The document summarizes the history and work of the Explosive Destruction Technology Working Group, which consists of members from various government and private organizations involved in the chemical weapons disposal process. It describes several key meetings where the group discussed using explosive destruction technology (EDT) to dispose of mustard munitions at Blue Grass Army Depot that were difficult to process through incineration. While the group did not endorse a specific EDT, they provided recommendations to consider EDTs if regulatory requirements and public involvement were met.
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EDT Involvement History of the Citizens' Advisory Commission/Citizens' Advisory Board 16 July 2013
1. EXPLOSIVE DESTRUCTION TECHNOLOGY
INVOLVEMENT HISTORY OF THE
THE CITIZENS ADVISORY COMMISSION /
CITIZENS ADVISORY BOARD
Presented by
Craig Williams, Chair
Explosive Destruction Technology Working Group
Citizens Advisory Board
16 July 2013
2. • The Explosive Destruction Technology (EDT) Working Group (WG) held its
first meeting on 6 May 2009
• The EDT WG consists of members of:
- The Chemical Demilitarization Citizens Advisory Commission (CAC)
- The Chemical Destruction Citizens Advisory Board (CDCAB)
- The Assembled Chemical Weapons Alternatives (ACWA)
- The systems contractor Bechtel/Parsons Blue Grass (BPBG)
- The Kentucky Department of Environmental Protection (KDEP)
- Washington Demilitarization Company (WDC)
- Booz Allen Hamilton (now IEM)
- Blue Grass Army Depot (BGAD)
- Madison County Emergency Management (CSEPP)
3. EDWG MEETINGS OF PARTICULAR NOTE
The 6 May 2009 “kickoff meeting” provided the EDT WG background
information on the basis for considering possible EDT deployment at Blue
Grass to handle Mustard munitions. There were four major issues that
created the basis for
the EDT consideration:
1) Identical manufacturing lots of “H” munitions are stored at the Blue Grass Chemical
Activity (BGCA) as are/were stored at the Utah location. These rounds discovered to
be difficult, if not impossible to process through the baseline incineration facility
without repeated manual intervention.
2) Repeated manual intervention created an unacceptable avoidable risk to the
workforce if there was a viable alternative in Kentucky.
3) Even a substantial number of rounds that were able to be disassembled robotically
contained high levels of solidified “H”, difficult to drain for processing.
4) Predictions associated with trying to accommodate “H” processing through the Blue
Grass Chemical Agent Pilot Plant (BGCAPP) would add an undetermined increase to
the overall schedule to eliminate the stockpile.
4. 155 mm Projectile
In Utah, it took 3 "hot" entries to
process each "reject" (a munition
that could not be disassembled
without manual intervention - i.e.
workers in "moon suits" with
hand tools to disassemble the
projectile). Here, it's estimated
that upwards of 6000 rounds
might require such intervention (>
59% heel). If we do the math,
assuming it's only 25% of the
estimated 6000, or 1,500. And
assume it takes only two entries
per munition. That would
require 3,000 hot entries - each
of which is a risky proposition.
That is what the CDCAB is
referring to saying "avoidable” in
our 2012 Recommendation
(Position # 1).
6. Why ANCDF needs EDT
Process munitions that are not amenable to reverse disassembly
These photos are of a 155mm mustard projectile where a cavity cut has
been performed to attempt to remove the Burster and Bursterwell. The
Bursterwell broke approximately in half leaving the fully intact Burster
inside the agent cavity.
TOCDF Photo of Half Burster Round
4
7. The 2 June 2009 meeting was attended but the EDT WG in addition to the
authors of the National Research Council (NRC) report entitled, Assessment of
Explosive Destruction Technologies for Specific Munitions at the Blue Grass
and Pueblo Chemical Agent Destruction Pilot Plants.
Representing the NRC EDT Review Committee were its chair, Dr. Richard
Ayen, and the Committee’s Vice-Chair, Mr. Douglas Medvile.
The Report looked at the four EDT’s under consideration.
The NRC Report looked at the following criteria:
Process maturity,
Process efficacy,
Process throughput,
Process safety,
Public and regulatory acceptability in a U.S. context, and
Secondary waste issues.
8. The result of the Report regarding the comparison of EDT’s against the
identified criteria was –
Recommendation 4-3. The Army should give preference to the use of the
DAVINCH DV65 or the Dynasafe SDC2000 for the destruction of 15,000
mustard-filled projectiles at BGCAPP. The TC-60 TDC is rated lower but would
also be acceptable. *
* It should be noted that the EDT WG and the CDCAB will NOT be
recommending a specific EDT to be deployed should the decision be to use
such. The value of the 2 June meeting was to garner an understanding of the
EDT process, capabilities and possible shortcomings as the CDCAB moved
towards making a recommendation on whether or not EDT should or should
not be deployed here for “H” munitions destruction.
9. The EDT WG met again on 30 November 2009
- Included a review and discussion of the Evaluation Criteria used in
Anniston, Alabama for the selection of an EDT there.
- Included a review and discussion of the Environmental Assessment and the
“Finding of No Significant Impact” (FNSI) for EDT at the Alabama site.
- The importance of the EDT Working Group having timely access to
performance data from EDT’s deployed at ANCDF, TOCDF and elsewhere.
- Assuming an EDT will be deployed for some element of the overall mission,
the EDT WG and the CAC/CDCAB should not endorse any particular EDT,
but rather identify what criteria points should weigh most heavily in the
selection process (i.e. cost vs. safety)
10. Additional EDT WG meetings were held in 2010-2012 that discussed various
technical and permitting issues associated with various EDTs.
Additionally, operational data from EDT operations in Alabama and
Colorado’s NEPA permitting process were discussed.
Additionally, draft KY EDT WG recommendations to ACWA were drafted,
reviewed by the WG and ultimately forwarded to the CAC/CDCAB for review
and input.
The final recommendation was provided ACWA on 31 January 2012.
The Recommendation reads as follows:
11. Positions:
1) The KY CAC/CDCAB recognizes that the results of the X-ray Assessment of
the Mustard munitions at the BGCA reflects an extremely high probability
that attempting to process these munitions in the BGCAPP facility would likely
result in repeated and avoidable risks to the workforce; inhibit accelerated
disposal of the Kentucky stockpile; and, put Kentucky further behind in our
international commitments within the context of the Chemical Weapons
Convention.
2) The KY CAC/CDCAB believes the deployment and use of the EDT at the
Anniston Chemical Demilitarization Facility (ANCDF) fulfills many of the
requirements of KRS 224.50-130 (3) (a)). However, there remain questions
concerning whether the experience at Anniston sufficiently demonstrates the
ability to meet the following requirement within the section: “During the
occurrence of malfunctions, upsets, or unplanned shutdown, all quantities of
any compound listed in subsection (2) of this section shall be contained,
reprocessed or otherwise controlled so as to ensure that the required
efficiency is attained prior to any release to the environment.”
12. 3) The KY CAC/CDCAB, in concert with other stakeholders, wishes to see a
continuous investigation of the “hold-test-release” capabilities of potential
agent emissions with any EDT considered for the Blue Grass disposal effort,
while recognizing that such investigations should not be allowed to
significantly impact EDT deployment.
4) The KY CAC/CDCAB unequivocally opposes the use of any EDT or EDS
(Explosive Destruction System) for the processing of nerve agent munitions or
nerve agent contaminated materials associated with the Blue Grass stockpile.
5) The KY CAC/CDCAB does not believe the EDS should be considered for
deployment at BGAD for disposal of any of the stockpile.
6) Permitting compliance issues associated with EDT at BGAD need to
continue to be brought forward by ACWA, KDEP and BGAD in a timely
manner, even beyond what is required by law, to ensure adequate public
involvement in the permitting process.
13. 7) Compliance with, and public involvement in, the National Environmental Policy Act
(NEPA) shall be attained prior to procurement of any EDT for Blue Grass.
8) The KY CAC/CDCAB recognizes the potential benefit of an EDT for its legacy
capability in the ongoing mission of the Blue Grass Army Depot’s conventional
weapons activities once the chemical weapons disposal mission is completed.
Recommendation:
The KY CAC/CDCAB recommends the use of an EDT system to dispose of mustard
munitions at BGAD assuming the areas of compliance identified above are met.
Signed:
Dr. Douglas Hindman, Chair
Kentucky Chemical Demilitarization Citizens Advisory Commission
Kent Clark, Co-Chair
Kentucky Chemical Destruction Citizens Advisory Board
Craig Williams, Co-Chair
Kentucky Chemical Destruction Citizens Advisory Board