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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants 4 Status of Planning for the Management of Secondary Wastes at BGCAPP and PCAPP This chapter presents the committee’s review and analysis of various factors that bear on how the secondary wastes at BGCAPP and PCAPP are to be managed. This includes the committee’s interpretation and analysis of the properties, quantities, and prospective courses of action planned for the secondary waste streams generated at BGCAPP and PCAPP, an assessment of the current state of Assembled Chemical Weapons Alternatives (ACWA) program planning for waste management, and the consideration of certain industrial practices that are used in comparable waste management situations. SECONDARY WASTE GENERATION FROM BGCAPP OPERATIONS THAT INCLUDE SUPERCRITICAL WATER OXIDATION Categories of Secondary Wastes and Waste Descriptions Waste Categories and Quantities Secondary wastes from the processing of chemical munitions at BGCAPP according to the current design, which uses neutralization followed by supercritical water oxidation (SCWO), can be grouped according to physical and compositional similarity, source, disposal options, or estimated waste stream quantities. Waste categories developed by the Army and its contractors are shown in Table 4-1, along with the source of the waste and the approach proposed for its management. The wastes listed in Table 4-1 are derived from materials generated by the operational processes described in Chapter 2, as well as from closure activities where applicable (BPBGT, 2006a). Waste estimates for BGCAPP were developed and reported in a 2006 report based on earlier experience at the Johnston Atoll Chemical Agent Destruction System (JACADS) (BPBGT, 2006a). The results of this comparison of waste types and quantities for BGCAPP is only an approximation, because JACADS was an incineration facility, while BGCAPP uses hydrolysis followed by SCWO. Nevertheless, there is enough similarity between the types of munitions that were processed at JACADS and those that will be processed at BGCAPP for the JACADS experience to provide insight into what will be generated at BGCAPP. As previously noted, secondary wastes listed in Table 4-1 reflect waste categories generated during munitions processing as well as from closure operations. Table 4-2 lists total specific types of agent-contaminated wastes and the quantities of each projected to be generated. According to Army estimates, nearly 2.1 million pounds of total agent-contaminated waste will be generated, approximately 400,000 pounds during munitions disposal operations and 1.7 millions pounds during closure operations (BPBGT, 2006a). Tables 4-3 and 4-4 provide estimated quantities of certain items in Table 4-2 according to the degree of agent contamination (1X or 3X-4X). Waste Descriptions As discussed in Operations and Closure Agent-Contaminated Waste Disposal Estimate Summary Report (known as the Waste Estimate Summary Report), secondary wastes generated at BGCAPP could include rags, containers, plastic drum liners, absorbents, solvents, paints, lubricants, tools, power extension cords, personal protective equipment (PPE), and failed electrical and mechanical components (BPBGT, 2006a). Some secondary wastes will be agent-contaminated, such as materials generated during routine entries into potentially agent-contaminated areas, decontamination residues, sludge, and PPE. The last mentioned can take many forms, including cotton clothing, butyl boots and gloves, leather welding aprons, M40 series rubber masks with carbon canister and plastic shield, impregnated chemical protective liner (shirts and trousers), hoods, aprons, rubber hoses from supplied air regulators, and life-support hoses. Decontamination residues will also be produced during operations and closure in forms such as spent decontamination solution,
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 4-1 Proposed Secondary Waste Management Approaches at BGCAPP Waste Source Approachesa Activated carbon Operations and closure activities Unspecified offsite TSDF Concrete Maintenance and closure activities Metal parts treater Unspecified TSDF (if agent contamination concentration is below release criteria) Energetics (rocket motor propellant) Rocket processing operations Preferred disposal method for noncontaminated rocket motors is offsite recycling Contaminated rocket motors hydrolyzed in energetics batch hydrolyzers Energetics (projectile bursters) H projectile processing operations Hydrolysis in energetics batch hydrolyzers Projectile munitions bodies Projectile processing operations Metal parts treater Metallic debris Maintenance and closure activities Metal parts treater Unspecified TSDF (if agent contamination concentration is below release criteria) Nonmetallic debris (combustible solids) Operations, maintenance, and closure activities Metal parts treater Unspecified TSDF (if agent contamination concentration is below release criteria) Aluminum precipitation system filter cake Aluminum precipitation Unspecified TSDF (not contaminated by agent) Residue from metal parts treater Operations and closure activities Unspecified TSDF (not contaminated by agent) Rubber/rubber-coated items Operations, maintenance, and closure activities Metal parts treater Unspecified TSDF (if agent contamination concentration is below release criteria) Spent decontamination solution Operations, maintenance, and closure activities Onsite hydrolysis SCWO Spill residue Spill response activities Metal parts treater Onsite hydrolysis with SCWO Unspecified TSDF (if agent contamination concentration is below release criteria) Chemicals w/expired shelf life Laboratory Unspecified TSDF (not contaminated by agent) Tank, sump, and strainer sludge Operations, maintenance, and closure activities Metal parts treater Unspecified TSDF (if agent contamination concentration is below release criteria) Used oils Maintenance and closure activities Recycling Reject brine from reverse osmosis of SCWO effluent SCWO Unspecified offsite TSDF aThe committee notes that these are proposed approaches to waste management; however, no waste analysis plan has been filed or approved. SOURCE: Adapted from PMACWA, 2008a. cotton rags, spill pillows, absorbent granular material, and paper towels. Preventive and corrective maintenance will produce smaller quantities of wastes, but they may be more varied in form. These include SDS and ACS pumps, strainer baskets and housings, gear boxes, hydraulic pumps and motors, hoses, lighting fixtures, heat tracing, CCTV cameras, ACAMS monitoring lines, valves, instruments, and sensors. Additional secondary wastes generated from such activities included: leather welding blankets, nylon straps, tygon tubing, extension cords, fiberglass ladders, plastic sheeting/bags, and plastic drums and containers. Also, the following waste streams are generated: glycol-based hydraulic fluid, gear oil, strainer media and socks, pre-filters, HEPA filters and carbon banks from HVAC filter housing assemblies. (BPBGT, 2006a, p. 7) Waste Processing Through the Metal Parts Treater Contaminated materials to be treated in the metal parts treater (MPT) include warhead debris from the energetics
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 4-2 BGCAPP Estimated Agent-Contaminated Waste Stream Summary for Operations and Closure Waste Designation Total Weight of the Waste (lb) Inert bulk solid waste Metal 1,243,545 Concrete 152,369 Aluminum waste 6,685 Foam core panels 95,498 Special coatings 12,333 Combustible bulk solid Nonhalogenated plastics 50,972 Tap gear 4,555 HEPA filters and prefilters 19,997 Adsorbents, cottons, rags, bulk 4,477 Paper, wood, fiberglass, rubber 63,794 Halogenated plastics 308,404 Sludge 1,997 RCRA toxic metal-bearing waste Paint chips 121 Leather gloves 224 Other 1,000 Waste oil and hydraulic fluids 1,620 Agent-contaminated activated carbon 103,488 Leaker campaign/overpack waste 15,000 Total 2,071,079 SOURCE: Adapted from BPBGT, 2006a. TABLE 4-3 BGCAPP Projected 1X Agent-Contaminated Secondary Waste Generation Rates During Operations and Closurea 1X Waste Projected Rate (lb/yr) Operationsb Closurec Combustible solids 2,520 21,150 Metal 11,893 307,847 TAP gear/rubber 267 267 Halogenated plastic 4,787 50,346 Nonhalogenated plastic 1,062 12,867 Pre-HEPA filters 502 9,000 ACS/SDS sludge 520 520 Concrete 0 34,283 Foam wall panel 0 21,487 Special coatings 0 2,775 Aluminum 0 1,472 Overpack waste 15,000 0 Total 36,571 462,014 NOTE: TAP, toxic agent protective; HEPA, high-efficiency particulate air; ACS, agent collection system; and SDS, spent decontamination solution. aThe source document for the estimates given in this table reported quantities using the Army’s X system of classification rather than the currently preferred system based on airborne exposure limits. (AELs). A classification of 1X indicates agent contamination to be >1 VSL. bBGCAPP operations are estimated to have a duration of 2.08 years. cBGCAPP closure is estimated to have a duration of 1.46 years. SOURCE: Adapted from PMACWA, 2006. TABLE 4-4 BGCAPP Projected 3X-4X Agent-Contaminated Secondary Waste Generation Rates During Operations and Closurea 3X-4X Waste (unless otherwise noted) Projected Rate (lb/yr) Operationsb Closurec Combustible solids 2,623 22,014 Metal 22,087 571,717 TAP gear/rubber 1,066 1,066 Halogenated plastic 14,360 151,039 Nonhalogenated plastic 1,733 20,994 3X pre-HEPA filters 82 5,084 Sludge 64 64 3X concrete 0 79,993 3X foam wall panel 0 50,136 Special coatings 0 6,475 3X aluminum 48 3,435 Total 42,063 912,017 a The source document for the estimates given in this table reported quantities using the Army’s X system of classification rather than the currently preferred system based on AELs. A classification of 3X or 4X indicates agent contamination to be <1 VSL. bBGCAPP operations are estimated to have a duration of 2.08 years. cBGCAPP closure is estimated to have a duration of 1.46 years. SOURCE: Adapted from PMACWA, 2006. batch hydrolyzer, contaminated pallets, shipping and firing tubes, secondary wastes generated during operations, and certain closure wastes. Decontamination by means of high temperatures in the MPT will be verified by ensuring that the waste met time and temperature requirements for attaining “unrestricted release” status. Other Waste Streams Based on the JACADS experience and BGCAPP estimates, the committee has identified the following waste streams in addition to those already identified in Table 4-1 and Table 4-2: SCWO reactor liners. Because SCWO is so highly corrosive, it may be necessary to replace the SCWO liner as often as once a week, but liner lifetime will not be known until the plant is in operation. Given the harsh nature of the SCWO environment, it is certain that some degree of liner replacement will be required. The reactor liners are fabricated of titanium, and at present it is not known how they will be disposed of. Multimedia filters and canister filter media from the SCWO. The SCWO effluent is passed through multimedia filters and canister filters before entering the reverse osmosis (RO) unit. The filter media will constitute secondary waste, but at present there
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants are no plans for characterizing or disposing of this material. Reverse osmosis brine. The RO rejectate will be a brine that is sent for offsite treatment. Scrubber water from the energetics offgas treatment (OTE) system. Scrubber water from the OTE is to be treated through “subsequent processing.” Neither the waste nor the subsequent processing has yet been characterized. Particulate filter media from the OTE. Filter media containing particulate matter are generated in the OTE. They must be characterized and disposed of as a secondary waste. Particulate filter media from the venturi scrubber. Filter media containing particulate matter are generated in the venturi scrubber. They must be characterized and disposed of as a secondary waste. 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. SECONDARY WASTE GENERATION FROM PCAPP OPERATIONS THAT INCLUDE BIOTREATMENT The processing of chemical munitions at PCAPP, which uses neutralization followed by biotreatment, will generate secondary waste streams during pilot testing, munitions processing operations, and closure. These wastes may arise from general maintenance activities, equipment cleaning and repair, measures to ensure worker safety, and sampling activities. Anticipated secondary waste streams, their source, and their anticipated management are listed in Table 4-5. The approaches for disposing of the different secondary waste streams will be decided once the waste analysis plan (WAP) has received final approval. Table 4-6 lists total estimated quantities of specific types of PCAPP wastes. Table 4-7 and Table 4-8 show estimated amounts of the various types of waste that will be generated during operations and closure, respectively, in terms of the degree of contamination by mustard agent (<1 VSL or >1 VSL). Dunnage, Energetics, and Miscellaneous Metal Parts Historical information, visual observation, and monitoring during transport to the energetics reconfiguration building and during munitions disassembly are used to determine if dunnage or energetics could be agent-contaminated. Noncontaminated dunnage will be shipped offsite to a commercial treatment, storage, and disposal facility (TSDF) as a hazardous waste due to the presence of pentachlorophenol. Noncontaminated propellant bags and wafers, ignition cartridges, and miscellaneous metal parts removed in the energetics reconfiguration building will be shipped offsite to a commercial TSDF. Agent-contaminated dunnage may be treated in the supplemental decontamination unit (SDU) or the autoclave. The dunnage would include metal straps and parts removed during reconfiguration, wood pallets and boxes, fiber tubes and packing material, asbestos packing rings, steel grommets, and other like materials. Agent-contaminated energetics (e.g., wafers, bursters, boosters, fuzes, and well cups) will be treated in the explosive destruction technology (EDT) unit; wastes from EDT treatment are not included in this report.1 Uncontaminated energetics will be shipped offsite as a Class 1 (explosive) hazardous material. Solids from the Munitions Treatment Unit Solids from the munitions treatment unit (MTU) include munitions bodies and burster wells as well as residue (e.g., paint chips) generated during periodic cleaning of the MTU. Decontaminated munitions bodies will be sent offsite and can be recycled for scrap metal under Colorado regulations (PMACWA, 2006).2 The characterization of residue includes an analysis for toxicity characteristic leaching procedure (TCLP) metals. It is subsequently drummed and shipped offsite to an appropriate TSDF. Filtering Media The offgas treatment systems and agent filter area (AFA) have filtering systems that will produce waste. These include particulate filter waste, iron sponge absorber waste, prefilters, and high-efficiency particulate air (HEPA) and activated carbon filters. Activated carbon is used as filter medium in 1 Again, as first noted in Chapter 2, a forthcoming NRC report will examine the applicability of the various types of EDTs for use at PCAPP and, possibly, BGCAPP. It will include an examination of wastes from EDT treatment. 2 See Section C-2c(1), page C-20, of the cited reference.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 4-5 Proposed Secondary Waste Management Approaches for PCAPP Waste Source Management Method Carbon from filter banks Operations and closure activities Unspecified offsite TSDF Concrete Maintenance and closure activities SDU or autoclave (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Energetics (propellants and explosives) Operations activities Onsite treatment (agent-contaminated) Unspecified recycler or TSDF (if agent contamination concentration is below release criteria) Decontaminated munitions bodies, processed through the MTU Operations activities Unspecified recycler Metallic debris Operations, maintenance, and closure activities SDU or autoclave (agent-contaminated) Unspecified recycler or TSDF (if agent contamination concentration is below release criteria) Nonmetallic debris (combustible solids) Maintenance and closure activities SDU or autoclave (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Brine reduction system solids Operations and closure activities Unspecified TSDF MTU residue Operations and closure activities Unspecified TSDF Nonmunitions PCD waste Maintenance activities SDU or autoclave (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Rubber/rubber-coated items Maintenance and closure activities SDU or autoclave (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Spent decontamination solution Operations, maintenance, and closure activities Onsite agent hydrolyzers Spill residue Spill response activities SDU (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Chemicals w/expired shelf life Laboratory activities Unspecified offsite disposal Onsite laboratory disposal Tank, sump, and strainer sludge Operations, maintenance, and closure activities SDU (agent-contaminated) Unspecified TSDF (if agent contamination concentration is below release criteria) Used oils Maintenance and closure activities Recycling SOURCE: Adapted from PMACWA, 2006, 2008b. the AFA, some tank vents, and in canisters associated with personal protective masks. AFA banks 2 through 6 and some mask canisters are not expected to be agent-contaminated (PMACWA, 2006).3 Agent monitors are used between the respective banks of carbon to indicate if any agent has broken through the preceding bank. Noncontaminated carbon is to be shipped offsite for treatment and/or disposal, with characterization based on generator knowledge. Agent-contaminated carbon is treated in the autoclave prior to agent analysis, followed by offsite treatment and/or disposal. Design plans for PCAPP do not anticipate changing out activated carbon filters prior to closure. Secondary Wastes from Water Recovery System and Brine Reduction System Sludges and other residues are produced by the biotreater and the water recovery system (WRS). Filter cake 3 See Section C-2b(4) of the cited reference.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 4-6 Total Estimated Secondary Wastes from Normal Operations and Closure for PCAPP (pounds) Waste Description Normal Operations Closure Operations Wood dunnage 3,550,390 0 Fiber tube 731,369 0 TAP gear 28,638 11,088 Steel/aluminum 38,182,554 129 Brine reduction generated 55,114,416 0 Water recovery thickener residue 3,900,792 0 Energetics 138,225 0 Brass and copper wire 211,600 0 Charcoal from PPE mask containers 2,583 1,000 Bulk solid waste 240,404 656,930 Halogenated waste 27,294 93,983 DPE suits 202,524 78,416 Waste oils 7,687 2,976 Spent hydraulic fluid 4,928 1,908 Leather 2,974 1,151 Absorbents 23,886 16,447 Polystyrene and polyethylene (poly drums and 5-mil poly bags) 14,024 3,685 HEPA/prefilters 0 38,000 HVAC 0 207,900 Filtration charcoal 0 170,000 Filter plenums 0 100,000 Filter ductwork Concrete scabbled 0 27,000 Combustible solid wastes Electrical parts/instrumentation (>5% plastics) 572 48,862 Nonhalogenated plastics 23,878 19,595 Sludge (tanks, building sumps, strainers) 1,524 590 Waste paint sludges 4,099 1,588 Batteries/mercury-containing lighting 48,980 1,833 Bioreactor offgas treatment system Iron sponge 0 431,520 Prefilters 0 644 HEPA prefilters 0 1,620 Carbon filters 0 60,000 Total 102,463,341 2,001,565 SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, 2008. from the WRS dewatering filter press is tested for TCLP metals, TCLP organics, and free liquids. This waste stream is drummed and shipped offsite for treatment and/or disposal in an appropriate TSDF. The brine reduction system treats the clarified effluent from the WRS to produce a solid cake that can be disposed of offsite. The filter cake is tested for TCLP metals and organics and for free liquids (PMACWA, 2006).4 This waste stream is drummed and shipped offsite for treatment and/or disposal in an appropriate TSDF. TABLE 4-7 PCAPP Projected Amounts of Mustard-Agent-Contaminated Secondary Waste from Normal Operations According to Level of Agent Contamination Stream Description Amount (lb) <1 VSL >1 VSL Wood 0 56,906 Fiber tubes, additional packing material, metal strapping, miscellaneous metal 0 0 TAP gear 9,639 6,709 Steel 0 0 Lead alloy 0 0 Aluminum 18 53 Brine reduction 0 0 Water recovery thickener residue 0 0 Energetics 0 0 Brass/copper wire 0 0 Charcoal from PPE mask containers 0 2,583 Inert bulk solid waste 15,421 35,790 Halogenated waste 3,153 2,661 DPE suits 121,514 81,010 Waste oils/spent hydraulic fluid 2,416 400 Leather 437 197 Absorbents 1,534 3,554 Paper/fiberglass/rubber 0 0 Polystyrene and polyethylene 669 2,318 Combustible solid waste 2,827 2,382 Waste paint sludge 915 455 Dry cell batteries 1,828 203 Lead acid batteries 1,219 135 Mercury-containing lighting 259 29 Total 161,849 195,385 NOTE: TAP, toxic agent protective; PPE, personal protective equipment. SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, 2008. Laboratory Wastes Laboratory wastes are collected in each hood. All agent-contaminated wastes are placed in a bleach solution daily. The liquids are decanted, analyzed to confirm that agent has been destroyed, and shipped offsite for disposal (PMACWA, 2006).5 The solids are bagged, screened for agent by head-space monitoring, and drummed for offsite disposal. Process knowledge is utilized to segregate agent-contaminated waste streams from noncontaminated laboratory waste streams; the latter do not require sampling or monitoring. Finding 4-2. At PCAPP, brine from the water recycling and sludge from the biotreatment are the largest waste streams. They are not considered to be contaminated with chemical agent but may be a hazardous waste for other reasons. 4 See Section C-2b(3), page C-14, of the cited reference. 5 Specifically, see Section C-2b(9), page C-16, of the cited reference.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 4-8 PCAPP Projected Amounts of Mustard-Agent-Contaminated Secondary Waste from Closure According to Level of Agent Contamination Stream Description Amount (lb) <1 VSL >1 VSL Wood 0 0 TAP gear 3,704 412 Steel 0 0 Aluminum 21 7 Brine reduction 0 0 Water recovery thickener residue 0 0 Propellant 0 0 Brass/copper wire 0 0 Charcoal 0 1000 Inert bulk solid waste 262,351 259,498 Halogenated waste 27,946 25,910 DPE suits closure (APB) 47,050 31,366 Waste oils/spent hydraulic fluid 927 164 Leather 147 98 Absorbents 350 3153 Paper/fiberglass/rubber 0 0 Polystyrene and polyethylene (poly drums and 5-mil poly bags) 0 785 HEPA/prefilters 9,500 28,500 HVAC Filtration charcoal 30,690 3,410 Filter plenums 15,300 1,700 Filter ductwork 9,000 1,000 Concrete 38,775 12,925 Combustible solid waste 26,359 26,503 Waste paint sludges/sludges 0 531 Dry cell batteries 707 79 Lead acid batteries 472 52 Mercury-containing lighting 100 11 Total 473,399 397,102 SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, 2008. PLANNING CONSIDERATIONS FOR SECONDARY WASTE MANAGEMENT Determination of Agent-Contaminated and Noncontaminated Waste BGCAPP Some of the secondary wastes generated at BGCAPP could be characterized as noncontaminated, or “clean,” based on generator process knowledge, risk assessment, or other evidence that the waste has never been in an environment where it could have become contaminated by agent. In such cases, these secondary wastes could be disposed of offsite as solid wastes unless they demonstrate a hazardous characteristic or contain another listed waste. A waste that cannot be certified as noncontaminated based on generator process knowledge can still be certified clean if headspace monitoring shows the agent level to be <1 VSL. For materials decontaminated at low temperature, headspace monitoring will be used for characterization. The Army has an array of monitors at its disposal that have been effective in past applications. It is likely that either near-real-time monitoring or Depot Area Air Monitoring System monitors would be used for headspace monitoring. Secondary wastes that have been in the vicinity of agent will need to be monitored to determine whether they are agent-contaminated. Examples of such process-related wastes are wood pallets, PPE, rocket motors, plastics, toxic agent protective gear, HEPA filters, absorbents, paper, and rubber. Monitoring for agent contamination is to be conducted in accordance with the Department of the Army’s Implementation Guidance Policy for Revised Airborne Exposure Limits (U.S. Army, 2004) and approved site procedures. For most potentially agent-contaminated solid wastes, the headspace of the packaged material will be monitored to determine their status as clean or agent-contaminated (NRC, 2007). Characterizations by means of extractive techniques may be required for certain types of secondary waste such as porous and/or adsorptive wastes for which headspace monitoring alone is not appropriate. Wastes that cannot be decontaminated to the appropriate applicable AEL(s) must be processed in the MPT before being shipped offsite for disposal in a permitted TSDF (BPBGT, 2006b).6 For liquid streams, the initial hydrolysate from chemical agent neutralization will be sampled and analyzed for agent. The analytical procedures for testing GB and VX hydrolysates have been outlined in the Technical Risk Reduction Program (TRRP) activity 2a, Phase II, and activity 11, respectively, which are discussed later in this chapter (Malloy et al., 2007; Dejarme and Lecakes, 2008).7 Once destruction efficiency (DE) has been demonstrated, subsequent batches can be transferred for further processing onsite or to an appropriate TSDF based on testing to be performed in accordance with the WAP.8 Validated process controls and statistical testing may be used in lieu of analysis. However, prior to release from the plant areas under engineering controls for agent, hydrolysates and other liquid effluents will be analyzed to meet the target action limit, which is the agent concentration for which 95 percent of the measurements are below the release criteria. 6 See Attachment 4, Section 4.2, of the cited document. 7 The TRRP involves a series of laboratory and prototype equipment tests that have been instituted as the ACWA program has evolved. The TRRP activities provide input into the design effort by filling data gaps and validating the design basis. The intent is to help ensure the facilities’ equipment and operations perform correctly once operations begin, which in turn will help to ensure safety, accelerate the process, and reduce cost. Among the studies conducted have been design, fabrication, and testing of key first-of-a-kind equipment; SCWO performance testing; and studies using nerve and mustard agent to confirm neutralization reactor conditions. 8 The WAP for BGCAPP had not yet been developed or submitted when this report was being prepared.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants PCAPP Under the WAP filed with the Colorado Department of Public Health and Environment (CDPHE), PCAPP will use generator process knowledge as the primary means of characterization, with direct sampling and analysis used to verify process knowledge. Agent monitoring is conducted in accordance with the Army’s AEL guidance dated June 18, 2004 (U.S. Army, 2004). There are three approaches for classifying and disposing of a secondary waste relative to its contamination by agent: The waste is containerized and its headspace is monitored to determine the appropriate classification; or The waste is assumed to be agent-contaminated and is decontaminated in accordance with the RCRA permit or regulations; adequate decontamination (<1.0 VSL) is verified via monitoring at the SDU or autoclave, whereupon it is reclassified as “clean” and shipped offsite; or The waste is assumed to be agent-contaminated and is shipped offsite to a facility permitted to receive such wastes. Following approach 1, if <1.0 VSL, the waste is classified as clean and shipped offsite, and if >1.0 VSL, approach 2 or approach 3 is followed (PMACWA, 2006).9 Adequate decontamination, defined as <1.0 VSL, may need to be accomplished in the SDU or the autoclave and verified via monitoring at the SDU or the autoclave. As previously indicated, Table 4-6 shows the total estimated secondary wastes, while Tables 4-7 and 4-8 show projected generated quantities of contaminated secondary wastes according to their level of contamination (before any onsite treatment) for the operational and closure stages of PCAPP, respectively. Finding 4-3. In the committee’s opinion, the waste management planning for PCAPP was overly optimistic in projecting there would be no agent-contaminated energetics, wood dunnage, etc. (as shown in Tables 4-7 and 4-8). The committee believes, based on the past experience of its members, that some of these wastes will in fact be contaminated to some extent. Nevertheless, the optimism in projecting no agent contamination of these wastes is accommodated by having a capability for decontamination, if necessary, in the supplemental decontamination unit or autoclave. Hydrolysate Chemistry, Related Analytical Approaches An important aspect of the secondary treatment of the agent hydrolysate is verification of 99.9999 percent agent destruction. The sodium hydroxide matrix has presented challenges for conventional chromatographic analysis schemes of VX and GB hydrolysates. This section describes the chemistry occurring during caustic hydrolysis of GB, VX, and mustard agent and notes the research that has been conducted to develop viable strategies for agent detection in the hydrolysate at required levels. GB Chemistry and Detection Base hydrolysis of GB results in formation of isopropyl methylphosphonic acid and sodium fluoride, which are the principal components of the hydrolysate. Diisopropylcarbodiimide (DICDI) was present in the original agent, where it was used as a stabilizer. However, DICDI undergoes hydrolysis in the original agent, forming 1,3-diisopropyl urea (DIPU), which is detected in both the agent feed and in the hydrolysate. Hydrolysis mostly produces an aqueous phase, but a small organic phase is also produced (Malloy et al., 2007). Two salient issues in the hydrolysis of GB motivated a TRRP activity (Malloy et al., 2007). First, quantities of GB that exceeded the minimum detection limit, 20 μg/L, had been found in the brines that are an end product of the process. Second, the neutralization process and the clearing (screening) of the resulting hydrolysates was too timeconsuming for the large-scale processing effort being proposed for BGCAPP. A primary objective of TRRP activity 2a, Phase II, was to find a workable new method for GB analysis (Malloy et al., 2007). The method previously used suffered from inaccuracy derived from the GB re-formation that occurred in the heated injector of the gas chromatograph used for the analysis. This proved problematic for demonstrating that the GB concentrations in the hydrolysate were <75 ppb, which was the action level for clearing the hydrolysate. An improved extraction-gas chromatograph/mass spectrometer method was developed using a cool-on-column injection that eliminated GB re-formation in the injector during the analysis. This enabled a much more rigorous evaluation of hydrolysis performance starting with GB batches of varying compositions. The new method (EXTN/COC/GC/MS, BGCAPP 104b) (Malloy et al., 2007) was demonstrated to be effective for GB hydrolysates of varying compositions, specifically GB stabilized with either tributylamine or DICDI, and also for GB crystals (DIPU). The method can also be used for measuring GB in other matrices, such as the munitions washout hydrolysate, blended hydrolysate, SCWO effluent, RO rejectate, and energetics hydrolysate (Malloy et al., 2007). See Appendix D for additional details of TRRP activity 2a, Phase II. 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 9 See Attachment C, Section C-2b(1), of the cited documents.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants II, provides assurance that the level of residual GB in the hydrolysate can be measured accurately. VX Chemistry and Detection Caustic hydrolysis of VX generates a hydrolysate that normally consists of two liquid phases: (1) an aqueous phase containing caustic and dissolved salts and (2) an organic phase that contains organics having limited water solubility (Dejarme and Lecakes, 2008). The hydrolysate contains ethyl methylphosphonic acid and diisopropylaminoethanethiol (also known as DESH, thiolamine, or VX thiol) as the main hydrolysis products. In addition, EtOH and a compound known as EA2192 are formed, which is significant because EA2192 is nearly as toxic as VX and is fairly stable. The organic phase is principally bis(diisopropylaminoethyl) disulfide, which is formed from oxidation of the thiolamine. Other compounds that might partition into the organic phase would include residual thiolamine, stabilizers such as DICDI, dicyclohexylcarbodiimide (DCC), and intact VX. Reaction of ethyl methylphosphonic acid with dicyclohexylcarbodiimide has been shown to result in formation of diethyl dimethyl pyrophosphonate (also known as VX pyro), which has substantial toxicity and will react further with the diisopropylaminoethanethiol to re-form VX (Brickhouse et al., 1998). TRRP activity 11 was conducted to determine whether the hydrolysate contained residual VX (Dejarme and Lecakes, 2008). For the BGCAPP design incorporating SCWO, this was important because clearance levels for moving hydrolysate to the SCWO reactor system were 160 µg/L for VX and 1 g/L for EA2192. Bench-scale reactor tests were conducted on five different batches of VX from munitions that contained either DICDI or dicyclohexylcarbodiimide as stabilizers. Experiments were conducted by mimicking the recipe for BGCAPP, which involved loading the reactor with 16.6 percent VX, 17.4 percent caustic (which was 50 percent sodium hydroxide), and 66 percent water and heating the mixture to 90°C. The reactor studies produced VX hydrolysate that could be analyzed for residual VX using a modified cool-on-column gas chromatograph method (see below). Residual EA-2192 was analyzed using high-performance liquid chromatography employing either diode array or ultraviolet detection (detail is provided in Appendix D). When the method was applied to hydrolysate generated in a reactor using the neutralization recipe to be used at BGCAPP, VX was not detected in any of nine batches, with limits of quantification ranging from 4 to 14 µg/L (ppb). EA2192 was detected in only one batch (at 51 ppm), with method detection limits ranging from 11 to 159 ppm. Reanalysis of this sample 24 hours later showed that EA2192 was not detected. Another significant result was that VX was not detected in the headspace of the reactor. Instrumental analyses for VX and EA2192 have been problematic in past operations, and it was reasoned that the validity of the results of the VX neutralization reactor tests for BGCAPP could be questioned on the basis of inaccurate, imprecise, or insensitive analytical procedures. For this reason, TRRP activity 11 (Dejarme and Lecakes, 2008) also examined the analytical methods for VX and EA2192 that are used for clearing the hydrolysate. It was believed that the method that had been used at Newport Chemical Agent Disposal Facility could be used at BGCAPP. However, operational challenges, including matrix interferences, were identified. Consequently, TRRP activity 11 included extensive research that produced a modified extraction-gas chromatography/mass spectrometry method that employed cool-on-column injection. This eliminated re-formation in the injector region and enabled refinement and optimization of both the extraction and chromatographic details. Additional details on the results of this research are presented in Appendix D. These studies indicate that the instrumental method used for clearing the VX hydrolysate for further SCWO treatment is adequate. 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. Mustard Agent (H, HD, HT) Chemistry and Detection Caustic hydrolysis of mustard results in formation of 2,2'-thio-bis-ethanol (thiodiglycol); 2,2'-[1,2-ethanediylbis(thio)]-ethanol; 2,2'-[oxy bis(2,1-ethanediylthio)] bis-ethanol; 1,4-oxathiane; 1,4-dithiane; 1,2-dichloroethane; and vinyl chloride (Yang et al., 1988).10 The TRRP activity that focused on characterization of mustard agent H hydrolysate did not indicate problems with either the hydrolysis chemistry or the analysis (Usinowicz et al., 2005). It is well known that mustard agent H undergoes degradation reactions during storage (Creasy et al., 1999), and some of these products can form higher molecular weight mustard heels (Yang et al., 1997). However, because these were readily soluble under washout conditions, they do not complicate either hydrolysis or analysis. 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. 10 Yu-Chu Yang, Assembled Chemical Weapons Alternatives Program, “Chemical compositions of liquid HT, solid HT, liquid H and solid H,” presentation to the Mustard Working Group Meeting, September 23, 2003.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants Offsite Treatment of Secondary Wastes In addition to the offsite shipment of noncontaminated secondary wastes, some potentially agent-contaminated wastes may be shipped offsite provided (1) the waste meets any release criteria or limit as established in the RCRA permit, (2) the offsite facility is permitted to receive such wastes, and (3) transportation risks are assessed and found to be acceptable.11 For example, the Army has proposed shipping spent activated carbon offsite for treatment. In addition, according to the briefing given to the committee on January 23, 2008, consideration may be given to offsite shipment of certain liquid streams.12 In such cases, release criteria will be established in accordance with federal, state, and Army policies, and only secondary wastes that meet these release criteria will be transported offsite for treatment or disposal. Release criteria may differ from DE levels (e.g., “nondetect” at PCAPP and target release levels at BGCAPP) for removal of liquids from areas of the facility under engineering controls for limiting exposure to agent. Depending on the requirements established in the facility’s WAP, such wastes must be characterized using an appropriate methodology before being shipped offsite. Such methodologies may include monitoring or extractive analyses, as well as characterization by generator knowledge—for example, operating records or process knowledge, vapor screening, and actual characterization). The receiving facility can also ask for additional tests beyond those done at the destruction facility. Finding 4-7. The applications for modifications of the research, development, and demonstration permits for both BGCAPP and PCAPP proposed that a number of specific secondary wastes be shipped offsite for treatment or ultimate disposal. Recommendation 4-2. The Program Manager for Assembled Chemical Weapons Alternatives should continue to pursue the acceptance of the planned offsite shipment and disposal of secondary waste through permit modifications and stakeholder involvement. In the BGCAPP and PCAPP facilities, the processes for munitions disassembly and agent destruction by hydrolysis (neutralization) are conducted in the munitions demilitarization building, which is under engineering controls for limiting exposure to agent. Processes for secondary treatment such as SCWO or biotreatment are outside the area under these engineering controls. Effluents from agent chemical neutralization would have to be sampled and analyzed. Current planning calls for validated process controls and statistical testing to be used in lieu of analyzing all batches of a hydrolysate once 99.9999 percent destruction efficiency has been demonstrated on agent hydrolysate.13 Liquid effluents would have to be analyzed to determine if they meet the established release criteria before release from the area of the munitions demilitarization building under engineering controls for agent. Finding 4-8. Generator process knowledge (validated process controls and statistical testing) is expected to be used where possible to determine destruction of agent in hydrolysate on a continuing basis at BGCAPP and PCAPP. Recommendation 4-3. Each batch of agent hydrolysate produced at BGCAPP and PCAPP should be sampled to ensure that the required level of agent destruction has been met to satisfy potential stakeholder concerns. To determine if a transportation risk assessment is necessary for offsite shipments of secondary wastes, the Army has proposed using hazardous solid waste assessment methodologies to ensure that concentrations of residual agent in any wastes shipped offsite are within the limits set by a standard approach (bounding)14 transportation risk assessment for wastes with >1 VSL; this approach is currently under development by the Chemical Materials Agency (CMA) (NRC, 2007). Examples of such assessment methodologies include, but are not limited to, headspace monitoring and extractive analysis (e.g., approved agent-related methods, EPA SW-846 methods and procedures (EPA, 2007), operational records, and characterization via generator knowledge). Closure Planning BGCAPP Wastes generated at BGCAPP during closure will not be dissimilar to those generated at JACADS.15 The anticipated wastes have been estimated based on knowledge from JACADS and adjusted for the BGCAPP footprint and design. The amount of contaminated closure wastes that will require decontamination for agent should be less than that experienced at JACADS because the plant is smaller and more of the processing equipment is outside the exclusion zone. The anticipated closure waste quantities are summarized in Tables 4-3 and 4-4. The largest amounts of waste will be metals, halogenated plastics, and concrete. Halogenated 11 Transportation risk assessments are discussed in a later section of this chapter. 12 Kevin Regan, environmental manager, BGCAPP, “Process alternates for wastes,” presentation to the committee, January 23, 2008. 13 Kevin Regan, environmental manager, BGCAPP, “Current waste analysis and certification,” presentation to the committee, January 23, 2008. 14 Bounding conditions are the maximum agent concentrations and maximum number of shipments specific to the site. 15 See NRC, 2002b, for information on the closure wastes at JACADS.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants plastic includes demilitarization protection ensemble suits and related entry equipment. In addition, there will be contaminated and noncontaminated activated carbon from the offgas treatment systems. Closure wastes contaminated with agent above clearance levels based on the Army’s AEL guidance and suited for treatment in the MPT are expected to be decontaminated in the MPT to appropriate release criteria that have not yet been established or approved (U.S. Army, 2004). This will require careful planning to ensure that the MPT is operational during deconstruction. It is expected that noncontaminated and decontaminated secondary waste will also be cleared for offsite shipment using the Army’s current AEL guidance or generator knowledge. Where possible, headspace analysis will be used to clear material. Several of the closure wastes present unique difficulties because they will come from agent processing areas that may have been exposed to elevated agent-vapor readings but are unlikely to be agent-contaminated. Examples of these wastes are electronic circuit boards, closed circuit television cameras, batteries, and mercury switches. The Waste Estimate Summary Report proposes that the wastes be chemically decontaminated and then shipped offsite for additional treatment and/or disposal rather than processed through the MPT (BPBGT, 2006a). The option of shipping wastes with low levels of agent contamination that are >1 VSL to an appropriate TSDF would still need to be negotiated with the regulatory authorities and would require active involvement of the public stakeholders in order to allow for a smooth operation. A significant closure waste stream is scabbled concrete. This material is of concern because agent that contacts it may be absorbed by the coatings on the concrete or into the pores below. Therefore “concrete may have to be removed or cracks may have to be chased locally” (BPBGT, 2006a, p. 12). The requirement at BGCAPP is that the potentially contaminated concrete will be “scarified to a nominal depth of 0.25-inch. The 0.25-inch scabbling depth should be sufficient to remove contaminants that may have permeated through the layers of protective coating” (BPBGT, 2006a, p. 11). This requirement is derived from experience in the nuclear industry and from the JACADS closure requirements. The experience in the nuclear industry is related to the migration of radionuclides (metal cations) into concrete, but chemical warfare agents (organic compounds) may not behave the same way. The second justification for the depth of this is derived from the JACADS closure requirement, but the Waste Estimate Summary Report does not seem to contain any further technical backing for the decision. Since the scabbled concrete could generate a significant volume of secondary closure waste, any action that would minimize the quantity of material categorized as agent-contaminated would result in substantial savings for the Army. Precautions have been taken in the areas of the plant likely to become contaminated with agent to minimize the contamination of concrete. An epoxy coating is used to minimize contamination of the concrete as a result of spilled agent, hydrolysate, and decontamination solution. The coating would have to remain intact over the much shorter operating period than the operating period for JACADS, which was 10 years. This could allow for shallower scabbling of the concrete than the 0.25-inch depth used at JACADS. It should also mean that there is less contamination in cracks and joints. PCAPP The anticipated closure wastes are summarized in Table 4-6. These are estimates based on the wastes generated during closure of the Aberdeen Chemical Agent Disposal Facility, which used the same neutralization process to destroy HD mustard agent stored in bulk. Estimates were made of the additional waste from the closure of the bioreactors, which were not a part of the process at Aberdeen, where the hydrolysate was sent to a commercial TSDF. The largest volumes of closure wastes will be steel and other metals, activated carbon, halogenated plastic, and concrete. These wastes will for the most part have agent contamination of <1 VSL because they did not come from the areas where neat agent was being processed. It should be possible to ship them to an appropriate TSDF as hazardous waste for further treatment or disposal. As at BGCAPP, the amount of concrete waste that will require treatment because of possible agent contamination could be much less than in past operations. The PCAPP design likewise calls for epoxy coating for all surfaces in the process areas where there is potential for exposure to agent. This would minimize the possibility of agent contamination of the concrete, in turn minimizing the depth of scabbling required to less than 0.25 inch. Based on JACADS experience, even the scabbled concrete was amenable to disposal without further treatment. Finding 4-9. The current plans for scabbling to a depth of 0.25 inch during the closure of BGCAPP and PCAPP appear to be conservative and to have no explicit scientific justification. This could result in more scabbled concrete than necessary being classified as agent-contaminated. Recommendation 4-4. The Program Manager for Assembled Chemical Weapons Alternatives (PMACWA) should examine the justification for scabbling the concrete to a 0.25-inch depth in order to understand how deep the concrete must be scabbled during the closure of BGCAPP and PCAPP. Alternatively, the PMACWA should investigate means for measuring residual agent on the concrete surfaces.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants COMPARISON WITH INDUSTRIAL PRACTICES The material in this section is supplemented by material in a previous National Research Council report (NRC, 2007), which addressed four chemical agent disposal facility sites in the continental United States that use incineration technology and one site that uses neutralization technology, all of them operated under the authority of the CMA. The regulatory requirements and the types of secondary wastes that will be generated at the two ACWA facilities being studied here are very similar to those at the CMA facilities. Waste Management Treatment and Disposal As described in Chapter 3, ACWA facilities and industrial hazardous waste facilities are both governed by RCRA regulations. In both cases, waste characterization, including acceptable analytical methodologies, is guided by the facility’s RCRA permit and the associated WAP. Based on the aforementioned report (NRC, 2007) and on discussions between members of the present committee with personnel from KDEP, BGCAPP,16,17 CDPHE, and PCAPP,18,19 the committee has determined that there is little difference between the application of regulatory conditions and requirements at industrial hazardous facilities and chemical agent disposal facilities. Moreover, for BGCAPP and PCAPP, as for the other chemical agent disposal facility sites, what few small differences do arise, arise for the same reason as given in the 2007 report, namely: the characterization, management, and disposal of chemical agents and the related secondary wastes at chemical agent disposal facilities are not specifically addressed in federal or state regulations and must therefore be addressed in the individual chemical agent disposal facility permit. This results in the differences seen between the management and disposal requirements at each chemical agent disposal facility, since each permit is based on an individual state’s regulatory interpretation of the limits necessary for these distinctive wastes. (NRC, 2007, p. 56) Human Health Risk Assessments Human health risk assessments (HHRAs), also sometimes called multiple-path health risk assessments or, simply, health risk assessments, are a type of risk assessment that addresses the long-term exposure of the public to the approved, long-term stack releases as they affect air, water, food, and so on and the subsequent human uptake.20 Both BGCAPP and PCAPP will employ treatment units to remove and destroy residual agent contamination that may exist on metal parts and other solid wastes generated as part of the agent treatment process. These units themselves possess the potential to emit air pollutants. As stated previously, current laws do not specifically require an HHRA, but state regulatory agencies may require one based on broad regulatory powers. BGCAPP KDEP has notified ACWA program staff that it will require an HHRA for BGCAPP.21 The HHRA methodology to be used has not been negotiated with KDEP, but it is expected to be a screening-level analysis rather than a detailed analysis since the emissions are expected to be low.22 However, if emissions during pilot-scale testing are higher than those assumed for the HHRA, the HHRA will be revised. Since the potential requirement to conduct an HHRA is likewise applicable to commercial industrial facilities, it is a reasonable requirement for BGCAPP. PCAPP The CDPHE required ACWA program staff to submit a draft protocol for conducting an HHRA for PCAPP (it uses the designation “multiple-path health risk assessment (MPHRA)).”23 The protocol for performing a screening-level MPHRA was finalized in mid-2007, and the MPHRA was submitted for CDPHE review in late 2007. However, if emissions during pilot-scale testing are higher than those assumed for the MPHRA, it will be revised. Since the potential requirement for an MPHRA is likewise applicable to commercial industrial facilities, it is a reasonable requirement for PCAPP. Finding 4-10. The same regulatory requirements concerning health risk assessments that apply to industry also apply to BGCAPP and PCAPP. Transportation Risk Assessments U.S. Department of Transportation (DOT) regulations for the transport of hazardous materials (49 CFR) have evolved and are modified as necessary to protect the public. Both commercial facilities and the ACWA facilities must 16 Committee fact-finding meeting with the KDEP, Frankfort, Ky., January 24, 2008. 17 Kevin Regan, environmental manager, BGCAPP, “Process alternates for wastes,” presentation to the committee, January 23, 2008. 18 Craig Myler, chief engineer for process and technology, Bechtel National, Inc., “PCAPP secondary waste discussion,” presentation to the committee, February 13, 2008. 19 Committee fact-finding meeting with the CDPHE, Denver, Colo., February 14, 2008. 20 The terms health risk assessment, human health risk assessment, and multiple-path health risk assessment all apply to the same type of risk assessment. 21 Kevin Regan, environmental manager, BGCAPP, “Process alternates for wastes,” presentation to the committee, January 23, 2008. 22 The screening-level methodology is also being used at PCAPP, as was learned at a committee fact-finding meeting with the CDPHE, Denver, Colo., February 14, 2008. 23 Fact-finding meeting with the CDPHE, Denver, Colo., February 14, 2008.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants comply with DOT regulations, including standards for packaging, marking, vehicular safety, and driver qualification. DOT regulations do not require or recommend a transportation risk assessment (TRA) for shipments of hazardous materials; however, a TRA can suggest measures to further mitigate risk, including routing to reduce the mileage, population along the route, and/or crash likelihood; additional or strengthened barriers to an uncontrolled release; and control of ambient and/or postcrash environments. Neither the state of Kentucky nor the state of Colorado has specific requirements that address the transportation of chemical munitions or wastes derived from them. However, in the case of PCAPP, Pueblo County land use regulations at Title 17, Chapter 176, Section 050, require that the “risk of accidents occurring during the transportation of any wastes to, from, or at the prosposed site … be considered when proposing to locate, construct, operate, or close a hazardous waste processing site.” A TRA was prepared for PCAPP in 2003 that addressed combinations of a number of the following categories for offsite shipment: (1) uncontaminated metal parts, dunnage and ash, bioreactor salt cake, sludge, and washout solution; (2) mustard agent hydrolysate; (3) energetics hydrolysate; and (4) energetics (burster, propellant, and fuze) (FOCIS, 2003). That TRA focused on the risk of injury or fatality due to accidents involving only a heavy truck (no cargo effects) and on the fire and explosion risk due to the energetics cargo. The effects of accidents involving the cargo in the case of the first three categories were qualitatively dismissed (owing to the nonreactivity and low volatilities of the materials) and were considered to have negligible risk compared to the risk of heavy truck, cargo-independent injuries and fatalities. An environmental assessment was prepared pursuant to the National Environmental Policy Act that relied on the above TRA for uncontaminated dunnage and uncontaminated, stable propellant. However, the committee is not aware of the formal submission of the underlying TRA, or any other TRA, to Pueblo County. Recently, CMA issued guidance on factors that must be considered and addressed for offsite shipment of agent-contaminated secondary waste. The guidance states as follows: When shipping waste that is determined to be above 1 VSL, a quantitative analysis will be performed to assess the potential agent hazards associated with higher levels of agent contamination and a qualitative hazard analysis concerning the nature of other constituents offered for transport. The CMA Risk Management Directorate (RMD) has developed a standard approach for performing a quantitative analysis to develop a site-specific Transportation Risk Assessment (TRA) for the chemical agent hazard. This approach shall be used by all CMA sites and activities for agent contaminated wastes above 1 VSL. The CMA RMD will assist sites in development of their TRA.24 It further states For waste greater than 1 VSL, sites should use existing hazardous waste assessment methodologies to appropriately characterize the waste to assure agent concentrations are within the bounding condition of the TRA.25 and A site-specific risk assessment should be developed to assess and establish the necessary monitoring requirements for loading, transportation, and processing operations related to secondary waste shipments greater than 1 VSL.26 and Waste shipments are to be managed in accordance with DOT regulations for appropriate state and local emergency response actions.…The CMA facility needs to work in concert with the receiving TSDF and the waste shipper to ensure that there are adequate response capabilities to respond to an emergency in route. 27 The ACWA program does not have similar guidance but expects to follow the CMA guidance with respect to offsite shipment.28 Finding 4-11. The PMACWA has stated the intention to follow the offsite shipment guidance of the Chemical Materials Agency (CMA). However, with respect to waste characterization and monitoring, the (June 25, 2007, CMA-issued) guidance requires the use of existing hazardous waste assessment methodologies. Recommendation 4-5. The PMACWA should seriously consider adopting the Chemical Materials Agency standard (bounding) approach in preparing transportation risk assessments. 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. 24 Memorandum to CMA commanders, site project managers, project manager for chemical stockpile elimination, and project manager for non-stockpile chemical materiel, Re: Guidance for Development of Site-Specific Plans for Shipment of Chemical Agent Contaminated Secondary Waste, from Dale Ormond, acting director, CMA, dated June 25, 2007, p. 2. 25 Ibid. 26 Ibid. 27 Ibid., p. 3. 28 Committee discussions with Joseph Novad, technical director, ACWA, Pueblo, Colo., February 14, 2008.