Section 1421 of the National Defense Authorization Act (NDAA) for Fiscal Year 20171 and this committee’s statement of task require the identification and evaluation of “any barriers to full-scale deployment of alternatives to open burning, open detonation, or non-closed loop incineration/combustion and recommendations to overcome such barriers.” In the context of this report, the committee defines the following terms:
- A barrier as something that must be overcome in order for alternative technologies to be applied to munitions within the demilitarization stockpile that are currently being treated via open burning (OB) or open detonation (OD); and
- Full-scale deployment of alternative technologies as maximizing the use of alternative technologies for all munitions in the stockpile that are currently being treated via OB/OD, to the extent possible, using (1) existing facilities; (2) designing, installing, permitting, systemizing, and deploying technologies at one or more Army demilitarization depots; or (3) initiating contracts with commercial facilities.
The Office of the Product Director for Demilitarization (PD Demil) provided information to the committee concerning the reason OB/OD was selected for the munitions on the list of the top 400 Department of Defense Identification Codes (DODICs) in the stockpile. The most common reasons given were safety—for example, the requirement to disassemble certain munitions before using alternative technologies may affect personnel safety and a lack of organic alternative technologies on-site at the depot where the munition was stored.2 Representatives of PD Demil also expressed concerns that the lower throughput attributable to some alternative technologies could impact the mission readiness of the DoD, although they also stated that currently existing alternative technology units are not being used to their maximum capacity and that PD Demil could improve and maximize the throughput of existing alternative technology units. PD Demil pointed out that it has used research, development, test, and evaluation funding to address efficiency of alternative technologies, including (1) expanding the APE 1236 for dual feed to get more throughput rather than limiting campaigns to single munition types and (2) implementing cryofracture preprocessing to support the use of other alternative technologies, such as contained burn chambers.3
The committee agrees that human health and personnel safety are the paramount reason that all demilitarization technologies must be evaluated and chosen carefully (see Chapters 2 and 6). However, the committee believes that if alternative technologies are available at other stockpile depots4 or through commercial contracts, it would be appropriate for PD Demil to consider all of these resources when deciding what technology to use, taking into consideration all pertinent criteria such as transportation cost, risk and public acceptance, and that the lack of an organic, on-site technology should not be the Army’s sole reason for continued use of OB/OD. The committee also believes that the required disassembly of munitions is not a significant barrier to using alternative technologies while ensuring minimal exposure of personnel to explosive safety risks (see Chapters 4, 7, and 8). The committee discussions in the previous chapters indicate that there are no significant technical, safety, or regulatory barriers to designing, installing, permitting, systemizing, and
1 Public Law 114-328, 130 Stat. 2571, December 23, 2016, Section 1421.
2 Copy of Information Request on OBOD Munitions.xlsx, October 2017.
3 Telephone conference call with PD Demil, June 6, 2018.
4 The Army indicated that between 7 and 15 percent of the current stockpile being treated via OB/OD could be treated by alternative technologies at another organic installation. J. McFassel, product director for demilitarization, PEO AMMO, and O. Hrycak, chief engineer, Office of PD Demilitarization, PEO AMMO, “Emerging Technologies Addressing Alternatives to Open Burn and Open Detonation,” presentation to the committee, August 22, 2017.
deploying alternative technologies for demilitarization of the vast majority of the conventional waste munitions in the Army stockpile that cannot be overcome. Only a relatively small quantity of unstable munitions that present safety concerns absolutely require use of OB/OD (see Chapter 7).
The committee believes that there is only one barrier to the full-scale deployment of alternative technologies in lieu of OB/OD—namely, funding. The committee, in addition, identifies two considerations that are not barriers, but could significantly impact the effective implementation of the Army’s strategy to transition away from OB/OD: (1) PD Demil’s lack of a detailed implementation plan to institutionalize the 2018 Demilitarization Strategic Plan goal to increase the use of contained disposal technologies (CDTs) and reclamation, recycling, and reuse (R3); and (2) the potential for public opposition to the implementation of alternative technologies at the individual stockpile depots.
Finding 9-1. There are no significant technical, safety, or regulatory barriers to the full-scale deployment of alternative technologies for the demilitarization of the vast majority of the conventional waste munitions, bulk energetics, and associated wastes.
Funding is a significant factor in PD Demil decisions regarding selection and use of demilitarization technologies. As stated in Chapter 2, overall funding for PD Demil increased from $134 million in FY2008 to about $198 million in FY2018; an increase of about 4 percent per year (Hrycak and Crank, 2015).5 However, the NDAA for FY2019, in reconciliation as this report was completed, shows that the Army requested and was granted only $158 million for conventional munitions demilitarization; a decrease of about 37 percent from the FY2018 appropriation of $250,826,000. These appropriations include demilitarization activities at both organic Army facilities and commercial contractors. PD Demil stated to the committee that the primary limitation on the quantity of munitions demilitarized is not technological capability or capacity, but budget.6 In 2015, the Government Accountability Office (GAO) reported that the Army, as the Single Manager for Conventional Ammunition (SMCA), stated that the Department of Defense (DoD) demilitarization budget request frequently does not match actual funding needs because the request is based upon the estimated disposal costs required to reduce the existing conventional munitions demilitarization stockpile as well as the costs of disposing of munitions that the services forecast they will submit for disposal in the future (GAO, 2015). However, the forecast information from the services is often inaccurate, although the forecasts have been improving (see Chapter 2). GAO stated that the SMCA “addresses the funding challenge each year by developing an annual demilitarization plan to dispose of as much of the [conventional ammunition demilitarization] stockpile as it can based on the amount of funding they receive.” As reported by GAO, Army officials stated that uncertainties in the amount of funding has caused them to be reluctant to initiate projects that increase demilitarization capacity or efficiency, since these capabilities may not be utilized in the future due to funding shortfalls. Furthermore, Army officials stated to GAO that they lack research, development, test, and evaluation funding to develop demilitarization processes for the disposal of some materiel in the stockpile that cannot be demilitarized using “current processes” (GAO, 2015). A December 2013 Army Audit Agency report by the Army Deputy Chief of Staff for Logistics (G-4) stated that the conventional munitions demilitarization program is considered a lower priority by the Army when compared to other needs (GAO, 2015).
Army and DoD guidance requires performance of full life cycle cost (LCC) analysis (often called Total Ownership Cost for defense systems).7 Such a LCC analysis is necessary to make a completely informed decision on whether to implement alternative technologies in lieu of OB/OD. The LCC for each permitted unit need to include the cost of clean closure required under the appropriate regulations (see Chapters 6 and 8). Conceptually, the LCC of OB/OD should be compared to the LCC of an alternative technology (GAO, 2001; Ryan et al., 2012). If the cost of clean closure at an OB/OD site is significant, the LCC of implementing an alternative technology may not be significantly different from the LCC of an OB/OD unit. Cost estimates provided to the committee in PD Demil presentations did not include full LCC, in that they did not include clean closure costs when comparing the cost per ton of alternative technologies versus OB/OD.
The committee makes no recommendation on the priorities, funding goals, or schedules that should be adopted. The decision on funding is a policy decision to be resolved between the Army (or, more broadly, DoD) and Congress through whatever budget process is appropriate. However, the committee believes that absent a clear directive from Congress, accompanied by sufficient funding, it will not be possible for the Army to implement full-scale deployment of alternative technologies.
5 J. McFassel, product director for demilitarization, PEO AMMO, “Clarifications on Demilitarization Policies and Procedures for National Academy of Sciences,” presentation to the committee on October 23, 2017.
Finding 9-2. The implementation and use of alternative technologies is a function of how much funding is requested by the Army and how much funding is appropriated, however, both the DoD and the Army have placed a relatively low priority on funding the demilitarization program, including the implementation of additional alternative technologies to replace OB/OD, as reflected in their past budget requests.
Finding 9-3. Uncertainty in the current and future funding levels for demilitarization of conventional munitions is a barrier to the development and increased use of alternatives to OB/OD.
Finding 9-4. Absent a clear directive from Congress, accompanied by sufficient funding, it will not be possible for the Army to implement full-scale deployment of alternative technologies in lieu of OB/OD.
Recommendation 9-1. To enable the Department of Defense and Congress to decide what level of resources should be devoted to increasing the use of alternative technologies in lieu of open burning (OB) and open detonation (OD), the Office of the Product Director for Demilitarization should prepare an analysis of the full life cycle costs of demilitarization of the munitions in the stockpile using alternative technologies and OB/OD to determine the funding necessary to increase the use of alternative technologies over various periods of time and the impact of that increase on the demilitarization enterprise.
In its 2007-2012 Demilitarization Strategic Plan, the SMCA stated a strategic goal to “emphasize closed disposal” (DIA, 2006). The enabling objectives/metrics for this goal were to
- Pursue and optimize cost-effective processes for CDTs, and
- Achieve a minimum level for CDTs at 80 percent of execution.
In fact, PD Demil has reduced the use of OB/OD at the seven stockpile depots substantially over the past two decades owing to a combination of the use of alternative technologies, increased reuse and recycling, and increased commercial sales or transfers (see Chapters 1 and 2).
In May 2018, the Army issued its new Demilitarization Enterprise Strategic Plan.8 There was no strategic plan between 2012 and 2018. The committee believes the lack of a strategic plan between 2012 and 2018 may reflect the relative low priority given to demilitarization of conventional munitions, and consequently, the goal of increasing the use of alternative technologies.
The 2018 Demilitarization Enterprise Strategic Plan focuses on the following four goals:
- Maximizing the capacity of commercial contracts (industrial base);
- Improving the efficiency and effectiveness of demilitarization capabilities;
- Institutionalizing design-for-demilitarization policies for all new and modified conventional munitions; and
- Increasing the use of CDTs9 and R3 while continuing to ensure minimal exposure of personnel to explosive safety risks.
Unlike the 2007-2012 Demilitarization Strategic Plan, the last goal in the 2018 Demilitarization Strategic Plan has no numerical goal for increasing the use of CDTs or for increasing the use of R3 in the execution of conventional munitions demilitarization.10 There are two metrics established for Objective 4a, “Increase Use of Closed Disposal Technology.”11 The first requires reports on the “percentage of annual tonnage of munitions demilitarized using closed disposal technologies” to “document the demilitarization enterprise is not completely reliant on open burning and open detonation and is making a significant investment in closed disposal technologies which are useable, safe and environmentally compliant.”12 The second metric calculates the “total configurations in the stockpile for which closed disposal technology exists or is feasible” focused on the top 400 DODICs by weight. The metric should “show an increase from the previous year.”13
8 Strategic Plan: For the Demilitarization Enterprise, draft document provided to the committee by J. McFassel, product director for demilitarization, PEO AMMO, via e-mail on May 25, 2018.
9 Although the PD Demil 2018 Demilitarization Strategic Plan uses the term “closed disposal technologies,” the committee believes it is best to use the term “contained” versus “closed” for two reasons. First, because most contained burn and contained detonation systems eventually release an air stream to the environment, these systems are not truly closed. Second, the committee wants to clearly differentiate the type of treatment (open versus contained) from Resource Conservation and Recovery Act (RCRA) unit closure requirements.
10 Although R3 is an important function for PD Demil, this committee’s charge is to identify and evaluate barriers to the full-scale deployment of alternatives to OB/OD or non-closed loop (i.e., noncontained) incineration/combustion technologies.
11 “Strategic Plan: For the Demilitarization Enterprise,” draft document provided to the committee by J. McFassel, product director for demilitarization, PEO AMMO, via e-mail on May 25, 2018.
The metrics for the first three goals and objectives in the 2018 Demilitarization Enterprise Strategic Plan require PD Demil to determine whether the calculated metric meets established performance ratings (i.e., green, yellow, and red) to demonstrate improvement; however, the metrics for increasing the use of CDTs, and conversely the transitioning away from OB/OD, do not.14 Therefore, other than the general, nonnumeric goal to increase the use of contained disposal and the associated general metrics calculations with no performance requirements stated in the 2018 Demilitarization Strategic Plan, it appears that neither the Army nor PD Demil has established formal internal guidance or an implementation plan for transitioning from the use of OB/OD to the use of alternative technologies.15
Finding 9-5. The goals and metrics in the 2018 Demilitarization Strategic Plan are focused on determining whether the program is meeting or exceeding its planned reduction in OB/OD and increase in R3, but they do not set quantitative end points or time tables.
The committee believes that there is a tendency within all organizations to resist substantive change. Switching to currently available alternative technologies for most or all munitions that are currently treated by OB/OD would involve a substantial institutional change within the Army and PD Demil. If PD Demil is to achieve its stated strategic goal to increase the use of CDTs and R3 while continuing to ensure minimal exposure of personnel to explosive safety risks, in addition to receiving the funding needed, a detailed implementation plan needs to be institutionalized within the DoD and PD Demil, taking into consideration the complex system of conventional munitions demilitarization comprised of personnel, infrastructure, technologies, as well as regulatory requirements.
Finding 9-6. PD Demil’s stated goal is to increase the use of contained disposal technologies. In addition, the Environmental Protection Agency staff and state staff presentations to the committee indicated an evolving preference to move away from OB/OD. Public interest groups also support the adoption of alternative technologies.
Finding 9-7. PD Demil has no implementation plan or process for increasing the use of alternative technologies and transitioning away from OB/OD.
Recommendation 9-2. The Office of the Product Director for Demilitarization should develop a detailed implementation plan for transitioning from open burning and open detonation to alternative technologies, with appropriate performance metrics, and institutionalize it throughout the Demilitarization Enterprise.
As discussed in Chapter 1, an impetus for this study is public opposition to OB and OD and support for seeking and using alternative technologies in lieu of OB/OD. Public interest groups presented to the committee16,17,18 their concerns with OB/OD and their general support for alternative technologies that can effectively meet criteria developed by the Cease Fire! Campaign, a national coalition of more than 60 groups (see Appendix B).
Presentations and comments to the committee indicate that public interest groups do not endorse specific alternatives; rather, they want PD Demil to give serious consideration to adopting alternatives and expending efforts to test and further develop and deploy them, given site-specific concerns and considerations. Communities are likely to differ in their preferences and how they weigh the various Cease Fire! Campaign criteria. In addition, public interest groups indicated to the committee that they recognize that all of the criteria do not need to be met all the time: they are aspirational and provide a list of issues that should be explicitly considered.
Thus, public support may be context-specific, and opposition could arise about particular alternative technologies in specific communities, thereby potentially affecting full-scale deployment of alternative technologies. For example, some representatives expressed to the committee strong opposition to incineration and to intersite transportation, while another believed that thermal treatment with pollution abatement may be worth considering, especially in water-scarce areas. In addition, despite a long history of public opposition to incineration, it is incorrect to conclude that there will necessarily be community opposition in the future and in specific instances to incineration technologies utilizing state-of-the-art pollution abatement systems controls. In addition, multiple criteria have more to do with the process of selecting and implementing alternative technologies than they do with the technologies per se. Factors that can lead to opposition have been clearly articulated to the committee and are included in Appendix D.
The presentations to the committee showed that public opposition currently is centered on non-PD Demil OB/OD
16 Lenny Siegel, executive director, Center for Public and Environmental Oversight, “Communities and Conventional Munitions Demilitarization,” presentation to the committee, August 23, 2017.
17 J. Williams, executive director, California Communities Against Toxics and F. Kelley, member, Steering Committee, Cease Fire! Campaign, Public Perspectives Panel Discussion with the National Academy of Sciences Committee on Alternatives for the Demilitarization of Conventional Munitions, October 23, 2017.
18 D. Bledsoe, founder, Environmental Patriots of the New River Valley, “OB/OD a Living Legacy at RAAP- Radford Army Ammunition Plant/RRAP 1941 to Present,” presentation to the committee, October 23, 2017.
activities, and the committee is not aware of active local public opposition to OB/OD at the seven stockpile depots. However, it is clear that the public does not always make the distinction between different Army activities. Local and nationally organized public opposition can impact the full-scale deployment of alternative technologies through the public notice and hearing provisions during the permitting process and through legislative and regulatory changes (see Chapter 6). Indeed, inclusion of a requirement to conduct this study in the NDAA for FY2017 is a specific example of avenues of effecting change by public interest groups. The committee also notes a history of successful public advocacy forcing changes in legislative and regulatory decision making, at both local and national levels, to Army and other federal programs, particularly in the United States’ chemical weapons demilitarization program.
Proactive, meaningful, and respectful engagement with the public can play an important role in building support for proposals for alternative technologies at specific facilities and communities. As discussed in Chapter 2, PD Demil does not have its own public engagement program. The Public and Congressional Affairs Office, which manages public affairs for the seven stockpile sites, is attached to, and funded by, the Joint Munitions Command (JMC). The director of the Public and Congressional Affairs Office reports to the JMC chief of staff, and the relationship to PD Demil and the demilitarization enterprise is informal. Information presented to the committee suggests that the Public and Congressional Affairs Office is not adequately staffed or funded to proactively and effectively build support for or address potential public opposition to specific alternative technologies. Last, the Public and Congressional Affairs Office is designed to focus less on public engagement or two-way communication than it is on one-way education and correcting misinformation (see Chapter 2). The experience at Camp Minden, even though not entirely collaborative or smooth (see Appendix D), demonstrates that public acceptance of alternative technologies viewed as risky may be possible when decision processes recognize the interweaving of technical and social issues, are responsive to community concerns, and promote shared learning.
Finding 9-8. There is a potential that proposals for alternative technologies to replace OB/OD at the stockpile sites could be contested by the public.
Finding 9-9. The public’s acceptance of technologies that they view as being risky may be fostered if the Army adopts more effective public involvement activities. Without proactive attention by PD Demil to the ways that the perception of technology and management are intertwined, public support may be undermined, resulting in delays in full-scale deployment of alternative technologies to replace OB/OD.
Recommendation 9-3. The Office of the Product Director for Demilitarization should, in coordination with the Joint Munitions Command Public and Congressional Affairs Office, include in its implementation plans proactive public affairs activities that build on the experience of other successful programs in resolving public concerns.
DIA (Defense Intelligence Agency). 2006. Strategic Plan 2007–2012 Leading the Defense Intelligence Enterprise. https://www.hsdl.org/?view&did=474568.
GAO (U.S. Government Accountability Office). 2001. Environmental Liabilities: Cleanup Costs from Certain DOD Operations Are Not Being Reported. https://www.gao.gov/assets/240/233164.pdf.
GAO. 2015. GAO-15-538. Defense Logistics, Improved Data and Information Sharing Could Aid in DOD’s Management of Ammunition Categorized for Disposal. https://www.gao.gov/assets/680/671536.pdf.
Hrycak, O. and T.G. Crank. 2015. Ammunition Demilitarization Research Development Technology and Engineering Program Update. Parsippany, N.J.: 2015 Global Demilitarization Symposium. https://ndiastorage.blob.core.usgovcloudapi.net/ndia/2015/demil/Hrycak.pdf.
Ryan, E., D. Jacques, J. Colombi, C. Schubert. 2012. A Proposed Methodology to Characterize the Accuracy of Life Cycle Cost Estimates for DoD Programs. https://ac.els-cdn.com/S1877050912000749/1s2.0-S1877050912000749-main.pdf?_tid=9f3b6d5e-74b6-4cd3-9357828337e22d7d&acdnat=1532980883_118b1fdb514d5fe9f9b2a414c03d7b36.