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Disposal Options for the Rocket Motors From Nerve Agent


Rockets Stored at Blue Grass Army Depot

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ISBN 978-0-309-26045-9 | DOI 10.17226/13439

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Disposal Options for the Rocket Motors from Nerve


Agent Rockets Stored at Blue Grass Army Depot

Committee on Disposal Options for the Rocket Motors of Nerve Agent Rockets at Blue
Grass Army Depot

Board on Army Science and Technology

Division on Engineering and Physical Sciences

THE NATIONAL ACADEMIES PRESS


Washington, D.C.
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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

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NOTICE: The project that is the subject of this report was approved by the Governing Board
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Medicine. The members of the committee responsible for the report were chosen for their
special competences and with regard for appropriate balance.

This study was supported by Contract/Grant No. W911NF-12-01-0075 between the National
Academy of Sciences and the U.S. Army. Any opinions, findings, conclusions, or
recommendations expressed in this publication are those of the author(s) and do not
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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

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iii

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

COMMITTEE ON DISPOSAL OPTIONS FOR THE ROCKET MOTORS OF


NERVE AGENT ROCKETS AT BLUE GRASS ARMY DEPOT

RANDAL J. KELLER, Chair, Murray State University, Murray, Kentucky


JUDITH BRADBURY, Consultant, Knoxville, Tennessee
RANDALL J. CRAMER, Navy Ordnance Environmental Support, Indian Head,
Maryland
ERIC D. ERICKSON, Naval Air Warfare Center, China Lake, California
BRAD E. FORCH, U.S. Army Research Laboratory, Research, Development and
Engineering Command, Aberdeen Proving Ground, Maryland
SCOTT E. MEYER, Purdue University, West Lafayette, Indiana
BOBBY L. WILSON, Texas Southern University, Houston, Texas

Staff

BRUCE BRAUN, Director, Board on Army Science and Technology


JAMES C. MYSKA, Senior Research Associate, Study Director
DEANNA SPARGER, Program Administrative Coordinator

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

BOARD ON ARMY SCIENCE AND TECHNOLOGY

ALAN H. EPSTEIN, Chair, Pratt & Whitney, East Hartford, Connecticut


DAVID M. MADDOX, Vice Chair, Independent Consultant, Arlington, Virginia
DUANE ADAMS, Independent Consultant, Arlington, Virginia
ILESANMI ADESIDA, University of Illinois at Urbana-Champaign
MARY E. BOYCE, Massachusetts Institute of Technology, Cambridge
EDWARD C. BRADY, Strategic Perspectives, Inc., Fort Lauderdale, Florida
W. PETER CHERRY, Independent Consultant, Ann Arbor, Michigan
EARL H. DOWELL, Duke University, Durham, North Carolina
JULIA D. ERDLEY, Pennsylvania State University, State College
LESTER A. FOSTER, Electronic Warfare Associates, Herndon, Virginia
JAMES A. FREEBERSYSER, BBN Technology, St. Louis Park, Minnesota
RONALD P. FUCHS, Independent Consultant, Seattle, Washington
W. HARVEY GRAY, Independent Consultant, Oak Ridge, Tennessee
JOHN J. HAMMOND, Lockheed Martin Corporation (retired), Fairfax, Virginia
RANDALL W. HILL, JR., University of Southern California Institute for Creative
Technologies, Playa Vista
JOHN W. HUTCHINSON, Harvard University, Cambridge, Massachusetts
MARY JANE IRWIN, Pennsylvania State University, University Park
ROBIN L. KEESEE, Independent Consultant, Fairfax, Virginia
ELLIOT D. KIEFF, Channing Laboratory, Harvard University, Boston, Massachusetts
WILLIAM L. MELVIN, Georgia Tech Research Institute, Smyrna
ROBIN MURPHY, Texas A&M University, College Station
SCOTT PARAZYNSKI, University of Texas Medical Branch, Galveston
RICHARD R. PAUL, Independent Consultant, Bellevue, Washington
JEAN D. REED, Independent Consultant, Arlington, Virginia
LEON E. SALOMON, Independent Consultant, Gulfport, Florida
JONATHAN M. SMITH, University of Pennsylvania, Philadelphia
MARK J.T. SMITH, Purdue University, West Lafayette, Indiana
MICHAEL A. STROSCIO, University of Illinois, Chicago
DAVID A. TIRRELL, California Institute of Technology, Pasadena
JOSEPH YAKOVAC, JVM LLC, Hampton, Virginia

Staff

BRUCE A. BRAUN, Director


CHRIS JONES, Financial Associate
DEANNA P. SPARGER, Program Administrative Coordinator

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

vi

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Preface
The Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP), under the
management of the Program Executive Officer for Assembled Chemical Weapons
Alternatives (PEO ACWA), is responsible for destroying the chemical weapons
stockpiles currently being stored at the Blue Grass Army Depot (BGAD) and the Pueblo
Chemical Depot. The BGAD stockpile consists of 523 tons of mustard agent loaded in
projectiles and nerve agents GB and VX loaded in both projectiles and rockets. The
rocket portion of the stockpile at BGAD consists of approximately 70,000 M55 rockets.
BGCAPP will destroy the M55 rockets in a process where the first step will be to cut the
rocket and separate it into the rocket warhead and the rocket motor. The rocket warhead
will be destroyed at BGCAPP by chemical neutralization followed by supercritical water
oxidation. Although the BGCAPP facility will have the capability for destroying an entire
M55 rocket, owing to a design change in the mid-2000s the separated rocket motors will
be disposed of at a place other than BGCAPP.
Disposing of the separated rocket motors outside of BGCAPP presents some
unique safety and environmental challenges, so the PEO ACWA asked the National
Research Council (NRC) to conduct a study to offer guidance on technologies and
options for the disposal of the separated rocket motors. The committee that was
assembled by the NRC held a number of meetings, a virtual meeting, and
teleconferences. It also visited the BGCAPP project offices in Richmond, Kentucky.
The focus of this report is on the potential sites and technologies that might be
used to dispose of the separated rocket motors outside of BGCAPP. These options
include treatment and disposal on-site at BGAD or off-site at a commercial or
governmental facility. Potential technologies, primarily thermal and chemical, that could
be used to dispose of the separated rocket motors are discussed. The report also addresses
safety, storage, throughput, and transportation.
As chair of this committee, I want to express my sincere thanks to the members of
the committee for their work on this report. Their expertise in energetics as well as their
experience with the safe disposal of conventional munitions was invaluable in addressing
the statement of task. I would also like to thank James Myska, senior research associate at
the Board on Army Science and Technology, and Bruce Braun, director of the Board on
Army Science and Technology, for their contributions in running this study. Mr. Myska
did an outstanding job on this project. He mastered the subject matter, kept the committee

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

focused on the statement of task, and ensured that the writing was concise and
accomplished in a timely manner. Lastly, I want to thank Deanna Sparger for her
invaluable administrative and research support to the committee.

Randal J. Keller, Chair


Committee on Disposal
Options for the Rocket Motors
of Nerve Agent Rockets at
Blue Grass Army Depot

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Acknowledgments

This report has been reviewed in draft form by individuals chosen for their
diverse perspectives and technical expertise, in accordance with procedures approved by
the National Research Councils (NRCs) Report Review Committee. The purpose of this
independent review is to provide candid and critical comments that will assist the
institution in making its published report as sound as possible and to ensure that the
report meets institutional standards for objectivity, evidence, and responsiveness to the
study charge. The review comments and draft manuscript remain confidential to protect
the integrity of the deliberative process. We wish to thank the following individuals for
their review of this report:

Ruth Doherty, Naval Surface Warfare Center,


Rebecca Haffenden, Argonne National Laboratory,
Jeffrey L. Lee, U.S. Army Research, Development and Engineering Command,
Hyla Napadensky, Independent Consultant,
James Neidert, U.S. Army Aviation and Missile Development and Engineering
Center,
Carol A. Palmiotto, E.I. du Pont de Nemours & Company,
Stanley Sandler (NAE), University of Delaware,
Leonard Siegel, Center for Public Environmental Oversight, and
Stefan Thynell, Pennsylvania State University.

Although the reviewers listed above have provided many constructive comments
and suggestions, they were not asked to endorse the conclusions or recommendations nor
did they see the final draft of the report before its release. The review of this report was
overseen by Royce W. Murray (NAS). Appointed by the National Research Council, he
was responsible for making certain that an independent examination of this report was
carried out in accordance with institutional procedures and that all review comments were
carefully considered. Responsibility for the final content of this report rests entirely with
the authoring committee and the institution.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Copyright National Academy of Sciences. All rights reserved.


Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Contents

SUMMARY 1

1 INTRODUCTION 7
Statement of Task, 10
The Committee, Report Scope, and Process, 10
Overview of Report, 11
References, 12

2 SAFETY 13
Energetics Safety Issues, 13
Electrical Safety, 17
Lead, 18
References, 18

3 TECHNOLOGIES FOR ROCKET MOTOR DISPOSAL 21


Recycling Options, 21
Overview of Disposal Technologies, 22
Thermal Technologies, 23
Open Thermal Technologies, 23
Open Detonation, 23
Buried Detonation, 24
Open Burning, 24
Open Static Firing, 25
Contained Thermal Technologies, 26
Contained Detonation, 26
Contained Combustion, 26
Contained Static Firing, 27
Confined Combustion, 27
Other Thermal Disposal Technologies, 28
Chemical Technologies, 29
Base Hydrolysis, 29
Supercritical Water Oxidation, 29
Humic Acid Treatment, 30
Summary, 30
References, 38

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

4 STORAGE OF SEPARATED ROCKET MOTORS 41


The Need for Storage Space for Separated Rocket Motors, 41
Requirements for Storage of Separated Rocket Motors, 42
Creating Additional Storage Space at the Blue Grass Army Depot, 42
Returning Separated Rocket Motors to the M55 Rocket Storage Igloos, 44
Propellant Degradation, Stabilizer Depletion, and Storage Risk, 44
References, 45

5 OPTIONS FOR DISPOSAL OF SEPARATED ROCKET MOTORS 47


On-site Disposal Options, 47
Open-Burning of Propellant Grain at the BGAD Permitted Facility, 47
Use of the Existing D-100 Detonation Chamber at BGAD, 49
Alternative Disposal Technologies That Could Be Added to BGAD
Capabilities, 51
Disposal of Separated Rocket Motors at BGCAPP after Completion of All
Chemical Agent Destruction Operations, 52
Public Sentiment, 52
Off-site Disposal Options, 53
Public Sentiment, 55
Shipping and Firing Tube Management, 55
Transportation of Separated Rocket Motors, 57
On-site Transportation of Separated Rocket Motors, 57
Off-site Transportation of Separated Rocket Motors, 58
Advantages and Disadvantages of On-site Separated Rocket Motor Disposal, 60
Advantages and Disadvantages of Off-site Separated Rocket Motor Disposal, 61
References, 62

APPENDIXES

A Glossary, 67
B Historical Overview of Public Sentiment Surrounding the Blue Grass Army Depot
and Blue Grass Chemical Agent-Destruction Pilot Plant Relevant to the Disposal
of Separated Rocket Motors, 69
C Committee Activities, 77
D Biographical Sketches of Committee Members, 79

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Tables and Figures


TABLES

1-1 Time-Weighted Average Maximum Exposure Limits, 8

2-1 Nominal Composition of M28 Propellant, 14


2-2 Hazard Classifications Applied to Explosive Materials, 14

3-1 Technology Comparison, 32


3-2 Technology Status and Applicability, 37

FIGURES

1-1 Simplified diagram of an M55 rocket in its shipping and firing


tube, showing where the tube and rocket will be cut, 8
1-2 Cutaway depiction of an M55 rocket in flight configuration with
fins deployed, 8
1-3 Simplified layout of a separated rocket motor showing its major
components, 9

4-1 Diagram showing the importance of storage for the disposal of


separated rocket motors, 41

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Abbreviations and Acronyms


BGAD Blue Grass Army Depot
BGCAPP Blue Grass Chemical Agent Disposal Pilot Plant

CAC Citizens Advisory Commission


CDCAB Chemical Destruction Community Advisory Board

DAVINCH Detonation of Ammunition in a Vacuum Integrated Chamber


DoD Department of Defense

EDS explosive destruction system


EDT explosive destruction technology
EONC enhanced on-site container
EPA Environmental Protection Agency
ESD electrostatic discharge

GB a nerve agent, also known as sarin


GPL general population limit

HAWG hazards analysis working group


HERO hazards of electromagnetic radiation to ordnance

KAR Kentucky Administrative Rules


KDEP Kentucky Department for Environmental Protection
KRS Kentucky Revised Statutes

MPPEH materials potentially presenting an explosive hazard

PCB polychlorinated biphenyl


PEO ACWA Program Executive Officer for Assembled Chemical Weapons
Alternatives
POP performance oriented packaging

RCRA Resource Conservation and Recovery Act

SCWO supercritical water oxidation


SDC Static Detonation Chamber, manufactured by Dynasafe AB
SFT shipping and firing tube
SOP standard operating procedure
STEL short-term exposure limit

TSCA Toxic Substances Control Act

VX a nerve agent

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Summary

This report responds to a request by the Program Executive Officer for Assembled
Chemical Weapons Alternatives (PEO ACWA) that the National Research Council
examine and evaluate options for disposal of the motors that will be separated from
approximately 70,000 M55 rockets stored at the Blue Grass Army Depot (BGAD) that
are not contaminated by the chemical nerve agent contained in the rocket warheads. The
Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) will be responsible for
destroying the chemical weapons stockpile currently being stored at BGAD. BGCAPP
was designed to separate M55 rockets into warhead and motor sections and process the
chemical agent warhead portion. However, BGCAPP is not designed to dispose of all of
the separated rocket motors.1 This report evaluates the potential technologies and options
that could be used to dispose of the separated rocket motors at a location other than
BGCAPP: either on-site (at BGAD) or off-site (away from BGAD).
It is important to note that, as per the statement of task, this report deals solely
with separated rocket motors that will have been monitored to ensure there is no agent
present above the short term exposure limit and cleared for transportation and disposal
off-site. Any separated rocket motors that are determined to be contaminated by agent
above the short-term exposure limit will be processed at BGCAPP. In this summary, the
committee presents what it believes are its most significant findings and
recommendations.
The committee was composed largely of members with expertise in the
destruction of conventional munitions. Accordingly, much of this report addresses the
safety risks that must be taken into account when handling and disposing of the separated
rocket motors. There are numerous safety risks that can impact the disposal of the
separated rocket motors because they contain aged and degraded energetic materials,
specifically the M28 propellant. The M55 rockets were manufactured between 1961 and
1965, meaning that the M28 propellant was between 47 and 51 years old when this report
was prepared. Due to aging and degradation, the M28 propellant may have become more
sensitive to shock and thermal conditions. The separated rocket motors will also be more
exposed to environmental conditions, such as heat and humidity, than they were as part of
an assembled rocket. This could accelerate propellant degradation and increase the safety
risks. Measures can be taken, however, to address the risk of accelerated propellant
degradation, among them using desiccant to control humidity and designing storage
boxes so that heat dissipation is adequate. In any case, the committee believes that the
separated rocket motors should be disposed of as soon as possible after rocket cutting.

1
The term separated rocket motor, as the committee uses it, is defined in Appendix A.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

The M55 rockets were designed at a time when the electromagnetic environment
was quite different from what it is todayfor example, wireless devices such as cell
phones had not yet been invented. The committee believes the process of cutting the
rocket creates a new motor configuration and could damage its electrical system, leaving
it susceptible to risks from electromagnetic emanations and electrostatic discharge. The
committee stressed that approved practices and procedures for safely handling energetic
materials need to be followed and that potential new safety risks need to be evaluated.
The committee also noted that the M28 propellant contains substances such as lead that
could pose a safety hazard depending on the destruction technology selected and how that
technology is implemented. The committee believes that a hazards analysis working
group would be an important tool to address the multiple safety concerns associated with
separated rocket motors.

Finding 2-2. The Armys 2002 M55 Rocket Assessment Summary Report for the intact
M55 rocket may not be directly applicable to the separated rocket motors. New not-
readily-apparent safety risks could emerge during demilitarization operations involving
the M55 rocket containing energetic materials.

Finding 2-5. The current hazards to the separated rocket motors posed by
electromagnetic radiation and the potential for electrostatic discharge may require
verifying the condition of the igniter system after cutting before placement in the storage
and shipping box.

Finding 2-3. Among the vitally important approved safety practices and procedures that
need to be followed in handling energetic materials are the assessment and approval of
standard operating procedures and hazard analyses. They will account for potential new
safety risks that emerge during the demilitarization process.

Recommendation 2-3. Blue Grass Chemical Agent-Destruction Pilot Plant program


staff should establish a hazards analysis working group to assess, analyze, and develop
risk mitigation practices and procedures with specific attention to energetic materials in
the overall demilitarization of the M55 rocket.

In addition to reviewing disposal technologies and options, the committee was


asked to examine the feasibility of recycling options for the M28 propellant. The
committee concluded that recycling these aged and degraded energetic materials was not
feasible based upon similar experience with conventional munitions. The committee did
find that the recycling of the metal components should be considered, provided that any
recycler takes appropriate precautions against lead exposure.

Finding 3-1. There are no practical, useful, or cost-effective means of recycling energetic
materials from the M28 propellant.

Finding 3-2. It is feasible to recycle the metal components of the separated rocket
motors.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Recommendation 3-1. The Blue Grass Chemical Agent-Destruction Pilot Plant program
staff should inform the recipient of materials for recycling of the potential for the
presence of lead or lead dust on recovered materials.

A significant portion of this report reviews the current technologies that could be
used to dispose of the separated rocket motors. These are primarily open thermal,
contained thermal, and chemical treatment options. The committee presents a comparison
of advantages and disadvantages of each technology and considers the estimate of
separated rocket motor throughput where available. The committee finds that a contained
thermal treatment technology is the best option for disposing of the separated rocket
motors.

Finding 3-4. Thermal treatment demilitarization and disposal operations performed in a


chamber require the least handling and permit treatment of product emissions. Chemical
technologies either are not mature or are not readily implementable for the disposal of the
separated rocket motors.

Finding 3-7. A contained thermal technology is the best option for disposing of the
rocket motors separated from the M55 rockets stored at the Blue Grass Army Depot.

The storage and disposal of the separated rocket motors could both be rate-
limiting factors in overall BGCAPP operations. For a variety of reasons, the disposal of
the separated rocket motors will likely proceed at a slower rate than the warhead
processing at BGCAPP. This necessitates the ability to store some number of separated
rocket motors from the time of rocket cutting until eventual disposal. The committee is
concerned that the storage space that is included in the BGCAPP design will not be
sufficient and that any mishap that interrupts the disposal of the separated rocket motors
could easily impact M55 rocket processing at BGCAPP. The committee discusses
securing additional storage space for separated rocket motors within the BGAD area,
such as converting the storage igloos in which the M55 rockets are currently stored into
explosive hazardous waste units.

Finding 4-1. The provision of adequate storage space for the separated rocket motors is
important for the overall rate of operations for M55 rocket disposal at the Blue Grass
Chemical Agent-Destruction Pilot Plant. Rocket-cutting and warhead-processing
operations would need to be slowed or halted if the combination of storage capacity and
separated rocket motor disposal could not meet the rate at which separated rocket motors
are produced.

Recommendation 4-1. Blue Grass Chemical Agent-Destruction Pilot Plant program


staff should secure additional space for storage of separated rocket motors. It is essential
that discussion with Blue Grass Army Depot staff concerning the option for securing
such additional space at the depot be given high priority.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Finding 4-4. Reusing emptied M55 rocket storage igloos for storage of separated rocket
motors is a possible solution to the problem of inadequate storage space. Pursuing this
option would entail much coordination and planning and would take time.

Recommendation 4-2. If a decision is made to pursue this option, Blue Grass Chemical
Agent-Destruction Pilot Plant program staff should prepare a plan to convert the M55
rocket storage igloos to hazardous waste storage sites that are also site-approved for the
storage of explosives. The plan should include management of the transition without the
need to submit separate approval requests one igloo at a time.

When considering storage for the separated rocket motors, it should be noted that,
owing to environmental and other factors, the storage risk may be greater for separated
rocket motors than for an intact M55 rocket. Further, owing to the new configuration of
the separated rocket motors, a new storage and transportation box may be required for
packaging the separated rocket motors.

Finding 4-5. Storage risk may increase more quickly in the case of separated rocket
motors than assembled M55 rockets because of the increased environmental exposure of
the separated motors. The effects of this environmental exposure on the separated rocket
motors have not been characterized.

Recommendation 4-3. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should dispose of separated rocket motors as soon as possible, using a first in, first out
protocol to minimize storage time and reduce risk.

It is technologically feasible to dispose of the separated rocket motors on-site (at


BGAD). BGAD currently operates an on-site open burn facility for the disposal of
conventional munitions and has an operational (though not currently operating) D-100
detonation chamber for the same purpose. Either of these could be adapted for the
disposal of separated rocket motors. It is also possible that other technologies could be
established on BGAD to dispose of the separated rocket motors. Key considerations will
be public acceptance of the technology chosen, obtaining the necessary permits, and
balancing separated rocket motor disposal with the overall BGAD workload. One
primary advantage to on-site disposal is that the transportation of the separated rocket
motors would likely be much safer than moving them over public roads and simpler as
well, since broader federal regulations would not apply because the entire process would
take place within the BGAD boundaries. Another on-site disposal option would be the
long-term storage of the separated rocket motors until BGCAPP completes all chemical
agent disposal operations, meaning the separated rocket motors would be stored for
several years if BGCAPP operations proceed as currently planned. The separated rocket
motors could then be returned to BGCAPP for disposal at whatever rate BGCAPP could
manage. The committee does not consider the last option to be the best approach in light
of propellant degradation and storage risk, which are discussed in Chapters 2, 4, and 5.

Finding 5-1. The Blue Grass Army Depot has a permitted, operational open-burning site
that might be capable of meeting separated rocket motor disposal requirements.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Finding 5-2. There are alternative disposal technologies to open burning that can be
instituted at the Blue Grass Army Depot. However, the use of these alternative
technologies would necessitate the inclusion of design, construction, and permitting time
into the project schedule.

Finding 5-3. A D-100 detonation chamber is currently operational at the Blue Grass
Army Depot to dispose of conventional munitions. It is possible that this could be
modified and permitted to dispose of the separated rocket motors. A number of other
contained technologies are available from commercial vendors, and it might prove
simpler to contract for one of these to be installed than to modify the D-100 and obtain
the necessary permit modification.

Finding 5-12. Transporting separated rocket motors solely on-site will be safer and easier
to accomplish than transporting separated rocket motors off-site.

The disposal of the separated rocket motors off-site is dependent on several


factors, including the identification of an appropriate disposal facility, satisfying the
pertinent environmental and transportation regulations, and gaining the acceptance of the
public.

Finding 5-6. There are potential technologies for the disposal of the separated rocket
motors that could be used concurrently at one or more off-site disposal facilities to meet
program requirements and schedule. Off-site disposal would increase flexibility in regard
to choice of a specific disposal technology. The Blue Grass Chemical Agent Disposal
Pilot Plant program staff would, of course, need to work with any off-site disposal facility
to ensure that all relevant environmental regulations, such as the Resource Conservation
and Recovery Act and the Toxic Substances Control Act, are complied with.

A key factor in off-site disposal is that the transportation of separated rocket


motors off-site would be subject to a greater degree of transportation regulation than on-
site transportation and would necessitate the design, approval, and procurement of
performance-oriented packaging in which to transport the separated rocket motors.

Finding 5-14. Transportation of separated rocket motors off-site must comply with
federal regulations governing the transportation of hazardous materials on public
thoroughfares, including the use of labeled performance-oriented packaging, which is
packaging that has been tested to meet anticipated environmental and transportation
stresses.

Finding 5-13. All off-site disposal options necessarily require removal of the separated
rocket motors from government property and transportation on public roads or railways.
There are numerous federal, state, and Army regulations governing the transportation of
explosive hazardous waste, permits, and safety standards that must be met.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Finally, public sentiment and acceptance will be a significant factor in the ability
to implement any technology to dispose of the separated rocket motors, as well in the
decision whether to dispose of the separated rocket motors on-site or off-site. There is a
long-standing, interested, and very knowledgeable community living and working around
BGAD. This community has successfully influenced program choices regarding
BGCAPP in the past and can be expected to continue to do so. Thus, while not explicit in
the committees statement of task, issues of public sentiment warrant some mention in the
report.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

1
Introduction
The Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP), under the
management of the Program Executive Officer for Assembled Chemical Weapons
Alternatives, is responsible for destroying the chemical weapons stockpile currently
being stored at the Blue Grass Army Depot (BGAD). BGCAPP and a facility being built
at the Pueblo Chemical Depot to dispose of the chemical agent stored there are parts of
the nations effort to destroy its chemical agent stockpile in line with its obligations under
the Chemical Weapons Convention treaty. The stockpile stored at BGAD consists of 523
tons of mustard agent in projectiles and nerve agents GB and VX in projectiles and
rockets. The chemical agent loads in the weapons will be destroyed by chemical
neutralization.1 In the neutralization process, the munitions are disassembled, the agents
and energetic materials are separated, and the agents are neutralized with caustic (for GB,
VX, and energetic materials, such as bursters) or water (for mustard agent), producing
effluents called hydrolysates. The hydrolysates will be further treated with supercritical
water oxidation (SCWO), which uses water at very high temperature (1200oF) and
pressure (3,400 psi).
The rocket portion of the stockpile at BGAD consists of about 70,000 M55
rockets, manufactured in 19611965, that contain the cholinesterase-inhibiting nerve
agents GB and VX (CMA, 2008). Those agents are organophosphates that are capable of
binding the enzyme acetylcholinesterase, which breaks down the neurotransmitter
acetylcholine in the neural synapses. When acetylcholinesterase is inhibited, the
parasympathetic nervous system is overstimulated by excess acetylcholine, resulting in
potentially fatal cholinergic effects. GB is the more volatile of the two agents, and its
primary mode of exposure is through the respiratory system; VX is absorbed primarily
through skin. The two materials are toxic at very low concentrations. Table 1-1 lists time-
weighted average maximum recommended exposure levels for the agents. The short-term
exposure level (STEL) is designed to protect employees, and the general population limit
(GPL) is designed to protect the community at large. Safe-handling procedures for
chemical agent weapons are in Volume 6 of Department of the Army Pamphlet 38561
(U.S. Army, 2008).
The M55 rockets stored at BGAD will be disposed of in a manner entirely
different from that used at the other chemical agent disposal facilities that disposed of
M55 rockets. At the other facilities, an entire M55 rocket was cut into pieces and
processed through incinerators, but the rockets stored at BGAD will be processed as
follows. Pallets of M55 rockets will be transported from their BGAD storage igloos in an
enhanced on-site container (EONC), received in the unpack area, and monitored for the

1
The term hydrolysis is used in the chemical demilitarization program.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

presence of chemical agent. If chemical agent is detected, the sealed EONC will be
opened in the explosive containment vestibule by workers in protective gear, who will
overpack any leaking or contaminated rockets; the remaining rockets will proceed to the
normal rocket destruction process. If no agent is detected, the rockets will be unpacked
from the EONC and placed into the automated rocket handling system (Schlatter, 2010).
From that point on, all operations to destroy the agent and warhead bodies will be
remotely controlled.

Table 1-1 Time-Weighted Average


Maximum Exposure Limits (g/m3)
Time Basis GB VX
GPL 24 hours 0.001 0.0006
STEL 15 minutes 0.1 0.01
SOURCE: U.S Army, 2008.

Figure 1-1 is a basic depiction of an M55 rocket in its shipping and firing tube
(SFT) and where it will be cut during processing. Figure 1-2 shows a cutaway model of
an M55 rocket in flight configuration with fins deployed. The first step in processing the
rockets will be for the rocket cutting machine (which works by pressing a rolling blade
first against the SFT and then against the rocket body) to cut the fiberglass SFT into two
pieces. The forward piece of SFT covering the warhead will be removed, conveyed to the
motor shipping room, and placed in a crate. The rocket cutting machine will then make a
second cut at the threaded connection between the warhead and the rocket motor. The
intact warhead containing the chemical agent, burster, and fuze will be destroyed at
BGCAPP by neutralization followed by supercritical water oxidation, as discussed above.

Cut

Motor section Warhead

Cut

FIGURE 1-1 Simplified diagram of an M55 rocket in its shipping and firing tube, showing where the tube
and rocket will be cut. SOURCE: Ron Hawley, Plant General Manager, Bechtel Parsons Blue Grass Team,
Rocket Processing, presentation to the committee, March 20, 2012.

FIGURE 1-2 Cutaway depiction of an M55 rocket in flight configuration with fins deployed. SOURCE:
Adapted from CMA, 2008.

The separated rear section of the M55 rocketcontaining the M28 rocket
propellant, igniter, rocket nozzle, fins and other componentsand the fore closure still in

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

its portion of the SFT will be loaded cut side up into a plywood shipping box designed to
hold 30 rocket motors. In this report, the term separated rocket motor will refer to the
separated rear section of the M55 rocket (see definition in Appendix A). Figure 1-3
shows a simplified layout of a separated rocket motor. Peak processing rates are projected
to be 20 GB-filled or 24 VX-filled M55 rockets per hour; the process will produce like
numbers of separated rocket motors each hour.2
The storage boxes containing the separated rocket motors will be placed into an
airlock, and the headspace above the motors will be monitored for the presence of any
chemical agent above the STEL before being released to the motor packing room and
later transportation and disposal. If any agent is detected, the individual separated rocket
motors will be manually monitored to determine which ones are contaminated with
chemical agent, and entire separated rocket motors that are contaminated will be
processed through BGCAPP. This report addresses only separated rocket motors that
have been monitored and cleared for disposal either on-site (on BGAD) or off-site (off
BGAD). The current plan is to dispose of separated rocket motors outside the BGCAPP
facility. The process for clearing the separated rocket motors has yet to be developed and
will, of course, need to be negotiated with the Kentucky Department for Environmental
Protection.
The BGCAPP facility currently under construction will have the capability of
demilitarizing and destroying an entire M55 rocket. Indeed, the original design of the
facility included the disposal of the entire M55 rocket in the facility with 18 energetic
batch hydrolyzers. As part of a cost-reduction initiative, a decision was made to eliminate
all but three of the energetic batch hydrolyzers and to dispose of the separated rocket
motors outside BGCAPP. The focus of this report is on the potential sites and
technologies that might be used to dispose of the separated rocket motors outside
BGCAPP. The options include treatment and disposal on-site or off-site at a commercial
or government facility.

Aft end cap Shipping and


with bail Rocket motor case Inhibitor layer M28 propellant grain
firing tube

Electric firing connect


Fin/nozzle assembly Anti-resonance rod Igniter Fore closure
for igniter
FIGURE 1-3 Simplified layout of a separated rocket motor showing its major components.

BGCAPP has identified the disposal of the separated rocket motors as a


potentially rate-limiting factor that could affect the overall rate of M55 rocket disposal at
BGCAPP. The main reason is related to storage space at BGCAPP. BGCAPP will have
about 1.25 days worth of storage space in the munitions demilitarization building for

2
Ron Hawley, plant general manager, Bechtel Parsons Blue Grass Team, Rocket Processing,
presentation to the committee, March 20, 2012.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

separated rocket motors. Any interruption in transportation of rocket motors out of this
storage could force a slowing or cessation of M55 rocket processing operations at
BGCAPP. Options are needed to address issues of storage, throughput, transportation,
and the treatment that will be required to dispose of the roughly 3,350 separated rocket
motors that BGCAPP plans to generate each month.3

STATEMENT OF TASK

The National Research Council will establish an ad hoc committee to address


these specific tasks:

Investigate off-site and on-site alternative options for disposal of approximately


70,000 M55 rocket motors stored at Blue Grass Army Depot that are not
contaminated by chemical nerve agent contained in the rocket warheads
Review and examine the status of maturity and assess the likelihood of success for
each option
Consider the feasibility of recycling options for the propellant and rocket motor
components
Assess relevant environmental considerations, including those pertaining to the
health and safety of workers, and regulatory requirements such as those stemming
from applicable Kentucky Revised Statutes and RCRA regulations
Examine shipping considerations for implementation of off-site alternatives,
including packaging requirements

THE COMMITTEE, REPORT SCOPE, AND PROCESS

The committee is composed of persons who have extensive experience in solid


rockets, energetic materials, munitions disposal, hazardous wastes, safety, and public
involvement. Several committee members have expertise pertinent to the regulations
governing the transport and disposal of various types of munitions and associated
hazardous materials. Biographies of all the committee members are in Appendix D.
The committee met three times. The first meeting was held in Richmond,
Kentucky, and included a briefing from BGCAPP about the options that have been
reviewed for the treatment and disposal of the separated rocket motors and committee
discussions to begin framing the approach to the study and the report. The second
meeting was held in Washington, D.C. where the committee discussed and developed the
report draft. The third meeting was also held in Washington, D.C. At this meeting the
committee resolved most remaining issues and laid out the path to achieving committee
consensus on the report. Committee activities are summarized in Appendix C.
This report reviews various approaches that could be used for safe disposal of the
rocket motors separated from the M55 rockets stored at BGAD. It also discusses issues of
safety, storage, throughput, transportation of the separated rocket motors, on-site and off-

3
Kevin Regan, environmental manager, BGAPP project, Rocket Motor (RM) Disposal, briefing
to the committee, March 20, 2012.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

site disposal options, and how public acceptance could influence the disposal of the
separated rocket motors. The coverage of the report begins after the M55 rockets have
been cut and the separated rocket motors have been monitored and cleared for
transportation and disposal off-site.

OVERVIEW OF REPORT

Chapter 2 focuses on safetyenergetics safety, electrical safety, and lead.


Although the chemical agent warheads will no longer be present when the separated
rocket motors are handled, the separated rocket motors are hazardous in their own right
because they contain M28 propellant, which has aged and degraded and will continue to
degrade. Explosives safety precautions are necessary in all handling and storage
operations that involve the separated rocket motors. Chapter 2 also addresses hazards of
electromagnetic radiation to ordnance and risks posed by electrostatic discharge if the
igniter leads and shunting are damaged when the rockets are cut.
Chapter 3 is an overview of technologiesprimarily chemical and thermal
treatment methodsthat could be used to dispose of the separated rocket motors. The
chapter presents information on both thermal treatment options (open and contained) and
chemical treatment options, such as base hydrolysis and supercritical water oxidation.
Recycling of the rocket motors is unlikely in that the M28 propellant is old and degraded
and contains lead. It would not be practical or cost-effective to reuse the propellant,
recover its ingredients, or work it into another form, such as fertilizer. In addition, the
SFTs contain polychlorinated biphenyls. The committee envisions that the separated
rocket motors will be removed from the SFTs before disposal of the motors, in part to
avoid the contamination of disposal waste streams with polychlorinated biphenyls; this is
discussed in more depth in Chapter 5. The discussion in Chapter 3 includes
recommendations of the technologies that may be best suited for disposal of the separated
rocket motors.
The storage of separated rocket motors is discussed in Chapter 4. The storage of
the separated rocket motors is a potentially limiting step in M55 rocket disposal at
BGCAPP, inasmuch as their disposal will probably proceed at a lower rate than the
rocket-cutting operations at BGCAPP. Although the storage of the separated rocket
motors is not an explicit item in the statement of task, it is central to the timely processing
of M55 rockets through BGCAPP. If the separated rocket motors cannot be transported to
a storage or disposal site outside BGCAPP at least as quickly as they are accumulated in
BGCAPP, rocket-cutting and warhead-processing operations at BGCAPP would need to
be slowed or halted.
Chapter 5 presents some of the specific issues that BGCAPP project management
will need to consider when selecting the most appropriate location for disposal of the
separated rocket motors. On-site disposal options reviewed by the committee include
open burning of the propellant grain at the BGAD permitted explosive hazardous-waste
treatment facility; using the D-100 detonation chamber currently operational at BGAD;
using alternative technologies, such as explosive destruction technologies, which can be
added to BGAD capabilities; and disposal at BGCAPP after completion of all chemical
agent destruction operations. Off-site disposal options, in which all the separated rocket

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

motors would be removed from BGCAPP and BGAD and delivered to other facilities for
disposal, are also discussed. The chapter considers transportation issues. For example, the
transportation of the separated rocket motors on public roads will need to comply with
Department of Transportation regulations and will require appropriate and specialized
packaging, whereas on-site transportation will have a different, and potentially less
demanding, regulatory framework.
The report contains two appendixes that supplement the committees work in the
main body of the report. Appendix A sets forth some definitions that are used specifically
by this committee. Appendix B reviews the history of public sentiment as it pertains to
the committees task. Although a consideration of public sentiment is not an explicit item
in the statement of task and a rigorous examination of it was beyond the committees
scope, the committee believed that it would be remiss not to include some discussion of it
in that it is likely to figure into the ability to implement any given disposal technology or
disposal option. Programs for destroying the chemical munitions stockpile managed by
the U.S. Army Chemical Materials Agency4 and the Assembled Chemical Weapons
Alternatives5 program have historically been heavily influenced by public sentiment. The
concerns of citizens near BGAD, along potential transportation routes, and near potential
off-site disposal locations are therefore going to be important in consideration of any
decision about the choice of a technology or option (whether on-site or off-site) to
dispose of the separated rocket motors.

REFERENCES

CMA (Chemical Materials Agency). 2008. Fact Sheet: M55 Rockets, March 5. Available
online at http://www.cma.army.mil/fndocumentviewer.aspx?docid=003677976. Last
accessed July 5, 2012.
Schlatter, J. 2010. Blue Grass Exchange: Chemical Munitions Destruction: A Rockets
Path Through the Pilot Plant Facility, April-June. Available online at https://www.
pmacwa.army.mil/info/bg_exchange_apr10_rocket_path.html. Last accessed July 5,
2012.
U.S. Army. 2008. Department of the Army Pamphlet 38561: Toxic Chemical Agent
Safety Standards, December 17. Available online at http://www.apd.army.mil/pdffiles
/p385_61.pdf. Last accessed June 7, 2012.

4
The U.S. Army Chemical Materials Agency has successfully and safely disposed of the chemical
agent and munitions stockpiles at Aberdeen, Maryland; Anniston, Alabama; Johnston Atoll; Newport,
Indiana; Pine Bluff, Arkansas; Tooele, Utah; and Umatilla, Oregon. Chemical neutralization was used to
dispose of bulk agent at Aberdeen, Maryland, and Newport, Indiana. Incineration was used to dispose of
the stockpiles at the other sites.
5
In addition to BGCAPP, a facility is under construction at the Pueblo Chemical Depot, in
Colorado, to dispose of the mustard agent stockpile there. The agent will be chemically neutralized by hot-
water hydrolysis, and the resulting hydrolysates will be processed through a biotreatment system.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

2
Safety
As with all chemical and industrial processes, the destruction of the separated
rocket motors1 from the M55 rockets will present inherent safety risks. Working with
energetic materials safely requires carefully devised and approved safe operating
procedures, processes, and equipment. M55 rockets were manufactured in 19611965
(CMA, 2008). The M28 propellant in the rockets was therefore 4751 years old when this
report was prepared. Disposing of the separated rocket motors will require additional
consideration given that the M28 propellant includes aged and degraded materials. And
the propellant contains lead compounds that must be taken into account in considering
disposal options.
A well-designed process for disposal of the separated rocket motors will provide
physical safety for the workers controlling or performing the work activities, protect the
community and local environment, minimize risks to the physical infrastructure and
capital equipment required to perform the work, and produce a manageable waste stream
that is minimized to the greatest extent possible. The Blue Grass Chemical Agent-
Destruction Pilot Plant (BGCAPP) will use extensive automation to minimize employee
exposure to agent and explosive hazards associated with the handling and destruction of
M55 rockets in the plant. However, M55 rocket processing in BGCAPP will result in the
need to dispose of about 70,000 intact rocket motor assemblies2 outside BGCAPP. For
more information on the important topic of process safety, the reader is referred to NRC,
2011.

ENERGETICS SAFETY ISSUES

Because the rocket motor propellant presents an energetic hazard, explosives


safety precautions must be taken in all handling and storage operations. Such operations
are governed by Department of Defense (DoD) Ammunition and Explosives Safety
Standards (DoD, 2008) and within the Army by the current version of the Armys
Ammunition and Explosives Safety Standards (U.S. Army, 2011). Guidance in those two
documents must be followed in any treatment program.

1
See Appendix A for how the committee defines separated rocket motor.
2
These assemblies include the rocket motor in its steel case, aluminum fins, ignition system and
wires, fins and miscellaneous parts, and fore closureall in the rear half of the shipping and firing tube.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

The composition of M28 propellant used in the M55 rocket is listed in Table 2-1.
It is a double-base3 propellant with a lead stearate burn-rate modifier. The propellant is
contained within a cellulose acetate inhibitor that has been plasticized with
dimethylphthalate. The purpose of the inhibitor is to limit propellant burning along the
outer surface of the propellant during motor firing. The hazard classification of the
separated rocket motors as determined by following the Department of Defense
Ammunition and Explosives Hazard Classification Procedures, TB 7002 (DoD, 1998),
affects the packaging requirements for the rocket motors, the number of rocket motors
that may be transported off-site in a given shipment configuration, and the number of
rocket motors that may be stored in a given location before disposal. The hazard
classification of the assembled M55 rockets in their shipping and firing tubes (SFTs) for
storage and transportation is currently 1.2.1, which means that they present a nonmass
explosion and fragment-producing hazard. BGCAPP intends to apply for a 1.3 hazard
classification, which would mean that they present a mass fire and minor blast or
fragmentation hazard, to cover shipping and handling of the separated rocket motors
(DoD, 1998).Table 2-2 lays out the hazard classifications that are applied to explosive
materials.

Table 2-1 Nominal Composition of M28 Propellant


Component Weight Percent Purpose
Nitrocellulose 60 Energy source
Nitroglycerin 23.8 Energetic plasticizer
Triacetin 9.9 Casting solvent
Dimethylphthalate 2.6 Plasticizer
Lead stearate 2.0 Burn-rate modifier
2-Nitrodiphenylamine 1.7 Stabilizer
SOURCE: CMA, 2005.

Table 2-2 Hazard Classifications Applied to Explosive Materials


Hazard Classification Hazard
1.1 Mass explosion
1.2 Nonmass explosion, fragment-producing
1.3 Mass fire, minor blast, or fragment
1.4 Moderate fire, no blast, or fragment
1.5 Explosive substance, very insensitive
(with mass explosion hazard)
1.6 Explosive article, extremely insensitive
SOURCE: DoD, 1998.

Finding 2-1. The hazard classification of the rocket motors has not been determined. The
classification will directly affect packaging, transportation, and storage requirements for
off-site disposal options.

3
The term double-base connotes that there are two active constituents in the propellant. In the case
of the M28 propellant, they are nitrocellulose and nitroglycerin.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Recommendation 2-1. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should expedite the process required to provide the hazard classification of the separated
rocket motors.

The aging and degradation of the M28 propellant could cause it to have increased
sensitivity to impact, shock, and thermal conditions. There were four pressure-pulse
events when the motors of M55 rockets were cut at the Umatilla Chemical Agent
Disposal Facility. There have also been over 20 fires when rocket motors were cut at
incineration-based chemical agent disposal facilities (CDC, 2006). Although the
separated rocket motors at the Blue Grass Army Depot will not be cut, those incidents
indicate some sensitivity of the propellant, which could be a factor in disposing of the
separated rocket motors. Because of the potential severity of incidents arising from
propellant sensitivities, the Department of Defense (DoD, 2008) and the Department of
Transportation (49 CFR 173.56) have instituted policies for handling these types of
materials.
Nitrate esters, such as the nitrocellulose in the M28 propellant, degrade slowly
and liberate nitrogen dioxide (NO2).4 One mechanism for that is the breaking of the
carbon monoxidenitrogen dioxide (CONO2) bond in the nitrocellulose, which is
thermally labile and can be broken under storage-temperature conditions. If liberated NO2
does not react with the nitrate ester (the propellant), it can react with water in air to form
acids, which will degrade nitrate esters further. For instance, NO2 is a strong oxidizer and
can react with the nitrocellulose or abstract hydrogen from the nitrocellulose to produce
nitrous acid (HONO). The CONO2 bond may also be hydrolyzed to form nitric acid
(HNO3). And the degradation of the propellant can be catalyzed by the presence of bases
and metals. Finally, the overall chemical reaction is exothermic (it generates heat), and
can catalyze degradation further. In other words, the degradation of the nitrate esters in
the M28 propellant is accelerated by its own degradation product (NO2). If the
degradation reaction rate becomes high enough, the nitrate ester will self-initiate, and this
can lead to ignition, deflagration, or detonation.
Standard practice is to avoid the undesirable consequences of the runaway
reaction by adding an NO2 scavenger, commonly referred to as a stabilizer. The stabilizer
does not contribute substantially to the energy delivered by the propellant when used for
its intended purpose, so quantities of stabilizer used in propellants are limited. Over time,
the stabilizer becomes depleted, and the undesirable reactions can become dominant.
Surveillance programs are instituted to ensure that sufficient stabilizer remains in
propellants to minimize the risk of autoignition. Such a program consists of accelerated-
aging estimations of stabilizer content combined with occasional monitoring of the rocket
motor inventory. Conventionally, both evaluations require the extraction of a piece of
propellant, followed by chemical analysis of that piece. In 2002, the Army determined
that the M28 propellant inside an intact M55 rocket assembly, in its current
configuration, could be handled with minimal risk (U.S. Army, 2002). In the 10 years
that have elapsed since the 2002 assessment, the propellant has degraded further. If the

4
Stephanie E. Leach and Bruce P. Thomas, Naval Air Warfare Center Weapons Division, China
Lake, California, Assessment of Alternative Strategies to Determine Solid Rocket Motor Stability,
meeting poster presented at the 2012 Pittsburgh Conference, March 16, 2012, Orlando, Florida.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

propellant has followed the degradation rate projected in 2002, the risk of autoignition
should not have increased appreciably. To the committees knowledge, the propellant has
not been assessed since 2002, so it does not know whether the propellant has degraded as
projected.
However, cutting the fiberglass SFT and separating the rocket motor from the
warhead changes both the system configuration and the storage environment of the rocket
motor. For instance, the propellant will have greater exposure to environmental factors,
such as heat and humidity, via an air pathway between the rocket motor case and the SFT
and up through the nozzle than when it was been sealed in an SFT as a whole rocket. The
chemical reactions in the propellant generate heat on an ongoing basis, and the storage
box in which the separated rocket motors will be placed will influence heat transfer to
and from a given rocket motor and the others boxed with it and heat exchange between
ambient air and the propellant. The design of the box, including its ability to dissipate
heat generated in the propellant grains and its ability to maintain a dry storage
environment, will determine the validity of the previous safety studies vis--vis the new
configuration of the cut rocket motors.
Other aging-related phenomena that may not correlate directly with the stabilizer
content include migration of nitroglycerin into the inhibitor and changes in mechanical
properties, such as softening and hardening of the propellant. The M28 propellant
contains nitroglycerin, which is used as a plasticizer to tailor the propellant's mechanical
properties (to increase its flexibility) and to increase energy content. The nitroglycerin
can diffuse and migrate within the bulk propellant, form small accumulations at the
propellant surface, be absorbed into the inhibitor layer, or lead to propellant brittleness.
Those physical effects can lead to a reduction in propellant stability and an increase in
propellant sensitivity, both of which warrant careful consideration in handling aged M28
propellant. Propellant softening is often exhibited as slumping, and propellant hardening
can be exhibited as cracking. On initiation, as in some disposal technologies, those
phenomena change the surface area being burned and can increase the inner pressure of
the motor case. If that pressure exceeds maximum limits for the nozzle or the case, a
catastrophic failure will occur and potentially can cause serious damage to personnel and
facilities. The phenomena can thus pose a safety risk during rocket motor disposal.
A hazards analysis working group (HAWG) is a useful and important tool for
addressing energetics safety (DoD, 2012). A HAWG comprises operators, safety experts,
industry experts, vendor representatives, and regulators at BGCAPP could examine in
great detail all the possible actions and activities that involve the M55 rocket with
specific focus on the energetic material components during demilitarization. A HAWG
assessment may reveal safety risks in a process or procedure that are otherwise not
readily apparent.

Finding 2-2. The Armys 2002 M55 Rocket Assessment Summary Report for the intact
M55 rocket may not be directly applicable to the separated rocket motors. New not-
readily-apparent safety risks could emerge during demilitarization operations involving
the M55 rocket containing energetic materials.

Finding 2-3. Among the vitally important approved safety practices and procedures that
need to be followed in handling energetic materials are the assessment and approval of

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standard operating procedures and hazard analyses. They will account for potential new
safety risks that emerge during the demilitarization process.

Finding 2-4. The design of the storage and shipping box will significantly influence the
storage environment of the M28 propellant.

Recommendation 2-2. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should ensure that the storage and shipping containers minimize the exposure of rocket
motors to environmental conditions that will accelerate propellant degradation, such as
heat and humidity, and allow adequate heat dissipation from the separated rocket motors.
For example, desiccant could be added to the storage and shipping containers to reduce
humidity.

Recommendation 2-3. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should establish a hazards analysis working group to assess, analyze, and develop risk
mitigation practices and procedures with specific attention to energetic materials in the
overall demilitarization of the M55 rocket.

ELECTRICAL SAFETY

The hazards of electromagnetic radiation to ordnance (HERO) and electrostatic


discharge (ESD) need to be considered as they apply to the separated rocket motors. The
rocket-cutting operation will produce a rocket motor with an ignition system
configuration that is different from that of an intact M55 rocket. The cutting operation
may also damage the igniter leads and shunting as the installed rocket motor ignition
system is integrated with the bottom half of the cut fiberglass SFT. Although the rocket-
cutting operation is designed not to damage the rocket motor, unintended damage to the
igniter leads and the safety shunting may occur when the rocket is cut because the SFT
will be clamped at the rear end for this operation, which is where much of the ignition
system is. In addition, because the steel rocket motor case will be exposed along the cut,
a new electrically conductive path that was not envisioned when the rockets were
designed will be created. That may change the systems sensitivity to ESD.
Regarding HERO, the current electromagnetic radiation environment is substantially
different from when this ordnance was produced. For example, personal electronic
devices and cellular-telephone towers did not exist when the M55 rockets were designed
and produced. They can produce local electromagnetic fields that could affect the
separated rocket motors and cause electrical safety problems, including possibly ignition.

Finding 2-5. The current hazards to the separated rocket motors posed by
electromagnetic radiation and the potential for electrostatic discharge may require
verifying the condition of the igniter system after cutting before placement in the storage
and shipping box.

Recommendation 2-4. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should address the condition of the ignition system after cutting. If it is warranted by the

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

changed configuration of the separated rocket motors, the design of the storage and
shipping box should provide protection from hazards of electromagnetic radiation to
ordnance and from electrostatic discharge.

LEAD

As shown in Table 2-1, the M28 propellant contains 2 percent lead stearate by
weight. The weight of the propellant in each motor is about 20 lb, so the propellant in
each motor contains about 0.4 lb of lead. Lead released from burning propellant will be in
the form of respirable particulate matter (PM2.5).5 Releases are likely to be in the form of
lead metal and lead oxides. Unpublished data on static-fired rocket motors indicate that a
substantial fraction (2-10 percent) of the lead may remain in the motor carcass after
firing. Any technology used to dispose of the separated rocket motors would need to
ensure minimal redistribution of lead through the environment and protection of
employees and the public.

Finding 2-6. Thermal and chemical processes that destroy the propellant will produce a
lead waste stream that will present challenges from worker, public health, and
environmental exposure perspectives.

REFERENCES

CDC (Centers for Disease Control and Prevention). 2006. M55 Rocket Fire/Explosion
Concerns, March 1. Aberdeen Proving Ground, Md.: U.S. Army Chemical Materials
Agency.
CMA (Chemical Materials Agency). 2005. Fact Sheet: M28 Propellant Grain. Available
online at http://www.cma.army.mil/fndocumentviewer.aspx?docid=003674658. Last
accessed September 12, 2012.
CMA. 2008. Fact Sheet: M55 Rockets, March 5. Available online at
http://www.cma.army.mil/fndocumentviewer.aspx?docid=003677976. Last accessed
July 5, 2012.
DoD (Department of Defense). 1998. Joint Technical Bulletin: Department of Defense
Ammunition and Explosives Hazard Classification Procedures, TB 7002, January 5.
Available online at http://www.ddesb.pentagon.mil/. Last accessed August 7, 2012.
DoD. 2008. DoD Ammunition and Explosives Safety Standards, DoD Number 6055.09-
M, February 29. Available online at http://www.dtic.mil/whs/directives/corres/html/
605509m.html. Last accessed June 8, 2012.

5
PM2.5 is Environmental Protection Agency nomenclature for particulate matter that has an
aerodynamic particle size equal to or less than 2.5 m. That particle size is important because such particles
can travel into the alveoli in the lungs.

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DoD. 2012. Department of Defense Standard Practice, System Safety, MIL-STD-882E,


May 11. Available online at http://www.everyspec.com/MIL-STD/MIL-STD-0800-
0899/MIL-STD-882E_41682/. Last accessed July 3, 2012.
NRC (National Research Council). 2011. Assessment of Approaches for Using Process
Safety Metrics at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants.
Washington, D.C.: The National Academies Press.
U.S. Army. 2002. M55 Rocket Assessment: Summary Report, July. Aberdeen Proving
Ground, Md.: U.S. Army Program Manager for Chemical Demilitarization.
U.S. Army. 2011. Department of the Army Pamphlet 385-64: Ammunition and
Explosives Safety Standards. Available online at http://armypubs.army.mil/epubs/
pdf/p385_64.pdf. Last accessed June 8, 2012.

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3
Technologies for Rocket Motor Disposal

RECYCLING OPTIONS

The first choice for any demilitarization or disposal program should be to recover
materials. The committee does not believe that this option is practical in the case of the
M28 propellant, however, because it is old and degraded. There are few applications for
aging rocket motor assets in general, and incorporating nitrate ester rocket motor
propellants that are specifically derived from chemical weapons, such as the M28
propellant, into new applications is unlikely.
Attempts to recycle nitrocellulose and nitroglycerin from double-base1 propellants
have not yielded acceptable products. Trace contamination by constituents of a degraded
propellant in a recovered material can have a serious adverse effect on the cure times and
safe storage life of any propellant made from recovered materials. The nitrocellulose in
the M28 propellant is degraded to the point where it is unlikely that any current program
of record for manufacturing new rocket propellant would be willing to incorporate it.
Furthermore, program-office requalification costs are substantial when alternative
sources of fully characterized composition are introduced into a programs inventory.
This is an issue especially when a propellant ages and produces chemical species that
catalytically degrade the propellant even when they are present only at trace
concentrations. Although it might be possible to extract and purify the nitroglycerin for
recycling, it would entail much work to determine whether this were worth while. The
committee does not believe that it would be a practical or worthwhile exercise.
Investigations into conversion of these energetic materials to other products, such as
fertilizer, have also met with little success. The fact that the M28 propellant contains
lead, which cannot be removed without destroying the propellant matrix by chemical or
thermal means, complicates any effort to recycle the propellant into fertilizer and further
reduces the practicality of recycling in general.

Finding 3-1. There are no practical, useful, or cost-effective means of recycling energetic
materials from the M28 propellant.

Metal components of the separated rocket motor2 can be recovered for recycling
after they have been mutilated to preclude restoration for further use in a rocket motor
(DoD, 2011). In addition, metal scrap must be certified as safe for public release and

1
The term double-base connotes that there are two active constituents in the propellant. In the case
of the M28 propellant, they are nitrocellulose and nitroglycerin.
2
See Appendix A for how the committee defines separated rocket motor.

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recycling. The Department of Defense (DoD) has instituted a policy for the identification
of munitions and munitions scrap that are free of explosive safety hazards (DoD, 2008).
The defined process includes specific training, storage, handling, inspection, and
certification requirements for all materials potentially presenting an explosive hazard
(MPPEH)that is, any material that has come into contact with an energetic material
before their release from DoD control. The policy applies to any scrap metal recovered
from the separated M55 rocket motors.
If the M28 propellant is treated while inside the steel motor case the, remaining
metal parts will be contaminated with lead and lead dust. Separation of the propellant,
igniter, and other energetic components of the rocket motor from the case, fins, and
electronics would simplify the recovery of the scrap metal from these components.
However, the recovered metal may still have to be thermally or chemically treated to
ensure that energetic residues are destroyed before the materials can be released to a
recycler.

Finding 3-2. It is feasible to recycle the metal components of the separated rocket
motors.

Finding 3-3. Depending on the destruction technology used, metal components may be
contaminated with lead and lead dust.

Recommendation 3-1. The Blue Grass Chemical Agent-Destruction Pilot Plant program
staff should inform the recipient of materials for recycling of the potential for the
presence of lead or lead dust on recovered materials.

OVERVIEW OF DISPOSAL TECHNOLOGIES

A wide variety of technologies have been proposed for the demilitarization and
disposal of conventional solid rocket motors. The technologies can be divided into
thermal and chemical. Thermal technologies for separated rocket motor demilitarization
and disposal include open detonation, buried detonation, contained detonation, open burn,
open static firing, contained combustion, contained static firing, confined combustion,
and incineration. Chemical technologies include base hydrolysis, supercritical water
oxidation, and the use of humic acid. The chemical technologies typically require
pretreatment in which the propellant is broken into a manageable form (e.g., a solution,
powder, or slurry). That process increases the handling of energetic materials and the
attendant risks. Thermal treatment usually requires less handling, but precautions must be
taken to prevent unplanned detonation or propulsive ejection of the rocket motors.
Technologies discussed here are summarized in Table 3-1. The committee envisions that
the separated rocket motors would be removed from the shipping and firing tubes before
disposal of the separated rocket motors, partly because the shipping and firing tubes
contain polychlorinated biphenyls; this is discussed in more depth in Chapter 5. Among
the criteria that will need to be considered in selecting a disposal technology for use with
the separated rocket motors is the TNT equivalence of the roughly 20 lb of M28
propellant in each motor.

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THERMAL TECHNOLOGIES

For purposes of the discussion in this report, thermal technologies are organized
into two subgroups: open and contained. In open technologies, emissions are not
contained or treated before release into the environment. In contained technologies,
emissions are contained and treated before release into the environment. A particular
subgroup of contained thermal technologies, explosive destruction technologies (EDTs),
will also be discussed.
If an open technology were used, the emissions from separated rocket motor
disposal would need to be within the allowed limits provided in the Air Pathway
Assessment section of the Resource Conservation and Recovery Act (RCRA) Subpart X
permit for the facility using the technology. In the case of a contained technology, gases
and particulate material would be captured and treated with the unit's pollution abatement
equipment. The contained technologies would need to be permitted through RCRA
Subpart X and would have to meet release limits agreed on with the Kentucky
Department for Environmental Protection.

Open Thermal Technologies

Open Detonation

Open detonation involves placing whole or broken-down rocket motors in a pile


with a booster explosive. Detonation of the pile initiates a chemical reaction that converts
organic energetic materials to carbon dioxide, nitrogen, and water. Emissions from the
process do not undergo further treatment and are released into the local environment.
They can include metals in the energetic material (such as lead in the M28 rocket
propellant), traces of unreacted energetics, materials in the rocket motor cases released
and ejected by the detonation, and entrained soil from the detonation site. Noise issues
and weather often limit the conditions under which these detonation events can be
conducted.
Open detonation has several advantages. Handling of energetic items is
minimized, and this reduces the risk of unexpected initiation and harm to personnel or
facilities. Secondary waste streams are limited to unreacted materials, mostly metal
components from the detonated solid rocket motors, such as the case and the fins. Data in
emissions databases are sufficient to allow an estimation of total emissions from the
process (Erickson et al., 2005; EPA, 2009). Efforts are under way to improve the
databases (Kim, 2010; Wright et al., 2010).
This technology also has many disadvantages. Emissions are not further treated
before release into the environment. In particular, there is a potential for releases of
respirable particles from metal components of the energetic formulation, such as the lead
in the rocket propellant, or from the soil. Noise issues often cause concerns for facility
neighbors and result in regulatory limitations on when the treatment can occur.
Propellants like that in the motors of M55 rockets can be difficult to detonate completely,
and incomplete detonation occasionally results in distribution of unreacted energetics

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over a large area. Other unreacted materials, such as rocket motor cases and liners, can
also be distributed over a large area. Most permits require regular cleanup of this
material. The release of scrap metal from the open detonation process requires prior
screening as MPPEH.
Open detonation is a mature technology that is commonly used for munitions
demilitarization and emergency ordnance destruction. Throughput from this process will
be a function of limits placed on a facilitys RCRA Subpart X permit.

Buried Detonation

Buried detonation is a variant of open detonation in which the pile is covered with
48 ft of soil to suppress detonation noise. The soil also increases safety by minimizing
blast and collateral damage that might be caused by metal fragmentation. This technology
has the advantage of minimization of the handling of the items being treated. However, it
also has disadvantages. Like emissions from open detonation, emissions from buried
detonation are not treated further before release into the environment. Because the soil
quenches afterburning reactions, buried detonation releases larger quantities of products
of incomplete combustion (such as soot and hydrocarbons) than are produced in open
detonation. Little work has been done to quantify this phenomenon, but tests are under
way to collect pertinent data (Kim, 2010; Wright et al., 2010). The potential exists for
environmental releases of metals and organic substances from both the soil and the waste
ordnance.
Buried detonation is a mature technology that is commonly used for munitions
demilitarization. Throughput is constrained by permit treatment limits and the time
necessary to prepare the site and bury the ordnance.

Open Burning

Open burning of rocket motors involves removal of the propellant grain from the
case and ignition of the propellant in an open burning pan. As in open detonation,
energetic components are largely converted to nitrogen, carbon dioxide, and water. Some
facilities use an additional fuel (such as jet fuel) to initiate and support combustion of
propellants that are difficult to ignite. Others conduct open burning of whole rocket
motors by cracking the motor case open with a shaped charge that also initiates propellant
combustion. Gaseous and particulate emissions from the burning propellant are not
treated further and are released into the local atmosphere. The combustion occurs at
atmospheric pressure. Residual ash requires evaluation as a potential hazardous waste.
An advantage of open burning is that components of the rocket are removed
before treatment and are available for recycling. Data on open-burning emissions are
sufficient to permit an estimation of total emissions from the process (Erickson et al.,
2005; EPA, 2009), and efforts are under way to improve the quality of the emissions
databases (Kim, 2010).
Open burning has several disadvantages in common with open detonation.
Emissions do not undergo further treatment before release into the environment. Heavy-
metal components of the propellant (such as lead in M28 propellant) are released to the

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atmosphere as respirable particles. Most propellants are designed to burn efficiently at


high pressures. Burning them at ambient atmospheric pressure results in emissions that
contain more products of incomplete combustion (such as soot and hydrocarbons) than
would be the case if they were burned as designed. Open burning of rocket motors
requires the removal of the propellant from the case to prevent propulsive events, and this
increases the handling of the items being disposed of. Finally, ash from the process is
probably laden with heavy metals from the propellant formulation and must be tested to
determine whether it must be handled as a hazardous waste.
This is a mature technology that is commonly used for munitions demilitarization.
The Blue Grass Army Depot (BGAD) is operating an open-burning facility under interim
permit status. The BGAD facility can treat up to 6,000 lb of energetic material in each
treatment event. That would theoretically permit a throughput of up to 300 separated M55
rocket motors per treatment event. The presence of lead in the propellant could lower the
throughput because of permit limits on lead releases.

Open Static Firing

Open static firing of rocket motors involves strapping down of the motor and
initiating it in its design mode. This is done in the open, so gaseous and particulate
emissions are released into the environment without further treatment. The process
minimizes handling and simplifies recovery of components of the rocket motor.
Catastrophic failure of aged rocket motors is rare, but not unheard of.
The technology has several advantages. As mentioned above, handling is
minimal, and this increases personnel safety. The combustion of the propellant occurs at
high pressure, which improves combustion efficiency, and there are thermochemical
models for predicting emission products. Components of the motor (such as case, fins,
and electronics) can be recovered after treatment.
There are, however, some important disadvantages. As in all processes carried out
in the open, atmospheric emissions are not treated before release into the environment.
With respect to two rocket motor systems that contained a lead burn-rate modifier, as
does the M28 propellant in the rocket motors separated from M55 rockets, it was one
committee members direct experience that a nontrivial fraction of the lead remained in
the case after treatment. The committee believes that it would be prudent to expect that
the motor case will require assessment as hazardous waste because of lead contamination
in addition to being managed as MPPEH. There is a potential for propellant cracking,
slumping, shrinking, or changing in density as the propellant ages. Those phenomena can
change the propellant surface area during burning. In extreme cases, they can result in
overpressurization and catastrophic failure of the rocket motor. Such a failure can
damage facilities and may initiate a re-evaluation of procedures.
This is a mature technology that is commonly used for munitions demilitarization.
Throughput will be limited by environmental permits, the number of motors strapped to a
test stand, and the time necessary to wire the initiation circuitry.

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Contained Thermal Technologies

Contained Detonation

Contained detonation involves the detonation of the rocket motor or the rocket
motor propellant in a sealed chamber. Contained detonation technologies often use a
donor explosive charge to detonate the propellant. Afterburning reactions are often
quenched as a result of efforts to protect the integrity of the chamber. After detonation,
gases in the chamber are passed through a pollution-abatement system to remove
contaminants before venting to the local atmosphere. To preserve the detonation
chamber, limits are placed on the quantity of energetic material that can be treated in a
single detonation, and this restricts process throughput. Designs for contained detonation
units are commercially available.
This technology has some advantages, such as minimization of the handling of the
items being disposed of. Furthermore, emissions are treated before release into the
environment. It also has several disadvantages. Over time, shrapnel can cause damage to
the facility and result in repair costs and possibly an interruption of processing. That and
other stressors also limit the lifetime of the detonation chamber. Large scrap residues
need to be removed after each treatment event to minimize the production of shrapnel.
The time needed for such clearance limits throughput of the technology. Toxic metal,
semivolatile, and nonvolatile emissions from the ordnance will contaminate the interior
of the detonation chamber. In the case of the separated rocket motors, such contaminants
would include the lead compounds from the M28 propellant. The contaminants would
pose a safety risk to personnel operating in the chamber. In addition, it is difficult to
ensure that a detonation chamber will remain leakproof over a lifetime of contained
detonations; avoidance of environmental contamination requires regular checks for leaks.

Contained Combustion

Contained combustion involves the burning of energetics in burn pans in a sealed


combustion chamber. Gaseous and particulate emissions from the combustion process are
stored in a holding tank for later processing before release into the environment.
Handling is minimized, but gas storage capacity can be a limiting factor. The time
required for postcombustion cleanup of the combustion chamber may decrease
processing throughput.
The minimization of handling and the treatment of emissions before
environmental release are advantages of this technology. However, as with contained
detonation, emissions of toxic metals, semivolatile compounds, and nonvolatile
compounds from the ordnance will contaminate the interior of the chamber and pose a
risk to personnel safety, and lead compounds would be a contaminant from the
combustion of M28 propellant. In addition, residues will require assessment for treatment
as hazardous waste, and metal scrap must be managed as MPPEH. Throughput will be
limited by workplace cleanliness standards and the time needed to treat collected
combustion gases.

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Contained Static Firing

Contained static firing involves the burning of an intact rocket motor or propellant
in a combustion chamber. Gaseous and particulate emissions from the combustion
process are stored in a holding tank for later processing before release into the
environment. Handling is minimized, but gas storage capacity and the potential for
damage from a catastrophic failure limit throughput.
Minimization of handling and treatment of emissions before environmental
release are advantages of this technology. However, the motor residues would need to be
removed after each treatment event, and this will limit process throughput. As with
contained detonation and contained combustion, emissions of toxic metals, semivolatile
compounds, and nonvolatile compounds from the ordnance will contaminate the interior
of the chamber and pose a risk to personnel safety. As above, one of the contaminants in
disposal of the M28 propellant will be lead compounds. Motor residues will require
assessment for treatment as hazardous waste, at least in part because of the presence of
lead compounds, and as MPPEH. There is a potential for propellant cracking, slumping,
or shrinking and changes in density as the propellant ages. Those phenomena can change
the propellant surface area during burning. In extreme cases, that can result in
overpressurization and catastrophic failure of the rocket motor. Such a failure can
damage facilities and may initiate a re-evaluation of procedures. This technology is
commercially available.

Confined Combustion

Confined combustion burns a rocket motor in a combustion chamber and, in


contrast with contained combustion, passes product gases through a pollution-abatement
system to remove atmospheric pollutants before release into the environment. Few
commercial pollution-abatement systems can handle the large changes in temperature,
pressure, and flow rate that occur over the short period of rocket motor combustion.
Throughput is limited by requirements for setup and chamber cleanup between motor
firings.
As with contained combustion, advantages of this technology include the
minimization of handling and the treatment of emissions before environmental release.
The limited availability of commercial pollution-abatement systems that have the
capacity to handle the operational environment of this technology is a potential
disadvantage. The motor case needs to be removed from the chamber after each treatment
event to minimize damage to the chamber from flying debris and thus prevent shutdown
of the unit, which would limit throughput. Emissions of toxic inorganic, semivolatile, and
nonvolatile chemicals from the ordnance will contaminate the interior of the chamber and
pose a risk to personnel safety. The motor case will require assessment for treatment as
hazardous waste at least in part because of the presence of lead compounds and will also
need to be managed as MPPEH.
This technology has undergone subscale and pilot-scale demonstration. Further
development is needed to make it directly applicable to the disposal of rocket motors
separated from M55 rockets.

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Other Thermal Disposal Technologies

Various other thermal technologies have been applied to the demilitarization and
disposal of solid propellant rocket motors. They include incineration by rotary kiln,
plasma arc, and fluidized bed technologies. As a group, the techniques involve the
placement of the propellant or rocket motor into an externally heated chamber and then
thermally induced detonation, deflagration, or combustion of the energetic material.
Chamber walls are designed to contain the detonation products and shrapnel.
Atmospheric emissions are typically passed through commercial pollution abatement
systems before release into the environment. Thermal technologies are commercially
available from various sources.
Four explosive destruction technologies (EDTs) have been and are being
evaluated for disposal of the rocket motors separated from the M55 rockets stored at
BGAD and for other uses in chemical demilitarization and disposal processes.3 These
EDTs are a subset of the conventional demilitarization and disposal technologies
described in this chapter. The EDTs can be used to implement contained burning,
detonation, or perhaps static-firing technologies. They are called out separately because
they are already familiar to the Blue Grass Chemical Agent-Destruction Pilot Plant
(BGCAPP) project staff, the public around BGAD, and some state regulators. The four
EDTs are as follows:

Detonation of Ammunition in a Vacuum Integrated Chamber (DAVINCH),


such as the DAVINCH DV65 manufactured by Kobe Steel, Ltd. This process
would involve the detonation of a separated rocket motor with a donor
explosive in an evacuated chamber that will withstand the detonation.
Emissions are treated with a pollution-abatement system. A larger version of
the DV65, the proposed DV120, would have a throughput of 36 separated
rocket motors in a 10-hour day (NRC, 2009).
Sandia National Laboratorys Explosive Destruction System (the EDS-1 and
EDS-2). This contained detonation process would involve the detonation of a
separated rocket motor with a donor explosive in a chamber designed to
withstand the blast and contain the shrapnel and gases and then treatment of
the emissions. Currently available EDS units are designed to contain the
explosive force from not more than 4.8 lb TNT-equivalent net explosive
weight and thus do not have the capacity to treat intact M55 separated rocket
motors (NRC, 2009). In addition, the EDS is designed to crack open munition
casings to access chemical agent fills and then chemically neutralize the agent.
It is not designed primarily for the disposal of energetic materials.
The Static Detonation Chamber, such as the SDC 2000 from Dynasafe AB.
Energetic materials are dropped into a preheated blast chamber, where they
burn, deflagrate, or detonate. Shrapnel is contained in the blast chamber, and
gaseous emissions are passed to a holding tank for treatment. Dynasafe has
proposed an enlarged version of the SDC 2000 to treat about 100 separated
rocket motors in a 10-hour day (NRC 2009). An SDC has been used at the
3
See NRC, 2006 and NRC, 2009 for more detailed information.

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Anniston Chemical Agent Disposal Facility to dispose of overpacked and


problem munitions that could not be readily processed through the facility.
Detonation chambers, such as the Transportable Detonation Chamber and the
Contained Detonation Chamber, manufactured by CH2M HILL. As
constructed, these are contained detonation chambers. CH2M HILL has
proposed using a modified version of the D-100 chamber currently installed at
BGAD as a contained static-firing chamber in which separated rocket motors
would be fired in their design mode into a containment vessel before treatment
of the exhaust products. It has been estimated that this approach would permit
the treatment of 180 separated rocket motors in a 10-hour day (NRC 2009). A
Transportable Detonation Chamber was used at Schofield Barracks, Hawaii,
to dispose of recovered chemical weapons materiel.

CHEMICAL TECHNOLOGIES

Base Hydrolysis

In base hydrolysis, energetic waste is added to water at a mild temperature (90


150C) and high pressure (200 psig) with a strong base (pH > 12). Organic components
of the energetic waste are converted to water-soluble nonenergetic materials. The feed
rate needs to be controlled to prevent a violent exothermic reaction, that is, deflagration
or detonation of the propellant. To control the feed rate and ensure efficient and thorough
reaction, it is usually necessary to add propellant to the caustic solution as a slurry. A key
advantage of this technology is that energetic waste is converted to water-soluble
nonenergetic products, but the resulting solution is still hazardous and must be treated
further.

Supercritical Water Oxidation

Supercritical water oxidation treatment (SCWO) involves addition of a powdered,


liquid, or aqueous slurry of energetic waste to a solution of water and an oxidizer at high
temperature (over 374C) and high pressure (over 3,000 psig). The organic waste is
broken down to water-soluble, nonenergetic materials. Inorganic waste components, such
as lead, are oxidized to insoluble salts that can be filtered out of the waste stream. SCWO
is already being installed at BGCAPP to treat the products of the chemical neutralization
of chemical agent and energetic materials. Use of this technique on the M28 propellant
will require some preprocessing to get the energetic into an amenable form.
An advantage of this technology is that all organic chemicals are fully
decomposed and inorganic materials can be filtered out of the process stream. However,
the feedstock is usually in the form of a liquid or slurry, so it would be necessary to
remove propellant from motor and pretreat it to get it into an appropriate form; this
increases the amount of handling required with the concomitant risks. This is a
commercial technology that has been used on a pilot scale to treat waste energetics.

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Humic Acid Treatment

Humic acid treatment involves heating the propellant in a vat that contains a
mixture of caustic and humic acids. Phosphate is usually added to immobilize heavy
metals. The resulting products can usually be used as fertilizer, but application of the
technique to M28 rocket propellant disposal would require experimentation to verify that
lead in the propellant remains immobile and that other toxins are thoroughly destroyed.
The production of fertilizer could be an advantage of this technology. However,
the presence of lead and other toxins in the propellant could hinder the manufacture of
fertilizer. Furthermore the technique has been applied to only a few propellant
formulations. Where it has been successful, substantial work has been required to achieve
that success. The committee is not aware that humic acid has been used to treat a
propellant similar to the M28 propellant in the M55 rockets, and there is a lack of data
with which to assess whether it would be successful in treating this propellant. The
technology has been demonstrated on a pilot scale.

SUMMARY

Table 3-1 shows a comparison of advantages and disadvantages of each


technology described here, and Table 3-2 presents the committees judgment of
technology status and identifies technology developers or users. Regardless of where the
propellant is demilitarized, the selected facility must deal with handling, treatment, and
transportation of the propellant and with any political and treaty issues involved with
items derived from chemical weapons. Most of the facilities listed in Table 3-2 have not
been used to demilitarize rocket motors derived from chemical weapons.
Table 3-2 presents estimated process throughputs for each technology on which
such information was available. It has been estimated (see Chapter 4) that a separated
rocket motor processing throughput rate of 167 motors per day will be needed to keep
pace with M55 rocket processing at BGCAPP.
Open thermal technologies result in atmospheric releases of respirable lead dust
from the M28 propellant. That may place an additional constraint on the throughput of
these technologies. For instance, although a facility may be able to process sufficient net
explosive weight to dispose of 167 or more separated rocket motors per day, permit
restrictions on lead releases could potentially result in much lower throughput. Contained
thermal technologies, such as the EDTs, will prevent the release of lead into the
environment. The estimated throughput for any of the EDTs has yet to be validated.
A detailed consideration of public sentiment about disposal technologies is
beyond the scope of this committees work, but the public around BGAD, although now
closely involved in discussions about key project decisions, has historically used political
and permitting processes to attempt to achieve the outcomes that they desired. Thus, the
committee recognizes that public sentiment, albeit a nontechnical issue, could be an
important factor in how readily any disposal technology can be implemented and believes
that it should be mentioned in this report.

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The public around BGAD has been strongly opposed to the use of incineration to
dispose of chemical munitions and the resulting waste streams, such as the separated
rocket motors. The public around BGAD is strongly committed to disposing of as much
material as possible at BGCAPP by chemical neutralization followed by SCWO.
However, willingness to consider the use of alternative technologies, such as the EDTs,
in limited applications where safety and other compelling concerns point to them as the
best options has been developing. That subject is covered in more depth in Appendix B.
A key concern of the public around BGAD has been the release of toxic materials into the
environment. Complete containment of emissions from disposal processes is very
important to the public. That might indicate that, overall, a contained technology might
be more easily implemented than an open technology.

Finding 3-4. Thermal treatment demilitarization and disposal operations performed in a


chamber require the least handling and permit treatment of product emissions. Chemical
technologies either are not mature or are not readily implementable for the disposal of the
separated rocket motors.

Finding 3-5. The presence of lead in the M28 propellant may significantly constrain the
throughput rate for disposing of separated rocket motors with open thermal technologies
because of permit limits on the environmental release of lead.

Finding 3-6. The public around the Blue Grass Army Depot has historically been
concerned about the release of toxic materials into the environment. Public concerns have
been important in the disposal of chemical munitions and related wastes. They could also
affect how readily a technology for the disposal of separated rocket motors could be
implemented.

Finding 3-7. A contained thermal technology is the best option for disposing of the
rocket motors separated from the M55 rockets stored at the Blue Grass Army Depot.

31

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot
TABLE 3-1 Technology Comparison
Technology Description Advantages Disadvantages
Open Ordnance is placed on a pile, Handling is minimized. Atmospheric emissions are not treated further.
detonation surrounded with donor explosive,
Secondary waste streams are limited to Potential releases of respirable heavy-metal
and detonated.
unreacted materials, mostly metal case particles from the rocket motor or soil.
Copyright National Academy of Sciences. All rights reserved.

components.
Unreacted materials can be distributed over a
Sufficient data are present in emissions large area.
databases to permit estimation of process
emissions. Efforts to improve the databases are
under way.

Buried Propellants and donor are buried Handling is minimized. Atmospheric emissions are not treated further.
detonation under 48 ft of soil and detonated.
Noise is less than for open detonation. The presence of large quantities of soil in the
plume suppresses afterburning and increases
concentrations of products of incomplete
32

combustion. Little work has been done to


quantify this phenomenon, but tests to collect
pertinent data are under way.
There is a potential for environmental releases of
metals and organic chemicals from soil and
ordnance.

Open burning Loose propellant is placed into a Components of the missile are removed before Emissions are not processed further.
pan and initiated. Some facilities treatment.
Most propellants are designed to burn efficiently
use an additional fuel (e.g. JP-8)
Data in emissions databases permit estimation at high pressure. Burning at atmospheric pressure
to initiate and support combustion.
of process emissions. Efforts to improve the results in incomplete combustion.
Some facilities initiate the process
databases are under way.
by cracking open a rocket motor There would be atmospheric releases of
case with a shaped charge. respirable heavy metals (e.g., lead) from the
propellant.
Rocket motors require prior removal of the
propellant from the case to prevent the possibility

32
Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot
TABLE 3-1 Continued
Technology Description Advantages Disadvantages
of propulsive events; this increases ordnance
handling.
Ash from the process must be treated as MPPEHa
and is probably laden with heavy metals.
Copyright National Academy of Sciences. All rights reserved.

Open static The rocket motor is secured, then Handling is minimized. Atmospheric emissions are not treated further.
firing initiated in its design mode.
Combustion occurs at high pressure, and this A nontrivial fraction of lead in the propellant
improves efficiency. remains in the carcass after treatment in the form
of lead metal and lead oxide dust.
There are thermochemical models for
predicting emission products. The carcass will require assessment as hazardous
waste and MPPEH.a
Components of the rocket motor (such as case,
fins, and electronics) can be recovered after Aged propellant can crack, slump, shrink, or
treatment. change density. In extreme cases, that can result
33

in overpressurization of the motor bottle after


ignition, which can lead to catastrophic failure of
the rocket motor. Such a failure can damage
facilities and may initiate a re-evaluation of
procedures.

Contained An ordnance item or energetic Handling is minimized. Over time, shrapnel can damage the facility and
detonation component is placed into a sealed limit facility lifetime.
Emissions are treated before release into the
detonation chamber. A donor
environment. Large residues need to be removed after each
charge is often required. The
treatment event to minimize shrapnel.
detonation reaction is initiated.
Afterburning reactions are often Emissions of toxic metal, semivolatile chemicals,
quenched as a result of efforts to or nonvolatile chemicals from the ordnance will
protect the integrity of the contaminate the interior of the detonation
chamber. After detonation, chamber.
product gases and particles are
passed through pollution control Regular leak checks are needed to prevent
instrumentation to remove environmental contamination as the detonation
undesirable contaminants. chamber ages.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot
TABLE 3-1 Continued
Technology Description Advantages Disadvantages
Contained Propellant is placed into a pan in a Handling is minimized. Large residues need to be removed after each
combustion combustion chamber and initiated. treatment event to minimize damage to the
Emissions are treated before environmental
Product gases are collected in a chamber from flying debris.
release.
holding tank and then processed
Emissions of toxic metal, semivolatile chemicals,
through a pollution abatement
Copyright National Academy of Sciences. All rights reserved.

and nonvolatile chemicals from the combustion


system.
will contaminate the interior of the burn
chamber.
The carcass will require assessment as hazardous
waste and MPPEH.a

Contained The rocket motor is secured and Handling is minimized. A nontrivial fraction of lead in the propellant
static firing fired into a containment vessel in remains in the carcass after treatment in the form
Combustion occurs at high pressure, and this
its design mode. After of lead metal and lead oxide dust.
improves efficiency.
combustion, atmospheric
Emissions of toxic metal, semivolatile chemicals,
contaminants are processed Emissions are treated before environmental
34

and nonvolatile chemicals from the combustion


through a pollution abatement release.
will contaminate the interior of the burn
system.
chamber.
The carcass will require assessment as hazardous
waste and MPPEH.a
Aged propellant can crack, slump, shrink, or
change density. In extreme cases, that can result
in overpressurization of the motor bottle after
ignition and lead to catastrophic failure of the
rocket motor. Such a failure can damage facilities
and may initiate a re-evaluation of procedures.

Confined A rocket motor is placed into a Handling is minimized. Few commercial atmospheric filtration devices
combustion combustion chamber and initiated. are capable of real-time handling of the changes
Emissions are treated before environmental
Product gases are not contained in temperature, pressure, and flow rate that occur
release.
but are passed immediately during a motor firing.
through pollution abatement
Large residues need to be removed after each

34
Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot
TABLE 3-1 Continued
Technology Description Advantages Disadvantages
equipment before release into the treatment event to minimize damage to the
environment. chamber from flying debris.
Work at China Lake involved Emissions of toxic metal, semivolatile chemicals,
burning of full-scale rocket and nonvolatile chemicals from the ordnance
Copyright National Academy of Sciences. All rights reserved.

motors with the nozzle removed. combustion will contaminate the interior of the
burn chamber.
The carcass will require assessment for treatment
as hazardous waste and MPPEH.a

Rotary kiln This is an enclosed incinerator in High feed rates have been demonstrated. Deflagration or detonation of energetic materials
which waste is slowly moved can damage facilities and interrupt operations.
Emissions are treated.
from one end to the other. Waste
Few atmospheric filtration devices are capable of
material detonates or combusts.
handling the extreme changes in pressure and
Emissions are treated.
flow rate that occur during a large detonation
event; this will limit the treatment rate.
35

Careful control of feedstock and combustion


conditions is needed to minimize production of
toxins like dioxins.

Fluidized bed Energetic waste is injected into a Emissions can be treated. The technique is limited to liquids, slurries, and
turbulent bed of hot sand. powders that have low inorganic content.
Substantial handling is needed to remove solid
propellants and convert them to a form amenable
to treatment.

Static Ordnance is dropped into a heated Handling is minimized. The furnace will need to be turned off regularly
Detonation chamber, where it detonates, to empty the chamber of collected incombustible
Emissions are scrubbed.
Chamberb deflagrates, or combusts. Product residues.
gases are scrubbed with a
Residues from rocket motors separated from
pollution abatement system.
M55 rockets will probably be contaminated with

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot
TABLE 3-1 Continued
Technology Description Advantages Disadvantages
lead and require lead abatement to handle.
Facility lifetime is limited by damage to the
detonation chamber from shrapnel.
Copyright National Academy of Sciences. All rights reserved.

Base Energetic wastes are added to Energetic waste is converted to water-soluble The resulting solution is still hazardous and must
hydrolysis water and heated to mild nonenergetic products. be treated further.
temperatures (90150C) usually
Careful control of feed rate is needed to prevent
at high pressure (200 psig) with a
the deflagration or detonation of propellant.
strong base (pH > 12); this
chemically degrades the energetic
materials.

Supercritical Organic waste, water, and an Organic chemicals are decomposed. Feedstock is usually in the form of a liquid or
36

water oxidizer (such as hydrogen slurry. It is necessary to remove propellant from


oxidation peroxide) are subjected to high the motor and pretreat it to get it into an
temperature (>374C) and appropriate form.
pressure (>3,000 psig); this
chemically degrades the organic
waste.

Humic acid Energetics are heated in a vat that Product is fertilizer. Used to date only on a few propellants.
treatment contains a mixture of caustic and
The record of success is mixed.
humic acids. Phosphate is usually
added to immobilize heavy The method might require much work for
metals. application to M28 propellant.
There is a lack of data with which to assess the
likelihood that the technology will work on M28
propellant.
a
MPPEH, materials potentially presenting an explosive hazard.
b
See discussion in section Other Thermal Disposal Technologies.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

TABLE 3-2 Technology Status and Applicability


Technology developer or Estimated M55 rocket motor
Technology Technology status representative user throughputa
Open Mature Naval Air Weapons Station, N/A
detonation China Lake (user)
Hill Air Force Base (user) N/A

Buried Mature Tooele Army Depot (user) N/A


detonation
Defense Ammunition Center N/A
(user)
Anniston Army Depot (user) N/A

Open burning Mature Naval Surface Warfare Center, N/A


Indian Head (user)
BGAD (user) 300 per event

Open static Mature Tooele Army Depot (user) N/A


firing
Anniston Army Depot (user) N/A
McAlester Army Ammunition
Plant (user)

Contained Commercially Naval Surface Warfare Center, N/A


detonation available Crane (developer and user)
Tooele Chemical Agent N/A
Destruction Facility (user,
DAVINCH DV65)
CH2M HILL (developer, D-100 N/A
Detonation Chamber)
Kobe Steel (developer, 36 per day for the Kobe
DAVINCH) Steel DAVINCH DV120
(NRC, 2009)

Contained Commercially Naval Surface Warfare Center, N/A


combustion available Crane (developer and user)
Naval Surface Warfare Center, N/A
Indian Head (developer and user)
CH2M Hill (developer) N/A

Contained static Commercially Naval Air Warfare Center, China N/A


firing available Lake, in partnership with
Lockheed-Martin (developer)
El Dorado Engineering N/A

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

TABLE 3-2 Continued


Technology developer or Estimated M55 rocket motor
Technology Technology status representative user throughputa
(developer)
CH2M Hill (developer, D-100 180 per day for static firing
Detonation Chamber) in the CH2M HILL D-100
Detonation Chamber (NRC,
2009)

Confined Sub-pilot and pilot Naval Air Warfare Center, China N/A
combustion scale Lake, in partnership with
Lockheed-Martin and Bechtel
(developer)
Rotary kiln Commercially Tooele Army Depot (user) N/A
available for small
munitions

Fluidized bed Pilot scale Defense Ammunition Center N/A


(user)

Static Commercially Anniston Chemical Agent


Detonation available Disposal Facility (user)
100 per day, upgraded SDC-
Chamber
Dynasafe AB (developer) 2000 (NRC, 2009)

Base hydrolysis Commercial process Defense Ammunition Center N/A


(user)

Supercritical Commercial process Defense Ammunition Center N/A


water oxidation (user)

Humic acid Pilot-scale Defense Ammunition Center N/A


treatment demonstration (user)
a
Estimate based on a 10-hour workday.

REFERENCES

DoD (Department of Defense). 2008. Department of Defense Instruction: Material


Potentially Presenting an Explosive Hazard, Number 4140.62, November 25.
Available online at http://www.dtic.mil/whs/directives/corres/pdf/414062p.pdf. Last
accessed on May 17, 2012.
DoD. 2011. Department of Defense Manual: Defense Demilitarization, 4160.28-M,
Volume 13, June 7. Fort Belvoir, Va.: Defense Technical Information Center.

38

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

EPA (Environmental Protection Agency). 2009. AP 42: Compilation of Air Pollutant


Emission Factors, volume 1, chapter 15, Ordnance Detonation. Fifth Edition. Available
online at http://www.epa.gov/ttn/chief/ap42/ch15/index.html. Last accessed on May
17, 2012.
Erickson, E.D., A.P. Chafin, T.L. Boggs, L.A. Zellmer, and B.M. Abernathy. 2005.
Emissions from the Energetic Component of Energetic Wastes During Treatment by
Open Detonation, NAWCWD TP 8603, June. China Lake, Calif.: Naval Air Warfare
Center Weapons Division.
Kim, B.J. 2010. Feasibility of New Technology to Comprehensively Characterize Air
Emissions from Full Scale Open Burning and Open Detonation, SERDP Project WP-
1672, Final Report, December. Available online at http://www.serdp.org/
content/download/9560/122378/file/WP-1672-FR.pdf. Last accessed on May 17, 2012.
NRC (National Research Council). 2006. Review of International Technologies for
Destruction of Recovered Chemical Warfare Materiel. Available online at
http://www.nap.edu/catalog.php?record_id=11777. Last accessed on June 29, 2012.
NRC. 2009. Assessment of Explosive Destruction Technologies for Specific Munitions at
the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants. Available online
at http://www.nap.edu/catalog.php? record_id=12482. Last accessed on May 17, 2012.
Wright, J., E. Erickson, and G. Thompson. 2010. Open Detonation (OD) Emission Factor
Development. Presentation to the 18th Annual Global Demilitarization Symposium
and Exhibition. May 10-13, Tulsa, Okla.

39

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

4
Storage of Separated Rocket Motors

THE NEED FOR STORAGE SPACE FOR SEPARATED ROCKET MOTORS

For a variety of reasons (e.g., permit restrictions and throughput capability), the
rate at which any given technology disposes of the separated rocket motors1 will probably
be lower than the rate of rocket-cutting operations in the Blue Grass Chemical Agent-
Destruction Pilot Plant (BGCAPP). Disposal of the separated rocket motors therefore has
the potential to be a limiting step in overall M55 rocket disposal. Rocket motor storage
and transportation to an eventual disposal facility (either on-site or off-site) will mitigate
the impact of the disparate processing rates, but separated rocket motor storage is a
potential and serious bottleneck that could affect the planned rate of M55 rocket-cutting
operations at BGCAPP. BGCAPP will have temporary storage for the separated rocket
motors. However, once the storage area reaches capacity, if the separated rocket motors
cannot be transported to an outside storage or disposal site at least as quickly as they are
being produced, they will accumulate at BGCAPP, and the planned rocket-cutting and
warhead-processing operations would need to be slowed or halted. The centrality of
storage of separated rocket motors is shown in Figure 4-1.

New onsite
Munitions Onsite
storage for
demilitarization building government
BGCAPP temporary separated separated rocket
disposal
rocket motor storage motors

Onsite contractor
disposal
Onsite storage and
return to BGCAPP
for disposal

Offsite disposal at Offsite disposal of at


government one or more
facility contractor sites

FIGURE 4-1 Diagram showing the importance of storage for the disposal of separated rocket motors.

Finding 4-1. The provision of adequate storage space for the separated rocket motors is
important for the overall rate of operations for M55 rocket disposal at the Blue Grass

1
See Appendix A for how the committee defines separated rocket motor.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Chemical Agent-Destruction Pilot Plant. Rocket-cutting and warhead-processing


operations would need to be slowed or halted if the combination of storage capacity and
separated rocket motor disposal could not meet the rate at which separated rocket motors
are produced.

REQUIREMENTS FOR STORAGE OF SEPARATED ROCKET MOTORS

It is estimated that the peak processing rate of M55 rockets at BGCAPP will be 20
GB-filled rockets per hour or 24 VX-filled rockets per hour, producing 20 or 24 separated
rocket motors, respectively, per hour. Overall, BGCAPP estimates that about 3,350
separated rocket motors would be ready for disposal per month. The munitions
demilitarization building is designed for a storage capacity of 1.25 operating days.2 There
is currently no additional designated storage space for separated rocket motors at the Blue
Grass Army Depot (BGAD) apart from the planned storage area at BGCAPP.
The limited storage capacity subjects the M55 processing operations to delays if
unexpected events occur, such as a shutdown of a rocket motor disposal facility in the
event of a safety incident or transportation delay. It is important to have storage capacity
sufficient to permit continuing rocket processing at BGCAPP if upsets in the schedule of
disposal of separated rocket motors occur.
It is also necessary to meet Environmental Protection Agency (EPA) and
Kentucky requirements regarding hazardous waste storage. The separated rocket motors
are explosive hazardous waste, and Resource Conservation and Recovery Act (RCRA)
requirements regarding storage of explosive hazardous waste must be met. Once a rocket
motor is separated from the warhead, the motor must be stored in a designated hazardous
waste storage site. The planned BGCAPP storage area can serve as a hazardous waste
storage site, but accumulating hazardous waste must comply with 40 CFR 262.34, which
limits the time that explosive hazardous waste can be stored before being disposed of.
Noncompliance with EPA and Kentucky hazardous waste regulations can result in
enforcement actions and fines.

CREATING ADDITIONAL STORAGE SPACE AT THE


BLUE GRASS ARMY DEPOT
The creation of expanded new safe storage space on site at BGAD outside the
physical boundaries of the BGCAPP facility would provide greater assurance that M55
rocket processing could continue without interruption caused by limits on safe storage-
space capacity. The committee believes that it is much more likely that substantial
additional safe storage space can be created on site at BGAD than at BGCAPP.
Furthermore, safe intra-installation transportation will facilitate movement of separated
rocket motors to any newly created safe storage space at BGAD.
The requirements for additional safe storage space on site at BGAD depend on
many factors. For example, the designated hazard classification of the separated rocket

2
Ron Hawley, Plant General Manager, Bechtel Parsons Blue Grass Team, Rocket Processing,
presentation to the committee, March 20, 2012.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

motors will define the quantity that may be stored at a given location, the distance
required between the storage area and other activities, and additional security and siting
issues (U.S. Army, 2011). Storage of rocket motors at BGAD would need to be in
magazines site-approved for storage of Hazard Class 1 materials. The magazines would
also need to meet both RCRA hazardous waste regulations and explosive safety
requirements. The site-approved magazines would need to be designated as long-term
(180-day) RCRA explosive hazardous waste sites and be managed as such as provided in
Section 3500 of RCRA and in 40 CFR 270. (Hazard classification is discussed in more
depth in Chapter 2.)
The committee has been informed that preliminary discussions between BGCAPP
and BGAD staff indicate that magazine storage space at BGAD is limited and may
already be filled to capacity. Nonetheless, because BGAD conducts demilitarization of
waste military munitions as part of its mission, the installation may already have RCRA-
permitted magazines designated for storage of waste military munitions or other
explosive hazardous waste munition components that could be used for storage of
separated rocket motors.

Finding 4-2. The planned rocket destruction throughput at the Blue Grass Chemical
Agent-Destruction Pilot Plant may be at risk because of insufficient capacity for storage
of separated rocket motors.

Recommendation 4-1. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should secure additional space for storage of separated rocket motors. It is essential that
discussion with Blue Grass Army Depot staff concerning the option for securing such
additional space at the depot be given high priority.

If the separated rocket motors qualify as waste military munitions, an alternative


option would be to designate BGAD magazines as conditionally exempt magazines3 for
storage of waste military munitions. That would allow long-term storage as long as
quarterly monitoring of the condition of the stored materials is documented and records
of it are provided to the state. Kentucky has not adopted the Munitions Rule (see 40 CFR
266.202) and has not developed any state-specific military munitions rules. Military
munitions are regulated by the Division of Waste Management of the Kentucky
Department for Environmental Protection. Regulations for the state's RCRA hazardous
waste management, including military munitions, are provided in Title 401, Natural
Resources and Environmental Protection Cabinet, Department for Environmental
Protection, Chapters 3036 and 38 of the Kentucky Administrative Rules (KAR), with
definitions in Chapter 224 of the Kentucky Revised Statutes (KRS). The process would
thus require coordination with the Kentucky Department for Environmental Protection.

3
40 CFR 266.205(a) gives the storage requirements (and exemptions) for munitions that are
exempted from being considered RCRA hazardous waste, as set forth in 40 CFR 266.203 (3)(1). When
following or invoking these definitions and requirements the military calls the storage areas conditionally-
exempt magazines.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

Finding 4-3. If the separated rocket motors qualify as waste military munitions,
magazines could potentially be designated as conditionally exempt to allow long-term
storage of separated rocket motors.

RETURNING SEPARATED ROCKET MOTORS TO THE M55 ROCKET


STORAGE IGLOOS

One possibility for additional safe storage of separated rocket motors would
appear to be returning them to the existing M55 rocket igloos as the igloos are vacated.
However, lethal and incapacitating chemical munitions and agents (that is, chemical
surety material) are generally stored separately from conventional ammunition and
explosives. The igloos in which the M55 rockets were originally stored could not readily
be used for storage of the separated rocket motors unless appropriate explosive safety site
approvals were obtained. A new application for site approval for storing rocket motors in
the original rocket storage igloos would need to be submitted and approved by the
Department of Defense Explosive Safety Board. Approval from the Kentucky
Department for Environmental Protection would also likely be necessary. The igloos
would need to be free of contamination with chemical agents before being reused for
storing separated rocket motors. Because of the logistics of the movement of M55 rockets
out of the igloos, the turnaround time for producing separated rocket motors that need
storage, and the time necessary for obtaining site approvals, returning separated rocket
motors to igloos for storage would require much planning and coordination.

Finding 4-4. Reusing emptied M55 rocket storage igloos for storage of separated rocket
motors is a possible solution to the problem of inadequate storage space. Pursuing this
option would entail much coordination and planning and would take time.

Recommendation 4-2. If a decision is made to pursue this option, Blue Grass Chemical
Agent-Destruction Pilot Plant program staff should prepare a plan to convert the M55
rocket storage igloos to hazardous waste storage sites that are also site-approved for the
storage of explosives. The plan should include management of the transition without the
need to submit separate approval requests one igloo at a time.

PROPELLANT DEGRADATION, STABILIZER DEPLETION, AND


STORAGE RISK

It is well understood that double-base rocket propellants, such as the M28


propellant in the M55 rockets, are subject to chemical degradation that decreases their
stability in storage and increases storage risk.4 Propellant degradation is mitigated by a
chemical additive called a stabilizer, such as 2-nitrodiphenylamine, that is depleted as it
traps the reactive gases that result from propellant degradation. Stabilizer depletion in

4
Storage risk is defined in Appendix A.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

turn can lead to a risk of autoignition of the propellant. Thus, storage risk increases with
storage time. Although stabilizer depletion is known to occur in the case of M28
propellant, previous studies have estimated that the frequency of autoignition of
propellant in intact M55 rockets and the overall storage risk are very low (U.S. Army,
2002).
The storage risk may be greater in the case of separated rocket motors than intact
M55 rockets. The shipping and firing tube that contains the intact M55 rocket isolates the
rocket motor from environmental conditions. During processing at BGCAPP, the
shipping and firing tube is cut, and this exposes the separated rocket motor to
environmental factors, such as humidity and heat, more than when it is part of an
assembled M55 rocket. Humidity can accelerate chemical reactions with the nitrogen
oxide gases formed from the degrading nitrate ester. The nitrogen oxide gases accelerate
nitrocellulose decomposition and stabilizer depletion; this leads to a self-accelerating
cycle. Heat also increases the stabilizer depletion rate in the M28 propellant by increasing
the rate of nitrocellulose degradation. The storage of intact M55 rockets in their pallets
and in overpacked configurations and their ability to dissipate excess heat from the
propellant were studied in 2002. The study found no immediate risk of propellant
autoignition in these configurations (U.S. Army, 2002). However, when the rocket
motors are separated from the M55 rockets and placed in new packaging, they are in a
new configuration, and prior safe-storage assessments may not be directly applicable.
Thus, separated rocket motors may have a shorter safe-storage life than assembled M55
rockets.

Finding 4-5. Storage risk may increase more quickly in the case of separated rocket
motors than assembled M55 rockets because of the increased environmental exposure of
the separated motors. The effects of this environmental exposure on the separated rocket
motors have not been characterized.

Recommendation 4-3. The Blue Grass Chemical Agent-Destruction Pilot Plant program
staff should dispose of separated rocket motors as soon as possible, using a first in, first
out protocol to minimize storage time and reduce risk.

REFERENCES

U.S. Army. 2002. M55 Rocket Assessment Summary Report, July. Aberdeen Proving
Ground, Md.: U.S. Army Program Manager for Chemical Demilitarization.
U.S. Army. 2011. Ammunition and Explosives Safety Standards, Department of the
Army Pamphlet 38564, May 24. Available online at http://armypubs.army.mil/epubs
/pdf/p385_64.pdf. Last accessed May 17, 2012.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

5
Options for Disposal of Separated Rocket Motors
In view of the various considerations and disposal technologies and their
advantages and disadvantages, discussed in previous chapters, a variety of possible
options exist for the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) and
the Blue Grass Army Depot (BGAD) to dispose of rocket motors separated from the M55
rockets stored at BGAD. These options, which fall into two main groups, were evaluated
by the committee:

On-site disposal options,


Open burning of the propellant grain at the BGAD permitted explosive
hazardous waste treatment facility,
Using the D-100 chamber currently at BGAD,
Disposal using alternative technologies (technologies not currently
resident at BGAD) that can be added to BGAD capabilities,
Disposal at the BGCAPP facility after completion of all chemical
agent destruction operations, and
Off-site disposal options.

The committee envisions that the separated rocket motors would be removed from the
shipping and firing tubes (SFTs) before the motors are disposed of, in part because the
SFTs contain polychlorinated biphenyls (PCBs). The issue of PCBs is discussed in more
detail below.

ON-SITE1 DISPOSAL OPTIONS

Open Burning of Propellant Grain at the BGAD Permitted Facility

If the SFT and the rocket motor case can be cut such that the propellant grain
could be readily removed from the rocket motor case, open burning of the propellant is an

1
In this report, the committee is using on-site to indicate disposal not at BGCAPP but at the
BGAD facility.

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option.2 The BGAD open burning/open detonation site is currently operating under an
interim status permit that allows treatment of 6 million pounds net explosive weight per
year for the whole site. Open-burn pans are site-approved for 6,000 lb per event. So if
200 M55 rockets were cut each day, each with a propellant weight of about 20 lb, BGAD
could carry out one 4,000-lb event every day and keep up with the pace of rocket motor
accumulation (weather and other workload permitting). A proposal with some
engineering design would be needed to test out base plate removal and propellant grain
extraction. Standard operating procedures (SOPs) or SOP modifications would need to be
written and approved for removal of the M28 propellant and the M62 rocket motor igniter
assembly.
Since the M28 grain contains lead stearate, the environmental office would need
to ensure that lead emissions remain within the permitted levels for their current air
pathway hazards assessment for the amount of propellant to be burned. Although BGAD
already has a Resource Conservation and Recovery Act (RCRA) Subpart X permit to
dispose of waste energetics, the levels of lead in the M28 propellant grain could restrict
the throughput of separated rocket motors.
The open burning of the propellant grain option would have the following
advantages:

There would be no need to modify the existing permit or apply for a new one,
provided lead releases do not exceed permitted levels;
If open-burning operations could keep pace with rocket cutting operations at
BGCAPP, the need for a large volume of long-term storage would be
eliminated;
SOPs are in place for open burning, though a modified SOP might be needed
for open burning of the M28 propellant grain;
There would be a significant reduction in the risk of endangerment by
eliminating the long-term storage of a hazardous material of unknown
stability;
The steel case could be readily inspected, the removal of all energetic
materials verified, and the case certified as safe for recycling;
The inert components could be accumulated for subsequent bulk disposal;
During thermal destruction, deflagration (burning) of a confined energetic
material could lead to an explosion or a transition to detonation. Removal of
the propellant grain from the steel case would eliminate the tight confinement
of the energetic material during thermal destruction; and
If the M28 propellant was removed before thermal treatment, the concern
about lead contamination of the metal components would be eliminated and
metal components could be readily demilitarized and recycled as processed
scrap metal.

The disadvantages of this option would include these:

2
Robotics strategies that have been developed for other conventional ordnance items could be
applied if the propellant does not easily slide out. Sandia National Laboratories has developed such
strategies.

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The removal of the propellant grain would entail greater handling of the
separated rocket motors than a disposal option that disposed of the propellant
grain while it was still within the motor case.
Lead would be released into the local environment in the form of fine
particulate matter. Over the course of treating 70,000 M55 rocket motors, the
total potential quantity of lead released would exceed 3 tons. This might
require the Kentucky Department for Environmental Protection (KDEP) to set
constraints on treatment schedules to minimize the impact on the local
population and the environment.
The lead releases could restrict throughput of motors to fewer than the number
that could be achieved based on net explosive weight limits.
BGAD currently disposes of conventional ordnance under the Program
Manager for Demilitarization. The rocket motor disposal workload would
need to be synchronized with already existing open-burning commitments.

Finding 5-1. The Blue Grass Army Depot has a permitted, operational open-burning site
that might be capable of meeting separated rocket motor disposal requirements.

Recommendation 5-1. If the option to burn the M28 propellant grain in the open is
investigated, the Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should consult the Blue Grass Army Depot on its workload and determine if the open-
burning unit could be available and easily scheduled for M28 propellant grain disposal.

Recommendation 5-2. Blue Grass Chemical Agent-Destruction Pilot Plant program staff
should request an engineering design proposal for safely removing the M28 propellant
grain from the rocket motor case to determine if the open-burning demilitarization option
would be practical to implement.

Use of the Existing D-100 Detonation Chamber at BGAD

One alternative to open burning would be for BGAD to design upgrades to the D-
100 detonation chamber already operational at BGAD although not currently in use. This
chamber could be used to perform contained burn or static firing disposal operations. As
currently designed, the D-100 detonation chamber is an explosive destruction technology,
which is discussed in more detail in Chapter 3. CH2M HILL, the chamber manufacturer,
and BGAD have proposed modifying this chamber to dispose of the separated rocket
motors.3 The throughput estimate is as high as 180 separated rocket motors per day for
the D-100 (NRC, 2009).
In the event the rocket motor is unstable or if the propellant is cracked or
degraded, a static fire could transition to detonation inside the chamber, damaging it and
possibly putting it out of commission until cleared to operate again. In any case, damage
to the chamber would accumulate in the course of normal operations, necessitating
maintenance and periodic repairs.

3
The committee was not able to see the details of this proposal because they are competition
sensitive.

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As noted above, the M28 propellant contains lead stearate. As separated rocket
motors are disposed of, lead compounds and residues would accumulate inside the
chamber on walls and floors and on the metal scrap. Abatement activities such as lead
monitoring and worker protection would be needed for personnel entering and working
inside the chamber. The presence of lead on the metal scrap could also complicate the
recycling of the metal scrap. The logistics associated with chamber cleanup and
maintenance, motor stand preparation, and lead abatement activities will require an
investment of time and resources to maintain the estimated throughput for this system.
The chamber would need to meet environmental and explosives safety criteria,
and BGAD would need to obtain a RCRA hazardous waste permit modification for
disposal of separated rocket motors in this chamber. Discussions with KDEP might result
in operating the D-100 under interim status until a final permit is issued by the state.
Obtaining these permits can be done within the time frame of the BGCAPP project if
KDEP input is sought early in the decision process. Similar units have already been
designed, installed, and used at other demilitarization sites to dispose of both
conventional and chemical munitions. The Controlled Detonation Chamber, for instance,
also manufactured by CH2M HILL, was used to dispose of recovered chemical warfare
munitions at Schofield Barracks, Hawaii. This experience might ease the permitting
process.
The use of the modified D-100 to dispose of the separated rocket motors would
have the following advantages:

All emissions and waste products from disposal would be contained.


Detonation chambers similar to the D-100 have already been used to dispose
of conventional and chemical munitions.
The D-100 is already on-site and is undergoing permitting. Adapting it for
separated rocket motor disposal would only entail modifications to the
existing chamber and a permit modification.
The entire separated rocket motor would be disposed of, requiring less
handling of the motors than in the open burn option.
The use of the D-100 would have the following disadvantages:
When factoring in maintenance, repairs, and unanticipated interruptions in
processing, the projected throughput rate for the D-100 might not quite keep
pace with the rate of separated rocket motor production at BGCAPP. This
would entail the need for either more than one disposal unit, not necessarily a
D-100, or the creation or securing of additional storage space on BGAD.
Lead compounds will accumulate in the chamber over the course of operation,
necessitating lead abatement and work protection activities.
Lead will also accumulate on the metal scrap from separated rocket motor
disposal, possibly complicating the recycling of this scrap.
A separated motor transitioning to detonation during disposal could damage
the chamber and have a significant impact on ongoing disposal operations and
thus on schedule.

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Alternative Disposal Technologies That Could Be Added to BGAD Capabilities

BGAD also has the option of contracting with a vendor to install a suitable
disposal technology other than the D-100 on-site for separated rocket motor disposal.
Several commercial units, discussed in Chapter 3 as explosive destruction technologies
and treated in more detail in NRC, 2009, are available. Some of these have been used at
other sites for chemical demilitarization operations.
The Kobe Steel DAVINCH is in use in Poelkapelle, Belgium, disposing of First
World War-era munitions. It has been estimated that the DAVINCH DV120 could
dispose of 36 separated rocket motors per day (NRC, 2009). The Dynasafe AB Static
Detonation Chamber has been used at Anniston to augment destruction of munitions at
the Anniston Chemical Agent Disposal Facility and is also in use in Munster, Germany,
for disposing of First World War-era munitions. It has been estimated that an upgraded
SDC 2000 could dispose of 100 separated rocket motors per day (NRC, 2009). This is not
meant to be an exhaustive discussion, and other commercial firms, such as El Dorado
Engineering, also provide contained disposal technologies that might possibly be used to
dispose of the separated rocket motors.
Depending on the system design, multiple separated rocket motors could be
treated simultaneously in a disposal unit. There would be a nominal setup time, but a long
postfire period might be needed with some systems to allow rocket emissions to cool and
settle before the chamber could be opened. All of these systems options are contained
units and thus share the issues discussed above regarding the D-100. Contracting with a
vendor to install a disposal unit could prove simpler than upgrading and retrofitting the
current D-100 detonation chamber; it might also ease the permitting process if the vendor
has experience in installing units in states other than Kentucky.
The advantages and disadvantages of any of these contained disposal technologies
would be substantively similar to those for the D-100 enumerated above. One possible
advantage is that, as mentioned above, contracting with a vendor to install, and perhaps
operate, a technology that has already been successfully used in some way in the
chemical demilitarization enterprise might be simpler from a permitting standpoint than
modifying the D-100 and obtaining the necessary permit modification. A possible
disadvantage is that the technologies for which estimated rates are available have
throughput rates well below the planned rate of separated rocket motor generation at
BGAD. This would mean having more than one of these units in operation and/or greatly
expanded storage for the separated rocket motors.

Finding 5-2. There are alternative disposal technologies to open-burning that can be
instituted at the Blue Grass Army Depot. However, the use of these alternative
technologies would necessitate the inclusion of design, construction, and permitting time
into the project schedule.

Finding 5-3. A D-100 detonation chamber is currently operational at the Blue Grass
Army Depot to dispose of conventional munitions. It is possible that this could be
modified and permitted to dispose of the separated rocket motors. A number of other
contained technologies are available from commercial vendors, and it might prove

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simpler to contract for one of these to be installed than to modify the D-100 and obtain
the necessary permit modification.

Finding 5-4. Use of any contained technology for the disposal of separated rocket motors
would result in contamination of the chamber and any scrap metal with lead. This would
necessitate lead abatement and worker protection activities and, possibly, complicate the
recycling of metal scrap.

Disposal of Separated Rocket Motors at BGCAPP after Completion of All Chemical


Agent Destruction Operations

Another option would be to store the separated rocket motors until all chemical
agent destruction operations at BGCAPP are complete. The BGCAPP facility could then
shift to the disposal of the separated rocket motors. The separated rocket motors could
then be disposed of using the base hydrolysis technology already at BGCAPP and the
same methodology as used for disposing of rocket motors contaminated with chemical
agent. BGAD would need to confirm that is has enough safe storage capacity for all of
the separated rocket motors on-site until all chemical agent disposal has been
accomplished. This would lead to increased storage risk4 compared to disposal of
separated rocket motors concurrent with M55 rocket cutting operations at BGCAPP, as
discussed in Chapters 2 and 4. The increased risk would be due to the normal issues
associated with aging and degrading propellant as well as, perhaps, accelerated
degradation of the separated rocket motors because they would be subject to greater
environmental exposure than an assembled M55 rocket in its SFT. For this reason, the
committee does not believe this is a good option.

Finding 5-5. The separated rocket motors could be stored and then disposed of using the
BGCAPP base hydrolysis process after chemical agent destruction operations are
complete. However, there is an increased storage risk inherent in this option.

Public Sentiment

While not an explicit item in the statement of task for the committee, public
sentiment would have a significant impact on the ability to implement any chosen
disposal technology or option (on-site versus off-site). The public has been very involved
thus far in the choice of the technologies for use at BGCAPP and in all subsequent
decisions involving BGCAPP, and it can be expected to be involved in this decision also.
As such, the committee believes public sentiment needs to be considered. The public
living and working around BGAD has historically been opposed to anything that
resembles the incineration of the wastes from chemical munitions, of which the separated
rocket motors are one, and it could have significant concerns about the disposal of the

4
Storage risk is defined in Appendix A.

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propellant grain by open burning. The committee believes the public is likely to be
sensitive to the issue of lead emissions from open burning.
Public sentiment has been evolving positively regarding the use of explosive
destruction technologies (discussed in Chapter 3) and perhaps, by extension, of any
contained disposal technology to process chemical munitions and the waste streams
resulting from chemical demilitarization operations, of which the separated rocket motors
are one. Contained disposal technologies also address the publics concerns about
emissions to the environment.
While these considerations are not listed under the advantages and disadvantages
of the on-site disposal options, the committee considers them worthy of mention and
consideration. A historical overview of public sentiment about contained disposal
technologies (specifically EDTs) and options (on-site versus off-site) can be found in
Appendix B.

OFF-SITE5 DISPOSAL OPTIONS

There are technically sound off-site disposal options for the separated rocket
motors from BGCAPP. Using an off-site disposal option could free BGCAPP from
having to choose a technology to dispose of the separated rocket motors. Indeed, the
selection of the disposal technologies used may be a secondary factor when considering
off-site disposal. Off-site disposal facilities might be able to use more than one
technology concurrently to meet the schedule for the destruction of the energetic material
in the separated rocket motors. One or more off-site facilities might be able to safely and
efficiently conduct disposal operations in compliance with their respective site permits
and regulatory requirements and within the project schedule. Overall, the off-site disposal
of the rocket motors would allow for flexibility in the disposal technologies and strategies
used.
One consideration regarding off-site disposal is that the motors of the M55
rockets are a unique propulsion system designed specifically for that rocket. It is thus
unlikely that any off-site facilities have ever disposed of these specific separated rocket
motors before. There are, however, likely facilities that have disposed of similar double-
base propellant rocket motors in the past, so the uniqueness of the rocket motors from the
M55 rockets might not be that much of an issue.
Separated rocket motors that have been cleared for transportation and disposal
off-site would have to be received by facilities that are capable of meeting the disposal
requirements, including any precautionary requirements that may be in place for
disposing of munition components derived from chemical weapons. This could limit the
number of off-site facilities that would be able to dispose of the separated rocket motors.
Off-site facilities receiving the separated rocket motors would need to have a
combination of sufficient permitted safe storage space and the disposal capacity to match
the rate at which BGCAPP would ship the separated rocket motors.
Having an off-site government facility that already demilitarizes conventional
munitions perform the separated rocket motor disposal work might be an option.

5
The committee is using off-site to indicate disposal away from the BGAD facility.

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Although the separated rocket motors would have to be transported away from BGAD,
they would be received by another government facility, and the communication channels
and chain of command would all be within the government. This could expedite
addressing any off-normal circumstances that might arise. Also, these installations
already have the necessary environmental permits and explosive safety programs in
place. Nonetheless, these demilitarization facilities also perform work for a variety of
customers, so any request for the disposal of separated rocket motors would likely need
to be coordinated with the demilitarization program offices having work performed there.
In the Army several demilitarization sites dispose of rocket motors, including McAlester
Army Ammunition Plant, Tooele Army Depot, and Anniston Army Depot.
A factor that might affect all off-site disposal options is the Chemical Weapons
Convention. While the committee does not regard a separated rocket motor as a chemical
munition, because the warhead containing the chemical agent will have been separated,
the BGCAPP project management anticipates that demilitarization of the separated rocket
motors will be required under the Convention.6 For this reason, there could be inspection
and monitoring requirements associated with the disposal of the separated rocket motors.
International teams of inspectors might need to be allowed access to the disposal
operations to verify the destruction of the separated rocket motors. This might impact the
willingness of either a commercial or a government facility to receive and dispose of the
separated rocket motors.

Finding 5-6. There are potential technologies for the disposal of the separated rocket
motors that could be used concurrently at one or more off-site disposal facilities to meet
program requirements and schedule. Off-site disposal would increase flexibility in regard
to choice of a specific disposal technology. The Blue Grass Chemical Agent-Destruction
Pilot Plant program staff would, of course, need to work with any off-site disposal facility
to ensure that all relevant environmental regulations, such as the Resource Conservation
and Recovery Act and the Toxic Substances Control Act, are complied with.

Recommendation 5-3. If off-site disposal is pursued, Blue Grass Chemical Agent-


Destruction Pilot Plant program staff should allow off-site disposal facilities to tailor the
mix of storage and disposal technologies that would allow for optimal, safe, and
regulation-compliant disposal of the separated rocket motors.

Finding 5-7. There are government installations that currently conduct conventional
munition demilitarization, including rocket motors. There might be advantages to having
another government facility dispose of the separated rocket motors if off-site disposal is
chosen.

Finding 5-8. Chemical Weapons Convention treaty requirements, such as inspection and
verification of the disposal of the separated rocket motors, might affect the willingness of
commercial or government off-site facilities to accept and dispose of the separated rocket
motors.

6
E-mail from Jeff Krejsa, BGCAPP, to James Myska, study director, on April 25, 2012.

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Public Sentiment

Again, while assessing public sentiment is not part of its task, the committee
believes that such sentiment will impact the ability to implement any disposal option for
the separated rocket motors. The public around BGAD has a history of being sensitive to
transporting off-site any secondary wastes from chemical demilitarization, of which the
separated rocket motors are an example. Over time, it has proved willing to consider
shipping categories of secondary wastes off-site on a case by case basis, but only if there
is a sufficient justification. One factor that could cause the public to be willing to
consider off-site transportation is safety, although this might leave unresolved other
factors such as potential impacts on receiving communities and communities along
shipping routes. If it would be safer to move a given waste off-site than to dispose of it
on-site, the public may be willing to consider such an option. However, history points to
the likelihood that the public will be much more accepting of an on-site disposal option.
This is discussed in more detail in Appendix B.

SHIPPING AND FIRING TUBE MANAGEMENT

One of the wastes from disposing of the separated rocket motors will be the
SFTs, which will constitute a waste stream distinct from the separated rocket motors. The
SFTs contain on average approximately 1,250 ppm of polychlorinated biphenyls (PCBs).7
This is based on trial burns conducted at the Deseret Chemical Depot (Kimmel et al.,
2001). PCBs are semivolatiles that readily penetrate the skin and are fat soluble. The
National Institute for Occupational Safety and Health has issued guidance on workplace
exposure to PCBs (NIOSH, 1977).
When items containing more than 50 ppm of PCB are declared to be a waste, the
Toxic Substances Control Act (TSCA) PCB disposal regulations in Subpart D of 40 CFR
761 come into play, requiring PCB containing items to be disposed of in a TSCA-
compliant incinerator, in a TSCA-compliant chemical waste landfill, or by an EPA-
approved alternative method. As a result of the M55 rocket disposal operations, BGCAPP
will be a generator of PCB waste as defined in 40 CFR 761.3. Since there are no liquid
PCB wastes it may be possible that the SFTs could be considered a PCB bulk waste,
defined as a

waste derived from manufactured products containing PCBs in a non-liquid state, at any
concentration where the concentration at the time of designation for disposal was 50 ppm
PCBs. PCB bulk product waste does not include PCBs or PCB Items regulated for disposal
under 761.60(a) through (c), 761.61, 761.63, or 761.64. (40 CFR 761.3)

If SFTs can be classified as PCB bulk waste they could possibly be disposed of in a
permitted non-hazardous-waste landfill, though this would need to be ascertained (40
CFR 761.62). If the SFTs cannot be designated as PCB bulk waste, they would have to be

7
Kevin Regan, environmental manager, BGAPP project, Rocket Motor (RM) Disposal, briefing
to the committee, March 20, 2012.

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treated like any other PCB article, as defined in 40 CFR 761.3, and would have to be
disposed of as specified in 40 CFR 761.60.
BGAD does not currently have a facility permitted to dispose of PCBs, so treating
or disposing of the SFTs on-site would be very challenging. The open burning of any
materials containing PCBs is not permitted (40 CFR 761.50(a)(1)). Thus if an open
disposal technology was selected to dispose of the separated rocket motors, the motors
would in any case have to first be removed from their SFTs. Even when using a
contained combustion disposal technology, if the separated rocket motors were not first
removed from their SFTs, the waste streams would be contaminated with PCBs and the
systems that treated the off-gases from these technologies would have to be able to
handle the PCB loading. Additionally, to dispose of the SFTs on-site, BGAD would have
to obtain a TSCA permit. For all of these reasons, the committee does not envision the
separated rocket motors being disposed of while still in their SFTs.
Once the separated rocket motors are removed from their SFTs, the SFTs no
longer need to be stored as an energetic material, and become subject to the regulations
governing the storage and transportation of PCB-containing materials. Items with PCB
concentrations 50 ppm or higher must be stored in accordance with 40 CFR 761.65. This
includes a requirement to destroy or dispose of these items within 1 year after their
removal from service, and may restrict storage time to less than 1 year. One-year
extensions are available.

Finding 5-9. Disposing of the separated rocket motors while they are still in the shipping
and firing tubes would contaminate the resulting waste streams with polychlorinated
biphenyls.

Recommendation 5-4. The separated rocket motors should be removed from their
shipping and firing tubes prior to disposal.

Finding 5-10. The storage, disposal, or treatment of the shipping and firing tubes, which
contain polychlorinated biphenyls, on-site would be very challenging and subject to the
Toxic Substances Control Act and Subpart D of 40 CFR 761.

Recommendation 5-5. The shipping and firing tubes should not be disposed of or treated
on-site. Any on-site disposal plan should include sending the shipping and firing tubes
off-site to a licensed commercial facility that complies with the Toxic Substances Control
Act and Subpart D of 40 CFR 761. Attention should be paid to the regulations governing
the storage and transportation of shipping and firing tubes after they are removed from
the separated rocket motors. These regulations impose time limits on the storage of
polychlorinated biphenyl-containing wastes.

If off-site disposal is selected for the separated rocket motors, then the off-site
facility could assume responsibility for the transportation, storage, and ultimate disposal
of the SFTs. Still, the SFTs would have to be transported in compliance with the
appropriate TSCA regulations, and the receiving off-site facility would have to be
compliant with TSCA and Subpart D of 40 CFR 761. The receiving off-site facility
would need to be made aware of the PCBs in the SFTs.

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Finding 5-11. If off-site disposal is selected for the separated rocket motors, the
receiving facility would have to be compliant with the Toxic Substances Control Act and
Subpart D of 40 CFR 761 and would need to be informed of the presence of
polychlorinated biphenyls in the shipping and firing tubes.

Recommendation 5-6. When exploring off-site options for the disposal of the separated
rocket motors, the Blue Grass Chemical Agent-Destruction Facility Pilot Plant project
management should ensure that potential receiving facilities are aware of the presence of
polychlorinated biphenyls in the shipping and firing tubes. They should also ensure that
any facilities selected are compliant with the Toxic Substances Control Act and Subpart
D of 40 CFR 761.

TRANSPORTATION OF SEPARATED ROCKET MOTORS

On-site Transportation of Separated Rocket Motors

Once cleared through headspace monitoring at BGCAPP, the separated rocket


motors will be transferred to temporary storage in the BGCAPP munitions
demilitarization building. At this point, they could also be transferred to BGAD from the
munitions demilitarization building temporary storage. This transfer would need to
follow the requirements of the following regulations:

Army Regulation 385-64, U.S. Army Explosives Safety Program (U.S. Army,
1997);
Army Regulation 385-10, The Army Safety Program (U.S Army, 2011a);
Department of the Army Pamphlet 385-64, Ammunition and Explosives
Safety Standards (U.S. Army, 2011b); and
Army Regulation 55-355, Defense Traffic Management Regulation (U.S.
Army, 1986).

The separated rocket motors will be RCRA-regulated explosive hazardous waste


based on the RCRA definition of reactive material (EPA Hazardous Waste Code: D003)
and based on toxicity related to lead (EPA D008-lead). As long as the rocket motors
remain on-site, RCRA transportation requirements will not be triggered. Thus, the RCRA
definition of on-site is important. Transportation of hazardous wastes within a
geographically contiguous property, including property divided by roads, is considered
on-site as long as the wastes are not transported along a public right-of-way. On-site
transportation would also significantly reduce the risk to safety presented by off-site
transportation of a hazardous material of unknown stability because BGAD would be
able to positively control traffic on the depot to ensure unrelated personnel are kept away
from the separated rocket motors during transport, and they would not be transported on
public rights of way.

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The separated rocket motors may also have been assigned a Kentucky state waste
code (N001 or N002) because they are derived from chemical weapons. Transportation
off-site of materials bearing these waste codes would likely be subject to regulatory
restrictions, so it might be more straightforward to accomplish on-site transportation than
to transport the materials off-site.
An important factor that will affect on-site transportationand off-site
transportation alsois the hazard classification of the separated rocket motors. This
classification will affect packaging and transportation requirements. The hazard
classification of the separated rocket motors is discussed in Chapter 2.

Finding 5-12. Transporting separated rocket motors solely on-site will be safer and easier
to accomplish than transporting separated rocket motors off-site.

Off-site Transportation of Separated Rocket Motors

Under Subtitle C of RCRA, a hazardous waste transporter is any entity that


transports hazardous waste off-site within the United States, if a manifest is required.
These regulations establish requirements for hazardous waste handlers; transporters; and
treatment, storage, and disposal facilities.
Transporting separated rocket motors off-site will require compliance with a
variety of regulations and coordination with all state regulatory entities along the planned
route. There are other requirements for transporting the separated rocket motors,
including having an Environmental Protection Agency identification number, transfer
facility requirements, manifesting and record keeping, and establishing actions to be
taken in the event of hazardous waste discharges or spills. The following documents
cover pertinent aspects of the transportation of energetic hazardous wastes and are
important references.

Title 40 of the Code of Federal Regulations, Part 262, Subparts B and C,


which address manifesting and pretransportation requirements for hazardous
wastes.
Title 40 of the Code of Federal Regulations, Part 263, which sets out the
standards applicable to hazardous waste transporters.
Title 40 of the Code of Federal Regulations, Part 761, Section 207, which
addresses the requirements for transporting wastes containing PCBs. This
would apply to the transportation of the SFTs.
Title 49 of the Code of Federal Regulations, Subtitle C, Hazardous Materials
Regulations, issued by the Pipeline and Hazardous Materials Safety
Administration. These govern the transportation of hazardous materials by
highway, rail, vessel, and air.8
Part II of the Defense Transportation Regulation, which stipulates that the
movement of regulated hazardous materials must comply with the rules of
regulatory bodies governing the safe transportation of regulated hazardous

8
See http://ecfr.gpoaccess.gov/cgi/t/text/text- idx?sid=69820f56014d9312d67ea8169b0e9e01
&c=ecfr&tpl=/ecfrbrowse/Title49/49tab_02.tpl.

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materials for selected modes of transportation, which includes ammunition,


explosives, and munitions (DoD, 2008a).
Department of the Army Pamphlet 385-64, which describes the Armys safety
criteria and standards for operations involving ammunition and explosives
(U.S. Army, 2011).
DoD Ammunition and Explosives Safety Standards, which set uniform safety
standards for ammunition and explosives throughout their entire life cycle.
The purpose of these standards is to protect personnel and property, whether
related or unrelated, and the environment from the potential damaging effects
of an accident involving ammunition and explosives (DoD, 2008b).
DoD Contractors Safety Manual for Ammunition and Explosives, which
contains requirements and provides guidance for safety, storage, site
requirements, and operations involving ammunition and explosives (DoD,
2008c).

As noted previously, the separated rocket motors might also bear a Kentucky state waste
code (N001 or N002) because they are derived from chemical weapons, and
transportation of materials carrying these waste codes off-site would therefore likely be
subject to additional regulatory restrictions.

Finding 5-13. All off-site disposal options necessarily require removal of the separated
rocket motors from government property and transportation on public roads or railways.
There are numerous federal, state, and Army regulations governing the transportation of
explosive hazardous waste, permits, and safety standards that must be met.

Transportation on public roads will require packaging these hazardous


components in performance-oriented packaging (POP) designed and tested to meet the
requirements of the U.S. Department of Transportation 49 CFR 178 (U.S. Army, 2008).9
These POP tests are conducted to ensure the packaging materials and design can
withstand the anticipated stresses of the shipping environment simulated by a series of
tests, including drop, stack, and vibration tests. It should be noted that large quantities of
propellants, explosives, assembled and disassembled ammunition, pyrotechnics,
fireworks, and a wide variety of other energetic materials and ingredients are routinely
and safely transported on public roads and railways without incident following
Department of Transportation regulations using well-established methods.
The U.S. Army Materiel Command Logistics Support Activity Packaging,
Storage, and Containerization Center at Tobyhanna, Pennsylvania, provides guidance on
the procedures to be followed when performing packaging testing, including test sample
procedures, scheduling, and test report format to ensure that the proposed packaging
materials and designs are capable of passing all applicable tests prescribed in the
Hazardous Materials Regulations in 49 CFR 178 (U.S. Army, 2008).

Finding 5-14. Transportation of separated rocket motors off-site must comply with
federal regulations governing the transportation of hazardous materials on public
9
More information can be found via https://www.logsa.army.mil/pscc/PSCC_WebDev/PSCC/
psccindex.htm.

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thoroughfares, including the use of labeled performance-oriented packaging, which is


packaging that has been tested to meet anticipated environmental and transportation
stresses.

Finding 5-15. Performance-oriented packaging does not exist for the off-site
transportation of the separated rocket motors. Such packaging would have to be designed
and certified prior to use. This is a time-consuming and expensive process.

ADVANTAGES AND DISADVANTAGES OF ON-SITE SEPARATED ROCKET


MOTOR DISPOSAL

On-site disposal of the separated rocket motors at BGAD would be carried out
near the site where the separated rocket motors originate and on property contiguous to
the treatment site. This alternative offers many advantages:

The explosives safety risk is minimized by having a short transportation path


from point of separated rocket motor generation and storage to the disposal
site. Being on contiguous property eliminates the hazards of transporting
explosive hazardous waste over public roads, keeps the explosive safety
hazards away from populated areas, and reduces the burden of transportation
regulatory compliance requirements. For instance, on-site transportation
would be exempt from RCRA transportation requirements, though it would
not be exempt from installation explosive safety and hazardous waste
management requirements.
BGAD is currently one of the demilitarization installations funded under the
Conventional Ammunition Demilitarization Program and has experience in
munitions demilitarization and explosive hazardous waste treatment and
disposal. BGAD has a munitions scrap metal program. The metal rocket
motor cases and other metal scrap recovered from disposal operations can be
included in the Demilitarization Enterprise scrap metal cost recovery program,
whereby the revenues obtained by this means are returned to the
demilitarization account.
BGAD has a permitted open-burning disposal site that might be able to meet
the disposal requirements for the separated rocket motors.
BGAD already has a RCRA Subpart X permit for disposal of explosive
hazardous waste. This permit could be amended to include a modification for
one or more contained units to dispose of separated rocket motors.
A D-100 CH2M Hill controlled detonation unit is already installed at BGAD
for the destruction of conventional weapons. The possibility of adapting this
technology to destroy separated rocket motors by static firing has been
proposed to BGCAPP by CH2M HILL and BGAD.
Installing an alternative technology to open burning could leave a residual
capability that BGAD could then use for future work.

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The public living and working around BGAD is likely to be much more
accepting of an on-site disposal option.

The disadvantages of on-site demilitarization include these:

The projected throughput of any on-site disposal technology other than open
burning would likely barely meet or not meet at all the planned rate of
separated rocket motor generation at BGCAPP without the use of multiple
units.
Open burning has as its main disadvantage the release of lead from the
propellant into the environment. If a contained disposal technology were
selected, there would likely be a need for more than one contained disposal
system, or increased on-site storage, or both.
The alternative technologies have yet to be put in place, so time and funds
would be needed to select and install an alternative technology and obtain the
necessary permits or permit modifications.
BGCAPP and BGAD would be responsible for the disposal of all resulting
waste streams, including the SFTs, which contain PCBs and are regulated
under TSCA.

ADVANTAGES AND DISADVANTAGES OF OFF-SITE SEPARATED ROCKET


MOTOR DISPOSAL

The off-site disposal of all of the separated rocket motors may offer some
advantages over on-site disposal:

Off-site disposal would relieve BGCAPP and BGAD of the many of the day-
to-day planning and logistics tasks that would be associated with on-site
disposal.
It would also allow flexibility in the choice of technology to dispose of the
separated rocket motors. Indeed, a specific technology or technologies might
not have to be chosen by BGCAPP project management.
Off-site disposal could significantly mitigate any need for increased storage
space for the separated rocket motors on BGAD.
The disposal contractor would be responsible for the disposal of all waste
streams, including the SFTs.
There are well-equipped and -staffed off-site facilities that can dispose of the
separated rocket motors with minimal start-up time and delay.
If all separated rocket motors were sent off-site for disposal, BGAD would not
need to establish, modify, or expand any rocket motor disposal facility and the
associated permits.

There are a number of disadvantages to the off-site disposal option:

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Transportation of the rocket motors off-site would require compliance with a


large body of federal regulation that would not be operative for transportation
and disposal wholly on-site at BGAD, as discussed above. Also, should
transportation across state lines become necessary, this could necessitate
coordination with the appropriate state regulatory bodies along the route.
An important factor in off-site transportation is public sentiment. Historically,
any transport of waste material derived from chemical weapons, such as the
separated rocket motors, away from a depot site has become a matter of
significant public concern. Selecting an off-site disposal option and
transporting the separated rocket motors off-site would open the possibility of
public action, slowing the process of transporting and disposing of the
separated rocket motors. This could pose a significant schedule risk.
Another disadvantage of an off-site disposal option is that safe transportation
requires POP-certified packaging for the separated rocket motors. Such
packaging does not currently exist for the separated rocket motors. The
currently planned storage and transportation box for the separated rocket
motors would only be usable for on-site transportation at BGAD. The effort to
design, produce, and obtain certification for the necessary POP-certified
packaging would be both time-consuming and expensive.
The BGCAPP project management anticipates that the demilitarization of the
separated rocket motors will be a treaty requirement under the Chemical
Weapons Convention. Any off-site facility that disposed of the separated
rocket motors might therefore have to accept inspection and verification. This
might impact the willingness of an off-site facility to accept and dispose of the
separated rocket motors.

REFERENCES

DoD (Department of Defense). 2008a. Defense Transportation Regulations, Part II:


Cargo Movement. DTR 4500.9-R Part II, June. Available online at
http://www.transcom.mil/dtr/part-ii/chapters.cfm. Last accessed June 1, 2012.
DoD. 2008b. DoD Ammunition and Explosives Safety Standards, DoD 6055.09-STD,
February 29. Available online at http://www.ddesb.pentagon.mil/2008-02-29%20-
%20DoD%206055.09-STD,%20DoD%20Ammuntion%20and%20Explosives
%20Safety%20Standards.pdf. Last accessed June 1, 2012.
DoD. 2008c. DOD Contractors Safety Manual for Ammunition and Explosives, DoD
4145.26-M, March 13. Available online at http://www.dtic.mil/whs/directives/corres/
pdf/ 414526mp.pdf. Last accessed June 1, 2012.
Kimmell, T., S. Folga, G. Frey, J. Molberg, P. Kier, B. Templin, and M. Goldberg. 2001.
Technology Resource Document for the Assembled Chemical Weapons Assessment
Environmental Impact Statement Volume 1: Overview of the ACWA Program and
Appendixes AE, ANL/EAD/TM-101. Argonne, Ill.: Argonne National Laboratory.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

NIOSH (National Institute for Occupational Safety and Health). 1977. Criteria for a
Recommended Standard: Occupational Exposure to Polychlorinated Biphenyls (PCBs),
DHHS (NIOSH) Publication Number 77-225, September. Available online at
http://www.cdc.gov/niosh/docs/1970/77-225.html. Last accessed August 23, 2012.
NRC (National Research Council). 2009. Assessment of Explosive Destruction
Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent
Destruction Pilot Plants. Available online at http://www.nap.edu/catalog.php?
record_id=12482. Last accessed on May 17, 2012.
U.S. Army. 1986. Army Regulation 55-355: Defense Traffic Management Regulation.
Washington, D.C: Headquarters, Department of the Army.
U.S. Army. 1997. Army Regulation 385-64: U.S. Army Explosives Safety Program,
November 28. Available online at http://uxoinfo.com/blogcfc/client/enclosures/
AR38564.pdf. Last accessed August 9, 2012.
U.S. Army. 2008. Performance Oriented Packaging Testing Policies & Procedures.
Available online at http://www.phmsa.dot.gov/staticfiles/PHMSA/Downloadable
Files/Files/LOGSA%20Policies,%20Procedures%20and%20Standards.pdf. Last
accessed June 1, 2012.
U.S. Army. 2011a. Army Regulation 385-10: The Army Safety Program, October 4.
Available online at http://armypubs.army.mil/epubs/pdf/r385_10.pdf. Last accessed
August 10, 2012.
U.S. Army. 2011b. Department of the Army Pamphlet 38564: Ammunition and
Explosives Safety Standards, May 24. Available online at http://armypubs.army.mil
/epubs/pdf/p385_64.pdf. Last accessed June 1, 2012.

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Appendixes

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Appendix A
Glossary
Demilitarization The act of rendering something useless for any military purpose. The
act of destroying the military offensive or defensive advantages inherent in certain types
of equipment or material. The term includes mutilation, dumping at sea, cutting,
crushing, scrapping, melting, burning, or altering; [demilitarization is] designed to
prevent the further use of this equipment and material for its originally intended military
or lethal purpose. The term applies equally to material in unserviceable or serviceable
condition that has been screened through an inventory control point and declared surplus
or foreign excess (DLA, 2004).

Disposal The elimination of rocket motors by any means, e.g., demilitarization,


destruction, recycling. End of life tasks or actions for residual materials resulting from
demilitarization or disposition operations (DoD, 2010). The process of reutilizing,
transferring, donating, selling, destroying, or other ultimate disposition of personal
property (DLA, 2004).

Off-site Disposal of rocket motors away from the Blue Grass Army Depot at a
commercial or a government facility.

On-site Disposal of rocket motors at the Blue Grass Army Depot.

Separated rocket motor The entire section of an M55 rocket aft of the warhead, after
separation by the rocket cutting machine. Includes the motor case, propellant, fins and
various miscellaneous parts, and the fore closure.

Storage risk The risk of an adverse incident in storage. As applied to chemical weapons
it refers mainly to the risk of a chemical agent leak developing. As applied to the M55
rockets it refers mainly to the risk of an autoignition event in a storage igloo or magazine
due to propellant degradation.

REFERENCES

DLA (Defense Logistics Agency). 2004. DoD 4160.21-M: Defense Materiel Disposition
Manual, May 28. Available online at http://www.dla.mil/dlaps/dod/416021m/
guide.asp. Last accessed June 19, 2012.

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Disposal Options for the Rocket Motors From Nerve Agent Rockets Stored at Blue Grass Army Depot

DoD (Department of Defense). 2010. DENIX Unexploded Ordnance (UXO): Glossary


A-D, December 22. Available online at http://www.denix.osd.mil/uxo/UXO411/
GlossaryAD.cfm. Last accessed June 19, 2012.

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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 committees 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 committees
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 committees
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

1
For 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.

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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 technologiesfor 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 technologiesfor example, (1) contained static fire, (2)
contained burn, and (3) use of a Static Detonation Chamber (SDC)5; and
Off-site processesfor 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).

2
Record 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.
3
As 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.
4
The Bechtel Parsons Blue Grass Team is the team of contractors who designed, are building, and
will operate, close, and dismantle BGCAPP.
5
This technology, from the vendor Dynasafe AB, is discussed in Chapter 3.

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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

6
This 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 managers 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.

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Bringing permitting issues to the publics 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

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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 sites 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
7
Record 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.
8
There 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.
9
For more information on Operation Swift Solution, see https://www.pmacwa.army.mil/bgcapp/
swift_solution.html.

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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 (Citizens Advisory Commissions). 2008. Statement Presented by the Colorado and
Kentucky Chemical Demilitarization Citizens 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_2
008.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_Summar
y_%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.

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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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Appendix C
Committee Activities

FIRST COMMITTEE MEETING


MARCH 20-22, 2012
RICHMOND AND LEXINGTON, KENTUCKY
Objectives: To introduce required administrative procedures set forth by the National Research
Council, conduct the composition and balance discussion, read the committee statement of task
and background review with committee sponsor, receive briefing presentations on rocket motor
disposal, review preliminary report outline and report-writing process, flesh the report outline out
into a concept draft, confirm committee writing assignments, and discuss next steps and future
meeting dates.

Blue Grass Chemical Agent-Destruction Pilot Plant, Jeff Brubaker, Site Project Manager
U.S. Army Element, Assembled Chemical Weapons Alternatives Blue Grass Chemical Agent
Destruction Pilot Plant Office

Rocket Motor Disposal, Kevin Regan, Bechtel Parsons Blue Grass Team

VIRTUAL MEETING
APRIL 27, 2012
Objective: To discuss the studys progress and path forward.

SECOND COMMITTEE MEETING


MAY 8-10, 2012
WASHINGTON, D.C.
Objectives: To conduct committee deliberations, discuss report status, conduct report drafting to
achieve a preconcurrence draft, and make any necessary final work assignments.

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THIRD COMMITTEE MEETING


JUNE 27-28, 2012
WASHINGTON, D.C.

Objectives: To discuss preconcurrence draft, achieve committee concurrence.

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Appendix D

Biographical Sketches of Committee Members

Randal J. Keller is currently a professor in the Department of Occupational Safety and Health at
Murray State University, Kentucky. He received a B.A. in chemistry from Eisenhower College
in 1979; an M.S. in toxicology from Utah State University in 1984; and a Ph.D. in toxicology,
also from Utah State University, in 1988. He is certified in the comprehensive practice of
industrial hygiene by the American Board of Industrial Hygiene, in the comprehensive practice
of safety by the Board of Certified Safety Professionals, and in the general practice of toxicology
by the American Board of Toxicology. Dr. Keller is widely published and maintains an
independent consulting practice related to toxicology, industrial hygiene, and safety. He served
on the NRCs Committee to Review and Assess Industrial Hygiene Standards and Practices at
Tooele Chemical Agent Disposal Facility (TOCDF), the Committee on Evaluation of Safety and
Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities, and the
Committee on the Assessment of Process Safety Metrics for the Blue Grass and Pueblo Chemical
Agent Destruction Pilot Plants.
Judith A. Bradbury is an independent consultant who recently retired from the Pacific
Northwest National Laboratory. She has extensive experience in the research and practice of
public involvement in hazardous technologies. Her work includes management of a series of
evaluations of the U.S. Department of Energys (DOEs) site-specific advisory boards and an
assessment of community perspectives on the U.S. Army Chemical Weapons Disposal program.
Her most recent experience was in managing public outreach activities for the Midwest Regional
Carbon Sequestration Partnership Program, sponsored by DOE. She has coauthored several
research reports on communication and engagement, including identification of factors
contributing to effective engagement in carbon capture and storage. She is currently a member of
the European ECO2 Scientific Advisory Board. Dr. Bradbury was initially educated in the
United Kingdom and has a degree in sociology from the London School of Economics.
Subsequently, she earned an M.A. in public affairs from Indiana University of Pennsylvania and
a Ph.D. in public and international affairs from the University of Pittsburgh.
Randall J. Cramer is an environmental protection specialist at the Ordnance Environmental
Support Office of the Naval Ordnance Safety and Security Activity. Dr. Cramer has a
multidisciplinary background and broad research experience in government, academia, and
private industry. He provides technical expertise in munitions and ordnance environmental
research and development, military munitions demilitarization recycling and reuse, pollution
prevention in ordnance development and manufacturing. He also performs U.S. Navy explosives
safety inspections to ensure navy installations are in environmental compliance with explosive

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hazardous waste management regulations. Dr. Cramer currently chairs the Joint Ordnance
Commanders Group Environmental Subgroup and is a member of the Joint Army-Navy-NASA-
Air Force Safety and Environmental Subcommittee and is the Navy representative on the
Interagency Committee on Explosives. He supports the Navy on the Clean Air Act, the Resource
Conservation and Recovery Act (RCRA), and EPCRA/TRI Services steering committees. He has
given numerous presentations to the technical community, published several papers, and is the
inventor for eight patents.
Eric D. Erickson is a senior scientist in the Energetics Research Division of the Weapons and
Energetics Department at the Naval Air Warfare Center in China Lake, California, where he
provides technical support for several weapons program offices. Before that, Dr. Erickson was a
principal investigator in the Instrumental Analytical Chemistry Branch in the Research and
Intelligence Department at the Center. His research activities have included the development of
several ordnance demilitarization technologies and the monitoring of their emissions. Dr.
Erickson received a B.S. in chemistry from Oregon State University and a Ph.D. in analytical
chemistry from Michigan State University. He also has a certificate of achievement in industrial
hygiene from San Diego City College.

Brad E. Forch has been the Army Chief Scientist for Ballistics (ST) for the Weapons and
Materials Research Directorate at the U.S. Army Research Laboratory since January 2009. His
research expertise is in a wide range of ballistics, including developing the fundamental
understanding of chemical and physical mechanisms controlling chemical energy storage,
ignition, combustion, and release in propellants, explosives, and novel energetic material
structures for weapons applications. He was the chief of the Propulsion Science Branch in the
Ballistics and Weapons Concepts Division of the Weapons and Materials Research Directorate
from 2000 to 2009 and chief of the Ignition and Combustion Branch in the Propulsion and Flight
Division of the Weapons Technology Directorate from 1995 to 2000. As a supervisory research
physicist, Dr. Forch was responsible for the direction of a wide range of basic and applied
scientific research and concept development activities in ballistics, energetic materials, novel
propellants and explosives, nanoenergetic materials, reactive materials, and ignition and
combustion research. He served as a research scientist and team leader from 1986 to 1995 in the
Interior Ballistics Division of what was then the U.S. Army Ballistic Research Laboratory
(BRL). His work focused on research leading to applications of lasers for the initiation of
propellants and propelling charges for large-caliber guns and the development of ignition
systems and requirements for current and future propulsion systems. Dr. Forch was a NRC
postdoctoral fellow at the BRL in 1985. His primary areas of research included the application
of laser-based techniques such as multiphoton photochemistry, multiphoton fluorescence and
ionization spectroscopy, and laser photochemistry to understand the detailed chemistry and
energy-releasing processes of energetic materials. Dr. Forch received a B.S. in chemistry and an
M.S. in physical chemistry from Illinois State University in 1978 and 1979, respectively. He
received a Ph.D. in physical chemistry/chemical physics from Wayne State University, in
Michigan, in 1984.
Scott E. Meyer is the managing director of the Maurice Zucrow Laboratories at Purdue
University. He is responsible for the safe and productive utilization of Zucrow Labs unique
research and testing capabilities. He collaborates with faculty in the development of new
experimental capabilities and is responsible for the design and implementation of new facility

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infrastructure. Mr. Meyer supervises Zucrow staff and approximately 75 graduate students in the
design, fabrication, setup, and safe operation of gas turbine, rocket, and other combustion
experiments, including the specification of instrumentation; data acquisition and control systems;
and fluid systems and components. Prior to joining Zucrow Laboratories, Mr. Meyer was a
propulsion engineer at Beal Aerospace and a project engineer in the Propulsion Wind Tunnel
group at Arnold Engineering Development Center. Mr. Meyer received both a B.S. and an M.S.
in aeronautics and astronautics engineering from Purdue University.
Bobby L. Wilson is the L. Lloyd Woods Distinguished Professor of Chemistry and Shell Oil
Endowed Chaired Professor of Environmental Toxicology at Texas Southern University (TSU).
He has held many positions during his more than 30 years at TSU, including provost and acting
president. Dr. Wilson received his B.S. in chemistry from Alabama State University; an M.S. in
chemistry from Southern University in Baton Rouge, Louisiana, and a Ph.D. in chemistry from
Michigan State University.
Dr. Wilsons research has focused on unusual metal-centered complexes of early first,
second, and third row transition elements using spectroscopic techniques and in the area of
environmental chemistry and toxicology, particularly water and air pollution. In addition to water
and air, trace metal and radionuclide concentrations are also being investigated. Other areas of
concerns are catalytic coal liquefaction to enhance the conversion yields and properties of the
liquid products from coal and the synthesis of transition metal complexes as models in an effort
to reduce lunar materials, such as titanium ilmenite (FeTiO3) and rutile (TiO2) with the
production of molecular oxygen. This could lead to the production of molecular oxygen on the
moon.
As founder of the TSU-NASA Research Center for Biotechnology and Environmental
Health (RCBEH) at TSU, Dr. Wilson led a team to investigate the toxicology of the space travel
environment by using the cutting-edge tools, approaches, and applications of nanotechnology
and genomics. The overall goals, associated with the two focus areas of microorganisms and
genotoxicology, are to identify space genes that may affect human adaptation in the space
environment and to measure oxidative stress and DNA damage in human and mammalian cells.
Dr. Wilson has been instrumental in building the research component of the science
programs at TSU. His efforts have generated over $60 million in research and training grants to
the university. His commitment to promoting the TSUs research agenda for its professors and
producing future scientists led to the construction of the TSU Science Center, a $35 million
structure with state-of-the-art laboratories, classrooms, and computer labs. A 4,300 square foot
lab houses the Houston Louis Stokes Alliance for Minority Participation Program. This lab has
33 computers, two large printers, and two 50-inch plasma flat screen monitors. It also has
teleconferencing capabilities, which enable students to interact with and present their research to
other colleges and universities.
Perhaps his most ambitious and forward-looking venture has been the establishment of
the Louis Stokes Alliance for Minority Participation (LSAMP) in seven Houston-area colleges
and universities. He is the co-principal investigator of this consortium, which is designed to
substantially increase the number of underrepresented minorities in the fields of science,
technology, engineering, and mathematics. Its success at Texas Southern University and other
Houston-area colleges and universities has been judged to be among the best LSAMP program in
the nation. This judgment bears witness to Dr. Wilsons vision and leadership.

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Dr. Wilson has also been a mentor to over 70 masters degree students in chemistry and
20 masters and/or Ph.D. students in the Environmental Toxicology Program, which he was
instrumental in establishing as TSUs first Ph.D. program.

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