REPLY TO ATTENTION OF:

SFAE-ACW-BG

DEPARTMENT OF THE ARMY ASSEMBLED CHEMICAL WEAPONS ALTERNATIVES FIELD OFFICE

BLUE GRASS CHEMICAL AGENT-DESTRUCTION PILOT PLANT 830 EASTERN BYPASS SUITE 106

RICHMOND, KENTUCKY 40475-2512

MEMORANDUM FOR RECORD

28 May 2014 ACW-14-0046

SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP) Meeting with Secondary Waste Working Group (SWWG) Members

1. Summary: On 7 May 2014, the BGCAPP team and the SWWG, a sub-committee of the Kentucky Chemical Destruction Community Advisory Board (CDCAB), met to discuss cyanide mitigation treatment and wor~er protection. In attendance were the following: Siobhan Adkins, BGCAPP; John Barton, Bechtel Parsons Blue Grass (BPBG); Jeff Brubaker, BGCAPP; Colette Easter, Kentucky Department for Environmental Protection (KOEP); Jeanne Marie Hibberd, CDCAB; Paula Maionchi, consultant to the SWWG; Bryan Makinen, CDCAB; Darcy Maupin, CDCAB; Amy McCracken, KOEP; Ramesh Melarkode, Blue Grass Army Depot; Robert Miller, Kentucky Chemical Demilitarization Citizens' Advisory Commission (CAC) and CDCAB; Sarah Parke, BGCAPP; David Postley, KOEP; Carl Richards, CDCAB; Ronnie Riddell , Estill County Emergency Management Agency; Kevin Roberts, BPBG; Aaron Thompson, CAC/CDCAB; April Webb, KOEP; Craig Williams, CAC/CDCAB; and Todd Williams, Blue Grass Chemical Activity.

2. Actions: BPBG will provide answers to SWWG members on the following : what will happen to the liquid if a Hydrolysate Storage Area (HSA) tank spills and the spill is contained; if isotainers are used to store the liquid, what is the approximate arrival time to get them on site and ready, and if there is a pre­selected area to set the isotainers; where the air intake is relative to the stacks in the Supercritical Water Oxidation (SCWO) Processing Building (SPB); if measures are in place if changes after hiring are observed in the personal lives of workers in high-stress work environments that may not be covered under the Personnel Reliability Program (PRP) or the medical screening program to make sure they are reliable employees; and how many tons of secondary waste from projectile bodies will be generated from the Static Detonation Chamber (SOC).

3. Presentations: Barton delivered a presentation on cyanide mitigation and worker protection, covering potential agent and industrial chemical hazards; Health Hazard Assessment methodology and approach; worker safety and occupational medicine program; the cyanide challenge for energetics neutralization process; cyanide exposure limits vs. BGCAPP levels; HSA design, construction and operations; and the SPB.

4. Discussion Topics:

a) Williams opened the meeting by informing the group that comments on the Resource Conservation and Recovery Act (RCRA) Class 3 Hazardous Waste Storage and Treatment Permit Modification Request, Addition of Explosive Destruction Technology (EDT), will be circulated to CAC/CDCAB members 9 May 2014 and any additional input will be submitted as part of the public comment period prior to 13 May 2014 deadline. Miller asked if the comments were significant or minor. Williams said in some cases they were minor, but significant in regard to the Off-Gas Treatment System.

b) Williams then introduced Barton and said the SWWG subgroup made tremendous progress on understanding the cyanide treatment issue as a result of a meeting held 28 April 2014. After the subgroup learned workers will not be in the SPB for eight hours a day, the concern for potential exposure

SFAE-ACW-BG SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant Meeting with Secondary Waste Working Group Members

to cyanide levels was reduced. Williams asked Makinen to provide the group with his research on the HSA tank design. Makinen said engineering controls and emergency procedures for this area are in place. Williams also asked Maionchi to elaborate on her research of Personal Protective Equipment (PPE). She said she feels confident BPBG will provide appropriate Level C or B suits to workers entering the SPB. Maionchi did have a concern about what happens to the effluent after it is no longer needed for the SCWO process. Barton said it will not be placed in Muddy Creek but the final disposition has not been determined.

c) Barton began his presentation by stating BGCAPP will deal with varied chemicals during operations, not just chemical agent and cyanide. He highlighted a program in place to assess all hazards. He mentioned hazard assessments were conducted in phases and recommendations and information were recorded and maintained.

d) Barton informed the group dilute agent will arrive on site in 2014. Williams asked if this was a result of systemization activities. Barton said the laboratory was being populated with staff and equipment and it is part of the testing process. It will be highly controlled . Next, Barton highlighted the PRP and medical screening program, noting the PRP considers both physical and psychological health.

e) The presentation then shifted to the technical challenges of cyanide mitigation. Barton noted project personnel focused on engineering controls rather than enhancing PPE in response to cyanide formation . He said that increasing temperatures in the Energetics Neutralization Reactors (ENR) does not change the chemistry and affect the SCWO process . He also said cyanide will form in the Energetics Batch Hydrolyzers and more than 95 percent will be destroyed in the automated ENR process. Williams asked if cyanide only involved energetics and not agent. Barton confirmed. Williams asked if there was any concern with agent and energetic hydrolysate being mixed before the SCWO process. Barton said no.

f) Barton also explained HSA spill containment and response procedures. Thompson asked what will happen to the liquid if a spill occurs and is contained . Barton said he was not sure, but it could be stored in isotainers. Maionchi asked about the response time to get isotainers in place and if there was a pre-selected area for them. Thompson asked if there was any danger while the spill was contained in the containment area. Barton explained the dedicated containment area is designed to withstand wind , additional water from rain and other measures.

g) The presentation then turned to the SPB. Barton explained the SPB contains four heating, ventilation and air conditioning systems. Makinen asked where the air intake was relative to the stacks.

h) Miller said he was interested in the psychological impacts to the workforce. He said some workers in high-stress situations may need to be monitored. He referred to people not included in PRP, but who still have an important job. He was interested to know the protocols in place for employees after the hiring process.

i) Barton concluded his presentation and SWWG members discussed EDT secondary waste. Maionchi asked what happens to scrap metal after everything is destroyed by the SDC. Williams said a final determination has not been made. He asked Webb if scrap metal could be recycled if it had an N code (code specified for waste directly derived from chemical warfare agent) . Webb said further discussions need to happen, but there are some exclusions for scrap metal in the RCRA permit. Maionchi was interested to know if there are Kentucky communities interested in recycling the scrap metal. Miller wanted to know if there could be some financial incentive. The group asked BGCAPP to provide the total number of tons generated from secondary waste projectile bodies from the SOC.

j) SWWG members also discussed the National Research Council (NRC) statement of task on the study of the conditions for potential off-site hydrolysate shipment. Williams said the statement was

2

SFAE-ACW-BG SUBJECT: Blue Grass Chemical Agent-Destruction Pilot Plant Meeting with Secondary Waste Working Group Members

broad, but he received confirmation from the NRC and the Program Executive Office, Assembled Chemical Weapons Alternatives that they will keep the group informed throughout the process. Thompson said he was concerned this study should have been conducted sooner. Brubaker said studies have been done and data does exist and will be provided to the NRC. Williams said this study is being conducted to determine the tipping point if SCWO cannot keep up with throughput and the hydrolysate needs to be shipped somewhere else. He said the CAC/CDCAB does not endorse off-site shipment, but this is in preparation for a worst-case scenario.

k) Brubaker informed the group of the statement of task timeline. He said the NRC will meet with community members in Pueblo, Colorado, first and then in Kentucky. The meeting will be publicized in advance. The study for BGCAPP will take about 15 months to complete.

5. Conclusion: The meeting was conducted to provide an update on cyanide treatment. BPBG will provide answers to the questions noted in the Actions section.

JEFFREY L. BRUBAKER Site Project Manager Blue Grass Chemical Agent-Destruction Pilot Plant

sp/dbp

CF: BGCAPP Document Control

3