Appendix B

Historical Overview of Public Sentiment Surrounding the Blue Grass Army Depot and the Blue Grass Chemical Agent-Destruction Pilot Plant Relevant to the Disposal of Separated Rocket Motors

A review of public sentiment was not part of the committee’s task. To the extent that public sentiment is included in this report, it is included only insofar as it might impact decisions about how to dispose of the rocket motors separated from M55 rockets stored at the Blue Grass Army Depot (BGAD). The reason for inclusion is that history demonstrates that public sentiment can have a very significant effect on the ability to implement any technical decisions in the context of the disposal of chemical munitions and their associated wastes.

The purpose of this appendix is to establish the basis for the committee’s speculation, expressed in the body of the report, about how the public around BGAD might react to decisions made on disposing of the separated rocket motors. It is important to note that the committee did not speak to the public, as it was not tasked to do so. It is also important to understand that none of what follows expresses the committee’s opinions; rather, it constitutes a reporting of historical public positions the committee believes are pertinent to the topic of this report.

HISTORICAL OVERVIEW OF PUBLIC SENTIMENT REGARDING THE SELECTION OF TECHNOLOGIES FOR USE AT BGAD

Surrounding communities have a long history of interest and active involvement in plans to dispose of chemical weapons stored at BGAD. Indeed, opposition to incineration was a key factor leading to creation of the original Assembled Chemical Weapons Assessment program and the choice of a nonincineration technology for the destruction of chemical agent and associated wastes at BGAD and the Pueblo Chemical Depot. Consequently, activist members of the Kentucky Chemical Demilitarization Citizens’ Advisory Commission (CAC) and Chemical Destruction Community Advisory Board (CDCAB), which represent the local public,¹ have shared an opposition to

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¹For a detailed description of the composition and role of the CAC and CDCAB, see NRC (2008). The two groups, which at that time were operating somewhat independently, now meet together on a quarterly basis. Meeting summaries and recommendations are available at http://www.pmacwa.army.mil/bgcapp/bgcapp_public_involvement.html.

incineration. They also share the belief that the Record of Decision,² which specified neutralization followed by SCWO as the technologies for Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP), represents a “commitment to the community” to use those technologies to dispose of as much material on-site as possible (NRC, 2008).³

In opposing incineration, activist groups established criteria by which they judge alternative technologies for destroying not only chemical weapons but hazardous wastes in general. Among these criteria are:

• Containment of all by-products,
• Identification of all by-products,
• No uncontrolled releases, and
• A series of criteria pertaining to worker safety (Crowe and Schade, 2002).

In 2006, following the fires experienced during M55 rocket shearing operations at the Umatilla and Pine Bluff Chemical Agent Disposal Facilities, the CDCAB Secondary Waste Working Group met and was briefed by the Non-Contaminated Rocket Motors Integrated Process Team, which presented options on behalf of the Bechtel Parsons Blue Grass Team for the disposal of separated rocket motors.⁴ Three options were presented:

• On-site nondeflagration technologies–for example, (1) caustic hydrolysis of the propellant, followed by supercritical water oxidation (SCWO), (2) wet grinding of the propellant followed by SCWO, and (3) caustic hydrolysis of the propellant, followed by biotreatment of the energetics hydrolysates;
• On-site deflagration technologies–for example, (1) contained static fire, (2) contained burn, and (3) use of a Static Detonation Chamber (SDC)⁵; and
• Off-site processes–for example, (1) caustic hydrolysis of the propellant and the off-site disposal of the energetic hydrolysates, (2) wet grind of the propellant, followed by off-site recycling, and (3) incineration.

Among these options, the CDCAB is on record as recommending, in order of preference, the following:

• On-site caustic hydrolysis of the propellant followed by treatment of the hydrolysates by industrial SCWO and
• Off-site recycling of the propellant at a government facility (CDCAB, 2006).

²Record of decision, Chemical Stockpile Disposal Project, destruction of the chemical agents and munitions stored at Blue Grass Army Depot, Kentucky, signed by Raymond J. Fatz, Deputy Assistant Secretary of the Army (Environment, Safety, & Occupational Health), dated February 27, 2003.

³As noted in NRC, 2008, public sentiment is not uniform: the CAC and CDCAB may not represent the totality of public sentiment, and a substantial portion of the community was reported in that study as simply supporting prompt elimination of the chemical agent stockpile.

⁴The Bechtel Parsons Blue Grass Team is the team of contractors who designed, are building, and will operate, close, and dismantle BGCAPP.

⁵This technology, from the vendor Dynasafe AB, is discussed in Chapter 3.

Subsequently, the joint CAC/CDCAB added another recommendation to continue studying the use of the SDC for only those rocket motors that are not contaminated by chemical agent, based on the SDC “emerging as a new, on-site treatment option” (CDCAB, 2007).

More recent discussion in the public record focused on disposal of the rocket motors is limited. No recent public record is available regarding use of any nonhydrolysis technologies (i.e., any technologies other than those already in the BGCAPP design) other than an explosive destruction technology (EDT). An EDT Working Group⁶ examined the possible use of four types of EDT for disposing of three categories of items, including separated rocket motors that had not been contaminated with chemical agent. The four EDTs considered were these:

• The Transportable Detonation Chamber (from CH2M HILL);
• The Detonation of Ammunition in a Vacuum-Integrated Chamber) (DAVINCH ) (from Kobe Steel, selected for use at the Tooele Chemical Agent Disposal Facility, though not for separated rocket motors);
• The SDC (from Dynasafe AB, at that time selected for use at the Anniston Chemical Agent Disposal Facility, again, not for separated rocket motors); and
• The EDS (produced by Sandia National Laboratories for the Program Manager for Non-Stockpile Chemical Materiel).

Since 2009, the CAC/CDCAB has issued two sets of positions or recommendations concerning use of an EDT at the BGCAPP, or at BGAD in support of BGCAPP operations. First, in December 2009, the CAC/CDCAB indicated that they would be willing to consider the use of an EDT to dispose of three categories of munitions, including separated rocket motors that had not been contaminated with chemical agent. They did place a number of caveats on this position, including

• Reserving the endorsement of any EDT until its capabilities and compliance with Kentucky state environmental regulations had been demonstrated to the satisfaction of the CAC/CDCAB;
• Insisting on playing an active role in the prioritization of evaluation criteria for selecting an EDT;
• Using an EDT to dispose of any actual nerve agent, such as contaminated rocket parts, is absolutely opposed, with the possible exception of overpacked nerve agent munitions and nerve agent munitions in a condition that would required significant handling to process through BGCAPP; and

⁶This group was originally established in 2009. It was reestablished in 2011 at the request of the BGCAPP site project manager, who noted that “several factors are important to the destruction process selection, the current design has limitations of unknown capacity and the ACWA Program will work with the EDT Working Group to receive input on considerations for the final EDT decision” (CDCAB, 2011, p. 6). The site project manager’s presentation to the CAC/CDCAB of the EDTs in December 2011 as a “potential method to augment the basic destruction plans for BGCAPP” (CDCAB, 2011, p. 6) is available on the Web site. However, as of this writing, the related CAC/CDCAB discussion had not yet been posted.

• Bringing permitting issues to the public’s attention in a timely manner, even going beyond the letter of what the law requires, to ensure that the public is adequately involved in the permitting process (CDCAB, 2009).

Second, in January 2012, following re-formation of the EDT Working Group, the CAC/CDCAB issued another recommendation on the use of the EDT at BGCAPP. They recommended its use to dispose of “problem” mustard heels, with caveats similar to those articulated in their 2009 statement (above) and with the addition of the following comments:

• The KY CAC/CDCAB believes the deployment and use of the EDT at the Anniston Chemical Demilitarization Facility (ANCDF) fulfills many of the requirements of KRS 224.50-130 (3) (a)). However, there remain questions concerning whether the experience at Anniston sufficiently demonstrates the ability to meet the following requirement within the section: “During the occurrence of malfunctions, upsets, or unplanned shutdown, all quantities of any compound listed in subsection (2) of this section shall be contained, reprocessed or otherwise controlled so as to ensure that the required efficiency is attained prior to any release to the environment.” (CDCAB, 2012, pp. 1-2)
• The CAC/CDCAB wants to see a “continuous investigation of the hold-test-release capabilities of potential agent emissions with any EDT considered for the Blue Grass disposal effort, while recognizing that such investigations should not be allowed to significantly impact EDT deployment.” (CDCAB, 2012, p. 2)

These more recent recommendations indicate provisional support for the use of an EDT for very specific applications on the part of organized public groups, specifically when they deem it is warranted to reduce the risk to workers and are convinced that the process can be conducted safely and in compliance with Kentucky regulations. Consequently, the use of an EDT for the separated rocket motors might prove acceptable to the public. Still, there are many caveats and conditions, and it is clear that further engagement with the public groups around BGAD will likely be necessary to ensure that they are comfortable with the use of an EDT or other contained disposal technology to dispose of separated rocket motors at BGAD.

HISTORICAL OVERVIEW OF PUBLIC SENTIMENT ON THE ISSUE OF ON-SITE VERSUS OFF-SITE DISPOSAL

Separated rocket motors would be a waste derived from a chemical munition. Public sentiment about where the wastes derived from chemical munitions should be disposed of is closely intertwined with support for the technology selection of hydrolysis

followed by SCWO, identified in the 2003 Record of Decision.⁷ A joint Colorado and Kentucky CAC public statement emphasized that their long-standing opposition to shipment off-site of any wastes derived from chemical agent or munitions is based on a number of factors, including the following:

• A perception on the part of the CACs of increased risks associated with transporting these wastes off-site;
• Concern about possible opposition from communities that would be receiving wastes;
• Concern about a negative economic impact on the communities around BGAD and the Pueblo Chemical Depot;
• Political opposition;
• The possibility of litigation;
• Concern about a risk of violating the site’s Resource Conservation and Recovery Act permit by changing the permitted processes; and
• The CACs’ concern about possibly violating environmental justice principles;⁸ and
• The elimination of a potential legacy use for on-site treatment facilities that would be left over at BGAD following the completion of BGCAPP operations. (CAC, 2008).

Members of the Kentucky and Colorado CACs have expressed the intent to use political influence, the permitting process, and legal action to prevent, or at a minimum delay, the program schedule in the event of a decision to implement off-site shipment of secondary wastes, of which separated rocket motors are one example (NRC, 2008).

Nevertheless, as with treatment technologies, the CAC/CDCAB has been willing to recognize the need for flexibility when faced with countervailing arguments, especially those concerning potential risks to workers and the general public. In fact, when Operation Swift Solution⁹ was implemented to dispose of three leaking ton containers of GB, the shipment of the resulting hydrolysates off-site was approved as a necessary measure for safety reasons. Still, the CAC/CDCAB is on record as stating as follows:

Tolerating this one time, off-site shipment of material the CAC/CDCAB does not in any way imply support for, the condoning of, or even consideration of any future similar shipments of similar materials off site associated with the Blue Grass Chemical Agent Pilot Plant (BGCAPP). (CDCAB, 2008, p. 1)

So, while it is clear that there are circumstances in which the local public organizations will tolerate the shipment off-site of wastes resulting from the disposal of chemical

⁷Record of decision, Chemical Stockpile Disposal Project, destruction of the chemical agents and munitions stored at Blue Grass Army Depot, Kentucky, signed by Raymond J. Fatz, Deputy Assistant Secretary of the Army (Environment, Safety, & Occupational Health), dated February 27, 2003.

⁸There is a concern that receiving communities and communities along shipping routes may already be economically disadvantaged and thus subject to environmental injustice by wastes from BGCAPP.

⁹For more information on Operation Swift Solution, see https://www.pmacwa.army.mil/bgcapp/swift_solution.html.

munitions, such toleration is accompanied by caveats and a significant level of concern. It can be anticipated that any proposal to transport separated rocket motors off-site for disposal will meet a similar level of concern from the public organizations around BGAD unless they can be satisfied of the necessity for such a course of action and its safety.

REFERENCES

CAC (Citizen’s Advisory Commissions). 2008. Statement Presented by the Colorado and Kentucky Chemical Demilitarization Citizen’s Advisory Commissions Regarding Off-Site Hydrolysate Treatment from ACWA Sites, November 20. Available online at https://www.pmacwa.army.mil/info/dl/9_nrc_noblis_statement_nov2008.pdf. Last accessed June 13, 2012.

CDCAB (Chemical Destruction Community Advisory Board). 2006. CDCAB Secondary Waste Working Group/CAC Recommendation on Non-Contaminated Rocket Motor Disposal Options, January 16. Available online at https://www.pmacwa.army.mil/info/dl/2_CDCAB_NCRM_Recommendation_January_2006.pdf. Last accessed June 13, 2012.

CDCAB. 2007. Recommendations for Treatment of Non-Contaminated Rocket Motors, October 8. Available online at https://www.pmacwa.army.mil/info/dl/5_Recommendations_non-contam_rocket_motors_Oct_2007.pdf. Last accessed June 13, 2012.

CDCAB. 2008. Recommendations of the KY CAC and CDCAB to ACWA on Secondary Waste Resulting from Operation Swift Solution, October 17. Available online at https://www.pmacwa.army.mil/info/dl/7_Recommendations_OSS_Waste_October_2008.pdf. Last accessed June 13, 2012.

CDCAB. 2009. “Bridging the Gap” with EDT @ BGAD, December 14. Available online at https://www.pmacwa.army.mil/info/dl/10_CDCAB_EDT.pdf. Last accessed June 13, 2012.

CDCAB. 2011. Chemical Demilitarization Citizens’ Advisory Commission (CAC) and Chemical Destruction Community Advisory Board (CDCAB) Meeting Summary of Action Items and Discussions. September 13. Available online at https://www.pmacwa.army.mil/info/dl/Sept_2011_CAC_CDCAB_Meeting_Summary_%2017_Oct_2011_Final.pdf. Last accessed June 18, 2012.

CDCAB. 2012. EDT @ BGCAPP, January 31. Available online at https://www.pmacwa.army.mil/info/dl/KY_CDCAB_EDT_Rec_12.pdf. Last accessed June 13, 2012.

Crowe, E., and M. Schade. 2002. Learning Not to Burn, A Primer for Citizens on Alternatives to Burning Hazardous Waste, June. Available online at http://www.cwwg.org/learningnottoburn.pdf. Last accessed June 18, 2012.

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.: National Academies Press.

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