Review and Assessment of Developmental Issues Concerning the Metal Parts Treater Design for the Blue Grass Chemical Agent Destruction Pilot Plant (2008)

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3 Assessment of Metal Parts Treater Testing Activities The metal parts treater (MPT) concept has been sub- than a bulk oxidizer (BOX) unit that will be used for the jected to testing by the Bechtel Parsons Blue Grass Team full-scale MPT and did not include the venturi scrubber. (BPBGT) in Technical Risk Reduction Programs (TRRPs) The CATOX unit had a processing rate of 30 pounds per for the Blue Grass Chemical Agent Destruction Pilot Plant hour (lb/h) of oxidizable gases. The BOX is being designed (BGCAPP), with most of the pertinent testing conducted to process up to 252 lb/h of oxidizable gases. Thus the flow under TRRP 05c. (See Box 3-1.) This testing has used a of off-gas from the MPT enclosures was demonstrated, but three-quarter-scale version of the MPT, designated as the not the OTM configuration, the maximum gas flow rates, or TRRP MPT. equipment that will be provided for the full-scale MPT. The The testing objectives as given in the Bechtel TRRP 05c OTM BOX unit is also considered to be a first-of-a-kind test plan were as follows (BPBGT, 2007d): system, as mentioned in Chapter 2. TRRP MPT testing was performed using surrogates of •  Demonstrate reliable mechanical performance of all parts all munitions metal parts and waste feed streams anticipated and functions of the MPT design, including seals, doors, for the two BGCAPP full-scale MPTs except halogenated bearings, and projectile jamming. waste and energetics batch hydrolyzer (EBH) waste con- •  Demonstrate BGCAPP-specific design improvements taining energetic materials. All feed streams were tested. such as: projectile orientation, steam-injection orientation, However, the BPBGT terminated the waste stream testing gas take-off orientation, and tray design to improve heat- up. before the completion of all planned tests because it was •  Calibrate the computational fluid dynamics (CFD) model felt that sufficient data to design the full-scale MPT had of the test unit on VX 155-mm projectiles to serve as a been obtained. basis for first-of-a-kind (FOAK) full-scale unit modeling. This committee has chosen to group the TRRP MPT test Inherent in this objective is the necessary demonstration results into three areas for review and evaluation. They are that the MPT can heat all parts of materials fed to it to (1) mechanical issues, (2) secondary and closure waste is- 1000oF for at least 15 minutes at a rate that meets expected sues, and (3) results of thermal testing and thermal modeling. feed rates during operation. A discussion of results obtained and required future testing •  Demonstrate treatment of simulated energetics batch hy- for the first two issues follows, and issue 3 is discussed in drolyzer (EBH) rocket warhead debris. Chapter 4. •  Demonstrate limited secondary-waste treatment options to gather data for further effort with the CFD model. •  Perform test runs and cycles of components to make ob- Mechanical Issues servations of critical design parameters that apply to the FOAK unit under design—particularly those that affect The following is a discussion of key mechanical issues the risk of scale-up to the full-scale unit. These include, identified in the TRRP MPT testing. but are not limited to, projectile paint debris generation and accumulation, thermal expansion stresses and deformation points, interferences, Gaussian field measurements and lo- New Door Closure Mechanism and Seals calized heating effects, and wall temperature distribution. Difficulties with getting an acceptably tight closure on the air lock and main chamber doors for the TRRP MPT The TRRP MPT testing used an off-gas treatment sys- have resulted in a change in the design of the door closure tem that included a catalytic oxidizer (CATOX) unit rather mechanism and seals for the full-scale MPT. Instead of the 20 

METHODOLOGY FOR PROSPECTIVE EVALUATION 21 J-type sliding closure mechanism used on the TRRP MPT, ing full-scale MPT testing, the BPBGT intends to reconsider the door for the full-scale MPT will be moved against the Stellite bearings that are interchangeable with the Graphal- closure face by using a two-direction cam design recom- loy® bearings. The BPBGT believes that it has identified an mended by a commercial oven contractor. To close a door, acceptable path forward for resolving the problem of pre- this design moves the door vertically downward with a mature main chamber conveyor bearing failures. However, mechanical screw drive to its bottom position, and the door replacing the bearing mounts will require cooling the unit is then moved horizontally against the closure face. In ad- and reheating. Excessive temperature cycling could cause dition, the seal material design has been altered to give the metal fatigue. The BPBGT has also developed maintenance equivalent of two gaskets between the door and closure face. protocols that shorten replacement times for bearings as A prototype of this new arrangement has been developed much as possible. and tested, but not under the expected operating conditions. Changes were also made in the structural support for the door Finding. The proposed conveyor bearing selection and re- closure and main chamber to make it easier to get a good seal. placement approach is appropriate, but actual demonstration It is noted that all of this testing was done with doors for a of reliable performance has yet to be achieved. If bearing 4-ft.-8-in.-diameter chamber and that the full-scale MPT will replacement is required more frequently than anticipated, it use a 6-ft.-6 in.-diameter main chamber. could reduce the MPT throughput rate. Finding. The larger size of the full-scale MPT doors will Recommendation 3-2. The proposed approach for the pose additional challenges in maintaining seal face alignment replacement of conveyor bearings should be tested in con- and minimizing air in-leakage during operation. junction with the testing of the full-scale MPT at operating temperature and design with tray loading at the fabrication Finding. The new closure mechanisms for the four doors facility. on the full-scale MPT have not been tested at operating conditions. Heating Zones Recommendation 3-1. The new closure mechanisms for The full-scale MPT will use two heating zones in the the full-scale MPT should be tested and cycled at operating main chamber. Each will be capable of 450 kW of induction conditions at the fabrication facility prior to systemization. heating. The TRRP MPT used one 600-kW induction heater. It is unclear whether maintenance on one MPT would be Bearings for the Conveyor Rollers possible while the other was in operation. If not, when one MPT required in-room maintenance, it could not be repaired The Graphalloy® bearings for the conveyor rollers in the until the second MPT was shut down. It would reduce the main chamber experienced galling and other wear failures availability of the MPTs if both had to be shut down when during TRRP testing. The bearing failures were attributed either required in-room maintenance. to oxidation/corrosion at the main chamber operating tem- perature. Three different bearing materials were evaluated: “improved” Graphalloy®, Stellite, and Deva (Deva-Mogul Finding. It is unclear that heat and magnetic fields generated sintered metal). The Stellite and Deva bearings are more by one MPT would allow maintenance on the second unit expensive than Graphalloy® bearings, and the Deva bearings while the first was in operation. are produced by a foreign manufacturer. The Stellite bear- ings exhibited surface galling and friction at temperature, Recommendation 3-3. The BPBGT should consider pro- causing the bearings to come loose from their mountings viding suitable spacing and electromagnetic and thermal and interfere with the trays. All materials experienced wear. shielding to allow maintenance on one unit while the other The BPBGT concluded that the “improved” Graphalloy® is operating. bearings were acceptable, although they exhibited some pit- ting. The BPBGT also developed a bearing-mounting design TRRP testing and computational fluid dynamics (CFD) that allows for quick replacement of the bearings. The ton- modeling showed that certain areas of some projectiles being container MPT used at the Newport Chemical Destruction heated in the main chamber were heating more slowly than Facility, Indiana, has experienced similar bearing failures, most parts of the projectiles. This slower heating required and a repair and replacement approach was adopted. Dur- longer heat-up times to achieve the 1000oF for 15 minutes for all projectiles. After its review of the chamber design, John Ursillo, Pasco Resident Engineer, Bechtel Parsons Blue Grass the BPBGT concluded that the slow heating resulted from Team, “MPT Technical Risk Reduction Program (TRRP) Testing,” presenta- “shadowing” of parts of the projectiles during the radiant tion to the committee, September 5, 2007. heating process. Question-and-answer session with BPBGT personnel and the commit- tee, September 6, 2007. 

22 Review and Assessment of Developmental Issues Concerning the Metal Parts Treater Design BOX 3-1 The Technical Risk Reduction Program (TRRP) 05c Heat Transfer Test The TRRP #05c Heat Transfer test will be performed in accordance with Appendix R of the BGCAPP Design-Build Plan, using the minimum equipment arrangement and testing material (at the Parsons Technology Development and Fabrication Complex) necessary to accomplish the objectives outlined within this Test Protocol and the corresponding Test Plan (to be developed as a follow-on to this protocol). As currently recognized, the overall test program objectives for resolution of the issues identified are described below. 1. Demonstrate design fixes to the PCAPP MPT Test Unit such as: seals, doors, bearings, projectile jamming, etc. as identified in the overall study protocol and the various reports and recommendations emanating from that effort. 2. Demonstrate BGCAPP-specific design improvements such as: effect of projectile orientation, steam injection orientation, gas take-off orientation, tray design to improve heatup. Calibrate the CFD Model of the test Unit on VX 155 mm projectiles to serve as a basis for FOAK full scale unit modeling. 3. Demonstrate treatment of simulated EBH rocket warhead debris. 4. Demonstrate limited Secondary Waste treatment options to gather data for further effort with the CFD Model. 5. Perform test runs and cycles of components to make observations of critical design parameters that apply to the FOAK unit under design­—par- ticularly those that affect the risk of scale-up to the full scale unit. These include, but are not limited to: projectile paint debris generation and accumula- tion, thermal expansion stresses and deformation points, interferences, Gaussian field measurements and localized heating effects, wall temperature distribution, etc. 6. Major Test Acceptance Criteria The following test results are considered acceptable (Note: see test matrix acceptance criteria for specific values): 1. Objective 1: a. Heat rate testing will be acceptable if 5X treatment is achieved as measured by temperature indicating for devices or paints (dosimeters, thermal indicating paints, thermocouples, optical pyrometer, etc.) values of at least 1000 degrees F for 15 minutes; with “coldest spot” thermal treatment duration times under 90 minutes this yields an overall tray duration of 105 minutes. This timing may be adjusted based on further CFD modeling underway for the new tray design and under-tray steam distribution header. b. New door structure travels without binding, operates smoothly with cycle times of no more than 60 seconds to open and 60 seconds to close. Actuat- ing mechanism is not unacceptably heated or mechanically stressed. Two-axis door operating motion remains trouble free and the door seats to the main chamber with no fit issues. The shadowing is being addressed by redesign of the Secondary and Closure Waste Treatment projectile trays, the superheated steam inlet header, and the Pyrolysis testing of secondary waste simulants was car- off-gas outlet header. The choice of mounting projectiles ried out at Hazen Research Inc. (HRI, 2005). This was fol- nose up or nose down in the trays is still a concern for full- lowed by MPT TRRP testing of secondary waste treatment at scale MPT projectile trays. The BPBGT intends to resolve the Parsons facility in Kennewick, Washington, in 2007. this issue by further analysis using the full-scale CFD model results (see Chapter 4). Waste to Be Treated in the MPT Finding. The proposed redesigns for the projectile trays and A flow diagram of the BGCAPP waste treatment system headers to reduce “shadowing” of parts of the projectiles is provided in Figure 1-1 in Chapter 1. Waste to be treated are appropriate. (See Chapter 4 for further information and in the MPT includes the washed munitions bodies from the support.) munitions washout system (MWS), solid residues from the EBH, and secondary and closure waste. Estimated secondary Recommendation 3-4. The proposed header and tray rede- waste generation and MPT processing rates for BGCAPP are signs to reduce “shadowing” of parts of the projectiles should given in Table 3-1. be tested at the full-scale MPT operating conditions at the Table 3-1 shows the waste streams in generic form: fabrication facility. metal waste, butyls, PVCs, sludge, wood, and so on. Specific 

METHODOLOGY FOR PROSPECTIVE EVALUATION 23 c. Main Chamber seal is tight and sufficiently contributes to maintaining the oxygen content in the MPT under 3 % after the appropriate purge cycle is completed. The seal remains in place and intact with no pulling loose, damage or visible misalignment. Face plate and flange heat warpage is minimal (i.e. does not affect the ability of the door seals to function. Helium leak testing devices will be in place to accomplish seal integrity tests.) d. Conveyor bearings enable free rolling tray with full set of projectiles evenly with no visible binding or excessive wear or deformation (i.e., upon post- test disassembly, close inspection yields little or no evidence of galling, pitting, bearing material degradation, etc.). 2. Objective 2: a. The Test Unit will perform as predicted by the CFD model within experimental accuracy. b. Nose up (PCAPP TRRP mode) and nose down (BGCAPP mode) projectile-loaded tray heat up times, in particular the so-called “cold spots” on predicted munition locations will perform as predicted within experimental accuracy; i.e. the location and times of the hotter munitions and the colder munitions are consistent with the CFD model. c. Projectiles will remain free in their tray locations and capable of ready removal after treatment. d. Alternative steam injection and main chamber gas removal orientation designed to mimic the FOAK unit installation will conform to the CFD model’s predicted “cold spot” heatup improvement effects and not degrade system performance. 3. Objective 3: a. Miscellaneous metal parts originating from the EBH treatment of rocket warheads will reach 1000 degrees F for a minimum of 15 minutes within an MPT main chamber thermal treatment duration under 90 minutes. Although this is not an EBH-pacing cycle time. 4. Objective 4: a. The limited secondary waste testing will be considered successful if design data can be obtained from the tray types, surrogate wastes, and heating profiles (low and high) to support further testing with actual secondary waste materials during plant systemization. Design data will consist of information and observations on the efficacy of different tray configurations, debris/particulate generation, treated waste consistency, etc. b. Data on heat transfer through various materials and loading configurations will be obtained to support CFD modeling. 5. Objective 5: a. Success criteria for this objective is to gather enough information during the short testing time available to help reduce the risk that the FOAK unit will have either major design flaws or a reduced throughput when it is tested during the Factory Acceptance Testing at the end of its fabrication. The quantity and type of information that will satisfy this criteria is subjective. SOURCE: BPBGT, 2007d. waste streams that are expected to be treated using MPTs • Agent-contaminated wood. are the following: • Other secondary waste that may be generated dur- ing operation, including miscellaneous metal parts, • Solid residue from the EBHs, a stream that includes contaminated metal straps from the enhanced on- metal parts and elastomeric material, M2 squib site containers, metal-reinforced hoses, metal pip- booster assembly, segments of the shipping and fir- ing, valves, and tools generated during facility ing tubes, and steel parts from the sheared rocket operation. propellant sections of contaminated rockets. The M2 • Other secondary waste that may be generated during squibs are heat-sealed in polyethylene. These com- closure, including solid residues, building compo- ponents are not decomposed in the EBH and must be nents, and appurtenances. “popped” within the MPT. • Nose closures from projectiles. For several of the secondary waste categories above, • Personal protective equipment and other plastic and agent-contaminated waste will be treated by chemical decon- rubber items. tamination. When chemical decontamination does not prove successful (e.g., for agent-contaminated pallets), such waste The rocket motor sections also include a squib in the M67 motor as- will be treated in the MPT before off-site disposal. Second- sembly. During normal operation these squibs are removed with the motor ary waste that is not agent-contaminated is not expected to section and sent off-site. However, during the leaker campaign they will also be processed through the MPT (BPBG, 2004). be sent to the EBH and then to the MPT where they are destroyed. 

24 Review and Assessment of Developmental Issues Concerning the Metal Parts Treater Design TABLE 3-1  Solid Waste Generation and Processing Rate TABLE 3-2  Summary of Results from Secondary Waste in the Metal Parts Treater Testing Carried Out in 2005 Waste Creation Required MPT Material Tested at 1200˚F During Processing Processing PVCa Operations Rate Time Needed Stream Hose Wood PTFEb Rubber Type of Waste (lb/week) (lb/week)a (hours/week) Feed, g 68.5 60.7 51.6 64.0 Metalsb   698 2,598c 1.0 Residue, g 40.2 11.4   0.0 23.8 Butyls   104   25.5 4.1 Weight change (loss to gas phase), g 28.3 49.3 51.6 40.2 PVCsd   762  100 7.6 Gas generated, g gas/g feed   0.413   0.842   1.00   0.628 Sludge   373 232 1.6 a PVC,polyvinylchloride. Wood   214   81 2.6 b PTFE,polytetrafluoroethylene. SOURCE: Sam Hariri, Process Design Lead, Bechtel Parsons Blue Grass Total 2,151 Team, “Thermal Modeling to Support OTM Design,” presentation to the aAs given in BPBG, 2006a. committee, September 5, 2007. bAll metal waste can be processed in a single tray over a 1-hour period. cWeight of GB projectile bodies within a tray and is given for comparison only. dPVC, polyvinylchloride. SOURCE: Adapted from Sam Hariri, Process Design Lead, Bechtel Technical Risk Reduction Program Testing of MPT Parsons Blue Grass Team, “Thermal Modeling to Support OTM Design,” Treatment of Secondary Waste presentation to the committee, September 5, 2007. TRRP testing of secondary waste treatment in the MPT was conducted at the Parsons fabrication facility in Ken- newick, Washington, May 15-31, 2007. Three issues were identified for evaluation in the testing: • Solid waste processing characteristics and rates: In Pyrolysis Testing of Secondary Waste Simulants coordination with the process and operations groups, establish the criteria and throughput processing rates A bench-scale test program was carried out at Hazen for secondary waste and miscellaneous metal parts. Research Inc. in 2005 using a muffle furnace. Four mate- • Real-time volatile organic compound (VOC) moni- rials were subjected to pyrolysis: polytetrafluoroethylene tors: Investigate and provide recommendations on (PTFE), butyl rubber, polyvinylchloride (PVC), and wood. the need for a real-time VOC or total organic carbon These materials were obtained in the form of PTFE sample analyzer system for the MPT and OTM to mitigate line tubing, butyl rubber boots with steel toes, PVC Lab OTM overload. Safety Supply (LSS) hose, and pallet wood. Butyl rubber • Duct plugging: Investigate and provide recommenda- boot material with no steel was also tested. Activated carbon tions on methods to mitigate the potential for down- was not tested because it is expected that this material will stream component plugging. be treated off-site. One objective was to obtain information on gas generation during pyrolysis to confirm the design of One issue that is still being addressed by the BPBGT the OTM. Another objective was to view the physical form is the thermal destruction of the fuze detonators in the EBH of the solid residues from pyrolysis. The test materials were waste stream. According to the TRRP test plan, approxi- pyrolyzed under a nitrogen and steam atmosphere. Sample mately 360 of these items are produced from each EBH dis- weight loss was recorded as a function of temperature as the charge. It is currently planned to send this waste to the MPT; temperature was increased to 1200˚F. A summary of results however, the method of controlling the energetic releases in is shown in Table 3-2. the MPT has not been identified. If not addressed properly, The amount of gas generated during heating to 1200˚F these releases could result in greatly increased maintenance ranged from 0.413 g of gas per gram of starting sample requirements and possible damage to the MPT. A separate material for PVC hose to 1.00 g of gas per gram of starting study is underway to investigate the potential effect of sample material for PTFE. This information is useful for energetics remaining in the EBH debris as fuze remnants confirming the design of the BOX and associated equipment. (BPBGT, 2007b). Visually, the wood sample and the PVC LSS hose had shrunk in size during treatment, but were intact. The butyl rubber boot material had crumbled. As would be expected from Samuel Hariri, Process Design Lead, Bechtel Parsons Blue Grass Team, the gas generation results, the PTFE tubing had essentially “Thermal Modeling to Support OTM Design,” presentation to the commit- disappeared. tee, September 5, 2007. 

METHODOLOGY FOR PROSPECTIVE EVALUATION 25 The simulated waste materials that were treated in the • Sharp, but low-level, spikes of VOCs and carbon MPT were these: monoxide were measured in the outlet air lock. These spikes are believed to be contributors to the rises in • Actual butyl rubber toxic agent protective gear: M3 CATOX noted in the preceding observation and are suits, aprons, boots, gloves; not considered a concern for the BOX unit. Also, • Surrogate demilitarization protective ensemble mate- since nitrogen purge is used in the outlet air lock, rial (30 mil poly sheet) and poly drum liners; ignition of these materials did not occur. • Ethylene propylene diene monomer chemical hose • Wood and cotton cloth waste did not flame when (non-PVC [LSS] air hose surrogate); the tray was removed. Most treated waste appeared • Spill pillows saturated with ethylene glycol (hydrau- reduced to nonorganic constituents and was readily lic fluid stimulant); removed from the WIC by vacuum or brush and • Simulated EBH rocket warhead debris (fuze mock- pan. ups, cut-to-length steel tubes, poly tube); • The mini-WICs showed very little thermal • Scrap piping components (large dense valves and deformation. pipe); and •  dosimeters indicated that treatment at 1000˚F for All • Simulated equipment test hardware rocket shipping 15 minutes was met within the 120-minute standard and firing tube sections and cut aluminum rocket residence time. Oxygen level response indicated that bulkheads from the rocket-cutting machine TRRP. all organic material was gone after 75 minutes. • Remaining issues of concern included steam flow Waste was fed on mini-waste incineration container into the air locks immediately on door opening, and (mini-WIC) trays, half the length but otherwise identical to the smoking of some types of waste shortly after the tray baseline-design WICs. WIC trays were “stacked” using fab- was placed in the chamber. ricated tray inserts to test the concept of “double-decking.” • Estimated weekly secondary waste processing rates The testing at Kennewick was limited to nonhalogenated were developed using an ASPEN model, projecting materials and did not include EBH energetic materials be- BGCAPP waste generation rates to estimate weekly cause of permitting considerations. Waste feeds were limited process time anticipated in the MPT. to 20 lb of organic constituents per tray since the CATOX • Inspection of duct interiors during disassembly of capacity was equivalent to the VOC loading from 30 lb/h the off-gas treatment system showed no buildup of of waste. tars or chars that would be indicative of full-scale The results indicated the following: operational cleanout or downtime issues. However, the amount and rate of surrogate material processed • Chamber oxygen content consistently fell from the was much lower than will be experienced in the full- initial value at tray insertion to less than detectable scale MPT. (<0.01 percent) within minutes after tray insertion. The process logic controller, which recorded O 2 Finding. The range of secondary waste materials tested was levels to 0.0001 percent, indicated that the O2 level limited in comparison to the anticipated range of waste to be continued to drop, stabilized, and eventually rose treated in the full-scale MPT. Furthermore, halogenated ma- rapidly back above the 0.01 percent level. This dura- terials were excluded because the TRRP MPT permit could tion was generally on the order of 60 minutes. not be readily changed to allow such materials. • The BPBGT pyrolysis study concluded that VOC/to- tal organic carbon monitors are not appropriate for Recommendation 3-5a. The BPBGT should perform more- determining the completion of pyrolysis when treat- comprehensive testing prior to systemization, drawing from ing organic-containing materials such as secondary operator experience at prior operating plants. This testing waste (BPBGT, 2007d). should include waste materials and waste flow rates represen- • The off-gas treatment CATOX experienced tempera- tative of those encountered during closure, as well as miscel- ture rises that exceeded the CATOX operating limits. laneous secondary waste from operations and maintenance The temperature spikes varied for different types and any possible residual energetics. of waste. This was not considered a concern by the committee because the full-scale BOX has a higher Recommendation 3-5b. The use of halogenated materials temperature rating. should be minimized in operations and maintenance ac- tivities wherever possible, and selection of materials should Bechtel Parsons Blue Grass Team, “Secondary Waste Testing 15–31 May 2007,” presentation to the committee, September 5, 2007. Bechtel Parsons Blue Grass Team, “Secondary Waste Testing 15–31 ASPEN is chemical engineering processing software. For more informa- May 2007,” presentation to the committee, September 5, 2007, slide 253. tion, see http://www.aspentec.com/products/process-engineering.efm. 

26 Review and Assessment of Developmental Issues Concerning the Metal Parts Treater Design anticipate halogenated materials and the possible corrosive Permits under the Resource Conservation and Recovery nature of steam. Also, testing prior to systemization should Act of 1976 for baseline incineration facilities generally include halogenated feeds at the rate expected from plant consider waste to be nonhazardous for chemical agents and design and operations. suitable for off-site shipment if extractive analysis of the waste shows the concentration of agent to be less than the Finding. Inadequate data were collected to serve as the basis WCL (NRC, 2007). The analysis can be done using the for determining processing rates for secondary waste. Waste toxicity characteristic leaching procedure, as described in loading in trays during the TRRP testing may not be repre- the Environmental Protection Agency’s publication SW-846, sentative of loading configurations during operation (e.g., or by using a different methodology approved by the state weight per tray, double-stacking, and so on). regulatory agency (NRC, 2007). In order to be able to use a WCL criterion, the BPBGT Recommendation 3-6. Additional testing is needed to verify would need to get approval from the State of Kentucky on the the complete destruction of secondary waste and to verify acceptable WCL for each agent and the method of analysis to appropriate feed (e.g., tray and loading) configurations that be used. If approval is obtained, each secondary waste batch render effective treatment of the variety of types of second- suspected of being agent-free may be tested. If it meets the ary waste. WCL, it can be shipped off-site with no further treatment. If it does not meet the criterion and is likely to char or tar at 1000oF, it can be treated at a lower temperature in the MPT Alternative Treatment and Disposition of Secondary Waste and the end product can be analyzed to verify that it meets In general, secondary waste can be shipped off-site the WCL. By lowering the temperature to ~500o F for 1 to safely if it meets one of two criteria: (1) if analysis shows 2 hours, six nines (99.9999 percent) agent destruction and levels less than the applicable waste control limits (WCLs) removal efficiency should be achievable, and char and tar or (2) if the waste has been subjected to thermal treatment at formation should be greatly reduced. 1000oF for 15 minutes. The second criterion, formerly called treatment to 5X, was a requirement for off-site shipment until Finding. In many cases, secondary waste can be shipped June 2004 when the WCL criteria were introduced. off-site for treatment and disposal in a safe manner. The BPBGT plans to heat all secondary waste to 1000oF for at least 15 minutes in the MPT. The advantage of that ap- Finding. For waste that cannot be shipped off-site, the MPT proach is that documentation is straightforward and no further could be used at a lower temperature for treating secondary analysis need be done before shipment. The disadvantage is waste to reduce tar and char load. that many of the secondary waste materials form chars and tars at that temperature that can foul the trays and the OTM. Recommendation 3-7. To reduce the technical risks in treating secondary waste in the MPT, the BPBGT should continue to strive to send as much secondary waste off-site WCLs and the analytical methods required to demonstrate that they have as possible, and should obtain the necessary permits to allow been achieved vary by state. In general, the WCL is defined as 20 parts per lower-temperature processing in the MPT. billion (ppb) for GB and VX and 200 ppb for HD, as determined by the Environmental Protection Agency’s (EPA’s) toxicity characteristic leachate Finding. TRRP MPT testing confirms that treatment of metal procedure (TCLP) applied to the residuals from the metal parts treater. The parts and secondary and closure waste can be performed at WCL may also, or additionally, be based on agent concentration in the air 1000˚F for 15 minutes in a suitably sized MPT if enough time space above the containerized waste treatment residuals. Minimum required levels are typically 1 STEL (short-term exposure limit)—0.0001 mg/m 3 for is allowed for the treatment and if the testing recommended GB, 0.00001 mg/m3 for VX, and 0.003 mg/m3 for HD. in Recommendation 2-1 is completed.