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4
Storage of Separated Rocket Motors
THE NEED FOR STORAGE SPACE FOR SEPARATED ROCKET MOTORS
For a variety of reasons (e.g., permit restrictions and throughput capability), the
rate at which any given technology disposes of the separated rocket motors1 will probably
be lower than the rate of rocket-cutting operations in the Blue Grass Chemical Agent-
Destruction Pilot Plant (BGCAPP). Disposal of the separated rocket motors therefore has
the potential to be a limiting step in overall M55 rocket disposal. Rocket motor storage
and transportation to an eventual disposal facility (either on-site or off-site) will mitigate
the impact of the disparate processing rates, but separated rocket motor storage is a
potential and serious bottleneck that could affect the planned rate of M55 rocket-cutting
operations at BGCAPP. BGCAPP will have temporary storage for the separated rocket
motors. However, once the storage area reaches capacity, if the separated rocket motors
cannot be transported to an outside storage or disposal site at least as quickly as they are
being produced, they will accumulate at BGCAPP, and the planned rocket-cutting and
warhead-processing operations would need to be slowed or halted. The centrality of
storage of separated rocket motors is shown in Figure 4-1.
New onsite
Munitions Onsite
storage for
demilitarization building government
BGCAPP temporary separated separated rocket
disposal
rocket motor storage motors
Onsite contractor
disposal
Onsite storage and
return to BGCAPP
for disposal
Offsite disposal at Offsite disposal of at
government one or more
facility contractor sites
FIGURE 4-1 Diagram showing the importance of storage for the disposal of separated rocket motors.
Finding 4-1. The provision of adequate storage space for the separated rocket motors is
important for the overall rate of operations for M55 rocket disposal at the Blue Grass
1
See Appendix A for how the committee defines separated rocket motor.
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Chemical Agent-Destruction Pilot Plant. Rocket-cutting and warhead-processing
operations would need to be slowed or halted if the combination of storage capacity and
separated rocket motor disposal could not meet the rate at which separated rocket motors
are produced.
REQUIREMENTS FOR STORAGE OF SEPARATED ROCKET MOTORS
It is estimated that the peak processing rate of M55 rockets at BGCAPP will be 20
GB-filled rockets per hour or 24 VX-filled rockets per hour, producing 20 or 24 separated
rocket motors, respectively, per hour. Overall, BGCAPP estimates that about 3,350
separated rocket motors would be ready for disposal per month. The munitions
demilitarization building is designed for a storage capacity of 1.25 operating days.2 There
is currently no additional designated storage space for separated rocket motors at the Blue
Grass Army Depot (BGAD) apart from the planned storage area at BGCAPP.
The limited storage capacity subjects the M55 processing operations to delays if
unexpected events occur, such as a shutdown of a rocket motor disposal facility in the
event of a safety incident or transportation delay. It is important to have storage capacity
sufficient to permit continuing rocket processing at BGCAPP if upsets in the schedule of
disposal of separated rocket motors occur.
It is also necessary to meet Environmental Protection Agency (EPA) and
Kentucky requirements regarding hazardous waste storage. The separated rocket motors
are explosive hazardous waste, and Resource Conservation and Recovery Act (RCRA)
requirements regarding storage of explosive hazardous waste must be met. Once a rocket
motor is separated from the warhead, the motor must be stored in a designated hazardous
waste storage site. The planned BGCAPP storage area can serve as a hazardous waste
storage site, but accumulating hazardous waste must comply with 40 CFR 262.34, which
limits the time that explosive hazardous waste can be stored before being disposed of.
Noncompliance with EPA and Kentucky hazardous waste regulations can result in
enforcement actions and fines.
CREATING ADDITIONAL STORAGE SPACE AT THE
BLUE GRASS ARMY DEPOT
The creation of expanded new safe storage space on site at BGAD outside the
physical boundaries of the BGCAPP facility would provide greater assurance that M55
rocket processing could continue without interruption caused by limits on safe storage-
space capacity. The committee believes that it is much more likely that substantial
additional safe storage space can be created on site at BGAD than at BGCAPP.
Furthermore, safe intra-installation transportation will facilitate movement of separated
rocket motors to any newly created safe storage space at BGAD.
The requirements for additional safe storage space on site at BGAD depend on
many factors. For example, the designated hazard classification of the separated rocket
2
Ron Hawley, Plant General Manager, Bechtel Parsons Blue Grass Team, "Rocket Processing,"
presentation to the committee, March 20, 2012.
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motors will define the quantity that may be stored at a given location, the distance
required between the storage area and other activities, and additional security and siting
issues (U.S. Army, 2011). Storage of rocket motors at BGAD would need to be in
magazines site-approved for storage of Hazard Class 1 materials. The magazines would
also need to meet both RCRA hazardous waste regulations and explosive safety
requirements. The site-approved magazines would need to be designated as long-term
(180-day) RCRA explosive hazardous waste sites and be managed as such as provided in
Section 3500 of RCRA and in 40 CFR 270. (Hazard classification is discussed in more
depth in Chapter 2.)
The committee has been informed that preliminary discussions between BGCAPP
and BGAD staff indicate that magazine storage space at BGAD is limited and may
already be filled to capacity. Nonetheless, because BGAD conducts demilitarization of
waste military munitions as part of its mission, the installation may already have RCRA-
permitted magazines designated for storage of waste military munitions or other
explosive hazardous waste munition components that could be used for storage of
separated rocket motors.
Finding 4-2. The planned rocket destruction throughput at the Blue Grass Chemical
Agent-Destruction Pilot Plant may be at risk because of insufficient capacity for storage
of separated rocket motors.
Recommendation 4-1. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should secure additional space for storage of separated rocket motors. It is essential that
discussion with Blue Grass Army Depot staff concerning the option for securing such
additional space at the depot be given high priority.
If the separated rocket motors qualify as waste military munitions, an alternative
option would be to designate BGAD magazines as conditionally exempt magazines3 for
storage of waste military munitions. That would allow long-term storage as long as
quarterly monitoring of the condition of the stored materials is documented and records
of it are provided to the state. Kentucky has not adopted the Munitions Rule (see 40 CFR
266.202) and has not developed any state-specific military munitions rules. Military
munitions are regulated by the Division of Waste Management of the Kentucky
Department for Environmental Protection. Regulations for the state's RCRA hazardous
waste management, including military munitions, are provided in Title 401, Natural
Resources and Environmental Protection Cabinet, Department for Environmental
Protection, Chapters 3036 and 38 of the Kentucky Administrative Rules (KAR), with
definitions in Chapter 224 of the Kentucky Revised Statutes (KRS). The process would
thus require coordination with the Kentucky Department for Environmental Protection.
3
40 CFR 266.205(a) gives the storage requirements (and exemptions) for munitions that are
exempted from being considered RCRA hazardous waste, as set forth in 40 CFR 266.203 (3)(1). When
following or invoking these definitions and requirements the military calls the storage areas conditionally-
exempt magazines.
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Finding 4-3. If the separated rocket motors qualify as waste military munitions,
magazines could potentially be designated as conditionally exempt to allow long-term
storage of separated rocket motors.
RETURNING SEPARATED ROCKET MOTORS TO THE M55 ROCKET
STORAGE IGLOOS
One possibility for additional safe storage of separated rocket motors would
appear to be returning them to the existing M55 rocket igloos as the igloos are vacated.
However, lethal and incapacitating chemical munitions and agents (that is, chemical
surety material) are generally stored separately from conventional ammunition and
explosives. The igloos in which the M55 rockets were originally stored could not readily
be used for storage of the separated rocket motors unless appropriate explosive safety site
approvals were obtained. A new application for site approval for storing rocket motors in
the original rocket storage igloos would need to be submitted and approved by the
Department of Defense Explosive Safety Board. Approval from the Kentucky
Department for Environmental Protection would also likely be necessary. The igloos
would need to be free of contamination with chemical agents before being reused for
storing separated rocket motors. Because of the logistics of the movement of M55 rockets
out of the igloos, the turnaround time for producing separated rocket motors that need
storage, and the time necessary for obtaining site approvals, returning separated rocket
motors to igloos for storage would require much planning and coordination.
Finding 4-4. Reusing emptied M55 rocket storage igloos for storage of separated rocket
motors is a possible solution to the problem of inadequate storage space. Pursuing this
option would entail much coordination and planning and would take time.
Recommendation 4-2. If a decision is made to pursue this option, Blue Grass Chemical
Agent-Destruction Pilot Plant program staff should prepare a plan to convert the M55
rocket storage igloos to hazardous waste storage sites that are also site-approved for the
storage of explosives. The plan should include management of the transition without the
need to submit separate approval requests one igloo at a time.
PROPELLANT DEGRADATION, STABILIZER DEPLETION, AND
STORAGE RISK
It is well understood that double-base rocket propellants, such as the M28
propellant in the M55 rockets, are subject to chemical degradation that decreases their
stability in storage and increases storage risk.4 Propellant degradation is mitigated by a
chemical additive called a stabilizer, such as 2-nitrodiphenylamine, that is depleted as it
traps the reactive gases that result from propellant degradation. Stabilizer depletion in
4
Storage risk is defined in Appendix A.
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turn can lead to a risk of autoignition of the propellant. Thus, storage risk increases with
storage time. Although stabilizer depletion is known to occur in the case of M28
propellant, previous studies have estimated that the frequency of autoignition of
propellant in intact M55 rockets and the overall storage risk are very low (U.S. Army,
2002).
The storage risk may be greater in the case of separated rocket motors than intact
M55 rockets. The shipping and firing tube that contains the intact M55 rocket isolates the
rocket motor from environmental conditions. During processing at BGCAPP, the
shipping and firing tube is cut, and this exposes the separated rocket motor to
environmental factors, such as humidity and heat, more than when it is part of an
assembled M55 rocket. Humidity can accelerate chemical reactions with the nitrogen
oxide gases formed from the degrading nitrate ester. The nitrogen oxide gases accelerate
nitrocellulose decomposition and stabilizer depletion; this leads to a self-accelerating
cycle. Heat also increases the stabilizer depletion rate in the M28 propellant by increasing
the rate of nitrocellulose degradation. The storage of intact M55 rockets in their pallets
and in overpacked configurations and their ability to dissipate excess heat from the
propellant were studied in 2002. The study found no immediate risk of propellant
autoignition in these configurations (U.S. Army, 2002). However, when the rocket
motors are separated from the M55 rockets and placed in new packaging, they are in a
new configuration, and prior safe-storage assessments may not be directly applicable.
Thus, separated rocket motors may have a shorter safe-storage life than assembled M55
rockets.
Finding 4-5. Storage risk may increase more quickly in the case of separated rocket
motors than assembled M55 rockets because of the increased environmental exposure of
the separated motors. The effects of this environmental exposure on the separated rocket
motors have not been characterized.
Recommendation 4-3. The Blue Grass Chemical Agent-Destruction Pilot Plant program
staff should dispose of separated rocket motors as soon as possible, using a "first in, first
out" protocol to minimize storage time and reduce risk.
REFERENCES
U.S. Army. 2002. M55 Rocket Assessment Summary Report, July. Aberdeen Proving
Ground, Md.: U.S. Army Program Manager for Chemical Demilitarization.
U.S. Army. 2011. Ammunition and Explosives Safety Standards, Department of the
Army Pamphlet 38564, May 24. Available online at http://armypubs.army.mil/epubs
/pdf/p385_64.pdf. Last accessed May 17, 2012.
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