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6 A Greater Role for the Explosive Destruction System in Destruction of the Pine Bluff Inventory of Recovered Chemical Warfare Material While evaluating the current PBNSF design, the commit- tee concluded that there are preferable alternative approaches for destroying the non-stockpile chemical materiel stored at the Pine Bluff Arsenal (PBA). The alternatives involve greater use of the well-proven EDS and are simpler, more reliable, less expensive, and better able to meet the Chemical Weapons Convention (CWC) deadline of April 2007. As outlined in this chapter, the EDS would be easier to operate and maintain without compromising the safety of the workers, the public, or the environment. Although changing to a new operational concept at this late stage in the design planning for PBNSF would present new challenges for meet- ing the CWC deadline, these challenges should be no greater than those for meeting the deadline with PBNSF operation as currently planned. The factors involved in deciding between the current PBNSF design and a design using mul- tiple EDS units are explored in this chapter. CONCERNS ABOUT THE DESIGN OF THE PINE BLUFF NON-STOCKPILE FACILITY Upon reviewing the engineering design plans for the con- struction of PBNSF and the operating plans, in accordance with the statement of task, the committee concluded that the basic design of PBNSF, as configured at the time that this report was finalized, is incomplete. The following issues re- main to be resolved if the design is to destroy all of the RCWM safely and in accordance with the schedule defined in the CWC: 1. 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. 2. The current PBNSF design has not been demonstrated to be able to neutralize the arsenical fills in some of the German Traktor rockets (GTRs). 3. While the Army has determined that the building de- 54 sign is consistent with Army safety regulations, its in- ability to withstand the maximum credible event (MCE) seems inconsistent with the congressional man- date to provide "maximum protection for the environ- ment, the general public, and the personnel who are involved in the destruction of the lethal chemical agents and munitions.") The committee has additional reservations regarding the complexity, safety, and robustness of PBNSF, as described below. Complexity The current PBNSF design employs complex prototype equipment inherited from the discontinued non-stockpile Munitions Management Device (MMD) program and the stockpile Assembled Chemical Weapons Assessment (ACWA) program. Although the equipment is functional, many modifications have been required to create an inte- grated system for PBNSF. As an example, the auxiliary pro- cessing vessel (APV) employed in the explosive contain- ment chamber (ECC) uses a remotely operated, hollow drill that is designed to drill access holes into the munition and then drain the contents. The APV is currently being consid- ered for modification by retrofitting a high-temperature wa- ter injection system to flush out the solidified mustard agent that is expected to be found in some recovered 4.2-in. mortar rounds.2 In the opinion of the committee, increasing the complexity of the equipment in such a manner is likely to i50 U.S.C. Section 1521(c)(~)(A), "Maximum protection for the envi- ronment," is discussed in Appendix D of Review of the Army Non-Stockpile Chemical Materiel: Disposal of Chemical Agent Identification Sets (NRC, 1999). 2Meeting between members of the committee and National Research Council staff, the Army, and Stone & Webster, Boston, May 21-22, 2003.

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A GREATER ROLE FOR THE EXPLOSIVE DESTRUCTION SYSTEM IN DESTRUCTION OF THE PINE BLUFF INVENTORY 55 require excessive equipment maintenance and to delay the schedule. Safety The complexity of the current PBNSF processing se- quence (drill and drain with washout, cut and washout, heel dissolving, metals washing, detonation chamber (DET), chemical neutralization) and its associated equipment leads to concerns about worker safety. The number of munition processing and handling steps and the need for on-the-spot choices of alternative processing modes are the basis for these concerns. The current design requires handling and moving each munition from one process station to another. As an example, an explosively configured 4.2-in. mortar round will be drilled in the ECC. If it contains solidified agent, an attempt will be made to wash it out with a water injector. It will then be transferred to the heel-dissolving tank for an overnight soak and then to the DET for final destruc- tion of the energetics in the munition body and any remain- ing undrained agent (U.S. Army, 2002b). In the EDS, all operations, including neutralization of the chemical agent, are done in the EDS chamber with no potential for exposure of personnel between steps. The only handling step when using the EDS is to place the munitions), which have been prepared for EDS processing by being placed in a fragment suppression system, into the EDS unit. All munition access- ing, chemical neutralization, and explosive destruction op- erations are accomplished without handling the munition. Making operational decisions during processing at PBNSF may often be difficult and require judgment calls on the part of the operating management. For example, if the interior of a 4.2-in. mortar round could not be completely cleaned in the heel-dissolving tank, a decision would have to he made between cutting onen the munition in a projectile washout system (PWS) within an explosion containment enclosure or detonating it in the DET. In either case, detona- tion, whether accidental or intentional, risks contaminating a piece of equipment that will be difficult to clean properly, especially by workers in Level A personnel protective equip- ment. In contrast, the EDS processing procedure is the same for every munition and tolerates great variations in condition of the munitions. O Robustness In the judgment ot~the committee, the current PBNSF pro- cessing procedure appears less capable of dealing with un- expected variations in munition type and condition than the EDS. For example, a mischaracterized munition could cause serious problems in the ECC or PWS operations, where there is more manual handling, and the processing steps are more variable than in the EDS. In addition, the current MMD- derived process appears to be vulnerable to unplanned deto- nations. For example, although the APV is housed in an ECC to protect workers in the event of accidental detonation while processing an explosively configured munition, such an event would probably severely damage the APV, resulting in lengthy schedule delays. An additional impetus for considering a multi-EDS alter- native in preference to the currently designed PBNSF arises from the fact that the latter employs equipment and processes from the abandoned MMD-1 and MMD-2 projects (U.S. Army, 2003f). As indicated in an earlier National Research Council report (NRC, 2001b), the MMD projects experi- enced numerous delays due to frequent equipment and pro- cess modifications as well as many regulator-imposed per- mit changes. Although the PBNSF design includes some non-MMD equipment such as the PWS (from the ACWA program) and has improved the MMD components, it is still conceptually much like MMD-2. The committee's concern is that the need for continuing equipment, process, and per- mit modifications could recur in the PBNSF program. The committee notes that the Army canceled the MMD program in 2000, citing in its press release the success of the EDS program (U.S. Army, 2001b). For the reasons above, the committee concludes that al- though PBNSF can successfully process the non-stockpile munitions stored at PEA, there are significant potential weaknesses and unresolved issues in its current design. Pro- cessing of RCWM in the EDS overcomes most of these prob- lems. The relative merits of PBNSF and the multi-EDS al- ternatives are compared in Table 6-1. The EDS alternative increases reliability and reduces schedule risks due to equip- ment failure. POTENTIAL EDS-BASED SYSTEMS The EDS has been used successfully to destroy non-stock- pile munitions similar to the PEA inventory in operations at Porton Down (U.K.~; Spring Valley, Washington, D.C.; Camp Sibert, Alabama; and Rocky Mountain Arsenal, Colo- rado.3 To date, the committee is aware of the destruction of 86 munitions and chemical agent containers in testing and use of the EDS. This experience is summarized in Table 6-2. Two or three EDS units can perform most if not all of the tasks currently planned for PBNSF. (Under one scenario, a larger EDS the EDS-2 could also perform most if not all the tasks envisioned for PBNSF.) The committee considered two options by which EDS systems could resolve some of the problems of the current PBNSF design. Both options as- sume that EDS units can be made available in a timely man- ner for use in destroying non-stockpile materials intended for PBNSF. 3William Brankowitz, Deputy Product Manager, Non-Stockpile Chemi- cal Materiel Product (NSCMP), "Non-Stockpile Chemical Materiel Prod- uct Program Status Update," briefing to the committee on June 12, 2003.

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A GREATER ROLE FOR THE EXPLOSIVE DESTRUCTION SYSTEM IN DESTRUCTION OF THE PINE BLUFF INVENTORY 59 TABLE 6-2 Usage Data for the EDS Site Month/Year Usage Porton Down, U.K. Phase 1 tests Rocky Mountain Arsenal, Colorado Former Camp Silbert, Gadsden, Alabama Spring Valley, Washington, D.C. Porton Down, U.K. Phase 2 tests November 1999- November 2000 2001 August 2002 May-June 2003 2003 4 cylinders arid 7 mortars containing CG 2 cylinders, 7 4.2-in. mortars, and 5 4.5-in. projectiles containing HD 1 cylinder containing GB 10 M139 bomblets 1 CG-filled 4.2-in. mortar round 15 75-mm artillery rounds containing HD Single-shot tests 4 4.2-in mortar rounds containing HD 3 DOT bottles containing GB Multiple-shot tests 2 tests, each consisting of 3 stokes mortar rounds containing CG 4 tests, each consisting of 3 British 25-lb artillery projectiles containing HD 3 tests, each consisting of 3 DOT bottles containing HD NOTE: The EDS was cleaned and rinsed after each shot in each test and the committee is unaware of any unusual or unexpected maintenance activities that may have occurred. Following the destruction of the bomblets at Rocky Mountain Arsenal, the test report stated: "There were no injures or first aid cases reported for this project." Also, none were reported in the test report issued following the completion of EDS Phase 1 testing at Porton Down. The committee has not reviewed arty other reports issued following EDS testing and use and is not aware of any injuries or safety incidents that may have taken place (U.S. Army, 2001c). Option 1 Option 1 would eliminate all of the currently designed processing equipment (ECC-1, ECC-2, PWS, heel-dissolv- ing tanks, DET, metal decontamination units (MDUs), and the chemical process trailer (CPT)) from PBNSF. In its place, multiple EDS units could be used to dispose of the non-stock- pile inventory at PBA (with the exception of 31 GTRs whose propellant contents exceed the explosive containment capac- ity of the EDS-2~. If it is possible to remove the rocket mo- tors (including propellant) from these GTRs, EDS-2 systems can be used to dispose of the entire PBA inventory. The cal- culations by which this conclusion was reached are provided in Appendix C. In addition to the factors cited above, a ma- jor advantage of the EDS technology 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 for workers, save much of the anticipated equip- ment modification cost, and reduce or eliminate the cost of a permanent building. The integration of agent accessing and neutralization operations within the EDS unit would greatly simplify the agent monitoring requirements for the muni- tions destruction process. 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 in the event that the motors cannot be removed from the warheads safely. The ECC-2 would be needed to process the complete GTRs because the total net explosive weight of the GTR, including propellant, exceeds the containment capacity of both EDS systems. Retention of the ECC-2 requires retention of sev- eral auxiliary facilities, including the CPT, a heel-dissolving tank, the DET, and an MDU. The Army is evaluating op- tions akin to Option 2 in which an EDS unit would be used in addition to PBNSF to ensure destruction of the PBA inven- tory of RCWM by April 2007. Factors for Consideration Both Options 1 and 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

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60 be permanent. The temporary shelters for the EDS units might retain their usefulness after conclusion of the PEA activities because they could be moved to other locations along with the EDS units that they enclose. FACTORS IN IMPLEMENTING A MULTIPLE-EDS DESIGN Need for Early Decisions and Testing The Army is committed to completing destruction of the PEA non-stockpile inventory by the CWC deadline of April 29, 2007. Meeting this deadline using the current PBNSF design will be challenging. Starting over with a new concep- tual approach based on the EDS system also presents sched- ule risk, but this risk might be offset by the advantages of using a relatively simple, well-proven system. For an EDS approach to succeed, several key tests and decisions must be made soon: Valiclation of Concept Some key assumptions about the utility of the EDS equip- ment need to be evaluated. Two of the most critical issues are (1) EDS productivity, i.e., whether an EDS can destroy more than one munition at a time, and (2) EDS capability, i.e., whether the GTR warheads can be safely separated from the propellant-containing rocket motors. EDS productivity. To calculate the number of EDS units required to destroy the 4.2-in. mortars and GTRs, the throughputs of the EDS units need to be established. Current tests at Porton Down suggest that the EDS-2 unit can pro- cess at least three mortar rounds per detonation.4 Tests to establish whether the EDS-2 can treat six or nine rounds at a time are to be conducted in late 2003, when the EDS-2 unit is returned to the Aberdeen Proving Ground.5 If multiround capability is verified and does not entail prob- lems in neutralization and subsequent secondary waste treat- ment and disposal, the number of EDS units required to de- stroy the munitions within the available time window could be reduced significantly. Additional testing is needed to es- tablish the following points: Can the EDS-1 successfully destroy three rounds in a single shot? The EDS-1 units on hand can handle the explosive load from detonation of three 4.2-in. mor- 4Laurence Gottschalk, NSCMP, "Non-Stockpile Chemical Material Product Explosive Destruction System - Phase 2 Unit 1 United Kingdom Testing Update," beefing to the committee on June 12, 2003. 5Laurence Gottschalk, NSCMP, "Non-Stockpile Chemical Material Product Explosive Destruction System - Phase 2 Unit 1 United Kingdom Testing Update," beefing to the committee on June 12, 2003. ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY tars, but the physical arrangements in the EDS cham- ber need to be worked out.6 Does the destruction of multiple rounds per shot entail greater quantities of neutralizing reagent or a longer neutralization time? Preliminary results from the multiround tests at Porton Down indicate that the amount of neutralent per munition treated is substan- tially less than in single-round shots.7 Indeed, there may be a significant reduction in the amount of liquid secondary wastes when multiround processing in the EDS is used rather than operations in PBNSF. Confir- mation of this by tests at Aberdeen Proving Ground would be a significant advantage for the multi-EDS concept. Does the multiround strategy cause any problems in waste treatment or disposal? The EDS units and the EDS containment shelters should generate much less carbon filter material for disposal than would the pro- posed PBNSF building system (cf. Chapter 4~. A chemical neutralization system for arsenical reagents found in some GTRs must still be developed for either a multi-EDS approach or the currently proposed PBNSF design. EDS capability. A critical question is whether GTR mo- tors can be separated from their warheads safely. The Army is currently studying this question. If the separation can be effected, the warheads of the 31 GTRs containing propel- lant-filled motors can be processed in an EDS-2 unit. This finding would confirm that all the non-stockpile munitions under consideration for PBNSF could be destroyed in EDS units (Option 1 above). The ECC-2 and attendant processing facilities would not be required. Availability of Explosive Destruction System Units The number of EDS units that would need to be operated concurrently to meet the April 2007 deadline would be based on the effective capacity of an EDS unit and on the antici- pated operational schedule. This will determine whether ad- ditional EDS units must be procured beyond the threes EDS- 1 units and the single EDS-2 unit now existing, and if so, when. Based on the schedule and capacity information given by the Army and summarized in Appendix C, two of the three EDS-1 units and the one EDS-2 unit, all now existing 6John Gieseking, NSCMP, "Multi-Round Testing with EDS PII," brief- ing to the committee on July 31, 2003. 7Laurence Gottschalk, NSCMP, "Non-Stockpile Chemical Material Product Explosive Destruction System - Phase 2 Unit 1 United Kingdom Testing Update," briefing to the committee on June 12, 2003. 8One of the three EDS-1 units is to be stationed at Aberdeen Proving Ground for deployment to other sites as necessary, so it is not included in schedule calculations for disposal operations at PBNSF.

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A GREATER ROLE FOR THE EXPLOSIVE DESTRUCTION SYSTEM IN DESTRUCTION OF THE PINE BLUFF INVENTORY 61 and planned for Pine Bluff, should be sufficient.9 A signifi- cant factor is when the EDS-1 unit currently planned for handling sensitive munitions with Pine Bluff munitions as- sessment system (PBMAS) could begin routine processing of munitions rather than just unstable mortars and rockets. Offsetting that need is that the "sensitive" munitions handled for PBMAS will commensurately decrease the inventory to be routinely handled in the PBNSF facility, and that the Army is developing increased processing capacity for the EDS-1 and 2 units. Builclings Neeclecl for Explosive Destruction System Units In previous deployments for example, at Spring Val- ley an EDS was housed in a temporary containment shel- ter. If EDS units were to replace the PBNSF processing equipment, the Army must decide whether they will be housed in similar temporary buildings and what sort of ad- ministrative and laboratory facilities might be needed, in- cluding a choice between a permanent building and trailers. Schedule Factors The committee considered the impact on the schedule of changing to a multi-EDS design. Although the primary con- cerns of the committee were reliability, safety, simplicity, and life-cycle costs, neither the Army nor the committee can ignore the fact that the United States is obligated to destroy its chemical weapons by April 2007 (if no extension is re- quested). The implementing United States legislation re- quires that the Army attain that schedule. Thus, the committee evaluated whether a significant change in the conceptual approach at this relatively late date in the facility design might result in failure to meet the April 2007 CWC deadline. Such a failure could result from techni- cal difficulty in implementing the revised design approach (including integration or operational issues), from a longer regulatory approval process due to the change in design, or from public opposition. Interplay of Schedule and Technical Factors Current plans for destruction of 4.2-in. mortar rounds and GTRs in PBNSF require completion of destruction opera- tions during a 10-month period beginning June 1, 2006.~ 9As of July 2003, the Product Manager for Non-Stockpile Chemical Ma- teriel planned to order three more EDS-2 units in the FY06-07 timeframe (two in FY06 and one in FY07) (Darryl Palmer, personal communication to the committee on July 10, 2003). The committee anticipates that, if re- quired, this number should be more than sufficient to dispose of the 31 GTR warheads that are separated from the motors plus the number of stand-alone GTR warheads that contain agent. William Brankowitz, Deputy Product Manager, NSCMP, "Non-Stock- pile Chemical Materiel Product Program Status Update," briefing to the committee on June 12, 2003. Achievement of this starting date requires that design, per- mitting, construction, and systemization of PBNSF adhere to a tight schedule. The anticipated high productivity of the ECC units (five rounds per day in each of the two planned units) and the PWS unit (ten rounds per day) should permit completion of the tasks within 10 months if there are no delays due to unforeseen technical or other problems. The committee is concerned that the complexity of the PBNSF processing is likely to cause just such problems. Implementing either of the two multi-EDS options to at- tain the April 2007 CWC deadline also depends critically on when munitions processing begins. Under current plans, one EDS-1 unit will be placed adjacent to the PBMAS facility to destroy unstable munitions promptly instead of sending them to PBNSF (U.S. Army, 2003f). If regulatory and safety ap- provals allow this EDS to also be used for routine mortar destruction, it could contribute significantly to reducing the non-stockpile inventory intended for PBNSF. However, the EDS-1 alone could not destroy all the mortar rounds before April 29, 2007, if operated on a one-round-per-shot basis. As stated earlier, it is critical to meeting the schedule that three or more rounds be destroyed in each EDS operational cycle. The Army believes that it would not be possible to begin EDS processing of mortar rounds on a three-per-shot basis before December 31, 2004. If the PBMAS EDS-1 unit were to be used routinely to destroy RCWM intended for PBNSF instead of just unstable munitions, it would have 28 months of operating availability (1/1/05-4/29/07~. During this time, it could reasonably process all 732 4.2-in. mortars using a single-shift schedule with three rounds destroyed per shot. i2 The schedule implications of several EDS-based op- erational modes are outlined in Appendix C. Destroying the 38 GTR warheads and 439 complete GTRs (including 31 with propellant in the motors) is in- cluded in the currently planned PBNSF operating schedule. The EDS-based approach can also handle the GTRs except for the 31 with live rocket motors containing propellant. Option 2, which retains the ECC-2 unit, is included in the proposal for an EDS alternative concept to address the latter situation. The EDS-2 unit, which is larger than the EDS-1, can accommodate the physical dimensions of the complete GTRs but cannot accommodate the amount of explosive potential in the rockets containing propellant.~3 If Army studies indicate that the live rocket motors containing pro- pellant can be separated from the GTR warheads safely, one George East, Task Manager, Stone & Webster, Inc., "Non-Stockpile Chemical Materiel Product PBNSF Munitions Processing Update," brief- ing to the committee on June 12, 2003. i2Based on the following assumptions: 10 weeks for systemization; op- erating 40 weeks per full year or 82 weeks total, with three three-rounds- per-shot per week. i3Laurence Gottschalk, NSCMP, "Non-Stockpile Chemical Material Product Explosive Destruction System - Phase 2 Unit 1 United Kingdom Testing Update," briefing to the committee on June 12, 2003.

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62 or two EDS-2 units can destroy the GTR inventory within the time allocated. Regulatory Aspects Several factors that must be considered in determining whether EDS units in addition to the one associated with PBMAS units should be employed in place of the current PBNSF design derive from environmental requirements, in- cluding the Resource Conservation and Recovery Act (RCRA) and air emissions permitting, as well as the Na- tional Environmental Policy Act (NEPA).~4 Much time and effort have been spent by the Army in preparing the current permit applications, which include both the PBNSF permit application and the permit application for the EDS unit that will be used in conjunction with the operation of PBMAS, and by the Arkansas Department of Environmental Quality in reviewing them. Switching to a multiple-EDS approach for PBNSF operations would necessitate an additional per- mitting effort and might jeopardize the Army' s CWC sched- ule obligations. However, the permit application documen- tation already existing for the EDS unit associated with the PBMAS (U.S. Army, 2003f) could be used as a basis for changes toward a multiple-EDS approach for PBNSF, thus limiting the additional effort that will be needed. In addition, because the use of multiple EDSs is a simpler approach than the current PBNSF design, permit application revisions and resulting permit documentation are likely to be not as long or complex. The committee also expects that the frequency of permit modifications during the life of the permit would be significantly reduced if a multi-EDS approach were implemented for PBNSF operations. Closure of the EDS units would also be simpler. Additional advantages of the multi-EDS approach are that the EDS has already received regulatory approvals from the Environmental Protection Agency and from Alabama, Colorado, and the District of Columbia and that it has a good track record. Another factor is whether new or revised environmental assessment documentation would need to be prepared and offered for public comment to satisfy NEPA. Preparing ad- ditional NEPA documentation and coordinating decisions considering public comment would entail additional time and effort. Whether additional or replacement environmental as- sessments would be needed is uncertain, however, since the Army has issued assessments that discuss both PBNSF and PBMAS EDS operations. This matter will no doubt need to be evaluated carefully by the Army. The committee believes that the public should be involved in this decision. Considering the above, from a permitting and NEPA standpoint, there are reasons why a multi-EDS encroach should be considered further. While the regulatory permit- - i4Environmental permitting and other requirements are reviewed more completely in Chapter 5. ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY tiny concerns associated with switching to another approach do pose some disadvantages, the advantages are significant. Permitting concerns are of less importance in this instance, and the decision on whether to consider the multi-EDS ap- proach further for PBNSF operations should be based on the merit of the approach. If a multi-EDS approach is considered, either of two per- mitting options could be pursued. The permit application now being processed for the single-unit EDS that will be used in conjunction with operations at PBMAS could be changed, or the current PBNSF permit application could be changed. With either approach, it is conceivable that multi- EDS operations could be combined under one permit. How- ever, it must be recognized that the PBMAS EDS permit would pertain to fuzed munitions that need to be dealt with expeditiously. While there are many similarities, using multi- EDS devices to routinely destroy non-stockpile materiel at PBNSF would entail a different mode of operation. The amount of non-stockpile munitions that would be processed routinely, for example, is likely to be substantially higher at PBNSF than the amount that would be processed in the PBMAS EDS. In addition, the operation of the EDS at PBMAS is expected to be completed far sooner than would be required for processing the remaining Pine Bluff non- stockpile inventory at PBNSF. Perhaps equally important, the PBMAS EDS unit is in a different physical location from the PBNSF EDS units. There are enough differences between the operational uses of the PBMAS EDS unit and the PBNSF EDS unit to warrant a separate permitting approach. This does not necessarily mean that separate permits are required for these operations. A 2002 National Research Council report recommended the use of alternative RCRA regulatory approval mechanisms when mobile treatment sys- tems or technologies are employed, particularly for small or even moderate quantities of newly discovered non-stockpile chemical warfare materiel (NRC, 2002a). One such alterna- tive mechanism is the RCRA emergency permit. This regu- latory approval mechanism was discussed at length in that report. The committee believes that considering the short- lived campaign planned for the PBMAS EDS unit, use of a RCRA emergency permit would be a viable, if not prefer- able, alternative approach. Public Acceptance While community preference is in itself not a sufficient reason to switch technologies midway in the PBNSF devel- opment process, community opposition could easily derail an Army proposal to replace the current PBNSF design with multiple EDSs. Through either political or legal action, op- ponents could delay and perhaps prevent such a change. In this case, however, all evidence suggests that both the Pine Bluff community and the national activist public that fol- lows chemical weapons disposal would welcome an EDS- based facility.

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A GREATER ROLE FOR THE EXPLOSIVE DESTRUCTION SYSTEM IN DESTRUCTION OF THE PINE BLUFF INVENTORY 63 For example, in urban Washington, D.C., members of the Spring Valley Restoration Advisory Board, as well as resi- dents at large, appeared to support the use of the EDS to dispose of recovered munitions similar to those found at Pine Bluff. Reportedly, residents preferred the EDS to off-site transportation, both before and after the Army destroyed fif- teen 75-mm shells containing HD in June 2003 (U.S. Army, 2003m). Similarly, at Rocky Mountain Arsenal, the commu- nity supported the use of the EDS to dispose of several M139 GB bomblets in 2001.~5 The Chemical Weapons Working Group (a national citi- zen group with a record of opposition to the use of incinera- tion technology that reviews and comments on the U.S. chemical weapons destruction program) applauded the Army' s development of the EDS as a safer approach for deal- ing with non-stockpile weapons (Williams, 2003~. Pine Bluff residents, local newspapers, and the local member of Congress have repeatedly expressed a strong preference that Pine Bluff not become the national dumping ground for recovered chemical weapons. While there is no evidence that the Army has sent or intends to send large numbers of non-stockpile materiel to Pine Bluff, the fear that this could occur should be considered in the Army's decisions. As a result, some Pine Bluff residents have ex- pressed support for transportable systems over fixed facili- ties. If the Army modified its design to include more exten- sive use of the EDS technology rather than a fixed facility, the committee anticipates that there would be community support because it would probably reassure them that when munitions are recovered elsewhere in the future, the disposal equipment will be moved to the recovery site rather than bringing the munitions to Pine Bluff. If the Army decides to consider a multi-EDS option, it should quickly prepare explanatory material and organize a community meeting in Pine Bluff, both to explain the poten- tial of such a change and to let the community express its preferences and concerns. Cost Factors Except for the $19.0 million estimate for the cost of con- structing the "bare" PBNSF building (i.e., without the equip- ment, piping, instrumentation), the committee has not had ac- cess to capital or operating cost data for either the PBNSF or the EDS equipment because it is procurement-sensitive infor- mation and not publicly available (U.S. Army, 2002f). Hence, any comparison of costs is qualitative rather than quantitative. Several aspects of a multi-EDS operation seem likely to be less expensive than the PBNSF as currently designed. A multi-EDS operation would not need a building de- signed to withstand the currently projected MCE because i5Teleconference with Elizabeth Crowe, Non-Stockpile Chemical Weap- ons Citizens' Committee, July 11, 2003. the EDS is designed to contain such an event once the muni- tion is placed within itch Whether the Army chooses to use trailers or a fixed structure to house laboratory and other support personnel during operations, the cost of the support structures should be much less than $19.0 million. The multi-EDS approach should yield significant savings in personnel-related operating expenses. From systemization through operations to closure, the simplicity and reliability of the EDS units should reduce long-term personnel costs. Because the EDS units are similar and have operated reli- ably under widely varying circumstances, systemization op- erations can be expected to be shorter, with savings in both schedule and cost. The commonality of the units would fa- cilitate maintenance once routine operations begin. Training of operating crews would be simpler, and the destruction operations might require fewer personnel. At the end of op- erations, closure might be simplified if there is no permanent structure to decontaminate. It is the committee's judgment that the multi-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 multi-EDS concept and 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 mo- bile EDS units should be useful for destroying non-stockpile materiel recovered at Army facilities or other locations across the country (e.g., situations similar to Spring Valley in Washington, D.C.~. By contrast, the PBNSF equipment would be used for RCWM destruction for less than a year. The PBNSF building itself might have continuing utility, but the equipment it contains is unlikely to be used again. The relative merits of PBNSF and the multi-EDS alterna- tives are summarized in Table 6-3. FINDING AND RECOMMENDATION Finding 6-1: The current design for the PBNSF, which em- ploys prototype equipment acquired from the non-stockpile MMD and stockpile ACWA programs, may be capable of destroying the entire inventory of 4.2-in. mortars and GTRs at the PEA but for a number of reasons might miss the April 29,2007, CWC deadline for completion of the task. An alter- native concept in which multiple EDS units replace the PBNSF processes appears safer, more reliable, and at least as likely to meet the deadline for destruction. Recommendation 6-1: The Army should promptly evaluate multi-Explosive Destruction System alternatives for destroy- i6The risks involved in transporting a munition to the EDS would be equivalent to those in moving it to the PBNSF. The risks involved in un- packing the munition and loading it into the EDS would be mitigated by use of a containment shelter, as was done at Spring Valley.

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64 CPT. ASSESSMENT OF THE ARMY PLAN FOR THE PINE BLUFF NON-STOCKPILE FACILITY TABLE 6-3 Summary Comparison of PBNSF and Multi-EDS Options Issue PBNSFa Option 1: Option 2: Multi-EDSb PBNSF + Multi-EDSC Safety Risk of failure to achieve CWC treaty date (2007) Cost Personnele Complexity Robustnessf Generation of secondary waste cd C C C C C C Environmental permitting B Public acceptability Issues to be resolved A C A A A A A A A A A B C B C C C C B C A C aPBNSF: ECC-1, ECC-2, PWS, heel-dissolving tanks, DET, MDU, and CPT; no EDS units. bOption 1: Uses multiple EDS units only; eliminates ECC-1, ECC-2, PWS, heel-dissolving tanks, DET, MDU, and COption 2: Uses multiple EDS units in lieu of the PWS and ECC-1; retains ECC-2, heel-dissolving tanks, DET, MDU, and CPT for processing of 31 complete GTRs. ~A, best; B. better; C, good. These ratings represent the collective judgment of the committee. Note that the committee has not conducted a poll of Pine Bluff residents and is basing its judgment of public acceptability on public support for transportable technologies and secondary waste reduction. eIn evaluating the issue of personnel, the committee considered the total number of site workers and the amount of specialized training required to operate the various systems and options. A system that requires fewer personnel with less specialized training is considered superior to a system that requires more personnel with more specialized training. fThe committee defines robustness as the ability to operate reliably over time under a variety of conditions and with a variety of inputs. 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 three 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 multiround testing as well as ongoing Army activities aimed at separating GTR warheads from their mo- tors and improving the characterization of the contents of the recovered chemical munitions in storage at Pine Bluff.