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.

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).

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 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