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.



The National Academies | 500 Fifth St. N.W. | Washington, D.C. 20001
Copyright © National Academy of Sciences. All rights reserved.
Terms of Use and Privacy Statement



Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.

OCR for page 5
1 introduction assemBled chemical WeaPoNs alTerNaTiVes destroyed number approximately 100,000 items, two-thirds ProGram hisTorY of which are M55 rockets. The various projectiles stored at PCD number nearly 800,000. Table 1-1 lists chemical agent Background munition types and quantities stored at BGAD; Table 1-2 lists those at PCD. In 1996, in response to local opposition to the use of The DOD’s Defense Acquisition Board issued an ac- incineration, the U.S. Congress passed Public Laws 104- quisition decision memorandum (ADM) in July 2002 that 201 and 104-208, which (1) froze funds for construction of approved neutralization (hydrolysis with water) followed chemical agent destruction pilot plants at the Pueblo Chemi- by biotreatment for full-scale pilot testing at the Pueblo site cal Depot (PCD) in Colorado and at the Blue Grass Army and directed acceleration of the destruction of the stock- Depot (BGAD) in Richmond, Kentucky; (2) required the pile.1 The record of decision (ROD) was signed on July 18, Army to demonstrate at least two alternatives to incineration 2002 (U.S. Army, 2002).2 The request for proposal (RFP) to to destroy assembled chemical weapons; (3) directed the design, build, operate, and close a chemical agent destruc- Department of Defense (DOD) to establish a new chemical tion facility at Pueblo was issued in July 2002. Although demilitarization program with a program manager who had the RFP specified that hydrolysis followed by biotreat- not been previously associated with the Army’s chemical ment was to be used in the process, the selection of all demilitarization program; and (4) required the Army to co- other unit operations was left to the RFP respondents. The ordinate these activities with the National Research Council only other requirement of the RFP was that all hazardous (NRC). This program became known as the Assembled materials were to be destroyed onsite. The system contract Chemical Weapons Assessment program and has since been was awarded to Bechtel National, Inc., in September 2002, renamed the Assembled Chemical Weapons Alternatives and work on a full-scale pilot plant design for the Pueblo (ACWA) program. Chemical Agent Destruction Pilot Plant (PCAPP) began in After an elaborate selection process in which the public December 2002.3 was extensively involved, six technologies received the grade Two of the technologies demonstrated in Demo II and of “acceptable technology,” and the Army chose three of one of those in Demo I were selected to undergo engineering them for demonstration (Demo I) of their technical viability design studies as candidates for destroying the weapons at to meet destruction objectives. Two of the three technologies Blue Grass. The Defense Acquisition Board issued an ADM were found acceptable after demonstration testing, and they on February 3, 2003, that approved neutralization (hydroly- proceeded to engineering design studies to assess their ac- ceptability for implementation to destroy the chemical stock- pile at PCD, which comprises nearly 800,000 projectiles and 1Memorandum from G.C. Aldridge, Under Secretary of Defense, to the mortar rounds filled with mustard agent. In 1999, Congress Secretary of the Army and the Program Manager, Assembled Chemical passed Public Laws 106-79 and 106-52, which required the Weapons Assessment (ACWA) program, “Disposal of the chemical weapons Army to demonstrate the remaining three technologies that stockpile at Pueblo, Colorado—acquisition decision memorandum (ADM), July 16, 2002.” had initially received the “acceptable technology” grade 2Under the National Environmental Policy Act, a final environmental (Demo II) and to consider all viable technology alternatives impact statement was issued on April 17, 2002. for destroying the chemical weapons at BGAD in Kentucky, 3PCAPP is not a pilot plant in the traditional sense of the term. Indeed, it where munitions containing both mustard agent and nerve is intended to destroy the entire stockpile of chemical agent and to perform agents are stored. At BGAD, the agents and munitions to be all associated treatments. This is also true for BGCAPP. 

OCR for page 5
 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg 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 Chemical Energetics Munition Type Fill (kg) Content (kg) Configuration 105-mm cartridge, M60 HD, 1.4 Burster: tetrytol, 0.12 Unreconfigured. Complete projectile includes fuze, Fuze: M51A5 burster. Propellant loaded with cartridge. Cartridges Propellant: M1 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 Includes propellant and ignition cartridge in a box. Propellant: M8 4.2-inch mortar, M2 HT, 2.6 Tetryl, 0.064 Includes propellant and ignition cartridge in a box. Propellant: M8 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 unit operations for the Blue Grass pilot plant was left to the (SCWO) for full-scale pilot plant testing at BGAD. An RFP RFP respondents. The Army awarded the contract to the to design, build, operate, and close a chemical agent destruc- Bechtel Parsons Blue Grass Team, a joint venture formed by tion pilot plant at Blue Grass was issued on February 7, 2003. Bechtel National, Inc., and Parsons Engineering. (The team- The ROD was signed on February 27, 2003.5 The RFP for ing subcontractors are Battelle, General Physics, General the Blue Grass Chemical Agent Destruction Pilot Plant (BG- Atomics, and the Washington Demilitarization Company.) CAPP) specified that hydrolysis followed by SCWO was to The Bechtel Parsons Blue Grass Team submitted the initial be used and that all hazardous materials were to be destroyed design to the Army on July 29, 2004 (BPBGT, 2004). onsite. As was the case for Pueblo, the selection of all other 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 4The terms “neutralization” and “hydrolysis” are often used interchange- quantities are estimates based on design. Both plants are ably in the literature on chemical agent demilitarization. Hydrolysis is the being designed and will be built based on RODs that were more appropriate term from a chemical process perspective. Neutralization promulgated in 2002 and 2003 for these first-of-a-kind dis- is more in keeping with the notion of neutralizing and thereby rendering posal facilities. Because there is much first-of-a-kind equip- innocuous. It may be found in the literature to refer to hydrolysis in either aqueous or nonaqueous media. ment, the facilities are being permitted under a research, 5Under the National Environmental Policy Act, a Final Environmental development, and demonstration (RD&D) provision of the Impact Statement was issued on December 27, 2002.

OCR for page 5
 iNTrOdUCTiON Resource Conservation and Recovery Act (RCRA), which viable without jeopardizing the safety, health, or protection allows for some flexibility through permit modifications. of workers, the public, or the environment. In continuing to At both sites, as the system is proven, a more traditional assist PMACWA as it proceeds with implementation of the RCRA permit under a Part B application will be required. ACWA project plans and schedules, the NRC has issued a At present, the plants are being permitted in stages under number of reports in recent years concerning various aspects the RD&D provision.6 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. Nrc activities Since the inception of the ACWA program in 1996, com- PUrPose oF This sTUdY mittees of the NRC have conducted a series of independent studies addressing various technical issues that have arisen as The purpose of this study is to provide PMACWA with the program has developed. These studies were conducted at a technical appraisal of its evolving plans to safely and ef- the request of the PMACWA and, along with other informa- ficiently handle, treat, and ultimately dispose of the waste tion, were used by PMACWA staff to make decisions on the materials that remain following the destruction of the as- direction of the program. During the technology selection sembled chemical weapons stored at PCD (Colorado) and phase of the program, they involved technical reviews of the BGAD (Kentucky). candidate technologies. These were followed by reports on These waste materials, termed secondary wastes, pose the demonstration testing that evaluated critical data on the a significant planning challenge in regard to considerations efficacy of specific processes. such as the operational parameters that process equipment After several technology providers had been selected must satisfy, the storage capacity needed for the materials, that offered alternative technology packages that satisfied and whether offsite disposal is advisable. These consider- the ACWA criteria for a total solution capable of completely ations in turn affect how long and in what manner the facil- destroying assembled chemical weapons, the NRC was ity will need to be operated, including the amount of time asked to perform in-depth reviews of the data, analyses, and needed for closure. results of testing that had been developed. Together, this In view of the effect that the disposition of secondary information comprised the engineering design studies for wastes has on facility operations, and recognizing the strong destruction facilities planned for the Pueblo, Colorado, and interest by the public that these materials be safely and re- Blue Grass (Richmond), Kentucky, sites. The NRC commit- sponsibly managed, PMACWA has requested that an NRC tee produced its analyses of the engineering design studies, committee review the current state of its planning in this one for the Pueblo facility (NRC, 2001) and one for the Blue regard and provide appropriate guidance and commentary Grass facility (NRC, 2002a). on options to be considered, including what may be accept- Shortly thereafter, PMACWA awarded contracts to able to regulators and the public and how comparable waste system contractors chosen to design, construct, operate, and materials are dealt with in commercial industrial operations. close first-of-a-kind chemical agent destruction pilot plants The statement of task given for the Committee to Review at the PCD and the BGAD. In 2005, yet another NRC com- Secondary Waste Disposal and Regulatory Requirements mittee issued interim design assessment reports, one for for the Assembled Chemical Weapons Alternatives Program PCAPP (NRC, 2005a) and one for BGCAPP (NRC, 2005b). is as follows: These reports were issued with the intent that PMACWA The NRC will conduct an examination of the environmen- could benefit from the committee’s assessment before the tal, regulatory and permit requirements that chemical agent pilot plant facility designs were finalized. disposal facilities (CDFs) are subject to, on a federal and In the years since then, the ACWA program has experi- state basis, concerning the treatment, storage, and/or han- enced changes largely attributable to budgetary constraints dling and shipping of secondary wastes (chemical agent placed on it by Congress. One of the changes has been the and non-agent related). Building on the current design plans departure from an absolute commitment to facility designs for the Blue Grass Chemical Agent Destruction Pilot Plant that have been termed “total solutions,” meaning that all (BGCAPP) and the Pueblo Chemical Agent Destruction Pi- lot Plant (PCAPP), as well as the recently completed study waste streams from munitions destruction would be com- on Chemical Materials Agency secondary waste disposal, pletely treated onsite. Instead, in recent years, there has the NRC will compare the requirements for CDFs to those been a recognition that more economical options may be of similar facilities in industry that also treat, store, and/or handle and ship secondary wastes, with particular emphasis on industrial best practices. 6Information gained in the course of site visits by committee subgroups to the pertinent state regulators: Kentucky Department of Environmental The comparison with industry practices includes, but is not Protection (KDEP), Frankfort, Kentucky, January 24, 2008, and Colorado limited to the following areas: Department of Public Health and Environment (CDPHE), Denver, Colorado, February 14, 2008.

OCR for page 5
 reView Of SeCONdAry wASTe diSPOSAL PLANNiNg • he degree of characterization necessary for secondary The nature of the secondary waste determines the op- t waste (chemical agent and non-agent) produced during tions for its processing and disposalspecifically, whether the stockpile disposal and/or storage operations, which is or not it is contaminated and how it is categorized ac- treated on-site or handled and shipped off-site for further cording to RCRA regulations. In addition, the concerns of treatment or disposal; members of the surrounding communities about disposal of • dentify additional studies that might be required to i the secondary waste that will be generated at BGCAPP and confirm if commercial Treatment, Storage and Disposal PCAPP will also influence the waste treatment decisions by Facilities can handle secondary waste from BGCAPP or PMACWA. PCAPP; • ecommended procedures and techniques to address r public (including environmental justice) and regulatory metrics on degree of agent contamination issues; • amifications and limitations of existing environmental In the past, the Army had a system for classifying wastes r permits including chemical demilitarization permit restric- as clean or contaminated that was based on the treatment the tions that do not exist in commercial/industrial permits; waste stream received. It now uses airborne exposure limits • he extent and number of health risk and transportation t (AELs), a measurement devised by the Centers for Disease risk assessments deemed necessary; Control and Prevention and incorporated into the waste con- • riteria being considered for shipment of agent contami- c trol limits (WCLs) that have been established in connection nated wastes for final treatment/disposal; and with treatment conditions of the wastes to determine the • acility closure requirements. f status of the wastes: “agent-contaminated” or “clean,” an approach used in this study as well. For agent-contaminated secoNdarY WasTe aT acWa chemical aGeNT waste materials that cannot be characterized by extraction desTrUcTioN PiloT PlaNTs procedures, the WCL is defined in terms of a vapor screen- ing level (VSL). Materials having agent contamination defining secondary Waste <1 VSL meet the WCL criteria. The VSL concentrations are equivalent to the short-term limit values used at other This study examines the wastes expected to be generated chemical agent disposal facilities.7 For agent-contaminated by the two ACWA program facilities that have yet to be built, materials that can be characterized by extraction procedures, BGCAPP and PCAPP. PCAPP will be processing munitions the WCL values of 20 ppb for VX and GB and 200 ppb for containing mustard blistering agent (in HD and HT forms), mustard agent have been adopted by some facilities. The while the BGCAPP will process munitions containing values were originally derived from Army chemical agent mustard agent H and nerve agents GB and VX, including regulations for workforce drinking water standards (NRC, M55 rockets having nerve agent fills. To distinguish clearly 2007). It is worthwhile noting that WCLs are implemented between these waste munitions and the wastes generated in terms of target release levels, which are in general some- during the process of their disposal, in this study, all wastes what lower than the WCLs to account for variability in the that ultimately leave the plant are considered “secondary degree of analytical precision. Target release levels have wastes.” Wastes that are generated during the processing not been set for BGCAPP and remain a high priority in the operations and are further treated in the pilot plant facility overall job of completing the waste analysis plan (WAP) are considered “process waste streams” and are considered required by RCRA.8 in this study only if they may be considered suitable for ul- timate disposal without further in-process treatment. This is consistent with an earlier NRC report, review of Chemical definition of “Generator Knowledge” Agent Secondary waste disposal and regulatory require- Like other industrial waste, secondary wastes from ments, which examined secondary waste issues at U.S. Army chemical agent disposal facilities are either hazardous or chemical agent disposal facilities other than BGCAPP and nonhazardous. A particular waste is classified into one or PCAPP that are currently in operation (NRC, 2007). the other of these categories by laboratory analysis or by It is certain that a significant quantity of secondary waste “generator knowledge” of the material’s source, use, and will be generated over the operational and closure lifetime of history of exposure. BGCAPP and PCAPP. The time, effort, and resources needed “Generator knowledge” is a hazardous waste evaluation to deal with the secondary waste will be substantial, and its method commonly accepted and defined by the Environmen- 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, 7The VSL and short-term limit values are as follows: GB, 0.0001 mg/m 3; and opportunities may exist for cost savings or for schedule VX, 0.00001 mg/m3; mustard agent, 0.003 mg/m3 (NRC, 2007). acceleration if other disposal options become applicable to 8John Barton, chief scientist, and Kevin Regan, environmental manager, BGCAPP, “Current waste analysis and certification,” presentation to the certain secondary waste streams. committee, January 24, 2008.

OCR for page 5
 iNTrOdUCTiON tal Protection Agency and individual states (EPA, 2005). It is the amounts and conditions of secondary waste generated, based in most cases on (1) a facility process flow diagram or state approvals, the availability of appropriate disposal sites, narrative description of the process generating the waste or and the like. (2) the chemical makeup of all ingredients or materials used The committee recognized that although plans for as- in the process that generates the waste. See Appendix B for sembled chemical weapons destruction at the Blue Grass additional information on the use of generator knowledge. 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. Waste management Planning For example, BGAD stores a wider variety of agents and The regulatory requirements governing the management munition types than does PCD. Moreover, the processes by of wastes generated at chemical agent disposal facilities which these agents and munitions will be destroyed have (and other industrial facility operations) require that a WAP both commonalities and differences. With this in mind, the be submitted before operations begin. The WAP provides committee determined that it would address the technical detailed information on all streams and proposed sampling issues from the perspectives of the individual sites, keeping and analytical methodologies. Such a plan is available for in mind that there may be programmatic aspects that would PCAPP9 and was submitted to the Colorado Department of be pertinent to both sites. Chapter 2 examines technical Public Health and the Environment (CDPHE). However, al- considerations related to the BGCAPP and PCAPP designs though it had not yet been approved as this report was being as presently configured, with emphasis on the generation of written, it did serve as an important source for the analysis waste streams. of the PCAPP situation in this study. Because no WAP was Chapter 3 describes the regulatory framework for the available for BGCAPP, other information had to be used to management and disposal of secondary waste at BGCAPP develop the committee’s analysis. 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 sTUdY meThodoloGY aNd rePorT designs for BGCAPP and PCAPP, plans and options for orGaNizaTioN disposal of these waste streams, and a review of certain prac- There are both advantages and disadvantages involved tices that are typically used in industrial waste management in addressing the generation, handling, and treatment of situations. In addition to being generated during operations, secondary waste at yet-to-be-constructed facilities using secondary waste will also be generated during facility clo- first-of-a-kind equipment and processes that have yet to be sure, and this also is briefly discussed. fully integrated into the overall processes of an operational The proper management of wastes from chemical agent facility. The advantage is that by examining the issues associ- disposal facilities is a matter of interest to the surrounding ated with secondary waste at this early juncture, technical, communities and other segments of the public. The structure regulatory, and public acceptance matters can be deliberated of public participation for each site is described in Chapter with sufficient time for adjustment and implementation. The 5, where issues of concern to public stakeholders and the disadvantage is the gaps in informationsome plans are still perspectives of their representatives are also examined. evolving and some data are still to be generatedand the Chapter 6 presents alternatives to current waste manage- uncertainties surrounding such things as public perceptions, ment plans for each site that PMACWA may wish to consider, including offsite disposal of several major waste streams. 9See Section C of PMACWA, 2006.