Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (2008)

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1 Introduction Assembled Chemical Weapons Alternatives destroyed number approximately 100,000 items, two-thirds PROGRAM HISTORY of which are M55 rockets. The various projectiles stored at PCD number nearly 800,000. Table 1-1 lists chemical agent Background munition types and quantities stored at BGAD; Table 1-2 In 1996, in response to local opposition to the use of lists those at PCD. incineration, the U.S. Congress passed Public Laws 104- The DOD’s Defense Acquisition Board issued an ac- 201 and 104-208, which (1) froze funds for construction of quisition decision memorandum (ADM) in July 2002 that chemical agent destruction pilot plants at the Pueblo Chemi- approved neutralization (hydrolysis with water) followed cal Depot (PCD) in Colorado and at the Blue Grass Army by biotreatment for full-scale pilot testing at the Pueblo site Depot (BGAD) in Richmond, Kentucky; (2) required the and directed acceleration of the destruction of the stock- Army to demonstrate at least two alternatives to incineration pile. The record of decision (ROD) was signed on July 18, to destroy assembled chemical weapons; (3) directed the 2002 (U.S. Army, 2002). The request for proposal (RFP) to Department of Defense (DOD) to establish a new chemical design, build, operate, and close a chemical agent destruc- demilitarization program with a program manager who had tion facility at Pueblo was issued in July 2002. Although not been previously associated with the Army’s chemical the RFP specified that hydrolysis followed by biotreat- demilitarization program; and (4) required the Army to co- ment was to be used in the process, the selection of all ordinate these activities with the National Research Council other unit operations was left to the RFP respondents. The (NRC). This program became known as the Assembled only other requirement of the RFP was that all hazardous Chemical Weapons Assessment program and has since been materials were to be destroyed onsite. The system contract renamed the Assembled Chemical Weapons Alternatives was awarded to Bechtel National, Inc., in September 2002, (ACWA) program. and work on a full-scale pilot plant design for the Pueblo After an elaborate selection process in which the public Chemical Agent Destruction Pilot Plant (PCAPP) began in was extensively involved, six technologies received the grade December 2002. of “acceptable technology,” and the Army chose three of Two of the technologies demonstrated in Demo II and them for demonstration (Demo I) of their technical viability one of those in Demo I were selected to undergo engineering to meet destruction objectives. Two of the three technologies design studies as candidates for destroying the weapons at were found acceptable after demonstration testing, and they Blue Grass. The Defense Acquisition Board issued an ADM proceeded to engineering design studies to assess their ac- on February 3, 2003, that approved neutralization (hydroly- ceptability for implementation to destroy the chemical stock- pile at PCD, which comprises nearly 800,000 projectiles and Memorandum from G.C. Aldridge, Under Secretary of Defense, to the mortar rounds filled with mustard agent. In 1999, Congress Secretary of the Army and the Program Manager, Assembled Chemical passed Public Laws 106-79 and 106-52, which required the Weapons Assessment (ACWA) program, “Disposal of the chemical weapons Army to demonstrate the remaining three technologies that stockpile at Pueblo, Colorado—acquisition decision memorandum (ADM), had initially received the “acceptable technology” grade July 16, 2002.” Under the National Environmental Policy Act, a final environmental (Demo II) and to consider all viable technology alternatives impact statement was issued on April 17, 2002. for destroying the chemical weapons at BGAD in Kentucky, PCAPP is not a pilot plant in the traditional sense of the term. Indeed, it where munitions containing both mustard agent and nerve is intended to destroy the entire stockpile of chemical agent and to perform agents are stored. At BGAD, the agents and munitions to be all associated treatments. This is also true for BGCAPP.  

 Review of secondary waste disposal Planning TABLE 1-1 Description of the Chemical Weapons in the BGAD Stockpile Munition Type Chemical Fill (lb) Energetics Content (lb) 155-mm projectile, M110 H, 11.7 Tetrytol, 0.41 8-inch projectile, M426 GB, 14.4 None 115-mm rocket, M55 GB, 10.7 Composition B, 3.2 M28 propellant, 19.1 115-mm rocket warhead, M56 GB, 10.7 Composition B, 3.2 155-mm projectile, M121/A1 VX, 6 None 115-mm rocket, M55 VX, 10.1 Composition B, 3.2 M28 propellant, 19.1 115-mm rocket warhead, M56 VX, 10.1 Composition B, 3.2 SOURCE: Adapted from data provided to PMACWA on the Munition Items Disposition Action System (MIDAS) by the MIDAS team in July 1997. TABLE 1-2 Chemical Weapons Stockpile of HD- or HT-Filled Munitions at PCD Chemical Energetics Munition Type Fill (kg) Content (kg) Configuration 105-mm cartridge, M60 HD, 1.4 Burster: tetrytol, 0.12 Unreconfigured. Complete projectile includes fuze, Fuze: M51A5 burster. Propellant loaded with cartridge. Cartridges Propellant: M1 packed two per wooden box. 105-mm cartridge, M60 HD, 1.4 Tetrytol, 0.12 Reconfigured. Includes burster and nose plug, but no propellant or fuze. Repacked on pallets. 155-mm projectile, M110 HD, 5.3 Tetrytol, 0.19 Includes lifting plug and burster but no fuze. On pallets. 155-mm projectile, M104 HD, 5.3 Tetrytol, 0.19 Includes lifting plug and burster but no fuze. On pallets. 4.2-inch mortar, M2A1 HD, 2.7 Tetryl, 0.064 Includes propellant and ignition cartridge in a box. Propellant: M8 4.2-inch mortar, M2 HT, 2.6 Tetryl, 0.064 Includes propellant and ignition cartridge in a box. Propellant: M8 NOTES: The terms “unreconfigured” and “reconfigured” are defined in the column labeled “Configuration.” The M1 propellant present in 105-mm cartridges that have not been reconfigured is present in M67 propelling charges—that is, granular propellant contained in bags as specified in MIL-DTL-60318C. SOURCE: Adapted from BPT, 2004. sis with caustic) followed by supercritical water oxidation unit operations for the Blue Grass pilot plant was left to the (SCWO) for full-scale pilot plant testing at BGAD. An RFP RFP respondents. The Army awarded the contract to the to design, build, operate, and close a chemical agent destruc- Bechtel Parsons Blue Grass Team, a joint venture formed by tion pilot plant at Blue Grass was issued on February 7, 2003. Bechtel National, Inc., and Parsons Engineering. (The team- The ROD was signed on February 27, 2003. The RFP for ing subcontractors are Battelle, General Physics, General the Blue Grass Chemical Agent Destruction Pilot Plant (BG- Atomics, and the Washington Demilitarization Company.) CAPP) specified that hydrolysis followed by SCWO was to The Bechtel Parsons Blue Grass Team submitted the initial be used and that all hazardous materials were to be destroyed design to the Army on July 29, 2004 (BPBGT, 2004). onsite. As was the case for Pueblo, the selection of all other Both BGCAPP and PCAPP are in the final stages of design, and some infrastructure is in the construction The terms “neutralization” and “hydrolysis” are often used interchange- phase. Thus, while the waste types are well established, the quantities are estimates based on design. Both plants are ably in the literature on chemical agent demilitarization. Hydrolysis is the more appropriate term from a chemical process perspective. Neutralization being designed and will be built based on RODs that were is more in keeping with the notion of neutralizing and thereby rendering promulgated in 2002 and 2003 for these first-of-a-kind dis- innocuous. It may be found in the literature to refer to hydrolysis in either posal facilities. Because there is much first-of-a-kind equip- aqueous or nonaqueous media. ment, the facilities are being permitted under a research, Under the National Environmental Policy Act, a Final Environmental development, and demonstration (RD&D) provision of the Impact Statement was issued on December 27, 2002. 

INTRODUCTION  Resource Conservation and Recovery Act (RCRA), which viable without jeopardizing the safety, health, or protection allows for some flexibility through permit modifications. of workers, the public, or the environment. In continuing to At both sites, as the system is proven, a more traditional assist PMACWA as it proceeds with implementation of the RCRA permit under a Part B application will be required. ACWA project plans and schedules, the NRC has issued a At present, the plants are being permitted in stages under number of reports in recent years concerning various aspects the RD&D provision. and revisions to the original designs put forth by the systems contractors for each site. A complete list of NRC reports on the ACWA program appears in Appendix A. NRC Activities Since the inception of the ACWA program in 1996, com- PURPOSE OF THIS STUDY mittees of the NRC have conducted a series of independent studies addressing various technical issues that have arisen as The purpose of this study is to provide PMACWA with the program has developed. These studies were conducted at a technical appraisal of its evolving plans to safely and ef- the request of the PMACWA and, along with other informa- ficiently handle, treat, and ultimately dispose of the waste tion, were used by PMACWA staff to make decisions on the materials that remain following the destruction of the as- direction of the program. During the technology selection sembled chemical weapons stored at PCD (Colorado) and phase of the program, they involved technical reviews of the BGAD (Kentucky). candidate technologies. These were followed by reports on These waste materials, termed secondary wastes, pose the demonstration testing that evaluated critical data on the a significant planning challenge in regard to considerations efficacy of specific processes. such as the operational parameters that process equipment After several technology providers had been selected must satisfy, the storage capacity needed for the materials, that offered alternative technology packages that satisfied and whether offsite disposal is advisable. These consider- the ACWA criteria for a total solution capable of completely ations in turn affect how long and in what manner the facil- destroying assembled chemical weapons, the NRC was ity will need to be operated, including the amount of time asked to perform in-depth reviews of the data, analyses, and needed for closure. results of testing that had been developed. Together, this In view of the effect that the disposition of secondary information comprised the engineering design studies for wastes has on facility operations, and recognizing the strong destruction facilities planned for the Pueblo, Colorado, and interest by the public that these materials be safely and re- Blue Grass (Richmond), Kentucky, sites. The NRC commit- sponsibly managed, PMACWA has requested that an NRC tee produced its analyses of the engineering design studies, committee review the current state of its planning in this one for the Pueblo facility (NRC, 2001) and one for the Blue regard and provide appropriate guidance and commentary Grass facility (NRC, 2002a). on options to be considered, including what may be accept- Shortly thereafter, PMACWA awarded contracts to able to regulators and the public and how comparable waste system contractors chosen to design, construct, operate, and materials are dealt with in commercial industrial operations. close first-of-a-kind chemical agent destruction pilot plants The statement of task given for the Committee to Review at the PCD and the BGAD. In 2005, yet another NRC com- Secondary Waste Disposal and Regulatory Requirements mittee issued interim design assessment reports, one for for the Assembled Chemical Weapons Alternatives Program PCAPP (NRC, 2005a) and one for BGCAPP (NRC, 2005b). is as follows: These reports were issued with the intent that PMACWA The NRC will conduct an examination of the environmen- could benefit from the committee’s assessment before the tal, regulatory and permit requirements that chemical agent pilot plant facility designs were finalized. disposal facilities (CDFs) are subject to, on a federal and In the years since then, the ACWA program has experi- state basis, concerning the treatment, storage, and/or han- enced changes largely attributable to budgetary constraints dling and shipping of secondary wastes (chemical agent placed on it by Congress. One of the changes has been the and non-agent related). Building on the current design plans departure from an absolute commitment to facility designs for the Blue Grass Chemical Agent Destruction Pilot Plant that have been termed “total solutions,” meaning that all (BGCAPP) and the Pueblo Chemical Agent Destruction Pi- waste streams from munitions destruction would be com- lot Plant (PCAPP), as well as the recently completed study pletely treated onsite. Instead, in recent years, there has on Chemical Materials Agency secondary waste disposal, been a recognition that more economical options may be the NRC will compare the requirements for CDFs to those of similar facilities in industry that also treat, store, and/or handle and ship secondary wastes, with particular emphasis Information gained in the course of site visits by committee subgroups on industrial best practices. to the pertinent state regulators: Kentucky Department of Environmental Protection (KDEP), Frankfort, Kentucky, January 24, 2008, and Colorado The comparison with industry practices includes, but is not Department of Public Health and Environment (CDPHE), Denver, Colorado, limited to the following areas: February 14, 2008. 

 Review of secondary waste disposal Planning •  he degree of characterization necessary for secondary t The nature of the secondary waste determines the op- waste (chemical agent and non-agent) produced during tions for its processing and disposalspecifically, whether the stockpile disposal and/or storage operations, which is or not it is contaminated and how it is categorized ac- treated on-site or handled and shipped off-site for further cording to RCRA regulations. In addition, the concerns of treatment or disposal; members of the surrounding communities about disposal of •  dentify additional studies that might be required to i the secondary waste that will be generated at BGCAPP and confirm if commercial Treatment, Storage and Disposal Facilities can handle secondary waste from BGCAPP or PCAPP will also influence the waste treatment decisions by PCAPP; PMACWA. •  ecommended procedures and techniques to address r public (including environmental justice) and regulatory Metrics on Degree of Agent Contamination issues; •  amifications and limitations of existing environmental r In the past, the Army had a system for classifying wastes permits including chemical demilitarization permit restric- as clean or contaminated that was based on the treatment the tions that do not exist in commercial/industrial permits; waste stream received. It now uses airborne exposure limits • he extent and number of health risk and transportation t (AELs), a measurement devised by the Centers for Disease risk assessments deemed necessary; Control and Prevention and incorporated into the waste con- •  riteria being considered for shipment of agent contami- c trol limits (WCLs) that have been established in connection nated wastes for final treatment/disposal; and •  acility closure requirements. f with treatment conditions of the wastes to determine the status of the wastes: “agent-contaminated” or “clean,” an approach used in this study as well. For agent-contaminated Secondary Waste at ACWA Chemical Agent waste materials that cannot be characterized by extraction Destruction Pilot Plants procedures, the WCL is defined in terms of a vapor screen- ing level (VSL). Materials having agent contamination Defining Secondary Waste <1 VSL meet the WCL criteria. The VSL concentrations This study examines the wastes expected to be generated are equivalent to the short-term limit values used at other by the two ACWA program facilities that have yet to be built, chemical agent disposal facilities. For agent-contaminated BGCAPP and PCAPP. PCAPP will be processing munitions materials that can be characterized by extraction procedures, containing mustard blistering agent (in HD and HT forms), the WCL values of 20 ppb for VX and GB and 200 ppb for while the BGCAPP will process munitions containing mustard agent have been adopted by some facilities. The mustard agent H and nerve agents GB and VX, including values were originally derived from Army chemical agent M55 rockets having nerve agent fills. To distinguish clearly regulations for workforce drinking water standards (NRC, between these waste munitions and the wastes generated 2007). It is worthwhile noting that WCLs are implemented during the process of their disposal, in this study, all wastes in terms of target release levels, which are in general some- that ultimately leave the plant are considered “secondary what lower than the WCLs to account for variability in the wastes.” Wastes that are generated during the processing degree of analytical precision. Target release levels have operations and are further treated in the pilot plant facility not been set for BGCAPP and remain a high priority in the are considered “process waste streams” and are considered overall job of completing the waste analysis plan (WAP) in this study only if they may be considered suitable for ul- required by RCRA. timate disposal without further in-process treatment. This is consistent with an earlier NRC report, Review of Chemical Definition of “Generator Knowledge” Agent Secondary Waste Disposal and Regulatory Require- ments, which examined secondary waste issues at U.S. Army Like other industrial waste, secondary wastes from chemical agent disposal facilities other than BGCAPP and chemical agent disposal facilities are either hazardous or PCAPP that are currently in operation (NRC, 2007). nonhazardous. A particular waste is classified into one or It is certain that a significant quantity of secondary waste the other of these categories by laboratory analysis or by will be generated over the operational and closure lifetime of “generator knowledge” of the material’s source, use, and BGCAPP and PCAPP. The time, effort, and resources needed history of exposure. to deal with the secondary waste will be substantial, and its “Generator knowledge” is a hazardous waste evaluation handling can become a subject of public debate or criticism method commonly accepted and defined by the Environmen- concerning the operation of the pilot plants. The catchall term “secondary waste” encompasses many different waste forms, The VSL and short-term limit values are as follows: GB, 0.0001 mg/m 3; and opportunities may exist for cost savings or for schedule VX, 0.00001 mg/m3; mustard agent, 0.003 mg/m3 (NRC, 2007). acceleration if other disposal options become applicable to John Barton, chief scientist, and Kevin Regan, environmental manager, certain secondary waste streams. BGCAPP, “Current waste analysis and certification,” presentation to the committee, January 24, 2008. 

INTRODUCTION  tal Protection Agency and individual states (EPA, 2005). It is the amounts and conditions of secondary waste generated, based in most cases on (1) a facility process flow diagram or state approvals, the availability of appropriate disposal sites, narrative description of the process generating the waste or and the like. (2) the chemical makeup of all ingredients or materials used The committee recognized that although plans for as- in the process that generates the waste. See Appendix B for sembled chemical weapons destruction at the Blue Grass additional information on the use of generator knowledge. and Pueblo sites have many features in common, there are also factors that make decisions on the management and disposition of secondary waste singular for each site. Waste Management Planning For example, BGAD stores a wider variety of agents and The regulatory requirements governing the management munition types than does PCD. Moreover, the processes by of wastes generated at chemical agent disposal facilities which these agents and munitions will be destroyed have (and other industrial facility operations) require that a WAP both commonalities and differences. With this in mind, the be submitted before operations begin. The WAP provides committee determined that it would address the technical detailed information on all streams and proposed sampling issues from the perspectives of the individual sites, keeping and analytical methodologies. Such a plan is available for in mind that there may be programmatic aspects that would PCAPP and was submitted to the Colorado Department of be pertinent to both sites. Chapter 2 examines technical Public Health and the Environment (CDPHE). However, al- considerations related to the BGCAPP and PCAPP designs though it had not yet been approved as this report was being as presently configured, with emphasis on the generation of written, it did serve as an important source for the analysis waste streams. of the PCAPP situation in this study. Because no WAP was Chapter 3 describes the regulatory framework for the available for BGCAPP, other information had to be used to management and disposal of secondary waste at BGCAPP develop the committee’s analysis. and PCAPP. Chapter 4 presents the committee’s review and analysis of the estimated quantities of the various secondary waste streams expected to be generated from the current Study Methodology and Report designs for BGCAPP and PCAPP, plans and options for Organization disposal of these waste streams, and a review of certain prac- There are both advantages and disadvantages involved tices that are typically used in industrial waste management in addressing the generation, handling, and treatment of situations. In addition to being generated during operations, secondary waste at yet-to-be-constructed facilities using secondary waste will also be generated during facility clo- first-of-a-kind equipment and processes that have yet to be sure, and this also is briefly discussed. fully integrated into the overall processes of an operational The proper management of wastes from chemical agent facility. The advantage is that by examining the issues associ- disposal facilities is a matter of interest to the surrounding ated with secondary waste at this early juncture, technical, communities and other segments of the public. The structure regulatory, and public acceptance matters can be deliberated of public participation for each site is described in Chapter with sufficient time for adjustment and implementation. The 5, where issues of concern to public stakeholders and the disadvantage is the gaps in informationsome plans are still perspectives of their representatives are also examined. evolving and some data are still to be generatedand the Chapter 6 presents alternatives to current waste manage- uncertainties surrounding such things as public perceptions, ment plans for each site that PMACWA may wish to consider, including offsite disposal of several major waste streams. See Section C of PMACWA, 2006.