Assessment of Approaches for Using Process Safety Metrics at the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants (2011)

In 1985, under a congressional mandate (Public Law 99-145), the Army instituted a sustained program to destroy elements of the chemical munition stockpile. In 1992, Congress enacted Public Law 102-484, which extended this program to destroy the entire stockpile.

In 1990, the chemical agent and munitions stockpile contained in excess of 31,000 tons of chemical agents stored at eight chemical weapons depots operated by the Army in the continental United States and on Johnston Island in the Pacific Ocean (southwest of Hawaii). Chemical weapons that had been stored overseas were brought to Johnston Island and destroyed by the Johnston Atoll Chemical Agent Disposal System (JACADS). Approximately 10 percent of the original stockpile is stored at the Pueblo Chemical Depot (PCD) and the Blue Grass Army Depot (BGAD), and approximately 90 percent of that stockpile was stored at sites being served by Chemical Materials Agency (CMA) disposal facilities. As of January 12, 2011, CMA had destroyed 83 percent of the stockpile being treated at its facilities.¹

The stockpile originally contained two types of chemical agents: cholinesterase-inhibiting nerve agents (GB and VX) and blister agents, primarily mustard (H, HD, and HT) but also a small amount of lewisite. Both types of chemical agents are liquids at room temperature. To store the agent, the stockpile originally consisted of (1) bulk (“ton”) containers of nerve and blister agent and (2) munitions, including rockets, mines, bombs, projectiles, and spray tanks loaded with either nerve or blister agents. Many of the munitions contain both chemical agent and energetic materials (propellants and/or explosives), a combination whose safe and efficient destruction poses special challenges.

JACADS completed its mission of destroying approximately 4 percent of the nation’s chemical agent stockpile that had been stored on Johnston Island in November 2000. Of the eight U.S. chemical agent weapons storage sites in the continental United States, three have completed destruction operations (Aberdeen, Maryland; Newport, Indiana; and Pine Bluff, Arkansas); disposal facilities are currently in operation at Anniston, Alabama; Tooele, Utah; and Umatilla, Oregon; and two chemical agent destruction pilot plants, the subjects of this report, are under construction at Pueblo, Colorado, and Richmond, Kentucky. All mines, bombs, and spray tanks have been destroyed. All rockets and nerve agent have been destroyed except for those in the stockpile at BGAD.

The largest stockpile site in the continental United States is the Deseret Chemical Depot near Tooele, Utah. This site initially stored 13,616 tons of agent. This component of the stockpile is being destroyed by the Tooele Chemical Agent Disposal Facility, which started operation in August 1996. The Tooele facility is currently destroying mustard agent. The other disposal facilities at Aberdeen, Maryland; Anniston, Alabama; Pine Bluff, Arkansas; Newport, Indiana; and Umatilla,

Oregon, have collectively destroyed more than 79 percent of the original stockpile. JACADS, Aberdeen, and Newport have been closed.

Chemical agent destruction pilot plants that employ nonincineration alternative destruction technologies are currently under construction at the PCD near Pueblo, Colorado (the Pueblo Chemical Agent Destruction Pilot Plant), and at BGAD in Richmond, Kentucky (the Blue Grass Chemical Agent Destruction Pilot Plant). Consequently, destruction operations have not yet begun at these sites. This report concerns the appropriate process safety metrics for use at these two sites.²

The law mandating the destruction of chemical agent and munitions requires that the destruction be executed with maximum protection to workers, the public, and the environment. In the initial years of the stockpile disposal program, reports by NRC’s Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program repeatedly encouraged the Army and its contractors to pay increased attention to safety and to engage in processes aimed at continuous improvement with respect to safety.³ More recently that committee’s successor committee, the standing Committee on Chemical Stockpile Demilitarization, and numerous ad hoc NRC committees concerned with chemical demilitarization have continued to emphasize safety.

The Army and its contractors have responded so effectively that the remaining operating facilities have attained Occupational Safety and Health Administration (OSHA) recordable injury rates of less than one injury per 200,000 hours worked. Even so, in the interest of continuous improvement, in 2007 the Army expressed a desire and intent to achieve safety performance that is equal to, or better than, that of the best industrial companies, which are consistently near an OSHA recordable injury rate of 0.5. To assist in achieving this goal, the NRC was asked to review existing safety and environmental metrics at operating chemical agent disposal facilities and to recommend additional metrics and/or program modifications, if necessary. The NRC issued its report, Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities, in April 2009.

Having been provided with the 2009 report, and for reasons such as the use of first-of-a-kind equipment and the need to conscientiously adhere to congressional mandates that the destruction of chemical agent and munitions be executed with maximum protection to workers, the public, and the environment, the Program Manager for Assembled Chemical Weapons Alternatives (PMACWA) determined that it would be useful for the NRC to conduct a study on process safety metrics to guide it in formulating a process safety plan for PCAPP and BGCAPP. Accordingly, PMACWA asked the NRC to undertake a study that would guide its development and application of process safety metrics. Since the PCAPP and BGCAPP sites are presently under construction, PMACWA has a timely opportunity to develop process safety metrics to measure and monitor process safety performance.

Because process safety metrics can measure the effectiveness of process safety program management, they are increasingly being used by industry. An independent investigation following an industrial accident at the BP refinery at Texas City, Texas, on March 23, 2005, underscored the inadequacy of injury rates alone to measure process safety performance and called attention to the value of process safety metrics. Specifically, the ensuing report by the BP Independent Refiners Safety Review Panel (the Baker panel report) stated:

The statement of task for the Committee to Assess Process Safety Metrics for the Blue Grass and Pueblo Chemical Agent Destruction Pilot Plants is the following:

This report is focused on metrics to manage operations from the process safety perspective. As will be discussed more fully below, process safety is a disciplined framework for managing the integrity of operating systems, processes and personnel handling hazardous substances, and operations by applying good design principles, engineering, and operating practices. At PCAPP and BGCAPP, process safety encompasses all aspects of the process from the delivery of the chemical weapons from storage, to shipping solid and liquid waste streams for final disposal. Process safety includes keeping materials inside their primary containment, preventing the unintended release of chemical agent, and safely handling all materials and chemicals related to the process. Historically, the CMA has focused its safety program on the prevention of agent releases, the safe handling of energetics, and the safe closure of chemical agent disposal facilities that have completed operations.

The systematic application ofprocess safety principles encompasses the various controls and monitoring of the operations, the data on process compliance, and the effectiveness of these systems. The focus is on performance—that is, on operating excellence that goes beyond strict compliance with regulations or procedures. The mindset of the organization and its ability to focus on and devote time to process safety is essential. The site management must be fully involved in a manner that fosters continuous improvements—for example, by tracking performance through periodic measurements.

A basic principle of a good safety culture is that safety cannot be delegated and is the responsibility of both line management and operations personnel. Line management must take an active leadership role to ensure the effectiveness of a process safety management system. Metrics for monitoring the effectiveness of key process safety programs can be used by management for accomplishing continuous improvement. A focused effort on both leading and lagging metrics is needed.⁴ Developing and implementing leading metrics is more complex and challenging than developing and implementing lagging metrics, but the former have been shown to provide better overall awareness and serve as an early warning of potential process safety incidents, allowing for preventative actions. Similarly, well-designed lagging metrics also provide valuable information about the process, which, if trends are measured, could serve as an indicator of continuous improvement.

The primary mission for chemical demilitarization operations is to destroy the agent and dispose of the associated munitions safely. Well-designed leading process safety metrics can provide an early warning of potential process safety incidents.

An effective process safety program, as outlined above, requires a strong commitment to the shared values and behaviors of a work culture that is pursuing safe operating excellence. Such efforts explicitly require (1) a willingness to devote time and resources to the safety system; (2) constant, focused management involvement; and (3) the active participation of all employees. Successful process safety operations must continuously assess the effectiveness of the process safety management program and the organization’s ability to focus on safety, including but not limited to operational discipline and adherence to standards and performance metrics. Actions to remediate nonconformances must be clearly spelled out along with responsibility for implementing them and time lines for completing them. The success of a safety program will rest on an organization’s ability to maintain operational excellence through demonstrated operational discipline at the management, supervisory, and process levels (operators, maintenance, etc.). Some key operational discipline elements include personal responsibility for understanding risks and the purpose of controls;

teamwork; active communication with other employees involved in the process; use of updated procedures; and training to ensure operators have the knowledge and skills necessary to safely operate the process. Such discipline is based on the deeply rooted dedication and commitment of every member of the organization to carry out each task the right way each time.

During site visits to Pueblo, Colorado, and Richmond, Kentucky, to meet with staff supporting PCAPP and BGCAPP, the committee learned that process safety management considerations have been incorporated. The intent at both sites is to operate under the principles and guidelines set forth in OSHA’s Process Safety Management (PSM) of Highly Hazardous Chemicals, which is located in 29 CFR 1910.119. The sites’ process safety management practices include, but are not limited to, the following:

• Technical risk reduction tests and studies;

• First-of-a-kind process equipment evaluations;

• Application of lessons learned from the Aberdeen and Newport neutralization sites⁵ and the baseline incineration design and operations;

• Design criteria that meet national codes and local regulations;

• Hazard and operability analysis to assess equip­ment and process hazards;

• Internal design reviews to ensure that plant design minimizes adverse safety impacts that would affect the ability to start up, operate, and maintain the sites;

• Use of management of change;⁶

• Process control systems designed to ensure over­all operational control and coordination from the control room, and monitoring of critical safety-related systems and agent-monitoring systems;⁷

• Well-defined operating boundaries using critical operating parameters;

• A formal certification program to ensure employ­ees are trained in and knowledgeable about their respective job duties; and

• Detailed material balances and throughput analyses.

Site plans at PCAPP and BGCAPP include the development of process safety management systems that will address OSHA PSM system requirements. Although the mustard agent to be processed at PCAPP is not covered by the OSHA PSM standard, PCAPP plans to establish a process safety management system to meet the intent of the OSHA PSM regulations. During its visits to PCAPP and BGCAPP, the committee saw that both sites recognized the need for process safety metrics and that they are in the initial stages of developing and implementing such metrics. Both sites had developed metrics to measure the effectiveness of several of the OSHA PSM required elements and are looking for additional guidance from this committee.

As is suggested by the statement of task, a committee with very specific expertise was required to undertake the task (see Appendix B).

Four meetings were held, and individual committee members interacted extensively between meetings. The first meeting focused on gathering information and developing an understanding of the processes to be employed at PCAPP and BGCAPP. Between the first and second meetings, the committee requested and received a considerable amount of information on the two sites.

Two members of the committee conducted a site visit to CMA at the Aberdeen Proving Ground in Maryland, where they evaluated process safety-related incidents at CMA sites since 1990 that were relevant to the work of the committee.

The purpose of the second meeting of the committee, held one day in Pueblo, Colorado, and a second day in Richmond, Kentucky, was to interact directly with ACWA project management personnel to gain an understanding of the operating processes at PCAPP and BGCAPP.

At the third meeting, the committee focused on the results of the process safety incident analyses and data

gathered on process hazards and on assessing how well the draft report met the statement of task.

At the fourth and final meeting, the committee reviewed the report draft, discussed and agreed on findings and recommendations, and set the stage for achieving concurrence soon after via virtual meetings and teleconferences.

Numerous teleconferences and virtual meetings were also conducted between committee meetings; these involved committee members, NRC staff, the Army representatives, and PCAPP and BGCAPP personnel.

This report assesses initiatives undertaken by other process safety-related organizations, such as the American Institute of Chemical Engineers (specifically, its Center for Chemical Process Safety), the American Petroleum Institute, and the United Kingdom Health and Safety Executive, and discusses the applicability of chemical and petroleum industry metrics to PCAPP and BGCAPP.

The committee reviewed process safety-related incidents at CMA facilities since 1990 and their associated key causal factors and suggested metrics based on those factors. The committee also drew on its discussions with project and operations management staff at PCAPP and BGCAPP to aid in the identification of specific process operations that would benefit from the application of process safety metrics.

Using this information, the committee prepared a list of process safety metrics it believes should be adopted at the sites (Recommendation 4-3) and suggested other possible metrics and approaches to generating metrics for consideration and use at the sites (Chapter 4). Additionally, two of the processing steps that will be used, hydrolysate handling and the energetics batch hydrolysis, were selected by the committee to provide guidance on identifying process safety metrics. These examples should help to clarify the process for developing process safety metrics. It is the committee’s expectation that site operations management will conduct thorough reviews of the process at both PCAPP and BGCAPP to identify the leading and lagging process indicators necessary for the effective management of process safety.

This study did not include an independent evaluation of the agent destruction processes planned for use at the two sites. The committee used the sites’ process designs as the basis for its work on metrics and focused on the processes that fall under PMACWA’s management: receipt of munitions for processing, removal of agent and energetics, treatment of recovered agent and energetics, treatment of empty munition bodies, destruction of agent, and secondary processing prior to release of the waste for disposal. Munitions storage is not managed by PMACWA and so is beyond the scope of this report. Also, since the use of explosive destruction technologies for destroying munitions containing agent has been studied extensively by other NRC committees, the committee did not include an assessment of this in this report.

The committee was somewhat constrained by the fact that with planned start-up dates of 2014 and 2018 at PCAPP and BGCAPP, respectively, many operational aspects of the plants are still being defined. As a result, specifying metrics would be premature, so the committee’s recommendations could not be overly specific and are instead more aligned with the members’ experience in other chemical operations. The committee, therefore, has mainly provided guidelines and suggestions for selecting and developing process safety metrics.

This report highlights the use of process safety metrics to provide timely feedback to operations management on the effectiveness of their process safety management system. Chapter 1 describes the U.S. chemical weapons stockpile stored in military depots in the United States. It includes a brief overview of the chemical weapons disposal program developed in response to congressional mandate. The congressional mandate (P.L. 102-484) includes a requirement to provide maximum protection to workers, the public, and the environment. It also provides background information on the role that the NRC has played in assisting the Army to conduct chemical agent disposal operations safely, the origin of the present report and the purpose to be served by it, and the activities to be undertaken by the committee in fulfillment of its statement of task. It also discusses what process safety management and its associated metrics encompass and why they are an important part of a high-functioning worksite safety culture.

Chapter 2 presents a high-level review of the process trains for chemical demilitarization at PCAPP and BGCAPP. Although both facilities will use neutralization processes to dispose of chemical agent, further processing of the resulting hydrolysate to ensure destruction of agent will be accomplished using biotreatment technology at PCAPP and supercritical water oxidation at BGCAPP. Process flow diagrams for the two plants

are provided. First-of-a-kind equipment and operations are also reviewed for the additional risk first-of-a-kind equipment can present.

In Chapter 3, a review of the process safety events that occurred at the CMA neutralization and incineration sites illustrates some causes of process safety incidents that might also occur at PCAPP and BGCAPP. There are also valuable lessons to be learned from experiences with those parts of the disposal process used at the CMA neutralization and incineration sites that are similar to the processes planned for use at PCAPP and BGCAPP.

In Chapter 4, the committee reviews the process safety metrics applied in industry, as well as those established by national and professional organizations, such as the American Institute of Chemical Engineers’ Center for Chemical Process Safety, the American Petroleum Institute, and the United Kingdom Health and Safety Executive. The committee then provides guidance to PMACWA to help in the selection of process safety metrics and related methodologies for PCAPP and BGCAPP.

Chemical Safety Board. 2007. The Report of the BP US Refiners Independent Safety Review Panel. Available online at http://www.csb.gov/assets/document/Baker_panel_report1.pdf. Last accessed on October 28, 2010.