5

Options for Disposal of Separated Rocket Motors

In view of the various considerations and disposal technologies and their advantages and disadvantages, discussed in previous chapters, a variety of possible options exist for the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) and the Blue Grass Army Depot (BGAD) to dispose of rocket motors separated from the M55 rockets stored at BGAD. These options, which fall into two main groups, were evaluated by the committee:

  • On-site disposal options,

–   Open burning of the propellant grain at the BGAD permitted explosive hazardous waste treatment facility,

–   Using the D-100 chamber currently at BGAD,

–   Disposal using alternative technologies (technologies not currently resident at BGAD) that can be added to BGAD capabilities,

–   Disposal at the BGCAPP facility after completion of all chemical agent destruction operations, and

  • Off-site disposal options.

The committee envisions that the separated rocket motors would be removed from the shipping and firing tubes (SFTs) before the motors are disposed of, in part because the SFTs contain polychlorinated biphenyls (PCBs). The issue of PCBs is discussed in more detail below.

ON-SITE1DISPOSAL OPTIONS

Open Burning of Propellant Grain at the BGAD Permitted Facility

If the SFT and the rocket motor case can be cut such that the propellant grain could be readily removed from the rocket motor case, open burning of the propellant is an

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1In this report, the committee is using on-site to indicate disposal not at BGCAPP but at the BGAD facility.



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5 Options for Disposal of Separated Rocket Motors In view of the various considerations and disposal technologies and their advantages and disadvantages, discussed in previous chapters, a variety of possible options exist for the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) and the Blue Grass Army Depot (BGAD) to dispose of rocket motors separated from the M55 rockets stored at BGAD. These options, which fall into two main groups, were evaluated by the committee: On-site disposal options, Open burning of the propellant grain at the BGAD permitted explosive hazardous waste treatment facility, Using the D-100 chamber currently at BGAD, Disposal using alternative technologies (technologies not currently resident at BGAD) that can be added to BGAD capabilities, Disposal at the BGCAPP facility after completion of all chemical agent destruction operations, and Off-site disposal options. The committee envisions that the separated rocket motors would be removed from the shipping and firing tubes (SFTs) before the motors are disposed of, in part because the SFTs contain polychlorinated biphenyls (PCBs). The issue of PCBs is discussed in more detail below. ON-SITE1 DISPOSAL OPTIONS Open Burning of Propellant Grain at the BGAD Permitted Facility If the SFT and the rocket motor case can be cut such that the propellant grain could be readily removed from the rocket motor case, open burning of the propellant is an 1 In this report, the committee is using on-site to indicate disposal not at BGCAPP but at the BGAD facility. 47

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option.2 The BGAD open burning/open detonation site is currently operating under an interim status permit that allows treatment of 6 million pounds net explosive weight per year for the whole site. Open-burn pans are site-approved for 6,000 lb per event. So if 200 M55 rockets were cut each day, each with a propellant weight of about 20 lb, BGAD could carry out one 4,000-lb event every day and keep up with the pace of rocket motor accumulation (weather and other workload permitting). A proposal with some engineering design would be needed to test out base plate removal and propellant grain extraction. Standard operating procedures (SOPs) or SOP modifications would need to be written and approved for removal of the M28 propellant and the M62 rocket motor igniter assembly. Since the M28 grain contains lead stearate, the environmental office would need to ensure that lead emissions remain within the permitted levels for their current air pathway hazards assessment for the amount of propellant to be burned. Although BGAD already has a Resource Conservation and Recovery Act (RCRA) Subpart X permit to dispose of waste energetics, the levels of lead in the M28 propellant grain could restrict the throughput of separated rocket motors. The open burning of the propellant grain option would have the following advantages: There would be no need to modify the existing permit or apply for a new one, provided lead releases do not exceed permitted levels; If open-burning operations could keep pace with rocket cutting operations at BGCAPP, the need for a large volume of long-term storage would be eliminated; SOPs are in place for open burning, though a modified SOP might be needed for open burning of the M28 propellant grain; There would be a significant reduction in the risk of endangerment by eliminating the long-term storage of a hazardous material of unknown stability; The steel case could be readily inspected, the removal of all energetic materials verified, and the case certified as safe for recycling; The inert components could be accumulated for subsequent bulk disposal; During thermal destruction, deflagration (burning) of a confined energetic material could lead to an explosion or a transition to detonation. Removal of the propellant grain from the steel case would eliminate the tight confinement of the energetic material during thermal destruction; and If the M28 propellant was removed before thermal treatment, the concern about lead contamination of the metal components would be eliminated and metal components could be readily demilitarized and recycled as processed scrap metal. The disadvantages of this option would include these: 2 Robotics strategies that have been developed for other conventional ordnance items could be applied if the propellant does not easily slide out. Sandia National Laboratories has developed such strategies. 48

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The removal of the propellant grain would entail greater handling of the separated rocket motors than a disposal option that disposed of the propellant grain while it was still within the motor case. Lead would be released into the local environment in the form of fine particulate matter. Over the course of treating 70,000 M55 rocket motors, the total potential quantity of lead released would exceed 3 tons. This might require the Kentucky Department for Environmental Protection (KDEP) to set constraints on treatment schedules to minimize the impact on the local population and the environment. The lead releases could restrict throughput of motors to fewer than the number that could be achieved based on net explosive weight limits. BGAD currently disposes of conventional ordnance under the Program Manager for Demilitarization. The rocket motor disposal workload would need to be synchronized with already existing open-burning commitments. Finding 5-1. The Blue Grass Army Depot has a permitted, operational open-burning site that might be capable of meeting separated rocket motor disposal requirements. Recommendation 5-1. If the option to burn the M28 propellant grain in the open is investigated, the Blue Grass Chemical Agent-Destruction Pilot Plant program staff should consult the Blue Grass Army Depot on its workload and determine if the open- burning unit could be available and easily scheduled for M28 propellant grain disposal. Recommendation 5-2. Blue Grass Chemical Agent-Destruction Pilot Plant program staff should request an engineering design proposal for safely removing the M28 propellant grain from the rocket motor case to determine if the open-burning demilitarization option would be practical to implement. Use of the Existing D-100 Detonation Chamber at BGAD One alternative to open burning would be for BGAD to design upgrades to the D- 100 detonation chamber already operational at BGAD although not currently in use. This chamber could be used to perform contained burn or static firing disposal operations. As currently designed, the D-100 detonation chamber is an explosive destruction technology, which is discussed in more detail in Chapter 3. CH2M HILL, the chamber manufacturer, and BGAD have proposed modifying this chamber to dispose of the separated rocket motors.3 The throughput estimate is as high as 180 separated rocket motors per day for the D-100 (NRC, 2009). In the event the rocket motor is unstable or if the propellant is cracked or degraded, a static fire could transition to detonation inside the chamber, damaging it and possibly putting it out of commission until cleared to operate again. In any case, damage to the chamber would accumulate in the course of normal operations, necessitating maintenance and periodic repairs. 3 The committee was not able to see the details of this proposal because they are competition sensitive. 49

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As noted above, the M28 propellant contains lead stearate. As separated rocket motors are disposed of, lead compounds and residues would accumulate inside the chamber on walls and floors and on the metal scrap. Abatement activities such as lead monitoring and worker protection would be needed for personnel entering and working inside the chamber. The presence of lead on the metal scrap could also complicate the recycling of the metal scrap. The logistics associated with chamber cleanup and maintenance, motor stand preparation, and lead abatement activities will require an investment of time and resources to maintain the estimated throughput for this system. The chamber would need to meet environmental and explosives safety criteria, and BGAD would need to obtain a RCRA hazardous waste permit modification for disposal of separated rocket motors in this chamber. Discussions with KDEP might result in operating the D-100 under interim status until a final permit is issued by the state. Obtaining these permits can be done within the time frame of the BGCAPP project if KDEP input is sought early in the decision process. Similar units have already been designed, installed, and used at other demilitarization sites to dispose of both conventional and chemical munitions. The Controlled Detonation Chamber, for instance, also manufactured by CH2M HILL, was used to dispose of recovered chemical warfare munitions at Schofield Barracks, Hawaii. This experience might ease the permitting process. The use of the modified D-100 to dispose of the separated rocket motors would have the following advantages: All emissions and waste products from disposal would be contained. Detonation chambers similar to the D-100 have already been used to dispose of conventional and chemical munitions. The D-100 is already on-site and is undergoing permitting. Adapting it for separated rocket motor disposal would only entail modifications to the existing chamber and a permit modification. The entire separated rocket motor would be disposed of, requiring less handling of the motors than in the open burn option. The use of the D-100 would have the following disadvantages: When factoring in maintenance, repairs, and unanticipated interruptions in processing, the projected throughput rate for the D-100 might not quite keep pace with the rate of separated rocket motor production at BGCAPP. This would entail the need for either more than one disposal unit, not necessarily a D-100, or the creation or securing of additional storage space on BGAD. Lead compounds will accumulate in the chamber over the course of operation, necessitating lead abatement and work protection activities. Lead will also accumulate on the metal scrap from separated rocket motor disposal, possibly complicating the recycling of this scrap. A separated motor transitioning to detonation during disposal could damage the chamber and have a significant impact on ongoing disposal operations and thus on schedule. 50

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Alternative Disposal Technologies That Could Be Added to BGAD Capabilities BGAD also has the option of contracting with a vendor to install a suitable disposal technology other than the D-100 on-site for separated rocket motor disposal. Several commercial units, discussed in Chapter 3 as explosive destruction technologies and treated in more detail in NRC, 2009, are available. Some of these have been used at other sites for chemical demilitarization operations. The Kobe Steel DAVINCH is in use in Poelkapelle, Belgium, disposing of First World War-era munitions. It has been estimated that the DAVINCH DV120 could dispose of 36 separated rocket motors per day (NRC, 2009). The Dynasafe AB Static Detonation Chamber has been used at Anniston to augment destruction of munitions at the Anniston Chemical Agent Disposal Facility and is also in use in Munster, Germany, for disposing of First World War-era munitions. It has been estimated that an upgraded SDC 2000 could dispose of 100 separated rocket motors per day (NRC, 2009). This is not meant to be an exhaustive discussion, and other commercial firms, such as El Dorado Engineering, also provide contained disposal technologies that might possibly be used to dispose of the separated rocket motors. Depending on the system design, multiple separated rocket motors could be treated simultaneously in a disposal unit. There would be a nominal setup time, but a long postfire period might be needed with some systems to allow rocket emissions to cool and settle before the chamber could be opened. All of these systems options are contained units and thus share the issues discussed above regarding the D-100. Contracting with a vendor to install a disposal unit could prove simpler than upgrading and retrofitting the current D-100 detonation chamber; it might also ease the permitting process if the vendor has experience in installing units in states other than Kentucky. The advantages and disadvantages of any of these contained disposal technologies would be substantively similar to those for the D-100 enumerated above. One possible advantage is that, as mentioned above, contracting with a vendor to install, and perhaps operate, a technology that has already been successfully used in some way in the chemical demilitarization enterprise might be simpler from a permitting standpoint than modifying the D-100 and obtaining the necessary permit modification. A possible disadvantage is that the technologies for which estimated rates are available have throughput rates well below the planned rate of separated rocket motor generation at BGAD. This would mean having more than one of these units in operation and/or greatly expanded storage for the separated rocket motors. Finding 5-2. There are alternative disposal technologies to open-burning that can be instituted at the Blue Grass Army Depot. However, the use of these alternative technologies would necessitate the inclusion of design, construction, and permitting time into the project schedule. Finding 5-3. A D-100 detonation chamber is currently operational at the Blue Grass Army Depot to dispose of conventional munitions. It is possible that this could be modified and permitted to dispose of the separated rocket motors. A number of other contained technologies are available from commercial vendors, and it might prove 51

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simpler to contract for one of these to be installed than to modify the D-100 and obtain the necessary permit modification. Finding 5-4. Use of any contained technology for the disposal of separated rocket motors would result in contamination of the chamber and any scrap metal with lead. This would necessitate lead abatement and worker protection activities and, possibly, complicate the recycling of metal scrap. Disposal of Separated Rocket Motors at BGCAPP after Completion of All Chemical Agent Destruction Operations Another option would be to store the separated rocket motors until all chemical agent destruction operations at BGCAPP are complete. The BGCAPP facility could then shift to the disposal of the separated rocket motors. The separated rocket motors could then be disposed of using the base hydrolysis technology already at BGCAPP and the same methodology as used for disposing of rocket motors contaminated with chemical agent. BGAD would need to confirm that is has enough safe storage capacity for all of the separated rocket motors on-site until all chemical agent disposal has been accomplished. This would lead to increased storage risk4 compared to disposal of separated rocket motors concurrent with M55 rocket cutting operations at BGCAPP, as discussed in Chapters 2 and 4. The increased risk would be due to the normal issues associated with aging and degrading propellant as well as, perhaps, accelerated degradation of the separated rocket motors because they would be subject to greater environmental exposure than an assembled M55 rocket in its SFT. For this reason, the committee does not believe this is a good option. Finding 5-5. The separated rocket motors could be stored and then disposed of using the BGCAPP base hydrolysis process after chemical agent destruction operations are complete. However, there is an increased storage risk inherent in this option. Public Sentiment While not an explicit item in the statement of task for the committee, public sentiment would have a significant impact on the ability to implement any chosen disposal technology or option (on-site versus off-site). The public has been very involved thus far in the choice of the technologies for use at BGCAPP and in all subsequent decisions involving BGCAPP, and it can be expected to be involved in this decision also. As such, the committee believes public sentiment needs to be considered. The public living and working around BGAD has historically been opposed to anything that resembles the incineration of the wastes from chemical munitions, of which the separated rocket motors are one, and it could have significant concerns about the disposal of the 4 Storage risk is defined in Appendix A. 52

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propellant grain by open burning. The committee believes the public is likely to be sensitive to the issue of lead emissions from open burning. Public sentiment has been evolving positively regarding the use of explosive destruction technologies (discussed in Chapter 3) and perhaps, by extension, of any contained disposal technology to process chemical munitions and the waste streams resulting from chemical demilitarization operations, of which the separated rocket motors are one. Contained disposal technologies also address the public's concerns about emissions to the environment. While these considerations are not listed under the advantages and disadvantages of the on-site disposal options, the committee considers them worthy of mention and consideration. A historical overview of public sentiment about contained disposal technologies (specifically EDTs) and options (on-site versus off-site) can be found in Appendix B. OFF-SITE5 DISPOSAL OPTIONS There are technically sound off-site disposal options for the separated rocket motors from BGCAPP. Using an off-site disposal option could free BGCAPP from having to choose a technology to dispose of the separated rocket motors. Indeed, the selection of the disposal technologies used may be a secondary factor when considering off-site disposal. Off-site disposal facilities might be able to use more than one technology concurrently to meet the schedule for the destruction of the energetic material in the separated rocket motors. One or more off-site facilities might be able to safely and efficiently conduct disposal operations in compliance with their respective site permits and regulatory requirements and within the project schedule. Overall, the off-site disposal of the rocket motors would allow for flexibility in the disposal technologies and strategies used. One consideration regarding off-site disposal is that the motors of the M55 rockets are a unique propulsion system designed specifically for that rocket. It is thus unlikely that any off-site facilities have ever disposed of these specific separated rocket motors before. There are, however, likely facilities that have disposed of similar double- base propellant rocket motors in the past, so the uniqueness of the rocket motors from the M55 rockets might not be that much of an issue. Separated rocket motors that have been cleared for transportation and disposal off-site would have to be received by facilities that are capable of meeting the disposal requirements, including any precautionary requirements that may be in place for disposing of munition components derived from chemical weapons. This could limit the number of off-site facilities that would be able to dispose of the separated rocket motors. Off-site facilities receiving the separated rocket motors would need to have a combination of sufficient permitted safe storage space and the disposal capacity to match the rate at which BGCAPP would ship the separated rocket motors. Having an off-site government facility that already demilitarizes conventional munitions perform the separated rocket motor disposal work might be an option. 5 The committee is using off-site to indicate disposal away from the BGAD facility. 53

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Although the separated rocket motors would have to be transported away from BGAD, they would be received by another government facility, and the communication channels and chain of command would all be within the government. This could expedite addressing any off-normal circumstances that might arise. Also, these installations already have the necessary environmental permits and explosive safety programs in place. Nonetheless, these demilitarization facilities also perform work for a variety of customers, so any request for the disposal of separated rocket motors would likely need to be coordinated with the demilitarization program offices having work performed there. In the Army several demilitarization sites dispose of rocket motors, including McAlester Army Ammunition Plant, Tooele Army Depot, and Anniston Army Depot. A factor that might affect all off-site disposal options is the Chemical Weapons Convention. While the committee does not regard a separated rocket motor as a chemical munition, because the warhead containing the chemical agent will have been separated, the BGCAPP project management anticipates that demilitarization of the separated rocket motors will be required under the Convention.6 For this reason, there could be inspection and monitoring requirements associated with the disposal of the separated rocket motors. International teams of inspectors might need to be allowed access to the disposal operations to verify the destruction of the separated rocket motors. This might impact the willingness of either a commercial or a government facility to receive and dispose of the separated rocket motors. Finding 5-6. There are potential technologies for the disposal of the separated rocket motors that could be used concurrently at one or more off-site disposal facilities to meet program requirements and schedule. Off-site disposal would increase flexibility in regard to choice of a specific disposal technology. The Blue Grass Chemical Agent-Destruction Pilot Plant program staff would, of course, need to work with any off-site disposal facility to ensure that all relevant environmental regulations, such as the Resource Conservation and Recovery Act and the Toxic Substances Control Act, are complied with. Recommendation 5-3. If off-site disposal is pursued, Blue Grass Chemical Agent- Destruction Pilot Plant program staff should allow off-site disposal facilities to tailor the mix of storage and disposal technologies that would allow for optimal, safe, and regulation-compliant disposal of the separated rocket motors. Finding 5-7. There are government installations that currently conduct conventional munition demilitarization, including rocket motors. There might be advantages to having another government facility dispose of the separated rocket motors if off-site disposal is chosen. Finding 5-8. Chemical Weapons Convention treaty requirements, such as inspection and verification of the disposal of the separated rocket motors, might affect the willingness of commercial or government off-site facilities to accept and dispose of the separated rocket motors. 6 E-mail from Jeff Krejsa, BGCAPP, to James Myska, study director, on April 25, 2012. 54

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Public Sentiment Again, while assessing public sentiment is not part of its task, the committee believes that such sentiment will impact the ability to implement any disposal option for the separated rocket motors. The public around BGAD has a history of being sensitive to transporting off-site any secondary wastes from chemical demilitarization, of which the separated rocket motors are an example. Over time, it has proved willing to consider shipping categories of secondary wastes off-site on a case by case basis, but only if there is a sufficient justification. One factor that could cause the public to be willing to consider off-site transportation is safety, although this might leave unresolved other factors such as potential impacts on receiving communities and communities along shipping routes. If it would be safer to move a given waste off-site than to dispose of it on-site, the public may be willing to consider such an option. However, history points to the likelihood that the public will be much more accepting of an on-site disposal option. This is discussed in more detail in Appendix B. SHIPPING AND FIRING TUBE MANAGEMENT One of the wastes from disposing of the separated rocket motors will be the SFTs, which will constitute a waste stream distinct from the separated rocket motors. The SFTs contain on average approximately 1,250 ppm of polychlorinated biphenyls (PCBs).7 This is based on trial burns conducted at the Deseret Chemical Depot (Kimmel et al., 2001). PCBs are semivolatiles that readily penetrate the skin and are fat soluble. The National Institute for Occupational Safety and Health has issued guidance on workplace exposure to PCBs (NIOSH, 1977). When items containing more than 50 ppm of PCB are declared to be a waste, the Toxic Substances Control Act (TSCA) PCB disposal regulations in Subpart D of 40 CFR 761 come into play, requiring PCB containing items to be disposed of in a TSCA- compliant incinerator, in a TSCA-compliant chemical waste landfill, or by an EPA- approved alternative method. As a result of the M55 rocket disposal operations, BGCAPP will be a generator of PCB waste as defined in 40 CFR 761.3. Since there are no liquid PCB wastes it may be possible that the SFTs could be considered a PCB bulk waste, defined as a waste derived from manufactured products containing PCBs in a non-liquid state, at any concentration where the concentration at the time of designation for disposal was 50 ppm PCBs. PCB bulk product waste does not include PCBs or PCB Items regulated for disposal under 761.60(a) through (c), 761.61, 761.63, or 761.64. (40 CFR 761.3) If SFTs can be classified as PCB bulk waste they could possibly be disposed of in a permitted non-hazardous-waste landfill, though this would need to be ascertained (40 CFR 761.62). If the SFTs cannot be designated as PCB bulk waste, they would have to be 7 Kevin Regan, environmental manager, BGAPP project, "Rocket Motor (RM) Disposal," briefing to the committee, March 20, 2012. 55

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treated like any other PCB article, as defined in 40 CFR 761.3, and would have to be disposed of as specified in 40 CFR 761.60. BGAD does not currently have a facility permitted to dispose of PCBs, so treating or disposing of the SFTs on-site would be very challenging. The open burning of any materials containing PCBs is not permitted (40 CFR 761.50(a)(1)). Thus if an open disposal technology was selected to dispose of the separated rocket motors, the motors would in any case have to first be removed from their SFTs. Even when using a contained combustion disposal technology, if the separated rocket motors were not first removed from their SFTs, the waste streams would be contaminated with PCBs and the systems that treated the off-gases from these technologies would have to be able to handle the PCB loading. Additionally, to dispose of the SFTs on-site, BGAD would have to obtain a TSCA permit. For all of these reasons, the committee does not envision the separated rocket motors being disposed of while still in their SFTs. Once the separated rocket motors are removed from their SFTs, the SFTs no longer need to be stored as an energetic material, and become subject to the regulations governing the storage and transportation of PCB-containing materials. Items with PCB concentrations 50 ppm or higher must be stored in accordance with 40 CFR 761.65. This includes a requirement to destroy or dispose of these items within 1 year after their removal from service, and may restrict storage time to less than 1 year. One-year extensions are available. Finding 5-9. Disposing of the separated rocket motors while they are still in the shipping and firing tubes would contaminate the resulting waste streams with polychlorinated biphenyls. Recommendation 5-4. The separated rocket motors should be removed from their shipping and firing tubes prior to disposal. Finding 5-10. The storage, disposal, or treatment of the shipping and firing tubes, which contain polychlorinated biphenyls, on-site would be very challenging and subject to the Toxic Substances Control Act and Subpart D of 40 CFR 761. Recommendation 5-5. The shipping and firing tubes should not be disposed of or treated on-site. Any on-site disposal plan should include sending the shipping and firing tubes off-site to a licensed commercial facility that complies with the Toxic Substances Control Act and Subpart D of 40 CFR 761. Attention should be paid to the regulations governing the storage and transportation of shipping and firing tubes after they are removed from the separated rocket motors. These regulations impose time limits on the storage of polychlorinated biphenyl-containing wastes. If off-site disposal is selected for the separated rocket motors, then the off-site facility could assume responsibility for the transportation, storage, and ultimate disposal of the SFTs. Still, the SFTs would have to be transported in compliance with the appropriate TSCA regulations, and the receiving off-site facility would have to be compliant with TSCA and Subpart D of 40 CFR 761. The receiving off-site facility would need to be made aware of the PCBs in the SFTs. 56

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Finding 5-11. If off-site disposal is selected for the separated rocket motors, the receiving facility would have to be compliant with the Toxic Substances Control Act and Subpart D of 40 CFR 761 and would need to be informed of the presence of polychlorinated biphenyls in the shipping and firing tubes. Recommendation 5-6. When exploring off-site options for the disposal of the separated rocket motors, the Blue Grass Chemical Agent-Destruction Facility Pilot Plant project management should ensure that potential receiving facilities are aware of the presence of polychlorinated biphenyls in the shipping and firing tubes. They should also ensure that any facilities selected are compliant with the Toxic Substances Control Act and Subpart D of 40 CFR 761. TRANSPORTATION OF SEPARATED ROCKET MOTORS On-site Transportation of Separated Rocket Motors Once cleared through headspace monitoring at BGCAPP, the separated rocket motors will be transferred to temporary storage in the BGCAPP munitions demilitarization building. At this point, they could also be transferred to BGAD from the munitions demilitarization building temporary storage. This transfer would need to follow the requirements of the following regulations: Army Regulation 385-64, U.S. Army Explosives Safety Program (U.S. Army, 1997); Army Regulation 385-10, The Army Safety Program (U.S Army, 2011a); Department of the Army Pamphlet 385-64, Ammunition and Explosives Safety Standards (U.S. Army, 2011b); and Army Regulation 55-355, Defense Traffic Management Regulation (U.S. Army, 1986). The separated rocket motors will be RCRA-regulated explosive hazardous waste based on the RCRA definition of reactive material (EPA Hazardous Waste Code: D003) and based on toxicity related to lead (EPA D008-lead). As long as the rocket motors remain on-site, RCRA transportation requirements will not be triggered. Thus, the RCRA definition of on-site is important. Transportation of hazardous wastes within a geographically contiguous property, including property divided by roads, is considered on-site as long as the wastes are not transported along a public right-of-way. On-site transportation would also significantly reduce the risk to safety presented by off-site transportation of a hazardous material of unknown stability because BGAD would be able to positively control traffic on the depot to ensure unrelated personnel are kept away from the separated rocket motors during transport, and they would not be transported on public rights of way. 57

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The separated rocket motors may also have been assigned a Kentucky state waste code (N001 or N002) because they are derived from chemical weapons. Transportation off-site of materials bearing these waste codes would likely be subject to regulatory restrictions, so it might be more straightforward to accomplish on-site transportation than to transport the materials off-site. An important factor that will affect on-site transportationand off-site transportation alsois the hazard classification of the separated rocket motors. This classification will affect packaging and transportation requirements. The hazard classification of the separated rocket motors is discussed in Chapter 2. Finding 5-12. Transporting separated rocket motors solely on-site will be safer and easier to accomplish than transporting separated rocket motors off-site. Off-site Transportation of Separated Rocket Motors Under Subtitle C of RCRA, a hazardous waste transporter is any entity that transports hazardous waste off-site within the United States, if a manifest is required. These regulations establish requirements for hazardous waste handlers; transporters; and treatment, storage, and disposal facilities. Transporting separated rocket motors off-site will require compliance with a variety of regulations and coordination with all state regulatory entities along the planned route. There are other requirements for transporting the separated rocket motors, including having an Environmental Protection Agency identification number, transfer facility requirements, manifesting and record keeping, and establishing actions to be taken in the event of hazardous waste discharges or spills. The following documents cover pertinent aspects of the transportation of energetic hazardous wastes and are important references. Title 40 of the Code of Federal Regulations, Part 262, Subparts B and C, which address manifesting and pretransportation requirements for hazardous wastes. Title 40 of the Code of Federal Regulations, Part 263, which sets out the standards applicable to hazardous waste transporters. Title 40 of the Code of Federal Regulations, Part 761, Section 207, which addresses the requirements for transporting wastes containing PCBs. This would apply to the transportation of the SFTs. Title 49 of the Code of Federal Regulations, Subtitle C, Hazardous Materials Regulations, issued by the Pipeline and Hazardous Materials Safety Administration. These govern the transportation of hazardous materials by highway, rail, vessel, and air.8 Part II of the Defense Transportation Regulation, which stipulates that the movement of regulated hazardous materials must comply with the rules of regulatory bodies governing the safe transportation of regulated hazardous 8 See http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?sid=69820f56014d9312d67ea8169b0e9e01 &c=ecfr&tpl=/ecfrbrowse/Title49/49tab_02.tpl. 58

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materials for selected modes of transportation, which includes ammunition, explosives, and munitions (DoD, 2008a). Department of the Army Pamphlet 385-64, which describes the Army's safety criteria and standards for operations involving ammunition and explosives (U.S. Army, 2011). DoD Ammunition and Explosives Safety Standards, which set uniform safety standards for ammunition and explosives throughout their entire life cycle. The purpose of these standards is to protect personnel and property, whether related or unrelated, and the environment from the potential damaging effects of an accident involving ammunition and explosives (DoD, 2008b). DoD Contractor's Safety Manual for Ammunition and Explosives, which contains requirements and provides guidance for safety, storage, site requirements, and operations involving ammunition and explosives (DoD, 2008c). As noted previously, the separated rocket motors might also bear a Kentucky state waste code (N001 or N002) because they are derived from chemical weapons, and transportation of materials carrying these waste codes off-site would therefore likely be subject to additional regulatory restrictions. Finding 5-13. All off-site disposal options necessarily require removal of the separated rocket motors from government property and transportation on public roads or railways. There are numerous federal, state, and Army regulations governing the transportation of explosive hazardous waste, permits, and safety standards that must be met. Transportation on public roads will require packaging these hazardous components in performance-oriented packaging (POP) designed and tested to meet the requirements of the U.S. Department of Transportation 49 CFR 178 (U.S. Army, 2008).9 These POP tests are conducted to ensure the packaging materials and design can withstand the anticipated stresses of the shipping environment simulated by a series of tests, including drop, stack, and vibration tests. It should be noted that large quantities of propellants, explosives, assembled and disassembled ammunition, pyrotechnics, fireworks, and a wide variety of other energetic materials and ingredients are routinely and safely transported on public roads and railways without incident following Department of Transportation regulations using well-established methods. The U.S. Army Materiel Command Logistics Support Activity Packaging, Storage, and Containerization Center at Tobyhanna, Pennsylvania, provides guidance on the procedures to be followed when performing packaging testing, including test sample procedures, scheduling, and test report format to ensure that the proposed packaging materials and designs are capable of passing all applicable tests prescribed in the Hazardous Materials Regulations in 49 CFR 178 (U.S. Army, 2008). Finding 5-14. Transportation of separated rocket motors off-site must comply with federal regulations governing the transportation of hazardous materials on public 9 More information can be found via https://www.logsa.army.mil/pscc/PSCC_WebDev/PSCC/ psccindex.htm. 59

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thoroughfares, including the use of labeled performance-oriented packaging, which is packaging that has been tested to meet anticipated environmental and transportation stresses. Finding 5-15. Performance-oriented packaging does not exist for the off-site transportation of the separated rocket motors. Such packaging would have to be designed and certified prior to use. This is a time-consuming and expensive process. ADVANTAGES AND DISADVANTAGES OF ON-SITE SEPARATED ROCKET MOTOR DISPOSAL On-site disposal of the separated rocket motors at BGAD would be carried out near the site where the separated rocket motors originate and on property contiguous to the treatment site. This alternative offers many advantages: The explosives safety risk is minimized by having a short transportation path from point of separated rocket motor generation and storage to the disposal site. Being on contiguous property eliminates the hazards of transporting explosive hazardous waste over public roads, keeps the explosive safety hazards away from populated areas, and reduces the burden of transportation regulatory compliance requirements. For instance, on-site transportation would be exempt from RCRA transportation requirements, though it would not be exempt from installation explosive safety and hazardous waste management requirements. BGAD is currently one of the demilitarization installations funded under the Conventional Ammunition Demilitarization Program and has experience in munitions demilitarization and explosive hazardous waste treatment and disposal. BGAD has a munitions scrap metal program. The metal rocket motor cases and other metal scrap recovered from disposal operations can be included in the Demilitarization Enterprise scrap metal cost recovery program, whereby the revenues obtained by this means are returned to the demilitarization account. BGAD has a permitted open-burning disposal site that might be able to meet the disposal requirements for the separated rocket motors. BGAD already has a RCRA Subpart X permit for disposal of explosive hazardous waste. This permit could be amended to include a modification for one or more contained units to dispose of separated rocket motors. A D-100 CH2M Hill controlled detonation unit is already installed at BGAD for the destruction of conventional weapons. The possibility of adapting this technology to destroy separated rocket motors by static firing has been proposed to BGCAPP by CH2M HILL and BGAD. Installing an alternative technology to open burning could leave a residual capability that BGAD could then use for future work. 60

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The public living and working around BGAD is likely to be much more accepting of an on-site disposal option. The disadvantages of on-site demilitarization include these: The projected throughput of any on-site disposal technology other than open burning would likely barely meet or not meet at all the planned rate of separated rocket motor generation at BGCAPP without the use of multiple units. Open burning has as its main disadvantage the release of lead from the propellant into the environment. If a contained disposal technology were selected, there would likely be a need for more than one contained disposal system, or increased on-site storage, or both. The alternative technologies have yet to be put in place, so time and funds would be needed to select and install an alternative technology and obtain the necessary permits or permit modifications. BGCAPP and BGAD would be responsible for the disposal of all resulting waste streams, including the SFTs, which contain PCBs and are regulated under TSCA. ADVANTAGES AND DISADVANTAGES OF OFF-SITE SEPARATED ROCKET MOTOR DISPOSAL The off-site disposal of all of the separated rocket motors may offer some advantages over on-site disposal: Off-site disposal would relieve BGCAPP and BGAD of the many of the day- to-day planning and logistics tasks that would be associated with on-site disposal. It would also allow flexibility in the choice of technology to dispose of the separated rocket motors. Indeed, a specific technology or technologies might not have to be chosen by BGCAPP project management. Off-site disposal could significantly mitigate any need for increased storage space for the separated rocket motors on BGAD. The disposal contractor would be responsible for the disposal of all waste streams, including the SFTs. There are well-equipped and -staffed off-site facilities that can dispose of the separated rocket motors with minimal start-up time and delay. If all separated rocket motors were sent off-site for disposal, BGAD would not need to establish, modify, or expand any rocket motor disposal facility and the associated permits. There are a number of disadvantages to the off-site disposal option: 61

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Transportation of the rocket motors off-site would require compliance with a large body of federal regulation that would not be operative for transportation and disposal wholly on-site at BGAD, as discussed above. Also, should transportation across state lines become necessary, this could necessitate coordination with the appropriate state regulatory bodies along the route. An important factor in off-site transportation is public sentiment. Historically, any transport of waste material derived from chemical weapons, such as the separated rocket motors, away from a depot site has become a matter of significant public concern. Selecting an off-site disposal option and transporting the separated rocket motors off-site would open the possibility of public action, slowing the process of transporting and disposing of the separated rocket motors. This could pose a significant schedule risk. Another disadvantage of an off-site disposal option is that safe transportation requires POP-certified packaging for the separated rocket motors. Such packaging does not currently exist for the separated rocket motors. The currently planned storage and transportation box for the separated rocket motors would only be usable for on-site transportation at BGAD. The effort to design, produce, and obtain certification for the necessary POP-certified packaging would be both time-consuming and expensive. The BGCAPP project management anticipates that the demilitarization of the separated rocket motors will be a treaty requirement under the Chemical Weapons Convention. Any off-site facility that disposed of the separated rocket motors might therefore have to accept inspection and verification. This might impact the willingness of an off-site facility to accept and dispose of the separated rocket motors. REFERENCES DoD (Department of Defense). 2008a. Defense Transportation Regulations, Part II: Cargo Movement. DTR 4500.9-R Part II, June. Available online at http://www.transcom.mil/dtr/part-ii/chapters.cfm. Last accessed June 1, 2012. DoD. 2008b. DoD Ammunition and Explosives Safety Standards, DoD 6055.09-STD, February 29. Available online at http://www.ddesb.pentagon.mil/2008-02-29%20- %20DoD%206055.09-STD,%20DoD%20Ammuntion%20and%20Explosives %20Safety%20Standards.pdf. Last accessed June 1, 2012. DoD. 2008c. DOD Contractor's Safety Manual for Ammunition and Explosives, DoD 4145.26-M, March 13. Available online at http://www.dtic.mil/whs/directives/corres/ pdf/ 414526mp.pdf. Last accessed June 1, 2012. Kimmell, T., S. Folga, G. Frey, J. Molberg, P. Kier, B. Templin, and M. Goldberg. 2001. Technology Resource Document for the Assembled Chemical Weapons Assessment Environmental Impact Statement Volume 1: Overview of the ACWA Program and Appendixes AE, ANL/EAD/TM-101. Argonne, Ill.: Argonne National Laboratory. 62

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NIOSH (National Institute for Occupational Safety and Health). 1977. Criteria for a Recommended Standard: Occupational Exposure to Polychlorinated Biphenyls (PCBs), DHHS (NIOSH) Publication Number 77-225, September. Available online at http://www.cdc.gov/niosh/docs/1970/77-225.html. Last accessed August 23, 2012. NRC (National Research Council). 2009. Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants. Available online at http://www.nap.edu/catalog.php? record_id=12482. Last accessed on May 17, 2012. U.S. Army. 1986. Army Regulation 55-355: Defense Traffic Management Regulation. Washington, D.C: Headquarters, Department of the Army. U.S. Army. 1997. Army Regulation 385-64: U.S. Army Explosives Safety Program, November 28. Available online at http://uxoinfo.com/blogcfc/client/enclosures/ AR38564.pdf. Last accessed August 9, 2012. U.S. Army. 2008. Performance Oriented Packaging Testing Policies & Procedures. Available online at http://www.phmsa.dot.gov/staticfiles/PHMSA/Downloadable Files/Files/LOGSA%20Policies,%20Procedures%20and%20Standards.pdf. Last accessed June 1, 2012. U.S. Army. 2011a. Army Regulation 385-10: The Army Safety Program, October 4. Available online at http://armypubs.army.mil/epubs/pdf/r385_10.pdf. Last accessed August 10, 2012. U.S. Army. 2011b. Department of the Army Pamphlet 38564: Ammunition and Explosives Safety Standards, May 24. Available online at http://armypubs.army.mil /epubs/pdf/p385_64.pdf. Last accessed June 1, 2012. 63

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