell 

Regional Counter Terrorism Programs 

Coordinator 

U.S. Environmental Protection Agency

1060 Chapline Street 

Wheeling, WV 26003 

304-234-0252 

Fax: 304-234-0259 

Email: powell.martin@epa.gov 

Frank Schaefer 

Microbiologist 

Biohazard Assessment Research Branch 

Microbiological and Chemical Exposure 

Assessment Research Division/NERL 

U.S. Environmental Protection Agency

26 West Martin Luther King Drive (MC 320) 

Cincinnati, OH 45268 

513-569-7222 

Fax: 513-569-7117 

Email: schaefer.frank@epa.gov 

40

Howard Schmidt 

Atmospheric Scientist 

Lockheed Martin/REAC 

2890 Woodbridge Avenue, Bldg. 209 

Edison, NJ 08837 

732-321-4280 

Fax: 732-494-4021 

Email: howard.d.schmidt@lmco.com 

John Skinner 

Executive Director and CEO 

Solid Waste Association of North America 

1100 Wayne Avenue 

Suite 700 

Silver Spring, MD 20910 

301-585-2898 

Fax: 301-589-7060 

Email: jskinner@swana.org 

Susan Thorneloe 

Senior Chemical Engineer 

Air Pollution Prevention and Control Division 

National Risk Management Research Laboratory 

(NRMRL) 

U.S. Environmental Protection Agency

109 TW Alexander Drive (E305-02) 

Research Triangle Park, NC 27711 

919-541-2709 

Fax: 919-541-7885 

Email: thorneloe.susan@epa.gov 

Greg Vogt 

Project Director 

SCS Engineers 

11260 Roger Bacon Drive 

Reston, VA 20190 

703-471-6150 

Fax: 703-471-6676 

Email: gvogt@scseng.com 

Richard Watson 

Chief Engineer 

Delaware Solid Waste Authority 

P.O. Box 455

Dover, DE 19903 

302-739-5361 

Fax: 302-739-7287 

Email: rpw@dswa.com 

Angela Weber 

Industrial Hygienist 

Environmental Health Services 

Division of Emergency and Environmental 

Health Services 

Center for Disease Control (CDC) 

4770 Buford Highway (F-28) 

Atlanta, GA 30321 

770-488-7533 

F: 770-488-7310 

Email: amw1@cdc.gov 

William White 

Research Chemist 

Threat Agent Team 

Edgewood Chemical Biological Center 

5183 Blackhawk Road (AMSSB-RRT-PC) 

Aberdeen Proving Ground, MD 21010 

410-436-3058 

Fax: 410-436-2330 

Email: wewhite@apgea.army.mil 

Alan Woodard 

Environmental Program Specialist 

Solid and Hazardous Materials 

New York State Department of Environmental 

Conservation 

625 Broadway 

Albany, NY 12233 

518-402-8706 

Fax: 518-402-8681 

Email: agwoodar@gw.dec.state.ny.us 

Contract Support 

Kate Schalk 

Vice President, Conference Services 

ERG 

110 Hartwell Avenue 

Lexington, MA 02421 

781-674-7324 

Fax: 781-674-2906 

Email: kate.schalk@erg.com 

John Wilhelmi 

Chemical Engineer 

ERG 

110 Hartwell Avenue 

Lexington, MA 02421 

781-674-7312 

Fax: 781-674-2851 

Email: john.wilhelmi@erg.com 

41