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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2 evaluation Factors specific to acWa sites application • Destruction verification capability and selecTioN oF eValuaTioN FacTors • Process flexibility. Selection of a treatment technology must consider many factors. The report Review of International Tech- Each primary factor comprises a number of sub- nologies for Destruction of Recovered Chemical Warfare factors expressed in the form of a question (see Materiel (International Technologies report) developed Tables 2-1 through 2-6). The original factors and six primary factors for evaluation (NRC, 2006): subfactors employed in the 2006 International Tech- nologies report have since been substantially edited and • Process maturity, modified to meet the needs of the current study. Each • Process efficacy, will be considered as it relates to the requirements set • Process throughput, forth for the use of EDTs at BGCAPP and PCAPP (see • Process safety, Chapter 1). • Public and regulatory acceptability in a U.S. con- text, and descriPTioN oF eValuaTioN FacTors • Secondary waste issues. Process maturity These factors are used in the current report to com- pare four explosive technologies (EDTs): the Army’s Process maturity is the readiness of an EDT for use explosive destruction system (EDS); the detona- in destroying the specific types of chemical munitions tion of ammunition in a vacuum integrated chamber (or components thereof) stored at the Blue Grass Army (DAVINCH) (DV65 from Kobe Steel, Ltd.); the TC-60 Depot (BGAD) and the Pueblo Chemical Depot (PCD). model of the transportable detonation chamber (TDC) The subfactors are listed in Table 2-1. The main evi- from CH2M HILL; and Dynasafe’s static detonation dence for process maturity is the testing of the technol- chamber model SDC2000. The information on these ogy that has been conducted with stored and recovered technologies is being updated in this report to allow chemical warfare materiel and/or surrogate materials, the technologies to be considered for implementation in either the United States or other countries. Whether at the two Assembled Chemical Weapons Alternatives a technology has been permitted or otherwise approved (ACWA) program facilities, the Blue Grass Chemi- for use in the United States is another key indicator. cal Agent Destruction Pilot Plant (BGCAPP) and In assessing the process maturity of the EDTs with the Pueblo Chemical Agent Destruction Pilot Plant respect to the requirements for BGCAPP and PCAPP, (PCAPP). Two additional factors were used in this the committee determined whether additional research study to facilitate the comparison: or development would be required before an EDT 

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 ASSESSMENT OF EXPLOSIVE DESTRUCTION TECHNOLOGIES TABLE 2-1 Process Maturity Subfactors Subfactor Relationship to Maturity Has the technology been permitted or otherwise If the technology is presently in use either within the United States or elsewhere, it approved and used for similar chemical is considered to be mature, although some modification may be necessary to meet munitions or energetics in the United States or the U.S. permitting requirement. If the technology has been permitted or otherwise other countries? 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 If a moderate or an extensive amount of RDT&E is required to implement the reengineering is required to implement the technology, it may not be sufficiently mature. technology? What, if any, are the scale-up requirements Many technologies may be proven on a bench scale or pilot plant scale, but needed to implement the technology? significant scale-up issues may remain. Can the technology be implemented within the A technology should be capable of being selected, permitted, constructed, and time frame of plant operations? 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 Relationship to Process Subfactor 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 of destruction efficiency (DE), the following equation may be found:1 International Technologies report (NRC, 2006) have been modified. DE = 100 × [(Input − Output)/(Input)] Process efficacy For destruction of a chemical weapon, input would EDTs could be used at BGCAPP and PCAPP to be the quantity of agent in a munition and output destroy noncontaminated rocket motors, mustard would be the quantity of agent in all the final residual agent-filled munitions in good condition, and leaking streams after the detonation process has destroyed that or rejected mustard agent munitions. In these applica- munition. For comparison, the destruction and removal tions, process efficacy will be considered relative to efficiency (DRE) is defined as environmental regulations and the requirements of the DRE = 100 × [(Feed rate − Emission rate)/(Feed rate)] Chemical Weapons Convention (CWC)—namely, Is the technology able to reliably satisfy the established destruction requirements? The subfactors for evaluating 1See http://www.basel.int/techmatters/popguid_may2004_uk_ process efficacy are listed in Table 2-2. For a definition pros%20and%20cons.pdf. Last accessed February 17, 2009.

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 EVALUATION FACTORS SPECIFIC TO ACWA SITES APPLICATION 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 Engineering controls should protect workers and the community from releases of developed to ensure process safety? chemical agent. where the emission rate is the rate at which the organic Early in its deliberations, the committee had decided compound selected for measurement exits the process that it would eliminate a technology from consideration in the exhaust gas stream. The DRE is a measure of if a major shortcoming in safety was identified. emissions to the atmosphere while DE measures total All of the EDTs evaluated in this report have with- destruction. However, for all practical purposes, the stood hundreds to thousands of detonations in their DE and the DRE will be the same number because the respective chambers and vessels and in no case was a liquid and solid secondary waste streams do not contain chamber wall breached as a result of stress cracking or measurable quantities of chemicals of concern. Some metal fatigue. Both the TC-60 TDC and the DAVINCH vendors report DEs and others report DREs. DV65 have been found to be in compliance with Other considerations in assessing efficacy are pro- ASME Boiler and Pressure Vessel Code Case 2564, for cess reliability and robustness. The EDT must be able impulsively loaded pressure vessel. This code calls for to destroy the materiel with minimal downtime for protection against both ductile and brittle failure—that maintenance. Further, the ability of a technology to is to say, there should be demonstration of stability operate without failure under a wide range of condi- against flaws for cracks caused by fragments resulting tions and within the schedule constraints for BGCAPP from detonations. and PCAPP was also considered. Public and regulatory acceptability in a u.s. context Process Throughput Regulatory approval and public involvement are key An EDT should have a throughput rate that suits the to gaining acceptance for a new technology. In other overall operational schedule for BGCAPP or PCAPP. words, regulators and the public must be involved in No table is provided for this factor because it has only any decision-making process to allow a technology to one subfactor. The report relies on the peak through- be implemented in the United States. Acceptability in a put rates provided by the vendors. As explained in a U.S. context also involves considerations about specific footnote to Table 4-2, the committee used throughput concerns that have been raised by the public over the information to project ranges for the time needed to years pertaining to chemical munitions destruction. complete disposal campaigns. This factor also specifically evaluates environmental regulations established by the Environmental Protection Agency (EPA) and by states regarding the destruction Process safety of chemical weapons and materials. Key in this evalu- Process safety for both the workers on-site and the ation is the ability of the technology to satisfy environ- adjacent community must be assessed. In addition, mental permitting requirements, especially those that the Department of Defense Explosive Safety Board were established under the Resource Conservation and Recovery Act (RCRA) for a “miscellaneous unit.”2 The (DDESB) will need to approve the Site Safety Sub- mission for each application or issue a systemwide approval document (as already done for the EDS). 2Since it is likely that the technologies evaluated in this report The subfactors involved in process safety are listed in will not be directly comparable to established technologies previ- Table 2-3. Process safety is a very important factor. ously permitted under the RCRA program, they will need to meet

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 ASSESSMENT OF EXPLOSIVE DESTRUCTION TECHNOLOGIES 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 The requirement to perform NEPA analyses may entail minimal or extensive effort Environmental Policy Act (NEPA) applicable and depending on the potential environmental impact of the technologies being evaluated. if they are, will there be impediments to meeting these requirements? Does the technology employ any thermal Some U.S. public stakeholders may oppose offgas treatment that employs treatment of the offgas that might be considered incineration or that is incineration-like. to be incineration or incineration-like? Could the process produce dioxins or other U.S. regulators and other stakeholders have reacted unfavorably to technologies that unwanted by-products? could create undesirable by-products. Does the process allow holding and testing U.S. regulators and public stakeholders have reacted favorably to technologies that process residuals prior to release? allow waste materials and by-products to be held and tested prior to their release. Does the process result in excessive noise, odors, U.S. regulators and other stakeholders have reacted unfavorably to technologies that or other nuisances? generate excessive noise, odors, or other nuisances. Would the process be able to satisfy environmental Permitting requirements under RCRA are stringent and have caused delays in regulatory requirements under RCRA? technology implementation, particularly if there is public opposition (see NRC, 2002). Would the process be able to satisfy environmental Permitting requirements under the CAA are stringent and have caused excessive regulatory requirements under the CAA? delays in technology implementation, particularly if there is public opposition (see NRC, 2002). Does the process satisfy the principals of Technologies, to the extent possible, should employ process chemicals that are pollution prevention and waste minimization? 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), secondary wastes were evaluated for their form (liquid, as well as the principles of pollution prevention and solid, gas), quantity, and toxicity. The subfactors to waste minimization, would apply as well. The subfac- evaluate secondary waste issues in terms of BGCAPP tors listed in Table 2-4 have been updated so they apply and PCAPP operations are listed in Table 2-5. Rel- to requirements for BGCAPP and PCAPP. evant characteristics of the generated secondary wastes were compared to the vapor screening level (VSL) for agent,3 CWC requirements, and environmental regula- secondary Waste issues tory requirements. Treatment of secondary waste and By definition, under RCRA, the materials to be disposition of final residuals were also assessed. treated are a waste. Consequently, the materials that remain after destruction of the agent and munition are destruction Verification capability considered secondary waste, which may take the form of solids, liquids, or gases. Phase changes may occur. To meet the CWC treaty requirements and protect For example, generated gases may be converted to solid worker and public safety, the destruction of the treated form via adsorption or to liquids via condensation. The materials must be verifiable. Verification can be accom- 3For mustard agent, the VSL, which is based on the airborne the broad and stringent requirements for “miscellaneous units” exposure limit (AEL), is 0.003 mg/m3. established under 40 CFR Part 264, Subpart X.

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 EVALUATION FACTORS SPECIFIC TO ACWA SITES APPLICATION 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 Form (liquid, solid, or gas) for wastes that may contain residual amounts of agent, agent degradation products, Volume or mass and other contaminants of concern in concentrations that warrant regulatory action. Toxicity (the extent to which the wastes contain agent, degradation products, metals, other contaminants) Do secondary wastes meet Army criteria for Secondary wastes must meet the Army’s requirements for decontamination and unrestricted release (≤1VSL)? may have to be destroyed in compliance with the CWC. It is theoretically possible CWC requirements? that some new technology might generate secondary wastes that need additional scrutiny under the CWC if they contain Schedule 2 chemicals.a Moreover, additional Requirements of environmental regulations? treatment may be required if secondary wastes do not meet environmental regulatory requirements as generated.b Which treatment/disposal methods will be The final treatment and repository for all generated secondary wastes must be practiced for each secondary waste and how will evaluated. the final treatment residues be disposed of? aThe CWC established a schedule of chemicals that are controlled under the CWC. Several of the agent degradation products are desig- nated 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 If the monitors measure destruction directly or indirectly, then the system can be place, and how is agent destruction ascertained? verified. If there are no such monitors, verification must be achieved in another way. To what extent can the effluents be tested to If the generated gases, liquids, and solids are directly evaluated to determine agent ensure destruction? residuals before posttreatment and no residuals are detected, then posttreatment may not be necessary. Are the effluent treatment systems tested for Destruction can be verified by sampling releases from all posttreatment units. residuals? Does the process destroy or deform the munition This is something inspectors from the Organization for the Prohibition of Chemical body so that it cannot be used again or refilled? Weapons, which implements the CWC treaty, look for. Does the process allow holding and testing U.S. regulators and public stakeholders have reacted favorably to technologies that process residuals prior to release? allow waste materials and by-products to be held and tested prior to their release. Process Flexibility plished using means such as monitoring devices and sampling at appropriate points in the treatment system At Blue Grass the 70,000 noncontaminated rocket and sampling the exiting materials. Each process must motors and 15,000 mustard agent-filled projectiles are provide verification of destruction. The subfactors for expected to be consistent feedstocks. For these applica- evaluating the ability to verify destruction are listed in tions, the flexibility of an EDT is not an issue unless the Table 2-6. Army chooses to use one EDT for both applications.

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 ASSESSMENT OF EXPLOSIVE DESTRUCTION TECHNOLOGIES assessmeNT oF eValuaTioN FacTors At Pueblo, however, the rejects may have anomalies aGaiNsT direcTiVes reFlecTed iN The and the rejects and leakers may be in one or more of a sTaTemeNT oF Task variety of overpacks, as shown in Table 1-2. Accord- ing to the Army, the ability to dispose of the munitions The committee believes that the overall system of without removing them from the overpack would be factors and subfactors used in this report satisfies the beneficial but is not a requirement.4 In the event that directives in the statement of task. a munition is stored in double overpacks, it could be removed from the outer overpack prior to disposal. reFereNce The committee understands that disposal of munitions without removal from the overpack offers advantages NRC (National Research Council). 2002. Systems and Technologies for the in throughput, safety, and flexibility. It is an advantage Treatment of Non-Stockpile Chemical Warfare Materiel. Washington, if the process is capable of handling all types and con- D.C.: The National Academies Press. NRC. 2006. Review of International Technologies for Destruction of figurations of munitions listed in the four requirements Recovered Chemical Warfare Materiel. Washington, D.C.: The National considered in this report (see Chapter 1). Academies Press. 4Personal communication between Allan Caplan, System Devel- opment Group Leader, Non-Stockpile Chemical Materiel Project, and the committee, August 27, 2008.