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

5

Transportation of Chemical Materials

This chapter addresses the risks of transporting hazardous materials, including hydrolysate. It first describes the federal regulations that define and govern the reporting of heavy truck accidents (i.e., crashes) and hazardous material incidents. Next it reviews historical data for the offsite transportation of hydrolysate and similar materials from chemical demilitarization sites. Finally the chapter addresses the risks of transporting hydrolysate. These risks include

• Those associated with heavy truck crashes, regardless of cargo;
• Those associated with transportation of hazardous material cargo in general; and
• Those unique to transportation of hydrolysate.

DEPARTMENT OF TRANSPORTATION REGULATIONS

The U.S. Department of Transportation (DoT) has the primary responsibility for protecting and enhancing the safety, adequacy, and efficiency of the national transportation system and related services. It comprises 11 individual operating administrations. Of these, the Pipeline and Hazardous Materials Safety Administration is responsible for the regulations governing hazardous materials, including their classification into one of nine classes and the associated vehicle placarding, packaging, and other requirements (49 CFR 171-180).

To date, all hydrolysate shipments have been by truck. Accordingly, this chapter emphasizes truck transport on public roads and highways. There may also be an option to transport hydrolysate by rail. Rail transport would present risks to the public similar to truck transportation: for example, direct physical impact at a crash scene and the release of the cargo to the environment, possibly exposing the public. This section introduces the concepts of “reportable crash,” “reportable incident,” and the first step of hazard classification, which dictates the subsequent regulations that must be adhered to.

The Federal Motor Carrier Safety Administration maintains a database on serious truck and bus crashes. A “DoT-reportable” crash is reported to the Federal Motor Carrier Safety Administration if it has the following elements (49 CFR 390.5):

• —Fatality; or
• —An injury requiring medical treatment away from the crash scene; or
• —The towing of any motor vehicle disabled in the crash.

A reportable hazardous material incident is defined and reported to the National Response Center, if as a direct result of a hazardous material (49 CFR 171.15),

• A person is killed,
• A person receives an injury requiring admittance to a hospital,
• The general public is evacuated for 1 hour or more, or
• A major transportation artery is shut down for 1 hour or more.

The incident is reported separately to the Pipeline and Hazardous Materials Safety Administration if, in addition to the circumstances in 49 CFR 171.15, the incident results in (49 CFR 171.16) the following:

• An unintentional release of a hazardous material or hazardous waste, or
• A specification cargo tank of 1,000 gallons or more containing hazardous material suffers damage to the lading retention system or to a system intended to protect the lading retention system.

TABLE 5-1 Historical Data on the Shipment of Hydrolysates and Neutralent

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

It should be noted that terminology differs across different DoT documents. The regulation defining “accident” (49 CFR 390.5) uses “occurrence” instead of “crash.” Further, “DoT-reportable” usually includes “accident.” However, many DoT documents use “crash” rather than “accident” to clearly indicate the presence and involvement of physical forces (e.g., DoT, 2014). It should also be noted that an incident may involve a hazardous material release without involving a crash. In this chapter the committee uses “accident” in the phrase “DoT-reportable accident” and “crash” elsewhere unless it is quoting a document.

To date, hydrolysate and similar liquids have been designated as Class 8 corrosive materials. A Class 8 hazardous material is defined as a liquid or solid that causes either (1) the destruction of the full thickness of human skin within a specified time period or (2) a specified corrosion rate for steel or aluminum (49 CFR 173.136).¹ The destruction rate defines the packing group for the material, the groups being I, II, or III. The hazardous material class and the associated packing group dictate a number of important DoT requirements, such as the selection of equipment and the procedures used when conducting inspections. While DoT regulations do not explicitly define “corrosive” using a pH value, the U.S. Environmental Protection Agency (EPA) defines hazardous waste as corrosive if either (1) it is 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 130°F (55°C). The EPA and DoT definitions of corrosive are frequently confused.

THE HISTORICAL TRANSPORTATION OF CHEMICAL MUNITION MATERIALS

Historical data are shown in Table 5-1 for the offsite transportation of GB, HD, and VX hydrolysate from, respectively, the Blue Grass Army Depot (BGAD) during Operation Swift Solution, Aberdeen Proving Ground (APG), and the Newport Chemical Depot (NECD), as well as the Explosive Destruction System (EDS) neutralent from destruction of GB bomblets at Rocky Mountain Arsenal (RMA) in 2001. All of these shipments were by truck. The composition of most materials in those shipments is given in Table 5-2; they can be compared to the anticipated composition of hydrolysates from the Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP) shown in Tables 2-1 through 2-6. The data in Tables 5-1 and 5-2 show that over 500,000 miles have been accumulated shipping materials similar to the hydrolysate that is anticipated to be generated at BGCAPP without a leak or even a minor crash.

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¹ Examples of Class 8 materials are hydrochloric acid, nitric acid, sulfuric acid at a concentration of >51 percent, and solid sodium hydroxide, all commonly transported materials.

TABLE 5-2 Comparison of Historical Hydrolysate and Neutralent Contents

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

^b December 12, 2006, Waste Characterization Sheet.

^c Laurence Gottschalk, director, Recovered Chemical Materiel Directorate, “Recovered Chemical Materiel Directorate (RCMD) Bomblet Destruction Campaign at Rocky Mountain Arsenal,” presentation to the committee on July 30, 2014.

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

SOURCES: Information provided to the committee on July 30, 2014.

Finding 5-1. The accumulated mileage for the historical shipment of hydrolysate and similar materials is dominated by the shipment of hydrolysate from NECD to the Veolia treatment, storage, and disposal facility in Port Arthur, Texas. The shipments from the Newport Chemical Depot, the Blue Grass Army Depot, Aberdeen Proving Ground, and Rocky Mountain Arsenal were free from even minor crashes and from any leaks of hydrolysate or similar fluids.

IDENTIFICATION OF THE RISKS OF TRANSPORTING HYDROLYSATE

Risk is the combination of the likelihood of a specified hazard being realized and the consequence of that hazard occurring. Likelihood in transportation risk analyses is usually expressed as crashes per mile or crashes per trip. Some of the factors that affect the likelihood are the number of shipments, the distance traveled per shipment, the route characteristics, the carrier, and the transportation mode. Conditional probabilities based on the factors in the consequence calculation are generally included in the likelihood calculation, e.g., the probability of a fire, given a crash, and the probability of fire causing a hazardous material container to fail, given that a fire occurs.² The potential consequences include

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² The hydrolysates will not themselves be flammable, so a simple spill would not result in a fire. Given a large truck, the probability of a fire is only a few percent.

injuries and fatalities not only due to the impact of a heavy truck with a person but also the exposure of members of the public to a released hazardous material. Some of the factors that affect exposure are the dispersion of the material not only due to the material properties such as vapor pressure, but also meteorological dispersion characteristics and the potential presence of a fire. Given an exposure, the health effects vary with the level of toxicity, corrosiveness, and so forth.

Methodologies used to analyze risk differ in their scope. One might entail selecting the most appropriate transportation mode or hazardous materials container and determining the necessary level of detail to meet the purpose of the analysis in question. Another methodology might look at whether the simple release of a hazardous material is the appropriate consequence, or whether dispersion and possible public exposure also need to be considered, factoring in the appropriate conditional probabilities, such as those mentioned above. All risk analyses aggregate to some degree the various factors that produce and affect risk. The extent of aggregation depends on the availability of data and the purpose of the analysis. The resulting analyses may be quantitative, qualitative, or quantitative for some portions and qualitative for others. This chapter does not specify the level of detail that would be appropriate for a BGCAPP quantitative transportation risk analysis (QTRA), or the numerous factors that should be included in the analysis. That is for BGCAPP to determine during the conduct of a QTRA. However, some general requirements for such an analysis are identified at the end of this chapter. Instead, this chapter examines how transportation risk changes with cargo type. Some quantification is provided to help evaluate risks associated with various cargo types.

The risks identified in this section are those associated with the following consequences:

• Fatalities and/or injuries resulting from the impact of a heavy truck with a person, independent of the cargo;
• Fatalities, injuries, and/or economic consequences resulting from the release of hazardous materials; and
• Those unique to hydrolysate.

As previously stated, transporting hydrolysate by rail is an option, but the focus of this chapter is on transportation by truck across public roads and highways. The process for identifying risk for rail transportation would be similar to the process for truck transportation.

Risks Due to a Heavy Truck Crash, Independent of Cargo

The likelihood of a large truck being involved in a serious crash is about 1.2 × 10^-6/mi, or somewhat more than 1 for each million miles traveled. In the event of a serious heavy truck crash, the probability of a fatality is about 1 percent, and that of an injury is about 23 percent, each independent of the cargo being transported (DoT, 2014).

Finding 5-2. There is a low risk of injuries and fatalities resulting from a heavy truck crash, independent of the cargo being transported.

Additional Risks from Carrying Hazardous Materials

On top of the cargo-independent risks resulting from a large truck crash, the risks associated with a release of hazardous materials include injuries, fatalities, and cleanup costs. A recent Transportation Research Board report notes that “hazmat-specific accident rates are usually not available and truck accident rates are often used as a proxy” (TRB, 2013). The reason for this is, in part, that private and public stakeholders (e.g., the Transportation Security Administration) protect data for a variety of reasons, such as maintaining competitiveness and operational security.

The current crash rate for Tri-State Motor Transit Company, a company frequently contracted to transport hazardous materials and the carrier contracted to transport the hydrolysate from NECD, is 0.38 in a million miles (0.38 × 10^-6/mi), or about one-third the rate for heavy trucks in general (DoT, 2015a). This rate applies to the company’s entire fleet, not just the hazardous materials portion. The crash rate for the hazardous materials portion of their fleet can be expected to be less than 0.38 × 10^-6/mi owing to the extra qualifications required of drivers who transport hazardous materials and other requirements for hazardous material shipments.

Table 5-3 summarizes highway incidents in 2014 by transport phase. While the number of incidents in transit is only slightly more than about a third of those occurring during loading and unloading, they cause the majority of fatalities and monetary damages. There are over 800,000 highway

TABLE 5-3 Highway Hazardous Material Incident Summary by Transportation Phase in 2014

SOURCE: DoT, 2015b.

hazardous material shipments each day (DoT, 2004), about 300 million per year. The 15,190 incidents in 2014 represent a very small proportion of hazardous material shipments on highways. Since the contribution of hazardous material risk is small compared to general truck transportation risk, fatalities and injuries related to hazardous material cargos are frequently neglected in the face of the much greater risk of cargo-independent fatalities and injuries.

Finding 5-3. The historical risk of a hazardous material incident during transportation has been small.

Additional Risks Posed by Transporting Hydrolysate

If hydrolysate is not processed through the supercritical water oxidation (SCWO) system and is shipped offsite, BGCAPP estimates that 221 truckloads of GB hydrolysate, 40 truckloads of VX hydrolysate, 386 truckloads of energetics hydrolysate, and 842 truckloads of condensate from the offgas treatment for the metal parts treater (which would have otherwise been processed through the SCWO) would be required. However, since reverse osmosis (RO) reject water from the water recovery system would no longer be produced, offsite shipments of RO reject would not be required, thus eliminating about 5,700 shipments from those currently planned. Overall, if hydrolysate is shipped offsite for treatment, there would be about 4,200 fewer shipments of waste material from BCAPP in the case of offsite treatment of hydrolysate.³ The committee believes that additional reductions in offsite shipments are likely in the case of offsite hydrolysate shipment, owing, for example, to the lack of aluminum filter cake to be transported, but those data were not provided. Other shipments required for BGCAPP operations, for example, caustic for the production of hydrolysate, would be essentially unchanged. To put these numbers in perspective, Noblis (2008) estimated the total number of shipments as 9,088 for the case of onsite treatment of hydrolysate.

As discussed in Chapters 4, 6, and 7, if SCWO performs adequately but the water recovery system fails, there is a possibility of shipping SCWO effluent offsite. In this case, the currently planned offsite shipments would change, primarily because the 5,700 RO reject shipments (30 percent of SCWO effluent) would be replaced by the shipment of the entire SCWO effluent, an increase of 70 percent of the SCWO effluent, or about 13,300 shipments. Because it is dilute brine, SCWO effluent would not pose a significant chemical toxicity hazard should a release occur in transport.

The likelihood of an injury or a fatality due to a heavy truck crash, provided above, applies to both the shipments planned for onsite hydrolysate treatment and the shipments that would be necessary with offsite hydrolysate (or SCWO effluent) treatment, as does the very low risk of a hazardous material incident.

Finding 5-4. Offsite hydrolysate transport would decrease the total number of shipments from BGCAPP by a net of about 4,200 shipments, about half the shipments with onsite treatment.

Finding 5-5. Offsite shipment of the entire SCWO effluent would increase the total number of shipments from BGCAPP by about 13,300 shipments, about double the shipments for onsite treatment.

Hydrolysate shipments from NECD and BGAD were subjected to enhanced safety measures as compared with typical hazardous material shipments, including safety inspections every 2 hours or so while on the road (Veolia, 2009). The same safety measures can be expected if hydrolysate is shipped from BGCAPP. Thus, a crash rate less than the 0.38 × 10^-6/mi cited above for a representative hazardous material transportation company can be expected for BGCAPP hydrolysate shipments. Further, a comparison of material compositions of historical hydrolysate shipments shown in Table 5-2 with anticipated compositions of the BGCAPP hydrolysates in Tables 2-1 through 2-6 provides no reason to expect any appreciable change in transportation risk due to the nature of the BGCAPP hydrolysates.

RELATED PRIOR FINDINGS AND RECOMMENDATIONS FROM NATIONAL RESEARCH COUNCIL REPORTS

The 2008 National Research Council (NRC) report Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (NRC, 2008) contained findings and recommendations relevant to the consideration of offsite transport of hydrolysate from BGCAPP. The 2008 report expressed a concern that hydrolysate-specific risks should be compared quantitatively with the cargo-independent risks from heavy trucks, rather than through a separate, independent qualitative methodology. The report pointed out that it is important to provide quantitative data to address concerns expressed about the prospect of offsite transportation. The 2008 report contained the following finding and recommendations that are applicable to BGCAPP:

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³ E-mail correspondence between John Barton, chief scientist, BPBG, and Jeff Krejsa, PE deputy site project manager, Compliance, ACWA BGCAPP, on March 11, 2015.

Finding 5-6. The findings and recommendations cited above from Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (NRC, 2008) are still relevant.

Recommendation 5-1. The transportation-related recommendations in Review of Secondary Waste Disposal Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (NRC, 2008) should be followed.

There is enough experience from transporting hydrolysate from BGAD, APG, and NECD to be able to perform a reasonable QTRA in the near term. The main piece of information still lacking for any analysis is the receiving treatment, storage, and disposal facility (TSDF). Procurement regulations may prevent the timely selection of a receiving TSDF. One option to address this is to perform a QTRA for one or more representative TSDFs. While the committee recognizes that this would entail a significant amount of work, it believes this approach would have several benefits, including these:

• Illustrating the impact of route selection on risk,
• Quantifying the relative contributions to risk from both the cargo-independent and the hydrolysate release scenarios,
• Quantifying the overall magnitude of the risk associated with hydrolysate transportation sufficiently for regulators and stakeholders to evaluate it, and
• Providing input for emergency response planning processes.

REFERENCES

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

DoT. 2014. Large Truck and Bus Crash Facts–2012, Federal Motor Carrier Safety Administration, FMCSA-RRA-14-004, June 2014. Available at http://www.fmcsa.dot.gov/safety/data-and-statistics/large-truck-andbus-crash-facts-2012.

DoT. 2015a. Company Snapshot: Bed Rock Inc. Accessed February 6, 2015. Available at safer.fmcsa.dot.gov.

DoT. 2015b. PHMSA Incident Statistics. Accessed March 11, 2015. Available at www.phmsa.dot.gov/hazmat/library/data-stats/incidents.

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

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

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

RCMD (Recovered Chemical Material Directorate). 2014. Bomblet Destruction Campaign at Rocky Mountain Arsenal. Provided to the committee by Larry Gottschalk 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.

Veolia Environmental Services. 2009. Transportation Safety and Emergency Response Plan for the Shipment of Operation Swift Solution Caustic Wastewater.