REVIEW OF SECONDARY WASTE DISPOSAL PLANNING FOR THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS

Committee to Review Secondary Waste Disposal and Regulatory Requirements for the Assembled Chemical Weapons Alternatives Program

Board on Army Science and Technology

Division on Engineering and Physical Sciences

NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES

THE NATIONAL ACADEMIES PRESS

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Committee to Review Secondary Waste Disposal and Regulatory Requirements for the Assembled Chemical Weapons Alternatives Program Board on Army Science and Technology Division on Engineering and Physical Sciences

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The NaTioNal academies Press 500 Fifth street, N.W. Washington, dc 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This study was supported by Contract No. W911NF-08-C-0020 between the National Academy of Sciences and the U.S. Army. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the views of the organizations or agencies that provided support for the project. International Standard Book Number-13: 978-0-309-12050-0 International Standard Book Number-10: 0-309-12050-0 Limited copies of this report are available from Additional copies are available from Board on Army Science and Technology The National Academies Press National Research Council 500 Fifth Street, N.W. 500 Fifth Street, N.W., Room 940 Lockbox 285 Washington, DC 20001 Washington, DC 20055 (202) 334-3118 (800) 624-6242 or (202) 334-3313 (in the Washington metropolitan area) Internet, http://www.nap.edu Copyright 2008 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Charles M. Vest is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advis- ing the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council. www.national-academies.org

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commiTTee To reVieW secoNdarY WasTe disPosal aNd reGUlaTorY reQUiremeNTs For The assemBled chemical WeaPoNs alTerNaTiVes ProGram PETER B. LEDERMAN, Chair, New Jersey Institute of Technology (retired), New Providence OTIS A. SHELTON, Vice-Chair, Praxair, Inc., Danbury, Connecticut CHARLES BARTON, Xoma, Berkeley, California GARY S. GROENEWOLD, Idaho National Laboratory, Idaho Falls REBECCA A. HAFFENDEN, Los Alamos National Laboratory, Santa Fe, New Mexico WILLIAM R. RHYNE, ABS Consulting, Inc. (retired), Kingston, Tennessee LEONARD M. SIEGEL, Center for Public Environmental Oversight, Mountain View, California WALTER J. WEBER, JR., University of Michigan, Ann Arbor staff MARGARET N. NOVACK, Study Director HARRISON T. PANNELLA, Senior Program Officer JAMES C. MYSKA, Senior Research Associate ALICE V. WILLIAMS, Senior Program Assistant v

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Board oN armY scieNce aNd TechNoloGY MALCOLM R. O’NEILL, Chair, Lockheed Martin Corporation (retired), Vienna, Virginia ALAN H. EPSTEIN, Vice-Chair, Pratt and Whitney, East Hartford, Connecticut RAJ AGGARWAL, Rockwell Collins, Cedar Rapids, Iowa SETH BONDER, The Bonder Group, Ann Arbor, Michigan JAMES CARAFANO, The Heritage Foundation, Washington, D.C. ROBERT L. CATTOI, Rockwell International Corporation (retired), Dallas, Texas DARRELL W. COLLIER, U.S. Army Space and Missile Defense Command (retired), Leander, Texas JAY C. DAVIS, Lawrence Livermore National Laboratory (retired), Livermore, California PATRICIA K. FALCONE, Sandia National Laboratories, Livermore, California RONALD P. FUCHS, The Boeing Company, Seattle, Washington WILLIAM R. GRAHAM, National Security Research, Inc. (retired), San Marino, California PETER F. GREEN, University of Michigan, Ann Arbor CARL GUERRERI, Electronic Warfare Associates, Inc., Herndon, Virginia M. FREDERICK HAWTHORNE, University of Missouri, Columbia MARY JANE IRWIN, Pennsylvania State University, University Park ELLIOT D. KIEFF, Channing Laboratory, Harvard University, Boston, Massachusetts LARRY LEHOWICZ, Quantum Research International, Arlington, Virginia EDWARD K. REEDY, Georgia Tech Research Institute (retired), Atlanta DENNIS J. REIMER, DFI International (retired), Arlington, Virginia WALTER D. SINCOSKIE, Telcordia Technologies, Inc., Morristown, New Jersey MARK J.T. SMITH, Purdue University, West Lafayette, Indiana MICHAEL A. STROSCIO, University of Illinois, Chicago JUDITH L. SWAIN, University of California at San Diego, La Jolla WILLIAM R. SWARTOUT, Institute for Creative Technologies, Marina del Rey, California EDWIN L. THOMAS, Massachusetts Institute of Technology, Cambridge ELLEN D. WILLIAMS, University of Maryland, College Park staff BRUCE A. BRAUN, Director CHRIS JONES, Financial Associate DEANNA P. SPARGER, Program Administrative Coordinator vi

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Preface The U.S. Army Program Manager for Assembled on Chemical Materials Agency secondary waste disposal, the NRC will compare the requirements for CDFs to those Chemical Weapons Alternatives (PMACWA) is charged with of similar facilities in industry that also treat, store, and/or disposing of chemical weapons as stored at two sites: Pueblo, handle and ship secondary wastes, with particular emphasis Colorado, and Blue Grass, Kentucky. In accordance with on industrial best practices. congressional mandates, technologies other than incinera- tion are to be used if they are as safe and as cost effective. The comparison with industry practices includes, but is not The weapons are to be disposed of in compliance with the limited to, the following areas: Chemical Weapons Convention. Although an element of the U.S. Army, the PMACWA is responsible to the Assistant • the degree of characterization necessary for secondary Secretary of Defense for Acquisitions, Technology, and waste (chemical agent and non-agent) produced during Logistics for completing this mission. the stockpile disposal and/or storage operations, which This report deals with the expected significant quantities is treated on-site or handled and shipped off-site for further treatment or disposal; of secondary wastes that will be generated during opera- • identification of additional studies that might be re- tions of the facilities and their closure. While there are only quired to confirm if commercial Treatment, Storage and estimates for the waste quantities that will be generated, Disposal Facilities can handle secondary waste from they provide a good basis for planning and developing al- BGCAPP or PCAPP; ternatives for waste disposal while the plants are still in the • recommended procedures and techniques to address design phase. Establishing efficient disposal options for the public (including environmental justice) and regulatory secondary wastes can enable more timely and cost-effective issues; operation and closure of the facilities. • ramifications and limitations of existing environmental This report on the management of the anticipated sec- permits including chemical demilitarization permit ondary wastes from the Pueblo and Blue Grass facilities restrictions that do not exist in commercial/industrial waste was initiated by the National Research Council (NRC) permits; • the extent and number of health risk and transportation at the request of the PMACWA to inform the latter’s consid- risk assessments deemed necessary; eration of potential waste management options. The state- • criteria being considered for shipment of agent contami- ment of task for the Committee to Review Secondary Waste nated wastes for final treatment/disposal; and Disposal and Regulatory Requirements for the Assembled • facility closure requirements. Chemical Weapons Alternatives Program is as follows: As the chair of the committee, I wish to express my The NRC will conduct an examination of the environmen- appreciation to my fellow committee members for their tal, regulatory and permit requirements that chemical agent contributions to the preparation of this report, which included disposal facilities (CDFs) are subject to, on a federal and interviewing officials and stakeholders, visiting sites, and state basis, concerning the treatment, storage, and/or han- collecting and analyzing significant information and issues dling and shipping of secondary wastes (chemical agent in a short time. Every member of the small committee made and non-agent related). Building on the current design plans significant contributions to the writing of the report. for the Blue Grass Chemical Agent Destruction Pilot Plant The committee in turn is grateful to PMACWA staff (BGCAPP) and the Pueblo Chemical Agent Destruction and their contractors for making information available in a Pilot Plant (PCAPP), as well as the recently completed study vii

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viii PrefACe timely manner. It is particularly grateful to Joseph Novad, of to serve as formal members of the study committees or as PMACWA, for making himself readily available and for his report reviewers. BAST was established in 1982 by the Na- extensive efforts in spite of his many other duties in ensuring tional Academies at the request of the Army. It brings broad that data were available in a clear format, as well as making military, industrial, and academic scientific, engineering, and sure that all of the committee’s questions were answered. The management expertise to bear on Army technical challenges committee also thanks the staff of the Assembled Chemical and other issues of importance to senior Army leaders. BAST Weapons Alternatives program Outreach Offices in Kentucky also discusses potential studies of interest; develops and and Colorado and the staff of the cognizant regulatory agen- frames study tasks; ensures proper project planning; sug- cies in those states, who spent valuable time with committee gests potential committee members and reviewers for reports members to clarify many issues even though the permits are produced by fully independent, ad hoc study committees; and still under review. The committee also greatly appreciates the convenes meetings to examine strategic issues. assistance of the NRC staff, who assisted in the fact-finding activities, carried on significant research in support of the report, and were instrumental in the production of the report. Peter B. Lederman, Chair Data gathering was completed on May 30, 2008. Committee to Review The Board on Army Science and Technology (BAST) Secondary Waste Disposal members listed on page vi were not asked to endorse the and Regulatory Requirements committee’s conclusions or recommendations, nor did they for the Assembled Chemical review the final draft of this report before its release, although Weapons Alternatives Program board members with appropriate expertise may be nominated

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acknowledgments This report has been reviewed in draft form by indi- Todd A. Kimmell, Argonne National Laboratory, viduals chosen for their diverse perspectives and technical W. Leigh Short, Principal and Vice President of expertise, in accordance with procedures approved by the Woodward-Clyde (retired), National Research Council’s (NRC’s) Report Review Com- Pnnisseril Somasundaran, Columbia University, and mittee. The purpose of this independent review is to provide Yu Chu Yang, Consultant. candid and critical comments that will assist the institution in making its published report as sound as possible and to Although the reviewers listed above have provided many ensure that the report meets institutional standards for ob- constructive comments and suggestions, they were not asked jectivity, evidence, and responsiveness to the study charge. to endorse the conclusions or recommendations, nor did they The review comments and draft manuscript remain confi- see the final draft of the report before its release. The review dential to protect the integrity of the deliberative process. of this report was overseen by Hyla Napadensky. Appointed We wish to thank the following individuals for their review by the National Research Council, she was responsible for of this report: making certain that an independent examination of this report was carried out in accordance with institutional procedures Richard A. Conway, NAE, Union Carbide Corporation and that all review comments were carefully considered. (retired), Responsibility for the final content of this report rests entirely John R. Howell, NAE, University of Texas, with the authoring committee and the institution. Hank C. Jenkins-Smith, University of Oklahoma, ix

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contents SUMMARY 1 1 INTRODUCTION 5 Assembled Chemical Weapons Alternatives Program History, 5 Background, 5 NRC Activities, 7 Purpose of This Study, 7 Statement of Task, 7 Secondary Waste at ACWA Chemical Agent Destruction Pilot Plants, 8 Defining Secondary Waste, 8 Metrics on Degree of Agent Contamination, 8 Definition of “Generator Knowledge,” 8 Waste Management Planning, 9 Study Methodology and Report Organization, 9 2 BGCAPP AND PCAPP PROCESS DESCRIPTIONS AND SECONDARY WASTE GENERATION 10 BGCAPP Process Description, 10 GB and VX Projectiles, 10 Mustard Agent H Projectiles, 13 GB- or VX-Filled M55 Rockets, 15 Nonprocess Secondary Wastes, 17 PCAPP Process Description, 17 Energetics Removal, Treatment, and Shipment, 18 Agent Hydrolysis and Munitions Body Treatment, 20 The SDU and the Autoclave, 20 OTS and AFA, 20 Biotreatment, 21 Water Recovery and Brine Reduction, 22 3 REGULATORY REQUIREMENTS APPLICABLE TO BGCAPP AND PCAPP SECONDARY WASTE MANAGEMENT 23 Federal Regulatory Framework for BGCAPP and PCAPP Operations, 23 Waste Characteristics and Listing, 23 Scrap Metal Exclusion, 24 Blue Grass Chemical Agent Destruction Pilot Plant, 24 Applicable Kentucky Statutes and Regulations, 24 BGCAPP Waste Analysis Plan, 25 xi

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xii CONTeNTS Pueblo Chemical Agent Destruction Pilot Plant, 25 Applicable Colorado Statutes and Regulations, 25 PCAPP Waste Analysis Plan, 26 4 STATUS OF PLANNING FOR THE MANAGEMENT OF SECONDARY WASTES AT BGCAPP AND PCAPP 27 Secondary Waste Generation from BGCAPP Operations That Include Supercritical Water Oxidation, 27 Categories of Secondary Wastes and Waste Descriptions, 27 Other Waste Streams, 29 Secondary Waste Generation from PCAPP Operations That Include Biotreatment, 30 Dunnage, Energetics, and Miscellaneous Metal Parts, 30 Solids from the Munitions Treatment Unit, 30 Filtering Media, 30 Secondary Wastes from Water Recovery System and Brine Reduction System, 31 Laboratory Wastes, 32 Planning Considerations for Secondary Waste Management, 33 Determination of Agent-Contaminated and Noncontaminated Waste, 33 Hydrolysate Chemistry, Related Analytical Approaches, 34 Offsite Treatment of Secondary Wastes, 36 Closure Planning, 36 Comparison with Industrial Practices, 38 Waste Management Treatment and Disposal, 38 Human Health Risk Assessments, 38 Transportation Risk Assessments, 38 5 PUBLIC PARTICIPATION 40 BGCAPP Stakeholder Interactions and Issues, 40 Mechanisms for Public Outreach and Involvement, 40 Summary of CDCAB Secondary Waste Working Group Positions and Resolutions, 40 Other Community Positions, 41 Issues Specific to the Treatment of BGCAPP Hydrolysates, 42 PCAPP Stakeholder Interactions and Issues, 42 Mechanisms for Public Outreach and Involvement, 42 CAC Positions and Resolutions, 43 Issues Specific to the Treatment of PCAPP Hydrolysates, 44 Underlying Factors in Both Communities, 44 Findings and Recommendations, 45 6 ALTERNATIVE OFFSITE WASTE MANAGEMENT OPTIONS 46 Major Wastes That Should Be Considered for Offsite Disposal, 47 Agent Hydrolysates, 47 Energetics Hydrolysate, 47 Activated Carbon, 47 Concrete, 47 Metal, 48 Brines, 48 Analytical Considerations, 48 Offsite Disposal Issues, 48 Transportation Risk, 48 Permit Modification, 49 Waste Characterizations, 49 National Environmental Protection Act, 50 Industrial Practices, 50 Past Experience with Offsite Disposal, 51

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xiii CONTeNTS REFERENCES 53 APPENDIXES A National Research Council Reports on the Assembled Chemical Weapons Assessment/ Alternatives Program, 57 B Definition of “Generator Knowledge,” 58 C Physical Properties of Chemical Agents in Munitions Stored at Blue Grass Army Depot and Pueblo Chemical Depot, 59 D Results from Technical Risk Reduction Program Activity 2a, Phase II, for GB and Activity 11 for VX, 61 E Committee Meetings and Site Visits, 64 F Biographical Sketches of Committee Members, 66

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Tables, Figures, and Boxes TaBles 1-1 Description of the Chemical Weapons in the BGAD Stockpile, 6 1-2 Chemical Weapons Stockpile of HD- or HT-Filled Munitions at PCD, 6 4-1 Proposed Secondary Waste Management Approaches at BGCAPP, 28 4-2 BGCAPP Estimated Agent-Contaminated Waste Stream Summary for Operations and Closure, 29 4-3 BGCAPP Projected 1X Agent-Contaminated Secondary Waste Generation Rates During Operations and Closure, 29 4-4 BGCAPP Projected 3X-4X Agent-Contaminated Secondary Waste Generation Rates During Operations and Closure, 29 4-5 Proposed Secondary Waste Management Approaches for PCAPP, 31 4-6 Total Estimated Secondary Wastes from Normal Operations and Closure for PCAPP, 32 4-7 PCAPP Projected Amounts of Mustard-Agent-Contaminated Secondary Waste from Normal Operations According to Level of Agent Contamination, 32 4-8 PCAPP Projected Amounts of Mustard-Agent-Contaminated Secondary Waste from Closure According to Level of Agent Contamination, 33 6-1 Anticipated Quantities of Hydrolysates from BGCAPP and PCAPP Operations, 46 C-1 Physical Properties of Nerve Agents, 59 C-2 Physical Properties of Mustard Agents, 60 FiGUres 2-1 Process and waste stream diagram for BGCAPP, 11 2-2 Munitions washout system, 12 2-3 Metal parts treater, 14 2-4 Energetics batch hydrolyzer, 15 2-5 Rocket cutting machine, 16 2-6 Rocket shear machine, 17 2-7 Process and waste stream diagram for PCAPP, 19 2-8 Munitions treatment unit, 21 BoXes 5-1 Members of Kentucky Chemical Destruction Community Advisory Board, December 2007, 41 5-2 Meeting Between Committee Chair and an Employee of the Environmental Protection Agency Assigned to Serve as Liaison to CWWG, 42 5-3 Members of Colorado Chemical Demilitarization Citizens’ Advisory Commission, 43 xiv

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abbreviations and acronyms ABCDF Aberdeen Chemical Agent Disposal Facility ENS energetics neutralization system ACWA Assembled Chemical Weapons Alternatives EPA Environmental Protection Agency ADM acquisition decision information ERB energetics reconfiguration building AEL airborne exposure limit ESM energetics service magazine AFA agent filter area AFS aluminum filtration system GB nerve agent (sarin) ANR agent neutralization reactor APB agent processing building H Levinstein mustard agent HD distilled mustard agent BGAD Blue Grass Army Depot HEPA high-efficiency particulate air (filter) BGCA Blue Grass Chemical Activity HHRA human health risk assessment BGCAPP Blue Grass Chemical Agent Destruction HT a mixture of HD and T, bis(2- Pilot Plant chloroethylthioethyl) ether BPBGT Bechtel Parsons Blue Grass team HVAC heating, ventilation, and air conditioning BRA brine recovery area BRS brine reduction system ICB immobilized cell bioreactor BTA biotreatment area JACADS Johnston Atoll Chemical Agent Disposal CAC Citizens’ Advisory Commission System CDCAB Chemical Destruction Community Advisory Board KDEP Kentucky Department of Environmental CDPHE Colorado Department of Public Health and Protection the Environment CMA Chemical Materials Agency LDR land disposal restriction COD certificate of designation LOQ limit of quantification CWWG Chemical Weapons Working Group LPMD linear projectile/mortar disassembly (machine) DE destruction efficiency DICDI diisopropylcarbodiimide MDL method detection limit DIPU 1,3-diisopropyl urea MPHRA multiple-path health risk assessment DOD Department of Defense MPT metal parts treater DOT Department of Transportation MTU munitions treatment unit DPE demilitarization protective ensemble MWS munitions washout system EBH energetics batch hydrolyzer NECDF Newport Chemical Agent Disposal EDT explosive destruction technology Facility EIS environmental impact statement NEPA National Environmental Policy Act NRC National Research Council xv

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xvi AbbreViATiONS ANd ACrONymS ROD record of decision OTE offgas treatment for the energetics RSM rocket shear machine neutralization system OTM offgas treatment for the metal parts SCWO supercritical water oxidation treater SDU supplemental decontamination unit OTS offgas treatment system SET Secure Environmental Treatment (a DuPont facility) P&A precision and accuracy SFT shipping and firing tube PCAPP Pueblo Chemical Agent Destruction Pilot Plant TAL target action limit PCB polychlorinated biphenyl TCLP toxicity characteristic leaching procedure PCD Pueblo Chemical Depot TRA transportation risk assessment PMACWA Program Manager for Assembled Chemical TRRP Technical Risk Reduction Program Weapons Alternatives TSCA Toxic Substances Control Act ppb parts per billion TSDF treatment, storage, and disposal facility PPE personal protective equipment ppm parts per million VOC volatile organic compound psig pounds per square inch gauge VSL vapor screening level VX nerve agent RCM rocket cutting machine RCRA Resource Conservation and Recovery WAP waste analysis plan Act WCL waste control limit RD&D research, design, and development WRS water recovery system RFP request for proposal RO reverse osmosis