public meeting for class 3 permit modification request to kentucky department for environmental...

Public Meeting for Class 3 Permit Modification Request to Kentucky Department for Environmental Protection (KDEP) to addExplosive 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.


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

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


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


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


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


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.


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


Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003Massive (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 agentAdditional Heel on side Additional Heel on side No visible heel on the sideLikely highly pressured Likely highly pressurized Likely low pressurization

X-ray Study – Agent Heel Examples

Liquid Line

Liquid Line

10


Round 1 – BGX-02-002 Round 2 – BGX-02-013 Round 3 – BGX-02-003Massive (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 agentAdditional heel on side Additional heel on side No visible heel on the sideLikely highly pressured Likely highly pressurized Likely low pressurization

X-ray Study – Agent Heel Examples

Liquid Line

Liquid Line

11


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


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


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 buildingconstructed atop a steel-laced concrete foundation

14


SDC 1200 C Similar to the BGCAPP Unit

15


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 abovecritical 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


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).


EDT Pollution Control System Overview

18

EDT air pollution control system basics Is treating off-gasses from EDT system

• Flamed• Therma

l Oxidizer

1• Particulat

eCollection

2 • Scrubbers3 Carbon

Filters4

Air Pollution Control System Process Overview

Off-gasses


Explosive Destruction Technologysite location

19

Explosive Destruction Technology

Utility Building

Supercritical Water Oxidation Process Building

Control and Support Building

Munitions Demilitarization Building


Public Participation, Resource Conservation Recovery Act, Class 3 Modification Process

20


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:[email protected]

Mail:Kentucky Department for Environmental ProtectionDivision of Waste Management200 Fair Oaks Lane, 2nd FloorFrankfort, KY 40601-1190

For more information contact:Heather Alexander, Kentucky Department for Environmental Protection, at (502) 564-6716

21

mailto:[email protected]


Questions?

22

public meeting for class 3 permit modification request to kentucky department for environmental...

Government & Nonprofit

blue grass chemical

chemical weapons stockpiles

blue grass mission

blue grass igloos

mustard agent

army pueblo chemical

sound destruction

projectiles agent type