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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6 alternative offsite Waste management options organics adsorbed on them are also managed successfully in The current designs for both BGCAPP and PCAPP appropriate permitted commercial TSDFs. include the capability for treating secondary wastes onsite. As discussed in more detail below, it is worthwhile This reflects the initial design approach, which was to treat noting that the secondary wastes being considered here are all contaminated or possibly contaminated hazardous wastes not chemical agent or streams with significant agent, agent onsite. However, the shipment of certain secondary wastes degradation, or other organic material concentrations. They to suitable offsite treatment, storage, and disposal facilities are typically liquids with trace concentrations of organics, (TSDFs) appears to present significant advantages, such as if any, or inert solids with no or very low levels of organics lower investment, a smaller footprint for the facility, and a adhering to the solid, so long as the clearance criteria (e.g., shorter time for closure. Indeed, it is anticipated that some waste control limits) are met. waste streams that are not contaminated or that have been treated onsite will be sent to an appropriate TSDF for ulti- Finding 6-1. The shipment of certain secondary wastes to mate disposal. This chapter presents possible alternatives to suitable offsite TSDFs could have significant advantages. onsite treatment of some of the largest waste streams gener- Among these are savings in facility infrastructure and equip- ated during operations and closure. ment costs, a smaller footprint for the facility, and a shorter The committee considered only the largest waste time for closure. streams for both BGCAPP and PCAPP: both agent and en- ergetics 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 TABLE 6-1 Anticipated Quantities of Hydrolysates from to date were given in Table 4-2 for BGCAPP and Table 4-6 BGCAPP and PCAPP Operations (gallons) for PCAPP. Quantities of hydrolysates estimated to be gener- ated at both sites are given in Table 6-1. PCAPPa Hydrolysate Type BGCAPP A number of secondary waste streams, such as decon- GB (sarin) 921,000 taminated personal protective equipment and aluminum VX 166,000 filter cake, are presently expected to be shipped offsite, as H (mustard agent) 241,000 discussed in Chapter 4. These wastes are similar to many HD/HT (mustard agent) 7,160,000 industrial waste streams that are managed using offsite GB/VX rocket energetics 4,323,266 disposal at appropriate permitted TSDFs, including many H projectile energetics 407,862 Total 6,059,128 7,160,000 aqueous caustic wastes that contain small amounts of organic matter. In many cases, those organics are more refractory aMustard agent HD/HT hydrolysate is the only hydrolysate expected to (i.e., less amenable to destruction by oxidation) than agent or be produced at PCAPP. Uncontaminated energetics are to be shipped off- site, and any contaminated energetics would be processed in an explosive agent degradation products. Many solid waste materials with destruction technology unit. SOURCE: Sam Hariri, lead process engineer, BGCAPP, “Process de- 1As discussed in earlier chapters, energetics hydrolysate is expected to be sign overview for Blue Grass Chemical Agent Destruction Pilot Plant produced only at BGCAPP. Noncontaminated energetic materials at PCAPP (BGCAPP),” presentation to the committee, January 23, 2008; and FOCIS, will be sent offsite for treatment, and any contaminated energetic materials 2003. will be treated in an explosive destruction technology unit. 

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 ALTerNATiVe OffSiTe wASTe mANAgemeNT OPTiONS major WasTes ThaT shoUld Be coNsidered operations. The amount of activated carbon that will have to For oFFsiTe disPosal 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 agent hydrolysates knowledge in the case of activated carbon will rely on the At BGCAPP, destruction of munitions containing GB-, agent-monitoring sensors located between the carbon beds VX-, and mustard agent H will generate three different agent through which the effluent gas streams sequentially flow. If hydrolysate streams over the course of the processing opera- the sensor detects breakthrough, the beds upstream and the tions (see Table 6-1). At PCAPP, only one agent hydrolysate one downstream will be considered contaminated. stream, from mustard agent treatment, is generated. All will In industrial practice, it is most common to regener- be highly caustic and consist of two or three phases: pri- ate the carbon in place. If this is not possible because of marily a water phase, a very small organic phase, and some the system configuration or for some process reason, the mixed organic/water emulsion. In the experience of the spent carbon is shipped to a reprocessor to regenerate the committee, similar caustic streams containing some organic carbon. It is not possible to regenerate the spent carbon chemicals are routinely shipped by road to TSDFs following at BGCAPP or PCAPP because the offgas treatment unit the appropriate Resource Conservation and Recovery Act design does not allow taking any of the beds out of service (RCRA) and Department of Transportation (DOT) regula- for regeneration. tions. Shipments from Newport Chemical Agent Disposal Spent activated carbon that has been contaminated with Facility (NECDF) of VX hydrolysate and from Aberdeen agent has been successfully shipped offsite to a permitted Chemical Agent Disposal Facility (ABCDF) of mustard TSDF for disposal from several of the currently operational agent hydrolysate have successfully demonstrated the vi- chemical agent disposal facilities. These shipments were ability of disposing of these waste streams offsite. made from the Anniston, Alabama, and Aberdeen, Maryland, chemical agent disposal facilities in double containers using headspace analysis to determine the suitability for shipment. energetics hydrolysate The spent activated carbon generated at both BGCAPP At BGCAPP and PCAPP, energetics, which include the and PCAPP will have the same contaminants as the carbon burster charges, fuzes, and contaminated propellants, are sent already shipped offsite from other chemical agent disposal to an energetics batch hydrolyzer for treatment to 99.999 facilities. percent destruction efficiency. Because the neutralization Carbon that is not contaminated with agent can, as is step for the treatment of energetics is similar to that step for standard industry practice, be shipped to a reprocessor. agent, the energetics hydrolysate will be similar to an agent hydrolysate but with a much lower residual agent concen- concrete tration and some organic energetic residues. Hydrolysate produced during rocket operations may also contain some Concrete waste is a major waste stream during closure. polychlorinated biphenyls (PCBs) from agent-contaminated An estimated 90 tons of concrete waste will be generated at shipping and firing tubes (see Chapter 2). If the energetics BGCAPP and at least as much will be generated at PCAPP. hydrolysate is to be shipped offsite, it will have to be sampled Most of this concrete (including rebar) will not be contami- and analyzed for PCB contamination. If the hydrolysate nated based on the experience at Johnston Atoll Chemical analysis demonstrates that PCBs are present in excess of 50 Agent Disposal System, where the concrete that was scab- ppm, BGCAPP would have to comply with Toxic Substances bled from surfaces to a depth of 0.25 inch was considered Control Act (TSCA) regulations, including the stipulation contaminated. It was later found that much of this was not that further treatment of this waste take place only at an ap- contaminated. At BGCAPP and PCAPP, all surfaces will be propriate TSCA-approved disposal facility. For disposal of coated with an epoxy coating to minimize contamination. liquid containing between 50 ppm and 500 ppm of PCBs, Therefore, it may be possible to scabble less concrete and the only approved disposal facilities are a TSCA-compliant thus generate less potentially contaminated concrete. It was incinerator, a high-efficiency boiler, or a chemical landfill also found that the concrete holds and also decomposes the (40 CFR 761.60). agent. It will be necessary to confirm this, and the commit- tee expects that an effort will be made to do this at sites that will undergo closure well before BGCAPP and PCAPP. If activated carbon sufficient agent decomposition on concrete proves to be the case, shipment of concrete, both contaminated and noncon- An estimated 104,000 lb of agent-contaminated activated taminated, should become an option. carbon from BGCAPP will have to be disposed of. Based on The option will require some testing, as well as finding generator knowledge, there will also be a significant amount an appropriate TSDF and appropriate shipping containers. of additional noncontaminated carbon. The generated carbon Noncontaminated concrete should be manageable just like waste will be treated and disposed of primarily at the end of

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg other normal construction debris, making special handling TRRP activity 11 was to characterize the main components, unnecessary. 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. metal Finding 6-2. The amount of residual agent in the organic Significant amounts of waste metalabout 660 tons at BGCAPP and significantly more at PCAPPwill be gener- layer of VX hydrolysate from caustic hydrolysis is not ated during closure in addition to the decontaminated muni- known and is a cause of anxiety among certain members of tions bodies generated during operations. In addition, metal the public even though the organic layer accounts for a very waste will be generated as a result of maintenance operations. minor portion of the total liquid. Small parts can be treated in the metal parts treater (MPT) at Recommendation 6-1. The PMACWA should rerun bench- BGCAPP or the munitions treatment unit (MTU) at PCAPP without hurting operations. However, the decontamination of scale hydrolysis reactions for VX and measure residual agent metal from closure operations using those units will require a and agent degradation products in the organic layer, using great deal of cutting so that parts can fit, and this requirement techniques having detection limits comparable to the limits may become the critical path for closure. In industrial opera- achieved for analyses of the aqueous layer conducted during tions, metal parts are cleaned and then recycled. For major TRRP activity 11. pieces of equipment and piping, a similar approach would appear to be viable for both BGCAPP and PCAPP. Pumps oFFsiTe disPosal issUes and other parts that have intricate configurations will prob- ably have to be treated in the MPT or MTU such that they Transportation risk will have been heated to 1000°F for at least 15 minutes before leaving engineering control. Large pieces, following indus- The potential for accidents during transportation that trial practice, should be decontaminated and then offered as would impact the public and the environment is a concern scrap metal to an appropriate smelter or recycler, as provided of stakeholders, as discussed in Chapter 5. Hydrolysate and for under the RCRA scrap metal exclusion provisions. other wastes have so far been shipped safely over the course of the U.S. chemical stockpile disposal program. However, Brines this remains an issue because chemical shipments can and do experience accidents. The Army continues to address At BGCAPP, brines that contain salts will be produced this issue. at the rate of between 10,000 and 25,000 lb/hr depending on In the section “Transportation Risk Assessments” in the particular operation. At PCAPP, salt-containing brines Chapter 4, it was reported that the Army’s Chemical Materi- will be produced at the rate of about 600 lb/hr of filter cake als Agency (CMA) had written specific guidance for offsite containing 50 percent solids. Brines and brine salts are rou- shipments of selected secondary wastes from currently oper- tinely disposed of offsite at all currently operating chemical ating chemical agent disposal facilities. This guidance, which agent disposal facilities. Those brines are the result of opera- the Assembled Chemical Weapons Alternatives (ACWA) tions that are similar to those anticipated at BGCAPP and program expects to follow, includes the following: PCAPP. They are tested for the presence of agent residue, and concentrations below the method detection limit (MDL) Risks for shipping agent contaminated wastes are effectively and clearance criteria have been found. mitigated to acceptable levels by utilizing equipment, pro- cesses, and regulations established by the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials aNalYTical coNsideraTioNs Safety Administration for over-the-road transportation and Certain public stakeholders have questioned the ac- under RCRA for managing waste. Existing DOT regulations sufficiently address the agent hazard and other hazardous curacy of the method for measuring residual agent in VX constituents in the majority of potential waste streams. The hydrolysate and are concerned that VX can re-form in the DOT regulations, therefore, are expected to be adequate hydrolysate matrix. The committee believes that technical controls for most shipments. However, sites need to ensure Risk Reduction Program (TRRP) activity 11 (discussed in that major hazardous constituents are identified, evaluated, Chapter 4 and Appendix D) shows that the cool-on-column and adequately controlled. 2 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. 2Memorandum to U.S. Army CMA commanders, site project managers, There is less certainty about whether there is agent in the or- the project manager for chemical stockpile elimination, and the project man- ganic layer as a result of inadequate mixing during sampling. ager for non-stockpile chemical materiel, Re: Guidance for Development of The purpose of the analyses of the organic layer reported in

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 ALTerNATiVe OffSiTe wASTe mANAgemeNT OPTiONS the storage, treatment, and disposal of chemical agent and Sites need to consult with their site environmental office to ensure that the shipment complies with RCRA and NEPA munitions. At this time, the permits and permit applica- [National Environmental Policy Act].3 tions provide only for the onsite hydrolysate treatment unitssupercritical water oxidation (SCWO) for BGCAPP The PCAPP transportation risk assessment for hydroly- and biotreatment for PCAPP. Permit modifications would sate (PMACWA, 2003) quantified the risks of heavy truck have to be filed if these units were to be eliminated and accidents independent of the hydrolysate cargo. The report hydrolysate was to be shipped offsite for further treatment concluded that the risks from a hydrolysate spill would be and disposal. negligible because of the low volatility. Either that assess- At PCAPP, the Colorado Department of Public Health ment was a qualitative one, or the quantitative supporting and Environment (CDPHE) said that a modification to elimi- analysis was not provided. It is important to provide quan- nate the use of the biotreatment unit and to add a loading titative data to calm the anxiety that can be triggered by the facility for offsite hydrolysate shipments would probably be prospect of offsite transportation. a Class 2 modification (one comment period of 6 months) or a Class 3 modification (two comment periods of longer Finding 6-3. A quantitative risk assessment is an important duration).4 Such a modification would also have to be ap- tool to provide insights on means to provide increased risk proved by Pueblo County, and a new certificate of designa- mitigation commensurate with the levels of residual agent tion (COD) would have to be issued. No operations could contamination in offsite shipments of secondary waste. be initiated until the Class 2 modification is approved and the COD is issued. Recommendation 6-2. The PMACWA should formally At BGCAPP, the Kentucky Department of Environmen- require a quantitative transportation risk assessment for the tal Protection (KDEP) indicated that if the first-of-a-kind shipment of secondary waste with agent contamination >1 SCWO treatment unit is eliminated, it might deem the RD&D VSL from chemical agent disposal facilities even though the approach inappropriate, and in that case, BGCAPP would Department of Transportation has no such regulation. have to apply for and receive a standard RCRA operating permit under a Part B application (Bizzigotti et al., 2006). Finding 6-4. Some members of the public and state regu- On the basis of discussions with state regulators, Mi- lators are concerned about the health risks of hydrolysate tretek concluded that if offsite shipment of hydrolysate is transport and believe there is a need for emergency planning adopted, neither BGCAPP nor PCAPP would be allowed along the route. to begin operations until an appropriate TSDF had been selected and a contract for receipt of the waste was in place Recommendation 6-3. The PMACWA should perform a (Bizzigotti et al., 2006). quantitative transportation risk assessment for hydrolysate, In addition, the receiving TSDF might be required to including a quantitative assessment of the human health con- obtain its own permit modification to treat the waste if it sequences of hydrolysate spills with and without a fire. This did not already have authority to treat this type of waste assessment needs to be completed to facilitate discussions i.e., caustic with organic phases and certain underlying with the public and regulators about the hydrolysate offsite constituents with land disposal restriction (LDR) standards. shipment alternative. However, since agent-contaminated wastes generated at BGCAPP and PCAPP are only state-listed wastes in Ken- Recommendation 6-4. The PMACWA should prepare a tucky and Colorado, respectively, out-of-state TSDFs would prototypical emergency response plan for hydrolysate ship- not be required to amend the RCRA permit granted in their ment, including the possibility of a fire or the occurrence of state to accept those state-specific waste codes. natural disasters such as floods. This plan would be the start- ing point for setting contractual requirements for the TSDF Waste characterizations and the shipper. The prototype plan needs to be completed to facilitate discussions with the public and regulators about To ship secondary hydrolysate offsite, the receiving the hydrolysate offsite shipment alternative. TSDF must have a complete characterization of the waste to be received and a determination that the treatment is suf- ficient to meet its own permit conditions, which can include Permit modification wastewater discharge, air emissions, and land disposal of Both BGCAPP and PCAPP currently have RCRA treated waste residue. Hydrolysate from both BGCAPP and research, design, and development (RD&D) permits for PCAPP will be a listed waste under state RCRA regulations. Site-Specific Plans for Shipment of Chemical Agent Contaminated Second- 4Committee fact-finding meeting with the CDPHE, Denver, Colo., ary Waste, from Dale Ormond, acting director, CMA, June 25, 2007, p. 2. 3Ibid., p. 3. February 14, 2008.

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0 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg In addition, it might have underlying listed hazardous waste characteristics (Section 262.11(c)). If the listed waste also constituents or additional hazardous characteristics that must exhibits a characteristic of hazardous waste, the treatment be considered before shipment offsite for treatment and standard for both waste codes must be met. In this case, both ultimate disposal.5 Kentucky and Colorado listed the wastes but did not publish any corresponding LDR treatment standards. Normally, a Finding 6-5. Hydrolysate shipments are similar to industrial TSDF in the state that has so listed a waste cannot accept chemical shipments in that characterization must be con- a waste without the appropriate LDR notification and/or ducted, with that characterization used to ensure compliance certifications. However, a TSDF in another state would not with DOT requirements. require such LDR documentation for a waste listed only in Kentucky or Colorado. Under the RCRA RD&D permits issued to both sites, waste may be shipped offsite only once it has met agent- National environmental Protection act related criteria set in the permit, as reflected in the state- approved waste analysis plan (WAP). PCAPP submitted a Under the National Environmental Policy Act (NEPA), WAP with its Stage 3 permit modification that outlines the both BGCAPP and PCAPP prepared and issued an environ- waste control limits for each secondary waste to be shipped mental impact statement (EIS) covering the construction and offsite, including hydrolysate. However, the WAP has not yet operation of the chemical agent treatment facilities. Neither been approved by the CDPHE. EIS nor the corresponding records of decision address offsite The CDPHE has said there are various options for offsite shipment of hydrolysate. Under NEPA regulations, if the new shipment of hydrolysate.6 These options would require de- proposed action is not adequately covered in an existing EIS struction of the agent by hydrolysis, followed by shipment to or environmental assessment, the site would have to prepare a publicly owned treatment works or a Safe Drinking Water an environmental assessment, which would result in either a Act permitted underground injection control unit. They are finding of “no significant impact” or a requirement to prepare in addition to using an appropriate TSDF. The hydrolysate a supplemental EIS. would have to be manifested as a hazardous waste and ac- companied by an LDR notice of constituents and a certifica- iNdUsTrial PracTices tion of agent treatment. BGCAPP has not yet developed its WAP, so there are In industry, large quantities of liquid waste having still no proposed waste management criteria for shipment of minute levels of organic and inorganic contaminants are hydrolysate offsite. It is possible that options similar to those routinely managed by shipment to and treatment at offsite discussed above for PCAPP could be available to BGCAPP TSDFs. The liquid waste is characterized by the generator once a management standard and release criteria are estab- in the form of a waste profile. TSDFs in turn assess their lished in a state-approved WAP. capabilities to properly treat the waste such that it meets Secondary wastes shipped offsite for treatment and dis- existing regulatory requirements such as LDRs and TSDF posal must meet any LDRs that would apply to the waste. permit provisions. The TSDFs that appear to be able to suc- Normally under an LDR, before a hazardous waste can be cessfully treat the waste are visited and evaluated to confirm landfilled,7 it must be shown that the waste has been treated that their treatment processes meet company and local, state, to or meets treatment standards established in the regula- and federal requirements. tions (40 CFR 268). A treatment standard can be expressed Once the waste is accepted by a TSDF, the TSDF is re- as either numeric concentrations of hazardous constituents sponsible for meeting regulatory and permit requirements as or as a required treatment technology. well as safety and emergency response needs for management For hydrolysate and other secondary wastes from these of the waste to ensure minimal impact on the public. Contracts facilities, the agent-related, state-listed waste code is the will usually call for a generator to carry out independent, main waste code; however, other characteristic and underly- periodic inspections of the TSDF to verify that contractual ing waste codes may also apply to this waste. As a general terms are being met. Shipments are subject to RCRA and DOT principle, a hazardous waste must meet all applicable treat- regulations on transportation, packaging, labeling, placarding, ment standards to be eligible for land disposal. For purposes manifesting, and emergency response contact information. For of the LDRs, a generator with a listed hazardous waste must chemicals that pose unique hazards to emergency responders, determine if the waste also exhibits any hazardous waste it is a common industrial practice to have personnel trained in emergency response available around the clock to respond to 5 “Land whatever emergencies might develop. disposal restrictions and PCAPP wastes,” document provided to the committee, February 19, 2008, by Douglas Knappe, CDPHE. 6Ibid. Finding 6-6. A common industrial practice applicable to 7That is, placed on the land, but this also includes incineration in that the safe transportation of agent hydrolysate involves hav- the listed waste codes are attached to the ash that is ultimately disposed of ing personnel available around the clock who are trained in to the ground.

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 ALTerNATiVe OffSiTe wASTe mANAgemeNT OPTiONS It is critical that spill contingency plans also consider and knowledgeable about the hazards of the material being natural disasters such as hurricanes and floods. Plans with transported and the actions to be taken to respond to the well-defined accountability and procedures for evacuation or various emergencies that would have been identified by a containment are necessary to mitigate damage. transportation risk assessment. Recommendation 6-5. For both BGCAPP and PCAPP, the In industrial practice, the generator of the hazardous selection of an appropriate TSDF for the treatment of agent waste is responsible for selecting the transporter(s) of the hydrolysates and other secondary wastes should take into waste and ensuring that appropriate emergency plans are in account transportation issues, emergency response consid- place. This responsibility likewise extends to shipment of the erations, and public and community interests. secondary wastes discussed in this report. The standard operating procedures of any entity that Recommendation 6-6. The PMACWA should consider ships hazardous wastes should include the following: incorporating the good industrial practice of having trained • emergency response personnel at BGCAPP and PCAPP Guidance for emergency response, • available around the clock to respond to transportation Training of emergency response personnel, • accidents. Programs for responding to transportation emergencies, • Vehicle inspections and maintenance, • Ensuring driver compliance with DOT requirements, PasT eXPerieNce WiTh oFFsiTe disPosal and • Development of contingency plans for spills. 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 Personnel responding to emergencies need to be trained interest are the experience at the ABCDF in Maryland with for the various emergency response scenarios, evaluated to mustard agent hydrolysate and the experience at the NECDF ensure medical fitness, and supplied with necessary personnel in Indiana with VX hydrolysate. protective equipment, as well as trained in the use of special VX hydrolysate at or below a concentration of 20 ppb equipment for emergencies. For offsite shipments, BGCAPP VX has been successfully shipped to a commercial TSDF and PCAPP will need to verify that personnel designated from the NECDF in Indiana since April 2007. The NECDF as responders satisfy these requirements. The emergency used hydrolysis technology to destroy the bulk nerve agent response guidebook: A guidebook for first responders VX stockpile at Newport Chemical Depot. The same tech- during the initial Phase of a dangerous goods/hazardous materials Transportation incident,8 is used widely in indus- nology will be used at BGCAPP, but with a different reactor configuration. To satisfy Chemical Weapons Convention try for ensuring safe emergency response. requirements for irreversible treatment, the Army selected It is very important to comply with DOT standards for Veolia Environmental Services to treat the hydrolysate from driver selection, qualification, and performance; vehicle in- NECDF at its Port Arthur, Texas, facility. Prior to shipment, spection, maintenance, and repair; product container selection each batch was analyzed for VX and was required to be and authorization; container and vehicle marking, labeling, nondetect for agent with a minimum detection limit <20 ppb and placarding; and hazardous material shipping documents. VX, to be nonignitable, and to contain <1 ppm EA-2192. Other transportation safety enhancements include reviews The material was primarily caustic water with a very thin of product handling, loading, and unloading procedures and organic layer and probably some emulsified oil and water. It evaluation of the safety programs for contract drivers. was sampled and analyzed directly from 4,600-gallon over- A key part of emergency response is the development the-road shipping containers. of contingency plans for spills. A spill of waste liquids from Veolia Environmental Services is a global environmen- BGCAPP or PCAPP may cause significant concern on the tal company with a permitted facility for burning hazardous part of the community. Every effort should be made to avoid waste. Shipments of VX hydrolysate to Veolia, which started such spills, but if one occurs, it should be contained to mini- in mid-2007, have been successful and were planned to con- mize its impact on the community. To determine the potential tinue through August 2008. Several public interest groups impact of a spill, it is suggested that dispersion analyses be expressed significant opposition to these shipments and conducted for potential spill scenarios and the information be many of their concerns are described in Chapter 5. made available for emergency response personnel. Transpor- Before deciding to ship the VX hydrolysate to Veolia, tation routes should be assessed to minimize the possibility consideration was given to shipping it to the DuPont Secure of spills into water. Spill containment equipment should be Environmental Treatment (SET) facility at its Chambers available to the emergency response teams. Works, in Deepwater, New Jersey. Extensive studies were carried out by DuPont, the Environmental Protection Agency, 8Available at http://hazmat.dot.gov/pubs/erg/erg2008_eng.pdf. Last ac- and the Centers for Disease Control and Prevention. Based cessed July 17, 2008.

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 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg on these studies, the DuPont SET facility was found to have uents. GB hydrolysate from BGCAPP should be amenable acceptable treatment technology for VX hydrolysate from to shipment to and treatment by a TSDF that can manage NECDF (DuPont, 2004; CDC, 2006). However, DuPont treatment of VX hydrolysate, provided the GB hydrolysate ultimately made a commercial decision not to handle this has been properly characterized and evaluated. waste at the SET facility. At present, the VX hydrolysate Spent activated carbon was shipped offsite for treatment, that is expected to be produced at BGCAPP will be cleared recovery, and/or disposal from the ABCDF after closure. for processing by the SCWO system at 99.9999 percent VX All wastes generated during closure of the ABCDF were destruction (<160 ppb VX).9,10 disposed of at appropriate permitted facilities. The currently operating baseline incineration disposal facilities all ship se- Finding 6-7. It is expected that if offsite shipment to a TSDF lected wastes, including brine solutions, metal that has been becomes the preferred method for treating VX hydrolysate tested to the established waste clearance level, and spent from BGCAPP, the operation of the agent neutralization activated carbon, to permitted offsite facilities. reactors may have to be modifiednamely, the residence The knowledge generated from the experiences at time of the agent increasedto produce a stream that con- formerly and currently operating chemical agent disposal tains residual VX and EA2192 at concentrations less than facilities, as well as continued ongoing development of new the release criteria. technology in the analysis, sampling, and monitoring of secondary waste, has been used to develop improved meth- Before VX hydrolysate from the NECDF was shipped ods for secondary waste handling and disposal. The offsite offsite, 7 million gallons of mustard agent HD hydrolysate transportation, treatment, and disposal of agent-contami- from the ABCDF in Maryland were shipped in 1,300 tank nated and noncontaminated secondary waste are currently truckloads to the DuPont SET facility without incident, being addressed under established programs and procedures where they were irreversibly treated according to a common that ensure the safety of the personnel handling the waste. practice used by industrial chemical operations faced with Such development work and accumulated experience have similar waste disposal needs for comparable waste streams. a bearing on developing options for permit requirements ap- Thus, the bulk mustard agent stockpile that had been stored plicable to the offsite shipment of agent hydrolysates from at the Edgewood Area of Aberdeen Proving Ground was BGCAPP and PCAPP. destroyed by sending its hydrolysate offsite. Finding 6-8. The experience to date with the offsite shipment The mustard agent HD hydrolysate at ABCDF was the product of a hydrolysis procedure identical to that envisioned and treatment of mustard and nerve agent hydrolysates from for PCAPP,11 where only mustard agent hydrolysate that is the Aberdeen and Newport Chemical Agent Disposal Facili- similar to that produced at ABCDF will be produced (see ties indicates that offsite transportation and disposal of these Table 6-1). As previously stated, the hydrolysate from ABCDF materials is a safe and technically viable course of action. was safely shipped to and treated in a commercial TSDF. Pres- Recommendation 6-7. Because experience shows that ent plans call for the agent hydrolysate to be treated at PCAPP in immobilized cell bioreactors. This type of biological treat- offsite shipment and treatment of agent hydrolysates from ment is also available in the many sewage treatment works BGCAPP and PCAPP is safe and technically viable, and that could receive such a stream if they had sufficient capac- in view of better analytical methods being developed, the ity available and the hydrolysate met other characteristics PMACWA should consider this option now, before the plants stipulated by the particular works. Here again, the hydrolysate are built and operating, to maximize the benefit from such would have to meet the nondetect levels for agent before leav- a change. It is important to consider everything that would ing the engineering controls of the PCAPP facility. impact such a change. Hydrolysate from GB destruction has not been produced Finding 6-9. Spent activated carbon and other closure to date in operations beyond the laboratory scale, so no di- rect facility-scale comparison is possible. However, the GB wastes were successfully shipped offsite from the Aberdeen hydrolysate from BGCAPP will, like VX hydrolysate, be Chemical Agent Disposal Facility to an appropriate TSDF primarily a caustic water solution with minor organic constit- for ultimate disposal. Recommendation 6-8. The shipment offsite to an appropri- 9Sam Hariri, lead process engineer, BGCAPP, “Overview of MPT and ate permitted TSDF of all types of wastes, including spent SCWO process design,” presentation to the committee, January 23, 2008. activated carbon and closure wastes, should be examined 10A destruction efficiency of 99.9999 percent is somewhat higher than and given serious consideration in light of past experience the values given; however, these values are used to ensure that the variance showing that it is a technically viable and safe method of range in the analyses results is taken into account. 11The toxicity of the product of mustard agent H hydrolysis at BGCAPP disposing of these wastes. is not expected to differ significantly from that of mustard agent HD hydrolysate.