BGCAPP Waste Analysis Plan

Recommendation 3-1. While the Bechtel Parsons Blue Grass Team and the Program Manager for Assembled Chemical Weapons Alternatives are not in violation of regulatory requirements and have ample time to meet the requirement to submit a waste analysis plan for BGCAPP 18 months prior to receipt of munitions at the facility, it would be prudent to develop and submit the plan as early as possible in order to determine the requirements that may be placed on the operations by the Kentucky Department of Environmental Protection and avoid unnecessary delays to the operation. 

Recommcndation 4-1. To avoid the possibility of unanticipated disposal problems, the PMACWA and the BGCAPP contractor should characterize and consider waste management options for reverse osmosis rejectate brine, supercritical water oxidation (SCWO) filtrate solid waste, SCWO titanium tank liners, venturi scrubber particulate filters, and energetics offgas treatment system filters before submitting the waste analysis plan required by RCRA. The PMACWA should also look carefully for any as-yet-unidentified secondary waste streams from BGCAPP or PCAPP. 

Finding 3-1. A detailed waste analysis planfor BGCAPP has not been developed or submitted for review and approval. Such a plan would detail sampling and analytical methods for each waste stream. 

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