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18 September 2013
Boone, CO
FINAL – OPSEC/ITAR REVIEW - 12 SEP 2013
Citizens’ Advisory
Commission Meeting
Operational Readiness
Review (ORR)
The Road to Initial Agent Operations
Presented by:
Paul Dent, PCAPP ORR Manager
Timeline - ORR
3
Briefing Objective
Provide an overview of the PCAPP Operational
Readiness Review (ORR) process and the
incremental approach to be used to assess
readiness for Initial Agent Operations (IAO)
4
Operational Readiness Review Overview
 The ORR process is used to
validate that PCAPP “plant, paper,
and people” collectively meet the
required criteria to allow a new
operation to begin.
 PCAPP ORR process is led by the
system-contractor (SC) to
support a declaration of
readiness.
 ACWA provides ORR oversight;
independent validation is used to
support the SC’s declaration of
readiness.
 Stakeholders may observe the
ORR process.
5
People
PlantPaper
Achieve Readiness – by Responsible Managers
Validate Readiness – by ORR Board
Declare Readiness – by Project Manager
Accept Readiness – by ACWA
ORR Overview
6
People Readiness
Paper Readiness
Plant Readiness
Ready for Agent Operations
Government Review and Concurrence
SPM ACWA concurrence
with BNI ORR
BPT declares readiness
for agent operations
The ORR process validates that
PCAPP plant, paper, and people
collectively meet the required
criteria to allow agent-
operations to begin.
System Start-up, Testing, and
Turnover to Operations
System Start-up, Testing, and
Turnover to Operations
Approve Permits,
Plans, Procedures,
Classes
Certify, Drill,
Optimize
IOD
Integrated Operations
Demonstration (IOD)
Readiness
The goal of Systemization is to achieve readiness for
Initial Agent Operations.
Stages of an ORR
Planning:
 Define Scope of ORR in an Implementing Procedure using Performance
Objectives and Criteria (PO&Cs)
 Identify Responsible Managers and pool of Independent Reviewers
 Charter the ORR Board
Execution:
 Responsible Managers define how readiness is achieved using affidavits
 Independent reviewers conduct interviews, review documents, and
observe field work to assess the degree of compliance with readiness
requirements
 ORR Board reviews documentation to assess readiness
 “Punchlist items” are defined as findings and tracked to closure
 Usually ends after an Integrated Operations Demonstration (IOD) to
exercise and assess plant, paper, and people functioning together
7
ORR Planning
PO&Cs are requirements for readiness, defined in cascading levels of detail
 Derived from contract defined requirements, such as:
• Safety/environmental regulations (e.g., OSHA, RCRA, CAA)
• Army regulations and guidance (e.g., AR 50-6, DA PAM 385-61)
• Industry standards (e.g., ANSI, NFPA)
 Developed by responsible managers and the ORR Team
 Reviewed by ACWA and stakeholders
 Approved by issuance of an ORR implementing procedure
8
Criterion 1.1
Criterion 1.2
Criterion 1.3
Criterion 1.4
Criterion 1.5
Criterion 1.6
Criterion 2.1
Criterion 2.2
Criterion 2.3
Criterion 2.4
Functional Area (by Responsible Manager)
Performance
Objective 1.0
Performance
Objective 2.0
Develop Performance Objectives and Criteria (PO&Cs)
Level 3 Criterion
A specific statement describing an element of readiness
within a performance objective (e.g., “A process is in
place to notify key treaty personnel when applying or
removing treaty seals, to track treaty sealing information,
and protocols are established for treaty seal application
and removal. Treaty seals have been applied to the
agreed upon doors/areas/equipment.“)
Level 2 Performance Objectives (POs)
A statement describing an aspect or area of readiness
within a functional area (e.g., “Treaty requirements are in
place for initial agent operations.“)
Level 1 Functional Areas
Typically follow organizational lines (e.g., Safety, Lab)
ORR Overview – Process
9
Board accepts
affidavit?
NO
Responsible manager
completes affidavit
Board reviews CRAD
Finding Categories
Assigned by Board
Responsible manager
completes actions
required to correct
deficiency
Finding closed?
NO
YES
IR evaluates criteria
and affidavit
Board chartered
Functional areas defined
Board reviews
affidavit
Requirements defined
Independent reviewers
(IRs) selected
IR completes CRAD
Affidavit and CRAD
packages finalized,
archived for report
Board accepts
CRAD?
YES
NO
YES
Criterion met?
Finding(s) generated or
approved to address
identified deficiencies
NO
Readiness Planning Stage
Board reviews
corrective actions and
finding closure
document
All criteria
met, all
CAT1
findings
closed, final
report
completed
DeclarationofReadiness
Finding closure approved
by the Board, archived
for report
YES
LORR Execution Stage (Single Criterion)
Finding categories
assigned by ORR Board
Performance objectives &
criteria developed
Key Readiness
Milestones
COMPLETE
IN PROGRESS
NOT STARTED
2. Lab Stock A Dilute Agent Operations
1. Boiler Ignition Readiness
13. Readiness Declared for
Initial Agent Operations
14. ACWA Readiness
Endorsement
6. ERB Provisional Operations
5. Yard Provisional Operations
7. BTA Provisional Operations
8. APB Provisional Operations
10. Soft Plant Lockdown
12. Integrated Operations
Demonstrations
11. Environmental Readiness
9. Crew Certifications
4. Agent Controls Readiness
1
8
9
6
5
4
2
7
11
12
13
14
3
3. Training Facility Integrated Assessment
10
ACRONYMS:
APB – Agent Processing Building
BTA – Biotreatment Area
ERB – Enhanced Reconfiguration Bldg.
IAO – Initial Agent Operations
ORR – Operational Readiness Review
RA – Readiness Assessment
Major Milestones for Initial Agent
Operations (IAO) Readiness
10
Initial Agent Operations
(IAO) Criteria
11
by Functional Area
Number of criteria subject to change through
implementing procedure review process
Integrated Operations
Demonstrations (IOD)
Near the end of ORR, integrated operations demonstrations (IODs)
are performed to validate that people, plant, and paper are ready for
initial agent operations.
IODs include exercises such as:
 Receive, transfer, and process munitions
 Handle, transfer, and process simulated agent-contaminated waste
 Perform toxic area entries; perform maintenance for critical equipment
 Sample tanks/perform laboratory analysis
 Perform treaty sampling
 Respond to contingencies or equipment upset conditions
Upon successful completion of IODs and closeout of
required Findings, SC will declare readiness.
Upon receipt of an endorsement of readiness
by ACWA, PCAPP will be poised to begin Pilot Testing.
12
13
QUESTIONS
An Overview of PCAPP’s
Pilot Demonstration Testing
Presented by:
Kim Jackson, PCAPP Operations Manager &
George Lecakes, PCAPP Chief Scientist
Timeline –
Pilot Test Demonstration
15
PCAPP Pilot Test Demonstration
Objectives1
1. Demonstrate agent removal, agent neutralization, and related agent
neutralization sampling and analysis.
2. Demonstrate munition body treatment (washout, thermal treatment).
3. Establish bounding operating ranges and set points for operating
parameters critical to agent removal, munition body treatment, and agent
neutralization operations.
4. Demonstrate energetics removal and establish bounding operating ranges
and set points for operating parameters critical to ensuring energetics
removal operations.
5. Validate monitoring protocols for all equipment and work areas in the ERB
and APB.
6. Validate treatment and monitoring protocols for disposition of dunnage,
energetics, and miscellaneous waste (e.g., OPP, PME, SDU, Autoclave as
designated for each waste material)
7. Demonstrate removal of TDG and document removal of other organic
compounds from hydrolysate waste stream (e.g., ICB, BRS)
8. Demonstrate processing systems can operate at a ramp rate that safely
supports the operating schedule.
1DERIVED FROM THE TEST CONCEPT PLAN, APPENDIX D; 3/21/2011
16
PCAPP Pilot Test Demonstration
Objectives (CONT.)
9. Demonstrate integrated facility operations with agent and energetics to verify
the following:
a) Compliance with safety requirements
b) Compliance with surety and security requirements
c) Integrated system operability
d) Plant-wide operations while remaining within emissions requirements (as stated in the Multiple
Pathway Health Risk Assessment Report for PCAPP Project [MPHRA], 24852-RD-3RC-000-V0004)
e) Handling and movement of munitions for current munitions campaign
f) Sampling and analysis protocols (e.g., agent, hydrolysate, brine, emissions)
g) Decontamination operations
h) Ability to perform routine and selected off-normal maintenance activities
i) Waste handling and disposition, including dust and odor control
10.Validate agent monitoring protocols for detecting agent (e.g., MINICAMS, Depot
Area Air Monitoring System [DAAMS]).
11.Demonstrate off-gas treatment performance. This will include demonstration of
agent destruction and removal at the OTS and AFA, odor control at the BTA.
17
Finally, the collection of site-wide emissions data for
finalization of the RCRA Part B Permit
Block 1 –
Systems, Fit, and Function
18
Systems: Block 1 – Baseline and Enhanced Reconfiguration includes OPP Monitoring, Munitions Monitoring
Table (Baseline Reconfiguration), PMD Operations and MME/PME Operations
Fit: After transport and receipt of munitions at PCAPP and prior to agent removal activities
Function: Prepares munitions for access and removal of agent by separating packing material (e.g., wooden
pallets, strapping, boxes) and energetics/miscellaneous parts from the munitions bodies
Explosion Containment
Room
MWS
MTU
Block 2 –
Systems, Fit, and Function
Systems: Block 2 – Munitions Body Treatment includes Munitions Washout System (MWS) and Munitions
Treatment Unit (MTU)
Fit: After Baseline and Enhanced Reconfiguration and prior to Agent Collection and Neutralization
Function: Drains and washes agent from energetics-free munitions bodies and thermally treats munitions
bodies to Clean Unrestricted, Releasable to the General Population (Clean Unrestricted)
19
Block 3 –
Systems, Fit, and Function
20
Systems: Block 3 – Agent Collection and Neutralization includes the Agent Water Separators, Wash Water Holding
Tanks, Agent Hydrolyzers, Hydrolysate Hold Tanks and 30-Day Storage Tanks
Fit: After Agent Collection and prior to Bio-Treatment of the cleared hydrolysate
Function: Separates the MWS agent drained and rinse water, hydrolyzes the mustard agent, and verifies destruction
prior to treatment in the Immobilized Cell Bio Reactors
Block 4 –
Systems, Fit, and Function
21
Systems: Block 4 – Hydrolysate Treatment and Water Recovery includes the Bio-Treatment System, Water Recovery
System (Brine Concentrate Feed Tanks), and the Brine Reduction System plus associated off-gas treatment units
Fit: After agent neutralization and clearing in Block 3 and prior to process water recycle or to off-site shipment of
secondary wastes (salt cake / bio sludge)
Function: Removes thiodiglycol (TDG) and other organics through biodegradation, recovers process water, de-
waters sludge for disposal and treats off-gasses for discharge.
Block 5 –
Systems, Fit, and Function
Systems: Block 5 – Supplemental Decon Units and Autoclave
Fit: Receives materials, equipment, components, and waste materials from other process areas including ERB, APB,
ESM, MSM.
Function: Reduces agent contamination levels to acceptable levels for either reuse and/or off-site disposal
22
Block 6 –
Systems, Fit, and Function
23
Systems: Block 6 – Off-gas treatment system including thermal oxidizer and scrubbers, the agent filtration area
(including particulate & HEPA filtration, granulated activated carbon and sulfur impregnated carbon) and the AFA stack
Fit: Receives process off-gas from the OTS and HVAC exhaust from ERB and APB ventilation systems
Function: Treat process off-gasses and HVAC exhaust from engineering controlled spaces to remove agent and other
COC’s to prescribed levels before releasing to the atmosphere.
Process Layout by Blocks
PCAPP PROCESS DIAGRAM
24
EDT REMOVED FROM PCAPP SCOPE
CONTAMINATED ENERGETICS AND IN-PROCESS LEAKERS &
REJECTS SENT TO G-BLOCK FOR SUBSEQUENT PROCESSING
IN A GOVERNMENT SYSTEM
Test Sequence
Pilot Testing (155mm)
 Block 1
 Block 2
 Block 3
 Block 4
 Block 5
 Block 6
Changeover Testing
 105mm Campaign
 4.2in Campaign
• Testing ≡ to define optimized
operating parameters
• Ramp-up ≡ capability of
personnel and equipment to
sustain operations
• Demonstration ≡ capability
of each process system
within the facility to process
munitions for 4-hour periods
per shift
Block 1 – Munitions Receipt and Enhanced Reconfiguration is to
support the testing, ramp-up and demonstration of the other
systems within Blocks 2, 3, 4 and 6.
Block 5 – Secondary Waste Treatment
Operating
Permit
INTEGRATED FACILITY DEMONSTRATION TEST
• Emissions Sampling
25
26
QUESTIONS

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CAC Meeting 18 September 2013

  • 1. 18 September 2013 Boone, CO FINAL – OPSEC/ITAR REVIEW - 12 SEP 2013 Citizens’ Advisory Commission Meeting
  • 2. Operational Readiness Review (ORR) The Road to Initial Agent Operations Presented by: Paul Dent, PCAPP ORR Manager
  • 4. Briefing Objective Provide an overview of the PCAPP Operational Readiness Review (ORR) process and the incremental approach to be used to assess readiness for Initial Agent Operations (IAO) 4
  • 5. Operational Readiness Review Overview  The ORR process is used to validate that PCAPP “plant, paper, and people” collectively meet the required criteria to allow a new operation to begin.  PCAPP ORR process is led by the system-contractor (SC) to support a declaration of readiness.  ACWA provides ORR oversight; independent validation is used to support the SC’s declaration of readiness.  Stakeholders may observe the ORR process. 5 People PlantPaper Achieve Readiness – by Responsible Managers Validate Readiness – by ORR Board Declare Readiness – by Project Manager Accept Readiness – by ACWA
  • 6. ORR Overview 6 People Readiness Paper Readiness Plant Readiness Ready for Agent Operations Government Review and Concurrence SPM ACWA concurrence with BNI ORR BPT declares readiness for agent operations The ORR process validates that PCAPP plant, paper, and people collectively meet the required criteria to allow agent- operations to begin. System Start-up, Testing, and Turnover to Operations System Start-up, Testing, and Turnover to Operations Approve Permits, Plans, Procedures, Classes Certify, Drill, Optimize IOD Integrated Operations Demonstration (IOD) Readiness The goal of Systemization is to achieve readiness for Initial Agent Operations.
  • 7. Stages of an ORR Planning:  Define Scope of ORR in an Implementing Procedure using Performance Objectives and Criteria (PO&Cs)  Identify Responsible Managers and pool of Independent Reviewers  Charter the ORR Board Execution:  Responsible Managers define how readiness is achieved using affidavits  Independent reviewers conduct interviews, review documents, and observe field work to assess the degree of compliance with readiness requirements  ORR Board reviews documentation to assess readiness  “Punchlist items” are defined as findings and tracked to closure  Usually ends after an Integrated Operations Demonstration (IOD) to exercise and assess plant, paper, and people functioning together 7
  • 8. ORR Planning PO&Cs are requirements for readiness, defined in cascading levels of detail  Derived from contract defined requirements, such as: • Safety/environmental regulations (e.g., OSHA, RCRA, CAA) • Army regulations and guidance (e.g., AR 50-6, DA PAM 385-61) • Industry standards (e.g., ANSI, NFPA)  Developed by responsible managers and the ORR Team  Reviewed by ACWA and stakeholders  Approved by issuance of an ORR implementing procedure 8 Criterion 1.1 Criterion 1.2 Criterion 1.3 Criterion 1.4 Criterion 1.5 Criterion 1.6 Criterion 2.1 Criterion 2.2 Criterion 2.3 Criterion 2.4 Functional Area (by Responsible Manager) Performance Objective 1.0 Performance Objective 2.0 Develop Performance Objectives and Criteria (PO&Cs) Level 3 Criterion A specific statement describing an element of readiness within a performance objective (e.g., “A process is in place to notify key treaty personnel when applying or removing treaty seals, to track treaty sealing information, and protocols are established for treaty seal application and removal. Treaty seals have been applied to the agreed upon doors/areas/equipment.“) Level 2 Performance Objectives (POs) A statement describing an aspect or area of readiness within a functional area (e.g., “Treaty requirements are in place for initial agent operations.“) Level 1 Functional Areas Typically follow organizational lines (e.g., Safety, Lab)
  • 9. ORR Overview – Process 9 Board accepts affidavit? NO Responsible manager completes affidavit Board reviews CRAD Finding Categories Assigned by Board Responsible manager completes actions required to correct deficiency Finding closed? NO YES IR evaluates criteria and affidavit Board chartered Functional areas defined Board reviews affidavit Requirements defined Independent reviewers (IRs) selected IR completes CRAD Affidavit and CRAD packages finalized, archived for report Board accepts CRAD? YES NO YES Criterion met? Finding(s) generated or approved to address identified deficiencies NO Readiness Planning Stage Board reviews corrective actions and finding closure document All criteria met, all CAT1 findings closed, final report completed DeclarationofReadiness Finding closure approved by the Board, archived for report YES LORR Execution Stage (Single Criterion) Finding categories assigned by ORR Board Performance objectives & criteria developed
  • 10. Key Readiness Milestones COMPLETE IN PROGRESS NOT STARTED 2. Lab Stock A Dilute Agent Operations 1. Boiler Ignition Readiness 13. Readiness Declared for Initial Agent Operations 14. ACWA Readiness Endorsement 6. ERB Provisional Operations 5. Yard Provisional Operations 7. BTA Provisional Operations 8. APB Provisional Operations 10. Soft Plant Lockdown 12. Integrated Operations Demonstrations 11. Environmental Readiness 9. Crew Certifications 4. Agent Controls Readiness 1 8 9 6 5 4 2 7 11 12 13 14 3 3. Training Facility Integrated Assessment 10 ACRONYMS: APB – Agent Processing Building BTA – Biotreatment Area ERB – Enhanced Reconfiguration Bldg. IAO – Initial Agent Operations ORR – Operational Readiness Review RA – Readiness Assessment Major Milestones for Initial Agent Operations (IAO) Readiness 10
  • 11. Initial Agent Operations (IAO) Criteria 11 by Functional Area Number of criteria subject to change through implementing procedure review process
  • 12. Integrated Operations Demonstrations (IOD) Near the end of ORR, integrated operations demonstrations (IODs) are performed to validate that people, plant, and paper are ready for initial agent operations. IODs include exercises such as:  Receive, transfer, and process munitions  Handle, transfer, and process simulated agent-contaminated waste  Perform toxic area entries; perform maintenance for critical equipment  Sample tanks/perform laboratory analysis  Perform treaty sampling  Respond to contingencies or equipment upset conditions Upon successful completion of IODs and closeout of required Findings, SC will declare readiness. Upon receipt of an endorsement of readiness by ACWA, PCAPP will be poised to begin Pilot Testing. 12
  • 14. An Overview of PCAPP’s Pilot Demonstration Testing Presented by: Kim Jackson, PCAPP Operations Manager & George Lecakes, PCAPP Chief Scientist
  • 15. Timeline – Pilot Test Demonstration 15
  • 16. PCAPP Pilot Test Demonstration Objectives1 1. Demonstrate agent removal, agent neutralization, and related agent neutralization sampling and analysis. 2. Demonstrate munition body treatment (washout, thermal treatment). 3. Establish bounding operating ranges and set points for operating parameters critical to agent removal, munition body treatment, and agent neutralization operations. 4. Demonstrate energetics removal and establish bounding operating ranges and set points for operating parameters critical to ensuring energetics removal operations. 5. Validate monitoring protocols for all equipment and work areas in the ERB and APB. 6. Validate treatment and monitoring protocols for disposition of dunnage, energetics, and miscellaneous waste (e.g., OPP, PME, SDU, Autoclave as designated for each waste material) 7. Demonstrate removal of TDG and document removal of other organic compounds from hydrolysate waste stream (e.g., ICB, BRS) 8. Demonstrate processing systems can operate at a ramp rate that safely supports the operating schedule. 1DERIVED FROM THE TEST CONCEPT PLAN, APPENDIX D; 3/21/2011 16
  • 17. PCAPP Pilot Test Demonstration Objectives (CONT.) 9. Demonstrate integrated facility operations with agent and energetics to verify the following: a) Compliance with safety requirements b) Compliance with surety and security requirements c) Integrated system operability d) Plant-wide operations while remaining within emissions requirements (as stated in the Multiple Pathway Health Risk Assessment Report for PCAPP Project [MPHRA], 24852-RD-3RC-000-V0004) e) Handling and movement of munitions for current munitions campaign f) Sampling and analysis protocols (e.g., agent, hydrolysate, brine, emissions) g) Decontamination operations h) Ability to perform routine and selected off-normal maintenance activities i) Waste handling and disposition, including dust and odor control 10.Validate agent monitoring protocols for detecting agent (e.g., MINICAMS, Depot Area Air Monitoring System [DAAMS]). 11.Demonstrate off-gas treatment performance. This will include demonstration of agent destruction and removal at the OTS and AFA, odor control at the BTA. 17 Finally, the collection of site-wide emissions data for finalization of the RCRA Part B Permit
  • 18. Block 1 – Systems, Fit, and Function 18 Systems: Block 1 – Baseline and Enhanced Reconfiguration includes OPP Monitoring, Munitions Monitoring Table (Baseline Reconfiguration), PMD Operations and MME/PME Operations Fit: After transport and receipt of munitions at PCAPP and prior to agent removal activities Function: Prepares munitions for access and removal of agent by separating packing material (e.g., wooden pallets, strapping, boxes) and energetics/miscellaneous parts from the munitions bodies Explosion Containment Room
  • 19. MWS MTU Block 2 – Systems, Fit, and Function Systems: Block 2 – Munitions Body Treatment includes Munitions Washout System (MWS) and Munitions Treatment Unit (MTU) Fit: After Baseline and Enhanced Reconfiguration and prior to Agent Collection and Neutralization Function: Drains and washes agent from energetics-free munitions bodies and thermally treats munitions bodies to Clean Unrestricted, Releasable to the General Population (Clean Unrestricted) 19
  • 20. Block 3 – Systems, Fit, and Function 20 Systems: Block 3 – Agent Collection and Neutralization includes the Agent Water Separators, Wash Water Holding Tanks, Agent Hydrolyzers, Hydrolysate Hold Tanks and 30-Day Storage Tanks Fit: After Agent Collection and prior to Bio-Treatment of the cleared hydrolysate Function: Separates the MWS agent drained and rinse water, hydrolyzes the mustard agent, and verifies destruction prior to treatment in the Immobilized Cell Bio Reactors
  • 21. Block 4 – Systems, Fit, and Function 21 Systems: Block 4 – Hydrolysate Treatment and Water Recovery includes the Bio-Treatment System, Water Recovery System (Brine Concentrate Feed Tanks), and the Brine Reduction System plus associated off-gas treatment units Fit: After agent neutralization and clearing in Block 3 and prior to process water recycle or to off-site shipment of secondary wastes (salt cake / bio sludge) Function: Removes thiodiglycol (TDG) and other organics through biodegradation, recovers process water, de- waters sludge for disposal and treats off-gasses for discharge.
  • 22. Block 5 – Systems, Fit, and Function Systems: Block 5 – Supplemental Decon Units and Autoclave Fit: Receives materials, equipment, components, and waste materials from other process areas including ERB, APB, ESM, MSM. Function: Reduces agent contamination levels to acceptable levels for either reuse and/or off-site disposal 22
  • 23. Block 6 – Systems, Fit, and Function 23 Systems: Block 6 – Off-gas treatment system including thermal oxidizer and scrubbers, the agent filtration area (including particulate & HEPA filtration, granulated activated carbon and sulfur impregnated carbon) and the AFA stack Fit: Receives process off-gas from the OTS and HVAC exhaust from ERB and APB ventilation systems Function: Treat process off-gasses and HVAC exhaust from engineering controlled spaces to remove agent and other COC’s to prescribed levels before releasing to the atmosphere.
  • 24. Process Layout by Blocks PCAPP PROCESS DIAGRAM 24 EDT REMOVED FROM PCAPP SCOPE CONTAMINATED ENERGETICS AND IN-PROCESS LEAKERS & REJECTS SENT TO G-BLOCK FOR SUBSEQUENT PROCESSING IN A GOVERNMENT SYSTEM
  • 25. Test Sequence Pilot Testing (155mm)  Block 1  Block 2  Block 3  Block 4  Block 5  Block 6 Changeover Testing  105mm Campaign  4.2in Campaign • Testing ≡ to define optimized operating parameters • Ramp-up ≡ capability of personnel and equipment to sustain operations • Demonstration ≡ capability of each process system within the facility to process munitions for 4-hour periods per shift Block 1 – Munitions Receipt and Enhanced Reconfiguration is to support the testing, ramp-up and demonstration of the other systems within Blocks 2, 3, 4 and 6. Block 5 – Secondary Waste Treatment Operating Permit INTEGRATED FACILITY DEMONSTRATION TEST • Emissions Sampling 25

Hinweis der Redaktion

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