Initial Closure Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants Letter Report (2020) / Chapter Skim
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Initial Closure Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
Initial Closure Planning for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants
Pages 3-36
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It highlights that many closure-related wastes may be classified as hazardous wastes based on the presence of chemical agents or other characteristics, although certain exemptions may apply, such as for debris that has been decontaminated or scrap metal that is recycled.
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. These plants use chemical neutralization to destroy chemical agent.
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Statement of Task Drawing on previous National Academies reports that addressed the closure of chemical agent disposal facilities, and on information that will be provided by PEO ACWA, the committee will: • Identify lessons learned, significant risks, or issues that arose during the closure of Chemical Materials Agency (CMA) 1 chemical agent disposal facilities that would be applicable to the closure of PCAPP and BGCAPP, including the treatment of hydrolysates and liquid secondary wastes.
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, but because there were several tenants on Johnston Atoll and several distinct federal agencies involved, formal closure took some time after that point. NOTE: ABCDF, Aberdeen Chemical Agent Disposal Facility ; ANCDF, Anniston Chemical Agent Disposal Facility; JACADS, Johnston Atoll Chemical Agent Disposal System; NECDF, Newport Chemical Agent Disposal Facility; PBCDF, Pine Bluff Chemical Agent Disposal Facility; TODCF, Tooele Chemical Agent Disposal Facility; UMCDF, Umatilla Chemical Agent Disposal Facility.
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4 E-mail communication between Jeffrey L Brubaker, technical advisor to the site project manager, Blue Grass Chemical Agent Destruction Pilot Plant (BCAPP)
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tons of mustard agent, or 3.61 percent of the chemical agent stockpile stored at BGAD. 7 Closing PCAPP and BGCAPP Closing PCAPP and BGCAPP, while conceptually similar to legacy facility closure operations, will be more complex.
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; 9 • PCAPP and BGCAPP permits and a wide variety of regulatory information; and • PEO ACWA closure guidance for PCAPP and BGCAPP. 10 8 Briefings from the Johnston Atoll Chemical Agent Disposal System closure final integrated product team meeting on September 9-10, 2003, in San Francisco, Calif.
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Recommendation 1. PEO ACWA should continue to use the lessons learned from previous closure activities to plan for the closure of PCAPP and BGCAPP.
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Residual agent can persist in occluded spaces, which can include cracks, crevices, pores, and absorptive materials such as organic polymers, posing the potential for unanticipated contamination in waste materials. PEO ACWA has defined specific criteria for categorizing waste materials as contaminated, potentially contaminated, and never contaminated (clean)
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17 At PCAPP, the decontamination strategy reflects implementation of the overall PEO ACWA guidance (CDPHE, 2018, Attachment I) : • Elimination of fluids; • Removal of components and equipment too complex for disassembly; • Exposure of occluded spaces; • Surface decontamination; • Thermal decontamination using the thermal treatment technologies at the sites, e.g., the MPT, MTU, and SDC; • Scabbling of concrete floors; and • Removal of sumps and trenches.
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In addition to permitted uses, thermal decontamination using the MTU and MPT are frequently referenced as the fallback decontamination approach for difficult-to-decontaminate items. The quantity of objects needing decontamination and their sizes are such that the capacity and throughput of the thermal treatment units may be inadequate for the timely decontamination of the waste items and materials.
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As part of the study, PCAPP and BGCAPP staff should identify all items that could be processed by thermal treatment, any disassembly necessary for larger equipment to fit into the thermal treatment units, and an estimate of throughput. PEO ACWA should also evaluate modifications to the environmental permits to enable the increased use of the thermal treatment units for decontamination of a broader range of contaminated materials and the overall impact of expanded thermal decontamination to the closure process.
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Significant experience was gained in SDC decontamination conducted at ANCDF. PCAPP and BGCAPP plant staff should conduct a detailed study of the Anniston Chemical Agent Disposal Facility decontamination efforts and develop a decontamination approach that accounts for difficulties similar to those encountered previously.
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The approach adopted by PEO ACWA is the unventilated monitoring test, in which a plastic enclosure, also known as a tent, encloses a putatively contaminated object and the system is then heated to 70°F if the ambient temperature is below that. The agent is allowed time to partition into the tent atmosphere, ostensibly reaching equilibrium.
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WORKER SAFETY AND INDUSTRIAL HYGIENE Overarching Worker Safety and Industrial Hygiene Assumptions and Best Practices As the facility owner, PEO ACWA has an obligation to ensure that all individuals on the site -- program personnel, contractors, sub-contractors, and visitors -- are clear about the site hazards and are familiar with their roles and what they need to do during both normal and emergency situations. Safety is only as strong as the weakest link in the safety culture.
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The continuous and persistent involvement of management in safety, from actions to prevent safety incidents to the investigation and tracking of safety incidents, has created the current safety culture and ensured good operational outcomes for the chemical demilitarization program to date by: • Making safety the first consideration of all activities; • Daily management participation in safety activities, including daily meetings to review work that is planned and underway and any documentation changes; • Management review of the results of all incident investigations and work pauses; • Collaboration among program and contractor leadership to make safety metrics readily available for review by management and workers; and • Encouraging high levels of participation in safety efforts by all site personnel. A best practice identified from the closure of PBCDF is that all changes to plant-related documents were communicated daily to all personnel via e-mail and were posted to the PBCDF website.
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Each site contributed important pieces to the methods used at subsequent sites for decontamination of equipment and surfaces potentially exposed to chemical agents. The PCAPP and BGCAPP closure plans will determine the requirements for the deconstruction or demolition of buildings, the final disposition of the wastes generated during these operations, and the final state of any surrounding utilities and the ground.
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Any cutting performed manually will need to account for hazards due to the potential aerosolization of residual agent or other hazardous contaminants during the cutting process. Thus, to be effective, closure work packages need to be comprehensive, including the following: • Job hazards analyses; • Experiences and data from previous closures; • Instructions from equipment vendors about how to best disassemble equipment; • A determination of what equipment will need to be cut up; and • Clear instructions for when to pause or stop work.
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Finding 11b. There appears to be an effective relationship between PEO ACWA and the contract labor force at both PCAPP and BGCAPP.
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These hazards are addressed in practice with a combination of management controls, medical monitoring, and PPE. Agent Hazards The determination of the potential for exposure to agent is accomplished via air monitoring and the Army methods of detecting surface contamination on materials as outlined in the section "Decontamination and Hazardous Wastes," earlier in this document.
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One example would be the potential for agent to leak through pump seals into the lubricating oil. The requirements for worker PPE to protect against chemical agent are detailed in U.S.
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During closure, plant management should ensure that health and safety hazards associated with materials, other than agent, receive adequate attention. Workers who will have potential exposures to silica and lead should receive appropriate medical monitoring, as laid out in the Occupational Safety and Health Administration regulations 29 CFR 1926.1153 and 1926.62, respectively.
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37 Closure Requirements The federal and state regulations require hazardous waste facilities in general -- and facilities managing chemical munitions that qualify as hazardous wastes in particular -- to be closed in a manner that controls, minimizes, or eliminates postclosure releases of hazardous wastes or hazardous constituents as necessary to protect human health and the environment. 38 Additional requirements apply to particular types of hazardous waste management units, such as container storage areas, tank systems, containment buildings, and miscellaneous treatment units.
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42 After closure is ultimately completed, a professional engineer must certify that the facility was closed in accordance with the specifications in the approved closure plan, and documents supporting the certification must be submitted to regulatory authorities upon request. 43 During the closure of other chemical agent disposal facilities, it was found that early and frequent communications with regulators and the professional engineer, who would be providing the closure certification, as well as careful documentation of such communications, were important in ensuring timely modifications to the closure plans and eventual certification of closure.
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and to obtain regulatory authority approval for these planning documents well before chemical agent disposal facility closure begins, so as not to impede closure plans for the chemical agent disposal facilities. In addition, closure activities should be coordinated." 46 See 40 C.F.R.
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54 However, certain aspects of the state regulations may depart from these general requirements for environmental media and debris as they relate to closure wastes at PCAPP and BGCAPP. As noted above, the Colorado regulations specifically list soil, water, debris, and containers contaminated with chemical agents or their treatment derivatives as hazardous wastes (K902)
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. However, while other chemical agent disposal facilities have been able to take advantage of the scrap metal exclusions or exemptions during closure, some of those facilities have found recycling of scrap metal to be a challenge.
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Kentucky Chemical Agent Treatment Requirements Kentucky law generally requires that facilities treating or disposing of chemical agents provide assurance that each of the relevant agents (i.e., VX, GB, and H) will be treated to a destruction or neutralization and removal efficiency (DRE)
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Importantly, many of these treatment standards require not only removal of the hazardous waste characteristics but also treatment of all "underlying hazardous constituents" until they are below certain "universal treatment standard" levels. 67 Thus, closure-related wastes may need to be treated to meet stringent standards for a variety of metals and organic constituents other than the chemical agents.
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69 The EPA has issued an exception for "[w] aste military munitions that are chemical agents or chemical munitions," but the Kentucky regulations explicitly reject that exception and the Colorado regulations do not include a comparable exception.
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BGCAPP management should study the extent to which the facility may become subject to Toxic substances Control Act closure requirements as a result of treatment of polychlorinated biphenyl-contaminated shipping and firing tubes, and modify the facility closure plans if necessary. CONCLUSION PEO ACWA has extensive experience gained from the successful closure of multiple legacy chemical demilitarization plants.
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PEO ACWA should also evaluate modifications to the environmental permits to enable the increased use of the thermal treatment units for decontamination of a broader range of contaminated materials and the overall impact of expanded thermal decontamination to the closure process. Recommendation 5.
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Recommendation 11. PEO ACWA should continue its effective relationship with contract labor, discuss the transition to closure activities.
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BGCAPP management should study the extent to which the facility may become subject to Toxic substances Control Act closure requirements as a result of treatment of polychlorinated biphenyl-contaminated shipping and firing tubes, and modify the facility closure plans if necessary.
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