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

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2Ron Hawley, Plant General Manager, Bechtel Parsons Blue Grass Team, “Rocket Processing,” presentation to the committee, March 20, 2012.



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