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3 Impacts on Calculation of Destruction Efficiency
Pages 18-28

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From page 18...
... mustard) agents must be proven in an operational facility of scale, configuration, and throughput where comparable to the proposed facility for a period of time sufficient to provide assurance of 99.9999 percent destruction M 1 = Mass of agent per batch entering into the agent or neutralization (i.e., destruction efficiency, or DE)
From page 19...
... ever, a rigorous consideration of the process flow pathways shows that it was conceivable that agent could also be present as vapor generated by the draining and washout operations, IMPACT OF WASHOUT DELETION ON THE and released into the processing room air, and from the ANS CALCULATION OF DESTRUCTION EFFICIENCY headspaces. Furthermore, agent adhering to drained projec- The committee recognizes that the following discussion tiles would be transported to the metals parts treatment unit is complex in places.
From page 20...
... NOTE: Acronyms are defined in the front matter. SOURCE: Adapted from John McArthur, environmental manager, Bechtel Parsons Blue Grass, "Destruction Efficiency Considerations," presentation to the committee on September 9, 2015.
From page 21...
... BGCAPP should demonstrate saton the metal parts.3 Therefore, agent on metal parts from the isfactory destruction efficiency for agent serially treated EBHs processed in the MPT is not expected to affect calcula- with caustic under the same conditions as those present in tion of the DE; that is, measurement of process stream #7652 the energetics batch hydrolyzers (EBHs) and the energetics for agent would not be required.4 However, the MPT was neutralization system at agent loadings equivalent to the highest quantities anticipated to be treated by the EBHs 2 Resource Conservation and Recovery Act (RCRA)
From page 22...
... these pressure and flow characteristics serve to remove If BGCAPP could count agent trapped on the carbon filter agent from the air prior to discharge to the atmosphere after banks of the MDB HVAC system as destroyed, then agent the air stream has passed through other air pollution control partitioned into the OTE gaseous effluent stream #8517 systems, including the OTM and OTE.8 The RD&D Permit would not affect whether BGCAPP achieves DE criteria, Revision 5 Submission, however, also anticipates that that because the multiple banks of both particulate (HEPA) MDB HVAC system controls contaminants that might be filters and activated carbon filtration banks that comprise the MDB HVAC system will capture all of the agent exit 5 Note that the name of this unit may be confusing in that the EBH off- ing the MDB.
From page 23...
... vapor by carbon bank adsorption in the MDB HVAC prior to release of exhaust to the atmosphere, the implementation Recommendation 3-4. BGCAPP should examine the of washout deletion will require significant permit modifica- possibility of routing the gaseous effluent from the OTE tions and has the potential to prevent BGCAPP from achiev- ( ­ energetics batch hydrolyzer off-gas treatment system)
From page 24...
... Hence, the residual agent in the headspace gases emanating from the ACS, ANS, BGCAPP is working with KDEP to identify appropriENS, and MPT could, possibly, be completely destroyed. ate methods to calculate DE after washout deletion and is If this assessment is correct, then effluent from the OTM considering two alternative approaches for generating valid would not convey any agent to the MDB HVAC system via DE calculations with their attendant measurements.
From page 25...
... would need to be measured on projectile bodies entering the MPT from the MWS and the rocket pieces from EBHs, and on filter socks from munitions drain operations. Summing the Calculation of Destruction Efficiency Under Approach 3 agent masses from these streams on a per-munition or per Under Approach 3 the overall process flow for calculating batch basis would provide a total MIn value.
From page 26...
... The orange and purple boxes represent the committee's interpretation of the measurement of BGCAPP effluents to be used in calculating the DE of 99.9999. The purple box around the MWS, PHS, and RHS, and the unnumbered maroon line from the purple box to the carbon filtration system represent fugitive agent emissions from munition drain operations, which are sent directly to the carbon filter banks.
From page 27...
... Approach 3 could conceivably be used for a agent on the metal parts from the MPT is expected to be defendable DE determination, because it accounts for the negligible based on the temperatures and treatment times OTE gaseous process stream #8517, provided it is modified used and historical knowledge of agent destruction under to include the fugitive releases of agent vapor directed to the these conditions. However, the amount of agent on the par- MDB HVAC system.
From page 28...
... However, a measurement of the concentration, together with a reasonable estimate of the volume produced per munition Note, the committee considered whether a revision to or per batch, will suffice to provide defendable MOut values the DE equation in the KAR would be possible that would in the three liquid effluent streams. BGCAPP will have to allow for only measuring the DE at the final exhaust of the determine whether the sensitivity of the current methodology MDB HVAC system -- in essence, including the removal of will be sufficient to confirm that DE criteria have been met.


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