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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4 status of Planning for the management of secondary Wastes at BGcaPP and PcaPP This chapter presents the committee’s review and analy- ity, while BGCAPP uses hydrolysis followed by SCWO. sis of various factors that bear on how the secondary wastes Nevertheless, there is enough similarity between the types at BGCAPP and PCAPP are to be managed. This includes of munitions that were processed at JACADS and those that the committee’s interpretation and analysis of the properties, will be processed at BGCAPP for the JACADS experience quantities, and prospective courses of action planned for the to provide insight into what will be generated at BGCAPP. secondary waste streams generated at BGCAPP and PCAPP, As previously noted, secondary wastes listed in Table an assessment of the current state of Assembled Chemical 4-1 reflect waste categories generated during munitions Weapons Alternatives (ACWA) program planning for waste processing as well as from closure operations. Table 4-2 management, and the consideration of certain industrial lists total specific types of agent-contaminated wastes and practices that are used in comparable waste management the quantities of each projected to be generated. Accord- situations. ing 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 secoNdarY WasTe GeNeraTioN From BGcaPP 1.7 millions pounds during closure operations (BPBGT, oPeraTioNs ThaT iNclUde sUPercriTical 2006a). Tables 4-3 and 4-4 provide estimated quantities of WaTer oXidaTioN certain items in Table 4-2 according to the degree of agent contamination (1X or 3X-4X). categories of secondary Wastes and Waste descriptions Waste Categories and Quantities Waste Descriptions Secondary wastes from the processing of chemical mu- As discussed in Operations and Closure Agent-Con- nitions at BGCAPP according to the current design, which taminated waste disposal estimate Summary report (known uses neutralization followed by supercritical water oxidation as the waste estimate Summary report), secondary wastes (SCWO), can be grouped according to physical and com- generated at BGCAPP could include rags, containers, plastic positional similarity, source, disposal options, or estimated drum liners, absorbents, solvents, paints, lubricants, tools, waste stream quantities. Waste categories developed by the power extension cords, personal protective equipment (PPE), Army and its contractors are shown in Table 4-1, along with and failed electrical and mechanical components (BPBGT, the source of the waste and the approach proposed for its 2006a). Some secondary wastes will be agent-contaminated, management. The wastes listed in Table 4-1 are derived from such as materials generated during routine entries into poten- materials generated by the operational processes described in tially agent-contaminated areas, decontamination residues, Chapter 2, as well as from closure activities where applicable sludge, and PPE. The last mentioned can take many forms, (BPBGT, 2006a). including cotton clothing, butyl boots and gloves, leather Waste estimates for BGCAPP were developed and welding aprons, M40 series rubber masks with carbon can- reported in a 2006 report based on earlier experience at ister and plastic shield, impregnated chemical protective the Johnston Atoll Chemical Agent Destruction System liner (shirts and trousers), hoods, aprons, rubber hoses from (JACADS) (BPBGT, 2006a). The results of this compari- supplied air regulators, and life-support hoses. Decontami- son of waste types and quantities for BGCAPP is only an nation residues will also be produced during operations and approximation, because JACADS was an incineration facil- closure in forms such as spent decontamination solution, 

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg TABLE 4-1 Proposed Secondary Waste Management Approaches at BGCAPP Approachesa Waste Source 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 Operations, maintenance, and closure Metal parts treater (combustible solids) activities Unspecified TSDF (if agent contamination concentration is below release criteria) Aluminum precipitation system Aluminum precipitation Unspecified TSDF (not contaminated by agent) filter cake Residue from metal parts treater Operations and closure activities Unspecified TSDF (not contaminated by agent) Rubber/rubber-coated items Operations, maintenance, and closure Metal parts treater activities Unspecified TSDF (if agent contamination concentration is below release criteria) Spent decontamination solution Operations, maintenance, and closure Onsite hydrolysis activities 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 Metal parts treater activities Unspecified TSDF (if agent contamination concentration is below release criteria) Used oils Maintenance and closure activities Recycling Reject brine from reverse osmosis of SCWO Unspecified offsite TSDF SCWO effluent 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 ing blankets, nylon straps, tygon tubing, extension cords, fiberglass ladders, plastic sheeting/bags, and plastic drums paper towels. and containers. Also, the following waste streams are gener- Preventive and corrective maintenance will produce ated: glycol-based hydraulic fluid, gear oil, strainer media smaller quantities of wastes, but they may be more varied in and socks, pre-filters, HEPA filters and carbon banks from form. These include HVAC filter housing assemblies. (BPBGT, 2006a, p. 7) SDS and ACS pumps, strainer baskets and housings, gear boxes, hydraulic pumps and motors, hoses, lighting fixtures, Waste Processing Through the Metal Parts Treater heat tracing, CCTV cameras, ACAMS monitoring lines, Contaminated materials to be treated in the metal parts valves, instruments, and sensors. Additional secondary treater (MPT) include warhead debris from the energetics wastes generated from such activities included: leather weld-

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP TABLE 4-2 BGCAPP Estimated Agent-Contaminated TABLE 4-4 BGCAPP Projected 3X-4X Agent- Waste Stream Summary for Operations and Closure Contaminated Secondary Waste Generation Rates During Operations and Closurea Total Weight of the Waste Projected Rate (lb/yr) Waste Designation (lb) Operationsb Closurec 3X-4X Waste (unless otherwise noted) Inert bulk solid waste Combustible solids 2,623 22,014 Metal 1,243,545 Metal 22,087 571,717 Concrete 152,369 TAP gear/rubber 1,066 1,066 Aluminum waste 6,685 Halogenated plastic 14,360 151,039 Foam core panels 95,498 Nonhalogenated plastic 1,733 20,994 Special coatings 12,333 3X pre-HEPA filters 82 5,084 Combustible bulk solid Sludge 64 64 Nonhalogenated plastics 50,972 3X concrete 0 79,993 Tap gear 4,555 3X foam wall panel 0 50,136 HEPA filters and prefilters 19,997 Special coatings 0 6,475 Adsorbents, cottons, rags, bulk 4,477 3X aluminum 48 3,435 Paper, wood, fiberglass, rubber 63,794 Total 42,063 912,017 Halogenated plastics 308,404 Sludge 1,997 a The source document for the estimates given in this table reported quan- RCRA toxic metal-bearing waste tities using the Army’s X system of classification rather than the currently Paint chips 121 preferred system based on AELs. A classification of 3X or 4X indicates Leather gloves 224 agent contamination to be <1 VSL. Other 1,000 bBGCAPP operations are estimated to have a duration of 2.08 years. Waste oil and hydraulic fluids 1,620 cBGCAPP closure is estimated to have a duration of 1.46 years. Agent-contaminated activated carbon 103,488 SOURCE: Adapted from PMACWA, 2006. Leaker campaign/overpack waste 15,000 Total 2,071,079 SOURCE: Adapted from BPBGT, 2006a. batch hydrolyzer, contaminated pallets, shipping and firing tubes, secondary wastes generated during operations, and TABLE 4-3 BGCAPP Projected 1X Agent-Contaminated certain closure wastes. Decontamination by means of high Secondary Waste Generation Rates During Operations and temperatures in the MPT will be verified by ensuring that the Closurea waste met time and temperature requirements for attaining “unrestricted release” status. Projected Rate (lb/yr) Operationsb Closurec 1X Waste other Waste streams Combustible solids 2,520 21,150 Metal 11,893 307,847 Based on the JACADS experience and BGCAPP es- TAP gear/rubber 267 267 timates, the committee has identified the following waste Halogenated plastic 4,787 50,346 streams in addition to those already identified in Table 4-1 Nonhalogenated plastic 1,062 12,867 and Table 4-2: Pre-HEPA filters 502 9,000 ACS/SDS sludge 520 520 • SCwO reactor liners. Because SCWO is so highly Concrete 0 34,283 Foam wall panel 0 21,487 corrosive, it may be necessary to replace the SCWO Special coatings 0 2,775 liner as often as once a week, but liner lifetime will Aluminum 0 1,472 not be known until the plant is in operation. Given Overpack waste 15,000 0 the harsh nature of the SCWO environment, it is Total 36,571 462,014 certain that some degree of liner replacement will be NOTE: TAP, toxic agent protective; HEPA, high-efficiency particulate air; required. The reactor liners are fabricated of titanium, ACS, agent collection system; and SDS, spent decontamination solution. and at present it is not known how they will be dis- aThe source document for the estimates given in this table reported quan- posed of. tities using the Army’s X system of classification rather than the currently • multimedia filters and canister filter media from preferred system based on airborne exposure limits. (AELs). A classification of 1X indicates agent contamination to be >1 VSL. the SCwO. The SCWO effluent is passed through bBGCAPP operations are estimated to have a duration of 2.08 years. multimedia filters and canister filters before enter- cBGCAPP closure is estimated to have a duration of 1.46 years. ing the reverse osmosis (RO) unit. The filter media SOURCE: Adapted from PMACWA, 2006. will constitute secondary waste, but at present there

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0 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg are no plans for characterizing or disposing of this respectively, in terms of the degree of contamination by mustard agent (1 VSL). material. • reverse osmosis brine. The RO rejectate will be a brine that is sent for offsite treatment. dunnage, energetics, and miscellaneous metal Parts • Scrubber water from the energetics offgas treatment (OTe) system. Scrubber water from the OTE is to Historical information, visual observation, and monitor- be treated through “subsequent processing.” Neither ing during transport to the energetics reconfiguration build- the waste nor the subsequent processing has yet been ing and during munitions disassembly are used to determine characterized. if dunnage or energetics could be agent-contaminated. • Particulate filter media from the OTe. Filter media Noncontaminated dunnage will be shipped offsite to a com- containing particulate matter are generated in the mercial treatment, storage, and disposal facility (TSDF) as OTE. They must be characterized and disposed of as a hazardous waste due to the presence of pentachlorophe- a secondary waste. nol. Noncontaminated propellant bags and wafers, ignition • cartridges, and miscellaneous metal parts removed in the Particulate filter media from the venturi scrubber. Filter media containing particulate matter are gener- energetics reconfiguration building will be shipped offsite ated in the venturi scrubber. They must be character- to a commercial TSDF. ized and disposed of as a secondary waste. Agent-contaminated dunnage may be treated in the supplemental decontamination unit (SDU) or the autoclave. Finding 4-1. The documentation for secondary waste The dunnage would include metal straps and parts removed streams made available to the committee failed to identify during reconfiguration, wood pallets and boxes, fiber tubes reverse osmosis rejectate brine, supercritical water oxidation and packing material, asbestos packing rings, steel grom- (SCWO) filtrate solid waste, SCWO titanium tank liners, mets, and other like materials. venturi scrubber particulate filters, or filters from the ener- Agent-contaminated energetics (e.g., wafers, bursters, getics offgas treatment system (OTE) as potential secondary boosters, fuzes, and well cups) will be treated in the explo- wastes from BGCAPP. sive destruction technology (EDT) unit; wastes from EDT treatment are not included in this report.1 Uncontaminated Recommendation 4-1. To avoid the possibility of unantici- energetics will be shipped offsite as a Class 1 (explosive) pated disposal problems, the PMACWA and the BGCAPP hazardous material. contractor should characterize and consider waste manage- ment options for reverse osmosis rejectate brine, supercritical solids from the munitions Treatment Unit water oxidation (SCWO) filtrate solid waste, SCWO titanium tank liners, venturi scrubber particulate filters, and energetics Solids from the munitions treatment unit (MTU) include offgas treatment system filters before submitting the waste munitions bodies and burster wells as well as residue (e.g., analysis plan required by RCRA. The PMACWA should also paint chips) generated during periodic cleaning of the MTU. look carefully for any as-yet-unidentified secondary waste Decontaminated munitions bodies will be sent offsite and streams from BGCAPP or PCAPP. can be recycled for scrap metal under Colorado regulations (PMACWA, 2006).2 The characterization of residue includes an analysis for toxicity characteristic leaching procedure secoNdarY WasTe GeNeraTioN From PcaPP (TCLP) metals. It is subsequently drummed and shipped oPeraTioNs ThaT iNclUde BioTreaTmeNT offsite to an appropriate TSDF. The processing of chemical munitions at PCAPP, which uses neutralization followed by biotreatment, will generate Filtering media secondary waste streams during pilot testing, munitions processing operations, and closure. These wastes may arise The offgas treatment systems and agent filter area (AFA) from general maintenance activities, equipment cleaning have filtering systems that will produce waste. These include and repair, measures to ensure worker safety, and sampling particulate filter waste, iron sponge absorber waste, prefilters, activities. Anticipated secondary waste streams, their source, and high-efficiency particulate air (HEPA) and activated and their anticipated management are listed in Table 4-5. The carbon filters. Activated carbon is used as filter medium in 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 1Again, as first noted in Chapter 2, a forthcoming NRC report will quantities of specific types of PCAPP wastes. Table 4-7 and examine the applicability of the various types of EDTs for use at PCAPP Table 4-8 show estimated amounts of the various types of and, possibly, BGCAPP. It will include an examination of wastes from EDT treatment. waste that will be generated during operations and closure, 2See Section C-2c(1), page C-20, of the cited reference.

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP 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 Operations activities Onsite treatment (agent-contaminated) explosives) Unspecified recycler or TSDF (if agent contamination concentration is below release criteria) Decontaminated munitions bodies, Operations activities Unspecified recycler processed through the MTU Metallic debris Operations, maintenance, and closure SDU or autoclave (agent-contaminated) activities Unspecified recycler or TSDF (if agent contamination concentration is below release criteria) Nonmetallic debris (combustible Maintenance and closure activities SDU or autoclave (agent-contaminated) solids) 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 Onsite agent hydrolyzers activities 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 SDU (agent-contaminated) activities 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 carbon is treated in the autoclave prior to agent analysis, personal protective masks. AFA banks 2 through 6 and some followed by offsite treatment and/or disposal. Design plans mask canisters are not expected to be agent-contaminated for PCAPP do not anticipate changing out activated carbon (PMACWA, 2006).3 Agent monitors are used between the filters prior to closure. respective banks of carbon to indicate if any agent has broken through the preceding bank. Noncontaminated carbon is to be secondary Wastes from Water recovery system and shipped offsite for treatment and/or disposal, with character- Brine reduction system ization based on generator knowledge. Agent-contaminated Sludges and other residues are produced by the bio- treater and the water recovery system (WRS). Filter cake 3See Section C-2b(4) of the cited reference.

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg TABLE 4-6 Total Estimated Secondary Wastes from TABLE 4-7 PCAPP Projected Amounts of Mustard- Normal Operations and Closure for PCAPP (pounds) Agent-Contaminated Secondary Waste from Normal Operations According to Level of Agent Contamination Normal Closure Waste Description Operations Operations Amount (lb) Wood dunnage 3,550,390 0 Stream Description 1 VSL Fiber tube 731,369 0 TAP gear 28,638 11,088 Wood 0 56,906 Steel/aluminum 38,182,554 129 Fiber tubes, additional packing material, 0 0 Brine reduction generated 55,114,416 0 metal strapping, miscellaneous metal Water recovery thickener residue 3,900,792 0 TAP gear 9,639 6,709 Energetics 138,225 0 Steel 0 0 Brass and copper wire 211,600 0 Lead alloy 0 0 Charcoal from PPE mask containers 2,583 1,000 Aluminum 18 53 Bulk solid waste 240,404 656,930 Brine reduction 0 0 Halogenated waste 27,294 93,983 Water recovery thickener residue 0 0 DPE suits 202,524 78,416 Energetics 0 0 Waste oils 7,687 2,976 Brass/copper wire 0 0 Spent hydraulic fluid 4,928 1,908 Charcoal from PPE mask containers 0 2,583 Leather 2,974 1,151 Inert bulk solid waste 15,421 35,790 Absorbents 23,886 16,447 Halogenated waste 3,153 2,661 Polystyrene and polyethylene (poly drums 14,024 3,685 DPE suits 121,514 81,010 and 5-mil poly bags) Waste oils/spent hydraulic fluid 2,416 400 HEPA/prefilters 0 38,000 Leather 437 197 HVAC 0 207,900 Absorbents 1,534 3,554 Filtration charcoal 0 170,000 Paper/fiberglass/rubber 0 0 Filter plenums 0 100,000 Polystyrene and polyethylene 669 2,318 Filter ductwork Combustible solid waste 2,827 2,382 Concrete scabbled 0 27,000 Waste paint sludge 915 455 Combustible solid wastes Dry cell batteries 1,828 203 Electrical parts/instrumentation 572 48,862 Lead acid batteries 1,219 135 (>5% plastics) Mercury-containing lighting 259 29 Nonhalogenated plastics 23,878 19,595 Total 161,849 195,385 Sludge (tanks, building sumps, strainers) 1,524 590 Waste paint sludges 4,099 1,588 NOTE: TAP, toxic agent protective; PPE, personal protective equipment. Batteries/mercury-containing lighting 48,980 1,833 SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, Bioreactor offgas treatment system 2008. 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 laboratory Wastes SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, Laboratory wastes are collected in each hood. All agent- 2008. 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- from the WRS dewatering filter press is tested for TCLP space monitoring, and drummed for offsite disposal. Process metals, TCLP organics, and free liquids. This waste stream knowledge is utilized to segregate agent-contaminated waste is drummed and shipped offsite for treatment and/or disposal streams from noncontaminated laboratory waste streams; the in an appropriate TSDF. latter do not require sampling or monitoring. The brine reduction system treats the clarified effluent from the WRS to produce a solid cake that can be disposed of Finding 4-2. At PCAPP, brine from the water recycling and offsite. The filter cake is tested for TCLP metals and organics sludge from the biotreatment are the largest waste streams. and for free liquids (PMACWA, 2006).4 This waste stream is They are not considered to be contaminated with chemical drummed and shipped offsite for treatment and/or disposal agent but may be a hazardous waste for other reasons. in an appropriate TSDF. 4See 5Specifically, Section C-2b(3), page C-14, of the cited reference. see Section C-2b(9), page C-16, of the cited reference.

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP clean if headspace monitoring shows the agent level to be TABLE 4-8 PCAPP Projected Amounts of Mustard- <1 VSL. For materials decontaminated at low temperature, Agent-Contaminated Secondary Waste from Closure headspace monitoring will be used for characterization. The According to Level of Agent Contamination Army has an array of monitors at its disposal that have been Amount (lb) effective in past applications. It is likely that either near- Stream Description 1 VSL real-time monitoring or Depot Area Air Monitoring System monitors would be used for headspace monitoring. Wood 0 0 Secondary wastes that have been in the vicinity of TAP gear 3,704 412 Steel 0 0 agent will need to be monitored to determine whether they Aluminum 21 7 are agent-contaminated. Examples of such process-related Brine reduction 0 0 wastes are wood pallets, PPE, rocket motors, plastics, toxic Water recovery thickener residue 0 0 agent protective gear, HEPA filters, absorbents, paper, and Propellant 0 0 rubber. Monitoring for agent contamination is to be con- Brass/copper wire 0 0 Charcoal 0 1000 ducted in accordance with the Department of the Army’s Inert bulk solid waste 262,351 259,498 implementation guidance Policy for revised Airborne expo- Halogenated waste 27,946 25,910 sure Limits (U.S. Army, 2004) and approved site procedures. DPE suits closure (APB) 47,050 31,366 For most potentially agent-contaminated solid wastes, the Waste oils/spent hydraulic fluid 927 164 headspace of the packaged material will be monitored to Leather 147 98 Absorbents 350 3153 determine their status as clean or agent-contaminated (NRC, Paper/fiberglass/rubber 0 0 2007). Characterizations by means of extractive techniques Polystyrene and polyethylene 0 785 may be required for certain types of secondary waste such (poly drums and 5-mil poly bags) as porous and/or adsorptive wastes for which headspace HEPA/prefilters 9,500 28,500 monitoring alone is not appropriate. Wastes that cannot be HVAC Filtration charcoal 30,690 3,410 decontaminated to the appropriate applicable AEL(s) must Filter plenums 15,300 1,700 be processed in the MPT before being shipped offsite for Filter ductwork 9,000 1,000 disposal in a permitted TSDF (BPBGT, 2006b).6 Concrete 38,775 12,925 For liquid streams, the initial hydrolysate from chemi- Combustible solid waste 26,359 26,503 cal agent neutralization will be sampled and analyzed for Waste paint sludges/sludges 0 531 Dry cell batteries 707 79 agent. The analytical procedures for testing GB and VX Lead acid batteries 472 52 hydrolysates have been outlined in the Technical Risk Re- Mercury-containing lighting 100 11 duction Program (TRRP) activity 2a, Phase II, and activity Total 473,399 397,102 11, respectively, which are discussed later in this chapter SOURCE: Answers to committee’s Question Set 5 for PCAPP, March 11, (Malloy et al., 2007; Dejarme and Lecakes, 2008).7 Once 2008. destruction efficiency (DE) has been demonstrated, subse- quent 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, PlaNNiNG coNsideraTioNs For secoNdarY prior to release from the plant areas under engineering con- WasTe maNaGemeNT trols for agent, hydrolysates and other liquid effluents will be analyzed to meet the target action limit, which is the agent determination of agent-contaminated and concentration for which 95 percent of the measurements are Noncontaminated Waste below the release criteria. BGCAPP Some of the secondary wastes generated at BGCAPP 6See Attachment 4, Section 4.2, of the cited document. could be characterized as noncontaminated, or “clean,” based 7The TRRP involves a series of laboratory and prototype equipment tests on generator process knowledge, risk assessment, or other that have been instituted as the ACWA program has evolved. The TRRP activities provide input into the design effort by filling data gaps and validat- evidence that the waste has never been in an environment ing the design basis. The intent is to help ensure the facilities’ equipment where it could have become contaminated by agent. In such and operations perform correctly once operations begin, which in turn will cases, these secondary wastes could be disposed of offsite help to ensure safety, accelerate the process, and reduce cost. Among the as solid wastes unless they demonstrate a hazardous charac- studies conducted have been design, fabrication, and testing of key first-of- teristic or contain another listed waste. a-kind equipment; SCWO performance testing; and studies using nerve and mustard agent to confirm neutralization reactor conditions. A waste that cannot be certified as noncontaminated 8The WAP for BGCAPP had not yet been developed or submitted when based on generator process knowledge can still be certified this report was being prepared.

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg PCAPP sented challenges for conventional chromatographic analysis schemes of VX and GB hydrolysates. This section describes Under the WAP filed with the Colorado Department the chemistry occurring during caustic hydrolysis of GB, of Public Health and Environment (CDPHE), PCAPP will VX, and mustard agent and notes the research that has been use generator process knowledge as the primary means of conducted to develop viable strategies for agent detection in characterization, with direct sampling and analysis used to the hydrolysate at required levels. verify process knowledge. Agent monitoring is conducted in accordance with the Army’s AEL guidance dated June GB Chemistry and Detection 18, 2004 (U.S. Army, 2004). There are three approaches for classifying and disposing of a secondary waste relative to its Base hydrolysis of GB results in formation of isopropyl contamination by agent: methylphosphonic acid and sodium fluoride, which are the principal components of the hydrolysate. Diisopropylcar- 1. The waste is containerized and its headspace is moni- bodiimide (DICDI) was present in the original agent, where tored to determine the appropriate classification; or it was used as a stabilizer. However, DICDI undergoes 2. The waste is assumed to be agent-contaminated and hydrolysis in the original agent, forming 1,3-diisopropyl is decontaminated in accordance with the RCRA urea (DIPU), which is detected in both the agent feed and permit or regulations; adequate decontamination in the hydrolysate. Hydrolysis mostly produces an aqueous (<1.0 VSL) is verified via monitoring at the SDU or phase, but a small organic phase is also produced (Malloy autoclave, whereupon it is reclassified as “clean” and et al., 2007). shipped offsite; or Two salient issues in the hydrolysis of GB motivated 3. The waste is assumed to be agent-contaminated and a TRRP activity (Malloy et al., 2007). First, quantities of is shipped offsite to a facility permitted to receive GB that exceeded the minimum detection limit, 20 μg/L, such wastes. had been found in the brines that are an end product of the process. Second, the neutralization process and the clear- Following approach 1, if <1.0 VSL, the waste is classi- ing (screening) of the resulting hydrolysates was too time- fied as clean and shipped offsite, and if >1.0 VSL, approach consuming for the large-scale processing effort being pro- 2 or approach 3 is followed (PMACWA, 2006).9 Adequate posed for BGCAPP. decontamination, defined as <1.0 VSL, may need to be A primary objective of TRRP activity 2a, Phase II, was accomplished in the SDU or the autoclave and verified to find a workable new method for GB analysis (Malloy et via monitoring at the SDU or the autoclave. As previously al., 2007). The method previously used suffered from inac- indicated, Table 4-6 shows the total estimated secondary curacy derived from the GB re-formation that occurred in wastes, while Tables 4-7 and 4-8 show projected generated the heated injector of the gas chromatograph used for the quantities of contaminated secondary wastes according analysis. This proved problematic for demonstrating that the to their level of contamination (before any onsite treat- GB concentrations in the hydrolysate were <75 ppb, which ment) for the operational and closure stages of PCAPP, was the action level for clearing the hydrolysate. respectively. An improved extraction-gas chromatograph/mass spec- trometer method was developed using a cool-on-column in- Finding 4-3. In the committee’s opinion, the waste manage- jection that eliminated GB re-formation in the injector during ment planning for PCAPP was overly optimistic in projecting the analysis. This enabled a much more rigorous evaluation there would be no agent-contaminated energetics, wood dun- of hydrolysis performance starting with GB batches of vary- nage, etc. (as shown in Tables 4-7 and 4-8). The committee ing compositions. The new method (EXTN/COC/GC/MS, believes, based on the past experience of its members, that BGCAPP 104b) (Malloy et al., 2007) was demonstrated some of these wastes will in fact be contaminated to some to be effective for GB hydrolysates of varying composi- extent. Nevertheless, the optimism in projecting no agent tions, specifically GB stabilized with either tributylamine contamination of these wastes is accommodated by having or DICDI, and also for GB crystals (DIPU). The method a capability for decontamination, if necessary, in the supple- can also be used for measuring GB in other matrices, such mental decontamination unit or autoclave. as the munitions washout hydrolysate, blended hydrolysate, SCWO effluent, RO rejectate, and energetics hydrolysate hydrolysate chemistry, related analytical approaches (Malloy et al., 2007). See Appendix D for additional details of TRRP activity 2a, Phase II. An important aspect of the secondary treatment of the agent hydrolysate is verification of 99.9999 percent Finding 4-4. The research on analysis methodologies for agent destruction. The sodium hydroxide matrix has pre- determining the level of residual agent in GB hydrolysate from Technical Risk Reduction Program activity 2a, Phase 9See Attachment C, Section C-2b(1), of the cited documents.

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP II, provides assurance that the level of residual GB in the problematic in past operations, and it was reasoned that hydrolysate can be measured accurately. the validity of the results of the VX neutralization reactor tests for BGCAPP could be questioned on the basis of inac- curate, imprecise, or insensitive analytical procedures. For VX Chemistry and Detection this reason, TRRP activity 11 (Dejarme and Lecakes, 2008) Caustic hydrolysis of VX generates a hydrolysate that also examined the analytical methods for VX and EA2192 normally consists of two liquid phases: (1) an aqueous phase that are used for clearing the hydrolysate. It was believed containing caustic and dissolved salts and (2) an organic that the method that had been used at Newport Chemical phase that contains organics having limited water solubil- Agent Disposal Facility could be used at BGCAPP. How- ity (Dejarme and Lecakes, 2008). The hydrolysate contains ever, operational challenges, including matrix interferences, ethyl methylphosphonic acid and diisopropylaminoethane- were identified. Consequently, TRRP activity 11 included thiol (also known as DESH, thiolamine, or VX thiol) as the extensive research that produced a modified extraction-gas main hydrolysis products. In addition, EtOH and a com- chromatography/mass spectrometry method that employed pound known as EA2192 are formed, which is significant cool-on-column injection. This eliminated re-formation in because EA2192 is nearly as toxic as VX and is fairly stable. the injector region and enabled refinement and optimization The organic phase is principally bis(diisopropylaminoethyl) of both the extraction and chromatographic details. Ad- disulfide, which is formed from oxidation of the thiolamine. ditional details on the results of this research are presented Other compounds that might partition into the organic in Appendix D. These studies indicate that the instrumental phase would include residual thiolamine, stabilizers such as method used for clearing the VX hydrolysate for further DICDI, dicyclohexylcarbodiimide (DCC), and intact VX. SCWO treatment is adequate. Reaction of ethyl methylphosphonic acid with dicyclohex- Finding 4-5. The research on analysis methodologies for ylcarbodiimide has been shown to result in formation of diethyl dimethyl pyrophosphonate (also known as VX pyro), determining the levels of residual agent in VX hydrolysate which has substantial toxicity and will react further with the from Technical Risk Reduction Program activity 11 provides diisopropylaminoethanethiol to re-form VX (Brickhouse et assurance that the level of residual VX in the hydrolysate can al., 1998). be measured accurately. TRRP activity 11 was conducted to determine whether the hydrolysate contained residual VX (Dejarme and Lecakes, Mustard Agent (H, HD, HT) Chemistry and Detection 2008). For the BGCAPP design incorporating SCWO, this was important because clearance levels for moving hydroly- Caustic hydrolysis of mustard results in formation of 2,2'- sate to the SCWO reactor system were 160 µg/L for VX and thio-bis-ethanol (thiodiglycol); 2,2'-[1,2-ethanediylbis(thio)]- 1 g/L for EA2192. Bench-scale reactor tests were conducted ethanol; 2,2'-[oxy bis(2,1-ethanediylthio)] bis-ethanol; on five different batches of VX from munitions that con- 1,4-oxathiane; 1,4-dithiane; 1,2-dichloroethane; and vinyl chloride (Yang et al., 1988).10 The TRRP activity that fo- tained either DICDI or dicyclohexylcarbodiimide as stabiliz- ers. Experiments were conducted by mimicking the recipe cused on characterization of mustard agent H hydrolysate did for BGCAPP, which involved loading the reactor with 16.6 not indicate problems with either the hydrolysis chemistry or percent VX, 17.4 percent caustic (which was 50 percent so- the analysis (Usinowicz et al., 2005). It is well known that dium hydroxide), and 66 percent water and heating the mix- mustard agent H undergoes degradation reactions during ture to 90°C. The reactor studies produced VX hydrolysate storage (Creasy et al., 1999), and some of these products that could be analyzed for residual VX using a modified can form higher molecular weight mustard heels (Yang et al., cool-on-column gas chromatograph method (see below). 1997). However, because these were readily soluble under Residual EA-2192 was analyzed using high-performance washout conditions, they do not complicate either hydrolysis liquid chromatography employing either diode array or ul- or analysis. traviolet detection (detail is provided in Appendix D). When Finding 4-6. Work on the characterization of mustard agent the method was applied to hydrolysate generated in a reactor using the neutralization recipe to be used at BGCAPP, VX hydrolysis showed that the analysis for mustard agent is was not detected in any of nine batches, with limits of quan- accurate and did not give any evidence of any outstanding tification ranging from 4 to 14 µg/L (ppb). EA2192 was de- risk to the public, the workforce, or the environment stem- tected in only one batch (at 51 ppm), with method detection ming from the hydrolysis chemistry or the analysis of the limits ranging from 11 to 159 ppm. Reanalysis of this sample hydrolysate. 24 hours later showed that EA2192 was not detected. An- other significant result was that VX was not detected in the 10Yu-Chu Yang, Assembled Chemical Weapons Alternatives Program, headspace of the reactor. “Chemical compositions of liquid HT, solid HT, liquid H and solid H,” pre- Instrumental analyses for VX and EA2192 have been sentation to the Mustard Working Group Meeting, September 23, 2003.

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg offsite Treatment of secondary Wastes rent planning calls for validated process controls and statis- tical testing to be used in lieu of analyzing all batches of a In addition to the offsite shipment of noncontaminated hydrolysate once 99.9999 percent destruction efficiency has secondary wastes, some potentially agent-contaminated been demonstrated on agent hydrolysate.13 Liquid effluents wastes may be shipped offsite provided (1) the waste meets would have to be analyzed to determine if they meet the any release criteria or limit as established in the RCRA established release criteria before release from the area of permit, (2) the offsite facility is permitted to receive such the munitions demilitarization building under engineering wastes, and (3) transportation risks are assessed and found controls for agent. to be acceptable.11 For example, the Army has proposed shipping spent Finding 4-8. Generator process knowledge (validated pro- activated carbon offsite for treatment. In addition, according cess controls and statistical testing) is expected to be used to the briefing given to the committee on January 23, 2008, where possible to determine destruction of agent in hydroly- consideration may be given to offsite shipment of certain sate on a continuing basis at BGCAPP and PCAPP. liquid streams.12 In such cases, release criteria will be estab- lished in accordance with federal, state, and Army policies, Recommendation 4-3. Each batch of agent hydrolysate pro- and only secondary wastes that meet these release criteria duced at BGCAPP and PCAPP should be sampled to ensure will be transported offsite for treatment or disposal. Release that the required level of agent destruction has been met to criteria may differ from DE levels (e.g., “nondetect” at satisfy potential stakeholder concerns. PCAPP and target release levels at BGCAPP) for removal of liquids from areas of the facility under engineering controls To determine if a transportation risk assessment is neces- for limiting exposure to agent. Depending on the require- sary for offsite shipments of secondary wastes, the Army has ments established in the facility’s WAP, such wastes must proposed using hazardous solid waste assessment method- be characterized using an appropriate methodology before ologies to ensure that concentrations of residual agent in any being shipped offsite. Such methodologies may include wastes shipped offsite are within the limits set by a standard monitoring or extractive analyses, as well as characterization approach (bounding)14 transportation risk assessment for by generator knowledgefor example, operating records or wastes with >1 VSL; this approach is currently under devel- process knowledge, vapor screening, and actual characteriza- opment by the Chemical Materials Agency (CMA) (NRC, tion). The receiving facility can also ask for additional tests 2007). Examples of such assessment methodologies include, beyond those done at the destruction facility. but are not limited to, headspace monitoring and extractive analysis (e.g., approved agent-related methods, EPA SW-846 Finding 4-7. The applications for modifications of the re- methods and procedures (EPA, 2007), operational records, search, development, and demonstration permits for both and characterization via generator knowledge). BGCAPP and PCAPP proposed that a number of specific secondary wastes be shipped offsite for treatment or ultimate closure Planning disposal. BGCAPP Recommendation 4-2. The Program Manager for As- sembled Chemical Weapons Alternatives should continue to Wastes generated at BGCAPP during closure will not pursue the acceptance of the planned offsite shipment and be dissimilar to those generated at JACADS. 15 The an- disposal of secondary waste through permit modifications ticipated wastes have been estimated based on knowledge and stakeholder involvement. from JACADS and adjusted for the BGCAPP footprint and design. The amount of contaminated closure wastes that In the BGCAPP and PCAPP facilities, the processes for will require decontamination for agent should be less than munitions disassembly and agent destruction by hydrolysis that experienced at JACADS because the plant is smaller (neutralization) are conducted in the munitions demilitariza- and more of the processing equipment is outside the exclu- tion building, which is under engineering controls for limit- sion zone. ing exposure to agent. Processes for secondary treatment The anticipated closure waste quantities are summarized such as SCWO or biotreatment are outside the area under in Tables 4-3 and 4-4. The largest amounts of waste will these engineering controls. Effluents from agent chemical be metals, halogenated plastics, and concrete. Halogenated neutralization would have to be sampled and analyzed. Cur- 13Kevin Regan, environmental manager, BGCAPP, “Current waste analy- 11Transportation risk assessments are discussed in a later section of this sis and certification,” presentation to the committee, January 23, 2008. chapter. 14Bounding conditions are the maximum agent concentrations and maxi- 12Kevin Regan, environmental manager, BGCAPP, “Process alternates mum number of shipments specific to the site. for wastes,” presentation to the committee, January 23, 2008. 15See NRC, 2002b, for information on the closure wastes at JACADS.

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP plastic includes demilitarization protection ensemble suits Precautions have been taken in the areas of the plant and related entry equipment. In addition, there will be con- likely to become contaminated with agent to minimize the taminated and noncontaminated activated carbon from the contamination of concrete. An epoxy coating is used to offgas treatment systems. minimize contamination of the concrete as a result of spilled Closure wastes contaminated with agent above clear- agent, hydrolysate, and decontamination solution. The coat- ance levels based on the Army’s AEL guidance and suited ing would have to remain intact over the much shorter oper- for treatment in the MPT are expected to be decontaminated ating period than the operating period for JACADS, which in the MPT to appropriate release criteria that have not yet was 10 years. This could allow for shallower scabbling of been established or approved (U.S. Army, 2004). This will the concrete than the 0.25-inch depth used at JACADS. It require careful planning to ensure that the MPT is operational should also mean that there is less contamination in cracks during deconstruction. and joints. It is expected that noncontaminated and decontaminated secondary waste will also be cleared for offsite shipment PCAPP using the Army’s current AEL guidance or generator knowl- edge. Where possible, headspace analysis will be used to The anticipated closure wastes are summarized in Table clear material. Several of the closure wastes present unique 4-6. These are estimates based on the wastes generated difficulties because they will come from agent processing ar- during closure of the Aberdeen Chemical Agent Disposal eas that may have been exposed to elevated agent-vapor read- Facility, which used the same neutralization process to de- ings but are unlikely to be agent-contaminated. Examples stroy HD mustard agent stored in bulk. Estimates were made of these wastes are electronic circuit boards, closed circuit of the additional waste from the closure of the bioreactors, television cameras, batteries, and mercury switches. The which were not a part of the process at Aberdeen, where the waste estimate Summary report proposes that the wastes hydrolysate was sent to a commercial TSDF. be chemically decontaminated and then shipped offsite for The largest volumes of closure wastes will be steel additional treatment and/or disposal rather than processed and other metals, activated carbon, halogenated plastic, and through the MPT (BPBGT, 2006a). concrete. These wastes will for the most part have agent The option of shipping wastes with low levels of agent contamination of <1 VSL because they did not come from contamination that are >1 VSL to an appropriate TSDF the areas where neat agent was being processed. It should be would still need to be negotiated with the regulatory au- possible to ship them to an appropriate TSDF as hazardous thorities and would require active involvement of the public waste for further treatment or disposal. stakeholders in order to allow for a smooth operation. As at BGCAPP, the amount of concrete waste that will A significant closure waste stream is scabbled concrete. require treatment because of possible agent contamination This material is of concern because agent that contacts it could be much less than in past operations. The PCAPP de- may be absorbed by the coatings on the concrete or into the sign likewise calls for epoxy coating for all surfaces in the pores below. Therefore “concrete may have to be removed process areas where there is potential for exposure to agent. or cracks may have to be chased locally” (BPBGT, 2006a, This would minimize the possibility of agent contamination p. 12). The requirement at BGCAPP is that the potentially of the concrete, in turn minimizing the depth of scabbling contaminated concrete will be “scarified to a nominal depth required to less than 0.25 inch. Based on JACADS experi- of 0.25-inch. The 0.25-inch scabbling depth should be suf- ence, even the scabbled concrete was amenable to disposal ficient to remove contaminants that may have permeated without further treatment. through the layers of protective coating” (BPBGT, 2006a, Finding 4-9. The current plans for scabbling to a depth of p. 11). This requirement is derived from experience in the nuclear industry and from the JACADS closure require- 0.25 inch during the closure of BGCAPP and PCAPP appear ments. The experience in the nuclear industry is related to to be conservative and to have no explicit scientific justifica- the migration of radionuclides (metal cations) into concrete, tion. This could result in more scabbled concrete than neces- but chemical warfare agents (organic compounds) may sary being classified as agent-contaminated. not behave the same way. The second justification for the Recommendation 4-4. The Program Manager for As- depth of this is derived from the JACADS closure re- quirement, but the waste estimate Summary report does sembled Chemical Weapons Alternatives (PMACWA) not seem to contain any further technical backing for the should examine the justification for scabbling the concrete decision. Since the scabbled concrete could generate a to a 0.25-inch depth in order to understand how deep the significant volume of secondary closure waste, any action concrete must be scabbled during the closure of BGCAPP that would minimize the quantity of material categorized and PCAPP. Alternatively, the PMACWA should investi- as agent-contaminated would result in substantial savings gate means for measuring residual agent on the concrete for the Army. surfaces.

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg comParisoN WiTh iNdUsTrial PracTices on and the subsequent human uptake.20 Both BGCAPP and PCAPP will employ treatment units to remove and destroy The material in this section is supplemented by material residual agent contamination that may exist on metal parts in a previous National Research Council report (NRC, 2007), and other solid wastes generated as part of the agent treat- which addressed four chemical agent disposal facility sites in ment process. These units themselves possess the potential to the continental United States that use incineration technology emit air pollutants. As stated previously, current laws do not and one site that uses neutralization technology, all of them specifically require an HHRA, but state regulatory agencies operated under the authority of the CMA. The regulatory may require one based on broad regulatory powers. requirements and the types of secondary wastes that will be generated at the two ACWA facilities being studied here are BGCAPP very similar to those at the CMA facilities. KDEP has notified ACWA program staff that it will re- quire an HHRA for BGCAPP.21 The HHRA methodology to Waste management Treatment and disposal be used has not been negotiated with KDEP, but it is expected As described in Chapter 3, ACWA facilities and indus- to be a screening-level analysis rather than a detailed analy- trial hazardous waste facilities are both governed by RCRA sis since the emissions are expected to be low.22 However, regulations. In both cases, waste characterization, includ- if emissions during pilot-scale testing are higher than those ing acceptable analytical methodologies, is guided by the assumed for the HHRA, the HHRA will be revised. Since facility’s RCRA permit and the associated WAP. Based on the potential requirement to conduct an HHRA is likewise the aforementioned report (NRC, 2007) and on discussions applicable to commercial industrial facilities, it is a reason- between members of the present committee with person- able requirement for BGCAPP. nel from KDEP, BGCAPP,16,17 CDPHE, and PCAPP,18,19 the committee has determined that there is little difference PCAPP between the application of regulatory conditions and require- ments at industrial hazardous facilities and chemical agent The CDPHE required ACWA program staff to submit disposal facilities. Moreover, for BGCAPP and PCAPP, as a draft protocol for conducting an HHRA for PCAPP (it for the other chemical agent disposal facility sites, what few uses the designation “multiple-path health risk assessment small differences do arise, arise for the same reason as given (MPHRA)).”23 The protocol for performing a screening- in the 2007 report, namely: level MPHRA was finalized in mid-2007, and the MPHRA was submitted for CDPHE review in late 2007. However, the characterization, management, and disposal of chemical if emissions during pilot-scale testing are higher than those agents and the related secondary wastes at chemical agent assumed for the MPHRA, it will be revised. Since the po- disposal facilities are not specifically addressed in federal or tential requirement for an MPHRA is likewise applicable to state regulations and must therefore be addressed in the indi- commercial industrial facilities, it is a reasonable require- vidual chemical agent disposal facility permit. This results in ment for PCAPP. 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 inter- Finding 4-10. The same regulatory requirements concerning pretation of the limits necessary for these distinctive wastes. health risk assessments that apply to industry also apply to (NRC, 2007, p. 56) BGCAPP and PCAPP. human health risk assessments Transportation risk assessments Human health risk assessments (HHRAs), also some- U.S. Department of Transportation (DOT) regulations times called multiple-path health risk assessments or, simply, for the transport of hazardous materials (49 CFR) have health risk assessments, are a type of risk assessment that ad- evolved and are modified as necessary to protect the public. dresses the long-term exposure of the public to the approved, Both commercial facilities and the ACWA facilities must long-term stack releases as they affect air, water, food, and so 20The terms health risk assessment, human health risk assessment, and 16Committee fact-finding meeting with the KDEP, Frankfort, Ky., Janu- multiple-path health risk assessment all apply to the same type of risk ary 24, 2008. assessment. 17Kevin Regan, environmental manager, BGCAPP, “Process alternates 21Kevin Regan, environmental manager, BGCAPP, “Process alternates for wastes,” presentation to the committee, January 23, 2008. for wastes,” presentation to the committee, January 23, 2008. 18Craig Myler, chief engineer for process and technology, Bechtel 22The screening-level methodology is also being used at PCAPP, as was National, Inc., “PCAPP secondary waste discussion,” presentation to the learned at a committee fact-finding meeting with the CDPHE, Denver, Colo., committee, February 13, 2008. February 14, 2008. 19Committee fact-finding meeting with the CDPHE, Denver, Colo., 23Fact-finding meeting with the CDPHE, Denver, Colo., February 14, February 14, 2008. 2008.

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 STATUS Of PLANNiNg fOr The mANAgemeNT Of SeCONdAry wASTeS AT bgCAPP ANd PCAPP comply with DOT regulations, including standards for pack- It further states aging, marking, vehicular safety, and driver qualification. For waste greater than 1 VSL, sites should use existing DOT regulations do not require or recommend a transpor- hazardous waste assessment methodologies to appropriately tation risk assessment (TRA) for shipments of hazardous characterize the waste to assure agent concentrations are materials; however, a TRA can suggest measures to further within the bounding condition of the TRA.25 mitigate risk, including routing to reduce the mileage, popu- lation along the route, and/or crash likelihood; additional or and strengthened barriers to an uncontrolled release; and control of ambient and/or postcrash environments. A site-specific risk assessment should be developed to assess Neither the state of Kentucky nor the state of Colorado and establish the necessary monitoring requirements for has specific requirements that address the transportation of loading, transportation, and processing operations related to chemical munitions or wastes derived from them. However, secondary waste shipments greater than 1 VSL.26 in the case of PCAPP, Pueblo County land use regulations at Title 17, Chapter 176, Section 050, require that the “risk of and accidents occurring during the transportation of any wastes to, from, or at the prosposed site . . . be considered when Waste shipments are to be managed in accordance with proposing to locate, construct, operate, or close a hazardous DOT regulations for appropriate state and local emergency waste processing site.” response actions. . . .The CMA facility needs to work in con- A TRA was prepared for PCAPP in 2003 that addressed cert with the receiving TSDF and the waste shipper to ensure that there are adequate response capabilities to respond to an combinations of a number of the following categories for emergency in route. 27 offsite shipment: (1) uncontaminated metal parts, dunnage and ash, bioreactor salt cake, sludge, and washout solution; The ACWA program does not have similar guidance but (2) mustard agent hydrolysate; (3) energetics hydrolysate; expects to follow the CMA guidance with respect to offsite and (4) energetics (burster, propellant, and fuze) (FOCIS, shipment.28 2003). That TRA focused on the risk of injury or fatality due to accidents involving only a heavy truck (no cargo effects) Finding 4-11. The PMACWA has stated the intention to fol- and on the fire and explosion risk due to the energetics cargo. The effects of accidents involving the cargo in the case of low the offsite shipment guidance of the Chemical Materials the first three categories were qualitatively dismissed (ow- Agency (CMA). However, with respect to waste character- ing to the nonreactivity and low volatilities of the materials) ization and monitoring, the (June 25, 2007, CMA-issued) and were considered to have negligible risk compared to the guidance requires the use of existing hazardous waste as- risk of heavy truck, cargo-independent injuries and fatalities. sessment methodologies. An environmental assessment was prepared pursuant to the National Environmental Policy Act that relied on the above Recommendation 4-5. The PMACWA should seriously TRA for uncontaminated dunnage and uncontaminated, consider adopting the Chemical Materials Agency stan- stable propellant. However, the committee is not aware of dard (bounding) approach in preparing transportation risk the formal submission of the underlying TRA, or any other assessments. TRA, to Pueblo County. Recently, CMA issued guidance on factors that must Recommendation 4-6. When developing transportation risk be considered and addressed for offsite shipment of agent- assessments, the PMACWA should use the most current haz- contaminated secondary waste. The guidance states as ardous waste assessment methodologies for characterizing follows: the wastes generated at BGCAPP and PCAPP. When shipping waste that is determined to be above 1 VSL, Recommendation 4-7. A site-specific transportation risk a quantitative analysis will be performed to assess the po- assessment should be developed for all wastes that may tential agent hazards associated with higher levels of agent be agent-contaminated and shipped from BGCAPP and contamination and a qualitative hazard analysis concerning PCAPP. 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 stockpile chemical materiel, Re: Guidance for Development of Site-Specific (TRA) for the chemical agent hazard. This approach shall be Plans for Shipment of Chemical Agent Contaminated Secondary Waste, used by all CMA sites and activities for agent contaminated from Dale Ormond, acting director, CMA, dated June 25, 2007, p. 2. wastes above 1 VSL. The CMA RMD will assist sites in 25Ibid. development of their TRA.24 26Ibid. 27Ibid., p. 3. 28Committee discussions with Joseph Novad, technical director, ACWA, 24Memorandum to CMA commanders, site project managers, project Pueblo, Colo., February 14, 2008. manager for chemical stockpile elimination, and project manager for non-