Review Criteria for Successful Treatment of Hydrolysate at the Pueblo Chemical Agent Destruction Pilot Plant (2015)

5

Transportation of Chemical Materials

This chapter begins with a description of the federal regulations relevant to the definition and reporting of heavy truck accidents (crashes) and hazardous material incidents. Some historical offsite transportation data for hydrolysate from chemical agent destruction sites is then presented. The risks of transporting hydrolysate, addressed next, entail the following: (1) those due to a heavy truck crash independent of the cargo, (2) those due to a hazardous material cargo, and (3) those unique to hydrolysate.

REGULATIONS OF THE U.S. DEPARTMENT OF TRANSPORTATION

The U.S. Department of Transportation (DOT) is the federal government agency with the primary responsibility for policies and programs to protect and enhance the safety, adequacy, and efficiency of the transportation system and services. DOT consists of 11 individual operating administrations, including the Federal Aviation Administration (FAA), the Federal Motor Carrier Safety Administration (FMCSA), the Federal Railroad Administration (FRA), and the Pipeline and Hazardous Materials Safety Administration (PHMSA). The PHMSA is responsible for hazardous materials regulations, including classification of hazardous materials into one of nine classifications, the associated placarding of vehicles, packaging requirements, and so on (49 CFR 171-180).

Hydrolysate shipments to date have been by truck, and the emphasis in this chapter is therefore on truck transport across public roads and highways. The shipment of hydrolysate by rail is potentially an option and will have similar risks to the public—that is, the potential for direct physical impact and the potential for release of the hazmat cargo. The purpose of this overview of DOT regulations is to introduce the concepts of a reportable crash, a reportable incident, and the first step of hazard classification that dictates subsequent regulations to be followed.

Of particular relevance to this report is that the FMCSA is responsible for maintaining a database to provide information on serious crashes of trucks (and buses). A crash is reported to FMCSA (“DOT-reportable”) if it involves the following (49 CFR 390.05):

• Any truck having a gross vehicle rating of more than 10,000 pounds used on public highways or any vehicle displaying a hazardous material (hazmat) placard.

and

• That vehicle is involved in a crash while operating on a roadway customarily open to the public, which results in any of the following:

—A fatality as a result of the crash;

—An injury requiring medical treatment away from the crash scene; or

—A tow-away of any motor vehicle disabled as a result of the crash.

Further, a reportable hazmat incident is defined (49 CFR 171.15) and reported (49 CFR 171.16) separately to PHMSA if, as a result of a hazmat,

• A person is killed or receives an injury requiring admittance to a hospital;
• The general public is evacuated for 1 hour or more;
• A major transportation artery is closed for 1 hour or more;
• An unintentional release of a hazmat or the discharge of any quantity of hazardous waste; or
• A specification cargo tank of 1,000 gallons or more containing hazmat either suffers damage to the lading retention system or requires repair to a system intended to protect the lading retention system even if no release occurs.

The above characteristics are important when the transportation of chemical munition materials is considered.

Other parts of the definition—for example, those involving radioactive materials—do not apply to this report.

The definition of “accident” in 49 CFR 390.5 uses “occurrence” instead of “crash.” Further, “DOT-reportable” usually includes “accident.” However, many DOT documents use “crash” in lieu of “accident” to clearly indicate that physical forces are involved (DOT, 2013). Note that an incident may or may not involve a crash but does involve a hazmat release. In this chapter the committee uses “accident” in the phrase “DOT-reportable accident” and “crash” elsewhere unless it is quoting.

Hydrolysate shipments to date in the chemical demilitarization program (Table 5-1) have been considered Class 8 “corrosive” hazmat. Class 8 hazmat is defined in 49 CFR 173.136 as a liquid or solid that causes (1) full thickness destruction of human skin within a specified period of time or (2) a specified corrosion rate of steel or aluminum. The rate of destruction defines the Packing Group as I, II, or III. The class and packing group then dictate a number of important DOT requirements (e.g., equipment selection and inspection procedures); however, a detailed discussion of DOT hazmat regulations is beyond the scope of this chapter. The DOT regulations do not explicitly equate corrosive with a pH value, but the U.S. Environmental Protection Agency (EPA) defines corrosive hazardous waste as (1) a liquid with pH <2 or >12.5 or (2) a liquid that corrodes steel at a rate of >0.250 in./yr at a test temperature of 55°C (130°F). The EPA and DOT definitions are frequently confused.

HISTORICAL TRANSPORTATION OF CHEMICAL MUNITION MATERIALS

The anticipated composition of the Pueblo Chemical Agent Destruction Pilot Plant (PCAPP) hydrolysate is compared in Table 5-1 to hydrolysate shipped from Aberdeen Proving Ground (APG) and the Newport Indiana Chemical Depot (NECD) as well as the Explosive Destruction System neutralent from destruction of bomblets at Rocky Mountain Arsenal (RMA) in 2001. Note that the data shown in Table 5-1 for PCAPP hydrolysate characteristics were provided by PCAPP at the committee meetings in July 2014. These parameters may differ from those presented in Table 2-1, which were derived from the 2003 Guelta and Fazekas-Carey study and from the 2006 Waste Analysis Plan filed by PCAPP as part of its Resource Conservation and Recovery Act (RCRA) RD&D permit, which is currently under revision. The differences, however, are not significant for the purpose of comparing the risk of hydrolysate shipments.

Historical offsite transportation data for sarin, distilled mustard agent, and VX nerve agent hydrolysate from Blue Grass Army Depot (BGAD), APG, and NECD as well as neutralent from RMA bomblet destruction are presented in Table 5-2. All shipments in the table were by truck.

The above data show that more than 500,000 shipment miles have accumulated with materials similar to the hydrolysate that will be generated at PCAPP without a leak or even a fender-bender crash.

Finding 5-1. The historical shipment mileage data are dominated by the shipment of hydrolysate from NECD to the Veolia TSDF. The NECD shipments, as well as those from APG, BGAD (Operation Swift Solution), and RMA were free from a minor fender bender or leaks of hydrolysate or similar fluids.

Finding 5-2. Offsite shipments of hydrolysate and similar chemical munition materials from APG, NECDF, BGAD, and RMA have been safe.

IDENTIFICATION OF HYDROLYSATE TRANSPORTATION RISKS

Risk is the combination of likelihood and the consequence of a specified hazard being realized. Likelihood is usually expressed in transportation risk analyses as crashes/mile, crashes/trip, etc., and may be modified by conditional probabilities such as the probability of a fire, given a crash, and the probability of fire causing failure of the hazmat container, given a fire occurs. The associated consequence could be injuries or fatalities from a hazmat release due to a fire. Risk analysis methodologies differ in (1) the scope of the analyses, e.g., selection of the various options available such as mode or container, and (2) the level of detail needed to accomplish the purpose of the analysis, e.g., hazmat release as an appropriate consequence or whether dispersion of the released hazmat and potential exposure to the public needs to be considered also, including the appropriate conditional probabilities. All risk analyses aggregate risk-producing components to some extent depending on the data availability and the purpose of the analysis. Therefore, the risk analysis may be qualitative, semiquantitative, or fully quantitative. The purpose of this chapter is not to completely specify the level of detail needed in a PCAPP quantitative transportation risk analysis (QTRA), although some general requirements are identified at the end of this chapter. Rather, the purpose is to identify how the transportation risk changes with the type of cargo. Some quantification is provided to help evaluate the risk associated with the cargo type.

The risks are identified in this section as (1) fatalities and/ or injuries due to the physical impact of a heavy truck with a person independent of the cargo, (2) fatalities, injuries, and/ or economic consequences due to the release of the hazmat cargo, and (3) risks unique to a cargo of hydrolysate in addition to (1) and (2). As stated earlier, the shipment of hydrolysate by rail is potentially an option, but for the purposes of this chapter, the focus is on truck shipment across public roads and highways. Risk identification will be similar for truck and rail.

TABLE 5-1 Comparison of Chemical Agent Liquid Treatment Content

NOTE: NaOH, sodium hydroxide (caustic); ND, not detected; ppm, parts per million; ppb, parts per billion; EDS, Explosive Destruction System.

^a PCAPP PFD 24852-RD-M5-B04-B0004 and 24852-RD-M5-B09-B0002.

^b Aberdeen Chemical Agent Disposal Facility shipment analysis data for shipments between June 14, 2004, and February 9, 2005, provided by Bill Steedman.

^c December 12, 2006, Waste Characterization Sheet.

^d Laurence Gottschalk, Director, Recovered Chemical Materiel Directorate, presentation to the committee on July 30, 2014.

^e Don Guzzetti, start-up field supervisor, PCAPP, “Biotreatment Area Risk Reduction and Mitigation,” presentation to the committee on July 29, 2014.

SOURCE: Adapted from data provided by PCAPP on July 30, 2014; subreferences as noted.

TABLE 5-2 Historical Shipment Data

NOTES: n.o.s., not otherwise specified; JPEOCBD, Joint Program Executive Office for Chemical and Biological Defense; GB, sarin; VX, a nerve agent; HD, distilled mustard agent; TSDF, treatment, storage, and disposal facility; RCMD, Recovered Chemical Materiel Directorate.

Risks Due to a Heavy Truck Crash Independent of the Cargo

The likelihood that a large truck would be involved in a serious crash is about 1 in a million miles (1.0 × 10^-6/mi). Given a serious heavy truck crash, the probability of (1) a fatality is about 0.01 (1 percent) and (2) an injury is 0.22 (22 percent) independent of the cargo (DOT, 2013).

Finding 5-3. Injuries and fatalities due to the physical forces involved in a heavy truck crash, independent of the cargo, are a risk.

Hazmat crash rates were found to be about half the rate for heavy trucks in general (Battelle, 2001). The current crash rate (DOT, 2014b) for Tri-State Motor Transit Co. (the parent company is Bed Rock Inc.), a company frequently used to transport hazmat and the carrier for NECDF, is 0.30 in a million miles (0.30 × 10^-6/mi) or one-third the rate for heavy trucks in general. This rate applies to the company’s entire fleet, not just hazmat.

Hydrolysate shipments from NECDF and APG were subjected to enhanced safety measures as compared with typical hazmat shipments—that is, safety inspections were carried out once every 2 hours or so. The same safety measures can be expected if hydrolysate is shipped from PCAPP, and a crash rate <0.30 × 10^-6/mi can be expected.

Table 5-3 estimates the number of PCAPP heavy truck shipments with onsite treatment of hydrolysate at 176/month. Table 5-3 also estimates 211 monthly shipments if hydrolysate is shipped offsite. This estimate of 211 shipments is probably an upper bound because the number of caustic shipments in the case of offsite hydrolysate treatment was not reduced owing to the committee’s lack of data about the extent of the reduction in the amount of caustic needed, given offsite shipment of hydrolysate. The likelihood of an injury or a fatality provided above applies to the 176 shipments as well as the 211 shipments.

Finding 5-4. Offsite hydrolysate transport would increase the number of shipments from about 176 per month to as many as 211 per month.

Additional Risks Posed by a Truck Carrying Hazmat

In addition to the cargo-independent consequences of a large truck crash, the potential consequences of a release of hazmat include injuries, fatalities, and cleanup costs. As noted in a recent report (TRB, 2013), “Hazmat-specific accident rates are usually not available and truck accident rates are often used as a proxy.” These rates and conditional release probabilities are not known, in part because private as well as public stakeholders (i.e., the Transportation Security

TABLE 5-3 Estimated PCAPP Truck Shipments (trucks per month)

NOTE: ICB, immobilized cell bioreactor; BRS, brine reduction system.

^a A significant number of caustic shipments could be eliminated.

^b PMACWA, 2006.

^c Rounded.

Agency) protect data for several reasons such as competitiveness and need to know.

When cargo-independent fatalities/injuries are compared with hazmat-cargo-related fatalities and injuries, the hazmat-cargo-related effects can frequently be neglected. This was the case in the 2003 transportation risk analysis of PCAPP solid wastes and hydrolysates (ANL, 2003). The committee’s finding and recommendations about this approach, originally presented in 2008, are presented later in this chapter.

Table 5-4 shows a summary of highway incidents in 2013 by transport phase (DOT, 2014a). The number of incidents in transit is about a third of those taking place during loading and unloading, but they account for the majority of fatalities and monetary damages.

More than 800,000 highway hazmat shipments occur each day (DOT, 2004), which is about 300 million every year. The number of annual highway incidents (13,873) is very small compared with the number of highway hazmat shipments.

Finding 5-5. Historically, the risk of hazmat release during transportation owing to either a leak due to a crash or a crash-independent leak has been small.

Additional Risks Posed by a Truck Carrying Hydrolysate

If hydrolysate is to be shipped offsite, approximately 1,400 tanker truckloads, each holding about 6,000 gal, would be required, or about two tanker trucks a day, every day, for approximately 2 years (PMACWA, 2006). The hazards due to hydrolysate exposure are considered moderate. In comparison, the hazard for 50 percent sodium hydroxide, a typical Class 8 material, is considered high (Noblis, 2008). Therefore, the discussion above regarding the risks of hazmat shipment deals with the risk of hydrolysate shipment.

Pueblo County requires that the “risk of accidents during the transportation of any wastes to, from, or at the proposed site . . . be considered” (Pueblo County land use regulations at Title 17, Chapter 176, Section 050). Noblis (2008) reported that in a 2007 meeting with stakeholders, the attendees indicated that the executive director of CDPHE “wants an assessment performed of the risk associated with the transport of hydrolysate within the State of Colorado.” The committee has no knowledge of the specific basis for the request and believes that the 2003 QTRA and subsequent hydrolysate transportation safety evaluations are publicly available.

TABLE 5-4 Highway Hazmat Incident Summary by Transportation Phase in 2013

RELATED PRIOR NRC FINDINGS AND RECOMMENDATIONS

The QTRA prepared for PCAPP, referred to earlier in this chapter (ANL, 2003), qualitatively dismissed the risks of transporting hydrolysate compared with the cargo-independent risks from heavy trucks. The 2008 NRC report said it was important to provide quantitative data to calm the anxiety that could be triggered by the prospect of offsite transportation. The 2008 report contained the following finding and recommendations, applicable to PCAPP:

Finding 5-7. The findings and recommendations cited above from the previous PCAPP review (NRC, 2008) continue to be relevant.

Recommendation 5-1. Transportation-related recommendations in the previous PCAPP review (NRC, 2008) should be followed.

The Army has sufficient experience transporting hydrolysate from APG and NECD to perform a reasonable QTRA in the near term including selection of the packaging (container). The primary missing piece is the selection of a TSDF for the analysis, and Army procurement regulations may preclude timely identification of the selected TSDF. The committee believes that utilizing several representative TSDFs and performing a QTRA for each will accomplish several objectives, including these: (1) illustrate the sensitivity of the risk to different routes to the different TSDFs, (2) quantify the relative risk contributions of both cargo-independent and hydrolysate release scenarios, (3) quantify the overall risk magnitude of hydrolysate transport to a sufficient degree for regulatory and stakeholder evaluation, and (4) provide input to emergency response planning. As noted above (NRC, 2008), the QTRA should include human health consequences of hydrolysate spills with and without a fire.

REFERENCES

ANL (Argonne National Laboratory). 2003. Transportation Risk Assessment: Options for the Offsite Shipment and Disposal of Residual Wastes from the Destruction of Chemical Weapons at the Pueblo Chemical Depot. Prepared for the Program Manager, Assembled Chemical Weapons Assessment. APG, Md. April.

Battelle. 2001. Comparative Risks of Hazardous Materials and Non-Hazardous Materials Truck Shipment Accidents/Incidents. http://www.phmsa.dot.gov/pv_obj_cache/pv_obj_id_2F1F1A79D0F916679838CDE369E5600B20733400/filename/hazmatriskfinalreport.pdf.

DOT (Department of Transportation). 2004. Crashes Involving Trucks Carrying Hazardous Materials. FMCSA-RI-04-024. Federal Motor Carrier Safety Administration. May. http://www.fmcsa.dot.gov/factsresearch/facts-figures/analysis-statistics/fmcsa-ri-04-024.htm.

DOT. 2013. Large Truck and Bus Crash Facts–2011. FMCSA-RRA-13-049. Federal Motor Carrier Safety Administration. October. http://www.fmcsa.dot.gov/safety/research-and-analysis/large-truck-and-bus-crash-facts-2011.

DOT. 2014a. PHMSA Incident Statistics. http://www.phmsa.dot.gov/hazmat/library/data-stats/incidents. Accessed August 7, 2014.

DOT. 2014b. Company Snapshot: Bed Rock Inc. http://safer.fmcsa.dot.gov. Accessed August 1, 2014.

Guelta, M.A., and L. Fazekas-Carey. 2003. Biodegradation of Hydrolyzed Mustard from an Assembled Chemical Weapons Assessment (ACWA) Projectile Washout Study. ECBC-TR-291. Aberdeen Proving Ground, Md.: Edgewood Chemical Biological Center.

JPEOCBD (Joint Program Executive Office for Chemical and Biological Defense). 2014. Offsite Hydrolysate Transport and Disposal Case Studies. Provided by PCAPP on July 30, 2014.

Noblis. 2008. Offsite Disposal of ACWA Hydrolysates. NTR 2008-61129. Falls Church, Va.

NRC (National Research Council). 2008. Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Plants. Washington, D.C.: The National Academies Press.

PMACWA (Program Manager, Assembled Chemical Weapons Assessment). 2006. Questions & Answers—Hydrolysate. Available at the Pueblo Chemical Stockpile Outreach Office. Pueblo, Colo.

PMACWA. 2012. PCAPP Hazardous Materials and Waste In and Out of the Facility. Provided by PCAPP on August 18, 2014.

RCMD (Recovered Chemical Materiel Directorate). 2014. Bomblet Destruction Campaign at Rocky Mountain Arsenal. Provided by PCAPP on July 30, 2014.

TRB (Transportation Research Board). 2013. Hazardous Materials Transportation Risk Assessment: State of the Practice, Visual Risk Technologies, Inc., Hazardous Materials Cooperative Research Program Report 12. Washington, D.C.