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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants Summary The U.S. Army is in the process of disposing of the nation’s stockpile of chemical agents and munitions. At present, there are five active disposal facilities and two that are in the design and early construction phases. This study deals with the wastes that will be generated as a result of the disposal of the munitions at the two facilities that have yet to be built and placed in operation. These wastes are considered to be “secondary wastes”; the munitions and agents are themselves considered to be “hazardous wastes.” Of the five operating facilities, four use combustion to process the agents and munitions, while the fifth uses neutralization to process bulk agent. The two facilities considered in this study will utilize neutralization (hydrolysis) as the basic agent destruction process, followed by different treatments of the product of the neutralization, hydrolysate. While the facilities are in many ways similar, they are also different in the types of agents and munitions that are to be disposed of. The Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP) will dispose of munitions containing nerve agents GB or VX, or mustard agent H. These are contained in a variety of munitions, including M55 rockets containing GB or VX. The Pueblo Chemical Agent Destruction Pilot Plant (PCAPP) will process projectile munitions that contain only mustard agent HD or HT; no rockets are stored at the Pueblo Chemical Depot (PCD). At the Blue Grass Army Depot (BGAD), the agents and munitions to be destroyed number approximately 100,000 items, two-thirds of which are M55 rockets. The various projectiles stored at PCD number nearly 800,000. While these facilities are called “pilot plants,” they are in fact full-scale facilities that are pilot plants only in the sense that a new technology is being used at each facility. Pilot plant designation, design, and fabrication also allow for more flexibility in the operation until the process and technologies have been demonstrated fully. This study is based on estimates of the wastes that will be generated during operations and closures. These estimates are based on design data for the respective pilot plants, data from other operating facilities, and data from the Johnston Atoll Chemical Agent Disposal System and the Aberdeen Chemical Agent Disposal Facility, which have already been closed. Many of the wastes will be the same as or very similar to those that were or are being generated at the other facilities, both closed and operating. While some wastes that will be generated at BGCAPP and PCAPP will be different from the wastes generated at facilities using combustion technology, neutralization technology was used at the Aberdeen Chemical Agent Disposal Facility to dispose of bulk mustard agent and at the Newport Chemical Agent Disposal Facility (NECDF) to destroy bulk nerve agent VX. These facilities thus offer additional insight into the secondary waste generation scenarios that can be expected for BGCAPP and PCAPP. The Committee to Review Secondary Waste Disposal and Regulatory Requirements for the Assembled Chemical Weapons Alternatives Program (ACWA Secondary Waste Committee) analyzed process flow sheets and other design information that was provided in order to comprehensively identify all sources of secondary waste streams. While the primary agent destruction process will be basically the same at BGCAPP and PCAPP, the facilities are very different in detail owing to the aforementioned differences in the types of munitions and agents to be processed by each. In brief, the munitions are moved from storage igloos to the disposal facility, where they are unpacked. Energetics, if any, are removed, and the agent is drained from the agent cavity of the munition. The agent is then neutralized and the liquid hydrolysate is treated in a second step to further degrade the organic material. The energetics are either shipped offsite or neutralized to produce a second liquid hydrolysate, which is also treated to further degrade it. Detailed descriptions of the two process systems may be found in Chapter 2. A large number of secondary waste streams emanate from the process steps, maintenance activities, personal protection equipment, and laboratory operations. The wastes are categorized as “contaminated” or “noncontaminated with agent residues” depending on whether they (1) have been in
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants contact with agent or (2) have been treated to destroy the agent residues or to meet certain waste clearance criteria. These criteria were established based on prior experience but in general have not been formally approved for the site by the respective regulatory permitting authorities. In the case of PCAPP, a waste analysis plan has been developed but not approved. For BGCAPP, a waste analysis plan must still be developed and submitted. In both Kentucky and Colorado, these wastes are “listed wastes,” as defined in Resource Conservation and Recovery Act (RCRA) regulations, because they stem from agent processing. Wastes may be “hazardous” because they are agent-contaminated or because they are “characteristic hazardous wastes” under RCRA and applicable state regulations. The regulations and permits under which the sites operate are discussed in Chapter 3. This study considers all secondary wastes that are generated from the disposal processes and focuses on the wastes that could be considered for offsite shipment. The wastes that are generated from the process at each site as currently designed are described in detail in Chapter 4. While all secondary wastes were considered, this study is primarily concerned with the major waste streams in terms of volume. The major wastes from BGCAPP include Dunnage, Metal from munitions, Supercritical water oxidation (SCWO) effluent solution, Spent decontamination solution, Plastics, particularly from demilitarization protective equipment, Noncontaminated energetics, and Hydrolysate (if shipped to a treatment, storage, and disposal facility (TSDF)). From PCAPP, they include Dunnage, Metal from munitions, Plastic, particularly for demilitarization protective equipment, Noncontaminated energetics, Water/brine recovery salt cake and biomass sludge, Spent activated carbon, and Hydrolysate (if shipped to a treatment, storage, and disposal facility (TSDF)). In addition, a great deal of metal, concrete, decontamination solution, plastics, and spent activated carbon will be generated during the closure phase. There is significant public sentiment, as expressed by the respective Citizens’ Advisory Commissions in Kentucky and Colorado as well as other interested groups, that all contaminated and potentially contaminated wastes should be treated onsite. This sentiment stems from concern about shipping chemical agents, which has been prohibited by statute since the mid-1990s. There has since been some movement toward shipping some wastes offsite, and there may be more willingness on the part of the stakeholders to consider offsite shipments of certain other wastes. However, this would require changing the current permits. Moreover, based on discussions with the stakeholders, appropriate safeguards are necessary to ensure that such shipments would be safe, environmentally sound, and considerate of environmental justice concerns of the transit and receiving areas. The committee met with various stakeholder groups to sample public sentiment. Issues raised in these discussions are valuable, but the committee notes that the conclusions arrived at are derived from only a small fraction of the population and may not be representative of the wider populations in the areas. The committee’s discussions with stakeholder groups are summarized in Chapter 5. The committee found that the ACWA program and its contractors appear to be treated by regulatory authorities just like any commercial facility that treats, stores, and disposes of listed hazardous wastes, with one exception: It is expected that the Army will treat the hazardous waste onsite. Many commercial hazardous wastes are routinely shipped to permitted treatment, storage, and disposal facilities (TSDFs). At present, this is not possible for many of the major volume waste streams that will be generated at BGCAPP and PCAPP despite the fact that many of these waste streams have been safely shipped to permitted TSDFs from the other combustion and neutralization facilities. In Chapter 6, the committee discusses the technical feasibility of shipping some of the major waste streams to TSDFs that are permitted to handle similar wastes that may be more difficult to dispose of. It recognizes that there may be institutional impediments to such alternatives. The committee concluded that from a technical perspective, the wastes could be shipped offsite without negatively impacting either safety or the environment and could have advantages in terms of disposal program acceleration, including lower investment, a smaller footprint for the facility, and a shorter time for closure. However, the offsite option may be unattractive for other reasons. That is a decision outside the scope of this study. Some of the institutional barriers or hurdles to using an alternative to onsite treatment are presented. MAJOR FINDINGS AND RECOMMENDATIONS Two key recommendations from Chapter 6 along with the major findings and recommendations from the other chapters appear below. Key Findings and Recommendations Finding 6-1. The shipment of certain secondary wastes to suitable offsite TSDFs could have significant advantages. Among these are savings in facility infrastructure and equip-
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants ment costs, a smaller footprint for the facility, and a shorter time for closure. Finding 6-8. The experience to date with the offsite shipment and treatment of mustard and nerve agent hydrolysates from the Aberdeen and Newport Chemical Agent Disposal Facilities indicates that offsite transportation and disposal of these materials is a safe and technically viable course of action. Recommendation 6-7. Because experience shows that offsite shipment and treatment of agent hydrolysates from BGCAPP and PCAPP is safe and technically viable, and in view of better analytical methods being developed, the PMACWA should consider this option now, before the plants are built and operating, to maximize the benefit from such a change. It is important to consider everything that would impact such a change. Finding 6-9. Spent activated carbon and other closure wastes were successfully shipped offsite from the Aberdeen Chemical Agent Disposal Facility to an appropriate TSDF for ultimate disposal. Recommendation 6-8. The shipment offsite to an appropriate permitted TSDF of all types of wastes, including spent activated carbon and closure wastes, should be examined and given serious consideration in light of past experience showing that it is a technically viable and safe method of disposing of these wastes. Other Major Findings and Recommendations Finding 3-1. A detailed waste analysis plan for BGCAPP has not been developed or submitted for review and approval. Such a plan would detail sampling and analytical methods for each waste stream. Recommendation 3-1. While the Bechtel Parsons Blue Grass Team and the Program Manager for Assembled Chemical Weapons Alternatives are not in violation of regulatory requirements and have ample time to meet the requirement to submit a waste analysis plan for BGCAPP 18 months prior to receipt of munitions at the facility, it would be prudent to develop and submit the plan as early as possible in order to determine the requirements that may be placed on the operations by the Kentucky Department of Environmental Protection and avoid unnecessary delays to the operation. Finding 4-1. The documentation for secondary waste streams made available to the committee failed to identify reverse osmosis rejectate brine, supercritical water oxidation (SCWO) filtrate solid waste, SCWO titanium tank liners, venturi scrubber particulate filters, or filters from the energetics offgas treatment system (OTE) as potential secondary wastes from BGCAPP. Recommendation 4-1. To avoid the possibility of unanticipated disposal problems, the PMACWA and the BGCAPP contractor should characterize and consider waste management options for reverse osmosis rejectate brine, supercritical water oxidation (SCWO) filtrate solid waste, SCWO titanium tank liners, venturi scrubber particulate filters, and energetics offgas treatment system filters before submitting the waste analysis plan required by RCRA. The PMACWA should also look carefully for any as-yet-unidentified secondary waste streams from BGCAPP or PCAPP. Finding 4-4. The research on analysis methodologies for determining the level of residual agent in GB hydrolysate from Technical Risk Reduction Program activity 2a, Phase II, provides assurance that the level of residual GB in the hydrolysate can be measured accurately. Finding 4-5. The research on analysis methodologies for determining the levels of residual agent in VX hydrolysate from Technical Risk Reduction Program activity 11 provides assurance that the level of residual VX in the hydrolysate can be measured accurately. Finding 4-6. Work on the characterization of mustard agent hydrolysis showed that the analysis for mustard agent is accurate and did not give any evidence of any outstanding risk to the public, the workforce, or the environment stemming from the hydrolysis chemistry or the analysis of the hydrolysate. Recommendation 4-6. When developing transportation risk assessments, the PMACWA should use the most current hazardous waste assessment methodologies for characterizing the wastes generated at BGCAPP and PCAPP. Recommendation 4-7. A site-specific transportation risk assessment should be developed for all wastes that may be agent-contaminated and shipped from BGCAPP and PCAPP. Finding 5-1. Through the Kentucky Chemical Demilitarization Citizens’ Advisory Commission (CAC) and the CAC’s subsidiary Chemical Destruction Community Advisory Board, as well as public affairs activities that include the Blue Grass Chemical Stockpile Outreach Office and public meetings, the communities around the Blue Grass Army Depot (BGAD) have ample opportunity to learn about BGCAPP operations as well as proposed secondary waste disposal. The ACWA program and its contractors do an effective job of cooperating with and supporting these organizations.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants Finding 5-2. Through the Colorado Chemical Demilitarization Citizens’ Advisory Commission, as well as a public affairs program that includes the Pueblo Chemical Stockpile Outreach Office and its field activities, the communities around the Pueblo Chemical Depot have ample opportunity to learn about PCAPP operations as well as proposed secondary waste disposal. The ACWA program and its contractors do an effective job of cooperating with and supporting these organizations. Finding 5-3. Communities that might be affected by the transportation and offsite disposal of secondary and closure wastes do not at present have an official forum through which they can interact with the ACWA program. Finding 5-4. Members of the communities around the Blue Grass Army Depot and the Pueblo Chemical Depot have not expressed serious concern about the disposition of secondary wastes other than hydrolysate from BGCAPP and PCAPP. However, they want technical assurance that the materials are not contaminated with agent, as defined by the minimum detection level, before being transported offsite for reuse or disposal. Finding 5-5. There is substantial local opposition to offsite shipment and disposal of hydrolysate from both BGCAPP and PCAPP. Local groups can be expected to forestall any such action by protracting the permitting process or the environmental review (if there is one) as well as by instigating political action and litigation. Recommendation 5-1. To avoid potential misunderstandings and obstacles, the PMACWA should explain in advance, and solicit feedback on, any proposals to ship wastes from BGCAPP and PCAPP. Special efforts should be made to include a diverse representation of the stakeholder communities. Recommendation 5-2. The PMACWA should explain to the public precisely how it plans to determine whether a particular waste stream is suitable for shipment, including analytical procedures for showing whether the stream contains any residual contamination by an agent or its by-products. Recommendation 6-3. The PMACWA should perform a quantitative transportation risk assessment for hydrolysate, including a quantitative assessment of the human health consequences of hydrolysate spills with and without a fire. This assessment needs to be completed to facilitate discussions with the public and regulators about the hydrolysate offsite shipment alternative. Recommendation 6-5. For both BGCAPP and PCAPP, the selection of an appropriate TSDF for the treatment of agent hydrolysates and other secondary wastes should take into account transportation issues, emergency response considerations, and public and community interests.