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 30–36 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.

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340 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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