Review Criteria for Successful Treatment of Hydrolysate at the Blue Grass Chemical Agent Destruction Pilot Plant (2015) / Chapter Skim
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4 Regulatory Requirements for Offsite Hydrolysate Shipment and Treatment
4 Regulatory Requirements for Offsite Hydrolysate Shipment and Treatment
Pages 28-36
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From page 28... ...
is to safely destroy the and treatment of hydrolysates or SCWO effluent beforehand Blue Grass Army Depot (BGAD) chemical stockpile, includ in coordination with KDEP and any other relevant regulaing meeting criteria for successfully treating the resulting tory bodies and with the Citizens' Advisory Commission hydrolysates in the supercritical water oxidation (SCWO)
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From page 29... ...
listed hazardous waste, hydrolysates will typically exhibit the RCRA corrosivity characteristic. These hydrolysates may also Finding 4-1. Without a modification to the Kentucky statute contain heavy metals and could therefore exhibit the RCRA that requires chemical munitions and their related comtoxicity characteristic.5 The energetic portion of the munitions pounds to be listed as acutely toxic hazardous wastes under would meet the RCRA reactivity characteristic; however, it is the Kentucky RCRA program, and subsequent modification anticipated that after hydrolysis, energetic hydrolysate will no of the Kentucky Department for Environmental Proteclonger be reactive (i.e., RCRA D003 waste)
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From page 30... ...
for these wastes is only applicable within Kentucky, any hydrolysate or SCWO effluent shipped offsite would only Recommendation 4-3. BGCAPP's Waste Analysis Plan have to respect the LDRs that apply in the state in which the should identify the characteristics and underlying confinal TSDF is located -- for example, that it no longer exhib- stituents of the spent decontamination solutions, agent and its a RCRA characteristic (e.g., D002 corrosivity) and that energetic hydrolysates, and SCWO effluent to facilitate it meets any additional treatment requirements for known identification of appropriate LDR treatment standards to be underlying hazardous constituents prior to final disposal.10, 11 used by a receiving treatment, storage, and disposal facility. In addition, under the RCRA LDR regulations, hazardous waste can be stored onsite for more than 1 year only upon Structure of RCRA Permit at BGCAPP a showing that such storage is necessary to facilitate proper future legitimate recycling, treatment, or disposal.12 This By statute and regulation in Kentucky, any applicant for may impact the permissible duration of storage while onsite a TSDF permit to treat chemical munition agent wastes and processes are modified to meet performance criteria or while associated compounds must demonstrate that the proposed preparations are being made for offsite shipment.
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From page 31... ...
Temporary permit or in the latest permit modification application.16 As authorizations to begin construction of ancillary facilities noted by BGCAPP and KDEP, any modification to elimi- may be useful if it becomes necessary to treat the GB agent nate the use of the SCWO treatment unit and instead ship and energetics hydrolysates generated at BGCAPP offsite, hydrolysates offsite for further treatment would negate the in order to ensure construction is complete or at least nearRD&D permit, since BGCAPP would no longer meet the ing completion at about the same time that the Part B permit definition of a FOAK pilot treatment facility.17 If SCWO modification is granted. treatment of the hydrolysate is not possible, and the RD&D An additional requirement of the BGCAPP RD&D permit permit is negated, BGCAPP would have to request a sepa- is to obtain from Madison County a Host Community Cerrate entucky Hazardous Waste Part B permit to continue K tification letter that infrastructure improvements identified treatment of the GB munitions.
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From page 32... ...
pointed out as follows: operating under the RD&D permit. However, if the severity of any problems makes it appear that offsite transport of the On the basis of discussions with state regulators, Mitretek hydrolysate or SCWO effluent may be necessary, BGCAPP concluded that if offsite shipment of hydrolysate is adopted, would need a Class III Part B permit modification to allow neither BGCAPP nor [the Pueblo Chemical Agent Destrucsuch offsite transport.
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From page 33... ...
Of those insignificant activities associated with the with the current water storage, not be able to supply sufficient SCWO, only the SCWO HVAC filter system exhaust must water for SCWO requirements, munition processing may meet a particular applicable regulation: namely, the KDEP have to be slowed or stopped until the permit modification requirements for opacity and particulate emissions.26 is granted so as to not jeopardize plant safety. Finding 4-5. If it appears that obstacles to WRS issues can not be overcome, or overcome before the existing process 22 RCRA Research, Development & Demonstration Permit Revision 5, water storage capacity is expended and additional water withFebruary 14, 2014, Section 3.2.3.5.
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From page 34... ...
The FEIS did not address offsite shipment of involving hazardous waste.29 The Army used the existing hydrolysate or SCWO effluent. The Record of Decision, NEPA documentation, including previous FEIS and Final issued February 27, 2003, does not consider offsite shipment Environmental Assessment documents, to support the REC it of hydrolysate or SCWO effluent and, in fact, finds that the had issued in April 2007.
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From page 35... ...
Department of TSDF did not raise the requirement for a supplemental EIS State. Destruction, under the CWC, is the process by which or environmental assessment.31,32 chemicals are converted in an essentially irreversible way Any permit modification to ship hydrolysates offsite from to a form unsuitable for production of chemical weapons BGCAPP would require a determination whether BCAPP's and which irreversibly renders munitions and other devices current NEPA documentation is adequate or if supplemental unusable as such.
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From page 36... ...
, Accelerated Neutralization of Chemical Agent and Off-Site Shipment of Liquid Process Effluents at the Newport Chemical Agent Disposal Facility. www.pmcd.army.mil/ fndocumentviewer.aspx?
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