pilot plants are full-scale facilities that face all of the normal state permitting requirements that any industrial facility must comply with in terms of dealing with effluents and waste streams. Since these general requirements are reasonably standard, this report focuses on the unique aspects of monitoring for chemical agent contamination.


The various waste streams generated at BGCAPP and PCAPP can be classified as primary or secondary:

•  Primary waste streams. Those encountered in conducting primary operations for disposal (e.g., explosives removed and agent drained from munitions) that are treated on-site, and

•  Secondary waste streams. Those generated by activities either in support of or downstream of the primary processes for agent and energetics destruction—for example, activated carbon, used demilitarization protective ensemble (DPE) suits, dunnage, and so on that ultimately leave the facility. These wastes include additional materials produced during facility closure such as demolished concrete.

The characterization of the expected secondary wastes from the Pueblo and Blue Grass facilities and the planning for their disposal were described in detail in NRC, 2008a. The purpose of that study was 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 and BGAD” (p. 7). In the course of preparing the present report, the ACWA Monitoring Committee received additional information on this subject.1

A general overview of the waste monitoring plan for PCAPP is shown in Figure 3-1, which itemizes the planned processes and corresponding analytical monitoring and sampling methods. A corresponding diagram for BGCAPP was unavailable to the committee, but the committee believes the PCAPP plan is reasonably illustrative and representative for the purpose of this report. The analytical methods are categorized by the primary process from which they originate and further identified by the type of sample and key measurement parameter.

In the case of generator knowledge, sampling is not needed if there was no opportunity for agent contamination to have occurred based on the Army’s criteria shown in Box 2-1. In other cases, headspace samples are taken after the waste is bagged or tented and allowed to equilibrate. The sample is then taken from the vapor space above the waste within the tented area, as described in the next section. In most cases, the methods are derived from standard EPA methods; however, some methods were


1This includes a presentation to the committee by Gary Groenewold, a member of the Committee to Review Secondary Waste Disposal and Regulatory Requirements for the Assembled Chemical Weapons Alternatives Program, “Sources and Amounts of Agent-Contaminated Wastes,” on February 23, 2011, and information provided by ACWA staff in response to committee questions or communications during site visits.

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