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Public Meeting for Class 3 Permit
Modification Request to Kentucky
Department for Environmental
Protection (KDEP) to add
Explosive Destruction Technology
(EDT) to BGAD RCRA Hazardous
Waste Permit
Date:
April 14, 2014
Presented by:
Allison Respess,
Bechtel Parsons Blue Grass,
Assistant Project Manager
A Partnership for Safe Chemical Weapons Destruction
ACWA’s Chemical Demilitarization
Mission
2
The safe and environmentally sound destruction of the chemical weapons stockpiles
stored at the Blue Grass Army Depot, Ky., and the U.S. Army Pueblo Chemical Depot, Colo.
A Partnership for Safe Chemical Weapons Destruction
3
Blue Grass Mission
 The Blue Grass mission is to safely
and efficiently destroy the chemical
weapons stored at the Blue Grass Army
Depot in Richmond, Ky.
 The U.S. Department of Defense’s
Program Executive Office, Assembled
Chemical Weapons Alternatives
(ACWA) manages all aspects of the
chemical weapons destruction program
for both Kentucky and Colorado
 Bechtel Parsons Blue Grass is under
contract to ACWA for the design,
construction, systemization, operations
and closure work at Blue Grass
Igloos at the depot store both conventional and
chemical weapons, and other non-stockpile items.
Chemical weapons such as these M55 rockets are
stored at and monitored by the Blue Grass Chemical
Activity.
A Partnership for Safe Chemical Weapons Destruction
4
Role as the systems contractor
 Bechtel Parsons Blue Grass is the systems contractor
responsible for design, construction, systemization, operations
and closure which includes:
– Main neutralization/supercritical water oxidation pilot plant
– Explosive Destruction Technology (EDT) system
A Partnership for Safe Chemical Weapons Destruction
BGCAPP Operational Philosophy
5
•Protect the workforce, public and environment
•Minimize or eliminate human interface with weapons
•Minimize or eliminate additional waste streams
BGCAPP Operational Philosophy
A Partnership for Safe Chemical Weapons Destruction
M110 155mm H-filled Projectile
(In 1943) (Today)
6
Blue Grass Mustard (H) Projectiles
 Mustard filled projectiles are the oldest
component of the Blue Grass Army Depot
(BGAD) stockpile
 Manufactured between 1941 and 1943 at
Edgewood Arsenal (EA), Md., today part
of Aberdeen Proving Ground
 Mustard filled projectiles are the only
projectiles at BGAD that have an
explosive charge referred to as a burster
 Mustard M110 155mm Projectiles
– Agent Type: Levinstein Mustard
– Burster Explosive: Tetrytol
– Percentage of Munition Inventory: 15.2 percent
– Percentage of Agent Inventory: 17.3 percent
A Partnership for Safe Chemical Weapons Destruction
Background: Problematic Mustard
Projectiles
7
 Problems processing mustard-agent filled 155mm projectiles at the
Tooele Chemical Agent Disposal Facility (TOCDF) led the ACWA
program to request the National Research Council to conduct an
assessment to analyze Explosive Destruction Technology (EDT) use
at Blue Grass and Pueblo
– Tooele projectiles had a high rate of agent solidification, which complicates
removal of the mustard agent from the projectile; and stuck bursters,
which require human interaction to remove the explosives from the
problematic munitions
– Blue Grass has a high number of same-lot problematic munitions as Tooele
(20 of the 31 Edgewood Arsenal lot numbers are common to both sites)
 ACWA worked closely with the U.S. Army Chemical Materials
Activity to incorporate lessons learned from processing problematic
mustard projectiles at TOCDF
A Partnership for Safe Chemical Weapons Destruction
Background: Problematic Mustard
Projectiles (cont’d)
8
Corroded off
bursterwell
pulled free of
round after
cavity cut.
Burster
remained
stuck in
round.
Bursterwell and Burster separated from 155mm mustard rounds at the Tooele Chemical Agent Disposal Facility.
A Partnership for Safe Chemical Weapons Destruction
X-ray Assessment
9
 ACWA and the Blue Grass Chemical Activity
conducted an X-ray assessment to learn about
extent of agent solidification problem at Blue Grass
 The X-ray assessment was performed from May to
June 2011, and was conducted to a 95 percent
confidence level
 All 96 H-filled munitions in sample contained heel
— Average heel – 54.8 percent
− Minimum heel – 15 percent
− Some weapons were completely solidified
 Approximately 6,100 munitions estimated to have
greater than 59 percent heel
─ This data suggests that less than 5 percent
could be processed in the main plant
Images taken May 25, 2011, courtesy BGCA
Clearly
visible
Heel
Additional
Heel along
the side
No liquid
agent line
visible
A Partnership for Safe Chemical Weapons Destruction
Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003
Massive (100%) visible Heel Large (72%) visible Heel Heel (17%) is limited in projo tail
“No liquid” agent line visible Little agent is available Large amount of liquid agent
Additional Heel on side Additional Heel on side No visible heel on the side
Likely highly pressured Likely highly pressurized Likely low pressurization
X-ray Study – Agent Heel Examples
Liquid Line
Liquid Line
10
A Partnership for Safe Chemical Weapons Destruction
Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003
Massive (100%) visible heel Large (72%) visible heel Heel (17%) is limited in projo tail
“No liquid” agent line visible Little agent is available Large amount of liquid agent
Additional heel on side Additional heel on side No visible heel on the side
Likely highly pressured Likely highly pressurized Likely low pressurization
X-ray Study – Agent Heel Examples
Liquid Line
Liquid Line
11
A Partnership for Safe Chemical Weapons Destruction
Environmental Assessment (EA)
 Completed EA to meet the requirements of the
National Environmental Policy Act, and Title 32 Code of
Federal Regulations Part 651
 EA published in June of 2013 with draft “Finding of
No Significant Impact” (FONSI)
 Public meeting held in July 2013 to discuss EA process
and draft FONSI
 Special Kentucky Chemical Demilitarization Citizens’
Advisory Commission and Chemical Destruction
Community Advisory Board meeting in October 2013 to
provide responses to commission and board members
on their collective comments provided during the
public comment period
 EA complete with “Finding of No Significant Impact”
12
A Partnership for Safe Chemical Weapons Destruction
Decision to use Explosive Destruction
Technology (EDT) at Blue Grass
 ACWA determined it was appropriate to direct Bechtel
Parsons to move forward with process to select an EDT to
destroy mustard projectiles at Blue Grass
 More than 15,000 155mm mustard projectiles, with fewer
than 200 in over-pack containers, along with two
Department of Transportation, known as DOT, bottles
containing mustard agent will be processed through the EDT
 ACWA decision considerations included: Environmental
Assessment and resulting Finding of No Significant Impact
and stakeholder involvement
13
A Partnership for Safe Chemical Weapons Destruction
Equipment Selection:
Static Detonation Chamber
 Equipment selected based upon competitive procurement
process performed by Bechtel Parsons Blue Grass
 Equipment selected: Static Detonation Chamber (SDC)
system supplied by UXB International, Inc.
 The SDC system includes a spherical, fully-contained and
high strength heat resistant stainless steel vessel
 The SDC uses electrically-generated heat causing munitions
to detonate or deflagrate, thus destroying the agent and
energetics
 The pollution abatement system includes thermal treatment
and scrubbers to remove any particulates, organics,
sulfur-dioxide, chlorine and heavy metals
 The system contains a robust carbon filtration system to
ensure air released back to the environment is clean
 The SDC will be enclosed within an engineered building
constructed atop a steel-laced concrete foundation
14
A Partnership for Safe Chemical Weapons Destruction
SDC 1200 C Similar to the BGCAPP Unit
15
A Partnership for Safe Chemical Weapons Destruction
16
Workers place
mustard projectiles
in Feed Trays with
the aid of Material
Handling Equipment
(MHE)
System allows for
single handling of
projectiles by
workers
Step 1 Step 2 Step 3 Step 4
Projectiles conveyed
to top of vessel
For added safety, it
is a fully automatic,
double air-lock
feeding conveyor
system
Projectiles fed into
electrically heated
Detonation Chamber
Chamber
temperature
maintained above
critical temperature
of energetics inside
the projectiles
High heat detonate
projectiles, mustard
agent and energetics
destroyed by
explosion / thermal
decomposition
Off-gases treated by
air pollution control
system
EDT System – How It Works – Overview
A Partnership for Safe Chemical Weapons Destruction
Static Detonation Chamber (SDC)
(cont’d)
17
 Scrap metal is retained in the
chamber until it has been
completely treated to destroy all
agent, including heels if present
 The remaining byproduct, clean
scrap metal will be removed for
recycling
Before
AfterAfter
Anniston SDC munitions service magazine (above).
Anniston SDC cool-down inspection conveyor system (above).
A Partnership for Safe Chemical Weapons Destruction
EDT Pollution Control System
Overview
18
EDT air pollution control system basics
 Is treating off-gasses from EDT system
Flamed
Thermal
Oxidizer
1 Particulate
Collection2 Scrubbers
3 Carbon
Filters4
Air Pollution Control System Process Overview
Off-gasses
A Partnership for Safe Chemical Weapons Destruction
Explosive Destruction Technology
site location
19
Explosive Destruction Technology
Utility Building
Supercritical Water Oxidation Process Building
Control and Support Building
Munitions Demilitarization Building
A Partnership for Safe Chemical Weapons Destruction
Public Participation, Resource
Conservation Recovery Act, Class 3
Modification Process
20
A Partnership for Safe Chemical Weapons Destruction
How to Comment
Community members and interested stakeholders may submit
comments on the permit modification request via:
 In Person:
Place your completed comment form in the box on the information table
 Email:
heather.alexander@ky.gov
 Mail:
Kentucky Department for Environmental Protection
Division of Waste Management
200 Fair Oaks Lane, 2nd Floor
Frankfort, KY 40601-1190
 For more information contact:
Heather Alexander, Kentucky Department for Environmental Protection,
at (502) 564-6716
21
A Partnership for Safe Chemical Weapons Destruction
Questions?
22

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Public Meeting for Class 3 Permit Modification Request to Kentucky Department for Environmental Protection (KDEP) to add Explosive Destruction Technology (EDT) to BGAD RCRA Hazardous Waste Permit

  • 1. Public Meeting for Class 3 Permit Modification Request to Kentucky Department for Environmental Protection (KDEP) to add Explosive Destruction Technology (EDT) to BGAD RCRA Hazardous Waste Permit Date: April 14, 2014 Presented by: Allison Respess, Bechtel Parsons Blue Grass, Assistant Project Manager
  • 2. A Partnership for Safe Chemical Weapons Destruction ACWA’s Chemical Demilitarization Mission 2 The safe and environmentally sound destruction of the chemical weapons stockpiles stored at the Blue Grass Army Depot, Ky., and the U.S. Army Pueblo Chemical Depot, Colo.
  • 3. A Partnership for Safe Chemical Weapons Destruction 3 Blue Grass Mission  The Blue Grass mission is to safely and efficiently destroy the chemical weapons stored at the Blue Grass Army Depot in Richmond, Ky.  The U.S. Department of Defense’s Program Executive Office, Assembled Chemical Weapons Alternatives (ACWA) manages all aspects of the chemical weapons destruction program for both Kentucky and Colorado  Bechtel Parsons Blue Grass is under contract to ACWA for the design, construction, systemization, operations and closure work at Blue Grass Igloos at the depot store both conventional and chemical weapons, and other non-stockpile items. Chemical weapons such as these M55 rockets are stored at and monitored by the Blue Grass Chemical Activity.
  • 4. A Partnership for Safe Chemical Weapons Destruction 4 Role as the systems contractor  Bechtel Parsons Blue Grass is the systems contractor responsible for design, construction, systemization, operations and closure which includes: – Main neutralization/supercritical water oxidation pilot plant – Explosive Destruction Technology (EDT) system
  • 5. A Partnership for Safe Chemical Weapons Destruction BGCAPP Operational Philosophy 5 •Protect the workforce, public and environment •Minimize or eliminate human interface with weapons •Minimize or eliminate additional waste streams BGCAPP Operational Philosophy
  • 6. A Partnership for Safe Chemical Weapons Destruction M110 155mm H-filled Projectile (In 1943) (Today) 6 Blue Grass Mustard (H) Projectiles  Mustard filled projectiles are the oldest component of the Blue Grass Army Depot (BGAD) stockpile  Manufactured between 1941 and 1943 at Edgewood Arsenal (EA), Md., today part of Aberdeen Proving Ground  Mustard filled projectiles are the only projectiles at BGAD that have an explosive charge referred to as a burster  Mustard M110 155mm Projectiles – Agent Type: Levinstein Mustard – Burster Explosive: Tetrytol – Percentage of Munition Inventory: 15.2 percent – Percentage of Agent Inventory: 17.3 percent
  • 7. A Partnership for Safe Chemical Weapons Destruction Background: Problematic Mustard Projectiles 7  Problems processing mustard-agent filled 155mm projectiles at the Tooele Chemical Agent Disposal Facility (TOCDF) led the ACWA program to request the National Research Council to conduct an assessment to analyze Explosive Destruction Technology (EDT) use at Blue Grass and Pueblo – Tooele projectiles had a high rate of agent solidification, which complicates removal of the mustard agent from the projectile; and stuck bursters, which require human interaction to remove the explosives from the problematic munitions – Blue Grass has a high number of same-lot problematic munitions as Tooele (20 of the 31 Edgewood Arsenal lot numbers are common to both sites)  ACWA worked closely with the U.S. Army Chemical Materials Activity to incorporate lessons learned from processing problematic mustard projectiles at TOCDF
  • 8. A Partnership for Safe Chemical Weapons Destruction Background: Problematic Mustard Projectiles (cont’d) 8 Corroded off bursterwell pulled free of round after cavity cut. Burster remained stuck in round. Bursterwell and Burster separated from 155mm mustard rounds at the Tooele Chemical Agent Disposal Facility.
  • 9. A Partnership for Safe Chemical Weapons Destruction X-ray Assessment 9  ACWA and the Blue Grass Chemical Activity conducted an X-ray assessment to learn about extent of agent solidification problem at Blue Grass  The X-ray assessment was performed from May to June 2011, and was conducted to a 95 percent confidence level  All 96 H-filled munitions in sample contained heel — Average heel – 54.8 percent − Minimum heel – 15 percent − Some weapons were completely solidified  Approximately 6,100 munitions estimated to have greater than 59 percent heel ─ This data suggests that less than 5 percent could be processed in the main plant Images taken May 25, 2011, courtesy BGCA Clearly visible Heel Additional Heel along the side No liquid agent line visible
  • 10. A Partnership for Safe Chemical Weapons Destruction Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003 Massive (100%) visible Heel Large (72%) visible Heel Heel (17%) is limited in projo tail “No liquid” agent line visible Little agent is available Large amount of liquid agent Additional Heel on side Additional Heel on side No visible heel on the side Likely highly pressured Likely highly pressurized Likely low pressurization X-ray Study – Agent Heel Examples Liquid Line Liquid Line 10
  • 11. A Partnership for Safe Chemical Weapons Destruction Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003 Massive (100%) visible heel Large (72%) visible heel Heel (17%) is limited in projo tail “No liquid” agent line visible Little agent is available Large amount of liquid agent Additional heel on side Additional heel on side No visible heel on the side Likely highly pressured Likely highly pressurized Likely low pressurization X-ray Study – Agent Heel Examples Liquid Line Liquid Line 11
  • 12. A Partnership for Safe Chemical Weapons Destruction Environmental Assessment (EA)  Completed EA to meet the requirements of the National Environmental Policy Act, and Title 32 Code of Federal Regulations Part 651  EA published in June of 2013 with draft “Finding of No Significant Impact” (FONSI)  Public meeting held in July 2013 to discuss EA process and draft FONSI  Special Kentucky Chemical Demilitarization Citizens’ Advisory Commission and Chemical Destruction Community Advisory Board meeting in October 2013 to provide responses to commission and board members on their collective comments provided during the public comment period  EA complete with “Finding of No Significant Impact” 12
  • 13. A Partnership for Safe Chemical Weapons Destruction Decision to use Explosive Destruction Technology (EDT) at Blue Grass  ACWA determined it was appropriate to direct Bechtel Parsons to move forward with process to select an EDT to destroy mustard projectiles at Blue Grass  More than 15,000 155mm mustard projectiles, with fewer than 200 in over-pack containers, along with two Department of Transportation, known as DOT, bottles containing mustard agent will be processed through the EDT  ACWA decision considerations included: Environmental Assessment and resulting Finding of No Significant Impact and stakeholder involvement 13
  • 14. A Partnership for Safe Chemical Weapons Destruction Equipment Selection: Static Detonation Chamber  Equipment selected based upon competitive procurement process performed by Bechtel Parsons Blue Grass  Equipment selected: Static Detonation Chamber (SDC) system supplied by UXB International, Inc.  The SDC system includes a spherical, fully-contained and high strength heat resistant stainless steel vessel  The SDC uses electrically-generated heat causing munitions to detonate or deflagrate, thus destroying the agent and energetics  The pollution abatement system includes thermal treatment and scrubbers to remove any particulates, organics, sulfur-dioxide, chlorine and heavy metals  The system contains a robust carbon filtration system to ensure air released back to the environment is clean  The SDC will be enclosed within an engineered building constructed atop a steel-laced concrete foundation 14
  • 15. A Partnership for Safe Chemical Weapons Destruction SDC 1200 C Similar to the BGCAPP Unit 15
  • 16. A Partnership for Safe Chemical Weapons Destruction 16 Workers place mustard projectiles in Feed Trays with the aid of Material Handling Equipment (MHE) System allows for single handling of projectiles by workers Step 1 Step 2 Step 3 Step 4 Projectiles conveyed to top of vessel For added safety, it is a fully automatic, double air-lock feeding conveyor system Projectiles fed into electrically heated Detonation Chamber Chamber temperature maintained above critical temperature of energetics inside the projectiles High heat detonate projectiles, mustard agent and energetics destroyed by explosion / thermal decomposition Off-gases treated by air pollution control system EDT System – How It Works – Overview
  • 17. A Partnership for Safe Chemical Weapons Destruction Static Detonation Chamber (SDC) (cont’d) 17  Scrap metal is retained in the chamber until it has been completely treated to destroy all agent, including heels if present  The remaining byproduct, clean scrap metal will be removed for recycling Before AfterAfter Anniston SDC munitions service magazine (above). Anniston SDC cool-down inspection conveyor system (above).
  • 18. A Partnership for Safe Chemical Weapons Destruction EDT Pollution Control System Overview 18 EDT air pollution control system basics  Is treating off-gasses from EDT system Flamed Thermal Oxidizer 1 Particulate Collection2 Scrubbers 3 Carbon Filters4 Air Pollution Control System Process Overview Off-gasses
  • 19. A Partnership for Safe Chemical Weapons Destruction Explosive Destruction Technology site location 19 Explosive Destruction Technology Utility Building Supercritical Water Oxidation Process Building Control and Support Building Munitions Demilitarization Building
  • 20. A Partnership for Safe Chemical Weapons Destruction Public Participation, Resource Conservation Recovery Act, Class 3 Modification Process 20
  • 21. A Partnership for Safe Chemical Weapons Destruction How to Comment Community members and interested stakeholders may submit comments on the permit modification request via:  In Person: Place your completed comment form in the box on the information table  Email: heather.alexander@ky.gov  Mail: Kentucky Department for Environmental Protection Division of Waste Management 200 Fair Oaks Lane, 2nd Floor Frankfort, KY 40601-1190  For more information contact: Heather Alexander, Kentucky Department for Environmental Protection, at (502) 564-6716 21
  • 22. A Partnership for Safe Chemical Weapons Destruction Questions? 22