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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants 2 Evaluation Factors Specific to ACWA Sites Application SELECTION OF EVALUATION FACTORS Selection of a treatment technology must consider many factors. The report Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel (International Technologies report) developed six primary factors for evaluation (NRC, 2006): Process maturity, Process efficacy, Process throughput, Process safety, Public and regulatory acceptability in a U.S. context, and Secondary waste issues. These factors are used in the current report to compare four explosive technologies (EDTs): the Army’s explosive destruction system (EDS); the detonation of ammunition in a vacuum integrated chamber (DAVINCH) (DV65 from Kobe Steel, Ltd.); the TC-60 model of the transportable detonation chamber (TDC) from CH2M HILL; and Dynasafe’s static detonation chamber model SDC2000. The information on these technologies is being updated in this report to allow the technologies to be considered for implementation at the two Assembled Chemical Weapons Alternatives (ACWA) program facilities, the Blue Grass Chemical Agent Destruction Pilot Plant (BGCAPP) and the Pueblo Chemical Agent Destruction Pilot Plant (PCAPP). Two additional factors were used in this study to facilitate the comparison: Destruction verification capability and Process flexibility. Each primary factor comprises a number of subfactors expressed in the form of a question (see Tables 2-1 through 2-6). The original factors and subfactors employed in the 2006 International Technologies report have since been substantially edited and modified to meet the needs of the current study. Each will be considered as it relates to the requirements set forth for the use of EDTs at BGCAPP and PCAPP (see Chapter 1). DESCRIPTION OF EVALUATION FACTORS Process Maturity Process maturity is the readiness of an EDT for use in destroying the specific types of chemical munitions (or components thereof) stored at the Blue Grass Army Depot (BGAD) and the Pueblo Chemical Depot (PCD). The subfactors are listed in Table 2-1. The main evidence for process maturity is the testing of the technology that has been conducted with stored and recovered chemical warfare materiel and/or surrogate materials, in either the United States or other countries. Whether a technology has been permitted or otherwise approved for use in the United States is another key indicator. In assessing the process maturity of the EDTs with respect to the requirements for BGCAPP and PCAPP, the committee determined whether additional research or development would be required before an EDT
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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 2-1 Process Maturity Subfactors Subfactor Relationship to Maturity Has the technology been permitted or otherwise approved and used for similar chemical munitions or energetics in the United States or other countries? If the technology is presently in use either within the United States or elsewhere, it is considered to be mature, although some modification may be necessary to meet the U.S. permitting requirement. If the technology has been permitted or otherwise approved for treatment of similar chemical munitions or energetic materials in the United States, the technology is mature. How much, if any, additional RDTE or reengineering is required to implement the technology? If a moderate or an extensive amount of RDT&E is required to implement the technology, it may not be sufficiently mature. What, if any, are the scale-up requirements needed to implement the technology? Many technologies may be proven on a bench scale or pilot plant scale, but significant scale-up issues may remain. Can the technology be implemented within the time frame of plant operations? A technology should be capable of being selected, permitted, constructed, and becoming operational within a period of time consistent with BGCAPP or PCAPP operating schedule. NOTE: RDTE, research, development, testing, and evaluation. TABLE 2-2 Process Efficacy Subfactors Subfactor Relationship to Process Efficacy/Throughput What is the DRE? Technologies should be able to achieve a DRE for agent of at least 99.9999 percent. What is the DE? Technologies should be able to achieve a DE for agent of at least 99.9999 percent. Is the process reliable? The technology should not have excessive downtime due to scheduled and unscheduled maintenance. Is the process robust? The EDT should be able to accommodate minor variations in the munitions and to destroy large numbers of munitions. could be applied. Again, the subfactors used in the International Technologies report (NRC, 2006) have been modified. Process Efficacy EDTs could be used at BGCAPP and PCAPP to destroy noncontaminated rocket motors, mustard agent-filled munitions in good condition, and leaking or rejected mustard agent munitions. In these applications, process efficacy will be considered relative to environmental regulations and the requirements of the Chemical Weapons Convention (CWC)—namely, Is the technology able to reliably satisfy the established destruction requirements? The subfactors for evaluating process efficacy are listed in Table 2-2. For a definition of destruction efficiency (DE), the following equation may be found:1 For destruction of a chemical weapon, input would be the quantity of agent in a munition and output would be the quantity of agent in all the final residual streams after the detonation process has destroyed that munition. For comparison, the destruction and removal efficiency (DRE) is defined as 1 See http://www.basel.int/techmatters/popguid_may2004_uk_pros%20and%20cons.pdf. Last accessed February 17, 2009.
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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 2-3 Process Safety Subfactors Subfactor Relationship to Safety What are the worker safety and health risks? The process should be able to operate with minimal risk to workers (e.g., minimizing handling, minimizing quantities of explosives). What are the community safety and health risks? The process should be able to operate with minimal risk to the surrounding community. To what extent have engineering controls been developed to ensure process safety? Engineering controls should protect workers and the community from releases of chemical agent. where the emission rate is the rate at which the organic compound selected for measurement exits the process in the exhaust gas stream. The DRE is a measure of emissions to the atmosphere while DE measures total destruction. However, for all practical purposes, the DE and the DRE will be the same number because the liquid and solid secondary waste streams do not contain measurable quantities of chemicals of concern. Some vendors report DEs and others report DREs. Other considerations in assessing efficacy are process reliability and robustness. The EDT must be able to destroy the materiel with minimal downtime for maintenance. Further, the ability of a technology to operate without failure under a wide range of conditions and within the schedule constraints for BGCAPP and PCAPP was also considered. Process Throughput An EDT should have a throughput rate that suits the overall operational schedule for BGCAPP or PCAPP. No table is provided for this factor because it has only one subfactor. The report relies on the peak throughput rates provided by the vendors. As explained in a footnote to Table 4-2, the committee used throughput information to project ranges for the time needed to complete disposal campaigns. Process Safety Process safety for both the workers on-site and the adjacent community must be assessed. In addition, the Department of Defense Explosive Safety Board (DDESB) will need to approve the Site Safety Submission for each application or issue a systemwide approval document (as already done for the EDS). The subfactors involved in process safety are listed in Table 2-3. Process safety is a very important factor. Early in its deliberations, the committee had decided that it would eliminate a technology from consideration if a major shortcoming in safety was identified. All of the EDTs evaluated in this report have withstood hundreds to thousands of detonations in their respective chambers and vessels and in no case was a chamber wall breached as a result of stress cracking or metal fatigue. Both the TC-60 TDC and the DAVINCH DV65 have been found to be in compliance with ASME Boiler and Pressure Vessel Code Case 2564, for impulsively loaded pressure vessel. This code calls for protection against both ductile and brittle failure—that is to say, there should be demonstration of stability against flaws for cracks caused by fragments resulting from detonations. Public and Regulatory Acceptability in a U.S. Context Regulatory approval and public involvement are key to gaining acceptance for a new technology. In other words, regulators and the public must be involved in any decision-making process to allow a technology to be implemented in the United States. Acceptability in a U.S. context also involves considerations about specific concerns that have been raised by the public over the years pertaining to chemical munitions destruction. This factor also specifically evaluates environmental regulations established by the Environmental Protection Agency (EPA) and by states regarding the destruction of chemical weapons and materials. Key in this evaluation is the ability of the technology to satisfy environmental permitting requirements, especially those that were established under the Resource Conservation and Recovery Act (RCRA) for a “miscellaneous unit.”2 The 2 Since it is likely that the technologies evaluated in this report will not be directly comparable to established technologies previously permitted under the RCRA program, they will need to meet
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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 2-4 Subfactors for Public and Regulatory Acceptability in a U.S. Context Subfactor Relationship to Public and Regulatory Acceptance in a U.S. Context Are requirements under the National Environmental Policy Act (NEPA) applicable and if they are, will there be impediments to meeting these requirements? The requirement to perform NEPA analyses may entail minimal or extensive effort depending on the potential environmental impact of the technologies being evaluated. Does the technology employ any thermal treatment of the offgas that might be considered to be incineration or incineration-like? Some U.S. public stakeholders may oppose offgas treatment that employs incineration or that is incineration-like. Could the process produce dioxins or other unwanted by-products? U.S. regulators and other stakeholders have reacted unfavorably to technologies that could create undesirable by-products. Does the process allow holding and testing process residuals prior to release? U.S. regulators and public stakeholders have reacted favorably to technologies that allow waste materials and by-products to be held and tested prior to their release. Does the process result in excessive noise, odors, or other nuisances? U.S. regulators and other stakeholders have reacted unfavorably to technologies that generate excessive noise, odors, or other nuisances. Would the process be able to satisfy environmental regulatory requirements under RCRA? Permitting requirements under RCRA are stringent and have caused delays in technology implementation, particularly if there is public opposition (see NRC, 2002). Would the process be able to satisfy environmental regulatory requirements under the CAA? Permitting requirements under the CAA are stringent and have caused excessive delays in technology implementation, particularly if there is public opposition (see NRC, 2002). Does the process satisfy the principals of pollution prevention and waste minimization? Technologies, to the extent possible, should employ process chemicals that are nontoxic and should result in minimal amounts of secondary wastes. Is the process transportable? Public acceptability is enhanced if the system can be removed quickly when a task is completed. For example, the technology used at BGCAPP or PCAPP can be dismantled when it is no longer needed and can be deployed elsewhere (at nonstockpile sites, for instance). permitting requirements of the Clean Air Act (CCA), as well as the principles of pollution prevention and waste minimization, would apply as well. The subfactors listed in Table 2-4 have been updated so they apply to requirements for BGCAPP and PCAPP. Secondary Waste Issues By definition, under RCRA, the materials to be treated are a waste. Consequently, the materials that remain after destruction of the agent and munition are considered secondary waste, which may take the form of solids, liquids, or gases. Phase changes may occur. For example, generated gases may be converted to solid form via adsorption or to liquids via condensation. The the broad and stringent requirements for “miscellaneous units” established under 40 CFR Part 264, Subpart X. secondary wastes were evaluated for their form (liquid, solid, gas), quantity, and toxicity. The subfactors to evaluate secondary waste issues in terms of BGCAPP and PCAPP operations are listed in Table 2-5. Relevant characteristics of the generated secondary wastes were compared to the vapor screening level (VSL) for agent,3 CWC requirements, and environmental regulatory requirements. Treatment of secondary waste and disposition of final residuals were also assessed. Destruction Verification Capability To meet the CWC treaty requirements and protect worker and public safety, the destruction of the treated materials must be verifiable. Verification can be accom-
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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants TABLE 2-5 Subfactors for Secondary Waste Issues Subfactor Relationship to Secondary Waste Issues What is the character of the secondary wastes? Secondary waste issues are most significant for wastes generated in large volumes or for wastes that may contain residual amounts of agent, agent degradation products, and other contaminants of concern in concentrations that warrant regulatory action. Form (liquid, solid, or gas) Volume or mass Toxicity (the extent to which the wastes contain agent, degradation products, metals, other contaminants) Do secondary wastes meet Army criteria for unrestricted release (≤1VSL)? Secondary wastes must meet the Army’s requirements for decontamination and may have to be destroyed in compliance with the CWC. It is theoretically possible that some new technology might generate secondary wastes that need additional scrutiny under the CWC if they contain Schedule 2 chemicals.a Moreover, additional treatment may be required if secondary wastes do not meet environmental regulatory requirements as generated.b CWC requirements? Requirements of environmental regulations? Which treatment/disposal methods will be practiced for each secondary waste and how will the final treatment residues be disposed of? The final treatment and repository for all generated secondary wastes must be evaluated. aThe CWC established a schedule of chemicals that are controlled under the CWC. Several of the agent degradation products are designated under CWC Schedule 2, and their manufacture and distribution in commerce is controlled. If secondary wastes contain Schedule 2 chemicals, additional scrutiny from CWC inspectors may be required during secondary waste treatment or disposal. bSome secondary wastes may contain hazardous waste (e.g., heavy metals) regulated under the RCRA program; if such contaminants are present at concentrations greater than allowed, the wastes may require additional treatment prior to ultimate disposal. TABLE 2-6 Subfactors for Destruction Verification Capability (for Chemical Agents) Subfactor Relationship to Verification Capability Which monitoring equipment is currently in place, and how is agent destruction ascertained? If the monitors measure destruction directly or indirectly, then the system can be verified. If there are no such monitors, verification must be achieved in another way. To what extent can the effluents be tested to ensure destruction? If the generated gases, liquids, and solids are directly evaluated to determine agent residuals before posttreatment and no residuals are detected, then posttreatment may not be necessary. Are the effluent treatment systems tested for residuals? Destruction can be verified by sampling releases from all posttreatment units. Does the process destroy or deform the munition body so that it cannot be used again or refilled? This is something inspectors from the Organization for the Prohibition of Chemical Weapons, which implements the CWC treaty, look for. Does the process allow holding and testing process residuals prior to release? U.S. regulators and public stakeholders have reacted favorably to technologies that allow waste materials and by-products to be held and tested prior to their release. plishing using means such as monitoring devices and sampling at appropriate points in the treatment system and sampling the exiting materials. Each process must provide verification of destruction. The subfactors for evaluating the ability to verify destruction are listed in Table 2-6. Process Flexibility At Blue Grass the 70,000 noncontaminated rocket motors and 15,000 mustard agent-filled projectiles are expected to be consistent feedstocks. For these applications, the flexibility of an EDT is not an issue unless the Army chooses to use one EDT for both applications.
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Assessment of Explosive Destruction Technologies for Specific Munitions at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants At Pueblo, however, the rejects may have anomalies and the rejects and leakers may be in one or more of a variety of overpacks, as shown in Table 1-2. According to the Army, the ability to dispose of the munitions without removing them from the overpack would be beneficial but is not a requirement.4 In the event that a munition is stored in double overpacks, it could be removed from the outer overpack prior to disposal. The committee understands that disposal of munitions without removal from the overpack offers advantages in throughput, safety, and flexibility. It is an advantage if the process is capable of handling all types and configurations of munitions listed in the four requirements considered in this report (see Chapter 1). ASSESSMENT OF EVALUATION FACTORS AGAINST DIRECTIVES REFLECTED IN THE STATEMENT OF TASK The committee believes that the overall system of factors and subfactors used in this report satisfies the directives in the statement of task. REFERENCE NRC (National Research Council). 2002. Systems and Technologies for the Treatment of Non-Stockpile Chemical Warfare Materiel. Washington, D.C.: The National Academies Press. NRC. 2006. Review of International Technologies for Destruction of Recovered Chemical Warfare Materiel. Washington, D.C.: The National Academies Press.