As of the writing of this report, the U.S. military has a stockpile of approximately 400,000 tons of excess, obsolete, or unserviceable munitions. About 60,000 tons are added to the stockpile each year. Munitions include projectiles, bombs, rockets, landmines, and missiles. Open burning/open detonation (OB/OD) of these munitions has been a common disposal practice for decades, although it has decreased significantly since the 2011.
OB/OD is conducted at numerous installations across the United States, including Army, Air Force, and Navy/Marine bases as well as at munitions production sites, on military ranges, and at other locations, such as Department of Energy (DOE) laboratories. OB/OD is relatively quick, procedurally straightforward, and inexpensive. OB typically involves either the burning of bulk propellants and energetics and waste materials contaminated with these materials in burn pans or other structures, or the static firing of rocket and missile motors. Static fire involves securing the motors on stands and igniting them. OD typically involves placing munitions and donor charges into pits, covering them with earth and activating the donor charges. While there have been safety incidents, OB/OD is considered by the Army to be a generally safe technology for workers. The downside of OB and OD is that they release contaminants from the operation directly into the environment. During OB/OD operations, thick plumes of smoke are quite often visible during these operations. This has generated significant concern on the part of public interest groups.1 These groups have been opposed to OB/OD operations for years, claiming the lack of adequate monitoring of emissions and potentially cumulative negative impacts on human health and the environment.
Current OB/OD operations are conducted under Resource Conservation and Recovery Act (RCRA) permits. These permits are built from a standard foundation of RCRA regulatory requirements, and are then customized for each facility. They include extensive conditions, including limitations on what can be treated, the rate of treatment, time-of-day and weather restrictions, and monitoring requirements. In order for a facility to receive an RCRA permit, the operation must be shown to be protective of human health and the environment—a statutory requirement of RCRA (42 U.S.C. 6902).
Over time, a number of technology alternatives to OB/OD have become available and more are in research and development. Alternative technologies generally involve some type of contained destruction of the energetic materials, including contained burning (CB) or contained detonation (CD) as well as contained methods that forego combustion or detonation. Emissions from CB and CD operations are captured, and gaseous emissions are treated in pollution abatement systems before release to the environment. Recycling, recovery, and reuse of munition components are often employed as well.
These alternative technologies, by their nature, release far fewer emissions into the environment, and thus are generally perceived by the public as more environmentally friendly and acceptable. There is the possibility of an increased safety risk to workers owing to additional handling requirements associated with preparing munitions for disposal by many of the alternative technologies, such as disassembly, size reduction, and the removal of problematic components such as cluster munitions. It should be noted, however, that some demilitarization facilities use automation to minimize handling and worker risk. This leads to the primary downside of most of the available CB/CD technologies. Alternative technologies are expected to have higher capital and operating costs than OB/OD because of the need to procure and install equipment, construct the facility, and pay for utilities, maintenance, and personnel. This cost differential would be even greater were automation used to minimize the handling of munitions. However, the closure and cleanup of alternative technology facilities will likely be less expensive than
1 In the course of its work the committee engaged with representatives of the California Communities Against Toxics, the CeaseFire Campaign, the Center for Public and Environmental Oversight, and the Environmental Patriots of the New River Valley.
OB/OD, as continuing contamination of the surrounding environment during repeated OB/OD operations will require extensive mitigation during closure, particularly if groundwater is contaminated.
In general, many of the CB/CD technologies will also have lower throughput than OB/OD operations. This difference may not be as great as generally assumed, considering the ability of CB/CD facilities to operate at any hour of the day and in most weather conditions. However, throughput for OB/OD operations may be substantially increased by using more burn pans and detonation pits, so long as these can be accommodated within existing permit conditions. It has become clear that throughput is often munition and technology specific.
In response to concerns expressed by public interest groups, the U.S. Congress directed the Secretary of the Army to enter into an arrangement with the Board on Army Science and Technology of the National Academies of Sciences, Engineering, and Medicine to conduct an evaluation of alternative technologies for the demilitarization of conventional munitions in lieu of OB/OD. Specifically, Section 1421 of the National Defense Authorization Act for Fiscal Year 2017 included the following statement of task (SOT) for the study:
- A review of the current conventional munitions demilitarization stockpile, including types of munitions and types of materials contaminated with propellants or energetics, and the disposal technologies used.
- An analysis of disposal, treatment, and reuse technologies, including technologies currently used by the Department and emerging technologies used or being developed by private or other governmental agencies, including a comparison of cost, throughput capacity, personnel safety, and environmental impacts.
- An identification of munitions types for which alternatives to open burning, open detonation, or non-closed loop incineration/combustion are not used.
- An 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.
- An evaluation of whether the maturation and deployment of governmental or private technologies currently in research and development would enhance the conventional munitions demilitarization capabilities of the Department.
The SOT lays out both the nature of and the constraints of the committee’s work. While the committee must address each item of the SOT, it is not permitted to exceed the scope of its work as set forth in the SOT. The SOT specifically focuses on the Department of Defense (DoD) conventional munitions demilitarization stockpile being destroyed at seven stockpile depots: Anniston Munitions Center; Blue Grass Army Depot (BGAD); Crane Army Ammunition Activity (CAAA); Hawthorne Army Depot; Letterkenny Munitions Center (LEMC); McAlester Army Ammunition Plant (MCAAP); and Tooele Army Depot (TEAD). It also includes private sector “industry partners” that operate under contract to the DoD to demilitarize stockpile munitions at their facilities using alternative technologies. It does not include OB/OD at other military bases, ammunition plants, military ranges, or other government-owned locations where OB/OD is conducted.
Nevertheless, the committee understands and acknowledges that the concerns of the public that resulted in this study extend beyond the demilitarization stockpile. The SOT was focused on the conventional demilitarization stockpile and, thus, prevented the committee from specifically addressing other OB/OD locations (discussed in Chapter 1). The committee’s work, however, does reflect the concerns of public interest groups, and the committee’s findings and recommendations for this study will have implications for, and applicability to, OB/OD conducted at these other locations.
The body of this report includes 30 findings and 8 recommendations that address a number of topics in some detail. The committee has consolidated the results of its work into the following six main messages. The findings and recommendations are listed below.
- The Office of the Product Director for Demilitarization (PD Demil) has a stated strategic goal to increase the use of alternative technologies in lieu of OB/OD. The Army has made progress in implementing alternatives at many of the stockpile and contractor locations.
- Some shock-sensitive or unstable munitions may not be safe to handle or transport for treatment by alternative technologies; thus, the capability for OB/OD will always be needed.
- Viable alternative technologies exist within the demilitarization enterprise, either stand-alone or as part of a treatment train, for almost all munitions currently being treated within the DoD conventional munitions demilitarization stockpile via OB/OD.
- Alternative technologies have both pros and cons. Implementing alternative treatment technologies for munitions that are currently treated via OB/OD will result in reduced emissions but will be associated with increased capital and operating costs, although with lower closure costs. The alternative technologies treating the same munitions as OB/OD will have varying throughput capacities compared to OB/OD, depending on the capabilities of the technologies, munitions being treated, and other factors, including
- permit restrictions (e.g., net explosive weight limits and weather restrictions).
- Public interest groups are expected to generally favor alternative technologies over OB/OD. Further progress in implementing alternatives will be facilitated by proactive engagement with federal and state regulators and the affected public, featuring increased two-way communication and transparency in decision making.
- There is only one barrier to the full-scale deployment of alternative technologies in lieu of OB/OD—namely, funding. In addition, there are two other considerations that could significantly impact the transition away from OB/OD: (1) The PD Demil’s lack of a detailed implementation plan to institutionalize the 2018 Demilitarization Strategic Plan and (2) the potential for public opposition to specific alternative technologies at the individual stockpile depots.
FINDINGS AND RECOMMENDATIONS
Finding 2-1. According to PD Demil, the primary factor determining the quantity of munitions demilitarized in a given year is the budget, not technological capacity or availability.
Finding 2-2. Despite the Army’s stated strategic goal of replacing OB/OD with alternative contained treatment technologies, reducing the use of OB/OD is not an explicit criterion used to evaluate projects in PD Demil’s research, development, testing, and evaluation program.
Recommendation 2-1. The Army should include the potential to reduce the use of open burning and open detonation as a criterion used to evaluate candidate projects in Office of the Product Director for Demilitarization’s research, development, test, and evaluation program.
Finding 2-3. The Army demilitarization program appears to have instituted an effective safety management program.
Finding 2-4. According to data provided to the committee by PD Demil, the use of OB/OD as demilitarization treatment methods has declined from an estimated 80 percent of demilitarized munitions in the mid-1980s to an average of about 30 percent in recent years.
Finding 2-5. Nonmunitions waste materials, including solvents and other organic liquids, positively identified as pyrotechnic, explosive, or propellant-contaminated are treated via OB at some of the stockpile demilitarization sites.
Recommendation 2-2. The Office of the Product Director for Demilitarization should investigate the use of alternative treatment or disposal methods, including commercial treatment, storage, and disposal facilities, for positively identified pyrotechnic, explosive, or propellant-contaminated nonmunitions wastes.
Finding 4-1. Contained burn chambers with associated pollution abatement systems designed to treat propellants and other energetics are available commercially and can be designed to meet the needs of PD Demil stockpile demilitarization as a substitute for OB.
Finding 4-2. Contained detonation chambers that can demilitarize some conventional munitions and munition components exist; however, limited explosion containment capabilities and the need to prepare or preprocess munitions can limit the applicability of these chambers.
Finding 4-3. For some munitions, combinations of processing steps will be required to prepare munitions for treatment in a CB or CD chamber. Although this increases complexity and handling risks, if not conducted remotely using automated equipment, these steps enable the munitions to be demilitarized without using OB or OD.
Finding 4-4. Several of the emerging technologies are in early stages of research and development and have not been demonstrated under full-scale operating conditions. None of those examined by the committee is expected to make a significant contribution to demilitarizing munitions in the near future.
Finding 6-1. There is no formal Environmental Protection Agency guidance for permit applicants or authorized state agencies to determine the requirements for applications or permit conditions (e.g., risk goals, treatment efficiencies, or waste and operational limitations) for alternative technology units that would be permitted as Subpart X units.
Finding 6-2. Provisions contained in permits for existing alternative technologies at Army demilitarization depots may limit the types of waste munitions that can be treated or the throughput of the units. Some of these limitations are based on the technology or regulatory limitations, but some may be the result of (1) how the RCRA application was worded or (2) availability of RCRA waste characterizations for a variety of munitions.
Finding 6-3. Public interest group representatives express the need to consider community preferences and site-specific conditions when selecting an alternative technology to implement, install, and permit at any of the seven demilitarization depots.
Recommendation 6-1. The Army should investigate whether permits for existing alternative technology units at
Army munition demilitarization depots can be amended to be more flexible regarding the types, frequency, and amounts of munitions that can be treated.
Recommendation 6-2. The Army should identify issues that could affect the Resource Conservation and Recovery Act permitting process for alternative technologies, including public concerns, and work with regulators in the states with jurisdiction over the seven demilitarization depots to establish requirements for Subpart X applications (e.g., developing scientific and technical analysis documents, emission modeling and estimates, and efficiency documentation for similar units) so as to address issues and questions before they become a problem that could significantly delay permitting alternative technologies.
Finding 7-1. Alternatives to OB/OD are not being used for some munitions because the munitions have become unstable and are too hazardous for the handling and transportation required for demilitarization using alternative technologies. A determination by the PD Demil that a munition is unstable and potentially shock sensitive is a valid reason for performing demilitarization via OB/OD to minimize transportation and handling and, therefore, the exposure of technicians to the explosive hazard. The capability for OB/OD will always be needed.
Finding 7-2. The configuration of some munitions will require handling and processing steps prior to munitions demilitarization using alternative technologies. This adds complexity to the process, may increase the cost of demilitarization, and may increase risks to workers. These factors will have to be considered when evaluating the use of alternative technologies.
Finding 7-3. The organic capabilities of the PD Demil and the contractor community have the technical capability—or could develop the capability—to demilitarize nearly all of the munitions in the stockpile using alternative technologies. There will, however, always be some munitions that need to be treated by OB/OD for safety reasons.
Recommendation 7-1. In keeping with stated strategic goal to increase the use of contained disposal, resource recovery, and recycling consistent with continuing to ensure minimal exposure of personnel to explosive safety risks, the Office of the Product Director for Demilitarization should perform a detailed technical and engineering evaluation of the munitions in the inventory currently demilitarized by open burning or open detonation and evaluate appropriate alternative demilitarization technologies for each munition along with an implementation schedule and budget requirements. This detailed evaluation should include the option of shipping munitions and munitions components to other organic or contractor facilities for demilitarization.
Finding 8-1. Each of the alternative technologies that the committee evaluated as potential replacements for OB and OD would have lower emissions and less of an environmental and public health impact, would be monitorable, and would likely be more acceptable to the public.
Finding 8-2. Throughput capacity for OB/OD and alternative technologies is dependent on many factors, some of which may offset each other. These factors include the capability of the treatment technology, the characteristics of the munition or munition component being treated, and permit restrictions.
Finding 8-3. Most of the alternative technologies that could replace OB/OD are mature and many have already been permitted.
Finding 8-4. The alternative technologies that could replace OB/OD could pose either more or less risk to personnel depending on the munition and on the extent to which munitions handling is required. The safety approvals currently required by the Department of Defense Explosives Safety Board for both OB/OD and CB and CD and their associated demilitarization processes are adequate to minimize explosive accidents and injuries.
Finding 8-5. Hold-test-release capability is neither necessary nor appropriate for technologies treating conventional munitions and associated wastes because of the difference in acute toxicity between chemical warfare agents and the components of conventional munitions.
Finding 8-6. The committee requested but was unable to obtain sufficient data to draw general conclusions regarding the relative life cycle costs of OB and OD and the alternative technologies, although the capital (startup) costs of the alternatives will likely be higher while the costs of environmental monitoring and closure will likely be lower. Operating costs of the alternatives appear to vary widely and in some cases may be competitive with OB/OD.
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.
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.
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 Reclamation, Recycling, and Reuse, but they do not set quantitative end points or time tables.
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.
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.