Assessment of the Army Plan for the Pine Bluff Non-Stockpile Facility (2004)

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1 Executive Summary The U.S. Army requested the National Research Council (NRC) to form a committee to review the design for the fa- cility intended to dispose of some 1,200 recovered non- stockpile munitions in storage at its Pine Bluff (Arkansas) Arsenal (PBA). These munitions, consisting mostly of 4.2-in. mortar rounds containing sulfur mustard agent and 15-cm German Traktor rockets (GTRs) containing a variety of fills, account for most of the non-stockpile inventory located there. Non-stockpile chemical materiel (NSCM) is materiel not in the current U.S. inventory of chemical munitions. It includes buried and recovered materiel (munitions or other), components of binary chemical weapons, former production facilities, and miscellaneous materiel. Much of the NSCM was buried at current and former military installations in 31 states, the U.S. Virgin Islands, and the District of Columbia (U.S. Army, 1996). This executive summary discusses the committee’s pri- mary recommendations only; additional recommendations are found in Chapters 2 through 6. NON-STOCKPILE MATERIEL AT THE PINE BLUFF ARSENAL The non-stockpile inventory at PBA (Table 1-1) accounts for about 85 percent of the known non-stockpile materiel in the United States. About 97 percent of this materiel was either recovered from excavated burial pits on the PBA site or has always been in storage at the site. The other 3 percent was transported from other sites around the country. The most problematic items are the 1,200-plus recovered munitions filled with agent or containing residual amounts of agent. Many of these munitions also contain energetic materials whose stability may have deteriorated over time. The Pine Bluff Non-Stockpile Facility (PBNSF) is designed to handle the destruction of these recovered munitions. Other means will be used to destroy the other non-stockpile items at PBA. The PBNSF site will occupy approximately 25 acres. As currently configured, the main process facility will be a 40,000 ft2 building containing accessing and treatment fa- cilities, along with support facilities (see Chapter 2). PBNSF relies in large part on legacy equipment from the discontinued Munitions Management Device (MMD) project, as well as on processing equipment developed un- der the Assembled Chemical Weapons Assessment (ACWA) program, which examined alternatives to incin- eration for stockpile disposal. The PBNSF equipment con- sists of trailer-mounted units that can be transported to new locations and assembled. The decision to reuse existing MMD equipment has resulted in continuing modifications, particularly to the explosive containment chamber (ECC) units, and in constraints on accessibility within the chemi- cal processing trailer. PBNSF will employ neutralization and/or oxidation technologies to destroy the chemical agents. A process flow diagram of the PBNSF is shown in Figure ES-1. THE TASK FOR THE COMMITTEE AND THE COMMITTEE’S FINDINGS In accordance with the statement of task (see Preface), the committee reviewed engineering design plans for the construction of PBNSF and plans for its operation. The com- mittee did not identify any single event or action that has a high probability of preventing the implementation of PBNSF but also concluded that the basic design of PBNSF, as con- figured at the time this report was finalized, is incomplete. In addition, the committee noted that because the PBNSF schedule must adhere to the munitions destruction require- ments of the Chemical Weapons Convention (CWC), there is very little slack in the time available for construction, test- ing, and operation of the PBNSF. As an alternative solution, the committee asserts that use of multiple explosive destruc- tion system (EDS) units will work better, with less risk, and in a more timely manner. The following issues remain to be resolved if PBNSF is to achieve the goal of destroying recovered chemical war-

2 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY FIGURE ES-1 Process flow diagram of the PBNSF. SOURCE: U.S. Army (2002b). fare materiel (RCWM) safely and in accordance with the schedule defined in the CWC: • The ability of the PBNSF processing equipment to pro- cess energetically configured 4.2-in. mortar rounds containing gelled or solidified mustard agent has not been demonstrated. • The current PBNSF design has not been demonstrated to be able to neutralize the arsenical fills in some of the GTRs. • While the Army has determined the design to be con- sistent with Army safety regulations, the inability of the building as designed to withstand the maximum credible event (MCE) seems inconsistent with the con- gressional mandate to provide “maximum protection for the environment, the general public, and the per- sonnel who are involved in the destruction of the lethal chemical agents and munitions” 50 U.S.C. Section 1521(c)(1)(A).1 In addition to having concerns about the unresolved de- sign issues that will affect the currently proposed schedule, the committee has serious reservations about the ability to meet this schedule even if no further changes are made to the design. An assessment by the Army Corps of Engineers, Little Rock District, independently confirms these reserva- tions and leaves no doubt that even minor issues—such as a delay of more than 5 minutes per trip in accessing the site or the effect of rainfall on the workability of the soil, two issues raised by the Corps of Engineers—would result in a failure to meet the proposed schedule (see Chapter 2). Recommendation 2-1: If the current design for the Pine Bluff Non-Stockpile Facility is pursued, a realistic schedule should be developed based on the time required to properly perform the engineering, construction, commissioning, and processing steps. As part of this task, the required basic de- sign criteria must be finalized. In addition, process hazard analyses must be completed and any issues raised by them resolved. The committee has serious reservations about the desir- ability of implementing the PBNSF design concept. In this 1“Maximum protection for the environment” is discussed in Appendix D of Review of the Army Non-Stockpile Chemical Materiel Disposal Pro- gram: Disposal of Chemical Agent Identification Sets (NRC, 1999).

EXECUTIVE SUMMARY 3 report, the committee sets forth its reservations about worker safety, the risk of failure to achieve the April 2007 deadline set by the CWC, cost, complexity, and the relative lack of robustness that is inherent in the current design. The committee recommends that the Army promptly evaluate multi-EDS alternatives (described in Chapter 6) for destroying the PBA non-stockpile inventory. Based on ex- isting information, this alternative could perform most if not all of the tasks intended for PBNSF as currently envisaged, doing so via a demonstrated technology, with improved safety and simplicity and lower costs. EFFECTS OF THE CHEMICAL WEAPONS CONVENTION DEADLINE The Army is constrained by the CWC treaty and legisla- tive mandates to destroy the munitions assigned to PBNSF by April 29, 2007.2 This constrant imposes an arbitrary deadline and creates serious conflicts. The April 29, 2007, deadline is independent of budget constraints imposed by Congress and does not take into account the unique com- plexity of disassembling aging, unstable weapons that con- tain not only deadly chemical agent but also explosives and energetics. In addition, the deadline does not recognize the technological limitations of the nonincineration technologies that are used to destroy the chemical agents or the challenge of satisfying both the regulatory requirements and the public’s desire that these weapons be destroyed in as safe a manner as possible. These technological challenges, combined with the unre- solved design issues for PBNSF, outlined above, increase uncertainty about whether the Army can attain the April 29, 2007, treaty deadline with the existing PBNSF approach. If the design criteria that are finally agreed upon require modi- fications to the initial assumptions and result in delays, the pressure on the schedule will increase still further. This could result in even less time for performing the engineering tasks required to design, construct, and systemize PBNSF than is available under the present schedule. The Army Corps of Engineers, Little Rock District, appears to share this con- cern. In a letter to the Product Manager for Non-Stockpile Chemical Materiel (PMNSCM), it expresses the concern that the development of the basic design is proceeding in parallel with (rather than prior to) the design of the building. Recommendation 2-3: As soon as possible, the Army should systematically review the design integration and op- eration of all the equipment in the Pine Bluff Non-Stockpile 2Late in the report review process, the Army announced that the United States would not meet the 45 percent chemical weapons stockpile destruc- tion deadline of April 29, 2004, and requested an extension of the deadline until December 2007 (DoD, 2003). However, the Product Manager for Non- Stockpile Chemical Materiel has stated that the non-stockpile program in- tends to meet the April 29, 2007, deadline. Facility (including piping, connections, and vessels) to find ways for simplifying the processing taking place there. This review should identify ways of (1) minimizing the chances for equipment or operational or human failures, using pre- ventive redesign and related measures to reduce reliance on protective clothing and (2) optimizing the reliability of the Pine Bluff Non-Stockpile Facility processes. PINE BLUFF NON-STOCKPILE FACILITY CONTAINMENT DESIGN The Product Manager for Non-Stockpile Chemical Mate- riel has defined the MCE for the PBNSF design as the deto- nation of a fully configured GTR motor and warhead combi- nation while being processed in the PBNSF. The MCE is important because it is used as the basis for facility design. While it is difficult to predict the likelihood of the MCE with any degree of certainty, it is important to review such poten- tial events and investigate designs that protect against even low probability risks when consequences might be severe. The committee recognizes that the PBNSF design calls for the MCE to be completely contained, but only when that GTR is actually being processed within the ECC-2. How- ever, should the MCE occur within PBNSF but outside the ECC-2, there would be a release of fragments and agent to the immediate area outside the PBNSF building; there are similar concerns should a fully configured GTR be detonated in transit. Nothing in this report should be construed as ex- pressing the view that such a release is likely to occur. The U.S. Army, citing Department of the Army Pamphlet 385-61 (U.S. Army, 2002a) Section 6.6 requirements with respect to containment, reports that this condition—MCE containment only when occurring within the ECC—is the required level of protection for both the stockpile and the non-stockpile disposal programs. However, should the MCE occur outside the ECC-2, it would almost certainly result in severe worker injuries or death and trigger a public outcry and regulatory review that would seriously delay the comple- tion of the PBNSF task regardless of the impact on the per- sonnel and the environment. For this reason, the committee believes that it would be preferable to design the entire PBNSF to contain the MCE. The possibility of the MCE occurring outside the ECC-2 also supports the committee’s recommendation to develop a system to decouple the GTR motor/warhead combinations in a separate facility designed to contain both explosions and releases of lethal chemicals with a minimum of transportation and handling. Separating the GTR warhead from the rocket motor and processing only the warhead in PBNSF would increase the safety of the PBNSF operation by eliminating the only situ- ation where the energetic capacity of the munition exceeds the containment capacity of the building. Recommendation 3-2: The German Traktor rocket war- heads should be separated from the rocket motors and only

4 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY the warheads should be allowed to enter the Pine Bluff Non- Stockpile Facility so as to reduce the maximum credible event to a level that can be fully contained by the structure. The Army should continue to investigate thoroughly the fea- sibility of separating the German Traktor rocket motors from their warheads to determine how and where these operations can be accomplished safely. Confirming the contents of RCWM items at PBNSF will occur in two stages: • The munition will be unpacked, examined, analyzed, and classified at the Pine Bluff munitions assessment system (PBMAS) and then returned to storage. • The munition will be assessed by x-ray and checked for leakage in the receiving room when the munition is first unpacked in the PBNSF facility prior to disposal. The munition is then sent to the next processing module, which is determined based upon its configuration (agent and explosive content) and condition (clean, corroded, etc.). Two options exist for gaining access to the chemical agents contained within the munitions. In general, munitions that contain energetics will be processed in one of the two ECC units, which are designed to contain the force of an explosion, should one occur during the drilling and draining operations. Those without energetics will typically be processed in the projectile washout system (PWS) developed under the ACWA program, which has a much higher capacity but is not config- ured to withstand an accidental detonation. Complete descrip- tions of these operations are in Chapter 2. MANAGEMENT OF SECONDARY WASTES The primary agent neutralization operations in PBNSF will be treatment of arsenicals using caustic or an oxidant as the neutralizing agent, treatment of nitrogen mustard using monoethanolamine as the neutralizing agent, and treatment of sulfur mustard, again using monoethanolamine as the neu- tralizing agent. While substantial in volume, the quantities of neutralent and decontamination solution generated will be small in comparison with those routinely handled by com- mercial treatment, storage, and disposal facilities. The Army plans to dispose of secondary waste from PBNSF at offsite locations through a contract awarded to Shaw Environmental, Inc. Shaw is required to team with one or more commercial hazardous waste treatment, storage, and disposal facilities to transport and dispose of secondary wastes from all Non-Stockpile Chemical Materiel Product (NSCMP) projects, including PBNSF. The contract states that nonincineration treatment is preferred to incineration treatment. The preference for nonincineration technology is part of a decades-long trend, first toward incineration as a preferred treatment technology, then away from incineration (NRC, 1994, 2002a). REGULATORY APPROVAL AND PERMITTING Before PBNSF can be constructed and operated, regula- tors and the public must be satisfied that planned operations can be carried out within the federal and state regulatory and legal framework. The regulatory approval and permitting process involves in-depth examination of the Army’s pro- posed treatment technologies and the requirements they must meet, and provides opportunities for public involvement in the decision making. Under Arkansas regulations, since the parent agent wastes are not listed as hazardous waste on the basis of agent con- tent (see Chapter 5), neither would be any secondary wastes that result from primary treatment. However, the non-stock- pile items themselves, along with the neutralent and most other secondary wastes, will most likely fall in the Resource Conservation and Recovery Act category of ignitable, corro- sive, toxic, or reactive waste and will on that basis (not be- cause of agent content) be specified as hazardous waste. Recommendation 5-1: For non-stockpile materiel to be pro- cessed at the Pine Bluff Non-Stockpile Facility, the Army should describe risk-based treatment goals for chemical agent destruction in publicly available documentation. The Army should also describe agent-related treatment goals for secondary wastes treated at offsite treatment, storage, and disposal facilities (e.g., for Schedule 2 compounds) in pub- licly available documentation. Treatment goals for related non-stockpile operations at the Pine Bluff Arsenal—for ex- ample, the rapid response system and the explosive destruc- tion system—should also be discussed in publicly available documents. PUBLIC INVOLVEMENT The involvement of the public in significant, potentially controversial activities such as the NSCMP is not only a legal requirement but also a key element of mission success. Public involvement means working with a range of “pub- lics,” or stakeholders. It has three components: (1) early pro- vision of public information; (2) outreach, or opening chan- nels of communication to allow the public to articulate its values, concerns, and needs; and (3) involvement, or provid- ing mechanisms that engage the public and allow it to pro- vide input and influence agency decisions (NRC, 2002a). The committee commends the Army for its continued commitment to working effectively with the Core Group (a group established by NSCMP to exchange information and opinions on non-stockpile issues) in addressing issues raised among stakeholders at the national level; for improving co- ordination among the various chemical weapons programs at local installations; and for increasing the visibility of non- stockpile activities at Pine Bluff and informal public-Army interactions. The committee believes that the NSCMP is in a position to build upon both the Pine Bluff area community’s

EXECUTIVE SUMMARY 5 unusually positive, or at least accepting, view of its proposed activities, as well as on its effective working relationships with national-level stakeholders. Recommendation 5-4: The committee recommends that the Product Manager for Non-Stockpile Chemical Materiel en- hance public involvement by (1) identifying and addressing the reasons for limited participation by the public in meet- ings at Pine Bluff; (2) establishing an informal advisory group at Pine Bluff similar to a restoration advisory board; (3) augmenting the national Core Group with citizen stake- holders from Pine Bluff and from the yet-to-be determined location of the facility that is selected to treat and dispose of the secondary wastes from the Pine Bluff Non-Stockpile Facility; and (4) ensuring that the contractor(s) for disposal of secondary wastes go(es) beyond information and outreach activities to involve local community stakeholders. Recommendation 5-6: As part of the public involvement process, the Army should consider preparing a new docu- ment that describes, in layman’s terms, the treatment tech- nologies and facilities being proposed for non-stockpile ma- teriel at Pine Bluff. These technologies include those outside the Pine Bluff Non-Stockpile Facility and should include the technologies ultimately selected to treat neutralent off-site. The document might include a timeline and a summary of the cumulative environmental impacts. It would give the public a clear understanding of the proposed actions and help them to understand the operation of each technology and the interrelationships among them. ALTERNATIVE APPROACHES While evaluating the existing PBNSF design, the com- mittee concluded that there are preferable alternative ap- proaches to destruction of the non-stockpile chemical mate- riel stored at PBA. The alternatives involve greater use of the well-proven EDS and would be simpler, more reliable, less expensive, and safer because of the smaller number of munition handling steps and improved ability to meet the CWC. That is, the simplicity and reliability of the EDS of- fers easier operation and maintenance while improving the safety of workers, the public, and the environment. The new challenges that would be posed by changing to a new operational concept at this late stage in the design plan- ning for PBNSF should be no greater than those associated with meeting the deadline with currently planned PBNSF operations. Although the committee concludes that PBNSF, as cur- rently designed, may be workable—subject to the findings and recommendations contained in this report—it has seri- ous reservations about the desirability of doing so. Employ- ing the complex prototype equipment inherited from the dis- continued non-stockpile MMD program and the stockpile ACWA program has caused many modifications to the de- sign of an integrated system for PBNSF. Further, the com- plexity of the current PBNSF design raises concerns about the sheer number of munition processing and handling steps. In addition, the current PBNSF processing procedure appears less capable than the EDS of dealing with unexpected varia- tions in munition type and condition. For example, a mischaracterized munition could cause serious problems in the ECC or in the PWS, operations where there is more manual handling and the processing steps are more variable than in the EDS. In contrast, the EDS explosively accesses the munition content and, in doing so, destroys much of the agent. Any remaining agent is destroyed via a neutralization reaction. The key issue is the ability to access the surfaces that contain agent, whether liquid, gelled, or solidified. The EDS is demonstrably superior to the PBNSF drill and drain equipment in exposing the interiors of the munitions and allowing the reagents to contact any residual agent. Two or three EDS units can perform most if not all of the tasks currently planned to be performed at PBNSF. The com- mittee considered two basic ways in which EDS systems could replace some of the problematic aspects of the current PBNSF design. Both options assume that EDS units can be made available for use in destroying non-stockpile materials intended for PBNSF. Option 1 Option 1 would eliminate all of the processing equipment (ECC-1, ECC-2, PWS, heel-dissolving tanks, detonation chamber (DET), metal decontamination unit (MDU), and the chemical processing trailer (CPT)) from the current design for PBNSF. In their place, multiple EDS units could be used to dispose of the non-stockpile inventory at PBA (with the exception of GTRs, whose propellant contents exceed the explosive containment capacity of the EDS-2). If it is pos- sible to remove the rocket motors from the 31 GTRs whose rocket motors contain propellant, EDS-2 systems can be used to dispose of the entire PBA inventory. Calculations are pro- vided in Appendix C. In addition to the factors cited above, an important advantage of the EDS over the current PBNSF design is that it is a well-proven system. Complete elimina- tion of the currently designed PBNSF processing equipment could eliminate much manual handling, reduce exposure potential, save much of the anticipated cost of equipment modification, and reduce or eliminate the cost of a perma- nent building. Option 2 Option 2 would replace the PWS and the ECC-1 with EDS units but retain the ECC-2 for processing the 31 com- plete GTRs with propellant-filled rocket motors if the mo- tors cannot be removed from the warheads safely. Use of the ECC-2 is necessary to process the complete GTRs because the total net explosive weight of the GTR, including propel-

6 ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY lant, exceeds the containment capacity of both EDS systems. Retention of the ECC-2 necessitates retention of several aux- iliary facilities, including the chemical processing trailer, a heel-dissolving tank, the DET, and an MDU. The Army is evaluating options akin to Option 2 in which an EDS unit would be used in addition to PBNSF to ensure destruction of the PBA inventory of RCWM by April 2007. Factors for Consideration Both Option 1 and Option 2 would involve modification of the current plan for a building to house PBNSF. In Option 2, which retains the ECC-2 and its supporting facilities, most aspects of the building would be retained. In Option 1, it might be possible to house the EDS units in low-cost, tem- porary containment shelters, as was done for the Spring Val- ley, Washington, D.C., non-stockpile disposal project com- pleted in 2003. Buildings to house administrative and laboratory facilities would also be needed, but they need not be permanent. The temporary shelters for the EDS units might retain their usefulness after conclusion of the PBA activities because they could be moved to other locations along with the EDS units that they enclose. The committee notes that some tasks would remain, such as validating the concept of destroying multiple rounds in the EDS equipment, establishing whether GTR motors can be separated from their warheads safely, and determining how many EDS units would be required to meet the April 2007 deadline. Other tasks derive from environmental re- quirements, including Resource Conservation and Recovery Act and air emissions permitting, as well as demonstrating compliance with the National Environmental Policy Act. Both the Army and the Arkansas Department of Environ- mental Quality have spent much time preparing and review- ing permit applications, including both the PBNSF applica- tion and the application for the EDS unit that will be used in conjunction with the operation of PBMAS. Switching in midstream to an EDS approach for PBNSF operations would cause the expenditure of additional permitting effort and might jeopardize the Army’s CWC schedule obligations. However, since permit application documentation already exists for the EDS unit associated with the operation of PBMAS, that documentation could be used as a basis for permitting the more extensive use of EDS units at PBNSF, limiting the additional effort. In addition, because the use of multiple EDS units represents a simpler approach than the current PBNSF design, permit application revisions and re- sulting permit documentation are likely to be less onerous and less complex. The committee also expects that the fre- quency of permit modifications over the course of PBNSF operations would be significantly reduced if an EDS ap- proach were implemented. Closure of the EDS units would also be simpler. An additional advantage of the EDS ap- proach is that it has already received regulatory approvals from the Environmental Protection Agency and three states and that it has a good track record. Cost Comparison It is the committee’s judgment that the multiple-EDS ap- proach is more likely to meet the mandated destruction schedule and to reduce the risk of delay-associated costs. A useful perspective on the relative costs of the multiple-EDS concept versus the current PBNSF design is that the multi- EDS concept, at most, accelerates the acquisition of EDS units already planned for the non-stockpile program. These mobile EDS units should be useful for destroying non-stock- pile materiel recovered at Army facilities or found at other locations across the country (as, for example, at Spring Val- ley in Washington, D.C.). By contrast, the PBNSF equip- ment would be used to destroy RCWM for less than a year. The PBNSF building itself might have continuing utility, but the equipment it contains is unlikely to be used again. As summarized in Table ES-1, the multiple-EDS alterna- tive has several advantages (see also Chapter 6). Recommendation 6-1: The Army should promptly evaluate multi-Explosive Destruction System alternatives for destroy- ing the Pine Bluff recovered non-stockpile munitions inven- tory. If the committee’s premises are borne out, planning, permitting, and public involvement activities aimed at utiliz- ing existing Explosive Destruction System units should be initiated promptly. Finally, the committee’s proposal for an alternative con- figuration for PBNSF using multiple-EDS units is a conse- quence of the success of EDS deployments, both technically and with respect to public acceptability, at four non-stock- pile sites across the United States. It is also a logical exten- sion of the Army’s efforts to enhance the efficacy of EDS units—such as multiple-round testing—as well as ongoing Army activities aimed at separating GTR warheads from their motors and improving the characterization of the con- tents of the recovered chemical munitions in storage at Pine Bluff.

7 T A B L E E S -1 D et ai le d C om pa ri so n of P B N S F a nd M ul ti -E D S O pt io ns Is su e P B N S Fa O pt io n 1: M ul ti pl e E D Sb O pt io n 2: P B N S F + M ul ti pl e E D Sc S af et y P ro P ro P ro N ot a pp li ca bl e. 1. M in im iz es h an dl in g of m un it io ns ( on e ha nd li ng p er 1. G T R w ar he ad a nd e ne rg et ic c om bi ne d ca n be h an dl ed in m un it io n- lo ad in g in to E D S ). E C C -2 . 2. D is po sa l o f m un it io ns c an b eg in im m ed ia te ly a ft er ch ar ac te ri za ti on in st ea d of b ei ng p ut b ac k in to s to ra ge . 3. S ig ni fi ca nt ly r ed uc es r is k to p er so nn el in c om pa ri so n w it h P B N S F . C on C on C on 1. M ul ti pl e ha nd li ng a ct iv it ie s (a ve ra ge o f fi ve ) fo r ea ch 1. G T R w ar he ad a nd e ne rg et ic c om bi ne d ca nn ot b e 1. M ul ti pl e ha nd li ng a ct iv it ie s (a ve ra ge o f fi ve ) fo r ea ch m un it io n be fo re f in al d is po sa l. ha nd le d in E D S . m un it io n be fo re f in al d is po sa l. 2. C ur re nt d es ig n do es n ot p ro vi de f or b ui ld in g to c on ta in 2. C ur re nt d es ig n do es n ot p ro vi de f or b ui ld in g to c on ta in re le as e fr om M C E . re le as e fr om M C E . R is k of f ai lu re P ro P ro P ro to a ch ie ve N ot a pp li ca bl e. 1. L ow ( if m ul ti pl e ro un ds c an b e pr oc es se d in E D S ). 1. N o m aj or d es ig n is su es f or E D S . C W C d at e 2. N o m aj or d es ig n is su es . 2. H as b et te r ch an ce o f ac hi ev in g C W C d ea dl in e th an (A pr il 2 00 7) 3. N o co ns tr uc ti on s ch ed ul e is su es . P B N S F o pt io n du e to u se o f m ul ti pl e E D S u ni ts . 4. E D S is p ro ve n to b e a ro bu st s ys te m o n ac tu al no n- st oc kp il e di sp os al p ro je ct s. 5. S ig ni fi ca nt ly r ed uc es r is k of f ai li ng to a ch ie ve C W C 20 07 d at e. C on C on C on 1. H ig h du e to o ut st an di ng d es ig n is su es ( se e be lo w ). N ot a pp li ca bl e. 1. U nr ea li st ic al ly s ho rt c on st ru ct io n sc he du le . 2. U nr ea li st ic al ly s ho rt c on st ru ct io n sc he du le . 2. R eq ui re s re te nt io n of th e C P T , he el -d is so lv in g ta nk s, 3. L ac k of r ob us tn es s of th e E C C -1 a nd E C C -2 th e D E T , a nd a n M D U . (c an no t w it hs ta nd a n ac ci de nt al d et on at io n w it ho ut 3. L ac k of r ob us tn es s of th e E C C -2 ( ca nn ot w it hs ta nd a n se ri ou s da m ag e) . ac ci de nt al d et on at io n w it ho ut s er io us d am ag e) . C os t P ro P ro P ro 1. S om e it em s al re ad y pu rc ha se d 1. C os ts f or E D S u ni ts a lr ea dy a ss ig ne d. 1. E D S a nd E C C -2 a lr ea dy p ur ch as ed . 2. N o la rg e bu il di ng r eq ui re d an d no s ig ni fi ca nt 2. P W S d oe s no t n ee d to b e de ve lo pe d an d E C C -1 is n ot eq ui pm en t p ur ch as e or in st al la ti on c os ts . re qu ir ed . 3. P er so nn el c os ts s ig ni fi ca nt ly lo w er . 4. M in im um c lo su re c os ts . 5. E D S u ni ts c an b e us ed a t o th er s it es . 6. S ig ni fi ca nt ly r ed uc es c os t o f de st ro yi ng in ve nt or y at P in e B lu ff . 7. S ig ni fi ca nt ly r ed uc es c os t o f de st ro yi ng in ve nt or y at ot he r si te s as E D S u ni ts c an b e m ov ed a nd r eu se d. co nt in ue d

8 T A B L E E S -1 C on ti nu ed Is su e P B N S Fa O pt io n 1: M ul ti pl e E D Sb O pt io n 2: P B N S F + M ul ti pl e E D Sc C os t C on C on C on (c on t.) 1. H ig h co st a ss oc ia te d w it h co ns tr uc ti ng b ui ld in g; N ot a pp li ca bl e. 1. H ig h co st a ss oc ia te d w it h co ns tr uc ti ng b ui ld in g, pu rc ha si ng c om pu te r co nt ro l, in st ru m en ta ti on , pu rc ha si ng c om pu te r co nt ro l, in st ru m en ta ti on , m on it or in g eq ui pm en t, he at in g, v en ti la ti on , a nd a ir m on it or in g eq ui pm en t, H V A C , e tc .; re cr ui ti ng , co nd it io ni ng ( H V A C ), e tc .; re cr ui ti ng , i ns ta ll in g, a nd in st al li ng , a nd tr ai ni ng p er so nn el ; a nd o pe ra ti on s an d tr ai ni ng p er so nn el ; a nd o pe ra ti on s an d cl os ur e. cl os ur e. 2. P B N S F f ac il it y ca nn ot b e us ed f or d es tr uc ti on o f 2. P B N S F f ac il it y ca nn ot b e us ed f or d es tr uc ti on o f in ve nt or y at o th er s it es . in ve nt or y at o th er s it es . P er so nn el P ro P ro P ro N ot a pp li ca bl e. 1. F ew er s ta ff th an P B N S F . N ot a pp li ca bl e. 2. L ow er o ve ra ll le ve l o f tr ai ni ng r eq ui re d. C on C on C on 1. L ar ge o pe ra ti on al s ta ff r eq ui re d. N ot a pp li ca bl e. 1. L ar ge o pe ra ti on al s ta ff r eq ui re d. 2. S ig ni fi ca nt a m ou nt o f tr ai ni ng . 2. S ig ni fi ca nt a m ou nt o f tr ai ni ng . 3. L ar ge a ss oc ia te d co st s. 3. L ar ge a ss oc ia te d co st s. C om pl ex it y P ro P ro P ro N ot a pp li ca bl e. 1. S im pl e sy st em . N ot a pp li ca bl e. 2. S ig ni fi ca nt ly r ed uc es c om pl ex it y of d es tr oy in g in ve nt or y at P in e B lu ff . C on C on C on 1. H ig hl y co m pl ex s ys te m ( co nt ro l s ys te m s, N ot a pp li ca bl e. 1. H ig hl y co m pl ex s ys te m ( co nt ro l s ys te m s, in st ru m en ta ti on , H V A C , E C C , C P T , e tc .) . in st ru m en ta ti on , H V A C , E C C , C P T , e tc .) . R ob us tn es sd P ro P ro P ro N ot a pp li ca bl e. 1. E D S u ni ts a re v er y ro bu st . 1. E D S u ni ts a re v er y ro bu st . 2. S ig ni fi ca nt ly in cr ea se s th e ov er al l r ob us tn es s of th e pr oc es s/ sy st em f or d es tr oy in g in ve nt or y at P in e B lu ff . C on C on C on 1. S ev er al e qu ip m en t i te m s (E C C , C P T , a ir m on it or in g, N ot a pp li ca bl e. 1. S ev er al e qu ip m en t i te m s (E C C , C P T , a ir m on it or in g, et c. ) ar e kn ow n to b e de si gn s th at h av e in cl ud ed et c. ) ar e kn ow n to b e de si gn s th at h av e in cl ud ed co m pr om is es o r ha ve a h is to ry o f pr ob le m s. co m pr om is es o r ha ve a h is to ry o f pr ob le m s. 2. E C C -1 a nd E C C -2 a re n ot a bl e to w it hs ta nd a n 2. E C C -2 is n ot a bl e to w it hs ta nd a n ac ci de nt al d et on at io n a cc id en ta l d et on at io n w it ho ut s er io us d am ag e. w it ho ut s er io us d am ag e. G en er at io n of P ro P ro P ro se co nd ar y w as te N ot a pp li ca bl e. 1. E D S u ni ts a nd c on ta in m en t s he lt er s sh ou ld g en er at e 1. E D S u ni ts a nd c on ta in m en t s he lt er s sh ou ld g en er at e m uc h le ss c ar bo n fi lt er m at er ia l f or d is po sa l t ha n m uc h le ss c ar bo n fi lt er m at er ia l f or d is po sa l t ha n P B N S F . P B N S F . 2. E D S u ni ts g en er at e sm al le r am ou nt s of li qu id 2. E D S u ni ts g en er at e sm al le r am ou nt s of li qu id s ec on da ry se co nd ar y w as te s. w as te s.

9 C on C on C on 1. W il l g en er at e m uc h m or e ne ut ra le nt a nd c ar bo n fi lt er 1. N eu tr al iz at io n ch em is tr y sy st em f or a rs en ic al r ea ge nt s 1. W il l g en er at e m or e ne ut ra le nt a nd c ar bo n fi lt er m at er ia l m at er ia l t ha n O pt io n 1 an d m or e th an O pt io n 2. fo un d in s om e G T R s m us t b e de ve lo pe d. th an O pt io n 1. 2. N eu tr al iz at io n ch em is tr y sy st em f or a rs en ic al r ea ge nt s 2. N eu tr al iz at io n ch em is tr y sy st em f or a rs en ic al r ea ge nt s fo un d in s om e G T R s m us t b e de ve lo pe d. fo un d in s om e G T R s m us t b e de ve lo pe d. E nv ir on m en ta l P ro P ro P ro pe rm it ti ng 1. P er m it d oc um en ta ti on h as a lr ea dy b ee n pr ep ar ed a nd 1. U se o f an E D S -o nl y op ti on w ou ld li ke ly r es ul t i n fa r 1. U se o f an E D S f or m os t o f th e m un it io ns a t P B N S F w il l su bm it te d an d is u nd er r ev ie w b y th e A rk an sa s fe w er p er m it m od if ic at io ns . he lp r ed uc e th e ne ed f or p er m it m od if ic at io ns . D ep ar tm en t o f E nv ir on m en ta l Q ua li ty . 2. T he E D S h as b ee n pe rm it te d pr ev io us ly . C on C on C on 1. L ik el y ne ed f or n um er ou s pe rm it m od if ic at io ns , w hi ch 1. T he e ff or t t o w it hd ra w th e ex is ti ng p er m it a pp li ca ti on 1. T he p er m it a pp li ca ti on w ou ld in cr ea se in s iz e an d m ay c au se d el ay s an d je op ar di ze a bi li ty to m ee t t he an d be gi n pr oc es si ng a n ew o ne is s ub st an ti al . co m pl ex it y, a nd p ro ce ss in g ti m e w ou ld in cr ea se a s w el l. C W C s ch ed ul e. P ub li c P ro P ro P ro ac ce pt ab il it y N ot a pp li ca bl e. 1. M ul ti pl e- E D S li ke ly to b e pr ef er ab le b ec au se N ot a pp li ca bl e. te ch no lo gy is f ul ly tr an sp or ta bl e an d ge ne ra te s le ss se co nd ar y w as te . C on C on C on N ot a pp li ca bl e. N ot a pp li ca bl e. N ot a pp li ca bl e. Is su es to b e 1. Is G T R a ge nt c ov er ed b y C W C ? 1. Is G T R a ge nt c ov er ed b y C W C ? 1. Is G T R a ge nt c ov er ed b y C W C ? re so lv ed 2. H ow c an th e E C C b e m od if ie d fo r w as ho ut o f 2. H ow c an th e ar se ni ca l a ge nt s in a pp ro xi m at el y 40 % o f 2. H ow c an th e E C C b e m od if ie d fo r w as ho ut o f so li di fi ed so li di fi ed m us ta rd ? G T R b e ne ut ra li ze d? m us ta rd ? 3. H ow c an th e ar se ni ca l a ge nt s in a pp ro xi m at el y 40 % o f 3. C an G T R w ar he ad /e ne rg et ic b e di sa ss em bl ed s o th at 3. H ow c an th e ar se ni ca l a ge nt s in a pp ro xi m at el y 40 % o f G T R b e ne ut ra li ze d? E D S c an b e us ed f or a ll it em s? G T R b e ne ut ra li ze d? 4. D es ig n ba si s fo r bu il di ng d oe s no t c on ta in M C E . 4. W he n ca n E D S u ni ts b e on li ne ? 4. D es ig n ba si s fo r bu il di ng d oe s no t c on ta in M C E . 5. A cc es s is su es a nd p ip in g de si gn is su es in th e C P T . 5. H ow m an y m un it io ns c an E D S p ro ce ss a t o ne ti m e? 5. A cc es s is su es a nd p ip in g de si gn is su es in th e C P T . 6. H ow c an g el le d or s ol id if ie d m us ta rd r ou nd s be 6. C an th e pe rm it b e m od if ie d w it ho ut p ub li c 6. W he n ca n E D S u ni ts b e on li ne ? ha nd le d? co nc er n/ de la y? 7. C an p er m it b e m od if ie d w it ho ut p ub li c co nc er n/ de la y? 7. C an G T R e ne rg et ic /w ar he ad b e di sa ss em bl ed s af el y? 8. F in al d es ig n of m un it io ns p ro ce ss in g eq ui pm en t (E C C , P W S ). a P B N S F : E C C -1 , E C C -2 , P W S , h ee l- di ss ol vi ng ta nk s, D E T , M D U , a nd C P T ; n o E D S u ni ts . b O pt io n 1: U se s m ul ti pl e E D S u ni ts o nl y; e li m in at es E C C -1 , E C C -2 , P W S , h ee l- di ss ol vi ng ta nk s, D E T , M D U , a nd C P T . c O pt io n 2: U se s m ul ti pl e E D S u ni ts in li eu o f th e P W S a nd E C C -1 ; r et ai ns E C C -2 , h ee l- di ss ol vi ng ta nk s, D E T , M D U , a nd C P T f or p ro ce ss in g 31 c om pl et e G T R s. d T he c om m it te e de fi ne s “r ob us tn es s” a s th e ab il it y to o pe ra te r el ia bl y ov er ti m e un de r a va ri et y of c on di ti on s an d w it h a va ri et y of in pu ts .