EXPLOSIVE DESTRUCTION TECHNOLOGY

INVOLVEMENT HISTORY OF THE THE CITIZENS ADVISORY COMMISSION /

CITIZENS ADVISORY BOARD

Presented byCraig Williams, Chair

Explosive Destruction Technology Working GroupCitizens Advisory Board

16 July 2013

• 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)

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.

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).

ANCDF DPE

ANCDF Demilitarizat

ion Protective

Ensemble

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Why ANCDF needs EDTProcess 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

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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, andSecondary waste issues.

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.

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)

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:

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.”

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.

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-ChairKentucky Chemical Destruction Citizens Advisory Board

Craig Williams, Co-Chair

Kentucky Chemical Destruction Citizens Advisory Board

Thank You