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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
1
Introduction
ASSEMBLED CHEMICAL WEAPONS ALTERNATIVES PROGRAM HISTORY
Background
In 1996, in response to local opposition to the use of incineration, the U.S. Congress passed Public Laws 104-201 and 104-208, which (1) froze funds for construction of chemical agent destruction pilot plants at the Pueblo Chemical Depot (PCD) in Colorado and at the Blue Grass Army Depot (BGAD) in Richmond, Kentucky; (2) required the Army to demonstrate at least two alternatives to incineration to destroy assembled chemical weapons; (3) directed the Department of Defense (DOD) to establish a new chemical demilitarization program with a program manager who had not been previously associated with the Army’s chemical demilitarization program; and (4) required the Army to coordinate these activities with the National Research Council (NRC). This program became known as the Assembled Chemical Weapons Assessment program and has since been renamed the Assembled Chemical Weapons Alternatives (ACWA) program.
After an elaborate selection process in which the public was extensively involved, six technologies received the grade of “acceptable technology,” and the Army chose three of them for demonstration (Demo I) of their technical viability to meet destruction objectives. Two of the three technologies were found acceptable after demonstration testing, and they proceeded to engineering design studies to assess their acceptability for implementation to destroy the chemical stockpile at PCD, which comprises nearly 800,000 projectiles and mortar rounds filled with mustard agent. In 1999, Congress passed Public Laws 106-79 and 106-52, which required the Army to demonstrate the remaining three technologies that had initially received the “acceptable technology” grade (Demo II) and to consider all viable technology alternatives for destroying the chemical weapons at BGAD in Kentucky, where munitions containing both mustard agent and nerve agents are stored. At BGAD, the agents and munitions to be destroyed number approximately 100,000 items, two-thirds of which are M55 rockets. The various projectiles stored at PCD number nearly 800,000. Table 1-1 lists chemical agent munition types and quantities stored at BGAD; Table 1-2 lists those at PCD.
The DOD’s Defense Acquisition Board issued an acquisition decision memorandum (ADM) in July 2002 that approved neutralization (hydrolysis with water) followed by biotreatment for full-scale pilot testing at the Pueblo site and directed acceleration of the destruction of the stockpile.1 The record of decision (ROD) was signed on July 18, 2002 (U.S. Army, 2002).2 The request for proposal (RFP) to design, build, operate, and close a chemical agent destruction facility at Pueblo was issued in July 2002. Although the RFP specified that hydrolysis followed by biotreatment was to be used in the process, the selection of all other unit operations was left to the RFP respondents. The only other requirement of the RFP was that all hazardous materials were to be destroyed onsite. The system contract was awarded to Bechtel National, Inc., in September 2002, and work on a full-scale pilot plant design for the Pueblo Chemical Agent Destruction Pilot Plant (PCAPP) began in December 2002.3
Two of the technologies demonstrated in Demo II and one of those in Demo I were selected to undergo engineering design studies as candidates for destroying the weapons at Blue Grass. The Defense Acquisition Board issued an ADM on February 3, 2003, that approved neutralization (hydroly-
1
Memorandum from G.C. Aldridge, Under Secretary of Defense, to the Secretary of the Army and the Program Manager, Assembled Chemical Weapons Assessment (ACWA) program, “Disposal of the chemical weapons stockpile at Pueblo, Colorado—acquisition decision memorandum (ADM), July 16, 2002.”
2
Under the National Environmental Policy Act, a final environmental impact statement was issued on April 17, 2002.
3
PCAPP is not a pilot plant in the traditional sense of the term. Indeed, it is intended to destroy the entire stockpile of chemical agent and to perform all associated treatments. This is also true for BGCAPP.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
TABLE 1-1 Description of the Chemical Weapons in the BGAD Stockpile
Munition Type
Chemical Fill (lb)
Energetics Content (lb)
155-mm projectile, M110
H, 11.7
Tetrytol, 0.41
8-inch projectile, M426
GB, 14.4
None
115-mm rocket, M55
GB, 10.7
Composition B, 3.2
M28 propellant, 19.1
115-mm rocket warhead, M56
GB, 10.7
Composition B, 3.2
155-mm projectile, M121/A1
VX, 6
None
115-mm rocket, M55
VX, 10.1
Composition B, 3.2
M28 propellant, 19.1
115-mm rocket warhead, M56
VX, 10.1
Composition B, 3.2
SOURCE: Adapted from data provided to PMACWA on the Munition Items Disposition Action System (MIDAS) by the MIDAS team in July 1997.
TABLE 1-2 Chemical Weapons Stockpile of HD- or HT-Filled Munitions at PCD
Munition Type
Chemical Fill (kg)
Energetics Content (kg)
Configuration
105-mm cartridge, M60
HD, 1.4
Burster: tetrytol, 0.12
Fuze: M51A5
Propellant: M1
Unreconfigured. Complete projectile includes fuze, burster. Propellant loaded with cartridge. Cartridges packed two per wooden box.
105-mm cartridge, M60
HD, 1.4
Tetrytol, 0.12
Reconfigured. Includes burster and nose plug, but no propellant or fuze. Repacked on pallets.
155-mm projectile, M110
HD, 5.3
Tetrytol, 0.19
Includes lifting plug and burster but no fuze. On pallets.
155-mm projectile, M104
HD, 5.3
Tetrytol, 0.19
Includes lifting plug and burster but no fuze. On pallets.
4.2-inch mortar, M2A1
HD, 2.7
Tetryl, 0.064
Propellant: M8
Includes propellant and ignition cartridge in a box.
4.2-inch mortar, M2
HT, 2.6
Tetryl, 0.064
Propellant: M8
Includes propellant and ignition cartridge in a box.
NOTES: The terms “unreconfigured” and “reconfigured” are defined in the column labeled “Configuration.” The M1 propellant present in 105-mm cartridges that have not been reconfigured is present in M67 propelling charges—that is, granular propellant contained in bags as specified in MIL-DTL-60318C.
SOURCE: Adapted from BPT, 2004.
sis with caustic)4 followed by supercritical water oxidation (SCWO) for full-scale pilot plant testing at BGAD. An RFP to design, build, operate, and close a chemical agent destruction pilot plant at Blue Grass was issued on February 7, 2003. The ROD was signed on February 27, 2003.5 The RFP for the Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP) specified that hydrolysis followed by SCWO was to be used and that all hazardous materials were to be destroyed onsite. As was the case for Pueblo, the selection of all other unit operations for the Blue Grass pilot plant was left to the RFP respondents. The Army awarded the contract to the Bechtel Parsons Blue Grass Team, a joint venture formed by Bechtel National, Inc., and Parsons Engineering. (The teaming subcontractors are Battelle, General Physics, General Atomics, and the Washington Demilitarization Company.) The Bechtel Parsons Blue Grass Team submitted the initial design to the Army on July 29, 2004 (BPBGT, 2004).
Both BGCAPP and PCAPP are in the final stages of design, and some infrastructure is in the construction phase. Thus, while the waste types are well established, the quantities are estimates based on design. Both plants are being designed and will be built based on RODs that were promulgated in 2002 and 2003 for these first-of-a-kind disposal facilities. Because there is much first-of-a-kind equipment, the facilities are being permitted under a research, development, and demonstration (RD&D) provision of the
4
The terms “neutralization” and “hydrolysis” are often used interchangeably in the literature on chemical agent demilitarization. Hydrolysis is the more appropriate term from a chemical process perspective. Neutralization is more in keeping with the notion of neutralizing and thereby rendering innocuous. It may be found in the literature to refer to hydrolysis in either aqueous or nonaqueous media.
5
Under the National Environmental Policy Act, a Final Environmental Impact Statement was issued on December 27, 2002.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
Resource Conservation and Recovery Act (RCRA), which allows for some flexibility through permit modifications. At both sites, as the system is proven, a more traditional RCRA permit under a Part B application will be required. At present, the plants are being permitted in stages under the RD&D provision.6
NRC Activities
Since the inception of the ACWA program in 1996, committees of the NRC have conducted a series of independent studies addressing various technical issues that have arisen as the program has developed. These studies were conducted at the request of the PMACWA and, along with other information, were used by PMACWA staff to make decisions on the direction of the program. During the technology selection phase of the program, they involved technical reviews of the candidate technologies. These were followed by reports on the demonstration testing that evaluated critical data on the efficacy of specific processes.
After several technology providers had been selected that offered alternative technology packages that satisfied the ACWA criteria for a total solution capable of completely destroying assembled chemical weapons, the NRC was asked to perform in-depth reviews of the data, analyses, and results of testing that had been developed. Together, this information comprised the engineering design studies for destruction facilities planned for the Pueblo, Colorado, and Blue Grass (Richmond), Kentucky, sites. The NRC committee produced its analyses of the engineering design studies, one for the Pueblo facility (NRC, 2001) and one for the Blue Grass facility (NRC, 2002a).
Shortly thereafter, PMACWA awarded contracts to system contractors chosen to design, construct, operate, and close first-of-a-kind chemical agent destruction pilot plants at the PCD and the BGAD. In 2005, yet another NRC committee issued interim design assessment reports, one for PCAPP (NRC, 2005a) and one for BGCAPP (NRC, 2005b). These reports were issued with the intent that PMACWA could benefit from the committee’s assessment before the pilot plant facility designs were finalized.
In the years since then, the ACWA program has experienced changes largely attributable to budgetary constraints placed on it by Congress. One of the changes has been the departure from an absolute commitment to facility designs that have been termed “total solutions,” meaning that all waste streams from munitions destruction would be completely treated onsite. Instead, in recent years, there has been a recognition that more economical options may be viable without jeopardizing the safety, health, or protection of workers, the public, or the environment. In continuing to assist PMACWA as it proceeds with implementation of the ACWA project plans and schedules, the NRC has issued a number of reports in recent years concerning various aspects and revisions to the original designs put forth by the systems contractors for each site. A complete list of NRC reports on the ACWA program appears in Appendix A.
PURPOSE OF THIS STUDY
The purpose of this study is to provide PMACWA with a technical appraisal of its evolving plans to safely and efficiently handle, treat, and ultimately dispose of the waste materials that remain following the destruction of the assembled chemical weapons stored at PCD (Colorado) and BGAD (Kentucky).
These waste materials, termed secondary wastes, pose a significant planning challenge in regard to considerations such as the operational parameters that process equipment must satisfy, the storage capacity needed for the materials, and whether offsite disposal is advisable. These considerations in turn affect how long and in what manner the facility will need to be operated, including the amount of time needed for closure.
In view of the effect that the disposition of secondary wastes has on facility operations, and recognizing the strong interest by the public that these materials be safely and responsibly managed, PMACWA has requested that an NRC committee review the current state of its planning in this regard and provide appropriate guidance and commentary on options to be considered, including what may be acceptable to regulators and the public and how comparable waste materials are dealt with in commercial industrial operations. The statement of task given for the Committee to Review Secondary Waste Disposal and Regulatory Requirements for the Assembled Chemical Weapons Alternatives Program is as follows:
The NRC will conduct an examination of the environmental, regulatory and permit requirements that chemical agent disposal facilities (CDFs) are subject to, on a federal and state basis, concerning the treatment, storage, and/or handling and shipping of secondary wastes (chemical agent and non-agent related). Building on the current design plans for the Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP) and the Pueblo Chemical Agent Destruction Pilot Plant (PCAPP), as well as the recently completed study on Chemical Materials Agency secondary waste disposal, the NRC will compare the requirements for CDFs to those of similar facilities in industry that also treat, store, and/or handle and ship secondary wastes, with particular emphasis on industrial best practices.
The comparison with industry practices includes, but is not limited to the following areas:
6
Information gained in the course of site visits by committee subgroups to the pertinent state regulators: Kentucky Department of Environmental Protection (KDEP), Frankfort, Kentucky, January 24, 2008, and Colorado Department of Public Health and Environment (CDPHE), Denver, Colorado, February 14, 2008.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
the degree of characterization necessary for secondary waste (chemical agent and non-agent) produced during the stockpile disposal and/or storage operations, which is treated on-site or handled and shipped off-site for further treatment or disposal;
identify additional studies that might be required to confirm if commercial Treatment, Storage and Disposal Facilities can handle secondary waste from BGCAPP or PCAPP;
recommended procedures and techniques to address public (including environmental justice) and regulatory issues;
ramifications and limitations of existing environmental permits including chemical demilitarization permit restrictions that do not exist in commercial/industrial permits;
the extent and number of health risk and transportation risk assessments deemed necessary;
criteria being considered for shipment of agent contaminated wastes for final treatment/disposal; and
facility closure requirements.
SECONDARY WASTE AT ACWA CHEMICAL AGENT DESTRUCTION PILOT PLANTS
Defining Secondary Waste
This study examines the wastes expected to be generated by the two ACWA program facilities that have yet to be built, BGCAPP and PCAPP. PCAPP will be processing munitions containing mustard blistering agent (in HD and HT forms), while the BGCAPP will process munitions containing mustard agent H and nerve agents GB and VX, including M55 rockets having nerve agent fills. To distinguish clearly between these waste munitions and the wastes generated during the process of their disposal, in this study, all wastes that ultimately leave the plant are considered “secondary wastes.” Wastes that are generated during the processing operations and are further treated in the pilot plant facility are considered “process waste streams” and are considered in this study only if they may be considered suitable for ultimate disposal without further in-process treatment. This is consistent with an earlier NRC report, Review of Chemical Agent Secondary Waste Disposal and Regulatory Requirements, which examined secondary waste issues at U.S. Army chemical agent disposal facilities other than BGCAPP and PCAPP that are currently in operation (NRC, 2007). It is certain that a significant quantity of secondary waste will be generated over the operational and closure lifetime of BGCAPP and PCAPP. The time, effort, and resources needed to deal with the secondary waste will be substantial, and its handling can become a subject of public debate or criticism concerning the operation of the pilot plants. The catchall term “secondary waste” encompasses many different waste forms, and opportunities may exist for cost savings or for schedule acceleration if other disposal options become applicable to certain secondary waste streams.
The nature of the secondary waste determines the options for its processing and disposal—specifically, whether or not it is contaminated and how it is categorized according to RCRA regulations. In addition, the concerns of members of the surrounding communities about disposal of the secondary waste that will be generated at BGCAPP and PCAPP will also influence the waste treatment decisions by PMACWA.
Metrics on Degree of Agent Contamination
In the past, the Army had a system for classifying wastes as clean or contaminated that was based on the treatment the waste stream received. It now uses airborne exposure limits (AELs), a measurement devised by the Centers for Disease Control and Prevention and incorporated into the waste control limits (WCLs) that have been established in connection with treatment conditions of the wastes to determine the status of the wastes: “agent-contaminated” or “clean,” an approach used in this study as well. For agent-contaminated waste materials that cannot be characterized by extraction procedures, the WCL is defined in terms of a vapor screening level (VSL). Materials having agent contamination <1 VSL meet the WCL criteria. The VSL concentrations are equivalent to the short-term limit values used at other chemical agent disposal facilities.7 For agent-contaminated materials that can be characterized by extraction procedures, the WCL values of 20 ppb for VX and GB and 200 ppb for mustard agent have been adopted by some facilities. The values were originally derived from Army chemical agent regulations for workforce drinking water standards (NRC, 2007). It is worthwhile noting that WCLs are implemented in terms of target release levels, which are in general somewhat lower than the WCLs to account for variability in the degree of analytical precision. Target release levels have not been set for BGCAPP and remain a high priority in the overall job of completing the waste analysis plan (WAP) required by RCRA.8
Definition of “Generator Knowledge”
Like other industrial waste, secondary wastes from chemical agent disposal facilities are either hazardous or nonhazardous. A particular waste is classified into one or the other of these categories by laboratory analysis or by “generator knowledge” of the material’s source, use, and history of exposure.
“Generator knowledge” is a hazardous waste evaluation method commonly accepted and defined by the Environmen-
7
The VSL and short-term limit values are as follows: GB, 0.0001 mg/m3; VX, 0.00001 mg/m3; mustard agent, 0.003 mg/m3 (NRC, 2007).
8
John Barton, chief scientist, and Kevin Regan, environmental manager, BGCAPP, “Current waste analysis and certification,” presentation to the committee, January 24, 2008.
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Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
tal Protection Agency and individual states (EPA, 2005). It is based in most cases on (1) a facility process flow diagram or narrative description of the process generating the waste or (2) the chemical makeup of all ingredients or materials used in the process that generates the waste. See Appendix B for additional information on the use of generator knowledge.
Waste Management Planning
The regulatory requirements governing the management of wastes generated at chemical agent disposal facilities (and other industrial facility operations) require that a WAP be submitted before operations begin. The WAP provides detailed information on all streams and proposed sampling and analytical methodologies. Such a plan is available for PCAPP9 and was submitted to the Colorado Department of Public Health and the Environment (CDPHE). However, although it had not yet been approved as this report was being written, it did serve as an important source for the analysis of the PCAPP situation in this study. Because no WAP was available for BGCAPP, other information had to be used to develop the committee’s analysis.
STUDY METHODOLOGY AND REPORT ORGANIZATION
There are both advantages and disadvantages involved in addressing the generation, handling, and treatment of secondary waste at yet-to-be-constructed facilities using first-of-a-kind equipment and processes that have yet to be fully integrated into the overall processes of an operational facility. The advantage is that by examining the issues associated with secondary waste at this early juncture, technical, regulatory, and public acceptance matters can be deliberated with sufficient time for adjustment and implementation. The disadvantage is the gaps in information—some plans are still evolving and some data are still to be generated—and the uncertainties surrounding such things as public perceptions, the amounts and conditions of secondary waste generated, state approvals, the availability of appropriate disposal sites, and the like.
The committee recognized that although plans for assembled chemical weapons destruction at the Blue Grass and Pueblo sites have many features in common, there are also factors that make decisions on the management and disposition of secondary waste singular for each site. For example, BGAD stores a wider variety of agents and munition types than does PCD. Moreover, the processes by which these agents and munitions will be destroyed have both commonalities and differences. With this in mind, the committee determined that it would address the technical issues from the perspectives of the individual sites, keeping in mind that there may be programmatic aspects that would be pertinent to both sites. Chapter 2 examines technical considerations related to the BGCAPP and PCAPP designs as presently configured, with emphasis on the generation of waste streams.
Chapter 3 describes the regulatory framework for the management and disposal of secondary waste at BGCAPP and PCAPP. Chapter 4 presents the committee’s review and analysis of the estimated quantities of the various secondary waste streams expected to be generated from the current designs for BGCAPP and PCAPP, plans and options for disposal of these waste streams, and a review of certain practices that are typically used in industrial waste management situations. In addition to being generated during operations, secondary waste will also be generated during facility closure, and this also is briefly discussed.
The proper management of wastes from chemical agent disposal facilities is a matter of interest to the surrounding communities and other segments of the public. The structure of public participation for each site is described in Chapter 5, where issues of concern to public stakeholders and the perspectives of their representatives are also examined.
Chapter 6 presents alternatives to current waste management plans for each site that PMACWA may wish to consider, including offsite disposal of several major waste streams.
9
See Section C of PMACWA, 2006.