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TECHNICAL TESTIMONY OF MR. BERND FRANKE; March 15, 1999. Mr. Franke received the German equivalent of a M.S. in Biology and
Geography, University of Heidelberg, 1978, and he previously received a
degree in Biology and Geography from the University of Marburg, 1975. Mr. Franke was the Executive Director of the U.S. office of the Institute
for Energy and Environmental Research (IEER) from 1984 to 1988; and from
1991 to 1999 he has been the Director of the Environmental Programs at
IFEU-Institut fur Eneregie und Umweltforschung, Heidelberg, Germany. He
was an IEER Project Director for the Department of Research and Technology,
Bonn, Federal Republic of Germany from 1981 to 1983, a member of the IEER
Senior Research Staff from 1979 to 1981, and researcher for the Department
of Social Affairs, State of Lower Saxony, Federal Republic of Germany,
1978. During his 20 years of professional experience of environmental consulting,
Mr. Franke has been involved in numerous projects which have addressed the
characterization and risk assessment of liquid and solid wastes. These
projects include: (1) Project Director of the first comparative assessment
of environmental risks from incineration and landfilling of solid wastes in
Germany in 1992; (2) main author of a two-year study (1992-1993) funded by
the German Federal Environmental Agency on "Organic and Inorganic
Pollutants in Solid Waste From Discarded Commercial Projects;" and (3)
participating as an expert in the review of the characterization of
hazardous and non-hazardous waste in Germany and addressing their potential
shortcomings in evaluating long term risks posed by landfill sites in 1995.
He has 20 years of study on radiological assessment and risk assessment
including pathway analysis and public risk. RADIOLYSIS is the decomposition of a substance as a result of radiation.
Alpha particles from the decay of transuranic waste can destroy the
molecular structure of plastic (polyvinyl chlorides (PVCs)) materials and
create new substances. Alpha particles can also impact cellulose. This
process continues as long as there is radioactive decay and these plastic
materials are present. Radiolysis of plastics can produce degradation
products such as hydrogen, hydrogen chloride, benzene, and carbon oxides.
Benzene is toxic and carcinogenic to the human body. These materials will
accumulate if they are generated in a closed rigid container. Mr. Franke testified that radiolysis will produce corrosive acids. A
technical advisor for the NMED concluded that hydrogen chloride, a
corrosive gas, could be generated from radiolysis. The technical advisor
also concluded, however, that hydrogen chloride would not be a problem
because enough would not be generated to cause any of the waste to have a
pH less than 2. The latter conclusion assumes that the hydrogen chloride
would not have reacted with water to form hydrochloric acid. It also
assumes that sealed, rigid containers did not prevent equilibrium from
taking place. The NMED's technical advisor did not have any data to
support the theory that all of the hydrogen chloride would be vented as a
gas. The draft permit recognizes that radiolysis occurs and requires the
Applicants to consider radiolysis, but the draft Permit does not include
sufficient provisions regarding radiolysis. Headspace gas sampling and analysis is the method used to detect and
measure degradation products, like benzene. Headspace gas sampling and
analysis captures only part of what is generated. Headspace gas sampling
and analysis assumes that there is an equilibrium in the gases between the
headspace and the interior of the drum, which is not always the case. The
DOE's study at the Idaho National Engineering and Environmental Laboratory
(INEEL) indicates that it takes about 245 days for gases to diffuse through
5 layers of plastic and to reach equilibrium within the drum. However, the
study neglected to address the radiolytic degradation products in rigid
containers. Sandia National Laboratory scientists Reed and Molecke's study
acknowledges, in the cases of neoprene rubber and PVC plastics, that
radiolysis will yield hydrogen chloride. Hydrogen chloride is corrosive in
its gaseous or liquid forms but is not monitored or addressed under the
draft Permit. Hygroscopic substances, like hydrogen chloride gas, attract water. The
combination of hydrogen chloride gas and water results in the formation of
corrosive, liquid hydrochloric acid. Benzene is monitored by means of headspace gas analysis, but there is no
monitoring of benzene in rigid inner containers. The accuracy of headspace
gas analysis depends on whether the gases in a waste container are in
equilibrium. The overall impact of rigid inner containers is that the drums of waste
cannot be adequately characterized. It is unknown whether there are
corrosive, ignitable, or reactive wastes in the rigid inner containers,
resulting in inadequate waste characterization. In addition, hydrogen
chloride gas is not monitored, even in the headspace gas analysis. Mr. Franke testified that the Applicant's waste characterization is
deficient because it does not monitor for substances such as hydrogen
chloride and it does not account for the gases that may be corrosive,
reactive, or ignitable and are contained within sealed, inner rigid
containers.
INEEL claims equilibrium of gases within a drum reaches 90% after 245 days,
even with 5 layers of plastic. The INEEL results are incomplete because of
the lack of testing for hydrogen chloride gas. Since hydrogen chloride is
most commonly thought of as a gas, one might expect it to be vented from
the headspace, but hydrogen chloride can leave the gaseous state at any
temperature above freezing when in the presence of a liquid. Hydrogen
chloride gas attracts water; the two combine to form droplets of liquid
hydrochloric acid. Techlaw, the NMED's contractor, concluded that hydrogen
chloride would not be a problem, but Mr. Franke disagrees with their
conclusions. Techlaw used a very short time period in their calculations
and did not sufficiently consider the rigid container issue. Techlaw
believes that all hydrogen chloride would exist in the gaseous state and
would be vented, but there is no available data supporting this. The fact
that hydrogen chloride compounds are not limited to the gaseous state was
ignored. Techlaw said that benzene was generated only from irradiation of PVCs, but
Reed and Molecke's study found that benzene could be produced in other
ways. Reed and Molecke stated that radiolysis of polyethylene did not
result in the production of benzene because it was not detected. However,
Reed and Molecke stated that this was a result of the lack of sensitivity
of their detection device. Benzene must be present in some quantity, though, because theoretical
chemistry predicts a radiolytic reaction that produces benzene. Headspace
gas analyses also detect benzene, so it must be produced by some reaction.
No one knows how much PVC plastic is contained in the waste. No one knows
how frequently benzene is generated within rigid containers, but VE has
shown that conditions conducive to benzene generation in rigid containers
do occur in the waste streams. These containers should be taken out and
sampled. Benzene may not be in high enough concentrations to be considered
hazardous waste, but its presence mandates testing and analysis to make an
educated decision about this. If one does not want to test for it, then
one can assume the waste is corrosive or reactive. There are established exposure limits for VOCs in order to protect public
health and the disposal room workers who handle the WIPP waste. It is
important that the final Permit set such limits on hydrogen chloride and
benzene concentrations as well. On some level, the Permit recognizes
radiolytically derived VOCs, but this recognition must be specifically
stated. The analyte list should be expanded to include hydrogen chloride,
and rigid inner containers should be sampled, even though this is difficult
to do. Hundreds of substances are released as degradation products from
radiolysis. Benzene is the best known because it is toxic and
carcinogenic. Hydrogen is explosive. The 4.4 pints [l liter] of water
allowed per container is sufficient to turn the hydrogen chloride into
hydrochloric acid. Mr. Franke's major concerns about hydrogen chloride do not address the
situation after a roof-fall. Mr. Franke's concerns deal with the fact that
inner rigid metal containers will corrode from the inside out, possibility
resulting in this loss of containment. This may cause pitting and rusting
of waste drums, thereby degrading their ability to contain the waste.
Hydrogen chloride may be the cause of the pitting and rusting found on the
DOE's TA-55-43 waste drums.
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