Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (2008)

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Summary The U.S. Army is in the process of disposing of the na- the Johnston Atoll Chemical Agent Disposal System and tion’s stockpile of chemical agents and munitions. At present, the Aberdeen Chemical Agent Disposal Facility, which have there are five active disposal facilities and two that are in the already been closed. Many of the wastes will be the same as design and early construction phases. This study deals with or very similar to those that were or are being generated at the wastes that will be generated as a result of the disposal the other facilities, both closed and operating. While some of the munitions at the two facilities that have yet to be built wastes that will be generated at BGCAPP and PCAPP will and placed in operation. These wastes are considered to be be different from the wastes generated at facilities using “secondary wastes”; the munitions and agents are themselves combustion technology, neutralization technology was used considered to be “hazardous wastes.” Of the five operating at the Aberdeen Chemical Agent Disposal Facility to dispose facilities, four use combustion to process the agents and of bulk mustard agent and at the Newport Chemical Agent munitions, while the fifth uses neutralization to process bulk Disposal Facility (NECDF) to destroy bulk nerve agent agent. The two facilities considered in this study will utilize VX. These facilities thus offer additional insight into the neutralization (hydrolysis) as the basic agent destruction pro- secondary waste generation scenarios that can be expected cess, followed by different treatments of the product of the for BGCAPP and PCAPP. neutralization, hydrolysate. While the facilities are in many The Committee to Review Secondary Waste Disposal ways similar, they are also different in the types of agents and Regulatory Requirements for the Assembled Chemical and munitions that are to be disposed of. Weapons Alternatives Program (ACWA Secondary Waste The Blue Grass Chemical Agent Destruction Pilot Plant Committee) analyzed process flow sheets and other design (BGCAPP) will dispose of munitions containing nerve information that was provided in order to comprehensively agents GB or VX, or mustard agent H. These are contained in identify all sources of secondary waste streams. While the a variety of munitions, including M55 rockets containing GB primary agent destruction process will be basically the same or VX. The Pueblo Chemical Agent Destruction Pilot Plant at BGCAPP and PCAPP, the facilities are very different in (PCAPP) will process projectile munitions that contain only detail owing to the aforementioned differences in the types mustard agent HD or HT; no rockets are stored at the Pueblo of munitions and agents to be processed by each. In brief, Chemical Depot (PCD). At the Blue Grass Army Depot the munitions are moved from storage igloos to the disposal (BGAD), the agents and munitions to be destroyed number facility, where they are unpacked. Energetics, if any, are approximately 100,000 items, two-thirds of which are M55 removed, and the agent is drained from the agent cavity of rockets. The various projectiles stored at PCD number nearly the munition. The agent is then neutralized and the liquid 800,000. While these facilities are called “pilot plants,” they hydrolysate is treated in a second step to further degrade the are in fact full-scale facilities that are pilot plants only in the organic material. The energetics are either shipped offsite or sense that a new technology is being used at each facility. neutralized to produce a second liquid hydrolysate, which is Pilot plant designation, design, and fabrication also allow also treated to further degrade it. Detailed descriptions of the for more flexibility in the operation until the process and two process systems may be found in Chapter 2. technologies have been demonstrated fully. A large number of secondary waste streams emanate This study is based on estimates of the wastes that from the process steps, maintenance activities, personal will be generated during operations and closures. These protection equipment, and laboratory operations. The wastes estimates are based on design data for the respective pilot are categorized as “contaminated” or “noncontaminated with plants, data from other operating facilities, and data from agent residues” depending on whether they (1) have been in  

 Review of secondary waste disposal Planning contact with agent or (2) have been treated to destroy the chemical agents, which has been prohibited by statute since agent residues or to meet certain waste clearance criteria. the mid-1990s. There has since been some movement toward These criteria were established based on prior experience but shipping some wastes offsite, and there may be more willing- in general have not been formally approved for the site by ness on the part of the stakeholders to consider offsite ship- the respective regulatory permitting authorities. In the case ments of certain other wastes. However, this would require of PCAPP, a waste analysis plan has been developed but not changing the current permits. Moreover, based on discussions approved. For BGCAPP, a waste analysis plan must still be with the stakeholders, appropriate safeguards are necessary developed and submitted. In both Kentucky and Colorado, to ensure that such shipments would be safe, environmentally these wastes are “listed wastes,” as defined in Resource Con- sound, and considerate of environmental justice concerns servation and Recovery Act (RCRA) regulations, because of the transit and receiving areas. The committee met with they stem from agent processing. Wastes may be “hazard- various stakeholder groups to sample public sentiment. Issues ous” because they are agent-contaminated or because they raised in these discussions are valuable, but the committee are “characteristic hazardous wastes” under RCRA and ap- notes that the conclusions arrived at are derived from only a plicable state regulations. The regulations and permits under small fraction of the population and may not be representative which the sites operate are discussed in Chapter 3. of the wider populations in the areas. The committee’s discus- This study considers all secondary wastes that are gener- sions with stakeholder groups are summarized in Chapter 5. ated from the disposal processes and focuses on the wastes The committee found that the ACWA program and its that could be considered for offsite shipment. The wastes contractors appear to be treated by regulatory authorities just that are generated from the process at each site as currently like any commercial facility that treats, stores, and disposes designed are described in detail in Chapter 4. While all of listed hazardous wastes, with one exception: It is expected secondary wastes were considered, this study is primarily that the Army will treat the hazardous waste onsite. Many concerned with the major waste streams in terms of volume. commercial hazardous wastes are routinely shipped to per- The major wastes from BGCAPP include mitted treatment, storage, and disposal facilities (TSDFs). At present, this is not possible for many of the major volume • Dunnage, waste streams that will be generated at BGCAPP and PCAPP • Metal from munitions, despite the fact that many of these waste streams have been • Supercritical water oxidation (SCWO) effluent safely shipped to permitted TSDFs from the other combus- solution, tion and neutralization facilities. • Spent decontamination solution, In Chapter 6, the committee discusses the technical • Plastics, particularly from demilitarization protective feasibility of shipping some of the major waste streams equipment, to TSDFs that are permitted to handle similar wastes that • Noncontaminated energetics, and may be more difficult to dispose of. It recognizes that there • Hydrolysate (if shipped to a treatment, storage, and may be institutional impediments to such alternatives. The disposal facility (TSDF)). committee concluded that from a technical perspective, the wastes could be shipped offsite without negatively impacting From PCAPP, they include either safety or the environment and could have advantages in terms of disposal program acceleration, including lower • Dunnage, investment, a smaller footprint for the facility, and a shorter • Metal from munitions, time for closure. However, the offsite option may be unat- • Plastic, particularly for demilitarization protective tractive for other reasons. That is a decision outside the scope equipment, of this study. Some of the institutional barriers or hurdles to • Noncontaminated energetics, using an alternative to onsite treatment are presented. • Water/brine recovery salt cake and biomass sludge, • Spent activated carbon, and Major Findings and Recommendations • Hydrolysate (if shipped to a treatment, storage, and disposal facility (TSDF)). Two key recommendations from Chapter 6 along with the major findings and recommendations from the other In addition, a great deal of metal, concrete, decontamination chapters appear below. solution, plastics, and spent activated carbon will be gener- ated during the closure phase. Key Findings and Recommendations There is significant public sentiment, as expressed by the respective Citizens’ Advisory Commissions in Kentucky and Colorado as well as other interested groups, that all contami- Finding 6-1. The shipment of certain secondary wastes to nated and potentially contaminated wastes should be treated suitable offsite TSDFs could have significant advantages. onsite. This sentiment stems from concern about shipping Among these are savings in facility infrastructure and equip- 

SUMMARY  ment costs, a smaller footprint for the facility, and a shorter getics offgas treatment system (OTE) as potential secondary time for closure. wastes from BGCAPP. Finding 6-8. The experience to date with the offsite shipment Recommendation 4-1. To avoid the possibility of unantici- and treatment of mustard and nerve agent hydrolysates from pated disposal problems, the PMACWA and the BGCAPP the Aberdeen and Newport Chemical Agent Disposal Facili- contractor should characterize and consider waste manage- ties indicates that offsite transportation and disposal of these ment options for reverse osmosis rejectate brine, supercritical materials is a safe and technically viable course of action. water oxidation (SCWO) filtrate solid waste, SCWO titanium tank liners, venturi scrubber particulate filters, and energetics Recommendation 6-7. Because experience shows that offgas treatment system filters before submitting the waste offsite shipment and treatment of agent hydrolysates from analysis plan required by RCRA. The PMACWA should also BGCAPP and PCAPP is safe and technically viable, and look carefully for any as-yet-unidentified secondary waste in view of better analytical methods being developed, the streams from BGCAPP or PCAPP. PMACWA should consider this option now, before the plants are built and operating, to maximize the benefit from such Finding 4-4. The research on analysis methodologies for a change. It is important to consider everything that would determining the level of residual agent in GB hydrolysate impact such a change. from Technical Risk Reduction Program activity 2a, Phase II, provides assurance that the level of residual GB in the Finding 6-9. Spent activated carbon and other closure hydrolysate can be measured accurately. wastes were successfully shipped offsite from the Aberdeen Chemical Agent Disposal Facility to an appropriate TSDF Finding 4-5. The research on analysis methodologies for for ultimate disposal. determining the levels of residual agent in VX hydrolysate from Technical Risk Reduction Program activity 11 provides Recommendation 6-8. The shipment offsite to an appropri- assurance that the level of residual VX in the hydrolysate ate permitted TSDF of all types of wastes, including spent can be measured accurately. activated carbon and closure wastes, should be examined and given serious consideration in light of past experience Finding 4-6. Work on the characterization of mustard agent showing that it is a technically viable and safe method of hydrolysis showed that the analysis for mustard agent is disposing of these wastes. accurate and did not give any evidence of any outstanding risk to the public, the workforce, or the environment stem- ming from the hydrolysis chemistry or the analysis of the Other Major Findings and Recommendations hydrolysate. Finding 3-1. A detailed waste analysis plan for BGCAPP has not been developed or submitted for review and approval. Recommendation 4-6. When developing transportation risk Such a plan would detail sampling and analytical methods assessments, the PMACWA should use the most current haz- for each waste stream. ardous waste assessment methodologies for characterizing the wastes generated at BGCAPP and PCAPP. Recommendation 3-1. While the Bechtel Parsons Blue Grass Team and the Program Manager for Assembled Recommendation 4-7. A site-specific transportation risk Chemical Weapons Alternatives are not in violation of assessment should be developed for all wastes that may regulatory requirements and have ample time to meet the be agent-contaminated and shipped from BGCAPP and requirement to submit a waste analysis plan for BGCAPP PCAPP. 18 months prior to receipt of munitions at the facility, it would be prudent to develop and submit the plan as early Finding 5-1. Through the Kentucky Chemical Demilitariza- as possible in order to determine the requirements that may tion Citizens’ Advisory Commission (CAC) and the CAC’s be placed on the operations by the Kentucky Department subsidiary Chemical Destruction Community Advisory of Environmental Protection and avoid unnecessary delays Board, as well as public affairs activities that include the Blue to the operation. Grass Chemical Stockpile Outreach Office and public meet- ings, the communities around the Blue Grass Army Depot Finding 4-1. The documentation for secondary waste (BGAD) have ample opportunity to learn about BGCAPP streams made available to the committee failed to identify operations as well as proposed secondary waste disposal. reverse osmosis rejectate brine, supercritical water oxidation The ACWA program and its contractors do an effective job (SCWO) filtrate solid waste, SCWO titanium tank liners, of cooperating with and supporting these organizations. venturi scrubber particulate filters, or filters from the ener- 

 Review of secondary waste disposal Planning Finding 5-2. Through the Colorado Chemical Demilitariza- vironmental review (if there is one) as well as by instigating tion Citizens’ Advisory Commission, as well as a public political action and litigation. affairs program that includes the Pueblo Chemical Stockpile Outreach Office and its field activities, the communities Recommendation 5-1. To avoid potential misunderstandings around the Pueblo Chemical Depot have ample opportunity and obstacles, the PMACWA should explain in advance, and to learn about PCAPP operations as well as proposed second- solicit feedback on, any proposals to ship wastes from BG- ary waste disposal. The ACWA program and its contractors CAPP and PCAPP. Special efforts should be made to include do an effective job of cooperating with and supporting these a diverse representation of the stakeholder communities. organizations. Recommendation 5-2. The PMACWA should explain to the Finding 5-3. Communities that might be affected by the public precisely how it plans to determine whether a particu- transportation and offsite disposal of secondary and closure lar waste stream is suitable for shipment, including analytical wastes do not at present have an official forum through which procedures for showing whether the stream contains any they can interact with the ACWA program. residual contamination by an agent or its by-products. Finding 5-4. Members of the communities around the Recommendation 6-3. The PMACWA should perform a Blue Grass Army Depot and the Pueblo Chemical Depot quantitative transportation risk assessment for hydrolysate, have not expressed serious concern about the disposition including a quantitative assessment of the human health con- of secondary wastes other than ­hydrolysate from BGCAPP sequences of hydrolysate spills with and without a fire. This and PCAPP. However, they want technical assurance that assessment needs to be completed to facilitate discussions the materials are not contaminated with agent, as defined with the public and regulators about the hydrolysate offsite by the minimum detection level, before being transported shipment alternative. offsite for reuse or disposal. Recommendation 6-5. For both BGCAPP and PCAPP, the Finding 5-5. There is substantial local opposition to offsite selection of an appropriate TSDF for the treatment of agent shipment and disposal of hydrolysate from both BGCAPP hydrolysates and other secondary wastes should take into and PCAPP. Local groups can be expected to forestall any account transportation issues, emergency response consid- such action by protracting the permitting process or the en- erations, and public and community interests.