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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants 6 Alternative Offsite Waste Management Options The current designs for both BGCAPP and PCAPP include the capability for treating secondary wastes onsite. This reflects the initial design approach, which was to treat all contaminated or possibly contaminated hazardous wastes onsite. However, the shipment of certain secondary wastes to suitable offsite treatment, storage, and disposal facilities (TSDFs) appears to present significant advantages, such as lower investment, a smaller footprint for the facility, and a shorter time for closure. Indeed, it is anticipated that some waste streams that are not contaminated or that have been treated onsite will be sent to an appropriate TSDF for ultimate disposal. This chapter presents possible alternatives to onsite treatment of some of the largest waste streams generated during operations and closure. The committee considered only the largest waste streams for both BGCAPP and PCAPP: both agent and energetics hydrolysates,1 metal, dunnage, activated carbon, and brines generated during the operations phase and significant quantities of metal, concrete, decontamination solution, and activated carbon during closure. The total quantities of these materials (other than hydrolysates) that have been estimated to date were given in Table 4-2 for BGCAPP and Table 4-6 for PCAPP. Quantities of hydrolysates estimated to be generated at both sites are given in Table 6-1. A number of secondary waste streams, such as decontaminated personal protective equipment and aluminum filter cake, are presently expected to be shipped offsite, as discussed in Chapter 4. These wastes are similar to many industrial waste streams that are managed using offsite disposal at appropriate permitted TSDFs, including many aqueous caustic wastes that contain small amounts of organic matter. In many cases, those organics are more refractory (i.e., less amenable to destruction by oxidation) than agent or agent degradation products. Many solid waste materials with organics adsorbed on them are also managed successfully in appropriate permitted commercial TSDFs. As discussed in more detail below, it is worthwhile noting that the secondary wastes being considered here are not chemical agent or streams with significant agent, agent degradation, or other organic material concentrations. They are typically liquids with trace concentrations of organics, if any, or inert solids with no or very low levels of organics adhering to the solid, so long as the clearance criteria (e.g., waste control limits) are met. Finding 6-1. The shipment of certain secondary wastes to suitable offsite TSDFs could have significant advantages. Among these are savings in facility infrastructure and equipment costs, a smaller footprint for the facility, and a shorter time for closure. TABLE 6-1 Anticipated Quantities of Hydrolysates from BGCAPP and PCAPP Operations (gallons) Hydrolysate Type BGCAPP PCAPPa GB (sarin) 921,000 VX 166,000 H (mustard agent) 241,000 HD/HT (mustard agent) 7,160,000 GB/VX rocket energetics 4,323,266 H projectile energetics 407,862 Total 6,059,128 7,160,000 aMustard agent HD/HT hydrolysate is the only hydrolysate expected to be produced at PCAPP. Uncontaminated energetics are to be shipped offsite, and any contaminated energetics would be processed in an explosive destruction technology unit. SOURCE: Sam Hariri, lead process engineer, BGCAPP, “Process design overview for Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP),” presentation to the committee, January 23, 2008; and FOCIS, 2003. 1 As discussed in earlier chapters, energetics hydrolysate is expected to be produced only at BGCAPP. Noncontaminated energetic materials at PCAPP will be sent offsite for treatment, and any contaminated energetic materials will be treated in an explosive destruction technology unit.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants MAJOR WASTES THAT SHOULD BE CONSIDERED FOR OFFSITE DISPOSAL Agent Hydrolysates At BGCAPP, destruction of munitions containing GB-, VX-, and mustard agent H will generate three different agent hydrolysate streams over the course of the processing operations (see Table 6-1). At PCAPP, only one agent hydrolysate stream, from mustard agent treatment, is generated. All will be highly caustic and consist of two or three phases: primarily a water phase, a very small organic phase, and some mixed organic/water emulsion. In the experience of the committee, similar caustic streams containing some organic chemicals are routinely shipped by road to TSDFs following the appropriate Resource Conservation and Recovery Act (RCRA) and Department of Transportation (DOT) regulations. Shipments from Newport Chemical Agent Disposal Facility (NECDF) of VX hydrolysate and from Aberdeen Chemical Agent Disposal Facility (ABCDF) of mustard agent hydrolysate have successfully demonstrated the viability of disposing of these waste streams offsite. Energetics Hydrolysate At BGCAPP and PCAPP, energetics, which include the burster charges, fuzes, and contaminated propellants, are sent to an energetics batch hydrolyzer for treatment to 99.999 percent destruction efficiency. Because the neutralization step for the treatment of energetics is similar to that step for agent, the energetics hydrolysate will be similar to an agent hydrolysate but with a much lower residual agent concentration and some organic energetic residues. Hydrolysate produced during rocket operations may also contain some polychlorinated biphenyls (PCBs) from agent-contaminated shipping and firing tubes (see Chapter 2). If the energetics hydrolysate is to be shipped offsite, it will have to be sampled and analyzed for PCB contamination. If the hydrolysate analysis demonstrates that PCBs are present in excess of 50 ppm, BGCAPP would have to comply with Toxic Substances Control Act (TSCA) regulations, including the stipulation that further treatment of this waste take place only at an appropriate TSCA-approved disposal facility. For disposal of liquid containing between 50 ppm and 500 ppm of PCBs, the only approved disposal facilities are a TSCA-compliant incinerator, a high-efficiency boiler, or a chemical landfill (40 CFR 761.60). Activated Carbon An estimated 104,000 lb of agent-contaminated activated carbon from BGCAPP will have to be disposed of. Based on generator knowledge, there will also be a significant amount of additional noncontaminated carbon. The generated carbon waste will be treated and disposed of primarily at the end of operations. The amount of activated carbon that will have to be disposed of from PCAPP will be in excess of 100,000 lb, about 20 percent of which (based on generator knowledge) is expected to be contaminated with agent at >1 VSL. Generator knowledge in the case of activated carbon will rely on the agent-monitoring sensors located between the carbon beds through which the effluent gas streams sequentially flow. If the sensor detects breakthrough, the beds upstream and the one downstream will be considered contaminated. In industrial practice, it is most common to regenerate the carbon in place. If this is not possible because of the system configuration or for some process reason, the spent carbon is shipped to a reprocessor to regenerate the carbon. It is not possible to regenerate the spent carbon at BGCAPP or PCAPP because the offgas treatment unit design does not allow taking any of the beds out of service for regeneration. Spent activated carbon that has been contaminated with agent has been successfully shipped offsite to a permitted TSDF for disposal from several of the currently operational chemical agent disposal facilities. These shipments were made from the Anniston, Alabama, and Aberdeen, Maryland, chemical agent disposal facilities in double containers using headspace analysis to determine the suitability for shipment. The spent activated carbon generated at both BGCAPP and PCAPP will have the same contaminants as the carbon already shipped offsite from other chemical agent disposal facilities. Carbon that is not contaminated with agent can, as is standard industry practice, be shipped to a reprocessor. Concrete Concrete waste is a major waste stream during closure. An estimated 90 tons of concrete waste will be generated at BGCAPP and at least as much will be generated at PCAPP. Most of this concrete (including rebar) will not be contaminated based on the experience at Johnston Atoll Chemical Agent Disposal System, where the concrete that was scabbled from surfaces to a depth of 0.25 inch was considered contaminated. It was later found that much of this was not contaminated. At BGCAPP and PCAPP, all surfaces will be coated with an epoxy coating to minimize contamination. Therefore, it may be possible to scabble less concrete and thus generate less potentially contaminated concrete. It was also found that the concrete holds and also decomposes the agent. It will be necessary to confirm this, and the committee expects that an effort will be made to do this at sites that will undergo closure well before BGCAPP and PCAPP. If sufficient agent decomposition on concrete proves to be the case, shipment of concrete, both contaminated and noncontaminated, should become an option. The option will require some testing, as well as finding an appropriate TSDF and appropriate shipping containers. Noncontaminated concrete should be manageable just like
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants other normal construction debris, making special handling unnecessary. Metal Significant amounts of waste metal—about 660 tons at BGCAPP and significantly more at PCAPP—will be generated during closure in addition to the decontaminated munitions bodies generated during operations. In addition, metal waste will be generated as a result of maintenance operations. Small parts can be treated in the metal parts treater (MPT) at BGCAPP or the munitions treatment unit (MTU) at PCAPP without hurting operations. However, the decontamination of metal from closure operations using those units will require a great deal of cutting so that parts can fit, and this requirement may become the critical path for closure. In industrial operations, metal parts are cleaned and then recycled. For major pieces of equipment and piping, a similar approach would appear to be viable for both BGCAPP and PCAPP. Pumps and other parts that have intricate configurations will probably have to be treated in the MPT or MTU such that they will have been heated to 1000°F for at least 15 minutes before leaving engineering control. Large pieces, following industrial practice, should be decontaminated and then offered as scrap metal to an appropriate smelter or recycler, as provided for under the RCRA scrap metal exclusion provisions. Brines At BGCAPP, brines that contain salts will be produced at the rate of between 10,000 and 25,000 lb/hr depending on the particular operation. At PCAPP, salt-containing brines will be produced at the rate of about 600 lb/hr of filter cake containing 50 percent solids. Brines and brine salts are routinely disposed of offsite at all currently operating chemical agent disposal facilities. Those brines are the result of operations that are similar to those anticipated at BGCAPP and PCAPP. They are tested for the presence of agent residue, and concentrations below the method detection limit (MDL) and clearance criteria have been found. ANALYTICAL CONSIDERATIONS Certain public stakeholders have questioned the accuracy of the method for measuring residual agent in VX hydrolysate and are concerned that VX can re-form in the hydrolysate matrix. The committee believes that technical Risk Reduction Program (TRRP) activity 11 (discussed in Chapter 4 and Appendix D) shows that the cool-on-column procedure now being used does properly measure residual VX levels in properly prepared (well-mixed) samples of the hydrolysate and that VX does not re-form in the hydrolysate. There is less certainty about whether there is agent in the organic layer as a result of inadequate mixing during sampling. The purpose of the analyses of the organic layer reported in TRRP activity 11 was to characterize the main components, not to bound the concentration of VX in the organic layer per se. A low-detection-limit analysis of the organic layer for agent could resolve this issue. Finding 6-2. The amount of residual agent in the organic layer of VX hydrolysate from caustic hydrolysis is not known and is a cause of anxiety among certain members of the public even though the organic layer accounts for a very minor portion of the total liquid. Recommendation 6-1. The PMACWA should rerun bench-scale hydrolysis reactions for VX and measure residual agent and agent degradation products in the organic layer, using techniques having detection limits comparable to the limits achieved for analyses of the aqueous layer conducted during TRRP activity 11. OFFSITE DISPOSAL ISSUES Transportation Risk The potential for accidents during transportation that would impact the public and the environment is a concern of stakeholders, as discussed in Chapter 5. Hydrolysate and other wastes have so far been shipped safely over the course of the U.S. chemical stockpile disposal program. However, this remains an issue because chemical shipments can and do experience accidents. The Army continues to address this issue. In the section “Transportation Risk Assessments” in Chapter 4, it was reported that the Army’s Chemical Materials Agency (CMA) had written specific guidance for offsite shipments of selected secondary wastes from currently operating chemical agent disposal facilities. This guidance, which the Assembled Chemical Weapons Alternatives (ACWA) program expects to follow, includes the following: Risks for shipping agent contaminated wastes are effectively mitigated to acceptable levels by utilizing equipment, processes, and regulations established by the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration for over-the-road transportation and under RCRA for managing waste. Existing DOT regulations sufficiently address the agent hazard and other hazardous constituents in the majority of potential waste streams. The DOT regulations, therefore, are expected to be adequate controls for most shipments. However, sites need to ensure that major hazardous constituents are identified, evaluated, and adequately controlled. 2 2 Memorandum to U.S. Army CMA commanders, site project managers, the project manager for chemical stockpile elimination, and the project manager for non-stockpile chemical materiel, Re: Guidance for Development of
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants Sites need to consult with their site environmental office to ensure that the shipment complies with RCRA and NEPA [National Environmental Policy Act].3 The PCAPP transportation risk assessment for hydrolysate (PMACWA, 2003) quantified the risks of heavy truck accidents independent of the hydrolysate cargo. The report concluded that the risks from a hydrolysate spill would be negligible because of the low volatility. Either that assessment was a qualitative one, or the quantitative supporting analysis was not provided. It is important to provide quantitative data to calm the anxiety that can be triggered by the prospect of offsite transportation. Finding 6-3. A quantitative risk assessment is an important tool to provide insights on means to provide increased risk mitigation commensurate with the levels of residual agent contamination in offsite shipments of secondary waste. Recommendation 6-2. The PMACWA should formally require a quantitative transportation risk assessment for the shipment of secondary waste with agent contamination >1 VSL from chemical agent disposal facilities even though the Department of Transportation has no such regulation. Finding 6-4. Some members of the public and state regulators are concerned about the health risks of hydrolysate transport and believe there is a need for emergency planning along the route. Recommendation 6-3. The PMACWA should perform a quantitative transportation risk assessment for hydrolysate, including a quantitative assessment of the human health consequences of hydrolysate spills with and without a fire. This assessment needs to be completed to facilitate discussions with the public and regulators about the hydrolysate offsite shipment alternative. Recommendation 6-4. The PMACWA should prepare a prototypical emergency response plan for hydrolysate shipment, including the possibility of a fire or the occurrence of natural disasters such as floods. This plan would be the starting point for setting contractual requirements for the TSDF and the shipper. The prototype plan needs to be completed to facilitate discussions with the public and regulators about the hydrolysate offsite shipment alternative. Permit Modification Both BGCAPP and PCAPP currently have RCRA research, design, and development (RD&D) permits for the storage, treatment, and disposal of chemical agent and munitions. At this time, the permits and permit applications provide only for the onsite hydrolysate treatment units—supercritical water oxidation (SCWO) for BGCAPP and biotreatment for PCAPP. Permit modifications would have to be filed if these units were to be eliminated and hydrolysate was to be shipped offsite for further treatment and disposal. At PCAPP, the Colorado Department of Public Health and Environment (CDPHE) said that a modification to eliminate the use of the biotreatment unit and to add a loading facility for offsite hydrolysate shipments would probably be a Class 2 modification (one comment period of 6 months) or a Class 3 modification (two comment periods of longer duration).4 Such a modification would also have to be approved by Pueblo County, and a new certificate of designation (COD) would have to be issued. No operations could be initiated until the Class 2 modification is approved and the COD is issued. At BGCAPP, the Kentucky Department of Environmental Protection (KDEP) indicated that if the first-of-a-kind SCWO treatment unit is eliminated, it might deem the RD&D approach inappropriate, and in that case, BGCAPP would have to apply for and receive a standard RCRA operating permit under a Part B application (Bizzigotti et al., 2006). On the basis of discussions with state regulators, Mitretek concluded that if offsite shipment of hydrolysate is adopted, neither BGCAPP nor PCAPP would be allowed to begin operations until an appropriate TSDF had been selected and a contract for receipt of the waste was in place (Bizzigotti et al., 2006). In addition, the receiving TSDF might be required to obtain its own permit modification to treat the waste if it did not already have authority to treat this type of waste—i.e., caustic with organic phases and certain underlying constituents with land disposal restriction (LDR) standards. However, since agent-contaminated wastes generated at BGCAPP and PCAPP are only state-listed wastes in Kentucky and Colorado, respectively, out-of-state TSDFs would not be required to amend the RCRA permit granted in their state to accept those state-specific waste codes. Waste Characterizations To ship secondary hydrolysate offsite, the receiving TSDF must have a complete characterization of the waste to be received and a determination that the treatment is sufficient to meet its own permit conditions, which can include wastewater discharge, air emissions, and land disposal of treated waste residue. Hydrolysate from both BGCAPP and PCAPP will be a listed waste under state RCRA regulations. Site-Specific Plans for Shipment of Chemical Agent Contaminated Secondary Waste, from Dale Ormond, acting director, CMA, June 25, 2007, p. 2. 3 Ibid., p. 3. 4 Committee 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 In addition, it might have underlying listed hazardous waste constituents or additional hazardous characteristics that must be considered before shipment offsite for treatment and ultimate disposal.5 Finding 6-5. Hydrolysate shipments are similar to industrial chemical shipments in that characterization must be conducted, with that characterization used to ensure compliance with DOT requirements. Under the RCRA RD&D permits issued to both sites, waste may be shipped offsite only once it has met agent-related criteria set in the permit, as reflected in the state-approved waste analysis plan (WAP). PCAPP submitted a WAP with its Stage 3 permit modification that outlines the waste control limits for each secondary waste to be shipped offsite, including hydrolysate. However, the WAP has not yet been approved by the CDPHE. The CDPHE has said there are various options for offsite shipment of hydrolysate.6 These options would require destruction of the agent by hydrolysis, followed by shipment to a publicly owned treatment works or a Safe Drinking Water Act permitted underground injection control unit. They are in addition to using an appropriate TSDF. The hydrolysate would have to be manifested as a hazardous waste and accompanied by an LDR notice of constituents and a certification of agent treatment. BGCAPP has not yet developed its WAP, so there are still no proposed waste management criteria for shipment of hydrolysate offsite. It is possible that options similar to those discussed above for PCAPP could be available to BGCAPP once a management standard and release criteria are established in a state-approved WAP. Secondary wastes shipped offsite for treatment and disposal must meet any LDRs that would apply to the waste. Normally under an LDR, before a hazardous waste can be landfilled,7 it must be shown that the waste has been treated to or meets treatment standards established in the regulations (40 CFR 268). A treatment standard can be expressed as either numeric concentrations of hazardous constituents or as a required treatment technology. For hydrolysate and other secondary wastes from these facilities, the agent-related, state-listed waste code is the main waste code; however, other characteristic and underlying waste codes may also apply to this waste. As a general principle, a hazardous waste must meet all applicable treatment standards to be eligible for land disposal. For purposes of the LDRs, a generator with a listed hazardous waste must determine if the waste also exhibits any hazardous waste characteristics (Section 262.11(c)). If the listed waste also exhibits a characteristic of hazardous waste, the treatment standard for both waste codes must be met. In this case, both Kentucky and Colorado listed the wastes but did not publish any corresponding LDR treatment standards. Normally, a TSDF in the state that has so listed a waste cannot accept a waste without the appropriate LDR notification and/or certifications. However, a TSDF in another state would not require such LDR documentation for a waste listed only in Kentucky or Colorado. National Environmental Protection Act Under the National Environmental Policy Act (NEPA), both BGCAPP and PCAPP prepared and issued an environmental impact statement (EIS) covering the construction and operation of the chemical agent treatment facilities. Neither EIS nor the corresponding records of decision address offsite shipment of hydrolysate. Under NEPA regulations, if the new proposed action is not adequately covered in an existing EIS or environmental assessment, the site would have to prepare an environmental assessment, which would result in either a finding of “no significant impact” or a requirement to prepare a supplemental EIS. INDUSTRIAL PRACTICES In industry, large quantities of liquid waste having minute levels of organic and inorganic contaminants are routinely managed by shipment to and treatment at offsite TSDFs. The liquid waste is characterized by the generator in the form of a waste profile. TSDFs in turn assess their capabilities to properly treat the waste such that it meets existing regulatory requirements such as LDRs and TSDF permit provisions. The TSDFs that appear to be able to successfully treat the waste are visited and evaluated to confirm that their treatment processes meet company and local, state, and federal requirements. Once the waste is accepted by a TSDF, the TSDF is responsible for meeting regulatory and permit requirements as well as safety and emergency response needs for management of the waste to ensure minimal impact on the public. Contracts will usually call for a generator to carry out independent, periodic inspections of the TSDF to verify that contractual terms are being met. Shipments are subject to RCRA and DOT regulations on transportation, packaging, labeling, placarding, manifesting, and emergency response contact information. For chemicals that pose unique hazards to emergency responders, it is a common industrial practice to have personnel trained in emergency response available around the clock to respond to whatever emergencies might develop. Finding 6-6. A common industrial practice applicable to the safe transportation of agent hydrolysate involves having personnel available around the clock who are trained in 5 “Land disposal restrictions and PCAPP wastes,” document provided to the committee, February 19, 2008, by Douglas Knappe, CDPHE. 6 Ibid. 7 That is, placed on the land, but this also includes incineration in that the listed waste codes are attached to the ash that is ultimately disposed of to the ground.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants and knowledgeable about the hazards of the material being transported and the actions to be taken to respond to the various emergencies that would have been identified by a transportation risk assessment. In industrial practice, the generator of the hazardous waste is responsible for selecting the transporter(s) of the waste and ensuring that appropriate emergency plans are in place. This responsibility likewise extends to shipment of the secondary wastes discussed in this report. The standard operating procedures of any entity that ships hazardous wastes should include the following: Guidance for emergency response, Training of emergency response personnel, Programs for responding to transportation emergencies, Vehicle inspections and maintenance, Ensuring driver compliance with DOT requirements, and Development of contingency plans for spills. Personnel responding to emergencies need to be trained for the various emergency response scenarios, evaluated to ensure medical fitness, and supplied with necessary personnel protective equipment, as well as trained in the use of special equipment for emergencies. For offsite shipments, BGCAPP and PCAPP will need to verify that personnel designated as responders satisfy these requirements. The Emergency Response Guidebook: A Guidebook for First Responders During the Initial Phase of a Dangerous Goods/Hazardous Materials Transportation Incident,8 is used widely in industry for ensuring safe emergency response. It is very important to comply with DOT standards for driver selection, qualification, and performance; vehicle inspection, maintenance, and repair; product container selection and authorization; container and vehicle marking, labeling, and placarding; and hazardous material shipping documents. Other transportation safety enhancements include reviews of product handling, loading, and unloading procedures and evaluation of the safety programs for contract drivers. A key part of emergency response is the development of contingency plans for spills. A spill of waste liquids from BGCAPP or PCAPP may cause significant concern on the part of the community. Every effort should be made to avoid such spills, but if one occurs, it should be contained to minimize its impact on the community. To determine the potential impact of a spill, it is suggested that dispersion analyses be conducted for potential spill scenarios and the information be made available for emergency response personnel. Transportation routes should be assessed to minimize the possibility of spills into water. Spill containment equipment should be available to the emergency response teams. It is critical that spill contingency plans also consider natural disasters such as hurricanes and floods. Plans with well-defined accountability and procedures for evacuation or containment are necessary to mitigate damage. Recommendation 6-5. For both BGCAPP and PCAPP, the selection of an appropriate TSDF for the treatment of agent hydrolysates and other secondary wastes should take into account transportation issues, emergency response considerations, and public and community interests. Recommendation 6-6. The PMACWA should consider incorporating the good industrial practice of having trained emergency response personnel at BGCAPP and PCAPP available around the clock to respond to transportation accidents. PAST EXPERIENCE WITH OFFSITE DISPOSAL The Army has been disposing of secondary wastes to offsite facilities from all of the currently operating chemical agent disposal facilities and continues to do so. Of particular interest are the experience at the ABCDF in Maryland with mustard agent hydrolysate and the experience at the NECDF in Indiana with VX hydrolysate. VX hydrolysate at or below a concentration of 20 ppb VX has been successfully shipped to a commercial TSDF from the NECDF in Indiana since April 2007. The NECDF used hydrolysis technology to destroy the bulk nerve agent VX stockpile at Newport Chemical Depot. The same technology will be used at BGCAPP, but with a different reactor configuration. To satisfy Chemical Weapons Convention requirements for irreversible treatment, the Army selected Veolia Environmental Services to treat the hydrolysate from NECDF at its Port Arthur, Texas, facility. Prior to shipment, each batch was analyzed for VX and was required to be nondetect for agent with a minimum detection limit <20 ppb VX, to be nonignitable, and to contain <1 ppm EA-2192. The material was primarily caustic water with a very thin organic layer and probably some emulsified oil and water. It was sampled and analyzed directly from 4,600-gallon over-the-road shipping containers. Veolia Environmental Services is a global environmental company with a permitted facility for burning hazardous waste. Shipments of VX hydrolysate to Veolia, which started in mid-2007, have been successful and were planned to continue through August 2008. Several public interest groups expressed significant opposition to these shipments and many of their concerns are described in Chapter 5. Before deciding to ship the VX hydrolysate to Veolia, consideration was given to shipping it to the DuPont Secure Environmental Treatment (SET) facility at its Chambers Works, in Deepwater, New Jersey. Extensive studies were carried out by DuPont, the Environmental Protection Agency, and the Centers for Disease Control and Prevention. Based 8 Available at http://hazmat.dot.gov/pubs/erg/erg2008_eng.pdf. Last accessed July 17, 2008.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants on these studies, the DuPont SET facility was found to have acceptable treatment technology for VX hydrolysate from NECDF (DuPont, 2004; CDC, 2006). However, DuPont ultimately made a commercial decision not to handle this waste at the SET facility. At present, the VX hydrolysate that is expected to be produced at BGCAPP will be cleared for processing by the SCWO system at 99.9999 percent VX destruction (<160 ppb VX).9,10 Finding 6-7. It is expected that if offsite shipment to a TSDF becomes the preferred method for treating VX hydrolysate from BGCAPP, the operation of the agent neutralization reactors may have to be modified—namely, the residence time of the agent increased—to produce a stream that contains residual VX and EA2192 at concentrations less than the release criteria. Before VX hydrolysate from the NECDF was shipped offsite, 7 million gallons of mustard agent HD hydrolysate from the ABCDF in Maryland were shipped in 1,300 tank truckloads to the DuPont SET facility without incident, where they were irreversibly treated according to a common practice used by industrial chemical operations faced with similar waste disposal needs for comparable waste streams. Thus, the bulk mustard agent stockpile that had been stored at the Edgewood Area of Aberdeen Proving Ground was destroyed by sending its hydrolysate offsite. The mustard agent HD hydrolysate at ABCDF was the product of a hydrolysis procedure identical to that envisioned for PCAPP,11 where only mustard agent hydrolysate that is similar to that produced at ABCDF will be produced (see Table 6-1). As previously stated, the hydrolysate from ABCDF was safely shipped to and treated in a commercial TSDF. Present plans call for the agent hydrolysate to be treated at PCAPP in immobilized cell bioreactors. This type of biological treatment is also available in the many sewage treatment works that could receive such a stream if they had sufficient capacity available and the hydrolysate met other characteristics stipulated by the particular works. Here again, the hydrolysate would have to meet the nondetect levels for agent before leaving the engineering controls of the PCAPP facility. Hydrolysate from GB destruction has not been produced to date in operations beyond the laboratory scale, so no direct facility-scale comparison is possible. However, the GB hydrolysate from BGCAPP will, like VX hydrolysate, be primarily a caustic water solution with minor organic constituents. GB hydrolysate from BGCAPP should be amenable to shipment to and treatment by a TSDF that can manage treatment of VX hydrolysate, provided the GB hydrolysate has been properly characterized and evaluated. Spent activated carbon was shipped offsite for treatment, recovery, and/or disposal from the ABCDF after closure. All wastes generated during closure of the ABCDF were disposed of at appropriate permitted facilities. The currently operating baseline incineration disposal facilities all ship selected wastes, including brine solutions, metal that has been tested to the established waste clearance level, and spent activated carbon, to permitted offsite facilities. The knowledge generated from the experiences at formerly and currently operating chemical agent disposal facilities, as well as continued ongoing development of new technology in the analysis, sampling, and monitoring of secondary waste, has been used to develop improved methods for secondary waste handling and disposal. The offsite transportation, treatment, and disposal of agent-contaminated and noncontaminated secondary waste are currently being addressed under established programs and procedures that ensure the safety of the personnel handling the waste. Such development work and accumulated experience have a bearing on developing options for permit requirements applicable to the offsite shipment of agent hydrolysates from BGCAPP and PCAPP. Finding 6-8. The experience to date with the offsite shipment and treatment of mustard and nerve agent hydrolysates from the Aberdeen and Newport Chemical Agent Disposal Facilities indicates that offsite transportation and disposal of these materials is a safe and technically viable course of action. Recommendation 6-7. Because experience shows that offsite shipment and treatment of agent hydrolysates from BGCAPP and PCAPP is safe and technically viable, and in view of better analytical methods being developed, the PMACWA should consider this option now, before the plants are built and operating, to maximize the benefit from such a change. It is important to consider everything that would impact such a change. Finding 6-9. Spent activated carbon and other closure wastes were successfully shipped offsite from the Aberdeen Chemical Agent Disposal Facility to an appropriate TSDF for ultimate disposal. Recommendation 6-8. The shipment offsite to an appropriate permitted TSDF of all types of wastes, including spent activated carbon and closure wastes, should be examined and given serious consideration in light of past experience showing that it is a technically viable and safe method of disposing of these wastes. 9 Sam Hariri, lead process engineer, BGCAPP, “Overview of MPT and SCWO process design,” presentation to the committee, January 23, 2008. 10 A destruction efficiency of 99.9999 percent is somewhat higher than the values given; however, these values are used to ensure that the variance range in the analyses results is taken into account. 11 The toxicity of the product of mustard agent H hydrolysis at BGCAPP is not expected to differ significantly from that of mustard agent HD hydrolysate.