DSHW-2010-046727 - 0901a068801d95e8

HAND DELIVERED
NOV 0 3 20t0
UTAH DIVISION OF
SOLID & HAZARDOUS WASTE
^010,O^H^"^
TOCDF Response to Division of Solid and Hazardous Waste (DSHW)
Concerning Permit Modification Request TOCDF-DAVINCH-03-1117 (DSHW
Tracking Number 2010 01938)
REPLY TO
ATTENTION OF
DEPARTMENT OF THE ARMY
US ARMY CHEMICALS MATERIAL AGENCY
TOOELE CHEMICAL AGENT DISPOSAL FACILITY
11620 STARK ROAD
STOCKTON, UT 84071
Tooele Chemical Agent Disposal Facility NOV 03 2010
HAND DELIVERED
my 0 3 2010
UTAH DIVJSION OF
SOLID & HAZARDOUS WASTE
^010.03^^8-
PM0831-10
Mr Scott Anderson
Director, Utah Department of Environmental Quality
Division of Solid and Hazardous Waste
PO Box 144880
195 North 1950 West
Salt Lake City, Utah 841 14-4880
SUBJECT Tooele Chemical Agent Disposal Facility (TOCDF) Response to State of Utah Division
of Solid and Hazardous Waste (DSHW) Concerning Permit Modification Request TOCDF-DAVINCH-
03-1 117 (DSHW TrackingNumber 2010 01938), EPA ID UT5210090002
Dear Mi Anderson
Please find enclosed the response to comments received from DSHW concerning Permit Modificanon
Request TOCDF-DAVINCH-03-11 17 which is titled "Install and Operate Explosive Destruction
Technology Subpart X Unit in Aiea 10" Also enclosed is a compact disc containing electronic files of
the TOCDF Resource Consei vation and Recovery Act Permit change pages, a redlined version of the
Destruction Plan, which incorporates the comment responses, and Process and Instrumentation Drawings
that have been reviewed by a Utah Certified Professional Engineei
Note the following
• TOCDF concurs with the DSHW recommendation to operate two Near Real Time Monitors
in staggeied mode at the Detonation of Ammunition in a Vacuum Integrated Chambei (DAVINCH)
Pollution Abatement System PMI sampling location, the monitoring location prior to the inlet of the
Retention Tank
• TOCDF intends to submit the analytical procedures listed in the response to DSHW
comment # 11 These procedures will be submitted to DSHW for appioval by the Executive
Secretary
• The DSHW lettei dated September 7, 2010 that transmitted the comments to the TOCDF
discussed the need to conduct stack testing Based on meetings held with DSHW, TOCDF proposes
the following test format
DAVINCH exhaust gas resulting from the detonation of single ovei packed 155iTim H Piojectiles
will be analyzed foi concentrations of Caibon Dioxide, Cai bon Monoxide, Sulfur Dioxide,
Nitrogen Oxides, Total Hydiocarbons, and Oxygen using an array of Continuous Emission
Momtoiing Systems Exhaust gas concentrations of Volatile Oi game Compounds will be
evaluated using a Fouriei Tiansfoim Infia Red Spectroscopy 155mm H Projectiles aie selected
Recycled Paper
PM0831-10
as the test case because it is duiing their processing when the maximum agent and explosive
weights are present in the DAVINCH Detonation Chamber
DAVINCH exhaust gas will be evaluated over the period of at least four separate detonations
Samples of ash and condensate will be taken from the Detonation Chamber The solid samples
will be analyzed for dioxins, explosives, and chloride content The liquid samples will be
analyzed for explosives and chlorides A set of samples will be collected at the end of the day
DAVINCH exhaust gas resulting from the detonation of overpacked 4 2-inch HD Mortars will be
evaluated for Mercury (Hg) concentrations using the TOCDF Hg Process Monitor (MPM) which
IS based on Environmental Protection Agency Reference Method 308 The MPM was used
throughout the Mustard non-Baseline Ton Container Campaign to evaluate TOCDF incinerator
Hg exhaust gas concentiatioiis Exhaust gas sample will be evaluated using the MPM for one day
during the processing of the HD mortars HD mortars are selected because they contain the
highest concentrations of Hg in their fill DAVINCH exhaust gas will be evaluated for a single
day because the all the HD mortals that will be processed in the DAVINCH will be processed in
one day
Note HD mortars will be processed toward the end of DAVINCH operations at TOCDF to limit
the amount of exhaust gas that will pass through the DAVINCH Pollution Abatement System
sulfur impregnated carbon filter bed after it is exposed to Hg This sampling approach requires
two separate sampling periods that will occur perhaps months apart (i e , one sampling period
when processing 155min H Projectiles, and one period when processing 4 2-inch HD mortars)
TOCDF will provide the DSHW will a test plan that will specify the sampling locations, test methods,
and their associated quality objectives 60 days prior to the date of the first sampling period which is
tentatively scheduled for early June or July of 2011
The points of contact in this matter are Ms Sheila R Vance at [phone] or Mr Trace Salmon
at [phone]
Sincerely,
Elizabeth A Lowes
EG&G Defense Materials, Inc
"CERTIFICATION STATEMENT
Thaddeus A Ryba, Jr
TOCDF Site Project Manager
"CERTIFICATION STATEMENT
Enclosure
• 1 CERTIFY UNDER PENALTY OF LAW THAT THIS DOCUMENT AND ALL ATTACHMENT S WERE I REPARED UNDER MY DIRECTION OR SUPERVISION IN
ACCORDANCE WITH A S^ STEM DESIGNED TO ASSURE THA r QUALIFIED PERSONNEL PROPERLY GATHER AND EVALUATE THE INFORMATION SUBMl FTFD BASED
ON MY INQUIRY OF THE PERSON OR PERSONS WHO MANAGE THE SYSTEM OR THOSE PERSONS DIRECTLY RESPONSIBLE FOR GATHERING THE INFORMATION THE
INFORMATION SUBMITTED IS TO THE BEST OF MY KNOWLEDGE AND BELIEF TRUE ACCURATE AND COMPLETE I AM AWARE THAT THERE ARE SIGNIFICANT
PENALTIES FOR SUBMITTING FALSE INFORMATION INCLUDING THE POSSIBILITY OF FINE AND IMPRISONMENT FOR KNOWING VIOLATIONS
HAND DELIVERED
DAVINCH EDT Modification Review Comments NOV 0 3 2010
fi*otu
The Utah Division of Sohd and Hazardous Waste SOLIO^&'HAZI^DOUS^W^
1 On page 6, midway through the paragraph, it states that wipe samples were taken off the
munition fragments and the interior of the detonation chamber but it does not report the results
Please provide the results of the sampling and analysis Please be aware that wipe sampling is
currently not accepted by the Division as an appropriate method for verification of
decontamination and an alternate method will need to be placed in all DAVINCH documents
Please provide all available analytical data from past DAVINCH operations to support the
statement that the DAVINCH is a proven technology such as analysis of residues and air
monitoring data
The wipe samples results were used to develop a Destruction Efficiency for the mustard
surrogates used during the testing The data was provided with the permit modification request
This information can be found on pages 33 through 47 of Attachment 2 to the permit
modification request
2 On page 8, in the last paragraph, it states that detonation chamber off-gas is sampled
both upstream and downstream from the cold plasma oxidizers How and where is the off-gas
sampled and what constituents are being looked for in the samples'^ Is the post oxidizer agent
monitor the PMI monitor shown on drawing DB31-EA101 just before the retention tank*^ How
long does it take the off-gas to travel from the detonation chamber to PMl*^ How much air
volume does the detonation chamber hold''
DB31-EA101 (Process Flow Diagram 1) shows that concentrations of hydrogen (H2) and
carbon monoxide (CO) are monitored prior to the inlet of the Cold Plasma Oxidizers, and
concentrations of CO, sulfur dioxide (SO2), hydrogen chloride (HCl), oxygen (O2), and
nitrogen oxides (NOx) are monitored after the oxidizers The instrument used to determine the
concentration of these constituents is a Gas Chromatograph equipped with a Thermal
Conductive Detector (GC-TCD)
Although agent monitor PMI is located near the Retention Tank, after the gases have been
analyzed, they are directed though a duct for approximately 30 feet before they reach the inlet
to the Retention Tank
A calculation for the time it takes detonation gases to reach the PMI sampling location is not
provided Rather, TOCDF has considered the recommendation of the State of Utah Division of
Solid and Hazardous Waste (DSHW) and wall use staggered Near Real Time (NRT) momtors
at the PMI sampling location (the location prior to the inlet of the Retention Tank) The use of
staggered NRT at the PMI location will provide continuous agent monitoring at this location
throughout each operational day
The volume of the Detonation Chamber is 30 4 cubic meters or 1,073 cubic feet
3 On page 9, midway through the second paragraph, it states that if agent is detected in the
off-gas, it IS re-circulated through the retention tank carbon filter and the retention tank until
the agent concentration m the off-gas is less than 1 VSL Annex B Monitoring Plan indicates
Page 1 of 45
that alarm levels are to be 0 5 VSL Please revise all areas of the modification documents to
reflect that the alarm levels for all monitoring will be 0 5 VSL Will the recirculation be timed to
ensure that the exhaust gas being sampled is representative'^ How many times will the gas be re-
circulated'^ As a proactive measure, the Division may require the exhaust gas to be re-circulated
at least once for every batch of exhaust gas no matter what the readings are on the agent monitor
prior to the retention tank Would this be possible*^ Is there enough exhaust gas during the first
treatment phase for this'' Would this negatively impact the operation of the unif
The TOCDF concurs with establishing DAVINCH''"'^ agent emission limit of 0 5 Vapor
Screening Limit (VSL) (VSL for mustard agents is 0 003 milligrams per cubic meter) The
permit conditions in Module VIII are revised to specify an upper agent concentration limit to
reflect this limit for DAVINCH™ exhaust gas
The detonation gas is circulated through the carbon filter at least one time after which it is
analyzed for agent concentration If the confirmed agent concentration in the gas is equal to or
greater than 0 5 VSL, the gas will be sent through the carbon filter again
Depending the results obtained during the initial detonation gas check, the valve downstream of
the Retention Tank outlet will remain open or be closed, after which the remainder of the
detonation will be transferred from the detonation chamber through the Cold Plasma Oxidizers
The TOCDF does not recommend directing all treated detonation gas through the Retention
Tank Carbon Filter The Pollution Abatement Systems (PASs) of other DAVINCHTM systems
currently in operation in other parts of the world are not equipped with a Retention Tank
Carbon Filter This filter was included in the DAVINCH™ PAS design at the request of
TOCDF as a contingency should agent be detected by the agent monitor located downstream of
the Cold Plasma Oxidizers and upstream of the Retention Tank inlet The DAVINCH^'^
systems have processed over 5,400 chemical munitions, and to date, there has not been an
instance where chemical agent was detected downstream of the Detonation Chamber
Therefore, based on this data, TOCDF does not expect that the Retention Tank Dedicated
Carbon Filter will be used
If each batch of detonation gas were to be directed through the Retention Tank Dedicated
Carbon Filter, the number of detonations that could occur in a day would be reduced fi-om
approximately six to an estimated five, which would extend the DAVINCH^"^ operations scope
by approximately 18 percent
Note that all detonation gases generated by the DAVFNCH'^'^ operation also pass through a
sulfiir-impregnated activated carbon filter before being released to the environment Sulftir-
impregnated activated carbon is effective in removing both mercury and organic compounds
that are entrained in process gases
4 On page 10, the last sentence of the first paragraph states that the munitions will be
delivered in overpacks Are these just the overpacks that the munitions are currently in, i e
prop charge cans, or ONCs or something else''
The reference to overpacks was to the overpacks in which the munitions are packaged The
type of overpacks used is shown in Table 7, page 25, of the permit modification request, under
the column headed Overpack(s)
Page 2 of 45
5 On page 11, the first paragraph discusses the closing and sealing of the door What
indication do the operators use to know that the door is closed and sealed properly''
Proximity switches are used to indicate that the door clamps are in the correct position to seal
the Detonation Chamber The status of the door and associated clamp position can be observed
fi-om the Control Screens located in the Control Trailer
6 On page 12, the third full paragraph again mentions 1 VSL See comment 3 above Why
aren't both Off-Gas Treatment 1 and Off-Gas Treatment 2 sampled for agent concentration''
The TOCDF concurs with the use of a 0 5 VSL limit for DAVINCH^M emission to the
environment as a criterion for continued release of detonation gas past the Retention Tank
outlet The TOCDF also concurs with the use of staggered NRT monitoring at this sampling
location The monitors will operate continuously throughout the shift in staggered mode,
therefore, detonation exhaust gas generated from both off-gas Treatments 1 and 2 will be
sampled for agent concentration
7 On page 14, the first paragraph under the heading. Waste Analysis Plan, are listed the
items to be treated by the DAVINCH This paragraph mentions HT and HD samples Please
provide more information on these samples How are they configured'' Where did they come
from*' Why it the DAVINCH be chosen as the treatment technology for them''
The mustard (HT and HD) samples were collected from past sample and analysis programs
conducted by the Army to determine the rate of degradation of the Deseret Chemical Depot
(DCD) chemical agent stockpile The mustard agent comprising the stockpile has been well
characterized through past sampling/analysis efforts that have supported TOCDF mustard
processing The samples were collected from ton containers and munitions, and analyzed for
agent purity These samples are packaged with four sample containers to each overpack The
samples are packaged in M2A1 overpacks There are 41 HT and 6 HD samples The volume
of each HT sample is 825 milliliters The volume of each HD sample is 452 milliliters Table
7, on page 25 of the DAVNCH^"^ permit modification request, shows the number of samples in
each overpack and their associated weights
The DAVINCH^'^ is proposed to treat these agent samples because of the reduced handling
requirement compared to what would be required to process the samples at the TOCDF There
IS also the possibility that the some of the sample container may be damaged which would
present a safety hazard for those having to unpack the samples Treatment in the DAVINCH
does not require the un-packaging of any of the sample overpacks Additionally, the expense
of operating the TOCDF to treat such a small amount of agent compared to the smaller expense
of operating the DAVINCH^*^ is a consideration
8 At the bottom of page 15 and top of page 16, there is a discussion of the process for
monitoring the drums of metal fragments The text states that a nitrogen purge is performed
before agent monitoring How long is the purge'' Is the purge exhaust monitored for chemical
agenf Why is the purge performed''
Page 3 of 45
The design of the DAVINCH^"^ munitions process allows for many contingencies to address
unexpected occurrences The munitions fragments removed from the detonation are expected
to be free of chemical agent contamination The procedure, which will be submitted to the
DSHW for approval prior to the start of DAVINCH''''^ agent operations, requires the
munition/overpack fragments to be placed in a drum The sealed drum is allowed to sit for a
minimum of four hours at a temperature of 70 °F before the drum and its contents are "head-
space" monitored If an unexpected result of greater than 0 5 VSL for solids and 1 0 VSL for
PPE IS obtained from the head-space monitoring, rather than using the nitrogen purge (which is
no longer included in the applicable procedure), the drum wall be opened near the inlets to the
DAVrNCH'T'^ Environmental Enclosure Heating, Ventilating, and Air Conditioning (HVAC)
System and vented into the DAVINCH HVAC system The HVAC system vents to the
atmosphere through three activated carbon filter units After the lid on the drum in question is
replaced the procedure require the sealed drum and its contents to sit for four hours at a
temperature of 70 °F before the next head-space monitoring occurs
9 On page 16, the third full paragraph discusses the analysis of condensate and spent
scrubber brines This is also discussed on page 40 of the Explosive Destruction Technology
(EDT) Destruction Plan in the first paragraph on the page Please explain why the scrubber
brines are not being analyzed for pH and specific gravity like the scrubber brines from the
incinerator PAS
The pH parameter is an analytical requirement to determine if the waste is Toxicity
Characteristic for corrosivity, and this parameter has been added to the required list of
parameter for analysis Specific gravity was not included as a parameter of analysis for this
waste steams because it has no bearing on how the waste will be treated at the off-site Subtitle
C Treatment, Storage, and Disposal Facility (TSDF) to which TOCDF will transfer the waste
Specific gravity was selected as a parameter of analysis for TOCDF scrubber brines because
there is also an incinerator operating parameter limit for maximum scrubber brine density
10 On page 16, the fourth full paragraph discusses the analysis of ash generated from several
sources What is the filter media used to remove particulate from the detonation gas'' The last
paragraph on the page discusses the analysis of spent carbon Carbon method validations will
need to be submitted for review and approval and incorporation into the permit
There are four places where ash accumulates and is removed from the DAVINCH™ system
Ash accumulates in the Detonation Chamber, and the accumulation containers that support the
inline Cyclone Filter F410, Screen Filter F420, and Screen Filter F320 (all filters are shown on
drawing DB31-EA101, Sheet 1) Filter F320 is used to remove particulate from the detonation
gas Filters F410 and F420 remove particulate from air that flows through the Detonation
Chamber when the door to the chamber is open
Filter F320 is comprised of stainless steel SA 213 TP213 filter mesh Filter 410 is an inline
cyclone filter to remove large particulate Filter F420 is bonded material, 2 micrometers, 99 99
% filtration, backwash equipped Filters F320 and F420 are rated at greater than 99 97 %
efficiency for removing particulate having a diameter greater than 2 microns
Regarding the analysis of the activated carbon used in the DAVINCH^"^ PAS, TOCDF is
developing a method to quantify the concentration of agent in activated carbon that is
determined to be contaminated based on the agent monitoring results obtained during
Page 4 of 45
operations The TOCDF is aware that agent-contaminated activated carbon cannot be
transferred off site until a DSHW-approved analytical method is available that allows for the
quantification of the agent concentration found in the carbon This method however is being
developed programmatically and not specifically for the DAVINCH™ application
To preclude the need to perform an agent extraction on spent activated carbon the
DAVINCH™ subcontractor has decided to operate WPL DAAMS at the inlet to the
Environmental Enclosure HVAC carbon filter units These DAAMS (which are identified in
the revised Annex B to the Destruction Plan), will generate a historic record of the HVAC
carbon's exposure to agent
11) Please provide all SOPS related to sampling and analysis including standard preparation,
sample preparation, data management that will be used for the DAVINCH Also include
revision identifier for SW-846 procedures Please provide matrix validation of the activated
carbon for metals and organics
The Laboratory Operating Procedures (LOPs) used to prepare monitonng and calibration
standards, and to perform the agent analysis on waste residues, will be provided to DSWH for
approval before agent operations begin The DAVINCH^"^ LOPs and Standard Operating
Procedures (SOPs) that will be provided to DSHW for approval by the Executive Secretary are
listed below
PR-006 Detonation Chamber Decontamination
PR-007 DAAMS Operation
PR-008 MIN ICAMS Operation
PR-010 Headspace Monitonng
PR-016 Agent Analysis
PR-017 Laboratory Quality Control Plan
PR-022 DAAMS Analysis
The data management for the DAVINCH in regards to the analytical QC review turn around
time will be similar to that of the Chemical Assessment Laboratory (CAL) since ECBC is
providing onsite QC personnel
Regarding the activated carbon analysis, an analytical method to determine agent
concentrations on activated carbon is being developed It is anticipated that the method
developed by TOCDF will be used to analyze DAVINCH^'^-operations-generated spent carbon
that IS suspected of being contaminated with mustard Any required metals analyses associated
with the spent DAVINCH''''^ PAS impregnated carbon will be conducted by an off-site
laboratory The samples of PAS carbon will be sent to an off-site laboratory after either an
agent extraction has been perfonned or after review of monitoring data, if the data show that
the carbon was not exposed to agent
12) On page 20, the sixth bullet states that there are two fixed-bed activated carbon filters but
drawing DB31-EA102 shows three filters Which is correct'' What type of carbon is used m
each of the carbon filters (HVAC and exhaust gas units)''
The Environmental Enclosure (EE) HVAC activated carbon filters are referenced in the sixth
bullet on page 20 of the DAVINCH pennit modification request Initially, it was assumed two
Page 5 of 45
of the three filters would be online at any time with one held in reserve However, the operator
of the DAVINCH''"'^ intends to operate all three filter units simultaneously (i e , all three fihers
will be online) when agent operations begin In summary, there are three HVAC filter units,
and all of them will be online during agent operations A single filter may be taken offline if a
carbon change out is required However, if a filter is taken offline, agent operations will be
suspended until all three filters are placed online
The type of activated carbon used in the HVAC filter units is standard activated carbon It is
not impregnated with any metals, and its sole purpose is to control organic emissions
13) At several locations in the modification and plan an estimate of the number of 4 2 inch
mortars to be treated in the DAVINCH is provided Now that all mustard projectile and mortar
processing is complete the exact number of items to be treated in the DAVINCH should be
known and the numbers at all locations throughout the modification and plans should be
updated The table on page 25 of the modification, condition VIII H 5, Table 2 on page 4 of the
Explosive Destruction Technology (EDT) Destruction Plan, Table 5 on page 35 of the Explosive
Destruction Technology (EDT) Destruction Plan
The only remaining energetic-configured munitions remaining in the DCD Chemical Stockpile
are the 155-miIlimeter (mm) Projectiles and 4 2-inch Mortars that will be processed by the
DAVINCH'^'** For this reason, the TOCDF Deactivation Furnace System (DFS) is no longer
needed and has been shut down
The TOCDF HD and HT Mortar Campaign contributed two additional HT mortar rejects to the
number of munitions to be processed by the DAVINCH™ It was anticipated that there would
be no more than 20 reject mortars from these campaigns
Because the DFS has been shut down, plans are underway to remove the demilitarization
machines that prepared its waste feed The Projectile and Mortar Disassembly Machines
(PMDs) will be removed from the Explosive Containment Rooms (ECRs) During their
removal and subsequent cleanup of the ECRs, it is possible that some explosive munition
components or pieces of explosive may be found The TOCDF desires to process these
components m the DAVINCH^M since it is not practical to relight the DFS to process the small
amount of explosive that might be found, it is also not economically or environmentally
practical to keep the DFS operable as it might not be used again, and it has large burners that
require a lot of fuel to maintain temperature
Therefore, the tables in Module VIII and the Explosive Destruction Technology (EDT)
Destruction Plan are revised to specify that 117 HT mortars will be processed - rather than 115
- to account for the two additional HT mortar rejects generated during the TOCDF Mortar
Campaign The tables are also revised to allow DAVrMCH^M treatment of ECR-closure-
generated explosive wastes to replace the batches no longer needed to process the anticipated
18 reject mortars that were included as a contingency, but were never encountered
Mortars are to be processed m the DAVINCH^M at a rate of three per batch Twenty mortars
would have required seven batch treatments to destroy The two reject mortars added to the
total will require one DAVINCH''"** treatment to destroy, leaving six batch treatments available
to process ECR closure explosive waste This tally results m the same number of
Page 6 of 45
DAVfKCH'^'^ batch treatments as proposed in the initial DAVrKCHi"** permit modification
request
The table m the Destruction Plan and Module VIII is revised as follows
Page 7 of 45
DAVINCH^'^ Operation Limitations"
1 2 3 4 5
Munition OvernacWs) Agent
No
Munitions
i& Samples
Munitions/
Shot
Shots/
Day'
Aeent/
Shot
m
Total
TNTea/
Shot
Ob)
4 2" HT Mortar M13A2 HT 44^ 117 3 7 174 118
4 2" HD Mortar M13A2 HD 18 3 7 18 118
UD-er
^ '"' IS'lnH-nr" HT 2XJ 6-0
1 JTIUI Idl 3 111 V/ V7 V
ECRExDiosive 9x41 or 7x27*' See See Note b 1 7 See 78
Wastes Note b Note b
155mm H Proio MI6A3 H 68 2 7 23 4 128
155mm H Proio 9x41 H 27 1 7 11 7 93
155mm H Proio M16A3/
M10A4 H 16 i 7 11 7 93
155mm H Proio PA37/
12x56 H 8 1 7 11 7 119
155mm H Proio M16A3/
12x56 H 79 1 7 11 7 119
HT Samoles M2A1 HT 4i 4 7 92 46
HD Samples M2A1 HD 6 4 7 5_L 46
Total • 386
"All values listed in columns 1 through 5 are maximums
Either over-pack may be used for over packing ECR explosive waste mortars roicctod in the TOCDF Munitions
Demilitarization Buildina during the This waste stream is limited to explosive or explosive munition components
found during the closure of the ECR and Subpart X Treatment Unit within the ECRs The number of DAVINCH™
treatment shall not exceed 6 mertar campaign The 9x41 over-pack has approximately twice the mass as the 7x27 The
Total TNTeq/shot associated with the treatment of mortars m either over-pack will not exceed the value shown Mertars
may bo filled with HD or HT since this grouping represents anticipated mortar rejects from TOCDF mortar processing
Does not include "Cleansing" shots when only explosives are added to Detonation Chamber to destroy
residual agent
Page 8 of 45
14) Please provide the materials of construction and design of the Environmental Enclosure
The Enclosure fabric is made of reinforced polymer The supports are made of steel and
aluminum The vendor makes enclosures having numerous commercial and military
applications
15) Please describe how the HVAC filter units will be operated Drawing DB31-EA102 shows
three monitors for each filter unit Annex B describes one NRT with three locations for each
unit, but three stations for DAAMS in each unit In Annex B please clarify this narrative and
explain each monitoring function at each location How many filter units will be operating at
one time*^
All three EE HVAC filter units will be online during agent operations Each filter unit consists
of a pre-filter, High Efficiency Particulate Air (HEPA) Filter followed by two activated carbon
beds, which are followed by a second HEPA Filter
Agent monitoring is provided for each filter unit Each unit has a dedicated MFNICAMS that is
used to monitor agent concentration in the air exhausting through each filter between the first
and second carbon bed Rather then using a "spider" assembly at the probe inlet, the
MINICAMS sampling location cycles (i e , "spools") between the top, middle, and bottom
section of the first carbon bed If agent is detected at the mid-bed location above the action
level of the MFNICAMS, the sampling location is changed to the outlet of the filter unit (a
location downstream of all three carbon beds and second HEPA Filter)
Each carbon filter unit is also equipped with three Depot Area Air Monitoring System
(DAAMS) A DAAMS samples the air as it passes through each carbon bed The DAAMS are
used to confirm or refute a MINICAMS indication of agent in the air exhausting through the
filter unit
16 ) Condition VIH A 1 h does not mention the samples The samples should be mcluded in
this condition
Condition VIIIA 1 h is revised to Condition VIII A 1 i (VIII A 1 h is marked "Reserved") and
revised to read
VIII A 1 1 One Detonation of Ammunition in a Vacuum Integrated Chamber
(DAVFNCH) for the treatment of over-packed leaking munitions and agents,
agent samples and ECR explosive waste specified in a DAVINCH
Destruction Plan approved by the Executive Secretary
17 ) Condition VHI H 3 VHI H 6 , andVIII H 7 u See Comment 3 regarding 1 VSL
The above reference conditions are revised to read
VIII H 3 The Permittee shall orally report to the Executive Secretary any release
of agent from the DAVINCH^'^ Environmental Enclosure or the
DAVINCH^^M Environmental Enclosure HVAC Filter System Stack that
exceeds the 4 0 5 Vapor Screening Limit for mustard (H/HT/HD) as
specified in Table 1 of this Permit
Page 9 of 45
VIII H 6 1 The Permittee shall release to the environment only those batches of detonation
gas determined to have an agent concentration less than 4-0 0 5 Vapor
Screening Limit (VSL) without application of Dilution Air Flow Controllers
(DAFCs) at the PMI sampling location, or XX** VSL with application of
DAFCs at the PMI samphng location using a dilution air to sample volume
ratio of YY**
Vlll H 6 11 The Permittee shall stop the flow of Detonation Off-Gas from the DAVINCH™
Pollution Abatement System (PAS) Retention Tank if the concentration of the
gas entering the tank is equal to or greater than ^ 0 5 VSL without
application of Dilution Air Flow Controllers (DAFCs) at the PMI sampling
location, or XX** VSL with application of DAFCs at the PMI samphng
location using a dilution air to sample volume ratio of YY**
VIII H 6 III Detonation Off-Gas having an agent concentration equal to or greater
than 4-0 0 5 VSL without application of Dilution Air Flow Controllers
(DAFCs) at the PMI samphng location, or XX** VSL with
application of DAFCs at the PMI sampling location using a dilution
air to sample volume ratio of YY** shall be directed to the dedicated
Retention Tank Carbon Filter and analyzed for agent concentration
before being released to the Environment
VIII H 7 11 The automatic valve located immediately downstream of the Retention Tank
outlet closes if agent is detected in the Detonation OfF-Gas at a concentration
equal to or greater than 4-0 0 5 VSL without application of Dilution Air
Flow Controllers (DAFCs) at the PMI sampling location, or XX** VSL
with application of DAFCs at the PMI sampling location using a dilution
air to sample volume ratio of YY**
**The dilution air to sample volume ratio is determined during systemization and validated during
the 28-dav initial baseline study Place holders XX and YY to be specified and incorporated in this
permit through a Class 1 Permit Modification Request prior to the start of Agent Operations
Note upon further review of the process flow diagram it was determined that DAFC would be
required at the PM1 sampling location (the location prior to the Retention Tank) because the
exhaust gas will be saturated at that point in the process
18 ) Condition VIII H 4 will need to have a revision number and date associated with the
destruction plan documents for configuration control purposes
The TOCDF concurs with the need to associate a date and revision number, so the condition is revised
to read
VIII H 4 The Permittee shall comply with the waste analysis, inspection, preparedness
and prevention, personnel training, agent monitoring, and closure requirements as
specified in the DAVfNCH™ Destruction Plan and associated annexes, dated XXXX,
Revision X
Place holders for the dates and revision number of the Destruction Plan are provided with the
intent of replacing them with the accurate information at the end of the permitting process
when all required revisions to the plan are complete
Page 10 of 45
19.) Condition VIII.H.5. Footnote "c" in the table mentions a "cleansing" shot used to destroy
residual agent. Please explain this footnote. What is meant by residual agent? Where does it
come from? How does the operator know it is there? Please provide more information on
cleansing shots.
The design of the DAVINCH™ munitions process allows for many contingencies to address
unexpected occurrences. Reference to a cleansing shot in Condition VIII.H.5 is included to
allow the operator to place and detonate an explosive charge in the chamber to destroy residual
chemical agent.
If used, a cleansing shot is comprised solely of donor (i.e., emulsion) explosive. No chemical
agent or munitions are added to the Detonation Chamber during a cleansing shot. The
cleansing shot is the typical method used to ensure that chemical agent concentrations within
the Detonation Chamber are maintained below detectable levels. Cleansing shots are also used
to decontaminate the Detonation Chamber when operations have been completed.
A cleansing shot will be performed prior to DAVINCH™ system disassembly and transfer to
an off-site location whose employees are trained to perform agent operations.
The absence or presence of agent contamination within the Detonation Chamber is determined
by monitoring the EE air that flows through the open chamber and into a portion of the
DAVENCH^"^ PAS. The air is sampled for agent after the air passes through the cyclone style
particulate filter. The contamination status of the Detonation Chamber is determined after each
detonation to determine the Personnel Protective Equipment (PPE) necessary to enter the
chamber.
The photographs below show a comparison of the Detonation Chamber before and after a
cleansing shot
Inside Chamber before (Left) and after (Right) a
Cleansing Shot
20. Condition VIII.H.7.i. and Condition VIII.H.7.ii. Since the residence time in the retention
tank is 10 minutes and the MINICAMS cycle time is seven minutes, is it possible to complete two
cycles of monitoring before the exhaust gas is released? Would it be possible to have staggered
Page 11 of45
monitors for this monitoring location*^ Do both the valves before and after the retention tank
close if agent is detected*^ Do the valves activate automatically or does an operator have to
activate them*^ Do the valves close for an agent monitor malfunction or power failure or other
upset conditions'^ Condition 7 ii should include monitor malfunction and power failure Is the
retention time the same during Treatment 1 and Treatment 2 phases of treatment*^ Is the flow
rate automatically controlled by the operating system or manually controlled by an operator*^
The TOCDF concurs with the suggestion to use staggered NRT monitors at the PMI sampling
location In addition, TOCDF concurs with the need to stop the flow of detonation gas from
the Retention Tank if either monitor at the PMI sampling location malfunctions or if there is a
power loss This feature of the control system will be tested and documented during the
Operational Readiness Review (ORR)
The valve before (3901) and after (3902) the retention tank closes when agent is detected, a
monitor malfianctions, or power fails
The flow rate of the detonation gas is controlled by an operator
21) Will Versar/ECBC provide all analytical capabilities or will EG&G/TOCDF provide
analytical support*^ The mobile laboratory will need to be audited and validated by the Division
prior to commencement of analyses since Department of Health, Bureau of Laboratory
Improvement does not certify mobile labs or specific methods (agent) What sample analysis will
the mobile lab perform'' Will any off-site analysis be performed'^
The Versar©/ Edgewood Chemical and Biological Center (ECBC) mobile lab will prepare the
Quality Plant (QP) sample used by the DAAMS, analyze the DAAMS tubes used at the
DAVINCH^'** site, and prepare the Research, Development, Test, and Evaluation (RDTE)
solutions used to challenge the MINICAMS The mobile laboratory will also perform the agent
extraction analyses on the waste residues generated by DAVfNCH''"'^ operations Metals and
organics analyses will be performed by an off-site laboratory certified by the bureau referenced
above (i e , Department of Health, Bureau of Laboratory Improvement)
The mobile laboratory will have fewer capabilities than the TOCDF Chemical Assessment
Laboratory (CAL) as it will not be certified to perform metals, free liquid, or pH analyses
22) The Table of Contents in the Explosives Destruction Technology (EDT) Destruction Plan
should be revised to include each of the Annexes
t
The EDT Destruction Plan Table of Contents references each of the annexes
23) On page v of the Explosive Destruction Technology (EDT) Destruction Plan in the second
paragraph of the Executive Summary and on page 1 in the second paragraph of the
Introduction, it states that 351 reject munitions will be treated The table in Permit Condition
VIII H 5 lists 398 items to be treated Please clarify these discrepancies See comment 13 above
regarding the exact count of items to be treated in the DAVINCH
The Executive Summary identifies 351 reject munitions to be processed This number is
derived from subtracting the number of samples to be processed (47), from the number of items
to be processed (398) The total number of reject munitions to be processed included the
Page 12 of 45
assumed 20 reject mortars that might have resulted from the TOCDF HD and HT Mortar
Campaign, however, there were only 2 reject HT Mortars Therefore, the total number of
mumtions to be treated by the DAVINCH^"^ is 333 However, the total number of items (i e ,
not just munitions) to be treated by the DAVINCH^M is 351-20+ 2 = 333, 333 +47
mustard samples + no more than 6 overpacks of ECR explosive waste total is 386 items
The Executive Summary is revised accordingly
24) The fourth paragraph on page 1 of the Explosive Destruction Technology (EDT)
Destruction Plan states, " leaking CWM are classified as hazardous waste in the State of Utah
as described by Utah Hazardous Waste Code P999 " This statement should be modified to read,
" CWM that are designated a waste destined for disposal are classified as hazardous waste in
the State of Utah, see the Utah Hazardous Waste Rules R315-2-11(e)(1) "
The Destruction Plan is revised to incorporate the suggested revision
25) The fifth paragraph on page 1 of the Explosive Destruction Technology (EDT)
Destruction Plan states, "The destruction of CWM is permitted and regulated by the Resource
Conservation and Recovery Act (RCRA) " This sentence should be revised to read, "The
destruction of CWM in the State of Utah is permitted and regulated by the permit"
The Destruction Plan is revised to incorporate the suggested revision
26) There is an extra period following "x-ray system" in the fourth line of paragraph 1 2 2 on
page 2 of the Explosive Destruction Technology (EDT) Destruction Plan
The Destruction Plan is revised to incorporate the suggested revision
27) There is an asterisk following M2A1 in the Designation column in Table 1 on page 3 of the
Explosive Destruction Technology (EDT) Destruction Plan that does not appear to have any
meaning If there is a missing reference, it should be added or the asterisk should be deleted
The reference to the asterisk that reads "estimated number of process leaker" is deleted, the
number of mortar rejects is now known because the TOCDF Mortar Campaigns have been
completed The number 20 is deleted from the table, and the 2 actual HT mortar rejects are
added to the number of HT mortars shown in the table (115 + 2=117)
28) The comments column of Table 1 on page 3 of the Explosive Destruction Technology
(EDT) Destruction Plan is confusing The comments are broken up into rows when it appears
that they should be grouped into one cell for each Munition Type Please clarify
The formatting of Table 1 is revised to merge rows under the associated munition type
specified in the first column of the table
29) On page 12 of the Explosive Destruction Technology (EDT) Destruction Plan, the word
"prevent" in the next to last line of paragraph 1 6 2 4 should be "prevented "
The Destruction Plan is revised to incorporate the suggested revision
Page 13 of 45
30) The next to last sentence in paragraph 1 6 5 on page 13 should be revised to read, "A spill
involves the release of a type or quantify of a hazardous waste or materials which, when spilled,
become hazardous wastes, that poses a threat to human health or the environment, this includes
an uncontrolled fire or explosion "
The Destruction Plan is revised to incorporate the suggested revision
31) On page 14 of the Explosive Destruction Technology (EDT) Destruction Plan in
paragraph 1 6 5 2 the acronym TOCDF is misspelled
The Destruction Plan is revised to incorporate the suggested revision
32) On page 14 of the Explosive Destruction Technology (EDT) Destruction Plan in the first
paragraph under 1 7 Monitoring, it states that the target agent for the monitoring plan is HD In
paragraph 1 7 1, it states that HD and HT will be used as the target compounds Which
statement is correct'' Please explain since H, HD, and HT will all be treated in the DAVINCH
The target analyte of the MINICAMS and DAAMS is distilled mustard (HD) Paragraph 1 7 I
is revised to remove the reference to HT
33) On pages 15 and 16 of the Explosive Destruction Technology (EDT) Destruction Plan are
listed the EG&G, TOCDF and DCD support functions Please add the word "contractors" to the
second bullet under 1 8 on page 15 Under paragraph 1 8 5, it states that EG&G and DCD will
provide a temporary 90-day storage location Who will be in charge of waste management for
the DAVINCH site including characterization, storage and shipment Somewhere in the plan
should be language that explains how waste will be managed and who will be managing it
The Destruction Plan is revised to incorporate the suggested revision
Regarding the management of waste residues generated by DIVINCH'^'^ operations, it is the
responsibility of VersarO/ECBC to
• Arrange for waste containers and labels, containerize the waste, and manage wastes in
satellite and 90-day storage areas while they remain at the DAVINCH'TM site It is also the
responsibility of Versar©/ECBC to collect samples of the waste residues and to perform
headspace monitoring The waste samples are analyzed by ECBC to determine their status
relative to the mustard Waste Control Limit (WCL)
• Collect samples of the waste and obtain associated waste analyses from off-site laboratories
that are certified by the State of Utah (Versar©)
• Arrange for the fransfer of the wastes to the TOCDF Waste Management organization
Once the wastes are transferred from the DAVINCH'''^ site to TOCDF, TOCDF is responsible
for them, as if the waste were generated by TOCDF (i e , TOCDF will store the wastes and
arrange for their off-site treatment and disposal at a Subtitle C TSDF)
The Destruction Plan was not revised to include this description Ultimately the waste manifest
used to transfer the waste to an offsite Subtitle C TSDF will bear the DCD EPA ID number
Page 14 of 45
34) On page 18 of the Explosive Destruction Technology (EDT) Destruction Plan midway
through paragraph 2 2 1, the acronym "HDPE" is misspelled
The Destruction Plan is revised to incorporate the suggested revision
35) Table 4 on page 20 of the Explosive Destruction Technology (EDT) Destruction Plan
contains a row labeled 10-hrs/day Mode What is this*' Please explain this row
The row labeled 10-hrs/day Mode is included to show the time devoted to preventative
maintenance The planned DAVINCH'^'^ operational schedule for each week includes four
days of processing and one day of maintenance The maintenance day is planned as a 10-hr
work day The first column of the table shows that a visual inspection will occur each day of
operation The second column shows the activities that will occur once a week on the day
dedicated to maintenance and that those activities will require three operators two hours to
complete (for a total of six man-hours) The third column shows the maintenance and
inspection activities that will occur on a monthly basis and that it will take four operators the
entire 10-hr day to complete (for a total of 40 man-hours)
36) On page 24 of the Explosive Destruction Technology (EDT) Destruction Plan in the last
sentence of paragraph 2 5 5, the acronym DAVINCH is used twice The second occurrence
appears to be an error
The Destruction Plan is revised to incorporate the suggested correction
37) On page 26 of the Explosive Destruction Technology (EDT) Destruction Plan, the last
sentence of the second paragraph refers to Figure 4 This reference should be Figure 5 On page
28, the first sentence under 3 5 1 refers to Figure 5 This reference should be Figure 6 Also on
page 28, the first sentence in the paragraph following the bullet list under 3 5 1 refers to Figure
6 This reference should be Figure 7 On page 29, paragraph 3 5 5 refers to Figures 7 and 8
These references should be Figures 8 and 9 respectively On page 33, paragraph 3 5 5 1
references Figure 8 This reference should be Figure 9 On page 37, the second paragraph
references Figures 9 and 10 These references should be Figures 10 and 11 respectively On
page 46, the sentence at the top of the page refers to Figure 11 This should refer to Figure 12
On page 47, the first paragraph under 4 4 refers to Figure 12 This should refer to Figure 13
The Destruction Plan is revised to incorporate the suggested corrections
38) On page 27 of the Explosive Destruction Technology (EDT) Destruction Plan, Section 3 3
discusses systemization of the unit Please provide more details about the systemization and
ORR process What surrogate chemicals will be used''
The TOCDF plans to test the DAVrNCH^M operation by detonating a series of over-packed
Simulated Equipment Test Hardware (SETH) munitions after the Explosive portion of the
Operational Readiness Review (ORR) is complete and before the beginning of the Agent ORR
Both ORRs must be successfully completed before the DAVINCH^** will be allowed to process
chemical munitions
The overpacked SETH munitions are being processed to familiarize the operator with the
Linear Shape Charge (LSC) and Donor Charge explosive configuration associated with each
Page 15 of 45
munition/overpack combination that will be processed at the DAVINCH''^'^ In addition, these
tests will be used to assure the operator that the system has been installed correctly and is
operating as expected Surrogate testing was conducted in Japan The test results were
provided with the initial permit modification request (See response to DSHW comment #1)
39) On page 29 of the Explosive Destruction Technology (EDT) Destruction Plan in
paragraph 3 5 2 3, the word "resistances" in the middle of the fourth line should be "resistance "
The Destruction Plan is revised to incorporate the suggested correction
40) On page 33 of the Explosive Destruction Technology (EDT) Destruction Plan paragraph
3 5 5 2 states, "This phase is accomplished by " What phase*' Please clarify this sentence
The paragraph makes reference to the DAVINCH''"'*' process step titled Air Vacuum, during
which the sealed Detonation Chamber is evacuated Paragraph 3 5 5 2 is revised to include the
name of this process step
41) On page 33 of the Explosive Destruction Technology (EDT) Destruction Plan, paragraph
3 5 5 6 refers to paragraph 3 15 5 This paragraph does not exist in the plan Please correct this
reference
The correct reference is paragraph 3 5 5 5, and the plan is revised to correct the reference
42) On page 33 of the Explosive Destruction Technology (EDT) Destruction Plan, paragraph
3 5 5 8 mentions Electrostatically Charged Aerosol Decontamination solution Please provide
more information on this solution What is if Is there an MSDS available'' If so, please
provide a copy What is its purpose'' How is it used'' How often would this step be performed''
The term Electrostatically Charged Aerosol Decontamination (ECAD) solution refers to a
method of apply decon solution Various solutions can be applied in this manner depending on
whether the target contaminant is biological or chemical
The following is from a report generated that investigated use of an ECAD application for
remotely decontaminating a rail station (e g , subway)
"The ECAD process produces an aerosol fog of electrically charged droplets of a liquid
decontamination reagent These droplets repel one another and are attracted to surfaces and
airborne particles in any orientation Thus, ECAD is a reagent delivery system that minimizes
the amount of reagent used, thus potentially minimizing damage to materials and equipment
(depending on the reagent used), while still achieving complete coverage of the area to be
decontaminated "
"The promise of hydrogen peroxide based formulations (e g , Decon Green) should be
noted If the reactivity towards the treated materials is not of importance, bleach (or in general,
active chlorine formulations) could be equally effective against chemical and biological
agents "
Page 16 of 45
TOCDF will be provided with an MSDS prior to the time the selected DAVINCH decon
solution to be used in the ECAD arrives This MSDS will be made available to DSHW at that
time
43) On page 36 of the Explosive Destruction Technology (EDT) Destruction Plan, Section 3 7
lists operating procedures for the EDT and highlights those that will have a Division approval
role The EDT decontamination procedure is not highlighted but should be reviewed and
approved Please add this procedure to the list of those needing approval
The referenced procedure is marked to indicate that DSHW approval of the procedure is
required prior to DAVINCH''"'^ hazardous waste operations
44) On page 36 of the Explosive Destruction Technology (EDT) Destruction Plan in the
second paragraph under 3 9, there is a discussion about decontamination verification This
discussion states that headspace monitoring at the STEL level for HD will be used for this
purpose In the approved Closure Plan for the CAMDS facilify, the VSL and USACHPPM
health-based screening levels are used A short term exposure limit does not seem to be
appropriate for this Please explain why the STEL is to be used with the DAVINCH
The decontamination clearance level for the DAVINCH™ equipment is revised to the Vapor
Screening Limit (VSL) in both the Destruction Plan and in the revised Closure Plan Note
• The DAVfNCH™ will not be discarded when the scope of the TOCDF applicafion is
complete Rather, the DAVINCHT""^ and associated PAS will be moved to an off-site
Federal facility and stored there until its services are contracted out again
• The employees of the organization at the Federal facility that will store the DAVINCH™
equipment are trained chemical agent workers
45) On page 37 of the Explosive Destruction Technology (EDT) Destruction Plan, the last
sentence of the first paragraph on the page does not make sense Please revise
The last sentence is revised to read
The system will be removed and transferred to a Federal installation and stored by
an agency whose workers are trained in chemical agent operations The system
will not be discarded upon completion of the TOCDF project, but stored for fijture
operations Theroforo, the closure standard for components that are determined to
be decontaminated through agent monitoring results is the mustard STEL rather
than the Vapor Screen Limit (VSL)
Note, the Closure Plan has been revised to reference the VSL rather than the STEL
46) On page 38 of the Explosive Destruction Technology (EDT) Destruction Plan, the first
complete sentence in the first paragraph on the page states that hazardous waste will be removed
by the operating contractor Is this referring to Versar, ECBC or EG&G'' Please clarify
Page 17 of 45
The reference to the "operating contractor" is to Versar©/ECBC The waste will be
containerized and transferred to the TOCDF Waste Management orgamzation Versar©/ECBC
IS responsible for determining the decontamination status of the waste in regard to agent
contamination and in characterizing the waste analysis by SW-846 method Note the SW-846
method analyses will be conducted by an off-site State of Utah certified laboratory
The TOCDF will determine the applicable State and Federal waste codes to assign to the waste,
and store and manifest the waste to an off-site Subtitle C TSDF
47) On page 38 of the Explosive Destruction Technology (EDT) Destruction Plan, the second
paragraph under 3 10 states that the SSSP is located in Annex C This is incorrect Please
correct this reference
The sentence is revised to clearly explain that the annex referenced is an annex in the Site
Specific Safety Plan (SSSP), and not that the SSSP is found in Annex C of the EDT
Destruction Plan This sentence and others are revised as follows
The PAED for the EDT maximum credible event (MCE) is defined in Armex D of the
SSSP
Annexe of the SSSP for the EDT Site defines the MCE for Establishing PAED as the
detonation of 133 lb of TNTeq
48) On page 38 of the Explosive Destruction Technology (EDT) Destruction Plan, the first
paragraph under 3 10 states that access within the PAED will be restricted to personnel directly
involved with the chemical operations Inspectors from the Division will need access to all areas
of the unit in order to perform their oversight duties and should be considered to be involved
with the chemical operations If special training is required, this training will need to be
provided
The TOCDF acknowledges that the State of Utah Division of Environmental Quality (DEQ)
Compliance Inspectors cannot be denied "nght of access" to the DAVINCH''''^ location as
needed The only restriction, which is applicable to DAVrNCHT"^ operational persormel and
EG&G persormel as well, is that personnel cannot be present within the Environmental
Enclosure (EE) during a detonation All personnel are required to exit the EE prior to and
during the Detonation step of the process
Training regarding the unique hazards associated with the DAVrNCHT"^ operations will be
provided to DSHW representatives if requested
49) On page 38 of the Explosive Destruction Technology (EDT) Destruction Plan, Section 3 11
discusses waste analysis and the characterization of the munitions and agent to be treated Is
EG&G sure that the past sampling and analysis has properly characterized the waste to be
treated'' Is there any concern that the actual mercury level in the waste munitions is higher than
what has been reported in the pasf In light of the experience at TOCDF with the PFS, is there
any concern that mercury will migrate through the carbon filter, F440, and become an emission
problem*' Has this filter been sized properly for its intended purpose'' How will the filter be
monitored to ensure that mercury does not migrate through the filter and become an emission
problem''
Page 18 of 45
The TOCDF is confident that the wastes to be processed in the DAVINCH''''^ have been
sufficiently characterized The TOCDF collected samples from 155-mm Projectiles throughout
the munitions' campaign The concentration of metals in the sample did not present a concern
in regards to metals emission rates These data were submitted to DSHW
The TOCDF also collected liquid and solid samples from HT Mortars according to a sampling
plan approved by DSHW The results of this sampling were provided to DSHW The metal of
concern for mortars is mercury (Hg), and the analytical results did not show high
concentrations of it However, the analysis of Metal Parts Furnace (MPF) exhaust gas samples
collected during the processing of the drained HT mortars showed concentrations of Hg
sufficiently high to prevent TOCDF from processing them at the desired rate until the MPF
PAS Filtration System (PFS) became operational
Solid and liquid samples were collected from HD mortars and analyzed The results are
reported in the Parsons Engineering Design Study I Projectile Washout System (PWS) Testing,
Vol 1 of 3, 14 August 2004 The liquid HD samples were found to contain minimal
concentrations of Hg The solid samples (with solids comprising approximately half the fill of
the mortars) were found to contain Hg at an average concentration of 766 parts per million
A fiirther review of the above-referenced report shows that the drained and rmsed mortars were
placed in a Metal Parts Treater (MPT) where they were heated The exhaust gas from the
treatment was sampled, analyzed, and found to contain Hg The table below presents an
estimate of the total Hg present in the mortars to be processed by the DAVINCH''"'^ based on
the result determined from the available analyses previously described
Page 19 of 45
DAVINCH Mercury (Hg) Emission Estimate
Mortar Casing Hg Content'
MPT^ Charge Interval (mm) 15
Mortars processed (no) 34
MPT Gas Flow Rate (cfm) 55
Exhaust Gas Hg Cone (ug/scm) 188
Total Hg m 34 mortars (mg) 14 9
Mortars m DAVINCH Scope (no ) 135
Hg to DAVINCH from Mortar Casmgs (lb) 0 13
HD Mortar Fill Hg Content^
Solid Heel Hg Content (mg/Kg) 768
Solid Heel wt Fraction (%) 16
HD Mortar Fill wt (lb) 60
DAVINCH HD Mortar Scope (no) 18
Hg to DAVINCH from HD Mortar Fill (lb) 0 013
HT Mortar Fill Hg Content"*
HT Mortar Hg Content (mg/Kg) 197
Solid Heel wt Fraction (%) 5
HT Mortar Fill wt (lb) 5 8
Incidence of Solid Heel m HT Mortars (%) 33
DAVINCH HD Mortar Scope (no ) 117
Hg to DAVINCH from HT Mortar Fill (lb) 0 002
Total Hg to DAVINCH (lb) 0 15
DAVfNCH Fixed Bed Sulfur Impregnated Carbon 99 99 Hg Removal Efficiency (%) 99 99
Total DAVINCH Hg Emission (lb) 0 00001
'Estimate based on data taken from "Summary of Parsons Engmeenng Design Study I
Projectile Washout System (PWS) TesUng Final Technical Report Volume I of III", 14 August 2003
^MPT = Metal Parts Treater that was used by Parsons durmg the testmg,
from which Hg exhaust gas samples were taken durmg operation
^Source is "Summary of Parsons Enigneermg Design Study I Projectile Washout System (PWS)
Testmg", dated 14 August 2003, Tables 3-25 (liquid HD results) and 3-29 (solid HD results)
''Source is Table 6-37 of Summary cf Parsons Engmeermg Design Study I Projectile Washout System (PWS)
Testmg, Vol 1 of 3, 14 August 2004
The TOCDF acknowledges that the mass of Hg in the munitions was imderreported in the past
as demonstrated by the unexpected results of the MPF exhaust sampling conducted during the
initial attempt to process HT mortars The information that the HT mortar casings contained
Hg was available prior to the beginning of the initial HT Mortar Campaign based on the
Page 20 of 45
exhaust gas sampling results generated from the Parsons MPT testmg The amount of Hg
contained in the mortar casings is accounted for in the estimate above
The TOCDF Pollution Abatement System (PAS) Filter Systems (PFSs) have been in operation
for over a year They were installed to control the emissions from processing a subset of HD
ton containers that were estimated to collectively contain over 1,200 pounds of Hg as compared
to an estimated 0 15 poimds of Hg in the mortars to be processed in the DAVINCH™ The
MPF processed approximately 1,000 non-Baseline ton containers and over 64,000 mortars
The DAVINCH™ will operate for a total of approximately two months Of the two types of
mortars (HT and HD), the solid heel contained in the HD mortars has been shown to contain
Hg at an average concentration of 766 ppm There are 18 HD mortars to process in the
DAVINCH''"'^, and this number can be processed in one day There are 117 HT mortars to
process, and they can be processed in 6 5 days
The sulfiar-impregnated activated carbon filter was sized based on residence time, however, the
amount of Hg to which the filter will be exposed is very low Past operational experience has
shown that the Hg contained in treated munitions remains in the Detonation Chamber and
partitions to the ash
Furthermore, the TOCDF experience with a fixed-bed sulfiir-impregnated activated carbon
system has shown that the useful life of the carbon bed is influenced by the amount of Hg to
which the bed is exposed and the amount of exhaust gas that flows through the bed Therefore,
TOCDF has planned the order of munitions treatment in the DAVINCH'^'^ such that mortar
processing will occur towards the end of DAVINCH''"'^ operations This "order of processing"
will limit the amount of exhaust gas that flows through the sulfiir-impregnated activated carbon
bed once the bed is exposed to Hg
The Hg emissions from the DAVINCH^"^ are not a concern considenng the limited number of
mortars to be processed therein, the short duration of the operation, the amovmt of Hg contained
in the mortars to be processed, and the revised order of munition treatment
Finally, the TOCDF is proposing to collect exhaust gas samples and analyze those samples for
Hg during the time that HD mortars are processed These results will demonstrate the
effectiveness of the DAVINCH and associated PAS in minimizing Hg emissions (see cover
letter this comment response)
50) On page 39 the first full paragraph lists waste to be generated by the DAVINCH This list
should also include monitoring wastes, spent decontamination solutions, PAS filters, HEPA
filters, and dust/particulate and ash
The paragraph is revised to read
Waste generated by DAVrNCH'^'^ operations are metal munition and overpack
fragments, condensate formed by the oxidation of the hydrogen contained in the
chemical agent, munition burster and explosive LSCs and donor charges, spent
scrubber solution, monitoring wastes, spent decontamination solution, particulate
filters, ash, spent activated carbon, and discarded PPE
Page 21 of 45
51) On page 39 of the Explosive Destruction Technology (EDT) Destruction Plan, the last
paragraph on the page discusses re-monitoring of drums of metal fragments that have a first
reading above 0 5VSL No contingency is discussed in the event that the contents of the drum
are still above the acceptable level after a second round of monitoring Other areas of the
modification documents mention the possibility of treating these metal fragments in the MPF
Please provide language detailing how this will be handled
The paragraph is revised to read
If the monitoring results show a drum headspace result equal to or greater than
0 50 VSL,-_an additional air purge is performed and the headspace equalizing
procedure is repeated (i e , four hours at 70 °F) the drum is moved underneath an
intake vent to the Environmental Enclosure, opened and allowed to vent After
venting the container is resealed and the -The container contents are then
monitored again to determine the agent concentration relative to the 0 50 VSL If
the drum headspace monitonng results continue to be above the 0 5 VSL limit for
metal fragments and 1 0 VSL for PPE after venting, the drum and its contents will
be transferred to the TOCDF and processed through the Metal Parts Furnace
(MPF)
Note the venting of the drums containing munition and overpack fragments that have
been removed from the DAVINCH''"'^ Detonation Chamber is provided as a contingency
Historical DAVINCH™ operations have shown the destruction of the chemical agent
within the Detonation Chamber to the extent that chemical agent residues are not present
on the residues removed from the chamber Use of the MPF to ftarther treat
munition/overpack fragments that may fail headspace monitoring criterion is provided as
a contingency to a contingency
52) On page 40 of the Explosive Destruction Technology (EDT) Destruction Plan, the word
"steam" in the second sentence in the first paragraph and the first sentence in the third
paragraph on the page should be "stream "
The Destruction Plan is revised to incorporate the suggested corrections
53) On page 40 of the Explosive Destruction Technology (EDT) Destruction Plan, the second
paragraph mentions that some of the over-packs may contain packing material and absorbent
What will happen to these materials during the detonation process'' Will there be anything of
significant size leff If there are significant amounts of these materials remaining, it may have to
be segregated as a separate waste stream for sampling and analytical purposes
During the overpack testing that was conducted by the manufacturer of the DAVINCH™ in
Japan, SETH munitions were wrapped in plastic sheeting, inserted into overpacks, and
detonated using the same explosive configurations that will be used during TOCDF
DAVINCH''''^ operations The residues generated during these tests were of a consistent size,
which will enable collection of a representative sample for waste characterization The
component of the target munition with the most variability in size was the overpack
Page 22 of 45
For pictures of target preparation and typical waste residues, see pages 50 through 61 of the
Overpack Test Report that was submitted as Attachment 2 to the DAVINCH™ permit
modification request
54) On page 40 and Table 8 of the Explosive Destruction Technology (EDT) Destruction Plan
the analysis of spent scrubber brine and ash generated during operations of the DAVINCH is
discussed The ash and brine need to be analyzed for explosives and perchlorate Is there any
concern that all the explosives will not be consumed in the detonation and explosives residues
will remain on the metal fragments and in the ash'' Because this is a small operation and the
amount of waste generated is much less than that generated from the incinerators at TOCDF,
each individual container should be sampled and analyzed without the samples being
composited Agent and agent breakdown products should be added to the analysis
Environmental Protection Agency (EPA) Method 8095 is applicable to the analysis of
explosive in soils and water matrices The applicability of this method to ash samples is
unknown Rather than add this analytical parameter to the associated Destruction Plan table, the
TOCDF proposes to analyze the samples of ash and condensate for explosive that are collected
during the testing that will occur at the beginning of the 155mm H projectile single overpack
campaign (which is planned to be the first campaign) to determine if explosive is present in the
waste residues at concentrations greater then the Land Disposal Restriction (LDR) limit If so
TOCDF would continue to analyze spent brine and water for explosives
The TOCDF does not concur with the need to analyze the waste residues for agent breakdown
products since no other TOCDF-generated waste residue is analyzed for these constituents
Additionally, it is the WCL that is the measure of compliance when determining whether the
treatment process has sufficiently destroyed the chemical agent to a level that allows the
transfer of waste residues to an offsite Subtitle C TSDF The WCL is based on the agent
concentration in the residue, and for mustard the limit is less than 200 parts per billion
The TOCDF does not concur with the suggestion to increase the sampling and analysis
frequency of waste residues The number of samples proposed to be composited into one
sample for analysis was determined by estimating the number of drums that would be generated
during the treatment of each type of mumtion/overpack combination The number of drums
proposed to be sampled during each sample/analysis event ensures the analysis of residues
generated from each munition/overpack combination
55) Table 8 on page 42 has a footnote 5 reference in several of the columns but no footnote
exists Please revise
The footnote reference is deleted
56) Table 8 on page 42 lists a TOCDF procedure for agent analysis Will EG&G personnel be
performing this analysis or will ECBC personnel be performing the analysis usmg the TOCDF
procedure''
The agent screen conducted on waste residues will be conducted by Versar©/ECBC personnel
at the Mobile Laboratory A procedure developed by ECBC will be used for this analysis
Table 8 is corrected to show the applicable procedure
Page 23 of 45
57) On page 43 under heading 3 12 2, the document states that leaking overpacks will be
repacked, then shipped back to storage Please explain why they are sent back to storage and
what will happen to them after that
Overpacked munitions are delivered to the DAVINCH''"'^ in a box truck The sealed storage
compartment is monitored for agent If the monitoring results are confirmed to be greater than
0 5 VSL the delivery is not accepted and the contents of the truck are returned to DCD to be
overpacked and processed by the DAVINCH at a later date
If the leak occurs after within the DAVfNCH'^'^ Environmental Enclosure the overpacked
munition will be placed in a plastic bag to stop the release of agent vapors and prevent
contamination and the bagged overpacked munition will be treated in the DAVINCH in the
intended manner
58) Section 4 0 of the Explosive Destruction Technology (EDT) Destruction Plan discusses the
organization for the EDT project How many operational/monitoring and lab teams are
proposed for the DAVINCH Operations'' How often will they rotate'' Are there any QC
personnel Please provide a list of each organization (CMA, EG&G, DCD, Versar, ECBC) and
list exactly what the responsibilities of each organization are (e g, ECBC - air monitoring, waste
analysis, DAVINCH operations)
The data quality review will be conducted by ECBC personnel located on-site
The number of personnel required to operate the DAVfNCH is currently being determined
A organization chart is provided in Annex G, page 7, Figure 2
59) On page 47 of the Explosive Destruction Technology (EDT) Destruction Plan, the last two
paragraphs on the page refer to Tables 8 and 9 These references should be to Tables 9 and 10
respectively
The Destruction Plan is revised to incorporate the suggested corrections
60) On page 48 of the Explosive Destruction Technology (EDT) Destruction Plan in the
Qualification/Experience column of Table 10, the acronym OSHA is misspelled Also, this table
does not address qualifications for monitoring personnel
Table 10 is revised to correct the misspelling and to include the qualifications for monitoring
personnel
61) In Annex A, there is no definition of the acronym "CBARR" used on page 46 of the
Explosive Destruction Technology (EDT) Destruction Plan Please provide this definition
Please provide the definitions for "CEES" and "n-DBS" as well
The acronyms CBARR, CEES, and n-DBS are added to Annex A
62) The following definitions in Annex A need to be corrected
DAVINCH - Detonation of Ammunition in a Vacuum Integrated Chamber
DSHW - Division of Solid and Hazardous Waste
Page 24 of 45
OSHA - Occupational Safety and Health Administration
The suggested corrections to Annex A are included
63) Annex B, page in, Table 9-1 is located on page 31 not page 32, Table 9-2 is located on page
32, not page 33, Table 11-1 is located on page 34, not page 35, Table 11-2 is located on page 35,
not page 36, Table 11-3 is located on page 42, not page 43
The suggested corrections are made to the revised Annex B provided with this submission
64) Annex B, page 1, Section 1 0 Applicable Monitoring and Laboratory
procedure/requirements should be at least as restrictive as TOCDF's Permit Specific
procedural changes that are unique to this process should be addressed in this modification
The personnel that will operate the DAVINCH'^'^ are provided by the ECBC They are
experienced in the destruction of the chemical munitions that are not part of the national
stockpile These personnel will adhere to requirements specified in a Laboratory Monitoring
Quality Confrol Plan (LMQCP) that meets the requirements of the Chemical Materials
Command (CMA) Laboratory Monitoring Quality Assurance Plan (LMQAP) and the
Monitoring Concept Plan (MCP)
65) Annex B, page 1, in the first paragraph under 1 1, it states that 351 reject munitions will
be treated The table m Permit Condition VIII H 5 lists 398 items to be treated Please clarify
these discrepancies See comment 13 above regarding the exact count of items to be treated in
the DAVINCH
The total number of munitions to be processed by the DAVINCH''"'^ is corrected from 351 to
333 The total number of items to be processed by the DAVINCHT'^ IS now 333 munitions and
47 agent samples
66) Annex B, page 1, Section 1 1, Please justify an alternate baseline instead of the required
30 days
The EDT project will perform standard initial (28-day) and continuing baseline studies
67) Annex B, page 2, Section 11, What is the frequency of agent challenge on the stack''
PMI4, the stack location NRT monitor, will be challenged at the instrument at the start and end
of daily destruction operations Historical monitoring at the Worker Population Limit (WPL)
will be performed on the stack This combination exceeds the monitoring requirements for a
filter stack
68) Annex B, page 3, Section 1 5 states that unmasked workers should not exceed STEL and
WPL limits but the agent monitoring plan has the monitoring for worker protection being done
at the VSL level It appears that this should be STEL in most cases and possibly WPL in some
Please review the entire monitoring plan with regards to the use of VSL and STEL and clarify
this issue
Page 25 of 45
Annex B was revised to remove STEL references The STEL is based on a time weighted
concentration The NRT are managed to alarm at a concentration that is equal to the STEL 15
minute exposure (i e , the VSL) The NRT sample/analysis cycle used for this application
however is less than 15 minutes
69) Annex B, page 5, the last sentence in the paragraph above Section 4 0 states that all
monitoring devices used for CWM detection will satisfy the requirements in the CMA-LMQAP
The TOCDF-LMQAP should be incorporated as an Annex to this plan and followed instead of
the CMA document
The ECBC will use their LMQCP, which meets the requirements of the CMA LMQAP and
MCP The EDT project will perform standard initial (28-day) and continuing baseline studies
70) Annex B, page 8, Table 4-2 needs to be reformatted to show the information properly Is
the value listed for the 12-hour WPL while using SCBA correcf This value decreased when all
the others increased
The table has been verified and corrected
71) Annex B, page 10 Please specify that the DAAMS tubes are TENAX for mustard As a
reminder, all monitoring requirements specified must meet in the TOCDF LQCMP
All DAAMS tubes used will contain Tenax® as the solid sorbent material
72) Annex B, page 10, Section 5 3 states that MINICAMS may be used to monitor at the
STEL, WPL, VSL and IDLH concentrations Will they be used to monitor for WPL and IDLH
at the DAVINCH site''
Paragraph 5 3 is corrected to state that NRT monitors are configured to detect agent at the VSL
73) Annex B, page 11, Section 5 4 references a Reporting Limit (RL) but does not provide
one Please specify the reporting limit or make reference to the location in the plan where this is
specified
The RL for WPL DAAMS methods is 0 5 WPL The RL for NRT confirmation DAAMS
samples is defined as a positive response based on a mimmum peak area which is determined
during the method development This information will be provided to DSHW pnor to the
beginning of agent operations
74) Annex B, page 11, Section 5 5 discusses dilution air flow controllers What is the ratio for
the dilution air flow on these monitors''
A Dilution Air Flow Controllers (DAFC) will be required at the PMI sampling location The
dilution ratio will be determined during systemization
75) Annex B, page 11, Section 5 6 The Stack and upstream retention tank monitoring location
(PMI) are all critical for processing and will have continuous/staggered agent monitonng
systems The HVAC monitor (PM13) will have a redundant monitor
Page 26 of 45
Staggered NRT monitors will be placed on the PMI location (upstream of the Retention Tank)
only There will be no redundant monitor at PMI 3 locations Considerations for this agent
monitoring configuration are as follows
• The source of agent is the Detonation Chamber The PMI location monitors Detonation
Chamber exhaust gas agent concentrations prior to this exhaust gas mixing with EE
ventilation air
• Munitions are not stored in the EE continuously Only the numbers of munitions or agent
samples that can be processed in one day are delivered to the DAVrNCH^"^ EE
• DAAMS systems continuously sample the exhaust gas exiting the DAVINCH'^'^ and EE
HVAC filter system Common Stack The DAAMS tubes collected from this location are
analyzed to create a historical record of agent emission from DAVFNCH''^'^ operations
76) Annex B, Table 5-1 states that critical NRT monitors are equipped with UPS but Table 7-
1 indicates that ALL NRT monitors have UPS This statement appears again on page 17 in the
first paragraph under 6 0 If it is true that all monitors have UPS, please delete these statements
If not, please clarify which monitors are considered critical and will have UPS Table 5-1 also
states that the size of the DAAMS tubes may vary depending on the agent operation Why
should they vary on this project where only one agent is being monitored'' Please provide the
DAAMS tube size and specifications Where are the specifications detailed'' Please explain what
a chromosorb moisture detection disk is
Table 5-1 is consistent with information included in Table 7-1 Table 5-1 reference shows that
critical monitors are supported by Uninterruptible Power Supply (UPS) system Table 7-1
shows which monitoring systems are supported by the UPS Note not all monitoring systems
are supported by the UPS Table 5-1 is further changed to indicate that 6-mm Tenax® tubes
will be used The specifications for tube construction are in the ECBC DAAMS Internal
Operating Procedure (lOP) The reference to a chromosorb moisture detection disc (indicator)
relates to NOx filters The chromosorb reference is deleted, as ECBC will not be using the
moisture indicator with their NOx filters
77) Annex B, Table 5-2 on page 16 lists Toxic gas mixtures under support gases Please list
the toxic gas mixtures that will be used or delete those that will not be used
The reference is deleted No toxic gas mixtures will be used on site
78) Annex B, page 17, Section 6 1 states that a qualitative method will be used for
confirmation monitoring A qualitative method has not been approved A quantitative Class 1
method as defined in documents referenced in Attachment 3 to the TOCDF Part B Permit will
need to be used Please revise this section accordingly
Based on previous State approval for CMA Non-Stockpile operations (Dugway EDS), and in
accordance with CMA guidance, ECBC uses a class III NRT confirmation method Although
the method is officially qualitative, ECBC reports any detectable amount of agent m a
confirmation method sample
Page 27 of 45
79) Annex B, pages 20 through 22, Table 7-1 The header row of this table needs to be
formatted so that it continues on each page
The table has been reformatted
80) Annex B, page 20, Table 7-1 Monitors noted in Table 7-1, AM4 and AM5 used to point
source monitor personnel should have a footnote describing this waste characterization process
of the suits
Any personnel monitoring performed in these airlocks does not serve as waste characterization
of PPE Waste characterization of bagged or drummed PPE will occur in the post-treatment
area
81) Annex B, page 20, Table 7-1 has two alarm levels for monitor AM7, 0 5 and 1 0 VSL
This should only be 0 5 VSL similar to the MPF Discharge Airlock.
The table has been revised to include the reporting limits of 0 2, 0 5, and 1 0 VSL, depending
on the operatton being performed
82) Annex B, page 22, Table 7-1 shows the monitoring level for the Stack monitor PM14 to be
VSL/WPL Shouldn't this be just VSL'' Please explain
PMI4 will operate at the VSL In addition, there will be a historical DAAMS collected at the
filter stack at the WPL concentration
83) Annex B, page 22, Table 7-1, footnote 4 should be revised to include NRT malfunction
and power loss in the conditions that cause automatic activation of the recirculation loop
This IS a fiinction of the Kobe DAVINCHTM control software, not the ME^ICAMS The
Distributed Control System code will include commands to stop the flow of detonation gas past
the Retention Tank if there is a loss of power or if one of the NRTs malfunctions
84) Annex B, page 22, Table 7-1, footnote 7 should state that the DAAMS tubes for the stack
will be collected and analyzed every four hours
Historical monitoring of the filter stack exhaust will be collected and analyzed every 8 hours
durmg daily destruction operations There are two sets of DAAMS on the stack that exhaust
the combined exhaust gas from the DAVfNCH'''** and the EE HVAC carbon filter system The
WPL DAAMS will be collected and analyzed every 8 hours throughout agent operations
85) Annex B, page 22, Table 7-1 footnote 8 states that there is one MINICAMS spools
between bed locations on each filter unit and that there is a separate DAAMS on each location
Some explanation needs to be provided in the plan on how the spooling works and how the
DAAMS tubes are set up and analyzed The QC also needs to be explained
Section 7 1 11 is updated to include a description of the monitoring approach for filter units
86) Annex B, page 24, paragraph 717 Please notify the Division prior to smoking testing
activities so a representative may be present to observe
Page 28 of 45
A smoke testing demonstration will be scheduled and DSHW will be notified
87) Annex B, page 24, paragraph 7 1 10 2 All lab areas (monitoring/analytical) regardless of
the agent standard level will require monitoring Any filter systems associated with the lab
should also have monitoring
Army safety regulations and CMA do not require monitoring of laboratory areas for non-surety
operations, they also do not require monitoring of mobile laboratory filtration systems
Monitoring is, however, provided in the laboratory using DAAMS only Agent monitoring is
not provided on the carbon filter that supports laboratory operations since the laboratory will
manage only RDTE solutions
88) Annex B, page 25, paragraph 7 1 12 states in the second sentence that first entry
monitoring is one complete cycle First entry monitoring should be at least two complete cycles
Please revise the sentence
Section 7 112 will be changed to reflect that first entry monitoring (FEM) will be conducted
using one complete cycle preceded by a purge cycle to ensure the sample line is filled with the
intended sample The text will also be clarified as this paragraph pertains to FEM prior to
personnel entry into the EE
89) Annex B, pages 25 and 26, paragraphs under 7 1 13 state that headspace monitoring is not
being used to support disposition of material On page 15 and 16 of the modification document
and again on page 39 of the Explosive Destruction Technology (EDT) Destruction Plan, it states
that headspace monitoring will be used to evaluate metal munition and overpack fragments for
agent contamination and make a waste determination These statements seem to be
contradictory Please clarify
The wording of 7 1 13 is revised Headspace results will be used to characterize wastes (PPE
and metal fragments)
90) Annex B, page 26, first paragraph on the page states that headspace monitoring will be
one complete sampling cycle A minimum of two complete cycles should be used Please revise
the sentence
The text is modified to indicate that one complete cycle preceded by a purge cycle will be
performed to ensure the sample line is filled with the intended sample
91) Annex B, page 26, second paragraph states that headspace monitoring for the purposes of
decontamination verification will follow the requirements of paragraph 4 4 of the CMA MCPO
Documents that are not provided as part of the permit modification should not be referenced
Please revise the text to include the requirements from paragraph 4 4 of the CMA MCPO
Text IS added to clarify the referenced requirements
92) Annex B, page 26, paragraph 7 1 14 states that monitoring of the waste drum area will be
done with a sample line hung less than two feet above the drums Which monitor is being used
for this purpose'' Is this being done to determine if there is any agent contamination on the
Page 29 of 45
outside of the drums'' If so, why are the drums not being tented in plastic and monitoring being
performed as it is at other parts of the TOCDF facilify'' Will waste containers be stored in the
environmental enclosure for longer than 24 hours''
The Momtonng Plan will be revised to clarify which MINICAMS will momtor the waste drum
area The exterior of the drums will be tented and monitored in Airlock 2 Waste containers
may be stored in the enclosure for more than 24 hours in designated 90-day storage locations
93) Annex B, page 26, Section 7 2 All historical monitors will need to be a quantitative
method or Class 1 method If a DAAMS that is not a Class 2 or 3 method is used, then any area
mass IS considered a confirmed alarm from the NRT
Based on previous State approval for CMA Non-Stockpile operations (Dugway EDS) and in
accordance with CMA guidance, ECBC uses a class III NRT confirmation method Although
the method is officially qualitative, ECBC reports any detectable amount of agent in a
confirmation method sample
94) Annex B, page 27, paragraph 7 2 6 1 states that laboratory work areas will be monitored
at the STEL and WPL Is this correcf If so, please justify the use of the STEL for this type of
monitoring
The current Monitoring Plan identifies monitoring in the laboratory work area (MINICAMS at
STEL level) Although Army safety regulations and CMA do not require monitoring for non-
surety laboratory operations, the monitoring is being provided per the requirement of
DAVINCH^** project management The monitor is calibrated to the STEL because the
laboratory will mange only RDTE solutions, the sample containers of waste residues that the
laboratory will receive are monitored for agent prior to being received at the lab, and the waste
residue sample containers are opened, and the samples are prepared for analysis under a fume
hood that vents to a carbon filter
95) Annex B, page 28, section 7 2 7 The Mobile Analytical Platform is not set up to vent
through the EE's HVAC system What are the specifications for the Mobile Analytical
Platform's laboratory ventilation system^ What happens if they get a hot tube'' Do they have
carbon filters on their ventilation system'' If yes, will it be monitored''
The GC/MS instruments will be properly vented to protect laboratory operators Carbon filters
are used on the laboratory filtration system, which wall not be monitored
96) Annex B, page 28, Section 7 2 7 Please substitute "quantitative confirmation" for
"qualitative confirmation" in all subsections of 7 2 7 as only quantitative confirmation methods
are allowed
Based on previous State approval for CMA Non-Stockpile operations (Dugway EDS) and m
accordance with CMA guidance, ECBC uses a class III NRT confirmation method Although
the method is officially qualitative, ECBC reports any detectable amount of agent in a
confirmation method sample
97) Annex B, page 28, Section 7 2 7 2 Please explain what "Chamber Discharge During
Venting" is
Page 30 of 45
The paragraph is revised to read
During chamber venting, the door to the Detonation Chamber is open and EE air is
drawing throug the chamber The DAAMS tubes will be used for qualitative
confirmation analysis of chemical agents The sample inlet will be co-located with the
MINICAMS™ HTSL distal end When the co-located MINICAMS^M alarms, the
DAAMS tube wall be retrieved to confirm or refute the alarm
98) Annex B, page 28, Section 7 3 states that first entry monitoring is one complete cycle
First entry monitoring should be at least two complete cycles Please revise the sentence Please
explain in more detail how first entry monitoring is performed Is first entry monitoring done
like it IS done for entering igloos at DCD'' How do you purge the sample line if you can't enter
the area'' Please clarify
The FEM for the EE will be conducted using one complete cycle preceded by a purge cycle to
ensure the sample line is filled with the intended sample Personnel will also enter the
Detonation Chamber to place the mumtions to be treated and, periodically, to remove ash and
perform inspections FEM of the Detonation Chamber will also be conducted prior to
personnel entering in the manner previously described
The paragraph in question is redundant and will be deleted The FEM is covered in section
7 1 12
99) Annex B, page 29, Section 7 4 Please add the level, 0 5, that samples will be monitored to
in the first sentence of the second paragraph Please delete the note about headspace monitoring
for decontamination verification This should be discussed in decontamination plans
Section 7 4 IS modified to reflect headspace monitormg is conducted using one complete cycle
preceded by a purge cycle to ensure the sample line is filled with the intended sample
Monitoring levels are addressed m Table 7-1 and depend on the item being monitored The
sentence regarding headspace monitoring for decontamination verification was clanfied and
verified for consistency with other sections
100) Annex B, page 29, Section 7 6 states that historical monitoring will operate only during
agent operations This sentence seems to imply that historical monitoring can be stopped if agent
munitions are not present Historical monitoring should be in operation shortly before the first
munitions arrive until closure of the unit Please revise the sentence to make this clear
Additionally, please clarify m the text that historical DAAMS tubes will be pulled and analyzed
every 12 hours with the exception of the stack which will require tubes to be analyzed every four
hours
Section 7 6 IS designed to be an overview of historical monitonng Details for each histoncal
location (including sampling frequency) are addressed in section 7 2, which is renamed
DAAMS Monitoring Historical monitoring of the filter stack exhaust (i e , WPL DAAMS)
wall be collected and analyzed every 8 hours dunng daily destruction operations
101) Annex B, page 29, Section 7 7 discusses vapor screening or samples prior to sending them
to the on-site lab For off-site analytical such metals and organics, is an extraction procedure
Page 31 of 45
performed prior to shipment off-site'' Which lab performs these analyses'' Please clarify in the
last sentence that this vapor screening applies only to samples going to the site lab and not for
waste characterization.
Section 7 7 IS renamed for clarity The section addresses sample container monitoring Sample
containers going to the site (mobile) lab will be headspace-monitored pnor to transport
Regarding the samples themselves, all residues sent to off-site laboratories for fiirther analysis
will be analyzed on site by the ECBC lab to verify that agent is not present above the WCL
This analysis is performed via solvent extraction
102) Annex B, page 29, Section 7 7 states that vapor screening will be conducted in accordance
with ECBC lOPs and DA PAM 385-61 Will these requirements be included in the analysis
plans and SOPs referenced on page 36 of the Explosive Destruction Technology (EDT)
Destruction Plan to be reviewed by the Division'' If not, the requirements should be spelled out
in this section
Additional information is added to section 7 7
103) Annex B, page 30, paragraph 8 0 states that ECBC Sample and Analytical Methods will
be used to characterize waste Will these methods be provided m the Analysis Plan and Analysis
SOPs listed on page 36 of the Explosive Destruction Technology (EDT) Destruction Plan'' If not,
they need to be provided for review and approval
Analytical methods will not be included in the Destruction Plan, but will be provided to the
State
104) Annex B, page 30 paragraph 9 3 states that the EG&G Site Safety and Health Officer
may be notified of NRT alarms Since EG&G is the operator responsible for all facility
operations under the EG&G permit, this should state that EG&G will be notified of all NRT
alarms no matter what the situation
Paragraph 9 3 references Table 9-1 (NRT Notification Matrix) The EG&G Safety Office and
TOCDF Environmental Shift Rep are required to be notified for all NRT alarms Upper EG&G
management notification will be through the notified EG&G representatives
105) Annex B, page 30, Section 9 4 discusses who will be notified of DAAMS sample results
All DAAMS sample data should be sent to an EG&G quality assurance person for verification of
data regardless if agent was detected or not Please revise the paragraph
Upon completion of ECBC internal quality review, data will be transmitted to EG&G for
verification
106) Annex B, page 31, Table 9-1 In the Possible Action column of the table, only the first row
lists Analyze DAAMS tubes as a possible action Is this because anything besides a single cycle
alarm is being considered agent detection and does not need confirmation'' This could also
imply that the DAAMS tubes are being pulled after the first cycle alarm The tubes should not
be pulled until the NRT has stopped alarming Please clarify this language The DAAMS station
sampling above the DAVINCH door should require a QP sample along with the air sample for
Page 32 of 45
verification Please provide a narrative in the monitoring plan detailing when and where QP
samples will be used
This table will be modified to add "analyze DAAMS tubes" to each section Since ECBC will
conduct a 28-day initial and continuing baseline studies, QPs will be rotated daily in
accordance with continuing baseline study requirements
107) Annex B, page 31, Table 9-1 In the three alarms row, the possible action column, it states
that filter system MINICAMS could be relocated to a post-bed location Isn't there already a
monitor at that location, PM13''
Each individual filter system has a dedicated MINICAMS that can stream-select between mid-
bed and post-bed for that filter system The standard operational configuration is to monitor the
mid-bed of each filter
108) Annex B, page 32, Table 9-2 The table formatting needs to be fixed How many
historical DAAMS stations are located in the EE and EE exhausf A review of Table 7-1 seems
to show that they are all for confirmation Please clarify the information in the Quality
Assurance Requirement row. The DAAMS tubes on this station should be sampled and analyzed
every 12 hours
The number and location of DAAMS samples in Table 7-1 will be updated to reflect all
historical and confirmation locations There will be one historical DAAMS location in the EE
and one at the filter stack The WPL tubes will be collected and analyzed for 8 hours Table 9-
2 will be revised All historical tubes are analyzed
109) Annex B, page 33, Section 9 5 mentions the Chemical Agent Worker Population Limit
(WPL) Excursion Plan but does not provide any details Please provide the details of this plan in
this section
A WPL excursion plan will be provided prior to operations
110) Please provide a copy of the DA Memorandum Performance Standard for Monitoring
Potentially Exposed Workers mentioned in paragraph 10 on page 33 of Annex B. Does EG&G
currently follow this documenf Does this document meet or exceed the current requirements
for EG&G''
The Department of the Army (DA) Memo is included with this submission The ECBC
procedures meet the requirements of the DA memo See Enclosure AA
111) Will the ECBC LMQCP and the lOPs mentioned in paragraph 11 0 on page 33 of Annex
B be part of the documents to be submitted for the Division review listed on page 36 of the
Explosive Destruction Technology (EDT) Destruction Plan'' If not, they need to be provided for
review and approval
The documents referenced will not be included in the Destruction Plan, but will be provided to
the State
Page 33 of 45
112) Annex B, page 33, Section 111 Method validations will need to be approved by the
Executive Secretary prior to implementation P&A studies will be in accordance with TOCDF
procedures Class III methods are not approved at TOCDF unless justification is provided and
approved
Method validations will not be available until ECBC is on site, and method precision and
accuracy studies are complete Based on previous State approval for CMA Non-Stockpile
operations (Dugway EDS) and in accordance with CMA guidance, ECBC uses a class III NRT
confirmation method Although the method is officially qualitative, ECBC reports any
detectable amount of agent in a confirmation method sample
113) Annex B, Table 11-1, page 34 Please specify the limits of 60-140% for line challenges and
75-125% for calibration and instrument challenges
Table 11-1 is revised to show an instrument calibrations and daily challenge tolerance range of
75 to 125% Paragraph 11 8 specifies a sample line challenge tolerance range of 60-140%
114) Table 11-2 on page 35 of Annex B needs to be reformatted to show the missing text in the
Frequency column and the Corrective Action column
The format is revised so that it is legible
115) Annex B, page 33, paragraph 111 and 1112 mention the use of mobile criteria which
seems to provide the operator with a different set of certification criteria Please explain the
difference and why mobile criteria would be applicable to the DAVINCH operations If mobile
criteria are to be used, please specify which instruments it will apply to Any mobile criteria
should follow procedures approved in TOCDF Permit Attachment 3
The reference to mobile criteria is deleted There are no plans for mobile NRT monitors
116) Annex B, page 33, Section 1112 discusses baseline method certification and validation
and references the CMA LMQAP Initial alternate baseline study method certification
requirements will need to follow the bolded sections of TOCDF's alternate baseline requirements
of Attachment 3 to the TOCDF Part B Permit Please state which stations will use alternate
baselines and which stations are defined as mobile stations These station definitions should not
be a moving target Monitoring cessation greater than 60 days will require an alternate baseline
to be conducted in accordance with TOCDF's procedures Monitoring cessation less than 60
days should follow procedures in Attachment 3 to the TOCDF Part B Permit
The EDT project will perform standard initial (28-day) and continuing baseline studies
117) Annex B, the QC requirements in Tables 11-1 and 11-2 cannot be evaluated until the
lOPs have been submitted for review The QP acceptance range of greater than 10% is not
acceptable Some parts of Table 11-2 seem to be cut off Please reformat the table as needed
Both Tables 11-1 and 11-2 have been reformatted
118) Annex B, page 36, Section 112 The calibration plans will need to be provided in specific
procedures for review and approval or specifics will need to be documented in this plan
Page 34 of 45
Calibration information for MINICAMS and GC/MSD systems will be added to section 112
119) Annex B, page 37, Section 11 2 1 The generic "may use" is not definitive Will the lab
use performance charts for tracking performance'' If not, how will the performance be
monitored'' Will ECBC provide a QC person onsite to review day-to-day data validation''
The use of performance charts is optional under the CMA and ECBC quality control programs,
and the ECBC will not use them ECBC is providing onsite QC personnel, so the data QA/QC
review will be conducted onsite
120) Annex B, page 37, Section 113 Please provide a site-specific table of the required QC for
each procedure performed instead of the reference to the CMA LMQAP
Section 11 3 IS updated, and references to the LMQAP have been removed
121) Please provide the sample frequency for NRT QP samples as mentioned in paragraph
11 3 1 on page 38 of Annex B
Section 11 3 1 IS revised to read
All NRT monitors methods used dunng operations will be challenged via OP samples
immediately following calibration and at the end of daily operations If no operations
occur on a given day, a challenge will be performed at least once during the day These
challenges will be designated as continuing baseline challenges If two consecutive
challenges fail to meet acceptance criteria, corrective action and data qualification is
required for all readings above 0 25Z according to the frequency identified in the CMP
LMQAP The QP challenge shall deliver agent to the instrument at 1 0 VSLZ
122) Annex B, page 40 Section 114 2, second paragraph discusses how corrections to errors
will be documented Along with initialing the "cross out" the date of the correction should be
included
The paragraph is revised to read
The sample identification system shall be documented, along with a method that relates
the field data to the samples All documentation of the samples shall be performed in
permanent ink If corrections are made to the data, the error will be crossed out once
and initialed and dated by the person documenting the data All field notebooks shall
become part of the project files
123) Annex B, page 40, Section 114 3 Samples will need to be analyzed for agent prior to
shipping to an off-site laboratory Which laboratory will perform this analysis, TOCDF or
ECBC
All residues sent to off-site laboratories for any analysis will be analyzed on site by the ECBC
lab to verify that agent is not present above the WCL This analysis is performed via solvent
extraction
Page 35 of 45
124) Annex B, page 41, Section 115 1 states that reports will be transmitted to EG&G on a
monthly basis EG&G, as the operator responsible for the proper operation of this unit, should
have access to this data on a daily basis
Upon completion of ECBC internal quality review, data will be transmitted to EG&G for
verification
125) Annex B, page 41, Section 115 2 discusses calibration curve data All calibration curve
limits will need to be specified and approved prior to implementation
Statistical analysis of calibration curve data will be addressed in the update of section 112
126) Annex B, page 41, Section 115 3 Data validation will need to be completed by an
independent reviewer prior to waste being shipped off-site Will TOCDF QC personnel be the
independent reviewer''
Upon completion of ECBC internal quality review, data will be transmitted to EG&G for
verification
127) Annex B, page 43, Section 13 0 EDT personnel will need to meet the TOCDF
requirements for those positions (e g, monitoring personnel, agent chemist, etc )
The ECBC will qualify and certify all monitoring and laboratory personnel in support of the
EDT project
128) Additional comments for Annex B Narrative or conditions need to be added for the
following
a Please explain what operations will cease until DAAMS analysis information is
available following an NRT alarm
Operational issues are addressed in the Destruction Plan
b All permit controlled agent monitors that are off line for more than 1 5 hours to have
the DAAMS tubes analyzed as the primary monitor
The ECBC can analyze NRT confirmation tubes for Resource Conservation and Recovery
Act (RCRA) NRT stations that are offline for more than 1 5 hours AH data from
confirmation tube analysis will be Class III data
c All sample line challenges will need to be performed through the NOx filters
The NOx filters will not be used for NRT sample lines, only DAAMS stations The
DAAMS stations for this project do not have sample lines
d Stack monitors need to be challenged at the distal end of the sample line
Page 36 of 45
The TOCDF does not concur with the need to challenge the stack momtors at the distal end
of the sample line The DAVINCH''"'^ is a batch process that will process up to 21 chemical
munitions and a maximum of 164 pounds of agent per day during the day shift, four days a
week A direct comparison of DAVINCH^"^ operations to a baseline incineration facility
that operates 24 hours a day with a permitted capability of processing 58,000 pounds of
agent per day is not pertinent
Additionally, the TOCDF incinerator NRTs are configured with Dilution Air Flow
Controllers (DAFC) because of the high moisture content of the exhaust gas The DAFC
allows the NRTs used to monitor the incinerator exhaust ducts and the TOCDF Common
Stack to be challenged at the distal end without removing the probe from the exhaust stack
The DAFCs are used only at the PMI sampling location monitoring To perform a distal
end challenge of the NRTs monitoring the stack, which combines the flows from the
DAVINCH™ and DAVINCH™ EE HVAC carbon filters, would require the probes to be
removed from the stack for each challenge since this monitor is not equipped with a DAFC
Operational history for mustard agent monitoring has not shown a loss of probe and sample
line performance in regards to agent transfer to the monitor over time when the sampled air
IS clean The exhaust gas passing through the monitoring location in question (i e , the
combined DAVINCH'^'^ and EE HVAC filter exhaust stack) is expected to be free of
contaminants that could cause degradation of the NRT response due to sample transmission
issues considering
• The exhaust gas is primarily EE ventilation air, which is the breathing air for
workers in the EE This air passes through carbon filter units equipped with HEPA
filters before reaching the sampling location The exhaust gas passing the sampling
location IS also primarily EE HVAC air (see flow rates shown on process diagrams
in Aimex D of the Destruction Plan)
The DAVFNCH''"'^ exhaust gas also passes through a HEPA-filter-equipped fixed-
bed carbon filter before reaching the sampling location
Note distil end challenge will be performed on the PMI monitors by virtue of the
monitors being equipped with DAFCs
e The change out frequency for NOx filters should not exceed seven days
The NOx filters will be replaced with the frequency indicated in the ECBC DAAMS lOP,
which has been shown to be adequate for experience
f Calibration and challenge frequencies need to be spelled out and not make reference to
additional documents that are not part of the permit or have not been provided as
supporting documentation
Calibration information for MINICAMS and GC/MSD systems will be added to section
11 2
Page 37 of 45
g All monitoring equipment exhaust will need to be vented to appropriate engineering
controlled areas or through a carbon filter
It IS ECBC practice to vent all monitoring equipment exhaust to engineering controls or to
carbon filters
h All DAAMS methods will need to be Class 1 methods or any peak in the agent retention
time window will be considered a confirmed alarm
Based on previous State approval for CMA Non-Stockpile operations (Dugway EDS) and in
accordance with CMA guidance, ECBC uses a class III NRT confirmation method
Although the method is officially qualitative, ECBC reports any detectable amount of agent
in a confirmation method sample
I Versar/ECBC will need to meet the requirements of the TOCDF monitoring plan and
the TOCDF LMQAP References to CMA documents should be references to TOCDF
documents or should be removed and specific requirements placed in the documents
The ECBC will use their LMQCP, which meets the requirements of the CMA LMQAP and
MCP The EDT project will perform standard initial (28-day) and continuing baseline
studies
J A corresponding QP will need to be sampled with all headspace monitoring of
treatment Results of the QP must be between 75-125% All stack DAAMS samples will
need to have a corresponding QP
The NRT headspace monitoring will utilize at least one QP sample Since ECBC will
conduct a 28-day initial and continuing baseline studies, QPs will be rotated daily in
accordance with continuing baseline study requirements
k Any NRT alarm on a monitor without a co-located DAAMS station for confirmation is
considered a confirmed alarm This should be placed in the text of the monitoring plan
All NRT stations will have co-located DAAMS confirmation
1 QP samples will need to be sampled and analyzed for all permitted stations daily with
the corresponding DAAMS tubes, all NRT are required to be challenged daily or more
frequently (every four hours) depending on location
Since ECBC will conduct a 28-day imtial and continuing baseline studies, QPs will be
rotated daily in accordance with continuing baseline study requirements
m QL will need to bracket the sample analysis (beginning and end) and every 20 samples
QL must meet the 85-115% recovery
The ECBC will analyze QL samples as continuing calibration verification samples in
accordance with Table 11-2
Page 38 of 45
129) Annex C, page C-2, paragraph 7 0 should be revised to read, "The inspection forms will
be maintained on-site at the EDT for review access "
The suggested change is mcluded m the revised Annex C mcluded with the submission
130) Annex C, Table C-1, page C-3, Item 1(c) Wouldn't the lid potentially sustain the same
type of damage as the outer shell and inner liner'' Shouldn't it be inspected for the same things''
The inspection of the lid is added to the inspection critena
131) Annex C, Table C-1 There are several items in the table that do not belong as permitted
inspections The following items typically are not listed in permit controlled inspection
schedules Items 11,12,13,14,15, and 16 Please explain why these items are included in the
schedule
The referenced items are deleted from the inspection tables
132) Annex C, Table C-1, Item 31 Please clarify the challenges are performed daily or every
four hours (stack) System verification such as heated lines, connection, gases may be inspected
three times a week
Stack monitor sample lines will be challenged at the same frequency as all other sample lines
on site PMI4, the stack location NRT monitor, will be challenged at the instrument everyday
at the start and end of daily destruction operations System verification checks will be
performed weekly
133) The inspection forms will need to be reviewed and approved prior to being used but do
not need to be incorporated into Annex C
The inspection forms will be available for DSHW review pnor to the beginning of
DAVINCH™ hazardous waste operations
134) Annex E, page E-4, first paragraph after the bullet list discusses decontamination
solutions in general and references Army Field Manual 3-5 and Table 1 from 40 CFR 268 45
Because it is not the intention of EG&G and Versar to dispose of the DAVINCH, the criteria
listed in Table 1 does not apply This paragraph should simply list the types of decontamination
solutions that are to be used and why each is appropriate for chemical agent decontamination
More detail should also be provided on cleansing shots and ECAD and their purposes
A description of the purpose of cleansing shots is added to page E-4 A cleansing shot refers to
the practice of placing donor explosives in the Detonation Chamber to remove contaminants
from previous detonations of chemical munitions Chemical mimitions are not added to the
chamber during a cleajising shot The entire energy of the explosive added is for the purpose of
destroying any residual agent that may reside in the chamber as determined through agent
monitoring Additionally, a cleansing shot may be used as a best practice for operators of
Detonation Chambers The DAVINCH''''^ is only one type Detonation Chamber, there are
others, and all use cleansing shots as a means of decontaminating their Detonation Chambers
Page 39 of 45
135) Annex E, page E-5, first complete paragraph on the page and page E-10, first paragraph
following the bullet list, top of page £-11, second paragraph on page E-12 These paragraphs
mention wipe sampling as a means to determine if decontamination has been adequate See
Comment 1 regarding this subject
References to wipe sample have been removed from Annex E
136) Annex E, page E-5, Table E-1 The value, 0 003 mg/m^, shown in the table as the air
monitoring performance standard is not an eight-hour TWA as stated in the table. This value is
actually the STEL, which is a 15-minute exposure limit
The value in Table E-1 has been revised and is now referenced as 1 VSL This value is chosen
because the DAVINCH™ and associated equipment will not be disposed of upon completion
of operations at the DCD Rather, the DAVINCH''"'^ will be disassembled and transported to a
Federal installation whose workers are trained in chemical agent operations, particularly the
operation of EDT systems It will be put in storage until another application for its use arises
137) Annex E The closure plan should specify the 10 step process as specified in the CAMDS
closure procedures Please review the current CAMDS closure plan to ensure that closure of the
DAVINCH follows a similar process Wipe sampling for verification of decontamination will not
be accepted An approved decontamination plan will need to be used to accomplish closure of
the unit
The requirements included in the CAMDS closure plan are not applicable to the DAVINCH'^'^
since the DAVINCH™ and associated equipment will not be discarded after completion of the
TOCDF project Rather, the DAVINCH^'^ will be decontaminated, disassembled, and
transported to a Federal facility and stored by an organization whose personnel are trained
chemical workers
138) Annex E, page E-6, Table E-2 In the first row in the Sampling Conditions column, the
word "equal" between "to" and "equilibrium" should be changed to "reach "
The suggested change is made to Table E-2
139) Annex E, page E-6, Table E-3 The SOPs and lOPs listed in the Analytical Methods
column of this table should be submitted for review and approval as part of the documents listed
on page 36 of the Explosive Destruction Technology (EDT) Destruction Plan
See response to DSHW Comment 11
140) Annex E, page E-8, last paragraph This paragraph states that the Versar EDT Program
Manager will certify closure This should state that the Versar EDT Program Manager and a
qualified Professional Engineer will certify closure Additionally, EG&G and Versar should be
aware that they must comply with Permit Condition IIJ 7 regarding notification of closure
The requirement that a Professional Engineer Certified in the State of Utah will certify closure
is included m the revised Annex E
Page 40 of 45
141) Annex E, Appendix E-1 does not discuss the sampling procedures to be used to verify
decontamination of the exhaust gas treatment equipment The procedure lists several methods
for sample collection, catch/grab and wipes but does not specify anywhere in the procedure
where they are used More detail is needed
Appendix E-1 to Annex E was revised to provide more detail on how agent monitonng will be
used during decontamination of equipment when operations are complete
142) Annex E, Appendix E-1 lists only one target analyte Additional target analytes should be
listed including metals and organics to allow for proper closure of the unit
Since the DAVINCH^"^ and associated equipment will not be discarded upon completion of
operations at DCD, the equipment must be decontaminated to the point that it can be
transferred to its intended storage location
The waste residues generated during closure will be analyzed for the same analytes as those
same waste residues that are generated during operations
143) Annex F, page F-2, Table F-1 states that TOCDF fire response will be dispatched in the
event of a fire at the DAVINCH site Shouldn't this be DCD fire response since they are
responsible for responding to all fires at TOCDF and TOCDF operated facilities''
Aimex F was revised to make reference to the DCD Fire Department
144) Annex F, page F-2, Table F-1 The acronym TOCDF is misspelled in the third column of
the fourth row
The suggested correction is included in the revised Annex
145) Annex F, page F-2, the last sentence on the page does not make sense and needs to be
revised
The sentence was revised as requested
146) Annex F, page F-3, the third and fourth paragraphs under 112 mention the TOCDF Fire
Department Shouldn't this be the DCD Fire Departmenf
Annex F was revised to make reference to the DCD Fire Department
147) Annex F, page F-4, the last bullet under 113 1 should be revised to read, "Placing
absorbed or pumped material into DOT-approved containers and managing appropriately in
accordance with all applicable permits and rules " The language as proposed would not allow
any flexibility in management of the waste
The bullet was revised to read
• Placing absorbed or pumped material into DOT-approved containers and
managing appropriately in accordance with applicable permits and rules
Page 41 of 45
pertaining to hazardous waste management and spill reporting for hazardous
material
148) Annex F, page F-4, the flfth bullet under 113 1 mentions following procedures from DA
PAM 385-61 Please provide the details from this document in the narrative
The bullet was revised to read
• Decontaminating the release area using installation policies and DA Pam 385-61,
including use of approved decontamination methods, including use of
decontamination solutions, and post-decontamination monitoring via MINICAMS
to the 1 0 VSL level, at 1 0 WPL, as needed
149) Annex F, page F-5, the last paragraph on this page deals with exposure to CWM
Shouldn't this paragraph be located under 113 2 Events Involving CWM instead of under
113 4 Industrial Accidents and Medical Emergencies Assistance''
The section also addresses Medical Emergencies Assistance The paragraph remains in the
same section as before, but was revised to read
For medical emergencies involving CWM exposures, personnel shall follow the
TOCDF Contingency Plan Additionally, procedures relative to medical
monitoring and post-exposure results are established by the TOCDF Medical
Director and will be adhered to in the event of individual exposure
150) Annex F, page F-6 and F-7, Sections 113 8 and 113 9 Please provide details that
explain how EDT personnel would secure the unit in the event of an evacuation or severe
weather event that occurs after a shot has been set up but not performed yet
A paragraph was added to each section to describe how personnel secure DAVINCH''''^
operation if required due to evacuation or severe weather
151) Annex F, page F-7 and F-8, Section 1 1 3 12 should also state that approval of the
Executive Secretary is required prior to the resumption of EDT operations
The affected paragraph was revised to read
Formal accident investigation will be conducted by the CMA/supporting safety
office in accordance with procedures identified in AR 385-10 Should changes to
EDT operations be required, those changes will be approved by CMA Risk
Management Division (RMD), ECBC Risk Management Office (RMO), and the
supporting safety office prior to resumption of EDT operations Approval of the
Executive Secretary is required pnor to the resumption of EDT operations
152) Annex F, page F-8, Section 1 2 1 Please delete the words, "at TOCDF" at the end of the
paragraph
Page 42 of 45
The suggested change is incorporated into the revised Annex F
153) Annex F, page F-9, the final sentence on this page states that WPL excursions will be
reviewed annually to determine any trends This project is short term. Excursions need to be
analyzed more often to determine if there are any trends Please revise this with a term more
appropriate to the time frame of this project such as weekly
The paragraph is revised to read
Investigations of all WPL excursions will be performed to determine the cause,
control the source, and prevent fiiture occurrences of the excursion Techniques
for controlling excursions might include conducting additional monitoring,
reviewing operational procedures, evaluating engineering controls, and/or other
procedures as determined by the SHO and EDT Site Manager All information
relevant to the investigation wall be provided to the TOCDF Clinic Instances of
excursions will be reviewed or analyzed at least monthly to determine any trends
154) Annex F needs to contain reporting requirements or make reference to the appropriate
permit conditions similar to paragraphs 9 4111 and 9 8 found in Attachment 9 of the TOCDF
Part B Permit
The notification and reporting section of Annex F was revised to read
113 11 Notification and Reporting
The primary responsibility for notification will he with the Crew Chief with assistance
from all other field personnel Table F-1 (shown previously) provides information for the
responsible person or agency notification In accordance with the appropriate Permit
Conditions, the Executive Secretary shall be notified within 24 hours if there is a
confirmed agent concentration in the DAVINCH"^** PAS and Environmental
Enclosure Combined Stack that is equal to or greater than 1 Vapor Screening
Limit (VSL) Required reports are made in accordance with R315-8-4 7(i) & (j) and
TOCDF Part B Permit Conditions
The operator must note in the operating record the time, date, and details of any incident
that requires implementing the Contingency Plan For any emergency event requiring
HAZMAT release reporting, the Control Room will notify the DCD EGG and the CMA
Shift Engineer, and provide a copy of the event report All reporting to the Army, local.
State, and Federal agencies will be handled by DGD
155) Annex F does not detail how personnel on site in the various buildings will be notified of
an emergency Please provide this detail
The DAVINCH site is equipped with an air horn that is used to notify the personnel in the
different trailers of an emergency
156) Is there a process or contingency for retreating or handling material from a shot if there
IS a mechanical failure or agent release problem'' Please explain
Page 43 of 45
If chemical agent remains in the Detonation Chamber after the detonation (as determined by the
NRT located at the PM2 sampling location (see Armex B or any Process Flow Diagram
drawing) a cleansing shot will be used If there is visible explosive remaining in the chamber
after a detonation an Ordinance Disposal (EOD) Team will be brought onsite to "render safe"
the explosives before operations resume
The DAVINCHi""^ system will undergo testing during the systemization and Operational
Readiness Review (ORR) when SETH rounds will be overpacked in the configurations as the
actual munitions to be processed, and detonated
157) Annex G, page 2, Section 1 1 in the second bullet the word TOCDF is misspelled the
second time it occurs
The suggested correction is incorporated into the revised Armex G
158) Annex G, page 2, Section 1 1 The list of applicable documents should include the
Explosive Destruction Technology (EDT) Destruction Plan and Annexes and the plans hsted on
page 36 of the Explosive Destruction Technology (EDT) Destruction Plan Please provide the
Division with a copy of the Kobe Steel Training Plan listed under Section 1 2
The training of the operator is scheduled to be conducted in early February 2011 A copy of
the training plan will be provided to DSHW when one is made available to TOCDF
159) Annex G, page 6, the fifth paragraph discusses the management of waste in a container
following detonation and clean-up of the detonation chamber The satellite accumulation and 90
day area rules will apply to DAVINCH operations
The TOCDF and DAVINCH™ operators intend to establish satellite and 90-day accumulation
storage locations wathm the EE
160) Annex G, page 23 In the first line of the first paragraph, the word "began" should be
"begin "
The suggested correction is incorporated into the revised Annex G
161) Annex G Please provide clarification as to which of the training courses listed in Annex
G will meet the requirements of R315-8-2 7(a) (3)
The following has been added to the revised Annex G
• The requirements in Utah R315-8-2 7(a) (3), which include 40-hour OSHA
training and refresher training carried by all operators prior to arrival at the
site, this includes, but is not limited to
(i) Procedures for inspection, use, repair, and replacement of facility
emergency and monitoring equipment (See Appendix 1, CBARR pre-
deployment training),
(ii) Communications or alarm systems (See Sec 3 13, Site Specific
Training),
Page 44 of 45
(ill) Key parameters for automatic waste feed cut-off systems (not
applicable),
(iv) Response to fires or explosions (See Sec 3 13, Site Specific
Training),
(v) Response to groundwater contamination incidents (See Appendix 1,
CBARR pre-deployment training),
(vi) Shutdown of operations (See Sec 2 3 1, EDT Operator Training)
162) Attachment 2, page 16 states that the remaining SETH and overpacks used in testing are
in storage at both locations How many SETH and overpacks are available at DCD for
systemization and testing of the equipment on site''
There are sufficient SETH and overpacks available to conduct systemization testing Prior to
processing the overpacked agent-filled munitions, TOCDF intends to test the DAVINCHi""^
system using overpacked SETH munitions The SETH rounds will be overpacked in the same
manner as the actual munitions, and will be prepared with donor and shape charges in the same
configuration as the munition/overpack combination that they are intended to represent The
DSHW will be notified as to the date and time of this testing so that they may be present This
testing will occur toward the end of the ORR
163) None of the drawings in Attachments 3 or 4 have PE stamps Utah law requires that
plans, specifications and reports prepared by or under the supervision of a professional engmeer
must bear the seal of the engineer when files with public authorities Please have the most
current revision of all drawings stamped as appropriate and re-submit them
The Piping and Instrumentation Diagrams (P&IDs) have been reviewed by a Professional
Engineer licensed in the State of Utah These drawings, bearing that seal, are included with
this submission in electronic format
Page 45 of 45
Enclosure AA
Performance Standard for Monitoring Potentially Exposed Workers Memo
EXPLOSIVE DESTRUCTION TECHNOLOGY (EDT)
DESTRUCTION PLAN
Submitted to:
EG&G DM I. Inc/URS
11600 Stark Rd.
Stockton, UT 84071
Subcontract DMB51843
Submitted by:
(^VERSAR
Versar, Inc.©
6850 Versar Center
Springfield, VA 22151
X^ovemberJOlO Deleted: April 201011
TABLE OF CONTENTS
LIST OF TABLES I\
LIST OF nGl^RES I\
EXEClTn E SITVIM \R\ \
1.0 INTRODUCTION 1
1.1
1.2
1.2.1
I.:.:
1.3
1.4
1.5
/.
/.
/.
/.
/.
/.
1.6
/.
/.
/.
/.
/.
1.-
/.
/.
1.8
/.
/.
/.
/.
/.
/.
/.
PliRPOSE I
ITEMS TO BE DESTRO^XD I
Tiii'iifi MiiiiiiioiL, J
Fill \ liiifiiiih 2
APPRO\ \L PROC ESS -I
HISTORIC AL PRECEDENT FOR EDT ^
SITE DESC'RIPTION(LNC'HT)LNC SITE PREPARATION REOHREMEINTS) ^
Eyiiiiiii^ Piivfil 9
iiliiiiiiiiiriiiivf 9
EDTSiic 9
Siiiiiiiiii 9
iililiiioiiiil (jdii' 9
Rfiiiicifil iccfii 9
E^lERCENC'^ PLAMNINC ANDCoNTlNCElNC•^ OPERATIONS 9
Siif Spfcific Siiffiy Pluii 9
Pivvfiiiioii of Siiililfii Ri'li'dii'i lo ilif Ein iroiiiiii'iii 10
Fiir PiYVfiiiioii 12
<. oiiiiiiiiiiiciiiioii Sviii'iii /.•'
S/Ji'll Ri'i/joiiii' /.•'
MONITORING I-I
Siiffiy Mr Moiiiioiiiiii / -I
Moiiiioriiiii Poiim N
EG&G. TOCDF. AND DCDSl'PPORT I-I
Ei/iii/jiiii'iii Eiiciliiifi /.i
L'liliiifi /.i
SiTiiiiiy /.i
Sill' PiYpiirniioii /.i
0/Ji'r<iiioiii Sii/j/jori /.i
Pliiiiiiiiiii Pfniiiiiiiiii I6
EDT Ojjfruiioiis lb
2.0 S\ STEM DESCRIPTION 17
2.1
2.3
0\TiR\nEw r
i.'oiicfpi of 0/Ji'r<iiioiii /'
Sviii'iii Di'iii^ii Ri'i/iiiiviiii'iiii /'
ENVIRONMENTAL ENCLOSIIRE(EE) DESCRIPTION IS
D-117.V(. //TM f onuiimih-m /S
EE Opfniiiiiii -Ircm Z*!
MAINTEINANCT: REQI'IREMENTS 19
Moiiiioriiiii Emii^if Dniiuiiif 19
Pivvfiiiivf Miiiiiifiiiiiicf 19
Ei/iiipiiii'iii Miiiiiifiiiiiicf Sclifiliilf 19
TABLE OFCONTENTS (conlinued)
2.4 DESIGN PEATiTiES 2n
J. 4.1 Dfioiiiiiioii <. Iiiiiiil'fy 20
2. -1.2 <. Iiiiiipiiiii Sviii'iii 21
2.-/.J MiiiiiiioiL, Hiiiiilliiiii liniiilliiiioii in i.'liiiiiil'fr 21
2. -I.-I i.'liiiiiil'fy Door \\<j\iil'lf Phil form 21
2.-/J 0(f-(J>i^ Eihcr 21
2.4.6 d(f-fJiii Hfiiifr 21
2.-I.' f'oolfi- 21
2.4. S 0(f-fJii!, .Sviifiii 21
2.4.9 V'liciiiiiii Piiiiipi
2.4.10 (. old Phiiimi OriJizfi- 22
2.4.11 f'oolfi- 22
2.4.12 Snubbcr 22
2.4.1 J SaOH Tank 22
2.4.14 0(f-iJ,i:, BloM fi- 22
2.4.1.^ Rfifiiiioii Tiiiik _V
2.4.16 Hfiiifr 2.^
2.4.1' I. iirl'oii Eilifi-i 2J
2.4.1^ Eyiiiiiiii Mr Blow fi: 2J
2.5 OTHEIR SiippoRT EQI'IPMENT 23
3.0 EDT OPERATIONS 25
3.1. S^STE1M DELFV E1R^ 2^
J.I.I. Traiiiporidiioii mul Dflivfiy of Main i.'liiiiiil'fr mul iiiocinifil i.'oiiipoiifiin _V
.•'./._''. Traiiiporidiioii mul Dflivfiy of Off-^Jiis TiYniiiifiii .Syni'iin _V
.•'./..•'. Dflivfiy of.Siippori Ei/iiipiiu'iii _V
3.2. S^STE1M INSTALLATION 2^
3.3. S^STEl^^z.ATlON 2"
3.4 OPEIRATIONAL READINESS RE\ [E\S 2"
3.5 OPEIRATIONS 2"
/ Opfrniioiiiil .Sii'pi 2^
2 Donor i. 'luiriif J"i
J <. Iiiiiiil'fr PiYpniiiiioii for Dfioiuiiioii 29
4 Implosion wiili Donor <. 'li<iri^i' 29
.i 0(f-(j<ii TiYiiiiiifni iiml Mr Plow P/jmci 29
3.6 THROIIGHPIIT 33
3." OPERATING PROCEDiTiES 3')
3.8 SCHElDliLE 3')
3.9 CLOSirRE 36
3.10 DESCRIPTION OFOc•cn'ANC'^ AND DESTRIICTION OF BnLDLNGS\MTHiN PifBLic-ACC ESS
EXGLliSION DlSTANC E(PAED) 3S
3.11 W ASTE ANAL^SIS PLAN 3S
3.12 PEIRSONNEIL Li\nTS AND PROTECTr\x EQITPMENT "(S
J. 12.1 Mrl'oriif EypoiniY Liinin i -\ELii '6
J. 12.2 EypoiniY Poinn '6
J. 12. J Pi'noiKil Proifciivf Ei/nipiiu'iii '6
TABLE OFCONTENTS (conlinued)
3.13 MITIGATION OF HAZ.ARDS (LNGLiTUNG CoNTLNGElNC•^ PLANS)
J.I
4.0
4.1
4.2
4.3
4.4
(. oniiiiniiifni
Siiffiy in EncloiuiY
PPE Eii Tcsiiiiii
Eini'rt^i'nry mulEvucuniion....
Eiiifriifncy Rf^ponsf ^riiom.
.\ Ifiliciil Suppori
ORGANIZATION 79
U.S. ARM> "9
STATE OF UTAH "9
CONTRACTORS Sn
EDT SITE OPERATIONAL ORGANIZ^ATION Sn
5.0 REFERENCES. 82
III
List ofTiibies
Table 1
Table 2
Table 3
Table 4
Table 5
Table 6
Table 7
Table S
Table 9
Table lo
(Characteristics ol" DCD Munitions 3
Projectei-I DCD In\ entorA- ol"(!)\ eq")ack Types ani.1 Munitions
lo be Processei.1 in ihe EDT 4
(!)\eq")ack SpeciUcalions 4
Schei-lule lor Pre\ enli\ e Maintenance 2()
TOC'DF EDT Throughput 35
Estimated Waste Generated from DAMNGH'^" Operations 39
TOODF DAMNOH'T^' Waste .Analysis Summary (On-Site) 41
TOODF DAMNOH'T^' Waste .Analysis Summary- (Orf-Site) 42
Role ol" Each (!)perations Group 4S
.lob ani.1 (Qualifications E.\perience 4S
List of Figures
F gure 1.
F gure 2
F gure
F gure 4.
F gure
F gure 6.
F gure 1.
F gure S.
F gure 9.
F gure lo
F gure 1 1
F gure 12
F gure 13
Munitions to be Destroyed by D.AMNGH'^" 2
EDT Proposed Site Location at TOGDF cS
EDT Site Location in .Area lo 7
EDT Site Oven iew S
Installation ani.1 ("ommissioning Schetlule 2cS
(\inceptual Steps of DA\"rNGHTM :S
Total DAMNGHT^" System 2S
DAMNGH'T^'OlT-GasTreatjnent Phases 31
EDT Block Flow Diagram 32
Insii.le Ghamber before ani.1 after Gleansing Shot 37
E(^AD Operation 37
TOGDF EDT Overall Organization 4cS
EDT Site (!)peration (!)rganization 47
.Annexes
.ANNEX .A. .Acronyms ani.1 .Abbre\ iations
ANNEX B. Monitoring Plan
.ANNEX G. Inspection Plan
ANNEX D. DAMNGHTM Operational Mode Diagrams
ANNEX E. Glosure Plan
ANNEX F. TOGDF EDT Emergency Response Plan
.ANNEX G. Training Plan
EXECUTIVE SUMMARY
The United States (U.S.) Army Chemical Materials Agency (CMA) is responsible for destroying
U.S. chemical warfare materiel. The Project Manager - Chemical Stockpile Elimination (PM-
CSE), established in 2006 by merging the Chemical Stockpile Disposal Project (CSDP) and the
Alternative Technologies and Approaches Project (ATAP), manages the safe treatment and
disposal of chemical agents and weapons stored at protected U.S. Army sites in Alabama,
Arkansas, Oregon, and Utah.
EG&G DMI, Inc., (EG&G) is contracted by the U.S. Army to operate the Tooele Chemical
Agent Disposal Facility (TOCDF) located on the U.S. Army Deseret Chemical Depot (DCD) in
Stockton, Utah. EG&G has a requirement for a technology to process^33 reject munitions that _,, - -[ Deleted; 351
have a high probability of exhibiting conditions that would not allow them to be processed using
baseline practices. Due to the apparent condition of the bursters and burster wells - and more
importantly, the high risks associated with destroying the problematic munitions with baseline
technology - new safer processes have been evaluated. The TOCDF researched other
technologies used to destroy chemical weapons and determined that Explosive Destruction
Technology (EDT) is the preferred alternative. Therefore, the DAVINCIF'^ Detonation In a
Vacuum-Integrated Chamber (DAVINCIF'^) technology will be used to destroy the target
munitions at TOCDF.
This Destruction Plan describes the process and procedures for destroying and treating over-
packed/leaking 4.2-inch Mortars, 155-nim Projectiles, and 47 samples containing chemical agent
(CA).
This process will run in parallel to TOCDF's current baseline operations. EG&G has contracted
for services to include a detonation chamber, exhaust gas filtration system, environmental
enclosure with an engineered cascade ventilation system, and all necessary subsystems and
operators as a complete package that will be delivered to, installed, systemized, staffed, operated,
closed, and removed from the DCD.
The agent fills to be treated consist of mustard (H), distilled sulfur mustard (HD), and thickened
mustard (HT).
This Destruction Plan is based on procedures used at two international sites: Kanda Harbor,
Japan; and Poelkapelle, Belgium, where the DAVINCH™ has successfully and safely destroyed
over 5,400 chemical munitions. The plan provides a description of the operations and sampling
strategy for this operation. The procedures described herein will ensure that the operation is
conducted in a safe, secure, and environmentally-sound manner.
EG&G is the lead for permitting with the State of Utah Department of Environmental Quality,
Divisions of Solid and Hazardous Waste (DSHW) and Air Quality (DAQ), which will provide
environmental regulatory oversight of the TOCDF EDT operations. These operations will be
permitted under a modification to the RCRA and CAA Title V Permits issued to the TOCDF by
the DEQ.
1.0 INTRODUCTION
The United States (U.S.) Army Chemical Materials Agency (CMA) is responsible for destroying
U.S. chemical warfare materiel. The Project Manager - Chemical Stockpile Elimination (PM-
CSE) manages the safe treatment and disposal of chemical agents and weapons stored at
protected U.S. Army sites in Alabama, Arkansas, Oregon, and Utah.
EG&G DMI, Inc., (EG&G) is contracted by the U.S. Army to operate the Tooele Chemical
Agent Disposal Facility (TOCDF) located on the Deseret Chemical Depot (DCD) in Stockton,
Utah. EG&G has a requirement for a technology to process 351 reject munitions that may be
difficult or unsafe to process using baseline practices. The TOCDF researched other
technologies used to destroy chemical weapons and determined that Explosive Destruction
Technology (EDT) is the preferred alternative. Therefore, the Detonation In a Vacuum-
Integrated Chamber (DAVINCH'^'^) technology will be used to destroy the target munitions at
TOCDF.
The DAVINCH'^'^ will support TOCDF as the approved chemical munitions disposal site for
over-packed leaker/reject munitions and agent samples. The DAVINCH™ is designed for a
maximum allowable explosive charge of approximately 133 pounds (lb) of net trinitrotoluene
explosive equivalent (TNTeq). The Chemical Warfare Munitions (CWM) are classified as
Hazard Division 1.2 in Department of Defense Standard 6055.9; therefore, associated Quantity-
Distance (Q-D) arcs are quantified as such. Descriptions of adjacent facilities, work to be done,
and operations are included in this submittal.
Additionally, CWM that are designated a waste destined for disposal are classified as hazardous
waste in the State of Utah, see the Utah Hazardous Waste Rules R315-2-1 l(e)(l)^ The
DAVINCH™ is a type of EDT that treats the chemical agent and energetic components of CWM
through controlled detonation facilitated by donor and Linear Shape Charges (LSCs) within a
detonation chamber.
Deleted: leaking CWM are classified as
hazardous waste in the State of Utah as
described by Utah Hazardous Waste
Code P999
The destruction of CWM is permitted and regulated by the TCODF Resource Conservation and
Recovery Act (RCRA) Permit. By these regulations the DAVINCH™ is classified as a Subpart
X Miscellaneous Treatment Unit.
1.1 Purpose
This Destruction Plan describes procedures for destroying and treating overpacked/leaking 4.2-
inch Mortars, 155-mm Projectiles, and samples containing CA.
1.2 Items to be Destroyed
Figure 1 shows pictures of the two munitions (i.e., projectiles and mortars) that are to be
destroyed by the TOCDF DAVINCH™.
TT
4.2-inch Mortar 155-mm Projectile
Figure 1. Munitions to be Destroyed by DAVINdFi^
1.2.1 Target Munitions
The DAVINCH™ system's design will accommodate TOCDF processing of the items shown in
Tables 1, 2 and 3.
1.2.2 Fill Materials
Documentation from DCD confirms that the stockpile munitions in question are filled with
mustard (H/HD/HT), as shown in Table 2. The over-packed items have been assessed using an
x-ray system that was conducted at Area 10 to determine the content levels, interstitial materials,
and configuration of the munitions targeted for destruction by EDT.
Table 1. Chiiriiclerislics of DCD Munitions
Designation Munition
Type Fill Explosi\es Comments
Igniter: M9
Fuze: PD MS
Burster: M14
(•threai.lei.1 on fuze) Length: 21.ol inches ('1S inches
w 0 ignition cartritlge)
Wii-lth: 4.2 inches
Total Wt: 24.CS7 lb ( 22 lb w o M2A1* 4.2-inch
Mortar
HT. 5.S lb
HD. cS.o lb
E.\plosi\e: Tetry l
E.\plosi\e Wt:
0.14 lb
Propellant: McS
Propellant Wt:
Length: 21.ol inches ('1S inches
w 0 ignition cartritlge)
Wii-lth: 4.2 inches
Total Wt: 24.CS7 lb ( 22 lb w o
E.\plosi\e: Tetry l
E.\plosi\e Wt:
0.14 lb
Propellant: McS
Propellant Wt:
ignition cartritlge ani.1 propellant
charges)
o.cS lb
Primer: M2SA2
Ml 04 1 55-m m
Projectiles
HD:
11.7 lb
Fuze: None
Burster: McS
E.\plosi\e: Tetrytol
E.\plosi\ e Wt:
.41 lb
Length: 2cS.S inch
Width: cS.oS2 inch
Total Wt: 95.1 lb
.Aluminum Bakelite Fuze Gup
Fuze: None
Burster: McS
E.\plosi\e: Tetrytol
E.\plosi\e Wt:
.41 lbs
Length: 2cS.S inches
Ml lo 1 55-m m
Projectiles
HD. 1 1.7
lb
Fuze: None
Burster: McS
E.\plosi\e: Tetrytol
E.\plosi\e Wt:
.41 lbs
Width: cS.oS2 inches
Total Wt: 94.59 lb
.Aluminum Bakelite Fuze Gup
Samples NA 452 ml HD NA NA Samples NA S25 ml HT NA NA
Table 2. Projected DCD Inventory of Overpack Types and Munitions
to be Processed in the EDT
Munition Type
Single Overpack Double Overpack
Munition Type M2A1 M13 M16
9x41
or
7x27
M16/M10 PA37/2 x 56 M16/12 x 56
4.2-inch HT mortar ( Deleted: lis 4.2-inch HT mortar 117
4.2-inch HD mortar 18 T ( Deleted: 20*
155-mm H projectile 68
155-mm H projectile 27
155-mm H projectile 16
155-mm H projectile 8 79
HT SAMPLES 41
HD SAMPLES 6
Deleted: * Estimated number of
process leakers.^f
Table 3. Overpack Specifications
Over Pack
Type
Exterior
Length
(inches)
Flange
Diameter
(inches)
Wall
Thickness
(inches)
Tube Outside
Diameter
(inches)
Empty
Weight
(lb)
7x27 27.625 10.4 0.134 7.12 52 lb
9X41 44.1 13.4 0.134 9.25 1001b
MIO A4 55 3/8 9.75 0.055 8-61/64 38 lb
M16 A3 42 21/32 8.5 0.055 6-7/8 33 lb
12X56 52.25 15.0 0.134 12.0 135 lb
PA 37 32 3/4 8.5 0.055 6-7/8 171b
M 13 A2 27 1/2 7.75 0.055 6-13/64 14.6 lb
Length Width Height
M2 Al 11 5-9/16 6-51/64 N/A 5.75 lb
1.3 Approval Process
Plans for using EDT at TOCDF will be submitted to the State of Utah Department of
Environmental Quality (DEQ) Division of Solid and Hazardous Waste (DSHW) for approval
before destruction begins. In addition, TOCDF will coordinate with the DCD, Department of
Defense Explosives Safety Board (DDESB), the U.S. Army Technical Center for Explosives
Safety (USATCES), and CMA. Concurrence/approval by UDEQ, DCD, DDESB, and
USATCES will be obtained before implementing this Destruction Plan.
1.4 Historical Precedent for EDT
The EDTs evolved from an increasing need to safely destroy recovered chemical warfare
material (RCWM), and they have safely destroyed RCWMs in Pine Bluff Arkansas; Waianae,
Hawaii; Porton Down, England (United Kingdom); Poelkapelle, Belgium; and Munster,
Germany. Riot control gas and various mustard agents, with and without energetics, have been
safely destroyed in EDTs. The EDTs have also proven effective for destruction of conventional
weapons.
The EDT operations are currently conducted safely and in an environmentally-sound manner.
The system uses explosives as the primary means of destroying the munition, overpacks, and
chemical fill through extreme temperatures, and pressures and shock waves. As of October 30,
2009, the DAVINdF"^ EDT technology has destroyed over 5400 munitions worldwide.
1.5 Site Description (including Site Preparation Requirements)
The TOCDF is a multi-incinerator hazardous waste treatment and storage facility located within
the federally-owned DCD, which covers about 7,900 hectares. The DCD is located in Stockton,
Utah [approximately 56 kilometers (35 miles) southwest of Salt Lake City]. The TOCDF was
designed and constructed for the treatment of the chemical agents and munitions stockpile
currently stored at the DCD Area 10 (i.e., the Chemical Munitions Storage Area).
Area 10 is immediately adjacent and physically connected to the northem end of TOCDF. Area
10 is operated by DCD and has secure, surety-rated access control, perimeter monitoring,
appropriate fencing, and an around-the-clock guard force.
The EDT will be located in the northem end of the Open Storage area, between Road C and
Road D. The permanently occupied areas of Area 10 include, but are not limited to, the
administration and guard areas near the main gate on the south side. There are temporary
activities ongoing in existing igloos near the EDT site.
Design criteria used for the EDT site include:
Altitude (above sea level) - 1557 m (5150 ft)
Maximum Temperature - 37 °C (93 °F) (dry bulb)
Mmimum Temperature - -17 °C (1.4 °F)
Monthly Rainfall (max) and mo. -5.13 inches
Rainfall in 1 hr - 0.94 inches
Average Total Precipitation - 13 to 16 inches
Relative Humidity - Maximum, 88 %; Minimum, 15 %
Maximum Basic Wind Speed - 90 mph (40.2 m/s)
Snow Load - 43 Ib/ft^
Wet-Bulb Temperature - 14 °C (58 °F)
Seismic Zone (International Bldg. Code) - D
The following three figures illustrate different drawings of the Area 10 location for the
DAVNCH. Figure 2 shows the proposed site location in Area 10, at the northern end of the open
storage area. Figure 3 depicts a notional diagram of the proposed EDT location in the Open
Storage Area. Figure 4 shows an overview of the site plan, including the access roads, gates, and
site layout.
EDT SITE
Figure 2. EDT Proposed Site Location at TOCDF
Figure 3. EDT Site Location in Area 10
Formatted: Font: (Asian) Japanese
DAVINCH SYSTEM
TOEOT SERVICES
General Plot Plan
PF3400 100 DB41 -PROOSK
Figure 4. EDT Site Overview
.As shown in Figure 3. the EDT site will occupy approximately 75.()()() lr at the northem eni.1 ol"
the (!)pen Storage area, atljacent to Buikling 1 S35. The site is a I'ormer storage area lor ton
containers (TCs): it is currently occupiei.1 with abani.lonei.1 storage racks for the TCs. which
consist of short sections of railroai.1 tracks ani.1 railroai.1 ties. This area will be grai.lei.1 after
remo\al ofthe TC racks. The major sections ofthe site are i.liscussei.1 below.
1.5.1 Existing Pa\ e(.l .Area
.At the northem eni.1 ofthe (!)pen Storage .Area there is an existing macai.lam roai.1 parking area.
This area pro\ ii.les a solii.1 surface for parking ani.1 entry into the site. \ ia an existing gate along
Road "D".
1.5.2 .Aelministrati\ e .Area
Immei-liately atljacent to the Existing Pa\ ei.l .Area is the location for temporary trailers, which
will house storage trailers, an office area, ani.1 the laboratory. This area will be grai.lei.1.
compactei.1. ani.1 built up with gra\ el to sufficient tlepth to support the trailers, which will open to
the parking area. a\ oii.ling the neei.1 for concrete or pa\ ei.l walkways.
1.5.3 EDT Site
The EDT ani.1 enclosure will occupy an area roughly 1 oo ft x 1 oo ft. This section will be grai.lei.1.
compactei.1. ani.1 built up abo\ e gratle using layerei.1 gra\ el to ensure i-lraining ani.1 pro\ ii.le a firm
footing for the mobile D.AMNCH'^" unit.
1.5.4 Staging .Area
.Ai-IJacent to the EDT site will be a 2()() ft x 2()() ft staging area, where utilities will be locatei.1.
Generators, storage tanks for fuel ani.1 gases, ani.1 other temporary ei.|uipment will be locatei.1 here.
This area will be grai.lei.1. compactei.1. ani.1 built up with gra\ el to a sufficient tlepth to support the
ei.|uipment. During installation, components that are being stagei.1 for assembly will also be
locatei.1 in this section.
1.5.5 .Additional Gate
To pro\ ii.le a logical llow of materials through the site, ani.1 to facilitate i.leli\ ery of munitions,
supplies, ani.1 other materials to the site, a new gate is proposei.1 for installation in the existing
fence atljacent to Roai.1 D. approximately 3()() ft from the existing gate. This gate will pro\ ii.le
ingress to ani.1 egress from the site.
1.5.6 Restricteel .Access
.All fencing will be establishei.1 in accortlance with existing DCD access rei.|uirements. .An
ai.klitional intemal fence will be usei.1 to i.li\ ii.le the (!)pen Storage .Area into a northem ( EDT)
sector ani.1 a southem sector to pre\ ent access to unauthorizei.1 areas.
1.6 Emergency Planning and Contingency Operations
1.6.1 Site Specific Sal'et\' Plan
.A Site Specific Safety Plan ( SSSP) contains infomiation regartling safety planning for the
implementation ofthe EDT. The SSSP contains infomiation on support operations such as
medical, fire, and emergency response at TOCDF and Area 10 for EDT operations. The SSSP
will be approved by DDESB.
1.6.2 Prevention of Sudden Releases to the Environment
The destruction of chemical agent munitions using the DAVINCH™ process is designed to
minimize the potential of fire and sudden and non-sudden unexpected releases of hazardous
waste to the environment.
1.6.2 .1 Minimized Handling
The DAVINCH™ will process approximately 350 leaking and over-packed 155-mm H
Projectiles, and 4.2-inch HD and HT Mortars. In addition, the DAVINCH^" will process
approximately 50 HD and HT samples. The munitions and agent samples are processed in their
over-packs as the DAVINCH™ process does not require the items to be removed from the over-
packs prior to treatment.
1.6.2.2 C ontainnient
The DAVINCH"^^ operations are conducted in an Environmental Enclosure (EE) that is
equipped with airlocks and appropriate high-density polyethylene (HDPE) interlocking flooring,
with a plastic floor liner under the HDPE panels, which interlock together to form a stable
platform. The Environmental Enclosure is maintained under a negative pressure, and air
circulating through the enclosure is vented to activated carbon filters. A damper system
maintains flow during operations (See Section 2.2 for a more detailed description ofthe EE).
1.6.2 .3 Controlled Detonation
The DAVINCH^"^ destroys the chemical munition agent fill and energetic components by
controlled detonation, a mechanism whereby the steel munition components, agent fill,
energetics, and overpacking are completely destroyed by the shock wave from the donor charge,
intense heat, and extreme pressures generated microseconds after the initiation ofthe detonation.
An explosive model of each detonation ensures the proper placement, size, and location of linear
shaped charges (LSCs), which cut the walls ofthe overpack and munition, and a staged series of
emulsion-type donor charges. The charges are attached to each munition based the munition
type, type and number of overpacks (i.e., one or two overpacks are used to contain the munition),
and on the position of the munition inside the overpack as determined by an x-ray assay. The
donor charges are attached to the munitions in a preparation area within the Environmental
Enclosure. Releases to the environment through an unplanned detonation of explosives are
minimized by:
• Minimization ofthe number of munitions and donor charges present at the DAVINCH'^'^
operational site. The number of munitions provided to the DAVINCIF^^ each day of
operations is limited to the amount that can be processed in one day. The DAVINCH™ is a
batch process system, and the schedule allows for a maximum of seven target treatment
detonations per day, not including cleansing shots. The number of munitions processed in
each batch is dependent on the type of munition: 155-mm H Projectiles are processed one or
two per batch depending on the number of overpacks, and 4.2-inch Mortars are processed
three per batch.
10
Storage of munitions in a separate location. The mimitions to be treated by the DAVINdF"^
for the day are stored within the Environmental Enclosure. The donor charges to be used for
the day are stored in the Day Explosive Storage Units, which are located near to the
Environmental Enclosure. The number of donor charges, and LSCs -at the DAVINCH™ site
will not exceed the amount necessary for a day's operations. A separate Day Explosive
Storage Unit is used to store detonators.
Inherent Stability of Donor Charges. The donor and shape charges that are used are
comprised of stable explosive formulations that require the use of a detonator. The detonator
circuit is enabled only after the prepared munition is placed in the Detonation Chamber.
Chamber Design. Sudden releases from the Detonation Chamber are prevented by the design
of the chamber. The Detonation Chamber is comprised of an outer and inner chamber:
The iimer chamber has a slightly smaller diameter than the outer chamber, which creates
an interstitial space between the chambers. The inner chamber is sacrificial and is
replaced after a designated number of shots. The Destruction Plan for TOCDF does not
require replacement ofthe inner chamber, since the total number of shots for the inner
chamber life is in the 2000 range, and the TOCDF plan requires only about a 300 shots
for the duration ofthe campaign. The inner chamber is neither a pressure vessel nor an
inipulsively-loaded vessel; it serves as the primary barrier against the heat, impulse, and
fragments associated with the contained detonation. The interstitial space between the
inner and outer chamber is open to the product gas.
The outer chamber is a multi-layered steel chamber designed to contain the high
temperatures and pressures generated by the confrolled detonation. The DAVINCH™
chamber will be manufactured at a factory in Japan that is an authorized manufacturer of
ASME SEC VIII pressure vessels; this facility has the technology available to construct
the multiple-layered-steel outer chamber. The system is designed in accordance with
ASME Code Case 2564 (January 2008) on impulsively-loaded vessels, which is the first
design guidance of this kind worldwide. The EDT subcontractor engineers participated
in the Task Group ofthe Code Case and designed the DAVINCH™ chamber according
to the design guidance.
Leak-Before Burst Failure Mode. The design criteria for this chamber are based on
numerical modeling. The multiple-layer design allows for the discontinuity between the
layers to provide an arresting mechanism for small cracks that might occur in the chamber
wall. In addition, the system is designed to prevent catastrophic failure even for loads well in
excess of its rated design criteria for pressure and impulse loads. The design ensures that the
failure mode ofthe vessel is "leak before burst," whereby the chamber will not
catastrophically fail. If a failure occurs, any release of contamination from the DAVINCH™
will be captured by the EE.
Near Real Time Strain Monitoring. Failure ofthe Outer Chamber is minimized by the
system unique to the DAVINCIP^^ which is referred to as DESTINY. This near real time
system uses strain gages to measure strain in the Outer Chamber metal fatigue at locations
11
that are based on numerical modeling and that have shown fatigue in previous DAVINCH™
operations. After each shot, an analysis is automatically run to show the accumulated
stress/strain on the system, using the strain gage data. Over 5,400 munitions have been
processed on similar systems with no structural failure, and those data are integrated into the
design of the DAVINCH™ System.
• Hold-Test-Release. Releases of agent from the DAVINCIP'^ stack are also prevented by the
Hold-Test-Release concept of operations as allowed by the design ofthe system. After each
shot, the off-gas is treated in a series of treatment trains, which incorporates a Retention Tank
that is located downstream ofthe Cold Plasma Oxidizers. The Retention Tank provides a
retention time of approximately 10 minutes, slowed by the baffles intemal to the tank. The
gas residence time is longer than the cycle time of the agent monitor that is located upstream
ofthe inlet to the Retention Tank. The pumps, blowers, and valves allowing off-gas to reach
the CA monitor are timed to synchronize the release of off-gas to the sampling point with the
sampling cycle ofthe MINICAMS'^'^ to ensure that detonation gas is sampled. If agent is
detected in the detonation gases, the Retention Tank outlet valve is closed, and the gases are
routed back through a dedicated activated carbon filter for additional treatment.
• Carbon Filtration. Releases of agent from the DAVINCH™ stack are further prevented by
passing treated detonation gases through a sulfur-impregnated activated carbon filter before
they are released to the environment. Releases from the DAVINCH™ Environmental
Enclosure to the ambient air are prevented by the supplied fixed bed activated carbon filters.
1.6.2.4 Prevention of Spills/Releases
Releases of liquid hazardous waste to surface and ground water are prevented by processing all
munitions and agent samples received at the DAVINCH™ operation site in the over-packs in
which they arrive: this is because ofthe DAVINCH™ high TNTeq rating ofthe DAVINCH™
system Detonation Chamber. Releases of liquid hazardous wastes are further controlled by the
use of an Environmental Enclosure that prevents the run-on and run-off of precipitation. The
DAVINCH™ Detonation Chamber, Cold Plasma Oxidizers, and Retention Tank are located
inside the Environmental Enclosure. The preparation ofthe munitions to be treated in the
DAVINCIF^* occurs within the Environmental Enclosure. The DAVINCH™ Pollution
Abatement System (PAS), which consists of a cyclone, 10- and 2-micron filter screens, wet
scrubber, and fixed-bed carbon filter are housed in two shipping containers. Secondary
containment is provided for the wet scrubber. Release of hazardous waste during the transfer of
waste residues from the DAVINCH'^'^ Detonation Chamber, and particulate and wet scrubbers is
prevented by conducting those activities inside the Environmental Enclosure and shipping
container, which house some of the DAVINCH™ PAS components.
1.6.3 Fire Prevention
Fire protection will be designed into the system. The trailers will be fire rated. Equipment and
materials, piping, and electiical will be in accordance with National Fire Protection Association
(NFPA) or underwriters [Underwriter's Laboratory (UL) Listed]. There will be a minimal
amount of flammable materials in the EE, and housekeeping standards for all areas will be
imposed to ensure that fire protection standards are met. Necessary equipment will be grounded.
12
and ground fault interruption will be applied to circuits that have a shock or fire hazard. No
smoking or open flames will be allowed in the restiicted area of the site.
1.6.3.1 Fire extinguishers rated D by UL in accordance with UL/ANSI 711, local codes, and
TOCDF requirements will be placed at designated locations throughout the EDT area of
operations.
1.6.3.2 The DCD Fire Department will be the primary response team for any fire associated
with the EDT operation. Contact with the TOCDF Control Room will be the primary method of
reporting a possible fire, and response will be coordinated by TOCDF and DCD.
1.6.4 Communication System
The DAVINCH'^'^ operations site is equipped with communication systems to alert employees to
various site conditions, upset conditions, emergencies, and operations updated for TOCDF.
1.6.4.1 The Site Public Address (PA) announcements will be managed from the EDT Control
Room. A feed from the TODCF site PA for overall TOCDF announcements will be provided.
The PA speakers will be mounted at locations at the EDT site to allow all site personnel to hear
announcements.
1.6.4.2 Cell phone use will be restricted during explosive operations. An exclusion area will
be established based on Department ofthe Army Pamphlet (DA PAM) 385-64. Site security
radios for DCD security will have the appropriate setbacks (i.e., defined areas where cell phones
and radios are prohibited to prevent unintended initiation of electronic detonators) incorporated
into the operation.
1.6.5 Spill Response
The EDT site will have Standard Operating Procedures (SOPs) and signage associated with
response to spills of hazardous materials. A spill involves the release of a type or quantity of a
hazardous waste or materials which, when spilled, become hazardous wastes, that poses a threat
to human health or the environment: this includes an uncontrolled fire or explosion^
1.6.5.1 The EDT site will have pre-positioned spill control kits for response to minor spills,
including but not limited to:
• Absorbents
Universal Spill Absorbent - 1:1:1 mixture of Flor-Dri (or unscented kitty litter), sodium
bicarbonate, and sand. This all purpose absorbent is good for most chemical spills
including solvents, acids, and bases.
Acid Spill Neuttalizer - sodium bicarbonate, sodium carbonate, or calcium carbonate.
Alkali (Base) Neuttalizer - sodium bisulfate.
Solvents/Organic Liquid Absorbent - Inert absorbents such as vermiculite, clay, sand,
Flor-Dri, and Oil-Dri.
• Personal Protective Equipment (PPE)
Goggles and face shield
Heavy neoprene gloves
Disposable PPE
Deleted: A spiU response plaii will
include response requirements for major
spills, minor spills, chemical agent spills,
and response plans in the event of a spill.
A spill involves the release of a type or
quantity of a chemical that poses an
immediate risk to health; tliis includes an
uncontrolled fire or explosion.
13
Plastic vinyl booties
Dust mask/respirator
• Clean-Up Material
Plastic dust pan and scoop
Plastic bags (30 gallon, 3-mil thickness) for contaminated PPE
One plastic bucket (5-gallon polyethylene) with lid for spill and absorbent residues.
1.6.5.2 For all spills exceeding the category of minor spills, or any spill that involves CA,
explosives, or Immediately Dangerous to Life or Health (IDLH), the J'OCDF HAZMAT Team
will be the primary response organization. The EDT site SOPs will address administration of
first aid, immediate response actions such as evacuation ofthe area and communication
procedures.
Deleted: TODCF
1.7 Monitoring
Air monitoring will be performed in accordance with the EDT Monitoring Plan, Annex B to this
Destruction Plan. Edgewood Chemical Biological Center (ECBC) and Versar will provide
personnel and equipment for air monitoring for chemical agent. Air monitoring objectives
include ensuring that worker and public safety and health are maintained by providing
environmental monitoring in accordance with Army Regulation (AR) 385-10 and the U.S. Army
Implementation Guidance Policy for Revised Airbome Exposure Limits. The target agent for the
monitoring plan is HD. Agent monitoring is performed using MINICAMS™ and Depot Area
Air Monitoring System (DAAMS)
The EDT Monitoring Plan describes three types of monitoring used at the EDT site: Safety
Monitoring/Personnel Safety; Process Monitoring, and Waste Monitoring. This monitoring shall
be used to evaluate the overall effectiveness of engineering and administtative conttols, and
when PPE is used, monitoring shall be in place to ensure that exposure levels are not exceeded.
1.7.1 Safetv Air Monitoring
The MINICAMS™ near real time monitors will be used to monitor the enclosure for the
presence of CA, using HD^s the target analysis compound^ The DAAMS tubes will be used to _
provide confirmation and historical monitoring documentation.
1.7.2 Monitoring Points
Monitoring points will be located in the unpack area, the preparation area, the DAVINCH™
chamber area, airlocks, changing room, and waste areas. Monitoring points will also include
first entry to the chamber after detonation, and mid-bed monitoring at the carbon filters. These
monitoring points will address a first entry/check for the box truck that will be used to deliver
munitions to the EDT site each day to confirm that no agent has leaked from the target munitions
during ttansport from the igloo area to the EDT site.
Deleted: andHT
Deleted: s
1.8 EG«&G, TOCDF, and DCD Support
14
EG&G and DCD will provide site support services in Area 10 and at DCD during the EDT
project. This includes oversight of EDT operations, which consists of ensuring:
• A comprehensive evaluation of contractor work control practices, operation, maintenance
and quality control procedures performed by TOCDF's Safety, Environmental, and Quality
departments.
• Vendor's and contractor's policies and procedures that meet or exceed TOCDF standards.
• Discrepancy resolution and procedure revision to the satisfaction of EG&G and the vendor
before any EDT operations commence.
• X-ray data results based on x-ray Requirements (D-003).
1.8.1 Equipment/Facilities
The TOCDF/DCD will provide the following equipment/facilities for the project:
• Temporary personnel facilities including shower/locker ttailers and break room trailers.
These facilities will be sized according to the number of user personnel identified by the
vendor.
• A bulk explosive storage building (storage igloo rated for Class 1.1 explosives) as applicable.
• Communications system between the Detonation Chamber site, the TOCDF Control Room,
and DCD Security.
• Shower and break facilities for EDT operators.
1.8.2 Utilities
The EDT is designed to be self-sustaining. EG&G will provide services to refill propane, diesel
fuel and water tanks.
1.8.3 Security
• DCD will provide round-the-clock security at Area 10 during setup, operations and
demobilization.
• Access conttol will be maintained at Area 10 through badging and escorts for non-
Unrestricted Access badged personnel. EG&G will coordinate badging and escorting. Note
that personnel with need for unrestricted access will be part ofthe DCD Unescorted Access
Program (UAP).
1.8.4 Site Preparation
EG&G will provide site preparation and civil consttuction for the site, including site preparation
based on vendor-provided site specifications per Site Design (Deliverable D-002).
1.8.5 Operations Support
EG&G and DCD will provide the following support during operations:
• Hazmat and decontamination team support in the event of a hazardous waste event.
• Fire suppression support (through DCD) in case of a fire at the EDT site
• Site-specific ttaining for all EDT personnel (see Annex G, Training Plan).
• Medical support via the TOCDF Clinic.
15
• Management and funding for the disposal of all hazardous waste generated.
• A temporary 90-day storage location for hazardous waste.
• Coveralls and cotton goods to be worn by operators during chemical weapons operations.
• Toxicological Agent Protective (TAP) gear to include butyl boots, gloves, and M2A1 Aprons
as required.
• Masks issue for visitors to the site.
1.8.6 Planning/Permitting
The operating contractor will provide the following:
• The Destruction Plan Approval by DCD, CMA, DSHW, and other regulatory agencies.
• The SSSP, which will be prepared and approval obtained by the U.S. Army Technical Center
for Explosive Safety (USATCES) and DDESB.
• Permitting, including necessary RCRA and CAA Permits, will be the responsibility of DCD,
TOCDF, and the operating contractor, EG&G.
1.8.7 EDT Operations
The EDT contractor will provide operations personnel, equipment, and consumables, including:
• The crew, which will consist ofthe necessary trained operators; safety, monitoring, and
laboratory personnel to conduct site setup, pre-operational checkout and acceptance,
systemization, and the Operational Readiness Review as supported by CMA, DCD, TOCDF
and EG&G).
• Donor Explosives; movement ofthe explosives, conducted by trained personnel, from igloo
storage to the day box will be coordinated with DCD and Area 10.
• Consumables, which will include items necessary to conduct operations and maintain the
system, including decontamination solutions, bottled gases, carbon and High Efficiency
Particulate Air (HEPA) filters, and liquid and vapor sample containers.
Note that munitions will be delivered by DCD/Area 10 personnel to the intake area at the EDT
site.
16
2.0 SYSTEM DESCRIPTION
2.1 Overview
The DAVINCH'^" system is designed to meet the requirements ofthe EDT project at TOCDF,
including but not limited to: mobility; standalone capability; safety; environmental protection
measures; EE containment while chemical agent is processed; process monitoring analysis of
chemical composition; appropriate connection with chemical agent monitoring (i.e., process
interlocks) and analysis: UPS backup; and appropriate redundancy to complete the ongoing
destruction backup operations.
2 .1.1 Concept of Operations
The explosive detonation system concept of operations is to destroy overpacked chemical
munitions using specialized explosive donor charges in a vacuum-assisted, multiple-layered,
armored-steel chamber capable of containing the explosion. The extteme pressures,
temperatures, and shock waves generated by the donor charge destroys the overpack, the
munition body, the explosives/burster charges contained in the munitions, and the chemical agent
fill in microseconds. Operation will be controlled from a remote Control Room that contains all
human-machine interface, process monitoring, closed-circuit television (CCTV), and
communication equipment. The DAVINCIF^ model DV60 has the capacity to desttoy 133 lb
(60 kg) of TNTeq of explosive and is capable of desfroying all the specified munitions listed in
the specification without unpacking munitions or requiring other pre-treatment. This can be
accomphshed in a 10 to 12-hour day/four-day week operation mode.
The system's major subsystems include the:
• DAVINCHTM Explosive Detonation Chamber;
• Off-Gas Treatment System;
• Control System;
• Utility System; and
• Ancillary Equipment.
See Design Features, Section 2.6, for more details on these subsystems.
2.1.2 System Design Requirements
The DAVINCH™ system is designed to meet the requirements ofthe EDT project at TOCDF.
The DAVINCH™ DV60 has the capacity to desttoy 133 lb (60 kg) TNTeq of explosive and can
desttoy all the specified munitions listed in Table 2 without unpacking or requiring other pre-
freatment at a rate of seven detonations per day.
The system is designed to be stand-alone. All utilities will be provided on-site, including electric
power from two 600 kW diesel generators; storage for water, which will be refilled from the VA-
inch line and spigot located in Area 10; and storage for gases and fuel, including propane and
diesel.
17
The rack-mounted off-gas system will be designed to simplify installation of the entire system, to
be completed in one month, at the TOCDF site. The DV60 main chamber will be tested under a
125 % load in Japan and brought to the U.S. for DDESB review and approval. The DV60 has a
design life of 5,000 to 8,000 shots for the outer chamber; approximately 300 shots are required to
fulfill the scope of this project. This DAVINCH™ will have the capability of desttoying the
over-packed, mustard-filled 155-mm Projectiles and 4.2-inch Mortars with out removing from
their over-packs. The over-packed munition is assembled with shaped and donor charges and
placed (hung) in the chamber, where the detonation is activated in a partial vacuum. The
emulsion explosive placed around the munition ensures an effective implosion process, thereby
reducing the speed and the size of detonation fragments, and ensuring a longer life ofthe inner
chamber. In the case of over-packed munitions, a shaped charge is added to the process to cut
the overpack and detonate the burster.
2.2 Environmental Enclosure (EE) Description
2.2.1 DAVINCH™ Containment
The "primary" containment for the munitions is the existing overpacks. The "secondary" or
DAVINCH™ containment is the chamber itself. The detonation chamber lid has a space to
capture escaping gas. The skid-mounted off-gas units are contained in 40-ft modular enclosures,
which are ducted to the EE enclosure (described in paragraph 2.2.2). The DAVINCH™ will be
located inside an EE comprised of a ceiling, sides, and flooring that will provide weather
protection and interior environmental control for workers comfort and safety. The floor ofthe
EE will be an^DPE interlocking floor, approximately 2 inches thick, underlain with , - - -( Deleted; HPDE
impermeable plastic sheeting. The structure also provides secondary vapor containment during
EDT operations in the event an unexpected release of chemical agent occurs while loading the
items. The EE will have a continuously-operating air filtration system that maintains a negative
pressure within the EE relative to the outside air; it will capture any chemical fill vapors resulting
from operations. The air flow from in the EE containment is kept at negative pressure, -0.10 to -
0.5 in WC, through a cascade-type ventilation system, with carbon filtration to the outside
atmosphere. The shelter meets the required wind load; the maximum criterion is 120 mph for a
three-second gust. The EE will provide a seal with the ground to prevent outside water from
entering and ensure air-tightness.
2.2.2 EE Operating Areas
The munition receipt and preparation area, detonation chamber unit, waste handling area, are
contained in separate sections ofthe EE. The off-gas tteatment equipment is housed in shipping
containers positioned outside ofthe EE. The receiving area, and preparation room are air
conditioned, and the shelter has local heaters and coolers for the operators. The exhaust air
blower system maintains the required ventilation air changes per hour, and air is exhausted
through a carbon filter. There are separate airlocks for personnel and material/equipment. The
floor coating, consisting of interlocking HDPE panels, will meet the requirement for dust control,
and provide a moisture barrier. Design load will be met; note that the slope coupled with the
slippery membrane is designed to shed snow load. Under normal conditions, the aluminum
frame has a 30-year design life, and the membrane has a two-year life. Humidity will be
controlled by the ventilation system. Lightning protection is incorporated into the design.
However, CWM will not be stored in the EE.
18
2.3 Maintenance Requirements
Maintenance inclui.les periotlic inspections, ani.1 pre\enti\ e maintenance ani.1 correcti\ e
maintenance.
2.3.1 Monitoring Fatigue Damage
DESTINE' Real Time Fatigue Monitoring instrumentation system allows the fatigue i.lamage to
be monitorei.1 (.luring e\ery shot. Inl'omiation regan.ling the prei.lictei.1 time of crack initiation is
assessei.1 as the key ini.licator for long-temi maintenance.
2.3.2 Pre\ enti\ e Maintenance
The pre\enti\ e maintenance is performei.1 as categorizei.1 in Table 4. This pre\ enti\ e
maintenance program is basei.1 on actual operational perfomiance. Inspection is performei.1 in
accori-lance with the Inspection Plan pro\'ii.lei.1 in .Annex C.
2.3.3 E(.|uipment Maintenance Scheelule
The control system ani.1 its interface with an off-site system for performance (.lata collection
(know as GRAND) offers the infomiation necessary for the ei.|uipment maintenance schetlule
ani.1 supports operators in real-time. It estimates the maintenance tim ing basei.1 on the tlatabase.
which incoqiorates statistical basei.1 estimation capabilities. The tlatabase is upi.latei.1 with
operational result input from similar sites worklwitle.
19
Table 4. Schedule for Pre\enti\e Maintenance
M.\1NTEN.\NCE
T\PE DA1L\ \\T:EKI\ MONTHL\ Bl.\NNl'ALL\
Maintenance A B C D Le\el A B C D
- Msual - Msual - Msual - Msual Inspection
Inspection Inspection Inspection - Cleaning
Chamber
Inspection
- Cleaning - Cleaning - Diameter Chamber
Inspection - Diameter
Measurement
Measurement
- NDE (MT.PT)
- Crack remo\ al. if
an\'
- Daily check - Remo\ mg - Measurement - Cleaning of filter
by list heavier i.lust check(hook elements
- Check (e.g.. - Check opening, chain - Perioi-lic inspection
Other Equipment
Inspection
(pump, cold
plasma, off-gas
filter)
\ isual. noise.
\ibration.
temperature,
llow rate,
leakage)
loosenei.1 bolts
arouni.1 \ al\es
near tletonation
chamber
i-liameter).
perioi-lic
inspection
('manufacturer's
stani.lan.1)
- Drain remo\ al
of stack
('manufacturer's
stani.lan.1)
- .Acetone cleansing
run of \ acuum
pum ps
- Change filter
elements if necessary
- Replacement
repair as necessary
Inclui.lei.1 in
10-hrs/day Mode the Daily
(!)pe ration
2 Hours 1 Da\-3 Days
Quantity of -, 4 S Personnel 4 S
PPE ^es ^es ^es ^es
NDE: Noil De-lniclioii Exaiiiiimlioii
MT: Mnaielic Te-I
PT: Liquid Peiielrnlioii Te-I
2.4 Design Features
2.4.1 Detonation Chamber
The system inclutles two relati\ ely close-fitting \ essels. The D.AMNCH'''" tletonation chamber
has i.listincti\ e features such as the i.louble-wallei.1 steel chamber with a replaceable inner \ essel
that protects the outer chamber from explosion fragments: ani.1 the \ acuujn that is establishei.1
prior to tletonation ani.1 sei.|uential tletonation to retluce the impulsi\ e loai.1. souni.1 ani.1 \ ibration.
ani.1 fatigue i.lamage. The i.louble-wallei.1 chamber tlesign is basei.1 on a " leak-before-burst"
philosophy. It is cylini-lrical in shape, with hem ispherical eni.1 caps: the D\'6() chamber interior
volume is appro.NJmately 1 So ff\ The maximum allowable explosive charge is 60 kg of TNTeq.
or approximately 133 lb of explosi\ es. The chamber opening is closei.1 with a NLI that uses a
hyi-lraulic clamping system ani.1 casketing to ensure pressure retention. The outer chamber is
fixei.1 to the founi-lation \ ia satklles ani.1 is fabricatei.1 with laminatei.1. cylini-lrical. carbon-steel
walls weklei.1 to monolithic carbon-steel top ani.1 bottom ellipsoii.lal heatls. The inner chamber
consists of layerei.1 steel ani.1 is consii.lerei.1 a maintenance item - it is replaceable. The
replaceable inner liner is also constructei.1 of special steel, ani.1 it is built up in layers to minimize
the propagation of any cracks, which are arrestei.1 by the i-liscontinuity between the layers.
2.4.2 Clamping S\stem
The "auto-clamping" NLI closure system was i.lesignei.1 untler recommeni-Lation by Lawrence
Li\ ennore National Laboratory. The earlier D.A\TNCH'''" tlesign usei.1 two U-shapei.1
circum ferential clamps, ani.1 closure was accomplishei.1 by manually bolting the clamps together.
The new system is constructei.1 using eight ini.lepeni.lent clamps, configurei.1 to allow optimal
control ofthe access tloor. These clamps are i.lri\en by automatic hytlraulic or oil pressure. This
pressure is monitorei.1 to ensure that all clamps are functional ani.1 supply the rei.|uirei.l closure
pressure.
2.4.3 Munitioas Hanelling Installation in Chamber
.A scissor-type lift is usei.1 to lift the configurei.1 munition to a position in the chamber that will
allow personnel to hang the munition ani.1 explosi\ e using nylon web straps ( or other appro\ ei.l
hanging materials) along an interior track at the top ofthe inner liner. The tletonation chain is
set. ani.1 the automatic hytlraulic clamping system acti\ atei.l remotely to ensure a complete seal.
2.4.4 Chamber Door Mo\ able Platl'onn
The hem ispherical chamber tloor is mountei.1 on an articulating mechanism that allows the tloor
to mo\ e away from the chamber to pro\ ii.le access to the inner main chamber. The main
chamber is accessei.1 by a mo\ able robotic access ramp that tloes not touch the inner chamber.
2.4.5 Off-Gas Filter
.An inline filter is usei.1 to remo\ e particulates, with filtration specification of 2 micro-meter
efficiency 99.97°o. The filter hasa backwash function.
2.4.6 Off-Gas Heater
.A stainless-steel inline electric resistance heater is usei.1 to maintain process temperature.
2.4.7 Cooler
.An inline gas cooler, using a gas air shell ani.1 tube configuration is usei.1 to nuxlulate temperature
ofthe off-gas to maintain process temperature.
2.4.S Off-Gas Svstem
The off-gas treatiiient system consists of a series of filttation banks ani.1 a "cokl plasma" gritl-arc
oxii-lizer. followei.1 by carbon filttation. The Retention Tank pro\ii.les a retention time of up to lo
m inutes. slowei.1 by the bafiles intemal to the tank: this allows sampling to occur prior to release.
ani.1 rei-lirection ofthe off-gas to the treatiiient process shouki any C.A be i.letectei.1.
2.4.9 \"acuum Pumps
Two rei.luni.lant. inline \ acuum pumps are usei.1 to e\ acuate the chamber. These are off-the-shelf
units with: a capacity of 35o NlV'm in: suction of 1.45 psi: ani.1 tlischarge of o.2 psi. The
i-letonation protluct gas is e.\nractei.l by a \ acuujn pump through an off-gas filter ani.1 then is sent
to the off-gas treatment system. .A pretletemiinei.1 amount of o.\ygen is mixei.1 with the off-gas at
the cokl plasma oxitlizer where the hytlrogen ani.1 carbon monoxii.le are o.Kii.lizei.1. .Any C.A
remaining in the off-gas is i.lestroyei.1 by the cokl plasma o.^itlizer.
2.4.10 C^okl Plasma Oxidizer
The cokl plasma oxitlizer unit is a unii.|ue piece of ei.|uipment. It is also callei.1 a Grii.l-.Arc Plasma
ani.1 has been i.le\ elopei.l for refomi ing some lii.|uii.l fuels into synthetic gas or partial oxitlation of
natural gas. ani.1 upgratling hytlrogen sullkle methyl-mercaptan. It is also now usei.1 as an
oxii-lizer. The atk antages of the cokl plasma are low power consumption, compact size, rapii.1
startup time, ani.1 there is no neei.1 for pretreatiiient or catalyst. Howe\ er. the \ ital atk antage of
the cokl plasma is the o.^itlation process. During the oxitlation process, the suppliei.1 o.\ygen is
con\ertei.l too.\ygen ratlicals by high energy of electrons, ani.1 an oxitlation reaction with Hjani.1
CO is triggerei.1. which makes the cokl plasma oxii.lizer completely i-lifferent from a con\ entional
seconi-lary combustion furnace. The i.letonation protluct gas is tlirectly mi.\ei.l with o.\ygen ani.1
injectei-l into the oxii.lizer as raw gas. The ratio of o.\ygen ani.1 i.letonation protluct gas is
maintainei.1 so that excess o.\ygen remains after the reaction, to ensure complete oxitlation. The
reaction temperature is controllei.1 by an appropriate ratio ani.1 llow rate ofthe i.letonation protluct
gas ani.1 o.\ygen. The oxii.lizer is initially heatei.1 by introtlucing a mixture of LPG ani.1 air. Once
the i.lesirei.1 temperature is reachei.1. the LPG llow is turnei.1 olTani.1 the raw gas is introi.lucei.1. The
llow rate of o.\ygen ani.1 raw gas are ai.liustei.1 to maintain the i.lesirei.1 stoichiomettic ratio, while
the total llow is ai.liustei.1 to maintain the oxii.lizer at the i.lesirei.1 temperature. The two units can
operate in a fail-safe nuxle. where one unit can continue to operate if there is a failure ofthe
other, albeit at a rei.lucei.1 llow rate. This ensures that any i.letonation gas will be tteatei.1 if either
unit fails to operate.
2.4.1 1 Cooler
The off-gas is coolei.1 after it passes through the cokl plasma oxii.lizer using an inline gas cooler
with a gas air shell ani.1 tube conllguration that nuxlulates the temperature of the offgas to
maintain process temperature.
2.4.12 Scrubber
The off-gas is scrubbei.1 using an inline gas scrubber with a sotlium hyi.lroxii.le wash tlown. The
coolei.1 gas is neutralizei.1 by the scrubber. The contlensate water generatei.1 in gas cooling is
circulatei.1 through the insitle of the scrubber.
2.4.13 NaOH Tank
This tank hokis the Na(!)H solution usei.1 for the scrubber.
2.4.14 Off-Gas Blower
.An inline blower is usei.1 to maintain llow into the off-gas retention tank. Specification is 42ooo
Nlr' hr at ambient pressure with a silencer.
2.4.15 Retention Tank
.A miki steel off-gas retention tank is usei.1 to slow the llow ofthe off-gas such that the gas
resilience time in the Retention Tank is longer than the upstream agent monitor's sample ani.1
analysis cycle time.
2.4.16 Heater
.A stainless steel inline electric resistance heater is usei.1 to maintain process temperature. To
exteni.1 the life of acti\ atei.l charcoal, the gas is heatei.1 to about 1 13 °F ('45 °C) before entering the
filter unit.
2.4.17 Carbon Filters
.A sulfur-impregnatei.1 carbon filter bank is usei.1 to filter the D.A\TNCH^" off-gas. with
monitoring pro\ ii.lei.l i-lownstream of the filter's e.Khaust.. The air filtration system for the EE
consists of pre filters. HEP.A filters, ani.1 carbon filters along with a monitor, port fan. ani.1
i-luctwork. .A series of nuxlular chem ical air filtration systems will be asei.1. ani.1 each system
houses two banks of carbon filters, two banks of HEP.A filters, ani.1 one bank of prefliters. Each
bank contains nine 1 S-inch first-time-use filters that ha\ e ne\ er been exposei.1 to chemical agent.
.A smoke test will be coni.luctei.1 at the initial setup to certify the air filtration system ani.1 check
airllow \ elocity to ensure that the EE is able to maintain negati\ e pressure insitle the sttucture
relati\e to the outsitle air. The size ofthe carbon filtration unit is ai.lei.|uate to atlsorb any
chemical agent that couki be releasei.1 from a leaking munition or item.
2.4. IS E.Khaust .Air Blower
.An inline blower is usei.1 to maintain llow into the En\ ironjnental Enclosure H\'.AC fixei.l-bei.1
carbon filters. The specification is 126oooNlr' hr.
2.5 Other Support Equipment
2.5.1 EDT Control Room
The EDT Conttol Room will consist of a rental ttailer ei.|uippei.l with appropriate \ entilation.
This will be the location for the Disttibutei.1 Control System (DCS) control computers,
communications conttol panel, safety system interfaces, ani.1 necessary manuals ani.1 SOPs. The
EDT Control Room will ha\ e a security lock, ani.1 access will be limitei.1 to operators who are
ttainei.1 to operate the system conttols. in accori-lance with the SOPs. The GRAND ani.1
DESTfN^' systems will be accessei.1 from the EDT Control Room.
2.5.2 Generators
Rei.luni.Lant 6oo kW tliesel generators will be installei.1 to pro\ ii.le power to the entire site. .A
nuxlular power i-listribution trailer will be usei.1 to tlisttibute power for the installation.
2.5.3 .Air Monitoring Shelter
.Air monitoring ei.|uipment will be locatei.1 in a shelter, with sampling lines running to the \ arious
monitoring locations at the EDT site.
2.5.4 Mobile Laboratory'
A mobile chemical laboratory will be set up at the EDT site to provide air and liquid sample
analysis services.
2.5.5 Explosive Storage/Day Boxes
To minimize the quantity of explosive and CWM that will be onsite at any given time, deliveries
of donor charges, detonation cord, LSCs, and detonators are limited to the number of munitions
that can be processed in a single shift. The number of donor charge and LCSs is also limited to
that required to treat the munitions delivered, which should only be enough for one day of
operations. The Day Explosive Storage Box, which is used to store the donor charges and LSCs,
is a modular system from an approved supplier of storage systems that meet or exceed the
requirements of 6055.9-STD Department of Defense (DoD) Ammunition and Explosives Safety
Standards (02-29-2008) and Bureau of Alcohol Tobacco and Firearms (ATF) requirements for
Type 2 ATF high-explosive storage. A separate explosive storage box, separated by the distance
specified in ARs will be used to store detonators. The boxes are outdoor rated, and are fire, theft,
and weather resistant. The maximum number of donor charge, detonators, and shaped charges
will be established for each ofthe DAVINCH'^'^ campaigns ^nd stored in accqrdance_\vith _ ,, - -{Deleted; DAVINCH™
regulation.
2.5.6 Storage of Munitions Pending Processing
Munitions delivered for processing are placed in the preparation room and are under the
continuous observation and control of operator personnel during preparation. Only the number
of munitions planned for processing per shift will be delivered from the igloos in Area 10. Any
munitions that are not processed during the shift are retumed to the storage igloo prior to site
shutdown for the day.
2.5.7 Break Room/Crew Trailer
A crew ttailer will be set up to allow breaks, rehydration, and rest area for the crew.
2.5.8 VIP Trailer
An observation ttailer, equipped with CCTV, will be provided so the destruction process can be
monitored without having to enter the exclusion zone.
2.5.9 Toilet Facilities
The TOCDF will provide portable toilet facilities for on-site personnel.
2.5.10 Uninterruptible Power Supply (UPS)
All monitoring equipment will be connected to an UPS. All other site equipment (including the
air filttation system) will be powered by the backup generator.
24
3.0 EDT OPERATIONS
The EDT will be operatei.1 in accori-lance with appro\ ei-l SOPs. .An operating ori-ler or scenario
will be i-le\ elopei-l for each munition or item, basei-l on the Munitions .Assessment Re\ iew Boari-I
('MARB) i-lata from the x-ray campaign coni-luctei-l by DCD. Each operating ori-ler will be locatei-l
in the EDT Control Room.
3.1. System Deli\ery
The i-leli\ery ofthe system will be accomplishei-l in three phases:
3.1.1. Transportation ani-l Deli\ er\' of Main Chamber ani-l .Associatei-I Components
The main chamber is the hea\iest component ofthe D.A\TNCH'''" system: it weighs
approximately 75.ooo lb. ani-l is approximately lo feet in i-liameter. 1 1 feet high, ani-l 23 feet long.
The major components of D.A\TNCH'''" ('main chamber, sai-klle. inner chamber. \ kl clamping
system, entry gantty. ani-l associatei-l piping) will be packagei-l for shipment at the Kobe Steel.
LILL. Takasago W orks, in Kobe. Japan. The system will be loai-lei-l into custom transportation
sai-klles. sttuctures. ani-l packaging to minim ize i-lamage i-luring shipment. The chamber
subsystem will be sea shippei-l \ ia a common carrier to a US port of entry. .At the port of entty. a
rigging subcontractor will ttansfer the system to a rail ttansportation configuration. The system
will be shippei-l from the coast by rail to a rail heai-l near DCD ( i.e.. to an ini-lustrial area near
Tooele. Utah). .A i-|ualifiei-l hea\y loai-l contractor will transport the system component \ ia
escortei-l ttuck from the rail heai-l to the DCD. .Arrangements will be mai-le with the State of Utah
ani-l local authorities to ensure safe transport ani-l roai-l capacit}'. The same hea\y loai-l contractor
will transport within DCD. ani-l ultimately, to the .Area 1 o EDT site. Special pro\ isions ani-l
coori-lination with DCD will ensure that roai-l ani-l gate configuration meet the rei-|uirements ofthe
shipper. The rigger will use an appropriate hea\ y crane to oflloai-l the unit onto the steel
founi-Lation. which will be installei-l prior to i-leli\ ery. Steel plating ani-l certain reinforcements
may be necessary to ensure roai-l i-lamage is pre\ entei-l.
3.1.2. Transportation ani-l Deli\ er\' ol'(!)lT-Gas Treatment S\stems
The off-gas treatment systems will be assemblei-l in Salt Lake City ani-l ttuckei-l to the site o\ er
state ani-l DCD roai-ls. The weights ani-l i-limensions ofthe off-gas systems are within the
capability of a stani-lari-l 4o-foot ttailer. The off-gas system nuxlular components will be olT-
loai-lei-l at the EDT site with a crane.
3.1.3. Deli\er\' ol'Support Ei-|uipment
Support ei-|uipment. inclui-ling but not limitei-l to. the generators, conexes. containment structure,
ai-lm inistrati\ e trailers, ani-l utility storage areas will be i-leli\ erei-l o\ er state ani-l DCD roai-ls.
3.2. System Installation
The site will be preparei-l for installation ofthe D.AMNCH'''" in accori-lance with the ci\il i-lesign.
which ai-klresses soil compaction rei-|uirements. grayling, i-lrainage. ani-l utilit}' locations.
Layers of road base, gravel and rock will be placed on compacted soil to a sufficient depth to
support the static and dynamic loading ofthe system. A heavy steel foundation will be
assembled on site, with steel plating on its surface. The DAVINCH™ chamber saddle will be
placed on the steel foundation, which will have steel penetrations into the soil and road base to
ensure thrust blocking. The floor ofthe DAVINCH^'^ area will be 2-inch HDPE interlocking
plastic modules, approximately 8 feet x 14 feet, leveled and attached to each other as necessary
via clamping fasteners. The floor will be under-laid by non-conducting, reinforced plastic
sheeting.
The off-gas units are designed as trailer-mounted units in 40-ft containers to minimize the piping
work on site. Field work will be continued on utilities while the tertiary containment structure is
assembled. Pre-commissioning includes running tests for all the equipment to confirm that no
damage occurred during transportation, and to validate proper connection of wiring and expected
functions. Confnmation of piping connection air tightness and vacuum testing will also be
conducted. Explosive tests will confirm the DAVINCIF^ chamber unit, off-gas unit, and
utilities supply function as designed. Figure^ shows the phases of installation. Deleted: 4
Period 1st week 2nd week 3rd week
Working day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Control /Electrical Room-n^
Electricity
Utility Utility
Preparation ^Changing
DAVINCH DAVINCH -Electrical Furnace
Off gas skid Off gas skid
Structure of sprung Covering over Equipment Structure of sprung Covering over Equipment
Membrane of sprung Membrane of sprung
Pipe Connection
HVAC system ,s HVAC system p
Wiring Wiring
Commissioning
Tes tfor each ur
ver Supply
lit
9 Pov
tfor each ur
ver Supply
Figure 5. Installation and Commissioning Schedule
The chamber is inspected and tested for pressure tightness; and the operating performance ofthe
automatic clamping system, moving deck, and material handling equipment for munition
handling at the assembling factory. The other auxiliary equipment (e.g., vacuum pumps,
charcoal filters) will be purchased from U.S. suppliers, and Quality Assurance (QA) inspections
are to be conducted at the manufacturing sites. The auxiliary equipment is designed as skid-
mounted modules as much as possible and are shipped in regular ttansportation containers. The
26
main equipment, such as the cold plasma oxidizer, vacuum pumps, and charcoal filters will be
manufactured independently and assembled in the 40-ft container units at a U.S. facility.
3.3. Systemization
The systemization process will follow the approved Systemization Plan. The Systemization Plan
will address the steps necessary to ensure that the system operates as designed, and that all
components are fully operational and assembled correctly at the site. After the facility has been
assembled at the TOCDF and commissioning is complete, acceptance testing will be performed.
The records from assembly, pre-commissioning, and commissioning will be reviewed for
completeness and accuracy. When assembly, pre-commissioning, and commissioning activities
have been accepted, system acceptance testing will be performed to ensure all systems are
working properly. Testing will be conducted using Simulation Equipment Test Hardware
(SETH) munitions, overpack containers, and surrogate chemicals.
Acceptance tests will be performed to confirm the following properties:
Throughput, including handling (feeding), detonation, and off-gas treatment.
Feeding system operability, including required time and safety.
Waste handling operability, including required time and safety.
Agent monitoring operation and management.
Environmental emission control.
Fatigue damage evaluation system (DESTINY) operation.
3.4 Operational Readiness Review
System Operation Readiness Review (ORR), and approval by the ORR Team and an ORR
Board, will be required prior to initiation of munitions operations at the EDT site. An ORR
Board will be established by TOCDF and the operating contractor to implement the requirements
of TOCDF ORR requirements per EG-073 R03 C03, Operational Readiness Review Guide.
3.5 Operations
A 2-month campaign plan will be established to conduct munition destruction operations. The
campaign will be set up to desttoy the categories of overpacked munitions previously identified
in Table 2 of this plan.
In the case of a 4-5 day/10 to 12 hour working schedule, 7 shots per day are required to maintain
the schedule. A plan for the destruction process for each day's operation, based on the individual
requirements of each munition type, will be established. Each day's target munitions will be
delivered at the EDT entry point, the box truck first entry clearance conducted using a spooled
MINICAMS'^" line, and the munitions/overpack container will be moved by forklift into the
unpack area and then to the preparation area.
Daily activity will also involve operators delivering donor charges to the day box from the Area
10 Storage Igloo. Appropriate system checks will begin prior to each shift.
27
3.5.1 Operational Steps
Figure^ shows the foUowing cone detonation:
• Installation of munitions with appropriate donor charge in the detonation chamber.
• Evacuation ofthe air in the chamber and supply of minimum oxygen.
• Activation ofthe controlled detonation explosion.
• Evacuating the detonation product gas, sampling ofthe gas, and transferring it to the off-gas
tteatment system.
Deleted: 5
Figure 2 shows the DAVINCH™ deton^^ and the off-gas treatment y^stem. The
cold plasma oxidizer is mainly for oxidizing the explosive products of CO and H2, and it is
expected to provide additional agent Destruction Efficiency (DE) for back up.
Deleted: 6
Munitions
„HE) Donor cliarge Vacuuming
Minimum oxygen
supply
Munitions (CAandHE) are
destroyed
Detonation
off- gas
(CO, H2, etc.;
Clean off-gas
(C02, H20, etc.;
Off-gas treatment system
DAVINCH detonation
chamber
open 0 Retention I
Tank |
^•1 Solid wastes
Cold Plasma
Oxidizer
Figure 6. Conceptual Steps of DAVINCH Figure 7. Total DAVINCH System
3.5.1.1 A quantity of over-packed munitions specific to the day's plan for detonation
operations is delivered to the site via the access road. The over-packs are received and
monitored for leakage of chemical agent.
3.5.1.2 The over-packed munitions (unloaded by a fork lift in the Unpack Area) are
transferred by a hand lifter to the preparation area for setting the donor charge. The over-packs
are moved on hand lifters by a hand crane for setting the donor charge.
3.5.2 Donor Charge
Each munition has a specific placement and quantity identified for detonation based on the
results of prior x-ray and analysis ofthe overpack/munition configuration. A quantity and
placement plan is relayed to the operators in the preparation area for the munitions to be
detonated. A shaped charge will be used in addition to the emulsion donor charge to cut the
overpack and detonate the burster. The x-ray analysis from the MARB database will be used to
identify the locations ofthe LSC charges, to ensure that the overpack and munition is
28
appropriately cut with the jet from the LSC. The emulsion donor charges are set in a
circumferential configuration around the overpack or munition/sample container, and timed to
initiate in a sequence designed to allow the explosive detonation pressure wave to implode the
target evenly, ensuring complete destruction. The donor charges are "sausage-packed" emulsion
explosive and are supplied in a pre-configured length and diameter by the explosive vendor.
Donor charges will be delivered to the EDT site in shifts to address the daily plan for detonation.
3.5.2.1 The donor charge and LSC are picked up from the storage magazine, and assembled
and transferred to the DoD- and ATF-rated modular Day Storage Box in the preparation
container. They are moved from the day box to the preparation area as needed. The same plan
will be used for the detonators, which are stored separately from the donor charges and LSCs.
3.5.2.2 The assembled donor charge is set aroimd the overpacks on the hand lifter by a
trained operator. The overpack and donor charge are transferred from the preparation room to
the detonation chamber through airlock by the hand lifter. The donor charges are manufactured
and delivered in approximately 2-inch diameter by 2-to-3-foot "sausages" of explosive. These
are taped into place using appropriate tape in accordance with the plan described above for each
shot. The configured overpack, now surrounded by a donor charge, is placed (hung) on nylon
webbed slings in the chamber by the material handling equipment.
3.5.2.3 In order to prevent improper operation and unintentional detonation, the detonation
circuit shall be checked before detonation operation. An operator measures the electric
resistance of detonation circuit after connecting the circuit to the switchbox, and then shorts the
outlet in the chamber. After confirming the resistance is correct, the switch box, plug, and outlet
near the firing device in the chamber are shorted to prevent improper operation. The operator
will connect the detonators after he exits the chamber. All the explosive operations shall be done
using the "buddy system" (two-man rule).
3.5.3 Chamber Preparation for Detonation
3.5.3.1 The unit's lid is robotically closed using the hydraulic clamping system, which has
specialized gaskets to prevent leakage.
3.5.3.2 The chamber is evacuated using a vacuum pump, and oxygen is introduced into the
chamber prior to detonation.
3.5.4 Implosion with Donor Charge
The detonation process creates an exttemely hot fireball and Shockwave that destroys the
chemical agent and the metal munition bodies, over-packs, and other parts, which are reduced to
shards of scrap. The emulsion explosive placed aroimd the munition ensures an effective
implosion process, reducing the speed and size of detonation fragments, and ensures a longer life
ofthe inner chamber.
3.5.5 Off-Gas Treatment and Air Flow Phases
The off-gas treatment process treats the detonation product off-gas on a batch-wise basis. Figure
il shq^vs thej)re-detonatio phases pf thej)rocess. Figure^
Deleted: s
Deleted: 7
Deleted: 8
29
shows the four basic irealmenl units, consisting of the H\'.AC unit lo tlraw a continuous llow of
air from the EE: Treatment Unit .A. which consists of the pre-filler ani.1 \ acuum pujnp: Treatment
Unit B. which consists of the Cokl Plasma (;)xii.lizer ani.1 its associalei.1 heal exchanger cooler ani.1
blower: Treatment Unit C. which consists ofthe retention lank, carbon filler bypass ani.1 C.A
monitor: ani.1 Treatment Unit D. which consists of an inline charcoal filler ani.1 blower. .A utility
system allows gases lo be inlroi.lucei.1 into the chamber or system. During operation, \ arious
nuxles are usei.1 lo ensure negali\ e air llow when the chamber is open, ani.1 lo balance the airllow
lo ensure EE negali\ e pressure. .A clamper is usei.1 lo conttol this balance of air llow. .Annex D
contains more i.lelailei.1 llow i-liagrams showing the \ arious nuxles i.lescribei.1 in this section,
inclut-line llow rales.
30
DAVINCH Operational Phase Treatment Phase
Preparation
Pre- Detonation
Detonation
Post- Detonation
Utility Management
Preparation
Vacuum Extraction
Oxygen injection
Detonation
Off-Gas Treatment-1
Off-Gas Treatment-2
Off-Gas Treatment-3
Fragment Recovery
Figure 8. DAVINCH Off-Gas Treatment Phases
31
HEPA Charcoal
Filter Filter
Stack
HVAC
Damper ^-r^
Detonation
Chamber
Containment
Filter Charcoal
Filter Blower
Cha rcoal
Filter
Retention
Tank
3 UnltD Unite
Vacuum LI,, ^
Pump
Unit A
3xidize^»|cooie^»^lowe^-
Unit B
Utility
Figure 9. EDT Block Flow Diagram
3.5.5.1 During pre-detonation, the off-gas system extracts air from the chamber, exhausting
that air through the carbon filter bed. The detonation chamber lid is open in this configuration.
The exhaust air from the HVAC System (reference Figure^, HVAC) is maintained at a constant
flow rate. The air is fed through Unit D during this mode of operation. During this phase,
munitions are himg, detonators set, and processing activity can occur within the chamber. The
damper is used in all phases to equalize air flow and maintain negative EE pressure with respect
to the exterior.
Deleted:
3.5.5.2 jrhe_ Air Vacuum phase (Le... evacuation of the chamber) is accomplished by
activating the vacuum pump, and extracting air from the sealed chamber through Units A and D.
When the appropriate vacuum is established, the chamber is isolated.
3.5.5.3 A stream of oxygen is fed to the evacuated chamber from the Utility area through the
exit of the chamber. The oxygen is used to combine with the detonation product gas and to
optimize the detonation.
3.5.5.4 During detonation, only the HVAC exhausting air from the EE is operational. The
chamber and other components are isolated.
3.5.5.5 After cool down, a preliminary test quantity of the detonation product gas is extracted
by the vacuum pump through Units A, B, and C. If CA is detected at the monitoring point M,
the system re-routes the gas, stops the flow of gas to the DAVINCH exhaust stack and directs the
gas through the Retention Tank Carbon Filter F392 located in Unit C2, The chamber lid remains
closed during this sequence.
3.5.5.6 After the preliminary CA check in 3 5.5, the system operates at full extraction, _
processing all ofthe detonation gas through units A, B, and C, and through the final, exterior
carbon beds.
Deleted: Tliis
Deleted: back througli Unit B for
fiirther treatment in tlie cold plasma
oxidizer.
Deleted: 1
3.5.5.7 The chamber lid is opened when all ofthe chamber off-gas is processed in Treatment
Phase 2. Air flow continues through units A, B, and C, and through the final, exterior carbon
beds.
3.5.5.8 There is a possible mode where the chamber lid is closed, and Electtostatically
Charged Aerosol Decontamination (ECAD) solution is introduced into the chamber from an
outside port. The chamber is isolated during that process. During this mode, the retention tank
is purged through its associated carbon filter. After the chamber is deconned, the system is
exhausted once again through Units A, B, and C.
3.5.5.9 The system reverts to the pre-detonation configuration where the exhaust gas is
removed as in the pre-detonation mode. Fragments are removed by electtomagnet and by hand,
if large enough.
3.6 Throughput
33
Table 5 shows the expeclei.1 throughput for each munition type, in a single or tlouble o\ erpack.
ani.1 samples. This throughput expectation is basei.1 upon the operational experience of 5 years of
operations in Japan ani.1 one year of operation in Belgium. Impro\ements on automatei.1 fragment
hani-lling ani.1 a larger capacity of off-gas treatment are incoqioratei.1 into this tlesign. Three 4.2-
inch HT Motor rouni.ls in M13.A2 single o\ er-packs can be i.letonatei.1 in a single shot, ani.1 a I 55-
mm H Projectile in M I6.A3 1 2.\56 tlouble o\ er-packs can be i.letonatei.1 by one shot, using a total
amount of explosi\ es of approximately I 1 S lb ( 53.6 kg) TNTei.|.
34
Table 5. TOCDF EDT Throughput
IiuiitiDii Ovei^i:ifk(s) Agent
Number of
Muniiioiis &
Samples
MiuiitiDns/
Package
Packages/
Shot
Miuiitioiis/
Sliot
Shots/
Day
Number/
Day Days Weeks' Shots
Agent/
Shot
(lb)
PEP/
Shot
(lb TNTeq)
Donor/
Shot
(lb)
Donor/
Shot
(lb TNTeq)
LSC/
Shot
(lb TNTeq)
Total TNTeq/
Shot
(lb)
4 2" I TMortiB-M13A2 HT 117 1 3 3 7 21 6 1.5 39 17.4 2.55c 87.6 88.8 26.2 117.6
4.2" I-D Mortar M13A2 KD 18 1 3 3 7 21 1 0.3 6 18 2.55c 87.6 88.8 26.2 117.6
ECR
Wasti
vloftars*
iKplosve 3x41 or 7x27 ED orHT See Note a
1 1 1 7 7 2 0.5 7 6.0 2.55c 65.7 66.6 8.7 77.9
155m. n H Projectile M16A3 H 68 1 2 2 7 14 5 1.3 34 23.4 0 86 102.2 103.6 23.3 127.8
155m. n H Projectile 3x41 H 27 1 1 1 7 7 4 1.0 27 11.7 043 76.6 77.7 14.6 92.7
155m n H Projectile M16A3/M10A4 H 16 1 1 1 7 7 3 0.8 16 11.7 043 76.6 77.7 14.6 92.7
155m n H Projectile PA37/12x56 H 8 1 1 1 7 7 2 0.5 S 11.7 043 102.2 103.6 14.6 118.6
155m n H Projectile M16A3/12x56 H 79 1 1 1 7 7 12 3.0 79 11.7 043 102.2 103.6 14.6 118.6
HI S i mples M2A1 HT 41 4 1 4 7 28 2 0 5 11 9 2 0 45.4 46 46 0
HD S imples M2A1 HD 6 4 1 4 7 28 1 0.3 2 5.1 0 45.4 46 46.0
1 Totnl Totals •> 58 <) 5
Either
with tht
s the 7x27. The Total TbTTeq/shot associated ver-pack may be used for /"aste mortars rejected in the TOCDF MDB during the mortar campaign. The 9xA 1 over pack has approjamately twice the r
tteatment of mortars iti either over pack will not exceed the value shown. Mortars may be filled with HD or HT since this grouping repressent aniticipated mortar rejects from TOCDF mortar processing.
•ste sfream is limitc- >.rce ofthe ECR an. C Treatment Unit within the ECRs. The number of DAVTtTCH This Wi
tteatme it shall not exceed 6. T T
'Eased
^PEPw
)n anticipated Four days per week munition processing
^ight included propellant. Note only one over-packed mortar is known to be cotifigured ^mtli propellent.
35
3.7 Operating Procedures
All operating procedures will be provided for review and approval by EG&G. They will include,
but not be limited to:
EDT Control System Operations
EDT Explosive Operations
EDT Off-Gas Operations
EDT Contingency Plan
EDT Delivery, Assembly, and Checkout
EDT Decontamination*
EDT Monitoring And Control Operations
EDT Air Monitoring Plan and Operations*
Analysis Plan and Analysis SOPs*
Waste Management Operations
Material Handling Operations
Maintenance Operations
Metal Fragment Drum Headspace Monitoring Operations*
(The * indicates required approval by DSHW prior to operations.)
3.8 Schedule
The schedule for the EDT program is based on the following assumptions:
• EDT equipment delivery date is on or about November 2010.
• Permitting will be required to be in place prior to any operations; however a temporary
generator may be used during installation until the air permitting process is completed which
will allow for the use ofthe generators that support DAVINCIFM operations.
• Completion of Installation and Systemization is anticipated to occur the first quarter of
Calendar Year (CY) 2011.
• The ORR will take place after histallation and Systemization.
• The operational phase will be completed in approximately 2 months, including maintenance.
• Decommissioning and Removal is anticipated to occur the Second Quarter of CY2011.
3.9 Closure
Annex E provides the Closure Plan for the EDT. Once the munition campaigns have concluded,
the site will be shifted to a decontamination and removal process. Then, when site closure has
been conducted with respect to decontamination levels, the system will be packaged for shipment
and removal. Minimal demolition will be required, and will be limited to a few minor system
components that are not part of the main systems.
Decommissioning is designed into the DAVINCH™ system. A site closure plan will guide the
process of ensuring that the system is completely decontaminated using headspace monitoring to
the Vapor Screen Lunit (VSL) for HD. All components will be decontaminated to the levels , - - { Deleted: short Term Exposure Limit
[ (STEL)
36
specified in the closure plan. The system will be removed and transferred to a federal
installation and stored bv an agency whose workers are trained in chemical agent operations.
The svstem will not be discarded upon completion ofthe TOCDF project, but stored for future
operations.
Components will be removed and enclosed in an approved enclosure (e.g., plastic film), and
monitoring will be conducted to demonstrate that the headspace ^VSL is met._
The system is self-cleaning to a large extent, simplifying the decommissioning process. A
combination of cleansing shots and ECAD are used for decontamination ofthe equipment/
piping. Necessary ports are pre-installed in the equipment and piping to provide an insert point
for the nozzle ofthe ECAD decon wands. As DAVINCH™ has no expansion tank, there is no
concern about accumulation of carbon dust with CA or heavy metals from the munitions paint
residue in the tank. Figure JJ) shows the effect of cleansing shots and Figure JL1, an illustration
of ECAD.
Deleted: Tlie system will be removed
to a site where plant workers are trained
and use the appropriate procedures for
chemical operations; therefore the closure
standard for instances where agent
monitoiing is used on the STEL for HD.
Deleted: STEL
Deleted: 9
Deleted: 10
1 I.-Ml ^h..t
Figure 10. Inside Chamber before
(Left) and after (Right) Cleansing
Shot Figure 11. ECAD Operation
The EDT will use TOCDF-approved decontamination solutions (such as caustic) for equipment
if decontamination is required.
The SOPs for decontamination of personnel are based on the latest Material Safety Data Sheet
(MSDS) for HD and HT. The decontaminating solution that will be used for personnel will be
consistent with the Emergency and First Aid Procedures that are addressed in the MSDS for HD
(revised: 5 March 2009), published by the ECBC. The primary decontaminating solution for a
liquid exposure to HD is warm or hot water with liquid soap. Sterile saline or water will be used
for any eye contact with HD. Decontaminating solution is collected in the washdown pan in the
change out area.
Any heavy metals are expected to remain within the chamber and will be removed using
decontamination procedures based on the type of metal. Heavy metals in the PAS ducting will
also be removed.
37
The chamber and lid systems will be placed on the shipping pads that were used to deliver the
components. A reversal ofthe process will be conducted to ship the system off-site. The off-gas
treatment systems, modular buildings, storage boxes, and utility components will be trucked off-
site. Any hazardous waste will be removed by the operating contractor in accordance with the
TOCDF Waste Management Plan. All general waste will be placed in approved roll-offs for
final disposition. The site will be cleared of debris and returned to Area 10 control after removal
of intemal fencing, wood, or other packing items.
3.10 Description of Occupancy and Destruction of Buildings within Public Access
Exclusion Distance (PAED)
The PAED is defined as the longest distance ofthe hazardous fragment distance (HFD),
Inhabited Building Distance (IBD) for overpressure, or the One Percent Lethality Distance. For
siting purposes, the PAED is analogous to the IBD for explosives; therefore, personnel not
directly associated with the chemical operations are not to be allowed within the PAED. The
PAED for the EDT maximum credible event (MCE) is defined in Annex D of the SSSP^ There
are no occupied facilities in Area 10 within the PAED distance arc. Site access controls will be
used to prevent entry into the PAED area during explosive operations by blocking off the
adjacent roads as necessary.
Annexe ofthe SSSP for the EDT Sit^ defines the MCE for Establishing PAED as the
detonati^on of lYs'lb of TNTeq' the MCE^ as~deYme~d"in DA PAMy85-6l7is"theVoteW^ for an
accident or incident to occur and cause agent release. For chemical munitions that have
explosive components assembled in them, the MCE will be based on the functioning of the most
disruptive component that would produce the maximum release of agent. The explosive safety
quantity distance for the DAVINCH™ site is based on the accidental detonation of 133 lb of
TNTeq, Hazard Division 1.2, and will be documented in accordance with the DoD Standard
6055.9.
Deleted: Aimex D
Deleted: Tlie
Deleted: (Aimex C)
3.11 Waste Analysis Plan
The DAVINCH™ will treat wastes that were previously characterized by TOCDF, and the
DAVINCH™ will generate wastes that are similar to waste currently generated by TOCDF
incinerator operations.
H Projectiles were characterized throughout the 155-mm H Projectile Campaign as different lots
were processed in the Metal Parts Fumace (MPF). Both liquid H and solid heel samples were
collected and analyzed. This waste stream has therefore been thoroughly characterized, and no
further characterization is required.
The HT mortars were characterized during the Parsons Engineering Design Study I Projectile
Washout System (PWS) Testing (Reference 3). Volume 1 (of 3) of this test report, dated 14
August 2004, provides the analytical results ofthe HT liquid agent and HT paste found in HT
mortars, and the liquid HD and solid HD heels found in HD mortars. The TOCDF additionally
collected liquid HT samples directly from mortars prior to feeding them to MPF and from the
Agent Collection Tank to which the drained HT from mortars was transferred. The mortars have
38
been sufficiently characterized by these previously sampling and analysis efforts for their
treatment in the DAVINCH™ considering that the issues with mortar characterization is the
presence of mercury. The DAVINCIF'^ PAS is equipped with sulfur-impregnated activated
carbon filter to control mercury emissions.
Waste generated by DAVINCH™ operation are metal munition and overpack fragments,
condensate formed by the oxidation ofthe hydrogen contained in the chemical agent, munition
burster and explosive LSCs and donor charges, spent scrubber solution, monitormg waste, spent
decontamination solution, particulate filters, ash, spent activated carbon, and discarded PPE.
The estimated quantities of waste to be generated from the DAVINCH™ operation described in
this plan are provided in Table 6.
Table 6. Estimated Waste Generated from DAVINCH Operations
Waste Description
Overpack Configuration Wastes Generated
Waste Description Overpack Overpack Metal Fragments Ash Condensate^ Waste Description Overpack Overpack (lb/Blast) (lb/Blast) (lb/Blast)
4.2" HT Mortar M13A2 98.3 0.55 32
4.2" HD Mortar M13A2 97.7 0.55 30
4.2" HD Mortar 9X41 or 7X27 182.5 0.55 39
155mm H Projectile M16A3 213.3 0.55 37
155mm H Projectile 9X41 117.9 0.55 34
155mm H Projectile M16A3 M10A4 137.5 0.55 33
155mm H Projectile PA37 12X56 234.8 0.55 42
155mm H Projectile M16A3 12X56 250.7 0.55 42
HT Samples M2A1 46.1 0.55 44
HD Samples M2A1 46.1 0.55 38
Totals (lb) • 42,988 133 9,126
^Condensate is the combination of scrubber brine and condensate generated from the oxidation of hydrogen
contained in the agent and explosives.
Metal munition and overpack fragments removed from the Detonation Chamber will be verified
to less than 0.50 VSL based on headspace monitoring results. The fragments will be placed into
barrels that are equipped with both an inlet and outlet valve. The procedure requires an air
purge, introduced into the sealed container using the inlet valve and vented to the Enclosure
HVAC Carbon Filter System through the headspace monitoring drum's outlet valve. The air
purge is then stopped and the valves closed. The contents ofthe seal container are allowed to
equilibrate for four hours at 70 °F before an agent monitor is attached to the outlet valve and the
contents sampled. If the monitoring results show the agent concentration in the drum to be less
than 0.50 VSL, the contents ofthe drum are transferred to a roll-off or DOT-approved shipping
container for disposal at a Subtitle C Treatment, Storage, and Disposal Facility (TSDF).
If the monitoring results show a drum headspace result equal to or greater than 0.50 VSL,,
the drum is moved underneath an intake vent to the Environmental Enclosure, opened and
allowed to vent. After venting the container is resealed and th^ container contents are then
monitored again to determine the agent concentration relative to the 0.50 VSL. . If the
Formatted: Indent: Left: 0 pt
Deleted: an additional air pmge is
perfonned and tlie headspace equalizing
procedure is repeated (i.e., four lioiiis at
70 °F).
Deleted: The
39
drum headspace monitoring results continue to be above the 0.5 \'SL limit for metal
fragments and 1.0 VSL for PPE after venting, the drum and its contents will be transferred
to the TOCDF and processed through the Metal Parts Fumace (MPF).
Condensate from the oxidation of hydrogen in the explosives and agent is combined with _,, - -(Deleted: t
scrubber brine. The waste stream exiting the liquid scrubber will be analyzed for agent content,
TCLP metals and TCLP organics. This waste stream will be transferred to an off-site Subtitle C
TSDF provided the agent analytical results show that the agent content is below the Waste
Control Limit (WCL), which for mustard agents is 200 parts per billion (ppb).
Ash is generated in the DAVINCIF'^ Detonation Chamber; the filters are used to remove
particulate from the Detonation Gas, and the cyclone filter is used to remove particulate from the
Detonation Chamber Ventilation air. The munitions to be processed in the DAVINCH™ were
over-packed either because the agent cavity was breached so that an agent sample could be
collected from the munition or because the munitions developed a leak while in storage. It is
possible that some ofthe over-packs contain packing material and absorbents that were added to
prevent the munition from moving inside the over-pack. The absorbents used were cloth rags
and vermiculite.
This waste steam is anticipated to contain metals in parts per million (ppm) concentrations and
will be sampled and analyzed for agent, TCLP metals, and TCLP organics. This waste stream
will be transferred to an off-site Subtitle C TSDF provided the agent analytical results show that
the agent content is below the WCL, which for mustard agents is 200 ppb.
Spent activated carbon generated from the DAVINCH™ PAS fixed-bed carbon filter will be
sampled and analyzed for agent, TCLP metals, total metals, and TCLP organics. This waste
stream will be transferred to an off-site Subtitle C TSDF provided the agent anal3^ical results
show that the agent content is below the WCL, which for mustard agents is 200 ppb. Tables 7
and 8 summarize the sampling and analysis requirements for the wastes previously discussed.
40
Table 7. TOCDF DAVINCIFM WASTE ANALYSIS SUMMARY (On-Site)
WASTES REQUIRING ON-SITE TREATMENT
WASTE STREAM TREATMENT
UNIT(S)
ANALYTICAL
PARAMETERS,
PREPARATION and
ANALYTICAL
FREQUENC Y OF
ANALYSIS, SAMPLING
- - METHOBL WASTE STREAM TREATMENT
UNIT(S) METHODS, CEstablisli Profile) ________ _ _~
Over-Packed 155-mm H
Projectiles DAVINCH™
Not Applicable; metals
and organics previously
characterized during
TOCDF 155-mm H
Projectile Campaign; data
provided to DSHW
Not Applicable Not Applicable Not Applicable
Over-Packed 4.2-inch
HT Mortars DAVINCHTM
Not Applicable; metals
and organics previously
characterized during
TOCDF HT Mortar
Campaign; data provided
to DSHW
Not Applicable Not Applicable Not Applicable
Over-Packed 4.2-mch
HD Mortars DAVINCH™
Not Applicable; HD
mortar metals and
organics characterized
during Projectile Washout
System Testing; data
provided to DSHW.
Not Applicable Not Applicable Not Applicable
Over-Packed HT and
HD Samples DAVINCH™
Not Applicable; metals
and organics
characterized during
TOCDF Ton Container,
HT, and Mortar
Campaigns. HD mortars
characterized during
Projectile Washout
System Testing; data
provided to DSHW.
Not Applicable Not Applicable Not Applicable
[ Deleted:
•I Deleted:
'( Deleted:
i Deleted:
41
Table 8. TOCDF DAVINCIFM WASTE ANALYSIS SUMMARY (Off-Site)
WASTES REQUIRING OFF-SITE TREATMENT/DISPOSAL
WASTE STREAM
GENERATION
SOURCE
ANALYTICAL
PARAMETERS^
PREPARATION and
ANALYTICAL
METHODS
FREQUENCY OF
ANALYSIS, SAMPLING
METHOD
Munition and Oveipack
Metal Fragments DAVINCH™ Container Headspace
Agent Monitoring PR-010 -Each-Drum Genaated -
Headspace
Monitoring
method; ensuie
iiepresentative - -
sample analyzed
by
MINICAMS™
Spent Scmbber Brine and
Condensate DAVINCH™
Agent HD
TCLP Metals
TCLP Organics
^R-016
Spent Scmbber Brine and
Condensate DAVINCH™
Agent HD
TCLP Metals
TCLP Organics
1311 and 6010 or 6020
and 7470 or 7471
1311 and 8260 and
8270
^040
One sample from each
of 3 containers
generated; composited
into one sample set for
analysis
Coliwasa Spent Scmbber Brine and
Condensate DAVINCH™
Agent HD
TCLP Metals
TCLP Organics
Detonation Chamber and
PAS Particulate Filter
Ash/Over-Pack Packing
Material
DAVINCH™
Agent HD
TCLP Metals
TCLP Organics
^R-016
Detonation Chamber and
PAS Particulate Filter
Ash/Over-Pack Packing
Material
DAVINCH™
Agent HD
TCLP Metals
TCLP Organics
1311 and 6010 or 6020
and 7470 or 7471
1311 and 8260 and
8270
One sample rrom each i
of 4 containers
generated; composited
into one sample set for
analysis
Trier or coring
device
Spent DAVINCH™ PAS
Activated Carbon DAVINCH™
Agent HD
TCLP Metals
Total Metals
TCLP Organics
^ee Note 1
Spent DAVINCH™ PAS
Activated Carbon DAVINCH™
Agent HD
TCLP Metals
Total Metals
TCLP Organics
1311 and 6010 or 6020
and 7470 or 7471
3050 or 3051 and 6010
or 6020 and 7470 or
7471
1311 and 8260 and
8270
Core sample from each
container generated
duiing change out;
composited into one
sample set for analysis
Trier or coring •
device
Deleted:
Deleted: ^
Deleted:' J
"I Deleted: See Monitoring Plan ]
-( Deleted: TE-LOP-57211 ]
"{ Formatted; Font: Not Bold ]
-{ Formatted; Font: Not Bold
-( Deleted: TE-LOP-57211
Deleted: Procedure cuixently under
review
"( Formatted Table
42
Spent Enviionmental
Enclosiue HVAC Svstem
Enviromnental
Eiiclosuie Carbon Aeent HD See Note 2
Core sample from eacii
container generated
during change out; Trier or coring
device Carbon Filter Units composited into one
sample set for analysis
Trier or coring
device
-{ Formatted; Left
"I Formatted; Centered
Notes:
1 Four digit number refer to SW-846 methods, most recent version.
2 Agent monitoring results may be used to demonstrate spent carbon is not contaminated with agent in lieu of performing an analysis
for chemical agent. If required, spent carbon will be place in storage until an DSHW approved method is available for analysis of
agent on an activated carbon matrix.
43
3.12 Personnel Limits and Protective Equipment
3.12.1 Airbome Exposure Limits (AELs)
The Centers for Disease Control and Prevention (CDC) promulgates airbome exposure limits
(AELs) for chemical nerve agents tabun (GA), sarin (GB), VX, and blister agent sulfur mustard
(including H, HT, and HD) for demilitarization workers and the general public (Reference 4).
Exposure criteria include short-term exposure limits (STELs) and immediately dangerous to life
or health (IDLH) values. These new criteria augment revised long-term criteria, which include
Worker Population Limits (WPLs) and General Population Limits (GPLs). The criteria were
revised using various risk assessment approaches, including reference concentration (RfC),
relative potency, categorical regression (CatReg), carcinogenicity potency, and the
CDC/National Institute for Occupational Safety and Health (NIOSH) IDLH methods. The CDC
believes the revised criteria meet the goal of protecting workers and the public at potential
airbome concentration levels below those that would result in adverse health effects from acute
exposure, and further protecting against risk for effects from long-term exposure.
For HD and HT, the AELs are:
• IDLH: 0.7mg/m^
• STEL: 0.003 mg/m^
• VSL: 0.003 mgW
. WPL(8hr): 0.0004 mg/m^
• GPL: 0.0001 mg/m^
3.12.2 Exposure Points
The DAVINCH™ process potential exposure points are:
• Leaking Overpack/at Delivery .QY^rpacked munitions are delivered to the DAVfflCH™
in a box truck. The sealed storage compartment is monitored for agent. If the monitoring
results are confirmed to be greater than 0.5 VSL the delivery is not accepted and the contents
of the tmck are retumed to DCD to be overpacked and processed by the DAVINCH at a later
date.
• Leaking^fter Receipt from DCD ^ICthg^I^^^QF^H^J^ft-fl^tjiin the_DAVIIsOP^_
Environmental Enclosure the overpacked munition will be placed in a plastic bag to stop the
release of agent vapors and prevent contamination and the bagged overpacked munition will
be treated in the DAVINCH m the intended maimer.
• Leaking after Entry into Chamber - If agent is detected in the chamber after hanging the
mimition, the DAVINCH™ process will continue. Personnel decontamination may be
necessary, which will follow established procedures.
• Exposure after Detonation - While potential for this scenario is low, any alarms after the
detonation will be investigated. Personnel will back out ofthe area for decontamination, and
the control system will place the system in the fail-safe mode. Established procedures will be
used to isolate, decontaminate, and address the cause of the leak. It should be noted that after
nearly 6,000 shots, no exposure has been detected at any of the DAVINCIP^ sites.
3.12.3 Personal Protective Equipment
Deleted: The oveipacked iiiimitions
will be checked prior to placement in the
transfer truck. If, after transport, the
munitions are leaking, vapor or Mquid
exposure could result in the Unpack Area.
The Unpack Area is equipped with near
real time monitoring, and if a leaking
overpack is identified, established
procedures will be used to isolate,
decontaminate, and repack tlie item, after
wlrich it will be removed from the site
and retimied to DCD storage
Deleted: during Placement of Donor
Charges
Deleted; If the monitoring alarm
soiuids during donor charge placement,
pereonnel will back out, and response
procedures will be implemented. Tlie
explosives will be stabilized and
decontaminated accordiug to estabhslied
procedures to isolate, decontamuiate, and
repack the item after which it will be
removed from the site and retumed to
' storage.
Formatted: Font: Bold
44
The PPE for the operator crews will consist of supplied PPE, including but not limited to
coveralls and cotton goods to be worn by operators during chemical weapons operations, and
Toxicological Agent Protective (TAP) gear to include butyl boots, gloves, and M2A1 Aprons as
required. Respiratory protection will be through M40 masks with approved activated carbon
canisters. The M40 mask combines the protective mechanisms of a charcoal filter against CWA
vapors (especially nerve agent and vesicant).
3.13 Mitigation of Hazards (including Contingency Plans)
Annex F provides the TOCDF EDT Emergency Response Plan, which will be the guiding
document for contingency planning for EDT operations.
3.13.1 Containment
The DAVINCH'^'^ containment systems are based on the following levels of containment/
engineering controls. The "primary" containment for the munitions are the existing overpacks.
The "secondary" or DAVINCH™ containment is the chamber itself The detonation chamber lid
has a space to capture escaping gas, and the skid-mounted off-gas units are contained in 40-ft
containers, ducted to the EE enclosure. The whole process of receipt and preparation of
munitions, the detonation chamber imit, waste handling, and the off-gas treatment are contained
in a temporary plastic-film (with aluminum- or steel-framed) shelters acting as the EE
containment stmcture. The airflow from the EE containment provides a design negative pressure
-0.10to-0.5inWC.
3.13.2 Safety in Enclosure
Safety systems included in the enclosure have explosion mitigation barriers in accordance with
DoD 6055.9-STD, DoD Ammunition and Explosives Safety Standards (02-29-2008). In
addition, worker safety will be ensured through a lockout/tagout program, a PA system for
notification, CCTV observation. Occupational Safety and Health Administration (OSHA) safety
markings and exclusion area markings within the facility, railings and buffer zones, and waming
or informational signage. Training will also be conducted to ensure safe operations in the
enclosure.
3.13.3 PPE Fit Testing
All operators will be responsible for ensuring that their PPE is fit for use, properly wom, and
checked on a periodic basis.
3.13.4 Emergency and Evacuation
In the event of an upset condition, mimitions operators, site workers, and site control system
operators will be notified by the PA system. Evacuation will then occur in accordance with the
SOP for response to upset conditions requiring evacuation. The operators will report to a
designated location and will be checked against the site occupancy sign-off list for the day to
ensure that all are safely evacuated.
3.13.5 Emergency Response Actions
45
The TOCDF and DCD have in place assets, programs, and plans for emergency response. The
TODCF will provide response to any EDT incident requiring emergency response. The EDT
operation will have a direct line to the TOCDF operations center for notification of upset or
emergency situations, such as a chemical event.
3.13.6 Medical Support
The TOCDF has a Medical Clinic available for handling medical emergencies, including
exposure to toxic agents, decontamination, and triage.
46
4.0 ORGANIZATION
The overall organization for the EDT Project at TOCDF is shown in Figure j. 2. Deleted: 11
Chemical Materials
Agency
Site Manager
Deseret Chemical
Depot
1
TOCDF
Site Manager
EDT Subcontractor
Figure 12. TODCF EDT Overall Organization
4.1 U.S. Army
The principal US Army organizations involved in implementing this Plan include the Chemical
Materials Agency (CMA), the Tooele Chemical Agent Destmction Facility (TOCDF), the
Deseret Chemical Depot (DCD), and Edgewood Chemical Biological Center (ECBC).
CMA provides oversight for the operation through its on-site representative.
DCD provides operations support in Area 10, munition transportation within Area 10, security,
surety and logistics support.
TOCDF provides the assets including emergency response, firefighting, and chemical/hazardous
materials response.
ECBC provides the assets of CBARR, for trained CPRP- and explosive- certified operators,
monitoring equipment, and mobile laboratory support.
4.2 State of Utah
The UDEQ will provide environmental regulatory oversight of the DAVINCIP^ operation at
TOCDF. The DAVINCIFM operation at TOCDF will be conducted under a Modification to the
RCRA and CAA permits for TOCDF and DCD, respectively.
47
4.3 Contractors
The TOCDF Operatmg Contractor, EG&G DMI (URS) will provide oversight ofthe EDT
subcontractor, Versar, Inc.
4.4 EDT Site Operational Organization
The EDT Site Operational Organization is shown in Figure The EDT Subconttactor w
provide the EDT equipment, and will control operations to ensure that destmction is conducted
in a safe and environmentally acceptable
manner.
The total mmiber of people on the operations team is approximately 18. The operation team
consists of one supervisor, one safety manager, two technical specialists, two analysts, five
groups of two persons each for operation (using the two-man mle buddy system) and 2 persons
for monitoring on night shifts and weekends.
Deleted: 12
Site Supervisor
Site
Heaitli and Safety
Site Engineering
Chemical
And
Explosive
Operators
Monitoring
Staff
Figure 13. EDT Site Operation Organization
Table ^ shows the role of each group for e_yery^ shot. Groups A, B, C, and D change the role for
every shot to reduce the total time of work in PPE. Group E operates DCS at the control room
without PPE; therefore. Groups A, B, C, and D are required to be EOD and mechanics, while
members of Group E should be engineers/chemical process operators.
Table shows the job and related qualification/e?^ for the personnel
comprising the groups. Groups A, B, C, and D should have the same qualifications/experience
and perform the same jobs alternatively in the field. The job of Group E is completely different
from A through D. Group E's job is to control the plant operation at the control room and no
field work is necessary. The Training Plan, Annex G, describes the type, frequency and
requirements for operator training for the TOCDF EDT.
Deleted:
Deleted: 9
48
DEPARTMENT OF THE ARMY
us ARMY CHEMICAL MATERIALS AGENCY (PROVISIONAL)
PROGRAM MANAGER FOR THE ELIMINATION OF CHEMICAL WEAPONS
4585 HOADLEY ROAD
ABERDEEN PROVING GROUND, MARYLAND 21010-4005
REPLY TO ATTENTION OF:
SFAE-CD-S 1 ^ 2003
MEMORANDUM FOR SEE DISTRIBUTION
SUBJECT: Performance Standard for Monitoring Potentially Contaminated Workers
References
a. Memorandum, Office of the Assistant Secretary of the Army, Installations and
Environment, 10 Jun 03, subject: Interim Guidance on Nerve and Mustard Agent
Decontamination and Medical Services in Industrial Activities.
b. Memorandum, US Army Chemical Materials Agency (CMA), AMSCM-D, 10 Jun
03, subject: Performance Standard for Monitoring Potentially Contaminated Workers.
2. This memorandum clarifies procedures and monitoring levels for evaluating
contaminated workers and supersedes guidance published in reference 1b. Clarified
guidance is enclosed.
3. CMA verify decontamination of agent contaminated workers using near real time
monitors set to the certified reporting limit before the worker leaves the accident site. At
any time during the decontamination procedure, medical or supervisory personnel may
decide to transport the contaminated worker to the health clinic or begin life saving
medical care.
4. Referenced lb Performance Standard was prepared by an interdisciplinary team
composed of representatives from the Program Manager for Chemical Demilitarization,
the US Army Edgewood Chemical Biological Center; the US Army Soldier and
Biological Chemical Command (SBCCOM), Stockpile, Industrial, Remediation, and
Restoration Enterprise, and the US Army Center for Health Promotion and Preventive
Medicine which was formed to develop guidance for point source monitoring from
currently available instruments. It has been modified based on input from users. This
guidance addresses monitoring levels to be achieved, required monitoring times,
identifies levels to determine when re-decontamination is required and establishes the
information on the material safety data sheet (MSDS) as the standard for
decontamination procedures.
SFAE-CD-S
SUBJECT: Performance Standard for Monitoring Potentially Contaminated Workers
5. Points of contact for further information are LTC Alan Cushen, SBCCOM Risk
Manager, [phone] or Mr. Steve Blunk, Chief, CMA Safety Office, (410) 436-
1435/3325.
End MICHAEL A. PARKER
Director
DISTRIBUTION:
AMSSB-OAN-CO (LTC Robert E. Jones)
AMSSB-OBG-CO (LTC Dennis M. Cantwell)
AMSSB-OCD-CO (COL Peter C. Cooper)
AMSSB-OEC-CO (LTC Gerald L. Gladney)
AMSSB-ONC-CO (LTC Joseph F. Marquart)
AMSSB-OPB-CO (COL Thomas Woloszyn)
AMSSB-OPA-CO (LTC James Bayha)
AMSSB-OPC-CO (LTC John A. Becker)
AMSSB-OUM-CO (LTC David Holliday)
SFAE-CD-CO-A (Timothy Garrett)
SFAE-CD-CO-T (Dale Ormond)
SFAE-CD-CO-P (Randy Long)
SFAE-CD-CO-U (Don Barclay)
SFAE-CD-AA (Joseph Lovrich)
SFAE-CD-AN (Jeffrey Brubaker)
SFAE-CD-N (LTC James P. Fletcher)
CF:
AMSSB-OAN-CO (Mary Snyder)
AMSSB-OBG-RD (Richard Hancock)
AMSSB-OCD-RM (Walt Levi)
AMSSB-OEC-DO (Paul Lemeshka)'
AMSSB-ONC-CO (Michael Orn)
AMSSB-OPB-RRS (Mark Lumpkin)
AMSSB-OPA-RM (Tony Poole)
AMSSB-OPC-RM (Pat Steranka)
AMSSB-OUM-IRM (Mervin Beck)
SAILE-ESOH (Jim Patton)
AMCPE-SF (Don Pittenger)
AMSSB-OSM (Trooper Studdert)
SFAE-CD^S (Gregory St. Pierre)
SFAE-CD-S
SUBJECT: Performance Standard for Monitoring Potentially Contaminated Workers
CF (Cont'd):
AMSSB-RCB-R (George Collins)
MCHB-TS-OFS (Stephan Graham)
PMATA
PMCSD
PMCSD (Tim Thomas)
PROCEDURES FOR NEAR REALTIME MONITORING
OF AGENT CONTAMINATED WORKERS
Chemical sites and operations involving chemical agent will implement the following
procedures when workers are contaminated with chemical agent (e.g., potentially
exposed workers, ref 1). At any time during the decontamination procedure, medical or
supervisory personnel may decide to transport the contaminated worker to the health
clinic or begin life saving medical care. As new technologies become available, they
may also be used as long as the technology meets the following performance standard:
"Chemical Materials Agency will verify decontamination of agent contaminated workers
using near real time monitors set to the certified reporting limit before the worker leaves
the accident site."
a. The primary type of jnstrument to determine if a worker is contaminated is near
real time chemical agent monitor (NRT monitor). The Automatic Continuous Air Agent
Monitoring System (ACAMS), the Miniature Chemical Agent Monitor (MINICAMS®), or
other low level near real time monitor is acceptable for this purpose. Regardless of
which instrument a site uses, trained personnel must properly maintain, calibrate, and
operate the low level NRT monitor. Site personnel must retrain the workforce on the
proper utilization ofthe existing low level NRT monitor hand-held probe using these
procedures.
b. To be effective, site personnel must pass the low level NRT monitor probe slowly
and deliberately over the contaminated worker for one full low level NRT monitor
sampling cycle. The probe must remain within one to two inches from the
contaminated worker's body. Properly protected personnel will screen the
contaminated worker's body by quadrant starting at the head. To achieve a slow and
deliberate screening of a contaminated worker, the low level NRT monitor operator will
coach the worker handling the probe on when to move to the next quadrant. One-
fourth ofthe low level NRT monitor sampling cycle will be spent on each quadrant of the
contaminated worker's body. As an example, for a low level NRT monitor running on a
two-minute cycle, thirty (30) seconds will be spent screening the face, chest, and
abdomen; thirty (30) seconds screening the head, arms (including each hand) and
back; thirty (30) seconds screening the pelvic region and front ofthe legs; and thirty
(30) seconds screening the back ofthe legs, feet, and buttocks. The low level NRT
monitor operator will verbally tell the worker with the probe how far they have
progressed in each cycle. Low level NRT monitor operators and probe operators must
practice this screening procedure at least quarterly.
c. For chemical sites and operations that do not have low-level NRT monitors, the
site safety plan must address the decontamination and screening of contaminated
workers to ensure workers are adequately protected.
d. The site will base the level of decontamination on the extent ofthe worker's
injuries. If after the initial decontamination, the NRT monitor operator still receives
reading above the certified reportable limit, the worker will be re-decontaminated if the
medical situation permits. At any time during the decontamination procedure, medical
or supervisory personnel may decide to transport the contaminated worker to the health
clinic or begin life saving medical care.
e. Site personnel will decontaminate all contaminated individuals according to the
emergency and first aid procedures listed on the agent material safety data sheet.
EDT DESTRUCTION PLAN
ANNEX A - ACRONYMS AND ABBREVIATIONS
November 2010
Formatted: Font: 14 pt
Formatted: Font: (Default) Times
New Roman, 14 pt
.\NIVE\ .\ - .\CRONMVlS .\ND .\BBRE\l.\TIONS
This .\nne.\ presents the .Acronyms and .Abbre\ iations used in the TOCDF EDT
Destruction Plan ani.1 .-\rine.\es.
.A-1
ACRONYM/ABBREVIATION
ANSI
AR
ASME
ATAP
ATF
CA
CAA
CBARR
CCTV
CDSP
CEES
CMA
CWM
DA PAM
DAAMS
DAVINCH
n-DBS
DCD
DDESB
DEQ
DESTINY
DSHW
DOT
DV60
ECAD
ECBC
EDT
EE
EG&G DMI
GC/MS
GRAND
H
HAZMAT
HD
DEFINITION
American National Standards Institute
Army Regulation
American Society of Mechanical Engineers
Altemative Technologies and Approaches
Program
Bureau of Alcohol, Tobacco and Firearms
Chemical Agent
Clean Air Act, as amended
Chemical Biological Applications & Risk
Reduction
Closed Circuit Television
Chemical Stockpile Disposal Program
Chloroethylethyl Sulfide
Chemical Materials Agency
Chemical Warfare Mimitions
Department ofthe Amiy Pamphlet
Depot Area Air Monitoring System
^Detonation of Ammunition in a Vacuum
Integrated Chamber
di-Butvl Sulfide
Deseret Chemical Depot
Department of Defense Explosive Safety
Board
Department of Environmental Quality
Damage Evaluation System - Time? Not
Yet!, as in real time damage assessment
system for DAVINCH
jPiyision of Solid and Hazardous Waste
Department of Transportation
DAVINCH EDT Chamber, 60 kg TnT Net
Equivalent Capacity
Electrostatically Charged Aerosol
Decontamination
Edgewood Chemical Biological Center
Explosive Detonation Technology
Environmental Enclosure
EG&G Defense Materials, Inc., Operating
Contractor, TOCDF
Gas Chromatography/Mass Spectrometry
Global Rapid Assistance Network of
DAVINCH
Mustard agent
Hazardous Materials (as in response team)
Mustard agent
Deleted: Detonation in a Vacuum
Integrated Chamber
I Deleted: Department
A-2
ACRONYM/ABBREVIATION DEFINITION
HEPA High efficiency particle arresting
HFD Hazardous Fragment Distances
HT Mustard agent
HVAC Heating, Ventilation, and Air Conditioning,
as in system
IBD Inhabited Building Distance
IDLH Immediate Danger to Life and Health
lOP Intemal Operating Procedure, ECBC
LPG Liquified Propane Gas
LSC Linear Shaped Charges, explosives
MARB Material Assessment Review Board
MINICAMS Miniature Chemical Agent Monitoring
System
MPF Metal Parts Fumace
MSDS Material Safety Data Sheet
NaOH Sodium Hydroxide
NFPA National Fire Protection Association
pSHA Occupational ^afetv and Health
Administration
ORR Operational Readiness Review
PA Public Address System
PAED Public Access Exclusion Distance
PAS Pollution Abatement System
PM-CSE Program Manager, Chemical Stockpile
Elimination
PPE Personal Protective Equipment
PWS Projectile Washout System
QA Quality Assurance
Q-D Quantity-Distance (arcs)
RCRA Resource Conservation and Recovery Act
RCWM Recovered Chemical Warfare Munitions
SETH Simulated Equipment Test Hardware, as in
simulated munition bodies
SOP Standard Operating Procedure(s)
SSSP Site Specific Safety Plan
TAP Toxicological Agent Protective, as in gear
TC Ton Container
TCLP Toxic Characteristic Leaching Procedure
(EPA requirement)
TNTeq TnT Equivalent, explosives
TOCDF Tooele Chemical Agent Destruction
Facility
TSDF Treatment Storage Disposal Facility
UAP Unescorted Access Program
UL Underwriters Laboratory
A-3
Deleted: OHSA
-\ Deleted: Health and
ACROINr\M/ABBRE\ lATION DEFIIMTION
L^PS UninletTuplei.1 power suppl\'
US.ATCES US .Arm\' Technical Center for E.\plosi\ es
Saret\-
\'SL \'apor Screening Le\el
W'C Inches of water column, as in pressure
(.iilTerenlia!
WCL Waste Control Limit
WPL Worker Population Limit
.\-4
EDT DESTRUCTION PLAN
ANNEX B
MONITORING PLAN
rRev. 1)
November 2010
SITE-SPECIFIC MONITORING PLAN
(Rev. 1)
155-mm Leaker Campaign
Explosive Destruction Technology (EDT) Operations
Deseret Chemical Depot (DCD)
Submitted to:
A niibhH ur
EG&G Defense Materials, Inc.
A Division of URS, Inc.
11600 Stark Rd.
Stockton, UT 84071
Submitted by:
VERSAR
Versar, Inc.
6850 Versar Center
Springfield, VA 22151 ^ { Deleted: August 23,2010
• - -[ Formatted; Indent: Rrst line: 0 pt
j^ovember 2010,__ /^.^ Deleted-.^
11
TABLE OF CONTENTS
TABLE OF CONTENTS i
.\PPEIVDICES ii
LIST OF TABLES iiii
LISTOFnClTiES iiii
1.0 INTRODUCTION l
1.1 B\CKGROLiND 1
1.2 PlfRPOSE 2
1.3 SCOPE 2
1.4 CiiiAiK .\i, .\GEiNTS Ol-CONCERN 2
1.5 MONITORINC ()B.|i:(TI\ ES 3
2.0 ORGANIZATION AND NL\NAGEMENT RESPONSIBILITIES 3
2.1 CMA 3
2.2 CMA-MoNiTORiNG OFFICE 4
2.3 ECBC 4
3.0 MONITORING CONCEPT 4
4.0 MONITORING ST.\ND.\RDS .\ND CONTROL LIMITS 5
4.1 AELs FOR CHEMIC.\L AGENTS 5
4.2 .\ELDEFIJNITIOINS 6
5.0 MONITORING .\ND S.\MPLING EQllPMENT 10
5.1 MEMCXMS"^" EQUIPMENT DESCRIPTION lo
5.2 DAAMS S.\MPLiNG EQii|p\[ENT DESCRIPTION lo
5.3 NE.\R-RE.\L-TIME MONITORS lo
5.4 DEPOT ARE.\ AIR MONITORING S^ STEM 11
5.5 DILUTION AIR FLOW CONTROLLERS(DAFC) 11
5.6 B.\CKUP EQUIPMENT 11
5.7 MoNiTORiNG.\ND AN.\L^Tlc.\L EQUIPMENT OPER\TIONS.\NDNL\INTEN.\NCE (O&M)
REQUIRE\ENTS 11
6.0 MONITORING OPER.\TIONS/STR.\TEGIES l"
6.1 .\RT/(:ONFIR\I.\TION 1 7
6.2 I IlSTORIC.\iy(\)NFIRMVnON 1 7
7.0 MONITORING S\ STEMS 18
7.1 NRT MoiviTORLNG 25
7.2 CONFIRM.vnoN MONITORLNC 2S
7.3 FIRST ENTR^• 3o
7.4 HE.\DSP.\CE 31
7.5 PERSONNEL DECONT.\MIN.\TION ST.\TION (PDS) 31
7.6 HISTORIC.^, MONITORING 31
1
TABLE OF CONTENTS (continued)
7.7 \'.\poR SCREENING 31
8.0 S.\MPLE AND .\N.\L\ TIC.\L METHODS 32
9.0 .\L.\RM RESPONSE/REPORTING POSITIN E CHENOCAL M\TERIEL
RESPONSES 32
9.1 MOIVITORUNG LE\ ELS 32
9.2 MIN1CAMST"AL.\RM SETPOINTS 32
9.3 NRT .NOTIFIC.VTIONS 32
9.4 CONFIRAUTION .\ND HLSTORIC.\L NOTIFIC.\TIONS 33
9.5 W PL EXCURSIONS 36
10.0 MONITORING OF POTENTIALL\ EXPOSED W ORKERS 36
11.0 Ql'ALIT\ CONTROL REQI'IREMENTS 36
11.1 CFRTIFK ATioN REQUIREMENTS 36
11.2 C.\LIBR.\TION .\NDTEST METHODS 39
11.3 QCS.\MPLING 40
11.4 S.\MPLE R\NDLING .\ND ST0R.\GE 42
11.5 ST.VHSTK AL N'ALIDATION 44
11.6 QC OF DAAMS TUBES 45
11.7 TUBE CONDITIONING 45
12.0 DOCnVIENT.\TION 46
12.1 GENER.\L MONITORING DOCUMENT.\TION 46
12.2 EQUIPMENT DOCUMENTATION 46
12.3 REFERENCE STANDARDS 46
13.0 TRAINING REQI'IREMENTS 46
.\PPENDICES
.\PPENDL\ 1 .ACRON^TvlS .\BBRE\"LATI(:)NS TERMS 45
.\PPENDL\2 REFERENCES 49
LIST OF TABLES
4-1 H"HD HT .AELs 7
4- 2 H HD HT .AELs S
5- 1 Description ani.1 Rei.|uiremenls I'or Monitoring ani.1 Sampling Ei.|uipment 1 2
5- 2 Support Gases Ei.|uipment Rei.|uirements 16
6- 1 Monitoring .Application ani.1 Monitor Type IS
7- 1 Summary- of Monitoring Strategv for D.AMNCH'^" DCD EDT Operations 2o
9-1 NRT No'tification Matri.x '7.'. 32
9-2 D.AAMS Tube .Analysis Matrix 33
I 1-1 (^C Requirements for lOP Nrr-o2 35
I 1-2 (^C Requirements for lOP NTT-Li 36
I 1-3 Samples Sizes lor Normal Inspection I'or Ma.\imum ol" 2.5 Percent Nonconlbnnance..43
USTOFFIGlTiES
7-1 Monitoring Locations ani.1 Diagram of D.A\TNCH'''" S\stem 19
1.0 INTRODl'CTION
This i-locument presents a site-specific plan for air ani.1 waste monitoring at the site ofthe
Detonation of .Ammunition in a \'acuum Integratei.1 Chamber ( D.A\TNCH''''^) E.\plosi\ e
Destruction Technology (EDT) System at the Deseret Chemical Depot ( DCD). Stockton. Utah.
This plan atklresses the monitoring rei.|uirements as specifiei.1 in the U.S. .Army Chem ical Materials
.Agency ('CMA) Progrummutic Monitoring Concept Plan (MCP). the CMA Progrummutic
Luhorutoiy an J Monitoring Quality- .Assurance Plan (LNK^.AP). ani.1 the Ei.lge\vooi.l Chemical
Biological Center ( ECBC) En\ ironment Monitoring Laboratory. Lahoratoiy anJMonitoring
Quality- Control Plan (L\ IQCP) Jbr Chemical Materials .-\genc\- (CM.-i) anJJbr Chemical .-\gent
StanJarJ .Analytical Reference Material (CAS.ARM).
1.1 B;ickground
EG&G DND. a contractor to the U.S. .Army ani.1 operator ofthe Tooele Chem ical Demilitarization
Facility (T(!)CDF). Iocatei.1 on the DCD. has a rei.|uirement for a technology to process 351 reject
munitions that either e.Khibitei.1 or ha\e a high probability of exhibiting contlitions that LIO not
allow them to be processei.1 using baseline practices. The T(!)CDF researchei.1 other technologies
usei.1 to i-lestroy leaking ani.1 ON eqiacketl chemical weapons, inclutling E.\plosi\ e Destruction
Technology (EDT) that has been or is currently being usei.1 in the Unitei.1 States. Unitei.1 kingtlom.
Belgium, ani.1 Germany.
E.\plosi\ e Destruction Technology e\ ol\ ei.l from an increasing neei.1 to safely tlestroy reco\ erei.l
chemical warfare material (RCWM). The EDTs ha\ e safely i.lestroyei.1 RCWMs in Pine Bluff.
.Arkansas: Waianae. Hawaii: Porton Down. Unitei.1 kingtlom: Poelkapelle. Belgium: ani.1 Munster.
Gemiany. Riot control ani.1 \ arious mustan.1 agents (with ani.1 without energetics) ha\ e also been
safely i.lestroyei.1 by EDTs. These EDTs ha\ e also pro\ en elTecti\ e for tlestruction of
con\ entional weapons.
EG&G DND has subcontractei.1 with \'ersar. Inc.. to pro\' itle EDT ser\ ices to inclutle a i.letonation
chamber. e.Khaust gas filtration system. en\ ironmental enclosure with engineerei.1 cascatle
\ entilation system, all necessary subsystems ani.1 operators as a complete package: this package
will be i.leli\ erei.l to. installei.1. systemizei.1. operatei.1. closei.1. ani.1 remo\ ei.l from the DCD in
Stockton. Utah. The EDT system to be provided by \ ersar ( i.e.. D.A\TNCH'r". model D\'6o )
will process the chem ical warfare material ('CWM) in\ entory of 1 55-mm Projectiles ani.1 4.2-inch
Mortars ( leakers ani.1 rejects) ani.1 agent samples storei.1 at the T(!)CDF ani.1 ii.lentifiei.1 for e.\plosi\ e
system tlestruction tlisposal by the Munitions .Assessment Re\ iew Boan.1 (NLARB). The chemical
agent of concern for these munitions is mustan.1. The EDT process at DCD is to run parallel to
T(!)CDF"s current baseline schetlule so as not to impact T(!)CDF mission completion by the CWC
treaty i.late.
The E.\plosi\e Detonation System concept of operations is to tlestroy o\erpackei.l chemical
munitions using specializei.1 e.\plosi\ e tlonor charges in a \ acuum-assistei.l. multiple-layerei.1.
annorei.1 steel chamber capable of containing the explosion. The extreme pressures,
temperatures, ani.1 shock wa\ esgeneratei.1 by the tlonor charge tlestroy the o\ erpack. munition
boi.ly. e.\plosi\ es burster charges containei.1 in the munitions, ani.1 chemical agent fill in
microseconi.ls. (!)perations will be controllei.1 from a remote control room that contains all human-
machine interface, process monitoring. CCT\'. ani.1 communication ei.|uipment. The D\'6o has
the capacity to tlestroy 1 33 lb (60 kg of TNT ei.|ui\alent) of e.\plosi\es ani.1 all ofthe specifiei.1
1
munitions listed in the REP without unpacking or other pre-treatment, in a lO-hour-day/4-day-
per-week operation mode.
The system's major subsystems include:
DAVINCHTM Explosive Detonation Chamber;
Off-Gas Treatment System;
Control System;
Utility System; and
Ancillary Equipment
The general personal protective equipment (PPE) to be wom during EDT System operations will
be Level C. However, all monitoring will be performed at levels required for unmasked workers,
designated as "no respiratory protection" in airbome exposure limit (AEL) tables.
A typical operational day will be 10 to 12 hours. All MINICAMS™ monitoring systems will
operate continuously under normal baseline and, therefore, will be challenged during non-
operational hours. However, if mobile criteria are used, challenges may occur periodically in
accordance with LMQAP. Chemical agent products are not intended to be stored on-site in the
Environmental Enclosure (EE) during non-operational hours.
1.2 Purpose
The purpose of this plan is to provide the strategy to monitor for potential airbome vapor
concentrations and generated waste products for the chemicals of concem during operation ofthe
DAVINCH™ System at the DCD EDT site. The monitoring equipment will serve to provide
agent detection, worker and general population protection at the site, and to indicate whether or
not EDT operations are in control.
1.3 Scope
This plan establishes monitoring objectives, procedures, and responsibilities for the execution of
a monitoring program at the DCD EDT site. Monitoring strategies used to support operations at
the site are based on the following assumptions:
• The chemical material contents of each munition/item have been identified.
• Items will be processed based on a predetermined quantity per day.
• The EDT unit will be located in an EE.
1.4 Chemical Agents of Concern
The DAVINCIF'** EDT System will be used to destroy munitions/items filled with the following
chemical agents:
• Levinstein mustard (H), or bis(2-chloroethyl) sulfide. Mustard produced by
2
the levinstein process contains about 30 percent sulfur impurities. The H is
monitored as distilled mustard (HD).
• Distilled mustard (HD), or bis(2-chloroethyl) sulfide, CAS number 505-60-2.
The HD is H that has been purified by washing and vacuum distillation to reduce
sulfur impurities.
• HT, or a lethal vesicant composed of approximately 60 percent HD [bis(2-
chloroethyl) sulfide] and 40 percent agent T {bis[2-(2-chloroethylthio)ethyl]ether}.
Both HD and T are alkylating agents. The HT is monitored as HD.
1.5 Monitoring Objectives
Monitoring during DAVINCH^'^ EDT operations will be performed to ensure that chemical
material destmction operations are being safely conducted, and to detect any conditions that may
cause a release of chemical material. Monitoring of the DCD EDT site during treatment activities
will:
• Provide worker protection.
• Protect the environment from a potential chemical agent release.
• Provide early waming to decision-makers for implementation of corrective
action(s).
• Verify that treatment activities are complete.
• Verify that cleanup activities satisfy necessary performance/compliance
standards.
For the chemical agents of concem, exposure limits are based on maximum concentration values
that are not to be exceeded for a given period of time, depending on the level of protection wom by
personnel. In general, unmasked workers should not exceed established unmasked worker
time/concentration Short-Term Exposure Limits (STEL) and/or Worker Population Limits
(WPL).
2.0 ORGANIZATION AND MANAGEMENT RESPONSIBILITIES
The EDT operations at DCD will require collaborative efforts between several govemment agencies.
2.1 CMA
CMA is responsible for:
• Developing and coordinating all plans and procedures required for EDT
operations.
• Ensuring that appropriate review/approval of EDT procedures is obtained from the
Department ofthe Army (DA) and outside agencies.
• Implementing a quality assurance (QA) program.
• Ensuring that Occupational Safety and Health Administration (OSHA) and DA
health and safety requirements are met
• Overseeing agent treatment and certifying that treatment is complete.
2.2 CMA-Monitoring Office
The CMA-Monitoring Office is responsible for:
Notifying outside agencies such as the Department of Health and Human Services
(DHHS) of monitoring results.
Defining laboratory and monitoring QA requirements for monitoring activities.
Advising on laboratory-related quality assurance/quahty control (QA/QC) practices.
Recoiumending QA/QC practices for use in supporting the EDT monitoring
activities.
Monitoring the effective implementation of this SSMP at the DCD EDT site.
Reviewing QC data and recommending remediation, as required.
2.3 ECBC
Monitoring operations will be conducted by the ECBC Monitoring Branch. ECBC will:
Collect md retain all monitoring data and monitoring QC data generated during
the project.
Provide guidance for monitoring operations conducted on-site.
Provide trained and certified personnel to set up, calibrate, and challenge
monitoring equipment; and collect monitoring and waste screening samples.
Provide calibration and challenge research development, test, and evaluation
(RDT&E) standards for chemicals of concem.
Perform monitoring procedures outlined in this plan.
Provide an operational Mobile Analytical Platform (MAP) configured with
instrumentation capable of analyzing Depot Area Air Monitoring System (DAAMS)
tubes.
3.0 MONITORING CONCEPT
Monitoring for toxic chemicals is a critical element for the effective implementation of the U.S.
Army's cardinal principle, which is defined as follows:
"The cardinal principle to be observed in any location or operation
involving explosives, ammunition, or toxic chemical agents is to
limit the potential exposure to a minimum number ofpersonnel,
for a minimum period of time, and to a minimum amount of the
hazardous material consistent with safe and efficient
operations. " (DA Pam 385-61, March 2002, Parag}~aph 6-1).
To effectively implement the cardinal principle, engineering controls, administrative controls,
and PPE are used in combination, and each play a critical support role. Engineering and
administrative controls shall be implemented, when practical, to minimize:
• Number of personnel involved in operations;
• Persormel exposure time; and
• Toxic chemical concentrations.
Use of engineering and administrative controls shall be implemented to the extent possible to
reduce the PPE level of protection. When engineering and administrative controls are not
practical or are determined to be insufficient, PPE shall be considered for effective mitigation of
potential exposure.
Monitoring shall be used to evaluate the overall effectiveness of engineering and administrative
controls, and when PPE is used, monitoring shall be used to ensure that levels, as defined in
section 4.0, are not exceeded.
Placement of each monitoring/sampling point shall be based on potential chemical migration
points, and designated monitoring points shall be verified via the use of sulfur hexafluoride (SF6)
or smoke tests. When monitoring supports personnel protection, monitoring locations should be
located in close proximity to personnel work activities. All monitoring devices used for
CWM detection shall satisfy the certification and performance requirements specified in the
CMA-LMQAP, most current revision.
4.0 MONITORING STANDARDS AND CONTROL LIMITS
Airborne Exposure Limits (AELs) for H, HD, HT, at the STEL, WPL, General Population
Limit (GPL), Vapor Screening Limit (VSL), and Source Emission Limit (SEE) are listed in
Tables 4-1 and 4-2.
4.1 AELs for Chemical Agents
Values identified in Table 4-1 are final CDC recommendations for H/HD/HT AELs. Values
identified in Table 4-2 are time-and-concentration derived values. Table 4-2 provides
maximum concentration values not to be exceeded for a given period of time, depending on
the level of protection wom by personnel. The STEL values are short-term exposure limits.
Occurrences above these short-term concentrations require immediate egress and re-entry in
increased level of protection. The WPL values are long-term exposure limits. If a worker is in
an area for 8 hours, the average concentration in the area for the 8-hour period should not exceed
the S-hour WPL exposure Mm it for the le\el of protection worn by the worker. If the exposure
limit is e.\ceei.lei.L implementation of correcti\e actions is rei.|uirei.l.
4.2 .\ELDerinilions
4.2.1 Genenil Population Limit (GPL)
The GPL is an allow able 72-hour. time-\\ eightei.l-a\ erage concentration for the general
population. The limit applies to the entire jiopulation. inclui.ling all ages ani.1 medical contlitions.
The 12-hour GPL for HD is 2 .x Kr mg m".
4.2.2 \\ orker Population Limit (\\ PL)
The WPL is the a\ erage allow able concentration that an unmaskei.1 worker coukl be e.xposei-l to
for an S- to 1 2-hour w orki.la\'. 4() hours per w eek for 3() \ ears. w ithout atk erse etlects. The WPL
for the DCD EDT Site has been ai.ljustei.1 to rellect a 1 o- to 1 2-hour work shift. How e\ er. since
operators will not speni.1 more than S hours untlergoing tlestruction operations, the S-hour WPL
for HD (i.e. 4 .x lo~^ mg m"') will be asei.!..
4.2.3 Short-Term Exposure Limit (STEL)
The STEL is the ma.ximum concentration to w hich unprotectei.1 chemical agent w orkers ma\'
be e.xposei-l to for up to 1 5 minutes, continuous!}'. The STEL for mustan.1 agent is 3 .x lo""'
mg m"\ Only one e.xposure i.lail\' is allowei.1 at the STEL for mustan.1.
4.2.4 \':ipor Screening Limit (\'SL)
The \'SL is a \ apor concentration term that is ini.lepeni.lent of time. It ma\' be usei.1 to (.lefine the
le\ el to w hich an item is monitorei.1 to tletermine the agent contamination le\ el. The \'SL for
mustan.1 agent is 3 .x 1 o""" mg m"\
4.2.5 Immediately Dnngerousto Life :uid Henlth (EDLH)
The EDLH is the ma.ximum concentration, in the e\ent of respirator failure, w here a person coukl
escape w ithin 3o minutes w ithout a respirator ani.1 w ithout e.xperiencing an\' escape-impairing
(e.g.. se\ ere e\ e irritation) or irre\ ersible health effects. The IDLH le\ el is o.7 mg m" for
mustan.1 aeent.
Table 4-1. H/HD/HT AELs"
Sulfiir Mustard (H, HD, HT) ^
Criteria GPL WPL STEL'^ IDLH*^
Exposure Level (mg/m3) 0.00002 0.0004 0.003 0.7
Averaging Time 12 hours 8 hours <15 minutes <30 minutes
Recoimnended Monitoring Method Historical^ Historical^ or Ne^-real-Near-real-time Near real-time
Although the Centers for Disease Conti'ol and Prevention (CDC) do not specifically recommend additional reduction factors for statistical assurance of
action at the exposure limit, exposm^es to sulfur mustard should be minimized given the uncertainties in risk assessment, particularly as related to
characterizing carcinogenic potency.
The toxicity data for agent T is inadequate for setting exposure limits. The very low vapor pressure for agent T precludes its classification as a vapor
hazai'd under normal ambieiit conditions. For suMir mustard and T mixtures, air monitoring for sulfui' mustard alone should be sufficient, under most
circumstances, to prevent exposure to T.
To be evaluated with a near-real-time instrument using shortest practicable analytic cycle time. No more than one exposure per work-shift.
The mustard IDLH is based only on non-carcinogenic effects. No IDLH has been established for carcinogens.
Historical monitoring typically is used for tmie-weighted-average (TWA) monitoring where the sample analyzed represents an extended time period, for
example, 8 or 12 hom^s. Results ai^e not known until laboratory analysis is completed after the sampling event. The AELs using historical monitoring are set at
levels at which health effects are not expected to occur for most workers. Exposures above the WPL-8, but below the STEL, likewise, are not expected to
result in significant health effects unless such exposures occur continuously for lor^ time periods.
Table 4-2. H/HD/HT AELs
Averaging l Time (mg/m^^
GPL WPL WPL WPL WPL STEL''
H/HD/HT (12 hours) (12 hours) (8 hours) (4 hours) (2 hours) (15 minutes) Variable
General 2 X 10"^
Population
No Respiratory
Protection 2.7 X 10"^ 4 X 10"^ 1.6 X 10"^ 3 X 10"^
Air-Purifying
Respirator For sulfur mustards, air-puriiy ing respirators are for escape purposes only.
Supplied-Air
Respirator w/o 0.27 0.4 0.8 1.6 3.0
Escape Bottle
Self-Contained
Breathing
Apparatus or 2.0 X 10'^ 4.0 8.0 16.0 30.0
Supplied-Air
Respirator with
Escape Bottle
Demilitarization
Protective
Ensemble lOO.O"
Deleted:
Deleted:
Vapor Screening
Limit (VSL)
Source Emissbn
Limit (SEL)
3x 10'
3 X 10"
iln\ iiicli .\jiiie\ B iiioiiiloriii2 |)laji Himl ve\ I .iloc
E.\|)Or:iirer: ill I lie STEL r:|iiill occiir iiol more IIKUI one I line |)er ihn . The ("eiilerr: lor Dir:eiir:e ("oiilrol ami Pre\ eiilioii (("D(") |)iil>Ur:li ii|)iliileil
iimiil>err:.
liii|)leiiieiileil ii.-: a ceiliiie \aliie.
Nole;::
.\irl>onie e.\|)Or:iire liiiiil?: (.AEL;;) iire lakeii Iroiii .Anii\ Reeiilalioii .iS'^-Ol ( 1 2 ()clol>er 01 ) ami O'-) FR 2'-) 1 (1-1-2'-) 1 oS (0.^ Ma\ 0-1).
.All .AEL;: are coiiceiilralioii ami lime \ ill lie?:, iiol coiiceiilralioii oiJ\ \ aliie?:. .Ailiiiiiur:lrali \ e coiilrolr: iiia\ l>e iir:eil lo liinil |)oleiilial e.\|)Or:iire lo vv orker?:.
Hovve\ er. l>ecaiir:e ailiiiiiur:lrali \ e coiilrolr: camiol l>e iir:eil lo limil Uie iliiralioii or|)oleiilial |)iil>lic e.\|)Or:iire. oiiK I he vv orker |)0|)iilalioii limil (\^'PL) |)rolecli \ e
acdoii le\ el ir: r:ieiiillcaiill\ alVecleil In ailiiiiiur:lrali \ e coiilrol;:. vv lucli lunil die il lira don or|)oleiilial e.\|)Or:iire.
The II lii-M Ilium iir:e coiicei Ural ion ir: die |)roihii.i ofllie .A EL ami I he ar:r:ieiieil |)rolecdoii liiclor lor die rer:|)iralor. The iir:r:ieiieil |)rolei.iioii liiclorr: iir:eil in ilur: lal>le
are liikeii Iroiii oS FR .'^-lO.Vi-.'^-l I h). o Jime 200.V
The mi.xmre HT r:liiill l>e iiioiuloreil a?: H D.
The r:oiirce eiiiir:r:ioii lunil war: |)re\ iour:l\ kjiovv II a?: llie allovval>le r:lack coiiceiilralioii (.AS(").
5.0 MONITORING AND SAMPLING EQUIPMENT
The chemicals of concem at the DCD EDT site will be monitored using the following equipment:
• MINICAMS™; and
• DAAMS tube sample collection followed by analysis with GC/MS or
GC/FPD.
The MINICAMS'^'^ is considered a Near-Real-Time (NRT) agent monitor. The DAAMS is used
as a historical method and for confirmation of NRT alarms and historical concentrations greater
than the reportable limit(s). The following paragraphs describe the monitoring equipment in more
detail.
5.1 MENICAMSTM Equipment Description
The MINICAMS™ is an automated gas chromatograph (GC) that operates by altemating between
sampling and analysis cycles. During the sampling cycle, a vacuum system pulls an air sample
into the MINICAMS™ via a heat-traced sample line (HTSL).
5.1.1 MINICAMS™ Configuration/Operation
The air sample enters the MINICAMS™ and concentrates on a solid sorbent tube (i.e., a pre-
concentrator tube). The sorbent tube is maintained at a temperature that will prevent condensation
from forming on the tube. During sample analysis, the solid sorbent tube is heated to thermally
desorb the analytes, while nitrogen flows into the sorbent tube to sweep the analytes into the
capillary column for analytical separation. Analytes undergo chromatographic separation
and are carried to the detector for sample analysis.
5.2 DAAMS Sampling Equipment Description
The DAAMS tubes are used to confirm agent MINICAMS™ alarms and to provide historical
monitoring at WPL. The DAAMS stations are comprised of solid sorbent DAAMS tubes,
sample manifolds, sequencers, pumps, and flow control devices. Air monitoring with DAAMS
employs air aspiration through the DAAMS tube for a predetermined period of time at a
controlled airflow rate. Contaminants in the air are adsorbed on the solid sorbent. Aspirated
DAAMS samples are then analyzed in the laboratory to detect chemical material at the
prescribed monitoring levels. Laboratory analysis uses thermal desorption ofthe analytes from
the sorbent tubes into a GC/MS or GC/FPD.
5.3 Near-Real-Time Monitors
The Near-Real-Time (NRT) Monitors are configured to monitor the chemical agents being
processed at the Site. These NRT monitors are used to monitor the operational areas,
filters, and stacks. They may monitor at th^ WPL, VSL, and IDLH co , ^ - -{ Deleted; STEL
mustard chemical agents.
10
5.4 Depot Area Air Monitoring System
Depot .Area .-\ir Monitoring S\ stem (•D.-\.-\MS) collects air samples to tletect chemical agents,
for conllrmation of NRT monitor alarms, .-\nal\ sis of D.-\.-\MS samples pro\ ii.les
conllrmation of agent if concentrations are at or abo\ e the i.lelmei.1 Reporting Limit ( RL).
Instrumentation usei.1 liir agent conllrmation are the Gas Chmmatograph}' Flame Photometric
Detector ( GC FPD) ( D.AAMS) orGC-Mass Selecti\ e Detector (GC-MSD).
5.5 Dilution Air Flow Controllers (DAFC)
Both the NRT monitor ani.1 D.-\.AAIS use tlilution airllow contmllers. The puqiose ofthe tlilution
llow controllers is to inject i.lr\- air into the sample stream to pre\ ent the lii.|uii.l in the sample Irom
coni-lensing in the sampling ei.|uipment. keeping the sample abo\ e the i.lew point. The tlilution
llow contmllers are i.lesignei.1 such that the llow contml i.le\ ice has a feetlback signal to a How
meter. This feetlback signal causes the ratio ofthe sample llow to sta\' constant once the t\\ o are
lockei.1 together. Therefore, the unit compensates for an\' interruptions in the sample llow ani.1
maintains the correct ratio. The agent concentration in the D.A-\MS tubes is calculatei.1 using the
\olume of sample air. not the tlilution air. The same theor\- of operation hokIs true w ith the NRT
monitors. The NRT monitors are calibratei.1 regartlless ofthe i.|uantit\' of i.lilution air. The
i-lilution air can be consii.lerei.1 a carrier for the sample. The agent concentration is basei.1 on the
\olume ofthe sample.
5.6 Backup Equipment
The function ofthe NRT monitor is to rapitlk tletect agent. Shouki a neei.lei.1 instrument fail, the
l1rst response is to tmubleshoot ani.1 repair it in place. Shouki the estimatei.1 repair time be in
e.xcess of 1' j hours the NRT monitor shall be replacei.1 w ith an NRT monitor Irom the
contingency'.
5. 7 Monitoring and Analytical Equipment Operations and M:iintenance (0«&M)
Requirements
This section summarizes the sampling ani.1 analytical ei.|uipment rei.|uirei.l for N erilying control of
agent m igration in air ani.1 in process eflluents for DCD EDT site acti\' ities. .All hartlware
associatei.1 with air monitoring ani.1 laboratory ei.|uipment will be maintainei.1 in accon.lance with
the manufacturers" operations ani.1 maintenance (•(!)^&M) manual recommeni-lations ani.1 ECBC
associatei.1 \OPs.
Table .^-1 pro\ ii.les general tlescriptions. operational rei.|uirements. ani.1 pre\ enti\e maintenance
rei.|uirements. Table .^-2 pro\' itles ei.|uipment rei.|uirements for support gases.
11
Monitoring
NRT Monitors:
MINICAMS
> XSD
Operational Components
Operational Components
• Preconcentrator
Tubes/Sample Tubes
• Sample Loops
• Capillarv Columns
• Mass Flow Controller
Support Gases:
• Purifiers (optional)
• Leak Detectors
• Compressed Gas
Regulators
Manufaqturer
Specifications
Electrical Requirements;
• Critical NRT
monitors equipped with
UPS
• Power is provided
m accordance with
manufacturer
specifications.
Temperature:
• Use operational
performance characteristics
to determine if the NRT is
operating within control.
• Doors to
environmentally controlled
NRT monitor shelter must
remain closed at all time,
except during personnel
entrv/egress.
• Condensation shall
be minimized and if
obser\'ed, corrective actions
will be taken immediatelv.
Minimum Operational
Requirements
Routine
Calibration
• Daily Challenges
• Calibration of
mass flow meter
• The sample
exhaust must be filtered,
retumed to the sampling
point, or vented to
appropriated engineering
controls.
Preventive
• PCT is replaced
as needed, based upon
challenge performance.
Deleted: Table 5-1: Description and
Requirements for Monitoring and
Sampling Equipment^
Monitoring Equipment ... [1]
"I Formatted; Bullets and Numbering
'I Formatted; Bullets and Numbering
'I Formatted; Bullets and Numbering
~( Formatted; Bullets and Numbering
"I Formatted; Bullets and Numbering
TABLE 5-1: Description and Requirements for Monitormg and Sampling Equipment
12
Deleted: ^End of Section"==«=
Table 5-1: Description and
Requirements for Monitoring and
Sampling Equipment (Continued)f
Monitoring Equipment | p21
\ I Formatted Table
r Formatted: Left
13
TABLE 5-1: Description and Requirements for Monitoring and Sampling Equipment (continued)
T. DAAMS Manufacturer Minimum Operational
Monitoring Operational Components Specifications Requirements Preventive
Depot Area Air DAAMS Tubes: Power Requirements: • The sample • Daily checking
Monitoring • Size mav varv • Power is provided exhaust must be filtered. of flow rates, critical
System depending on agent in accordance with retumed to the sampling orifices, fittings, and
(DAAMS) operations. manufacturer point, or vented to fermles.
specifications. appropriate engineering • Vacuum pump.
Sequencers: • Critical DAAMS controls. sequencer, and sample
• Director and control equipped with UPS. transfer line preventive
flow pattern Vacuum Pumps: maintenance will be
Temperature: • Used in perfonned in accordance
DAAMS Manifold: • Temperamre is coniunction with a flow with manufacturer
• Provides stable maintained to minimize control device or critical specifications.
support svstem. condensate formation. orifice. • Require air.
• Designed to provide • Should maintain nitrogen, or other inert
a directional sample flow Manifold: critical ratio of inlet to gas flow through tube
patter and distribute the • Fabricated from outlet vacuum across the and thermal desorption
sample flow. stainless steel orifice. of tube for conditioning.
NOx Filter: Hoses:
• Change-out • Used to connect
frequency is based on a site-sequencer sample ports
specific basis. to the DAAMS manifold
• Silastic tubing
must not be used
upstream of the
DAAMS tube.
• Units that
demonstrate detectable
leaks, poor flow rates, or
broken sections are
repaired or replaced.
••-^ 'l^i'J Deleted: t
\\\
Deleted: End of Section
Table 5-1: Description and
Requirements for Monitoring and
Sampling Equipment (Continued)f
Monitoring Equipment |'3j
'I Formatted Table
^ iM Formatted Table
, V \
\ s '[ Formatted; Bullets and Numbering
\ \ \ ^ [ Formatted: Bullets and Numbering
y \ [ Formatted; Bullets and Numbering
\ \ j Formatted: Bullets and Numbering"
\ I Formatted; Bullets and Numbering"
I Formatted: Bullets and Numbering
'I Formatted; Bullets and Numbering
[ Formatted; Bullets and Numbering
~[ Formatted; Bullets and Numbering
I Formatted: Bullets and Numbering
14
Formatted: Left
TABLE5-1: Description and Requirements for Monitoring and Sampling Equipment (continued)
Monitoring
GC Analytical
Systems:
• FPD
• MSD
XSD
Operational Components
Operational:
• Sample inlet
• Capillary column
• Colunm switching
system
Support gases
Integration system
Thermal transfer
system
Exhaust
Cryofocusing
Roughing pump
Manufacturer
Specifications
Power Requirements:
• Power is provided
in accordance with
manufacturer
specifications.
• Confirmation
monitoring is equipped
with UPS^
• Power board is 120
volts altemating current.
Room Temperature:
• Between 68° and
80°F during operational
periods. May be exceeded
if instrument performance
is acceptable.
In accordance with
manufacmrer specifications
Minimum Operational
Requirements
• Exhaust is
vented to appropriate
engineering controls if
required by safety
analysis.
• Temperature
flow rate, and desorption
time shall be optimized
on a site-specific bases.
In accordance with
manufacmrer
specifications
Preventive
• Performed on an
''as-needed basis" in
accordance with the
O&M Manuals.
• Roughing pump
oil is exchanged to
maintain vacuum
efficiency.
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted; Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Deleted: NOx Filters
^ Formatted: Bullets and Numbering
" The unintermptible power supply (UPS) must have brown-out protection and constant voltage output and must operate the instruments for at
least 15 minutes during a power failure.
^ Mass selective detector (MSD) only Deleted: Table 5-1: Description and
Requirements for Monitoring and
Sampling Equipment (Continued)^
Monitoring Equipment ['5"[
Formatted Table
15
TABLE 5-2: Support Gases Equipment Requirements
Support Gases Purifiers Leak Detectors
Compressed Gas
Regulators Compressed Gas Line
May Include: Moisture and May Include: • Will be tAvo-• Will be pre-
• Air Hydrocarbon Traps j • Simple soap solution stage regulators or cleaned tubing. ••
• Nitrogen • Frequency of • Electronic leak equivalent • All fittings will ••
• Helium change-outs are identified detector be Swagelok fittings
in the Site-Specific Oualitv or equivalent.
Cryofocusing requires Control Plan Utilization:
liquid nitrogen or • UseJ^ased on • Completed in
carbon dioxide. instmmentation
performance.
accordance with
manufacturer specifications
Support gases are and requirements.
handled and stored m
accordance with the
Site Chemical
Hvaiene Plan, which
mcoriDorates:
• The CGA
Pamphlet P-1; AR
700-68
• CGA Pamphlet
S-1.1-1963 and 1965
addendum and S-1.2-
1963
• 29 CFR
1910.101
Formatted: Bullets and Numbering
Deleted: (if recommended bv
manufacturer or vendorl
[Formatted: Bullets and Numbering ^
I Formatted; Bullets and Numbering ~^
-{ Deleted: B )
'I Formatted; Bullets and Numbering ~^
Formatted; Bullets and Numbering
*Gas generators will be operated in accordance with manufacmrer specifications.
16
6.0 MONITORING OPERATIONS/STRATEGIES
Placement of each monitoring location is based on potential chemical migration points, and
designated monitoring points shall be verified via the use of a smoke test. When monitoring
supports personnel protection, monitoring locations should be located in close proximity to
personnel and preferably at the breathing zone height. Heat-traced sample lines (HTSLs) will be
no more than the length that allows agent recovery in one sampling cycle. All critical NRT
monitoring equipment will be connected to an unintermptible power supply (UPS).
During DCD EDT operations, monitoring will be conducted based on the agent being
destroyed (i.e, HD). The NRT monitoring for HD^ will be conducted with MINICAMS™ units
equipped with^alqgen selectiye detectors (XSDs}. A.dditiqnally, confiimation DAAMS tiibes
will be co-located at each NRT monitoring location.^ Historical DAAMS samples will be
collected in locations with the most likely potential for exposure for individuals with no
respiratory protection.
Table 6-1 specifies the monitoring application and type of monitor to support each application. The
monitoring types discussed in the following paragraphs will be employed during DCD EDT
operations.
6.1 NRT/Confirmation
The NRT/confirmation locations shall consist of an instmment that satisfies the monitoring
requirement identified for NRT monitors and incorporate a confirmation monitoring method. At
a minimum, confirmation monitoring shall consist of a qualitative method as defined in the
CMA MCP and LMQAP. The confirmation method shall be capable of confirming a single
cycle NRT alarm response. When NRT monitoring is coupled with a confirmation method, and
chemical materiel is confirmed, the NRT measured concentration shall be the value of record.
Formatted: Left: 70.55 pt, Top:
76.3 pt, Bottom: 30.95 pt, Header
distance from edge: 36.7 pt. Footer
distance from edge: 35.3 pt
Deleted; f
Table 5-2: Support Gases Equipment
Requirements f
Support Gases ["s]
Deleted: flame photometric detectors
(FPDs) or
6.2 Historical/Confirmation
Historical monitoring will be performed by DAAMS sampling and subsequent analysis by gas
chromatograph/mass spectrometer (GC/MS)^ A separate confimation me
when GC/MS is employed. When class III methods are used for NRT confirmation samples, any
positi\"e response will be considered a confirmed detection.
Deleted: or gas chromatogiaph flame
photometric detector (GC/FPD)
17
HT will be monitored as HD.
^ When collecting DAAMS tubes for HD detection, a nitrogen oxide (NOx) filter will be installed at the distal
end of each sampling location.
Table 6-1. Monitoring Application and Monitor Type
Analyte Monitor/Equipment Notes
NRT Monitoring
HD/HT MIMCAM^®con%uredwi1h_a_rc^
Confirmation of NRT Alarm and Historical Monitoring
HD DAAMS; GC/MS_Qualitative confirmation ofthe MINICAMS®^larm and
quantitative historical DAAMS
Historical Monitoring
HD DAAMS; GC/MS.Quantitative analysis
Deleted:
Deleted: MINICAMS™
Deleted: or FPD
\ Deleted:
Deleted: or GC/FPD
^ Deleted: or GC/FPD
HT will be monitored as HD.
Notes:
DAAMS = Depot Area Air Monitoring Systen^
GC/MS = Gas Chromatograph/Mass Spectrometer
HD = DistiUed Sulfiir Mustard (Bis(2-Chloroethyl) Sulfide)
HT = ({Bis[2-(2-Chloroethylthio)ethyl]Ether})
NRT = Near- Real-Time
PCT = Preconcentrator Tube
XSD = Halogen Selective Detector
Deleted: ^
FPD = Flame Photometric Detector
Formatted: Tabs: 54 pt, Right +
Not at -76.5 pt + 49.5 pt + 197 pt
7.0 MONITORING SYSTEMS
The following paragraphs describe the monitoring systems that wiU be employed during DCD
EDT operations. Monitoring locations during chemical agent operations are illustrated in
Figure 7-1.
A summary of the monitoring systems is provided in Table 7-1. Detailed discussions of the
monitoring systems and locations are provided in the following paragraphs.
18
SCft 1"* l*M7| [6M*i [121*11
1 Cx-imj \ s
s=
o
s
s
B
o
o
h-1 en
s 'C Q •«->
d
o
CXI
TableJ-l: Summary of Monitoring Strategy for DAVINCHT^^^ EDT Qperations Deleted:
Station
# MINICAMS^
AMI
AM2
AM3
AM4
No. 1
No. 2
No. 3
No. 4
DAAMS
N/A
NO. 1
NO. 2
N/A
Instrument
Location
Monitoring
Trailer
Monitoring
Trailer
Monitoring
Trailer
Monitoring
Trailer
Area Monitored
Delivery Van
UPA Area
Preparation
Area
Changing
Room
Power
Source
UPS
UPS
UPS
UPS
Monitoring
Level
VSL
VSL
VSL
VSL
Alarm
Level
0.5
0.5
0.5
0.5
DAAMS Mode
N/A
MINICAMS
TM
Confirmation
MINICAMS
TM
Confirmation
N/A
RCRA
Station.s
No
No
No
No
Smoke
Test
Requir'd
No
Yes
Yes
No
Formatted Table
Comment
Not&„-H Deleted: l
Deleted: Note 3
Note Deleted; 2
AM5 No. 5 N/A
Monitoring
Trailer
Air Shower
Room UPS VSL 0.5 N/A No No Note Deleted; 2
AM6
AM7
No. 6
No. 1
NO. 3
Monitoring
Trailer
Detonation
Chamber Area
(DOOR) UPS VSL 0.5
MINICAMS
TM
Confirmation No No Note 4
N/A
Monitoring
Trailer Jleadspace UPS VSL
0.2
0.5
1.0 N/A Yes No Note. 2 ,^ Deleted; Post Treatment )
AMl^ No. 1 N/A
Monitoring
Trailer
Note 2,3
Airlock 2 UPS VSL 0.5 N/A No No Deleted; 7-S
Deleted: Note 10
20
Station
# MINICAMST>«
AMll No. 1
AM13 No. 1
AM8 No.7
AM9 No. 8
DAAMS
N/A
N/A
No. 4
NO. 5
Instrument
Location
Monitoring
Trailer
Monitoring
Trailer
Monitoring
Trailer
Monitoring
Trailer
Area Monitored
UnitG
Davinch Lid
Shroud
Airlock 1
j^qntainment
Room
Power
Source
UPS
UPS
UPS
UPS
Monitoring
Level
VSL
VSL
VSL
VSL/WPL
Alarm
Level
0.5
0.5
0.5
0.5
DAAMS Mode
confirmation
ronfirmation
MINICAMS
TM
Confirmation
MINICAMS
TM
Confirmation
RCRA
Stations
No
No
No
No
Smoke
Test
Requir'd
No
No
Yes
Yes
Formatted Table
Comment
Note 1.2
Note 2
Deleted; Mobile Analytical Platform
Deleted; Note 8 ]
AM12 N/A NO. 20 N/A
Mobile
Laboratory N/A WPL 0.5 Historical No No
PMI No. 9/No. 17 NO. 6
Monitoring
Trailer
Upstream of
Retention Tank UPS VSL 0.5
MINICAMS
TM
Confirmation Yes No
Note
5,13
PM2 No. 10 NO. 7
Monitoring
Trailer
Chamber
Discharge
during venting UPS VSL 0.5
MINICAMS
TM
Confirmation No No Note 6
PM3 No. 11 NO. 8
Monitoring
Trailer
Process
Discharge UPS VSL 0.5
MINICAMS
TM
Confirmation Yes No
PM4 No. 12 NO. 9
Monitoring
Trailer
Mid bed of
HVAC Filter
El UPS VSL 0.5
MINICAMS
TM
Confirmation Yes No Note 9
21
Smoke
Station Instrument Power Monitoring Alarm RCRA Test
# MINICAMST^i DAAMS Location Area Monitored Source Level Level DAAMS Mode Stations Requir'd Comment
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM5 No. 12 NO. 10 Trailer El UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM6 No. 12 NO. 11 Trailer El UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM7 No. 13 NO. 12 Trailer E2 UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM8 No. 13 NO. 13 Trailer E2 UPS VSL 0.5 Confirmation Yes No Note9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM9 No. 13 NO. 14 Trailer E2 UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PMIO No. 14 NO. 15 Trailer E3 UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PMI I No. 14 NO. 16 Trailer E3 UPS VSL 0.5 Confirmation Yes No Note 9
Mid bed of MINICAMS
Monitoring HVAC Filter TM
PM12 No. 14 NO. 17 Trailer E3 UPS VSL 0.5 Confirmation Yes No Note 9
MINICAMS
Monitoring HVAC TM
PM13 No. 15 NO. 18 Trailer Discharge UPS VSL 0.5 Confirmation Yes No Note 7
Formatted Table
22
Station
#
PMi4
PMI 5
PM16
PM17
MINICAMST>«
No. 16
N/A
N/A
N/A
DAAMS
NO. 19
NO. 21
NO. 22
NO. 23
Instrument
Location
Monitoring
Trailer
N/A
N/A
N/A
Area Monitored
Stack
PrefilterEl
Prefilter E2
Prefilter E3
Power
Source
UPS
N/A
N/A
N/A
Monitoring
Level
VSL/WPL
VSL
VSL
VSL
Alarm
Level
0.5
N/A
N/A
N/A
DAAMS Mode
MINICAMS
TM
Confirmation
process
process
process
RCRA
Stations
Yes
No
No
No
Smoke
Test
Requir'd
No
No
No
No
Formatted Table
Comment
Note 8
,£ntigal| Formatted; Font: 10 pt
DAAMS
Note 11
Note 11
Note 11
jNlotes: _ _
L With DAAMS capability,^
2. iSpooled loj:ation_ _
3. Headspace monitoring (4 hours @70°Fy Clearance levels are 0.2 VSL for exterior of diimis. 0.5 VSL for chamber solid waste inside dnmis. and 1.0 VSL for other
(PPE) dmimned waste.
4. No smoke test required; will position according to proximity to chamber opening/door. For daily entry clearance/maintenance this station may be used with DAAMS
for WPL monitoiing.
5. Controls the release of detonation gas to synq^witliMC cyclg. Iii the event of aim g^tiyates^
6. Peisoimel entiy chamber cleaiance spooled based on chamber status.
7. Upstream of process discharge.
8. WPL DAAMS station must be collected and analyzed on a daily basis for this station.
9. One MINICAMS™ spools between bed locations on each filter unit. Separate DAAMS on each location. Also has ability to spool to post-filter location if necessaiT
to deteiiniiie if breaktluough has occmTed in final stage of filter.
10. j'ersonnel poiiit sourc^ I._ These process sa^npl^g jL^Jo j^teiimiie if ag^nt is^bdng loa^^ onto caibon filters^ .Qfigg. ^gg^tjg. j^?Pl^j^il9_ft^dll^" jopBi^Q-^fflj_
requiied.
12. Stations not supporting operations mav be taken offline and carbon traps placed on the inlet.
^71
Formatted: Font: 10 pt
Deleted:
Deleted: Also Spools to AM7 and AM
7-S
Deleted: Personnel point source.
Deleted; h
' Deleted; Spools from Post Treatment to
Airlock 2.
Deleted; t
13. If the process stream contains too much moiNtme. a DAFC mav be used. The detection limit for this location will be increased based on dilution ratios.
14. NRT confiimation based on comparison of results obtained from differently configured NRTs aboard Real Time Analytical Platform (RTAP) provided by DCD.
RTAP monitor sample the same sample since sample is contained in box tnick's storage compaitmeiit.
23
Formatted: Left: 70.55 pt, Top:
76.3 pt, Bottom: 30.95 pt, Section
start: New page
7.1 NRT Monitoring
The NRT monitoring is online monitoring, conducted in areas where contamination is likely or
possible, to determine an airbome chemical concentration in the shortest amount of time at the
monitoring level commensurate with engineering controls and worker protection. This
monitoring will take place at the locations discussed in the following paragraphs. Table 6-1
details the MINICAMS™ configurations for monitoring chemical agents. All NRT stations will be
configured with un-interruptible power supplies.
7.1.1 Worlcspace Process Area (Delivery Van)
The NRT monitoring ofthe Delivery Van will be performed using an HTSL interfaced with a
MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location will
be performed at the VSL.
7.1.2 Workspace Process Area (Unpack Area (UPA))
The NRT monitoring ofthe Unpack Area will be performed using an HTSL interfaced with a
MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location will
be performed at the VSL
7.1.3 Workspace Process Area (Preparation Area)
The NRT monitoring of the Preparation Area will be performed using an HTSL interfaced with a
MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location will
be performed at the VSL
7.1.4 Workspace Process Area (Aii'lock 1)
The NRT monitoring of Airlock 1 will be performed using an HTSL interfaced with a
MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location will
be performed at the VSL.
7.1.5 Facility Support Area (Changing Room)
The NRT monitoring ofthe Changing Room will be performed using an HTSL interfaced with a
MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location will
be performed at the VSL.
7.1.6 Facility Support Area (Air Shower Room)
The NRT monitoring ofthe Air Shower Room will be performed using an HTSL interfaced with
a MINICAMS™ located in the Monitoring Container/Station. The monitoring at this location
will be performed at the VSL.
25
7.1.7 Process Area (Detonation Chamber Door)
Deleted: Coutainment Area
The NRT monitoring ofthe Detonation Chamber/Containment Area will be performed using an
HTSL interfaced with a MINICAMS™ located in the Monitoring Container/Station. The HTSL
will be coiled and hung over the Detonation Chamber Containment Vessel such that it is less
than 2 feet above and slightly in front of the Detonation Chamber door. The monitoring at this
location will be performed at the VSL. A DAAMS may be used at this location optionally to
provide clearance for maintenance or entry using a WPL clearance level.
7.1.8 Workspace Process Area (Post Treatment Area)
The NRT Headspace Monitoring ofthe firagments in the Post Treatment Area will be performed
using an HTSL interfaced with a MINICAMS™ located in the Monitoring Container/Station.
The Headspace Monitoring at this location will be performed at the VSL.
7.1.9 Workspace Process Area (Airlock 2)
The NRT monitoring of Airlock 2 will be performed using an HTSL interfaced with a
MINICAMS'^'^ (spooled) located in the Monitoring Container/Station. The monitoring at this
location will be performed at the VSL.
7.1.10 Laboratory Work Area/Mobile Analytical Platform
^Laboratory areas ^vhere the RDT&E diliite levels are not exceeded do not require NRT
monitoring.
7.1.11 Ventilation Exhaust Filter System
The ventilation exhaust filter system includes the facility's ventilation system exhaust where
CWM is processed for demilitarization. It does not include the laboratory ventilation system or
other buildings in the facility where CWM is not processed.
7.1.11.1 Upstream of Retention Tank
The NRT monitoring will be performed upstream from the Retention Tank. Monitoring will
be performed using an HTSL interfaced with a MINICAMS™. The monitoring will be
performed at this location at the VSL.
7.1.11.2 Chamber Discharge during Venting
The NRT monitoring ofthe Chamber Discharge during venting will be performed using an
HTSL interfaced with a MINICAMS™. The monitoring will be performed at this location at the
VSL during operations. This location will also be used to perform fust entry monitoring into the
26
Deleted: Laboratory work areas are
where chemical agent standards are
prepared or used and/or where samples
are analyzed that may contain chemical
agent. Chemical agent contamination is
not expected, but because ofthe nature of
the operations being performed in these
areas, tliere is a potential for
contamination.^
7.1.10.1 Operations with Chemical
Agent Above RDT&E Dilute Level. ^
The process areas include laboratory
areas where operations with chemical
agent above RDT&E dilute level are
conducted or where samples expected to
contain chemical agent above RDT&E
dilute level are analyzed. Tliese
laboratory work areas require NRT
monitoring at the STEL and liistorical
monitoring at the WPL during chemical
agent operations. The monitoring level
will be selected in accordance with PPE
level and administrative controls, but as a
standard requir ement, the STEL and the
WPL (consistent with the site-defmed
work shift) for unmasked woiicers shall
be utilized. Confinnation monitoring is
required for botli the NRT and liistorical
monitoring.il
7.1.10.2 Dilute RDT&E Operations.^
Davinch chamber.
7.1.11.3 Process Disc ha rge
The NRT monitoring of the Process Discharge will be performed using an HTSL interfaced
with a MINICAMS™. The monitoring will be performed at this location at the VSL.
7.1.11.4 Midbed ofHVA C Filter
The NRT monitoring will be performed at the midbed location ofthe air filtration unit using
an HTSL interfaced with a MINICAMS™. The monitoring will be performed at this location at
the VSL.
7.1.11.5 HVAC Discharge
The NRT monitoring will be performed at the HVAC Discharge ofthe air filtration unit using
an HTSL interfaced with a MINICAMS™. The monitoring will be performed at this location at
the VSL.
7.1.11.6 Stack
The NRT monitoring will be performed at the Stack location ofthe air filtration unit using an
HTSL interfaced with a MINICAMS™. The monitoring will be performed at this location at the ^ -(Deleted; andwPL
VSI^ ~
7.1.12 First Entiy
First entry monitoring will be conducted, prior to persormel entry, to determine the potential
contamination of an enclosed area that was previously contaminated or has not been under
continuous monitoring. First entries require NRT monitoring at the VSL for one complete
sampling cycle ofthe NRT. Prior to monitoring for one complete sampling cycle, the sample
line should be purged to ensure that a clean representative sample is taken. The monitoring level
will be selected in accordance with the PPE level of personnel making the entry. Confirmation
monitoring is not immediately required but can be performed after the NRT response
indicates possible chemical agent contamination.
7.1.13 Headspace
Headspace monitoring may be used to screen samples to determine such information as
operational constraints, PPE requirements, and handling precautions.
Headspace monitoring shall be performed jn accordance with table 7-1 on solid samples that _ ^ - - \ Deleted; at o.s of the VSL
have been bagged or contained in an agent-tight barrier of sufficient volume to permit sample air
to be withdrawn while minimizing dilution with incoming air. Headspace monitoring requires
one complete sampling cycle ofthe NRT. Prior to monitoring for one complete sampling cycle,
the sample line should be purged to ensure that a clean representative sample is taken.
Historical monitoring can be performed instead of NRT monitoring. Liquid samples may not be
headspace analvzed to support the disposition ofthe liquid. Liquid waste samples must be
27
cleared by extraction and meet project waste control limits. ^_
JHeadspace monitoring for the piirpose of decontamina^^^ shall include the followin^;^^
- the item has been surface decontaminated by locally approved procedures
- the item has been bagged or contained in an agent-tight barrier of sufficient volume to -"^^
permit sample air to be withdrawn while minimizing dilution with in-coming air
- the Item shall be allowed to off-gas for a minimum of 4 hours at temperatures at or
above 70 degrees Farenheit
7.1.14^aste Prums /
J^RT monitoring 9^ waste dmmj, bej)erform^^ a _
MINICAMS™ (spooled) located in the Monitoring Container/Station. ^TTie monitoring at this
location will be performed at the VSL. Waste drums will be cleared to 0.2 VSL at the exterior of "^v
the drum by headspace monitoring, before removal from the EE.
7.1.15 Decontamination Area/Air Shower
In the event of a potentially exposed worker, MINICAMS™ will be available to conduct NRT
monitoring in the Air Shower Room. The monitoring at this location will be at the VSL.
7.1.16 UnitG
NRT monitoring will be performed at Unit G using an HTSL interfaced with a MINICAMS^^'
(spooled) located in the Monitoring Container/Station. The monitoring at this location will be
performed at the \"SL..
Deleted: One complete sampling cycle
of the NRT monitor is required.
Historical monitoring can be perfonned
instead of NRT monitoring.
" Deleted; Note that these results may
not be used to support disposition of
material that requires decontamination.
Deleted: the requirements
Deleted: described in paragraph 4.4 of
the CMA MCPO.
Formatted: Indent: Left: 36 pt
Deleted: Above
Deleted: Tlie
Deleted: the
Deleted:
Deleted: Tlie HTSL will be coiled and
hung over the waste dnuns such that it is
less than 2 feet above the dnmis.
7.2 Confirmation and Historical Monitoring
Confirmation monitoring is performed to validate or invalidate a positive measurement from
another monitoring system, either an NRT method or historical method. Sampling is
accomplished by the collection of an air sample in the immediate vicinity of the NRT monitor or
historical sampling location, and subsequent analysis is conducted offline at the site laboratory.
Confirmation monitoring is used for informational and qualitative data reporting purposes in
the event of a chemical material release. The confirmation sample, if required, shall be analyzed
by a method different from the principal method (NRT or historical) to increase the likelihood of
detecting interferences and only upon a principal method (NRT or historical) positive
response. Confirmation monitoring samples shall be given priority over all routine samples.
For class III confirmation samples, a positn e response shall be considered a confirmed
detection.
Confirmation DAAMS tubes are continually aspirated throughout the work day. In the event of
28
an NRT alarm, the DAAMS tubes co-located with the alarming MINICAMS'^'^ are collected and
analyzed.
Note that when using a DAAMS GC/MS historical method, a separate confirmation method is
not required.
7.2.1 Workspace Process Area (Delivery Van)
The DAAMS tubes samples will be used for qualitative confirmation analysis of chemical agents.
The sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-
located MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.2 Workspace Process Area [Unpack Area (UPA)]
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.3 Workspace Process Area (Preparation Area)
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.4 Workspace Process Area (Au'lock 1)
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.5 Process Area (Detonation Chamber/Containment Area)
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.6 Laboratory Work Area/Mobile Analytical Platform
J^aj3oratory areas where the RDT&E dilute levels are not exceeded do not require moni^^
However, the ECBC laboratorv will be monitored using historical DAAMS.
J.2.7 Ventilation Exhaust Filter
The ventilation exhaust filter system includes the facility's ventilation system exhaust where
CWM is processed for demilitarization. It does not include the laboratory ventilation system or
other buildings in the facility where CWM is not processed.
29
Deleted: Laboratoiy work areas are
areas where chemical agent standards are
prepared or used and/or areas where
samples are analyzed that may contain
chemical agent. Chemical agent
contamination is not expected, but
because of tlie nature ofthe operations
being performed in these areas, there is a
potential for contamination.^
7.2.6.1 Operations with Chemical
Agent Above RDT&E Dilute Level. ^
The process areas include laboratory
areas where operations with chemical
agent above RDT&E dilute level are
conducted or where samples expected to
contain chemical agent above RDT&E
dilute level are analyzed. Tliese
laboratoiy work areas require NRT
monitoring at the STEL and liistorical
monitoring at the WPL during chemical
agent operations. The monitoring level
will be selected in accordance with PPE
level and administrative controls, but as a
standard requiiement, the STEL and the
WPL (consistent with the site-defined
work shift) for umnasked workers shall
be utilized. Confirmation monitoring is
required for both the NRT and liistorical
monitoring.1
7.2.6.2 Dilute RDT&E Operations.^
Deleted: 11
7.2.7.1 Upstream of Retention Tank
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.7.2 Chamber Discharge During Venting
During chamber venting, the door to the Detonation Chamber is open and EE air is drawing
throug the chamber. The DAAMS tubes will be used for qualitative confirmation analysis of
chemical agents. The sample inlet will be co-located with the MINICAMS™ HTSL distal end.
When the co-located MINICAMS™ alarms, the DAAMS mbe will be retrieved to confirm or
refute the alarm.
7.2.7.3 Process Discharge
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.7.4 Midbed of HVAC Filter
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.7.5 HVAC Discharge
The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents. The
sample inlet will be co-located with the MINICAMS™ HTSL distal end. When the co-located
MINICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm.
7.2.7.6 Stack
^The stack shall be monitored for NRT alaim confirmation and for historical dtU DAAMS \ Deleted; uie
tubes will be used for qualitative confirmation of NRT alarms and jbr historical monitoring to | Deleted: daily
the WPIy The DAAMS NRT confinnation sample inlet will be co-located with the _ , , -{Deleted; analysis of chemical agents
MINICAMS™ HTSL distafend.' When the co-located MINICAMS™ alarms, the confirmation "
DAAMS tube will be retrieved to confirm or refute the alarm.
7.3 First Entry
First entry monitoring will be conducted, prior to personnel entry, to determine the potential
contamination of an enclosed area that was previously contaminated or has not been under
continuous monitoring. First entries require NRT monitoring at the VSL for one complete
sampling cycle ofthe NRT. Prior to monitoring for one complete sampling cycle, the sample
line should be purged to ensure a clean representative sample is taken. The monitoring level
will be selected in accordance with PPE level of personnel making the entry. Confirmation
30
monitoring is not immediately required but can be performed after the NRT response
indicates possible chemical agent contamination.
7.4 Headspace
Headspace monitoring may be used to perform things like screen samples to determine
operational constraints, PPE requirements, and handling precautions.
Headspace monitoring shall be performed m accordance with table 7-1 on solid samples that
have been bagged or contained in an agent-tight barrier of sufficient volume to permit sample air
to be withdrawn while minimizing dilution with incoming air. Headspace monitoring is
required for one complete sampling cvcle ofthe NRT. Prior to monitoring for one complete
sampling cycle, the sample line should be ]?urged to ensure that a clean representatn'e sample is
taken. Historical monitoring can be perfonned instead of NRT monitoring. Liquid samples may
not be headspace analyzed to support the disposition ofthe liquid. Liquid waste samples must
be cleared by extraction and meet applicable waste control limits.
Headspace monitoring for the purpose of decontamination verification shall include the following:
- the item has been surface decontaminated by locally approved procedures
- the item has been bagged or contained in an agent-tight barrier of sufficient volume to
permit sample air to be withdrawn while minimizing dilution with in-coming air
- the Item shall be allowed to off-gas for a mmiimim of 4 hours at temperatures at or
above 70 degrees Farenheit
^.5 ^Personnel Decqntaminafion Station (^
In the event of a potentially exposed worker, MINICAMS™ will be available to conduct NRT
monitoring in the Air Shower/Changing Rooms. The monitoring at this location will be at the
VSL.
7.6 Historical Monitoring
Historical monitoring is performed to measure very low concentrations of airborne analytes at
the WPL, where contamination is unlikely or workers are operating without PPE. Sampling is
accomplished by the collection of an air sample over an extended period of time (usually the
duration of a workday), and subsequent analysis is conducted offline at the site laboratory.
Historical monitoring is designed to trigger activities to investigate the source of contamination
that may be found below the alarm level ofthe NRT system. All historical DAAMS samples
must be analyzed within 72 hours of sampling termination.
During agent operations (whenever unmasked workers are in the EE), historical DAAMS
stations will be employed.
7.7 Vapor Screening of Sample Containers
As a minimum, headspace monitoring shall be implemented on all solid process sample
3f
Formatted: Indent: Left: 36 pt
Deleted: Headspace monitoiing shall
be perfonned at the VSL on samples tliat
have been bagged or contained in an
agent-tight barrier of sufficient voliune to
pennit sample air to be withdrawn while
niininiizing dilution with incoming air.
One complete sampling cycle of tlie NRT
monitor is required. Historical
monitoring can be perfonned instead of
NRT monitoring.^
Note: Tliese results may not be used to
support disposition of material that
requires decontamination. Headspace
monitoring for the purpose of
decontamination verification shall follow
the requirements described in paragraph
4.4. ofCMA'sMCP.t
Formatted: Right: 1.55 pt
contamers, and any liquid process sample containers j?rior to jransfer to the laboratory (i.e., _
Mobile Analytical Platform). The purpose of this screening is to provide evidence that
contamination is not present on the sample container prior to the container leaving the
environmental enclosure. ,
Vapor screening will be performed on items that have been bagged or contained in an agent-tight
banier of sufficient volume to permit sample air to be withdrawn while minimizing dilution with
incoming air. Vapor screening can be performed with either MINICAMS™ or DAAMS tubes. If
results provide a concentration greater than 0.5 VSL, conective actions shall be implemented (e.g.,
confirmation, repeat decontamination process, and re-monitor).
^•9 SAMPLE AND ANALYTICA^^ METHODS
The ECBC Sample and Analytical Methods will be used to characterize the waste prior to
shipment of waste off-site.
Deleted:
Deleted: shipment
Deleted: Vapor screening will be
conducted in accordance with ECBC
lOPs and Department ofthe Army
Pamphlet (DA Pam) 385-61.1[
Formatted: Expanded by 0.15 pt
Deleted: ^
9.0 ALARM RESPONSE/REPORTING POSITIVE CHEMICAL MATERIEL
RESPONSES
All worker and environmental protection MINICAMS'^'^ alarms will require confirmation
analysis. The MINICAMS™ alarm confirmation will be performed by collection and analysis
of a DAAMS tube sample.
9.1 Monitoring Levels
Monitoring at the VSL will be performed in areas where worker protection monitoring is required.
If the NRT sampling and analysis cycle time is less than 15 minutes (the STEL), excursion is
manually calculated using the concentration reported by the NRT monitor.
The VSL is intended for applications and/or locations that require monitoring for an
environmental release, engineering controls (e.g., filters), process upset condition, or vapor
decontamination classification monitoring. The VSL is a concentration-only value and does not
consider the analysis method's sampling duration other than to determine the volume of air
sampled to calculate the anal5^e concentration.
9.2 MINICAMSTM Alarm Setpoints
During EDT operations at DCD, the following alarm levels will be used:
• 0.5 Z will be used in all areas where worker protection is being performed (all
locations inside the EE and the PDS).
9.3
• 0.5 Z will be used in all process monitoring areas (within the air filtration units).
NRT Notifications
32
In the event of an alarm, the MINICAMS™ operator will notify the Versar EDT Site Manager
and ECBC Site Supervisor. In addition, the EG&G Site Safety and Health Officer (SSHO) may
be notified, depending on the situation. Table 9-1 lists several possible scenarios, persons to be ^ -{Deleted; notified,
^Qotified and possible actions to be taken. ^ -'
9.4 Confirmation and Historical Notifications
The support laboratory will notify the Versar EDT Site Manager ofthe results of all DAAMS tube
analyses. If the samples were confirmation samples, the Versar EDT Site Manager will notify
the EG&G Safety Office ofthe results. If the samples were analyzed only for historical purposes,
the Versar EDT Site Manager will notify the EG&G Safety Office only if agent was detected.
The EG&G Project Manager will be notified of all detections and confirmed detections of
chemical agent. Table 9-2 is the DAAMS tube analysis matrix.
33
Table 9-1: NRT Notification Matrix
Situation Notification Possible Action*
Single NRT Alarm • Versar EDT Site
Manager and ECBC Site
• Await result of next
MINICAMS™ cvcle
Single NRT Alarm
Supervisor
• ECBC SSHO
• EG&G Safetv Office
• TOCDF Environmental
Shift Rep
• Evaluate non-essential
personnel
• Evaluate PPE
• Analvze DAAMS tubes * -
Two Consecutive NRT
Alarms
• Versar EDT Site
Manager and ECBC Site
• Await result of next -^-^
MINICAMS™ cvcle
Supervisor
• EG&G Safetv Office
• ECBC SSHO
• TOCDF Environmetnal
Shift Rep
• Evaluate PPE
• Determine source of
contamination
• Analvze DAAMS tubes
Three Consecutive NRT
Alarms
• Versar EDT Site
Manager and ECBC Site
Supervisor
• EG&G Safetv Office
• ECBC SSHO
• Determine source of
contamination
• Analvze DAAMS tubes
• Relocate filtration svstem
MINICAMS™ sample point fi:om
Three Consecutive NRT
Alarms
• TOCDF Environmental
Shift Rep
midbed location to post-bed * -
location
" \ Formatted: Bullets and Numbering
I Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
Formatted: Bullets and Numbering
*This table is based on detection of chemical warfare materiel (CWM) at the alarm set point-
Decision on actual actions taken will reside with the Versar ETD Site Manager. Actions may
varv, depending on the actual concentration of CWM detected.
Notes:
DAAMS - Depot Area Air Monitoring System
DCD - Deseret Chemical Depot
EDT - Explosive Destruction Technology
PPE - Personal Protective Equipment
Deleted: \
Table 9-1. NRT Notification Matilxf
situation |^3'j
Formatted Table
Formatted Table
34
Table 9-2: DAAMS Tube Analysis Matrix
Response to Location/Scenario DAAMS Tube Analysis Sites
NRT Alarm EE Co-located confirmation DAAMS Tubes
NRT Alarm Midbed carbon filter position in EE air
handlina unit
Co-located confirmation DAAMS Tubes
Continaency Visually observe item leaking inside EE All historical DAAMS stations in EE and
EE exhaust filtration system
Contingency Failure of engineerina controls in EE All historical DAAMS stations in EE and
EE exhaust filtration system
Oualitv Assurance Requirement Each day of destruction operations at least
one - OP DAAMS tubejor each method
Notes:
DAAMS - Depot Area Monitoring System
EDT - Explosive Destruction Technology
EED - Environmental Enclosure
"I' If
"• H
lit /
Deleted: from above the door of the
EDT vesel
Deleted: Table 9-2. DAAMS Tube
Analysis Matrix^
Response
To Location/Scenario DAAMS Tube
Analysis Sites^f
Deleted: MINICAMS™®
Deleted: NRT EE Co-located
confirmation DAAMS tubes^l
Alarm^l
Deleted: MINICAMS^
Deleted: NRT^j
Alarm Midbed carbon filter Co-
located confirmation DAAMS tubes^f
position in EE air^
handling unit^
Contingency Visually observe item
All historical DAAMS stations in EE and
EE exhaust^l
leaking inside EE filtration system^l
Deleted: (outside of EDTt
vessel)!
Deleted: Contingency Failure of
engineering All historical DAAMS
stations in EE and EE exhaust^!
controls in EE filfration system^l
Quality Assurance Each day of
destruction operations at least one -f
Requirement • DAAMS tube from
above the door of the EDT^I
vessel!!
Notes:f
DAAMS = Depot Area Air Monitoring
System^!
EDT = Explosive Destruction
TechnologyTI
EE = Environmental Enclosure!!
Formatted: Expanded by 0.1 pt
35
9.5 WPL Excursions
In the event of a WPL excursion, the Chemical Agent Worker Population Limit (WPL)
Excursion Plan for the DCD EDT System at Tooele, developed by ECBC, will be implemented.
10.0 MONITORING OF POTENTIALLY EXPOSED WORKERS
Monitoring of potentially exposed workers will be conducted in accordance with the DA
Memorandum: Performance Standard for Monitoring Potentially Exposed Workers,
13^eptember 2007^
11.0 QUALITY CONTROL REQUIREMENTS
All monitoring operations will be conducted in accordance with the ECBC LMQCP, the CMA
LMQAP, and apphcable lOPs. The ECBC will incorporate the data generated into the monitoring
40-year data storage program, should access to additional information be required. The QC
requirements for applicable ECBC lOPs ^lOP MT-6^ and lOP MT-13) are proyided in Tables
11-1 and 11-2, respectively.
11.1 Certification Requirements
The laboratory shall perform a certification and validation process for operators, instruments,
and methods to confirm that analytical processes are suitable for use.
Method certification will require completion of a successfiil precision and accuracy (P&A)
study and initial baseline study. JVIethod certfication will be required before the method can be
used in support o£operations. Method validation will be demonstrated through the continuing^
baseline study.
11.1.1 Precision and Accuracy (P&A) Method Certification
All NRT and historical agent methods will be certified as Class I methods via P&A studies in
accordance with the LMQAP. Confirmation methods will be certified as Class IE methods..
Class in method results that yield a positive response will be considered confirmed detections .
The P&A studies will be performed on-site j)rior to thepre-operatiqnal survey for data evaluation
by the CMA Monitoring Office.
Deleted:
Deleted: lOP MT-16,
Deleted: 02
Deleted: However, if mobile criteria
are used, challenges may occur
periodically in accordance witli CMA
LMQAP Table 12-1.
Deleted:
Deleted: via P&A studies
Deleted: at DCD
11.1.2 Baseline Method Certification and Validation
All methods shall successfully satisfy the regular initial j^aseline study method certification
requirements as shown in Table 13-3^qf the CMA LMQAP before tl^^
support operations. ,
Deleted: alternate
Deleted: 4
Deleted: However, if mobile criteria
are used, challenges may occur
periodically in accordance witli CMA
LMQAP Table 13-3.
36
Deleted: 02
Table 11-1: OC Requirements for lOP MT-6e
Deleted:, HT
Deleted: Initial
37
QC Sample Frequency Acceptance Limits Corrective Action
Sampling Flow Rate
Measurements
During Calibration HD; 400± lOOmL/min Adjust and recheck before Sampling Flow Rate
Measurements
During Calibration
starting calibration and analysis
^CalibrationjChallenge (1.0 Z^^ ^ollowma calibration miections 0.7.\to 1.25,4 Investigate and perform
corrective action. Repeat
calibration^ if required.
JDailv challenge After the end of daily p. 75 to 1.254 Investigate and correct cause.
operations or if no operations
occur, at least 12 hours after
c a 11 b r a 110 n c h a 11 e n 2 e
Recalibrate if necessary. Note
on data forms and qualify data.
Deleted: (ICAL) l High Level
Deleted: VSL
Deleted: Started of each operational
day or after failing midday challenge
Deleted: 60
Deleted: 40
Deleted: VSL
Deleted: correct i
Deleted: ICAL
^ Operafion and Maintenance Procedures for Fixed Site MNICAMS™ r
Note: \ \>t
HD - distilled sulfur mustard \ >f
,piL/min - milliliter per minute ^ '
OC - quality control \
T ^ X
T
Table 11-2: OC Requirements for lOP MT-IS"
Deleted: Continuing Cahbration
Verification (CCV ) - Also Called
Challenge 1 Low-level Challenge (0.25
VSL)*"
Deleted: Afler every 4 to 5 hours of
operation and at the end of operational
date
Deleted: VSL
Deleted: Repeat ICAL if failure is for
midday challenge. No action if fai _ ^ ["g"!
Deleted:''Distal end line clialh p^Qi
Deleted: HT - {bis[2-(2-...[11]
Deleted: VSL - Vapor Screening Limits
Deleted: J
Formatted: Left
Formatted: Left
Formatted: Left
Formatted: Left
Deleted; ° Operation and Main [131 ^
Formatted: Left
QC Sample
Sampling Flow Rate
Measurments
Five Point Initial Calibration
(ICAL)
Initial Calibration Verification
(ICV}
Continuing Calibration
Verification (CCV)
Method Blank
Quality Process (QP) - Similar
to Matrix Spike
Frequency
Before and after sample
collection
When instrument parameters
change. After Preparation of
new standards
At the start of each day of
analysis. After ICAL
At the end of a sample run or
every 12 hours, whichever is
shorter
At least one before analyzing
samples
1 each per batch of 20 or fewer
samples.
Acceptance Limits
Starting and ending flow rates
within 10% ofthe average flow
rate.
R2>0.99
Each target analyte ±15% of
true value
Each target analyte ±15% of
true value.
Absence of target analytes and
interferences
Recovery >10% (Note: Agent-
specific limits are currently
under development)
Corrective Action
Repeat sampling unless
samples are one of a kind. If
one of a kind, flag data.
Investigate and correct the
cause. Repeat ICAL.
Recalibrate.
If results >115% of true value,
recalibrate. Sample results may
be reported.
If results <85% of true value,
recalibrate. Analyze second
sample tube for each sample
analyzed since.
Investigate and correct. Repeat
method blank to verify
acceptable performance.
Verify spiking solutions.
Analyze second QP tube. If
results are confirmed spike and
analyze second sample tube
from location where QP was
taken.
^Analysis of Chemical Warfare Agents and Degradation Products on DAAMS Tubes using a Gas Chromatography System Coupled with a
Mass Selective Detector
•^gi^jl _ _ Q^ajitY Control
38
Deleted: f
Formatted: Left
Deleted: Table 11-2: QC
Requirements for TOP MT-13"'
Deleted: <sp>Table 11-2. QC
Requirements for lOP MT-13"f
QC Sample Frequency Acceptance
Limits Corrective Actionf
Sampling Flow Rate Measurements
Before and after sample Starting and
ending flow Repeat sampling unless
samples are one ofK
collection rates within 10% of the a
kind. If one of a kind, flag data.^^
average flow ratef
<sp>l
Five Point Initial Calibration
(ICAL) Wlien instmmentK
parameters changef
After preparation of new standards!!
When ICV or CCV fails [-141
During the initial baseline studies, all sampling and analysis operations shall be performed
exactly as set forth in the applicable analytical procedures under similar operating conditions
for instruments shown to be in control. The^initial baseline study^shall be cpniposed of _
challenges performed at the end of each operational day for not less than 20 days.
The continuing baseline study will be conducted to validate long-term performance ofthe
monitoring systems. The continuing baseline study begins immediately after successful
completion ofthe initial baseline and will be conducted in accordance with table 13-3 of the CMA
LMOAP.
^or monitoring cessation of less than 60 days, NR^pietliod re-certification^h^an b^
accordance with CMA LMQAP, table li-5V//////////////_ _ _____
11.2 Calibration and Test Methods
The laboratory shall have an established calibration program. Air monitoring methods shall
undergo calibration in accordance with ECBC lOPs. This plan shall define the calibration
requirements for chemical materiel methods, including physical measurement equipment or
other laboratory equipment that validates a measurement.
The calibration plan shall have documented instmctions on using and operating all relevant
equipment, handling and preparing calibration items, and calibrating equipment. All up-to-date
instmctions, standards, manuals, and reference data relevant to the monitoring or laboratory
operation shall be maintained and be readily available to staff and auditors. The laboratory and
monitoring staff shall use documented procedures and legally defensible statistical techniques to
select representative samples for analysis, where applicable.
All calculations and data transfer performed in support of solution preparation, calibration,
and sample analysis shall be documented on a calculation sheet, signed and checked by a
separate person. The validator shall sign the calculation sheet once it is deemed accurate.
Where computers or other automated equipment are used to capture, process, manipulate,
record, report, and/or store or retrieve calibration or test data, the laboratory shall ensure that:
• The computer software is documented, fully tested, and adequate for use.
• Computer and automated equipment is maintained to ensure proper functioning
and is provided with the environmental and operating conditions necessary to
maintain its integrity.
• Procedures are implemented to protect data integrity.
• Appropriate and up-to-date virus protection is in use.
Deleted: alternate
Deleted: will consist of one challenge
event, the beginning of the operational
workday, tlien not less than three
challenge events per station per day with
a challenge event every 2 to 3 hours. The
alternate baseline will be conducted for 3
consecutive days. If necessary, mobile
criteria may be used in heu of the
alternate baseline.
Deleted: Tlie mobile baseline study will
consist of one cliallenge event at the start
ofthe work day or operation, a challenge
every 4 to 5 hours, and at the end ofthe
workday or operation, each day of
operations.^
For monitoring cessation greater tlian 60
days, tliree 1-day imtial and continuing
baselines will be repeated.
Deleted: baselines
Deleted: 0
• Previous releases of software packages are maintained if data reprocessing is
required.
EDT personnel shall establish and implement appropriate procedures for the maintenance and
39
security of data, including the prevention of unauthorized access to and amendment of computer
records.
11.2.1 .Calibration of Near Real Time Instruments
NRT systems used to support class I air monitoring methods shall be calibrated using a minimum
of two injections at the l.OZ level. Calibration will be considered acceptable if a challenge
sample yields acceptable per cent recovery and carry over is less than 0.2 Z as compared to a
blank cycle.
ai.2.2 Calibration of GC/MS Systems
GC MSD s\'stems used to analyze class I air samples shall be calibrated using a minimum three
point calibration curve with masses covering the analytical range for each chemical to analyzed.
At least one mass equivalent will be at or below the lowest l.OZ monitoring level. Cahbration
regression lines shall provide a correlation coefficient value of 0.990 or greater.
11.3 QC Sampling
All instmments used for the analysis of chemical agents shall be subject to periodic QC sample
analysis to check the process from sample collection through analysis. The QC samples are also
used to:
• Evaluate the accuracy and precision of analytical data to establish the
quality ofthe data.
• Provide an indication of the need for corrective actions.
• Determine the effectiveness of corrective actions when they are
implemented.
The laboratory and monitoring staff that supports EDT operations uses numerous types of QC
samples to inspect the measurement process. The QC samples provide data that can validate the
results of the analysis of an actual sample. The following types of QC samples are used by the
laboratory staff during EDT operations:
• Blanks;
• Replicates;
• Calibration checks;
• Matrix spikes (MSs);
• Field spikes [quahty plant (QP)]; and
• Laboratory spikes [quality laboratory (QL)].
40
Deleted: Performance Charts
Deleted: Tlie laboratory may use
performance charts for intemal QC
tracking. A perfomiance chart is a
graphical plot of challenge results with
respect to time or sequence of challenges,
with limits drawn witliin wliich results
are expected to lie when the analytical
scheme is in a state of "performance
control." In addition to identifying
methods or instrumentation that are out of
"perfomiance control," tlie chart discloses
any trending.^!
Formatted: Font: Bold
Formatted: Font: Bold
Detailed definitions and descriptions of QC samples are available in the CMA LMQAP. ,
11.3.1 NRT Methods
All NRT monitors ^will be challenged via QP samples immediately following calibration and at
the end of daily operations. If no operations occur on a given day, a challenge will be
performed at least once during the day. These challenges will be designated as continuing
baseline challenges. If two consecutive challenges fail to meet acceptance criteria,
corrective action and data ciiialification is reciuired for all readings above 0.25Z. J'he QP
challenge shall deliver agent to the instmment at 10^.
Deleted: Limiting Conditions of
operation (LCOs) can also be found in
the LMQAP.
Deleted: metliods used during
operations
11.3.2 Historical/Confirmation Methods
• QP Samples. All historical/confirmation methods will be challenged via QP samples in
accordance with the CMA LMQAP, Table 13-4 and table 7-1. Confirmation QP
samples must be analyzed within 72 hours of sample termination.
A QP sample challenge failure will require corrective action and additional daily QP
challenges until the problem is resolved. These QP challenges will not be included in
the baseline studies, but will be included in the corrective action report.
• QL Samples. All laboratory instmments used for analysis as part of historical or
confirmation methods shall be challenged with QL samples [initial calibration
verification (ICV) or continuous calibration verification (CCV) samples] to assess the
laboratory's cross-contamination and bias.
11.3.3 In-Control Criteria and Notification
The term in-control is used to indicate that the laboratory and monitoring analytical activities are
within the pre-established statistical control limits and meet baseline study requirements. When
instmmental methods are in-control, the analytes are detected and accurately quantitated if
present in a sample. To protect personnel at the site, the monitoring equipment must be
operating and in control before operations start each day and remain in control for the operational
period. The EDT personnel report to the Versar EDT Site Manager the status ofthe monitoring
and analytical instmmentation on a daily basis. The ECBC will record the control status ofthe
laboratory and monitoring equipment in a daily operational log. If the laboratory or monitoring
equipment is determined to be out of control, or if control status is questionable, then the Versar
EDT Site Manager will be notified immediately. This ensures that agent concentrations above or
equal to the MINICAMS™ alarm set_point at sampling locations will be properly detected and
quantitated, and laboratory equipment will provide unqualified analyses.
11.3.3.1 Monitoring Equipment In-Control Critena/LCOs
The EDT monitoring equipment is in-control if the following criteria are met:
• The MINICAMS™ alarm systems have successfully passed their daily initial
baseline challenge.
• The alarm confimiation and historical sample stations are online and operating.
41
Deleted: according to tlie frequency
identifled in tlie CMA LMQAP.
~ H Deleted: VSL
The QC sample results reported back to the site from the laboratory are
acceptable.
• The monitoring teams have qualified personnel onsite to maintain
monitoring operations in accordance with this SSMP.
11.3.3.2 Laboratory In-Control Criteria/LCOs
The laboratory is in-control if the following criteria are met:
• The instruments that will be used for sample analysis have been calibrated and
challenged, and meet all performance criteria.
• The samples can be received, stored, prepared, and analyzed in accordance with
approved SOPs and this monitoring plan.
• The laboratory is staffed with qualified personnel to prepare samples,
perform sample analysis, document and report sample analysis results,
and maintain monitoring operations in accordance with this SSMP.
The in-control status of the laboratory will be recorded in the instrument data sheets on a daily
basis prior to sample analysis. Traceability will include calibration of analytical instmments and
qualifications of the operators.
11.3.3.3 Corrective Action
If a QL result is outside the acceptable limits, then the method being checked is considered out of
control. Another QL sample that duplicates the initial QL sample conditions will be mn as soon
as possible. Immediate corrective actions will be taken to identify the source ofthe out-of-
control condition. The Versar EDT Site Manager or designee will be notified if the laboratory
cannot be retumed to an in-control status.
11.4 Sample Handling and Storage
All laboratory and monitoring work performed during EDT operations shall follow strict COC
procedures. The maintenance of records on the samples collected, received, and analyzed is a
critical part of the monitoring program.
The laboratory and monitoring personnel are required to ensure that COC is properly conducted.
The recei'ving chemist will monitor the receipt of samples and compliance with preservation
and holding time specifications. Specific procedures will be established by the laboratory
and monitoring teams and ECBC under guidelines provided in the following paragraphs.
11.4.1 Shipping Containers and Custody Seals for Nonagent Analysis
Cleaned sample bottles will be sent to the field in shipping containers that will be used for return
of samples to the laboratory. Each sample container will contain packing material to protect the
42
samples from movement during shipment. Individuals collecting samples will follow published
U.S. Environmental Protection Agency (USEPA)-approved procedures (SW-846) and site-
specific SOPs, as approved by state agencies. The sample collection record will contain, as a
minimum:
Sample identification (ID);
Date and time;
Start and stop flow rates or collection times;
Start and stop times of sampling period;
Volume of sample;
Sample location;
Operator's ID
Agent and monitoring level;
Sample type; and
Preservative, if any.
Deviations from SOPs, security, and unusual environmental conditions shall also be included in the
sample collection record.
11.4.2 Sample Identification
A unique sample ID number will be affixed to the sample or sample container. To ensure
traceability and uniqueness ofthe sample identification, the sample ID number should
incorporate the sample type, date, and time that the sample was collected. Any deviations from
standard procedures shall be noted in the comments section ofthe sample COC form.
The sample identification system shall be documented, along with a method that relates the field
data to the samples. All documentation ofthe samples shall be performed in permanent ink. If
corrections are made to the data, the error will be crossed out once and initialed and dated by
the person documenting the data. All field notebooks shall become part ofthe project files.
11.4.3 Sample COC Documentation
The COC documentation will be strictly maintained. Evidence of sample custody shall be traceable
from the time the samples are collected until the samples are disposed of after sample analysis.
After samples are collected, the COC form will be completed, and the original will be placed in
a plastic bag inside the secured sample transport container. Samples identified for analysis by
the Organization for the Prohibition of Chemical Weapons will require a custody seal to be
affixed to each sample container. A COC form will be forwarded with the samples as they are
stored, prepared, analyzed, and finally disposed of in the laboratory. Receipts from post offices,
copies of bills of lading, and airbills will be retained as part ofthe COC documentation for samples
43
that have been shipped off-site.
11.4.4 Sample Storage
The laboratory shall be responsible for the documentation, security, and maintenance of storage
conditions for sample storage.
11.5 Statistical Validation
Statistical validation will be documented in reports including QC data, statistical analysis, and
corrective actions. The laboratory will submit the QC data to the CMA mandated statistical
program from baseline through closure at https://home.cma.armv.mil/qcdrs.
11.5.1 Routine Statistical Reports
Raw data will be submitted to the operating contractor for data treatment. Reports shall be
transmitted via the web-based statistical software to EG&G and CMA-Monitoring Office
representatives on a monthly basis. These reports will contain information regarding the
initial and continuing baseline studies. The laboratory will use the software to produce
statistically valid and defensible reports.
11.5.2 Statistical Analysis of Cahbration Cui've Data
Calibration curve data for the analj^ical equipment used in the sample measurement process will
be analyzed statistically. Once the laboratory has defined the calibration method for an instmment,
acceptance criteria for the calibration curve data will also be developed.
The chemical material raw calibration data shall be generated from the laboratory specified
calibration curves. Algorithms used for calibration curves shall satisfy the calibration requirements
specified for each analytical method.
11.5.3 Data Vahdation
Data validation of laboratory and monitoring data shall be performed routinely to ensure all data are
used effectively and in accordance with the approved QC plan. Validation may be performed more
frequently when data integrity has been or is suspected to have been compromised. Data
captured that do not satisfy applicable data quality objectives (DQOs) will be deemed compromised
data. Compromised data must be qualified appropriately and corrective actions shall be
implemented to ensure that future data have the capability of satisfying applicable DQOs.
The laboratory will define and document proper site validation procedures. To validate analytical
and monitoring data, all equations and calculations must be validated during internal audits of the
laboratory and monitoring teams. The internal data validation review will be documented in
the laboratory or monitoring files, whichever is appropriate. If the internal data validation
identifies an error, the CMA-Monitoring Office or designee will be notified. All actions taken
to correct the error shall be documented.
44
11.6 QC of DAAMS Tubes
New DAAMS tubes shall be subjected to the following test^ The nimber of tubers to bej)ulled
for testing is provided in Table 11-3
Sampling/acceptance and inspection requirements consist of:
• The Sample number, which is in accordance with American National Standards
Institute (ANSI)/American Society for Quahty Control (ASQC) Z1.4, acceptable
quality level of 2.5 percent nonconformance.
• Visual inspection for loose packing, warped tube ends, and loose sorbent material
• A pressure-drop test to ensure sufficient airflow through the mbe. For DAAMS
6-mm tube Tenax® TA, the pressure drop may not exceed 15 inches of mercury
(Hg).
Deleted: , or the manufacturer shall
supply documentation with each lot
purchased, attesting that the lot of
DAAMS tubes have been subjected to
these tests and meets all requirements
Table 11-3. Samples Sizes for Normal Inspection for Maximum of 2.5 Percent
Nonconformance
Lot or Batch Size
General Inspection
Level 1, Number of Samples Rejection Number"
2 to 8 2 1
9 to 15 2 1
16 to 25 3 1
26 to 50 5 1
51 to 90 5 1
91 to 150 8 1
151 to 280 13 2
281 to 500 20 2
501 to 1,200 32 3
Reject the entiie lot if this number of samples is found to be defective.
11.7 Tube Conditioning
After the representative mbes from a lot pass visual inspection and pressure drop testing, they
will be conditioned in a flow of nitrogen at 290 °C for 20 minutes, followed by a 5-niinute
cooling period. All mbes must be conditioned before agent recovery testing.
11.8 Heated Sample Lines
Heated sample lines will be challenged at the distal end every 60 days for all locations
except the stack. Heated sample lines used for stack NRT monitors will be challenged every
45
two weeks. Heated sample lines used for headspace monitoring will be challenged at the
distal end before and after each analysis batch. All sample line challenges will be performed
at l.OZ and will demonstrate recovery of 0.60 to 1.40Z.
12.0 DOCUMENTATION
12.1 General Monitoring Documentation
During operations, ECBC personnel will maintain documentation of all monitoring activities.
The documentation will include activity information on daily air monitoring, sample records, chain-
of-custody (COC) forms or transfer of possession, sample analysis records, equipment
calibration, equipment maintenance records, agent response, and Standing Operating Procedures
(SOPs) and/or Intemal Operating Procedures (lOPs) for air monitoring and laboratory analysis.
12.2 Equipment Documentation
All support laboratory analytical equipment infomiation will be documented by ECBC support
laboratory persormel. The laboratory will document and maintain all acceptance test results for
the equipment. Information regarding each instrument is documented in logbooks, an electronic
database, or other applicable format.
12.3 Reference Standards
The RDT&E dilute CASARM solutions will be used. Agent standards received by the agent
custodian or designated alternates will be accounted for, undamaged, and properly labeled at all
times.
^ •{ Formatted; Font: Bold
^12.4 Laboratorv Wastes ..^'^
Waste generated by air monitoring operations will be managed in accordance with local mles
and regulations.
13.0 TRAINING REQUIREMENTS
All EDT monitoring personnel are required to meet the minimum training requirements outlined in
the OSHA standard 29 Code of Federal Regulations (CFR) 1910.120 covering Hazardous
Waste Operations and Emergency Response (HAZWOPER). The ECBC personnel will
perform all monitoring and analytical operations at the site. All monitoring personnel must also
meet the training criteria detailed in the ECBC LMQCP.
46
APPENDIX 1.
ACRON\MS/ABBRE\ lATlONS/TERMS
-17
APPEIVDIX 1. ACRON\MS/ABBRE\ lATlONS/TERMS
•AEL airbome e.\posure limit
•ANSI .American National Slani.lan.ls Inslilule
•ASC .Allowable Slack Concenlralion
.\SQC .American Society lor (Quality Control
C. AS.ARM Chemical .Agent Slani.lan.1 .Analytical Rel'erence Material
CC\' continuous calibration \ eril1calion
CDC Center for Disease Control
CFR Cotle ol"Fei.leral Regulations
CMA U.S. .Army Chemical Materials .Agency
COC Chain ol'Cuslotly
D. A Department ol'lhe .Army
D.A Pam Department ol" the .Army Pamphlet
D.AAMS Depot .Area .Air Monitoring System
DCD Deseret Chemical Depot
DHHS Department ol" Health ani.1 Human Ser\' ices
DQO (.lata i.|ualily obiecli\ e
-!«
ECBC Ei.lge\vooi.l Chemical Biological Center
EE En\ ironmenlal Enclosure
FPD llame photometric (.leleclor
G. A la bun
GB sarin
GC gas chromatograph
GC FPD gas chromatograph llame photometric (.leleclor
GC MS gas chromatograph mass spectrometer
GD soman
H. AZ\\'(!)PER Hazartlous W aste (!)peralions ani.1 Emergency Response
HD i.lislillei.1 sulfur muslan.1 ('Bis('2-chloroelh\ 1) sullkle)
Hg mercuiy
HT !bis[2-('2-chloroelhylthio)elhyl]elher;
HTSL heal-tracei.1 sample transfer line
IC.AL Initial Calibration
1C\' initial calibration \ erificalion
ID klenlificalion
IDLH ImmetlialeK' Dangerous to Life ani.1 Health
\0P intemal (!)peraling Procetlure
LCO limiting contlilion ol"operation
LNK^.AP Laboratoiy ani.1 Monitoring (^ualit\' .Assurance Plan
LMC^CP Laboratoiy ani.1 Monitoring (Quality Control Plan ( for Chemical Materials
.Ai:enc\' ('CMA ianLl for Chemical .Aeenl Slani.lan.1 .AnaKlical Reference
Material (•(^AS.ARM))
MAP Mobile .Analytical Platform
MARB Materiel .Assessment Re\ ie\v Boan.1
MCP Monitoring Concept Plan
MS Mairi.\ Spike
-19
MS Mass Speclrophotomeliy
NRT near-real lime
OSHA '•!)ccupalional Safely ani.1 Health .Ai.lministralion
PA A precision ani.1 accuracy
PCT Pre-Concenlralor Tube
PDS Personnel Decontamination Station
PMNSCM Project Manager for Non-Stockpile Chem ical Materiel
PPE personal prolecli\ e ei.|uipmenl
QA '.(ualily n.s.surnnce
QA (^c '.|ualily assurance i.|ualily control
QC '.|ualit\' control
QL '.|ualily laboratoiy
QP '.|ualily plant
RDTAE research i.le\ elopmenl. lest, antl e\ alualion
RT.AP Real-Time .Analytical Plalfomi
SOP Slantling (!)peraling Procetlure
SSHO Site Safet}- and Health Officer
SSMP Site-Specific Monitoring Plan
SEL Source Emission Limil
STEL short-lemi e.\posure limil
TWA rime W'eighlei.1 .A\ erage
USEPA U.S. En\ ironmenlal Protection .Agency
\"SL \'apor Screening Le\ el
\'X '•:)-ethyl S-('2-diisopropylaminoethyl)melhylphosphonolhioale
WPL worker population limil
.\SD haloeen selecli\e (.leleclor
50
Formatted: Left: 70.55 pt, Right:
72 pt, Top: 76.3 pt. Bottom: 30.95
pt
APPENDIX 2.
REFERENCES
Formatted: Left: 70.55 pt, Top:
76.3 pt. Bottom: 30.95 pt
APPENDIX 2. REFERENCES
ANNEXE Site-Specific Monitoring Plan for the Explosive Destruction System at Dugway
Proving Ground, U.S. Army Chemical Materials Agency Project Manager for Non-
Stockpile Chemical Materiel Site-Specific Monitoring Plan for the Explosive Destruction
System at Dugway Proving Ground, Final Revision 2, March 2009.
CMA, Programmatic Monitoring Concept Plan, most recent version.
Department ofthe Army (DA), Implementation Guidance Policyfor Revised Airbome
Exposure Limits for GB, GA, GD, GF, VX,H,HD, andHT, 18 June 2004.
DA, Interim AMC Supplement to the Implementation Guidance Policy for Revised Airbome
Exposure Limits for GB, GA, GD, GF, VX,H,HD, andHT, 14 December 2004.
DA, Memorandum, Subject: Performance Standard for Monitoring Potentially Exposed Workers,
13 September 2007.
DA Pamphlet 385-61, Toxic Chemical Agent Safety Standards, 17 December 2008.
U.S. Army Chemical Materials Agency (CMA), Programmatic Laboratoiy and Monitoring Quality
Assurance Plan, most recent version.
U.S. Environmental Protection Agency, Test Methods for Evaluating Solid Wastes, Physical/
Chemical Methods, SW-846, current version.
52
Page 12: [1] Deleted arlita.privett 10/20/2010 6:14:00 AM
Table 5-1: Description and Requirements for Monitoring and Sampling Equipment
Manufacturer Minimum Operational
Monitoring Operational Components Specifications Requirements Preventive
NRT Monitors:
MINICAMSTM^
NRT Detectors:
FPD
XSD
PFPD
Operational Components:
Preconcentrator
Tubes/Sample Tubes
Sample Loops
Capillary Columns
Mass Flow Controller
Support Gases:
Purifiers
Leak Detectors
Compressed Gas
Regulators
Electrical Requirements:
Critical NRT monitors
equipped with UPS^
Power is provided in
accordance with
manufacturer
specifications.
Temperature:
Use operational
performance
characteristics to
determine if the NRT
is operating within
control.
Doors to
enviroimientally
controlled NRT
monitor shelter must
remain closed at all
times, except during
personnel
entry/egress.
Condensation shall be
minimized and if
observed, corrective
actions will be taken
immediately.
Routine Calibration
Daily Challenges
Calibration of mass
flow meter
The sample exhaust
must be filtered,
retumed to the
sampling point, or
vented to appropriate
engineering controls.
PCT is replaced as
needed, based upon
challenge
performance.
Page 13: [2] Deleted arlita.privett
=End of Section=
10/20/2010 6:15:00 AM
Table 5-1: Description and Requirements for Monitoring and Sampling Equipment (Continued)
Monitoring Operational
Manufacturer
Specifications
Minimum Operational
Requirements Preventive
Depot Area Air
Monitoring System
(DAAMS)
DAAMS Operational
Components:
DAAMS Tubes:
Size may vary
depending on agent
operation.
Sequencers:
Direct and control flow
patterns
DAAMS Manifold:
Provides stable
support system
Power Requirements:
Power is provided
in accordance
with
manufacturer
specifications.
Critical DAAMS
equipped with
UPS'
Temperature:
Temperature
is
maintained
to
minimize
condensate
formation.
The sample
exhaust must be
filtered, retumed
to the sampling
point, or vented to
appropriate
engineering
controls.
Vacuum Pumps:
Used in
conjunction with
a flow control
device or critical
orifice
Should maintain
critical ratio of inlet
to outlet vacuum
across the orifice
Daily checking of
flow rates, critical
orifices, fittings,
and ferrules
Vacuum
pump,
sequencer, and
sample transfer
line preventive
maintenance will
be performed in
accordance with
manufacturer
specifications.
Require air,
nitrogen, or other
inert gas flow
through tube and
thermal desorption
of tube for
conditioning
Page 14: [3] Deleted arlita.privett
Section Break (Next Page)
10/20/2010 6:15:00 AM
Table 5-1: Description and Requirements for Monitoring and Sampling Equipment
(Continued)
Monitoring Equipment Operational Components
Manufacturer
Specifications
Minimum Operational
Requirements Pre
Fabricated from stainless
steel
Page 14: [4] Deleted arlita.privett
Changeout frequency
site-specific basis.
10/20/2010 6:18:00 AM
Stainless steel
demonstrate
detectable leaks,
poor flow rates, or
broken sections are
repaired or
replaced.
Page 15: [5] Deleted arlita.privett 10/20/2010 6:31:00 AM
Table 5-1: Description and Requirements for Monitoring and Sampling Equipment
(Continued)
Monitoring Operational
Manufacturer
Specifications
Minimum Operational
Requirements Pre'
GC Analvtical Systems: Operational Power Requirements: Exhaust is vented to
FPD
MSD
XSD
Sample inlet
Capillary column
Column
switching
system
Support gases
Integration system
Thermal
transfer system
Exhaust
Cryofocusing
Roughing pump''
Power is provided
in accordance
with
manufacturer
specifications.
Confirmation
monitor
is equipped with
UPS.'
Power board is
120 volts
altemating
current.
Room Temperature:
Between 68 and 80 F
during operational
periods
NOx Filters N/A In accordance
with
manufacturer
specifications
In accordance
with
manufacturer
specifications
The imintermptible power supply (UPS) must have brown-out protection and constant voltage output and
must operate the instmments for at least 15 minutes during a power failure.
Mass selective detector (MSD) only
Page 17: [6] Deleted arlita.privett 10/20/2010 6:32:00 AM
Table 5-2: Support Gases Equipment Requirements
Compressed Gas
Support Gases Purifiers Leak Detectors [Regulators Con
May include: Moisture and Hydrocarbon May include: Will be
Hydrogen Traps(if recommended by Simple soap solution two-stage
regulators or
equivalent Air manufacturer or vendor): Electronic leak detector
two-stage
regulators or
equivalent
Nitrogen
Helium Frequency of change-outs Utilization: Use of toxic
chemical
are: approved
Completed in
accordance
with
nianufacturer
specitlcations
;ind
requirenients
* Gas generators will be operatei.1 in accori-lance with manul'acturer specil'ications.
Section Break (Next Page)
Page 23: [7] Deleted arlita.privett 10/20/2010 3:49:00 PM
With DAAMS capability. Also Spools to AM7 and AM 7-S.
Personnel point source.
Headspace monitoring (4 hours @ 70 °F). Clearance levels are 0.2 VSL for exterior of dmms, 0.5 VSL
for chamber solid waste inside dmms, and 1.0 VSL for other (PPE) dmmmed waste.
No smoke test required; will position according to proximity to chamber opening/door. For daily entry
clearance/maintenance this station may be used with DAAMS for WPL monitoring.
Controls the release of detonation gas to synch with MC cycle. In the event of alarm, recirculation loop
automatically activates.
Personnel entry chamber clearance spooled based on chamber stams.
Upstream of process discharge.
WPL DAAMS station must be collected and analyzed on a daily basis for this station.
One MINICAMS™ spools between bed locations on each filter unit. Separate DAAMS on each location. Also has ability to
spool to post-filter location if necessary to determine if breakthrough has occurred in final stage of filter.
Spools from Post Treatment to Airlock 2.
11 These process samples are to determine if agent is being loaded onto carbon filters. Once agent is
detected, no further monitoring is required.
Page 34: [8] Deleted arlita.privett
Table 9-1. NRT Notification Matrix
Situation Notification Possible Action^
Single
NRT Alarm
• Versar EDT Site •
Manager and ECBC •
Site Supervisor
• ECBC SSHO
• EG&G Safety
Await resuh of next MINICAMS™ cycle
Evacuate non-essential oersonnel
Evaluate PPE
Analvze DAAMS tubes
Two Consecutive
MINICAMSTM
• Versar EDT Site
Manager and ECBC •
Site Supervisor •
. EG&G Safety
Office
• ECBC SSHO
Await resuh of next MINICAMS™ cycle
Evaluate PPE
Determine source of contamination
Analyze DAAMS tubes
10/20/2010 6:42:00 AM
Three Consecutive Versar EDT Site Determine source of contamination
MINIC AMSTMNR Manager and ECBC • Analyze DAAMS tubes
T Alarms Site Supervisor Relocate filtration system MINICAMS™
sample point from prefilter midbed
location to post-bed location
EG&G Safety (if alarm occurs at the prefilter and the
Office midbed
• ECBC SSHO MINICAMS™ and/or a confiimed midbed
alarm occurs)
^ This table is based on detection of chemical warfare materiel (CWM) at the alarm setpoint. Decision on actual actions taken will reside with the Versar EDT Site
Manager. Actions may vary, depending on the actual concentration of CWM detected.
Notes:
DAAMS = Depot Area Air Monitoring System
DCD = Deseret Chemical Depot
EDT = Explosive Destmction Technology
PPE = Personal Protective Equipment
Page 37: [9] Deleted michael.knudsen 10/20/2010 9:59:00 AM
Repeat ICAL if failure is for midday challenge. No action if failure is at the end of the day.
Page 37: [10] Deleted michael.knudsen 10/21/2010 9:49:00 AM
^ Distal end line challenges will be performed on a weekly basis. Acceptance limits will be 0.60 to 1.40 VSL. Method is for one-of-a-kind,
near-real-time samples. Reanalysis is not possible for QC failures.
Page 37: [11] Deleted michael.knudsen 10/20/2010 10:01:00 AM
HT - {bis[2-(2-chloroethylthio)ethyl]ether}
Page 37: [12] Deleted arlita.privett 10/20/2010 6:46:00 AM
Table 11-1. QC Requirements for lOP MT-02''
QC Sample Frequency Acceptance Limits Corrective Action
Sampling Flow Rate Measurements During calibration HD, HT: 400 ±100 mL/minAdjust and recheck before starting
calibration and analysis.
Initial Calibration (ICAL)
1 High-level Challenge (1.0 VSL)
Start of each operational day
or after failing midday
challenge
0.60 to 1.40 VSL Investigate and correct cause. Repeat
ICAL if required.
Continuing Calibration
Verification (CCV) - Also
Called Challenge
1 Low-level Challenge (0.25
VSL)*"
After every 4 to 5 hours
of operation and at the
end of operational day
Low: 0.75 to 1.25 VSL Investigate and correct cause. Repeat
ICAL if failure is for midday
challenge. No action if failure is at
the end of the day. Note on data
forms.
arlita.privett 10/20/2010 6:44:00 AM Page 37: [13] Deleted
" Operation and Maintenance Procedures for Fixed Site MINICAMS™.
^ Distal end line challenges will be performed on a weekly basis. Acceptance limits will be 0.60 to 1.40 VSL. Method is for one-of-a-kind, near-real-time samples.
Reanalysis not possible for QC failures.
Notes:
HD
HT
mL/min
=QC
STEL
= distilled sulfur mustard
= {bis[2-(2-chloroethylthio)ethyl]ether}
= milliliter per minute
= quality control
= short-term exposure limit
Page 38: [14] Deleted arlita.privett 10/20/2010 6:46:00 AM
Table 11-2. QC Requirements for lOP MT-IS"
QC Sample Frequency Acceptance Limits Corre
Sampling Flow Rate Measurements
flow
samples are one of
Before and after sample Starting and ending
Repeat sampling unless
collection rates within 10% of the a kind. If one of a
average flow rate
Five Point Initial Calibration (ICAL) When instmment
parameters change
After preparation of
new standards
R2 >0.99 Investigate and c<
ICAL.
Initial Calibration Verification (ICV) At the start of each day of
±15% Recalibrate.
analysis
After ICAL
Each target analyte
of tme value
Continuing Calibration
Verification (CCV)
At the end of a sample
mn or every 12 hours,
whichever is shorter
Each target analyte
±15% of tme value
Ifresult>115%.
recalibrate. Sam]
reported.
If result <85'
recalibrate. Ana
tube for each si
Method Blank At least one before
analyzing samples
Absence of target analytes Investigate and coi
and interferences blank to verify acc(
Quality Process (QP) - Similar
to Matrix Spike
1 each per batch of 20
or fewer samples
Recovery >10%
(Note: Agent-specific
limits are currently
under development.)
Verify spiking
second QP tube
spike and analyz
from location w
^ Analysis of Chemical Warfare Agents and Degradation Products on DAAMS Tubes using a Gas
Chromatography System Coupled with a Mass Selective Detector
Notes:
QC quality control
REVISION 1
EDT DESTRUCTION PLAN
ANNEX C
INSPECTION PLAN
November 2010
REVISIONS
1) Page C-2. p;u\igraph 7.0 re\ ised to read. "Tlie inspection tbrnis \\ ill be maintained on-site at
the EDT for re\ iew access."
2) Table C-1. page C-3. item 1(c). .Add: "and inspect inner lid liner for e\idence of physical
diiniage such as cracks, gouges, and dimples, beyond e.\pected depth"
3) Table C-1. Note added to Table C-1: items 11. 12. 13. 14. 15. and 16 are intemal inspections
and not part ofthe pennit requirements. Tliese lia\e been included to ensure safe operations".
4) Table C-1. item 31. Table C-1 niodiHed to clarify that the 3.\ per week inspections are o\er
and abo\e the daily calibration challenges. .Added clariUcation at the end ofthe last sentence in
the last block of item 31: "records. (Regular MINICAMS challenges are not part of this
inspection)."
5) Page C-2. Section 7.0. added "The fomis will be re\ iewed and appro\ed prior to use".
EDT Destruction Plan
.Anne.\ C
Inspection Plan
TABLE OF CONTENTS
TABLE OF C ONTENTS C -i
LIST OF TABLES C-i
1.0 INTRODICTION C-1
2.0 GENERAL INSPEC TION REQI IREMENTS C -1
3.0 SCOPE C-1
4.0 TYPES OF PROBLEMS TO BE IDENTIFIED C -2
5.0 FREQI ENCA OF INSPEC TION C -2
6.0 CORRECTI\ FACTIONS C-2
7.0 INSPEC TION FORMS AND INSPEC TION DOC I'MENTATION C -2
LIST OF TABLES
Table C -1. Inspection Items for the TOOELE DAMNC H EDT C -3
C-i
EDT Destmction Plan
Annex C
Inspection Plan
1.0 INTRODUCTION
The Detonation of Ammunition in a Vacuum Integrated Chamber (DAVINCH™) Explosive
Destmction Technology (EDT) treatment operation at Tooele Chemical Agent Destmction
Facility (TOCDF) will be permitted by a TOCDF Resource Conservation and Recovery Act
(RCRA) Permit modification issued by the State of Utah Division of Solid and Hazardous Waste
(DSHW). This EDT Inspection Plan has been prepared to meet the inspection requirements for
RCRA Permit Subpart X, Treatment Units.
2.0 GENERAL INSPECTION REQUIREMENTS
The EDT site will be inspected according to a prescribed inspection schedule designed to detect
equipment deterioration and prevent potential equipment malfunctions that could cause a release
of hazardous wastes or otherwise pose a threat to human health and the environment. The
inspection schedule document and inspection logs will be located in the EDT Control Room (at
the EDT site). At a minimum, the inspection program will include inspections of the equipment
items listed in Table C-1. Various forms are necessary to address the inspections required.
3.0 SCOPE
This inspection plan addresses the RCRA requirement for Subpart X Treatment Units to conduct
periodic inspections. The inspection criteria is based on good industrial practices of operation.
Items to be inspected include:
• EDT Chamber and components;
• Off-gas treatment system;
• Environmental Enclosure (EE) and the Heating, Ventilating, and Air Conditioning (HVAC)
system;
• Air monitoring equipment;
• Less-than-90-day waste storage areas;
• EDT loading/unloading areas;
• Processing areas;
• Fire protection, safety equipment (to include but not limited to spill kits, shovels, brooms,
portable decon sprayers, and eye washes);
• Communication items and equipment;
C-1
EDT Destmction Plan
Annex C
Inspection Plan
• Security fencing and signs; and
• Emergency backup power.
4.0 TYPES OF PROBLEMS TO BE IDENTIFIED
The types of problems that may be identified during inspections are listed in Table C-1 (below).
5.0 FREQUENCY OF INSPECTION
The inspections listed in Table C-1 will be conducted at the specified frequency to identify and
correct problems before they cause harm to human health or the environment. Inspection
frequencies of individual items may vary, but are based upon the rate of possible deterioration of
the equipment and the probability of an environmental or human health incident if a problem
remains undetected during inspection.
6.0 CORRECTIVE ACTIONS
Corrective actions are measures taken to address and resolve any issues discovered during
inspection to prevent a malfimction or deteriorated/defective equipment from potentially causing
a release of hazardous materials or otherwise posing a threat to human health and the
environment. Corrective actions may include necessary repairs or further investigation of
potential problems. All corrective actions are recorded and described on the inspection forms;
these forms are dated and signed by the inspector, who also follows up on the corrective actions
to ensure implementation and success
7.0 INSPECTION FORMS AND INSPECTION DOCUMENTATION
The inspection forms will be maintained on-site at the EDT for review access.
C-2
EDT Destruction Plan
.Anne.\ C
Inspection Plan
Table C -1. Inspection Items for TOOELE DAMNC H EDT
Item Number Item Description Inspection Frequency Types of Problems
(Inspection Criteri;i)
Detonation Chamber ani.1 Interior Ei.|uipment
1(a) Main Chamber (!)uter Shell Daily
when in use
Msually inspect e.\terior inclutling tubing,
hoses, ani.1 \ al\es lor e\ii.lence ofcorrosion
ani.1 leakage: this inclutles other physical
i-lamage such as tears, stresses, gouges,
i-limples. rips, cracks, ani.1 fasteners.
1(b) Main Chamber Inner Liner Daily
when in use
Msually inspect interior for e\ ii.lence of
physical i.Lamage such as cracks, gouges.
ani.1 i-limples. beyoni.1 e.\pectei.l tlepth
1(c) Main Chamber Lii.1 Daily
when in use
Coni-luct inspection ani.1 cleaning of sealing
surfaces, .n-^.i m |-.'. I mn>-¥ lul ini-T I - .r
2 Pass-through lor Detonation Daily
when in use
Coni-luct high-potential test through open
\ essel i.loor: coni.luct continuity check of
feei.l-through ani.1 tletonator terminal blocks
for proper functioning.
(!)IT-Gas Treatment Systems
EDT (!)IT-Gas Treatment Container
Unit A
Daily
when in use
Msually inspect for e\ ii.lence of corrosion,
leakage, or other physical i.lamage such as
cracks, gaps, or holes.
4 EDT Process \'entilation
Unit B
Daily
when in use
Msually inspect for e\ ii.lence of corrosion,
leakage, or other physical i.lamage such as
cracks, gaps, or holes.
EDT Process \'entilation
UnitsCl and C2
Daily
when in use
Msually inspect for e\ ii.lence of corrosion,
leakage, or other physical i.lamage such as
cracks, gaps, or holes.
6 EDT (!)IT-Gas Treatment Container
Unit D Daily Msually inspect for e\ ii.lence of corrosion,
leakage, or other physical i.lamage such as
C-3
EDT Destmction Plan
Annex C
Inspection Plan
Item Number Item Description Inspection Frequency Types of Problems
(Inspection Criteria)
when ni use cracks, gaps, or holes.
Ventilation System
7(a) Carbon Filter Unit El Daily
Visually inspect for evidence of corrosion,
leakage, or other physical damage such as
cracks, gaps, or holes.
7(b) Carbon Filter Unit E2 Daily
Visually inspect for evidence of corrosion,
leakage, or other physical damage such as
cracks, gaps, or holes.
7(c) Carbon Filter Unit E3 Daily
Visually inspect for evidence of corrosion,
leakage, or other physical damage such as
cracks, gaps, or holes.
8 Ventilation Blower/HVAC Blower Daily
Visually inspect for any evidence of
malfunction, blockage, or maintenance
issues.
9 Stack Daily Visually inspect for any evidence of
malfunction.
Unpack Area (UPA)
10 Unpack Area Daily Inspect for evidence of spills, leakage, or
damage to area.
i_
Preparation Area
-I
T T T
T »
T » • T
Utilities
T J
Deleted:
;
Deleted:
M210
Deleted:
/'(
I'l'
r
Deleted:
comiection
I'l'
,1/'
I'l'
Deleted: I'l'
,1/'
I'l'
Deleted:
M141
Deleted:
fi'i'i
I'l'i'i
i'l' I'l'
Deleted:
comiection
iVi'i' Deleted:
Deleted:
M130
/^'|" Deleted: /^'|"
Deleted:
comiection
S|i|i|'i' /
i Ih'i 1
Deleted:
S|i|i|'i' /
i Ih'i 1 Deleted:
MHO
Deleted:
ft'/'
hi' i' 1' ''''I','
Deleted:
comiection
1 '
r /'' ' '
1'!' //
Deleted: 1 '
r /'' ' '
1'!' //
Deleted:
M170
i I ,
f'///
Deleted: i I ,
f'/// Deleted:
comiection
Deleted:
Deleted:
Unit F
Deleted:
Deleted:
C-4
EDT Destmction Plan
Annex C
Inspection Plan
Item Number Item Description Inspection Frequency Types of Problems
(Inspection Criteria)
17 Generators Weekly
Inspect for spills, proper operation,
electrical output, fuel consumption
abnormalities
18 UPS Weekly
Check for battery life and indicators,
correct voltage; check for leaks/corrosion
in battery area.
Communications
19 Link to TOCDF Control Room Daily Ensure link working to TODCF Control
Room.
20 PA Daily Test PA.
21 Alarm Panels Weekly Check function of alarms.
22 Alarm Horns Weekly Check function of homs.
23 CCTV Weekly Check for operability, visual clarity; pan
and zoom if applicable.
24 Radios/Cell Phones Daily Check for operability.
Security
26 Fences Weekly Check for integrity, obstmction, gaps.
27 Lighting Weekly Check for operability.
28 Waming Signs Weekly Check for presence and legibility.
Fire Protection/Safety Equipment
28 Fire Extinguishers Weekly Check pressure, general condition, and
service date.
29 Personnel Decontamination Station Weekly Check for availability of decon solution,
access, and operability.
30
Spill Kits
Fire Extinauishers
Safetv Equipment
Weekly
Check for inventory, condition, and
expiration dates.
C-5
EDT Destruction Plan
•Annex C
Inspection Plan
Item Number Item Description Inspection Frequency Types of Problems
(Inspection Criteri;i)
•Air Monitoring
31 Chemical .Agent Monitors
(MINK^AMST^'. DA.AMS) 3x AVeek
Msual inspection for integrity, tliagnostic
ini-licator check, sample lines ani.1
connections, heat traces, \ entilation for
e.Khaust. ani.1 calibration i h.:jui.fi
En\ ironmental Enclosure Weekly Check for breaches, weatheri-lamage.
leakage, ani.1 air monitoring integrity
C-6
Page 4: [1] Deleted drew papadakis 11/2/2010 11:41:00 AM
Inspect for damage, labeling, potential damage, proper stowage of gas cylinders.
REVISION 1
EDT DESTRUCTION PLAN
ANNEX E - CLOSURE PLAN
November 2010
REVISIONS
1) Annex E, page E-4, first paragraph after the bullet.
2) Page E-5, Change sentence to read: "Once the EDT unit is certified clean-closed to 1
VSL';^
3) Changes 1.2. Closure Strategy, last paragraph, to read as follows^
FormaUed: Font color: Auto
Formatted: Font color: Auto
Formatted; Bullets and Numbering
Formatted: Indent: Left: 18 pt
Formatted: Indent: Left
Formatted: Indent: Left
36 pt
54 pt,
Tabs: 72 pt, List tab + Not at 54 pt
Tenting and/or closing areas off and conducting head space nionitoruig using
MINICAMS to 1 VSL for HD for two successive MINICAMS cvcles.
1) Disassembling components ofthe chamber and chamber door, decontaminating •
components (e.g.. 0-ring. blast shield, and covers), and manuallv
cleaning/decontaminating these components if headspace monitoring is identified.
2) Conducting "cleansing shots" which are explosive detonations without munitions
to clean the interior ofthe chamber, and use the detonation process to remove any
contaminants.
Formatted: Bullets and Numbering
Deleted: Aiuiex E, page E-5, first
complete paragraph on the page and page
E-10, first paragraph following the bullet
list, top of page E-11, second paragraph
on page E-12. These paragraphs mention
wipe sampling as a means to determine if
decontamination has been adequate. See
Comment 1 regarding this subject.
31
4)
Clearing sample and drain lines.
Cleaning contact surfaces (electrical panels, debris pan, spill containment trays,
railings, and other operator-contacted surfaces).
4) ^Wipe sampling has been deleted from the approach^
Formatted: Bullets and Numbering
Deleted: Annex E, page E-5, Table E-1.
The value, 0.003 mg/m', shown in tlie
table as the air monitoring perfonnance
standard is not an eight-hour TWA as
stated in the table. Uiis value is actually
the STEL, wliich is a 15-minute exposure
limit.
Formatted: Bullets and Numbering
6) Annex E, page E-6, Table E-2. ,"equal" between "to" and "equilibrium" Jias been
changed^to "reach/'_ _
7) Annex E, page E-8, last paragraph, .^dd "and a qualified Professional Engineer wih
certify closure". ^ _
Deleted: <#>Annex E. Tlie closure
plan should specify the 10 step process as
specified in the CAMDS closure
procedures. Please review the current
CAMDS closure plan to ensure tliat
closure ofthe DAVINCH follows a
similar process. Wipe sampling for
verification of decontamination will not
be accepted. An approved
decontamination plan will need to be
used to acconq^hsh closm e of the unit^
\ \\ 1 Deleted: In tlie fnst row in the
Deleted: should be
Deleted:
Deleted: t
<#>Annex E, page E-6, Table E-3. The
SOPs and lOPs listed in the Analytical
Methods colimin of tliis table should be
submitted for review and approval as part
of the documents listed on page 36 ofthe
Explosive Destruction Technology (EDT)
Destruction Plan.^
Formatted: Bullets and Numbering
Deleted: Tliis paragraph states that the
Versar EDT Program Manager will
certify closure. This should state that tlie
Versar EDT Program Manager
Deleted: Additionally, EG&G and
[ Versar should be aware that they n ... ["!]
Deleted: <#>Annex E, Appendix E-1
does not discuss the sanyling proc \^ ['2]
TABLE OF CONTENTS
T.\BLE: OF CONTENTS E i
LIST OF FIGURES E ii
LIST OF T.\BLES E ii
LIST OF .\PPENDICES E ii
1.0 INTRODUCTION El
1.1 GEMER_\L DESCTilPTION E-1
1.2 CLOS^lRESTRATEC^ E-1
2.0 CLOSURE PERFORM\NCE ST.\ND.\RDS E 5
3.0 DISPOS.\LOR DECONT.\MIN.\TION OF EQUIPMENT. STRUCTURE. .\ND \\.\STE E "
4.0 CLOSURE SCHEDULE OF .\CTI\ ITIES E "
5.0 CONFIRM\TION .\CTI\ IT^ E 8
E-i
List of Figures
Fieure E-1. Overv iew of Closure Slraleev for D.AMNCH'r^' EDT E-3
List ofTiibles
Table E-1. Closure Standards for D.A\TNCH'r^' EDT E->
Table E-2. .Air Monitoring Sampling Rei.|uirements E-6
Table E-3. Sampling ani.1 .Analysis Methotls E-6
Table E-4. Closure Schetlule (!)\ er\ ie\v E-7
List of Appendices
.APPENDIX E-1. EDT S.AMPLFNG PROCEDirRES E-9
E-i
1.0 INTRODUCTION
This Closure Strategy describes performance standards and procedures to clean-close the
DAVINCIF'^ Explosive Detonation Technology (EDT) for reuse. This plan presents methods
to identify contaminated system equipment; decontaminate contaminated system equipment;
dispose of all wastes and contaminated materials; perform verification sampling to confirm
successful decontamination; and certify closure.
After the system operations are completed, the DAVINCH'^'^ will be transported to a storage
facility at a Govemment site where qualified plant workers using appropriate procedures will
operate the system. The DAVINCH'^'^ will remain under Government control (expected to be
the Edgewood Chemical Biological Center in Edgewood, Maryland); therefore, the standard for
decontamination of the equipment for removal is "3X" or VSL for HP. ,- \ Deleted: i VSL for HD~
1.1 General Description
The EDT will be located in Area 10 at DCD. It will be used to destroy overpacked chemical
munitions and various samples from the Deseret Chemical Depot (DCD) Chemical Stockpile.
Operational waste will be handled in accordance with the TOCDF Waste Management Plan and
Chapter 3.11 of the Destmction Plan.
1.2 Closure Strategy
Figure E-1 presents the general process for ensuring that the EDT site is closed in accordance
with applicable standards. The EDT and associated equipment addressed in this strategy
includes the DAVINCH™ main chamber, the off-gas treatment systems, the Environmental
Enclosure (EE), and associated equipment that may have been in contact with chemical agent
(CA) as determined by agent monitoring results and a review of DAVINCH™ operational
history. No hazardous waste residue will remain on the EDT site after closure.
Per Utah R315-8-7, Closure and Post-Closure (that incorporates by reference 40 CFR 264.111),
an owner or operator must close a permitted hazardous waste management unit in a manner that
minimizes the need for further maintenance and controls; minimizes or eliminates, to the extent
necessary to protect human health and the environment, post-closure escape of hazardous waste,
hazardous constiments, leachate, contaminated mn-off, or hazardous waste decomposition
products to the groundwater, surface waters, or the atmosphere.
All EDT operations are performed in a manner designed to control and eliminate the escape of
hazardous waste and hazardous constituents into the environment. The EDT operations at
TODCF will take place inside an EE comprised of a ceiling, sides, and flooring that will protect
the hazardous waste management unit from precipitation and mn-on as well as prevent the
creation of any contaminated mnoff Engineering and administrative controls are in place to
control, minimize, or eliminate the possibility of contamination to groundwater, surface waters,
or the atmosphere from EDT operations; they include:
• An air filtration system with carbon filtration;
E-1
Trained explosive handling and chemical operators in appropriate Personal Protective
Equipment (PPE);
Approved work procedures; and
Prohibition of open flames, cutting, welding, smoking, and radiant heat inside the EE.
E-2
Assess EDT
Equipment'
Decontaminate
Equipment with
ECAD, Cleansing
Shot, Hot Soapy
Water
Clean
Closure
Achieved"'
Determined through air monitoring, surface wipes, sampling, operational log review.
Air monitoring via MINICAMST" and DAAMS, and analysis of surface wipes/samples.
Rinse water will be samples and analyzed. Results compared to closure standards (See Table E-1).
EDT or component can be removed from EE and removed from site
Figure E-1. Oven iew ofClosure Str:iteg> for DA\ INCFF" EDT
E-3
Decontamination procedures involve:
• Tenting and/or closing areas off and conducting head space monitoring using MINICAMS to
1 VSL for HD for two successive MINICAMS cycles.
5) disassembling components ofthe chamber and chamber door, decontaminating
components (e.g., 0-ring, blast shield, and covers), and manually
cleaning/decontaminating these components if headspace monitoring is identified.
6} Conducting "cleansing shots" which are explosive detonations without munitions to
clean the interior ofthe chamber, and use the detonation process to remove any
contaminants.
7) Clearing sample and drain lines.
8) Cleaning contact surfaces (electrical panels, debris pan, spill containment trays,
railings, and other operator-contacted surfaces).
• Monitoring, and if necessary, cleaning the EE.
• Collecting disposable components (i.e., plastic film shielding and other items considered
consumable/not reusable), and placing them in waste containers for disposal.
• Performing air monitoring, sampling, and pertinent assessments to confirm that the standards
for removal are met; these assessments include, but are not lunited to, rinsate sampling, filter
media sampling, visual assessment of system condition to ensure that no visible residue
remains m the chamber or piping. re\ae\\' of monitoring records to detennine potential for
system intemal contamination and headspace monitoring.
• Reassembling and packing the EDT and subsystems for shipment off-site.
Cleaning/decontaminating solutions may include hot soapy water/general detergent or other
appropriate decontaminant; technique is referenced in United States (U.S.) Army Field Manual
(FM) 3-5 or identified in Table 1, Alternative Treatment Standards for Hazardous Debris (40
CFR 268.45). The U.S. Environmental Protection Agency (EPA) recommends and approves the
use of the Table 1 alternate treatment standards for Resource Conservation and Recovery Act
(RCRA) closure purposes. For example, sodium hypochlorite (NaOCl), a standard
decontaminant for chemical agent, is identified as a suitable decontaminant under the chemical
destmction technology category. The decontamination/cleaning solutions are generally applied
manually with a spray device or by wiping down with cloth or paper towels and wipes.
Prior to initiating closure and verification activities to confirm successful EDT decontamination,
the previously-described decontamination procedures will have been conducted and air
monitoring results recorded; and all EDT process and cleaning wastes collected, containerized,
and removed from the EE. Wastes will be properly characterized as outlined in the Waste
Management Plan (Section 3.11 ofthe EDT Destmction Plan) and temporarily stored in a less-
than-90-day waste storage area pending shipment off-site for further treatment or disposal.
Air monitoring results will be compared to the closure performance standards listed in Table E-1.
If results do not meet the closure performance standards, then decontamination will be repeated
until the closure performance standards are met. The sampling method, EDT components, and
areas for de-ionized water rinsate sampling, if necessary, are identified in Appendix E-1.
Monitoring results will be compared against the closure performance standard values listed in
Table E-1; if monitoring analytical results do not meet the closure performance standards in
Deleted: <#>If MINICAMS readings
exceed 1.0 VSL, then decontamination
actions are executed including, but not
limited to tlie following: %
<#>Pei"forming decontamination ofthe
chamber and chamber door tlirough
Electrostatically Charged Aerosol
Decontamination (ECAD), which uses a
proprietary method of applying
decontamination fluids to tlie chamber
and its ulterior passages. Tlie ECAD uses
a statically charged particle generator to
ensuie that decon solution adheres to the
imier surface of the chamber and the
imier liiier(s) for the chamber and lids. H
Formatted: Bullets and Numbering
E-4
Table E-1, equipment will be decontaminated until they are met.
The EDT will be deemed clean-closed when air monitoring, and if necessary, liquid sampling
results meet the closure performance standards identified in Table E-1.
The EE air filtration system will continue to operate and monitoring conducted until air
monitoring and rinse water sample results are received. The EE will be decontaminated to the
1.0 VSL level for retum to ECBC.
Once the EDT unit is certified clean-closed to 1.0 VSL, the EDT and EE will be demobilized.
Demobilization will involve packing and removing the EDT equipment from the enclosure and
then dismantling the enclosure. If, during demobilization, equipment or areas are discovered to
be still contaminated, these areas/equipment will be decontaminated and decontamination
verified as previously described.
The types of wastes expected to be generated from closure activities include spent
decontamination solutions/rinse waters; used PPE; and wipes, rags, and other absorbent and
cleaning materials used to conduct decontamination. If the carbon filters from the air filtration
system cannot be reused, they will be removed and managed as State of Utah waste code P999
hazardous waste. Rinse waters will be managed as State of Utah waste code F999.
Table E-1. Closure Standards for DAVINCIFM EDT
Media and Parameter Performance Standard
Equipment - Mustard (HD/HT) US ARMY 3X -1 VSL headspace air monitoring
Liquid Waste - Mustard (HD/HT) 200 ppb
2.0 CLOSURE PERFORMANCE STANDARDS
Clean-closure ofthe EDT unit and associated equipment will be deemed complete when air
monitoring and rinsewater sampling results meet the closure performance standards identified in
Table E-1, for movement to a government facility. Air will be monitored for specific periods as
detailed in Table E- 2.
Closure performance standards for air monitoring of chemical agents are based on headspace
vapor sampling and analysis and are established as the "3X" level, or screening to 1 VSL.
Sampling conducted to determine decontamination and clean-closure is summarized in Table E-3.
E-5
Table E-2. Air Monitoring Sampling Requirements
Item Sampling Conditions
Equipment
Isolate potentially contaminated equipment by
enclosing in plastic and allowing headspace in the
enclosure to.jeach equilibrium for 4 hours at or Equipment
above 70°F before monitoring.
Fixed Equipment 4 hours at or above 70°F before monitoring
Portable Equipment 4 horns at or above 70°F before monitoring
®
After the conditions listed in this table are established, MINICAMS or Depot Area Air Monitoring System
(DAAMS) samples will be collected. MINICAMS alanns will be confinned using DAAMS. If results meet
closure perft)nnance standards in Table E-1, the stmcture or equipment is considered "clean-closed".
Deleted: equal
Table E-3. Sampling and Analysis Methods'
Sample Source
Headspace Gas
Sample of EE
and EDT
Equipment
Rinse Waters
Number of
Samples
Two sampling
cycles for
each
equipment or
space
Two
Sampling
Method/
Equipment^
Low-level air
monitor/using
MINICAMS™
or DAAMS
Grab
Analytical
Parameters
Chemical
Agents
Chemical
Agents
Analytical Method
j:DT-TOCDF:
PROO^-ECBC lOP
MT-11 D.\_\MS
TUBE
MONITORMG
EDT-TOCDF-
PR008 MINICAM
EDT-TOCDF-PR-
022. ANALYSIS
OF CWM ON
DAAMS.
^DT-TOpCF-PROl 6-_ _
K:BC.IOPMTrOS- "
ANALYSIS PLAN AND
ANALYSIS SOP.
Sample
Holding
Time
N/A
N/A
Formatted: Font: 9 pt
Formatted: Bullets and Numbering
Formatted: Font: 9 pt
Deleted: ECBC lOP MT-02
(MINICAMS), MT-11 (DAAMS), and
MT-13 (GC/MS)
Formatted: Font: 9 pt, Not Bold
Mobile laboratoiy will perfonn confirmation agent analysis for all wastes, using state-approved
analytical methods.
^ DAAMS will be used to confirm MINICAMS™ alann. Mustard, HT will be measured. HT will be
measmed as HD.
^ SPS/IOP's are Internal Operating Piocedures from Edgewood Chemical Biological Center and adopted for
EDT. Copies will be provided prior to initiation of operations.
Deleted: ECBC SOP Number CNG-
044 lOP MT-8
Formatted: Font: 9 pt
E-6
Upon closure ol'lhe EDT unit ani.1 associalei.1 ei.|uipmenl. there will be no hazartlous wastes or
hazari-lous waste constituents, inclutling i-lecontamination wastes, remaining. Prior to beginning
closure, all irealmenl resitlues ani.1 relalei.1 wastes will be remo\ ei.l iVom the EDT site. .All wastes
generalei.1 (.luring closure acli\ ilies. such as spent i-leconlaminalion solutions ani.1 rinse waters,
will be conlainerizei.1. samplei.1. analyzei.1. characlerizei.1. ani.1 managei.1 appropriately, basei.1 on
waste classiUcalion ani.1 in accori-lance with applicable regulatory rei.|uiremenls.
Spent i-leconlam inalion solutions ani.1 rinse waters will be managei.1 as F999 hazartlous waste.
Closure wastes will be placei.1 in a less-lhan-9()-i.lay waste storage area pentling shipment to a
pemiilled TSDF.
During closure acli\ ilies. personnel will use appropriate personal prolecli\ e clothing ani.1
ei.|uipmenl as i.lelenn inei.1 by the EDT Site Salely ani.1 Health (!)lTicer. In general. Department ol"
the .Army Pamphlet (D.A Pam) 3S5-61. Toxic Chemical.-igenl Sajet}- Standards, will be Ibllowei-I.
as well as (!)ccupalional Safely ani.1 Health .Ai.lminislralion ((!)SH.A) safely slani.lan.ls.
3.0 DISPOSAL OR DECONTAMINATION OF EQllPMENT, STRI CTI^RE, AND
\\ ASTE
Soil remo\ al shouki not be necessary (.luring closure because the EDT operations are enclosei.1
(the enclosure consists of ceiling, sitles. grouni.1 co\ er. ani.1 llooring) ani.1 coni.luclei.1 on a closei.1-
olT-gas irealmenl system with secontLaty containment. .Any incitlenls in\ ol\ mg chemical agent
release or hazartlous waste (.luring operations wouki be manage(.l un(.ler Emergency Response an(.l
Contingency .Actions. oulline(.l in the site-specific SSSP.
4.0 CLOSIRRE SCHEDULE OF ACTIMTIES
Table E-4 presents the notional sche(.lule of closure actions by (.lay
Table E-4. Closure Schedule 0\en lew
lleiii Da> Coiiipleled
liuiiiiie Cio-^iire .\cii\iiie-; Dm n
Coinliici Decoiiiiuiu Mill ion Dii\ ^
()\er-^2lii iuni Re\ievv Dm
Piick EDT eiiiu|)iiieiii Dii\ 6
EG.tG Reiiio\iiJ iiil vvii-;ie iVoiii EDT Siie Dii\ S
Coiii|)leie Cio-^iire Dii\ Ml
E-7
5.0 CONFIRMATION ACTIVITY
The Versar© Program Manager, EDT, will ensure that confirmation activities have been
accomplished. These activities inclu(ie confirming that:
• Spills, releases, and cleanup activities were noted and evaluating them.
• The EDT procedures for closeout (servicing, cleaning/decontaminating, and preparing the
EDT and associated equipment for reuse and demobilization) were followed.
• The EDT was air monitored to verify adequacy of cleaning/decontamination.
• Air monitoring results were documented and the recorded values met the closure
performance standards.
• Decon rinsate and anv de-ionized water rinsate sampling results met the closure performance j Deleted: oe-ionized water rinsate
QtnnflnrH« sampling and analysis were conducted SldnUdrus. according to procedure, t
• Wastes generated from closure activities were transferred to a less-than-90-day waste storage ^
area pending shipment off-site.
When the closure performance standards for air monitoring and decon rinsate sampling have
been met, the Versar© EDT Program Manager will certify in writing that the EDT was clean-
closed in accordance with the approved closure strategy and all applicable regulations. A
licensed UT Professional Engineer will review and sign the closure certification. This
certification shall be provided to EG&G for further submittal to TOCDF, DCD, and the Utah
DEQ as required.
Additionally, all activity will be consistent and comply with Permit Condition II.J.7. regarding
notification of closure.
E-8
APPENDIX E-1.
EDT S AMPLING PROCEDIRRES
E-9
APPENDIX E-1
EDT SAMPLING PROCEDURES
Purpose:
Sampling will be conducted to validate clean-closure of the EDT and associated equipment in
accordance with this procedure.
Objectives:
Headspace monitoring will be conducted to determine the 1.0 VSL screening limit for the
following equipment:
• EDT Main chamber inside walls;
• EDT Main chamber door/lid;
• Hose and lines;
• Personnel decontamination station;
• Mobile Laboratory;
• Monitoring Enclosure; and
• EE.
Any areas that require additional decontamination will be treated with rinsate/decon solution.
Once the decon /insate samples have been collected from the previously-listed EDT
components/areas, the rinsate wastes can be commingled into a single container for easier
management. If required, the Operating Subcontractor (Le..jVersar) wilL^P^ggt^^^, _
characterization sample(s) from the rinsate waste container once the container has been
transferred to the less-than-90-day waste storage area. ,
Target Analytes:
Target analytes are listed in Table E-1 (i.e.. Mustard [H/HD/HT).
Laboratories:
Utah-certified chemical laboratory, on-site laboratory, and surety laboratory as required.
Participants:
EDT operators and subcontractor (Versar) personnel.
Observers:
Versar Chemical Safety Manager.
Formatted: Underline, Font color:
Red
Deleted: C
Deleted: URS
Deleted: Additional wipe samples may
be used in the chamber interior.
E-10
Sampling Method:
MINICAMS headspace monitoring
PPE:
Level D.
Decontamination/Rinse Equipment:
Garden-type plastic sprayers (2);
Squeeze bottles (polyethylene) (4);
2- gallons of deionized water;
Plastic film and catch basins to catch and transfer rinsates;
Paper towels;
Waste containers;
5-gallon pails; and
ECAD spray device.
Sample Prep and Shipment:
1-liter sample bottles (24 bottles);
Sample labels;
Floor and wall squeegee;
Chain(s) of custody forms;
Clear packing tape for positive closure of sample jars;
Sample coolers approved for Department of Transportation (DOT) shipment;
Ice for sample preservation;
Plastic "bubble wrap" for packaging samples in coolers;
Adequate rubber bands to secure bubble wrap around sample jars;
DOT Labels (if required) and address labels for shipping coolers (if required);
Box tape;
Razor knife; and
Shipping labels, and shipment or pickup by an appropriate ovemight carrier (if required).
Sampling Procedures:
Inner Chamber
The inner chamber will be tented using visqueen. The chamber will be allowed to stabilize for 4
hours at 70 degrees F. Two consecutive MINICAMS readings will be taken to determine if the
inner chamber is contaminated above the 1.0 VSL screening limit. If the interior of the chamber
is deemed contaminated, additional decon will take place based on the procedures in the closure
plan.
E-U
Chamber Lid/Door
Containment/Floor Area/Mobile Laboratory/Monitoring Enclosure
The mam area ofthe enclosure will be sealed off and the H\'AC shut down. The enckisure will
be allowed to stabilize for 4 hours at 70 degrees F. Two consecutive MINICAMS readings will
be taken in the interior ofthe enclosure to detemiine if the area contains residual agent, or is
contaminated above the 1.0 VSL screening limit. If the enclosure is deemed contaminated,
additional decon will take place based on the procedures in the closure plan.
T
Waste Processing Area
The waste processing area will be sealed off and the HVAC shut down. The enclosure will be
allowed to stabilize for 4 hours at 70 degrees T. Two consecutn'e MINICAMS readings will be
taken in the interior ofthe enclosure to determine if the area contains residual agent, or is
contaminated above the 1.0 VSL screening limit. If the waste processing area is deemed
contaminated, additional decon will take place based on the procedures in the closure plan.
T
Sampling Lines
An EDT technician will use a garden sprayer or other spray source (e.g., a squirt bottle) filled
with de-ionized water to spray into sampling lines, allowing water to pass through the lines and
be collected into a plastic catch pan at the opposite end. Sampling personnel will collect the
samples from the plastic catch pan, and remaining rinsate will be placed into the designated
rinsate waste container.
Waste Management and RCRA Characterization
All excess rinsates will be placed in a DOT-approved container (possibly a 5-gallon plastic,
closed-top pail for liquids). The container will be labeled as hazardous waste pending RCRA
characterization. The waste container will be transferred to Operating Subgontractqrj?ery>nnel
for management.
' Deleted: One EDT samphng teclmician
will place a clean plastic pan on tlie floor
in a position to allow capture of spray
water beneath the lid/door. The
teclmician will then proceed to use the
de-ionized water-filled garden sprayer to
rinse all areas on tlie inner side ofthe
lid/door. The rinsate produced will be
captured in the plastic catch pan.
Spraying will continue until the entire
area has been sprayed. Sampling
personnel will collect the samples fiom
the plastic catch pan. Remaining rinsate
will be placed into the designated rinsate
waste container. ^
Deleted: An operator will spray over
the entire contaimiient area: floor, bottom,
and sides. Spray activity will continue
until the entire floor ofthe containment
pan has been sprayed. The second
teclmician will collect the containment
rinsate using a squeegee and place it in a
plastic pan of an adequate size to hold the
rinsate generated from at least one pass
across the containment area. Sampling
personnel will collect the samples from
the plastic catch pan, and remaining
rinsate wiU be placed into the designated
rinsate waste container. One wipe sample
per 100 fp will be taken from tlie interior
of tlie EE. K
Deleted: Tlie dmm area, including the
spill control pallets, will be sampled. Tlie
spill pallet will be elevated and laid on its
side in a maimer that will allow the
placement of a plastic catch pan
undemeatli the opening of a pallet to
catch the rinsate as it exits the pallet.
Sampling personnel will collect the
samples from the plastic catch pan.
Remaining rinsate will be placed into the
designated rinsate waste container. ^
Deleted: C
E-12
Page 2: [1] Deleted PKendall 10/6/2010 7:00:00 PM
Additionally, EG&G and Versar should be aware that they must comply with Permit
Condition II.J.7. regarding notification of closure.
Page 2: [2] Deleted PKendall 10/6/2010 6:59:00 PM
Annex E, Appendix E-1 does not discuss the sampling procedures to be used to verify
decontamination of the exhaust gas treatment equipment. The procedure lists
several methods for sample collection, catch/grab and wipes but does not specify
anywhere in the procedure where they are used. More detail is needed.
REVISION 1
EDT DESTRUCTION PLAN
ANNEXE
TOCDF EDT EMERGENCY RESPONSE PLAN
November 2010
REMSIONS
1) Paee F-:. Table F-1. Chanee "TOCDF" to "DCD". .Added to last line of Table F-1
Noli Ik'iiiioii ol'i )ilier
FiiL'iliiie-; BiiUiliiis-; iii E\eiii ol'
Eiiier2eik'\
T( )DCF Coiiirol Room
The TOCDF Coiiirol Room -liiiJI lie
re-;|)oii-;il>le I'or iioii l\ iiig oilier
I'iiL'Uii ie-; biiUiUiis-; ol'EDT
eiiiergeik'ie-;. lo iiiclmle. l>iii iioi l>e
Uiiuieilio. .AiilOL-liive. D\ SD\ SSR
iuiil .ATL IC |)er-;oiuiel
2) Page F-2. Table F-1. Corrected spelling of "TOCDF" in Table F-1.
3) Page F-2. the last sentence changei.1 to reai.1: "Use ol"controllei.1 access ( i.e.. the personnel
i-lecontamination station airlock to the en\ ironmental enclosure must be passei.1 through by
personnel as they enter)".
4) The thiri-l ani.1 I'ourth paragraphs untler 1.1.2: Change "T(!)CDF" to "DCD"
The last bullet untler 1.1.3.1 re\ isei.l to reai.1. "Placing absorbei.1 or pumpei.1 material into DOJ-
appro\ ei.l containers ani.1 managing appropriately in accon.lance with all applicable pemiits ani.1
rules."
6) Page F-4. ai.klei.1 to bullet: "inclutling use ol"appro\ei.l i-lecontamination methotls. inclutling
use ol'i-lecontamination solutions, ani.1 post-tlecontamination monitoring \ ia NITNIC.AMS to the
1.0 \"SL level, at l.o \"SL"
7) Page F-.^. ai.klei.1 this phrase to the the last paragraph on this page - "metlical emergencies
in\ ol\ ing" to clarily that metlical emergencies may in\ ol\ e chemical agent."
S) Page F-6 ani.1 F-7. Sections 1.1.3.Sani.l 1.1.3.9. .Ai.klei.1 this paragraph to Section I.I.3.S. .Any
munitions in o\ erpacks that are on site in the e\ ent ol'an e\ acuation or work stoppage ol"
operations tlue to se\ ere weather contlitions will be securei.1 in the enclosure. I fcN acuation is not
callei.1 for. then CPRP members will monitor the status ofthe munitions. If munitions o\erpacks
are set up with e.\plosi\ es ani.1 not yet placei.1 in the chamber, the e.\plosi\ es operator will
remo\ e any tletonators ani.1 rentier the item safe before e\ acuation. or. (.luring se\ ere weather. If
the munition ON eqiack is in the chamber, the chamber tloor will be closei.1 ani.1 securei.1 by the
DCS. In all cases, health ani.1 safet\' conceras will o\ errii.le an\' actions taken to secure munitions.
9) Page F-6. .Atkl to the eni.1 of Section 1.1.3..^: "I fa shot is i.leterminei.1 to be a partial tletonation.
SOP procei-lures will be followei.1. In the e\ ent that such a partial tletonation occurs, procetlures
ani.1 risk assessments are in place to enter the chamber ani.1 atklress the issue. It is not consii.lerei.1
an emergency contlition unless a release or e.\plosi\ e hazan.1 e.Kists. which will be ai.klressei.1 as
part of this plan. The Hazan.1 .Assessment has i.letenn inei.1 that this is an unlikely occurrence."
lU) Page F-S. Seclioii 1.1.3.1 1 . .Added "In accoiclaiice \\ illi llie appiopiiale Peniiil CondiIIOIL-^. The
E.\ecuti\e Secretary shall be notifiei.1 within 24-hour if there is a confirmei.1 agent concentration
in the D.A\TN("H P.AS ani.1 En\ ironmental Enclosure ("ombinei.1 Stack that is ei.|ual or greater
than 1 \'apor Screening Limit (A'SL). Re(|iiiied lepoiis are made in accordance wiili R313-S-l.7( i)
(J) aiid TOCDF Pail B Peniiil Coiidilioiis.
The operator must note in the operating recon.1 the time. i.late. ani.1 tletails of any incipient that
rei.|uires implementing the Contingency Plan. For any emergency e\ ent rei.|uiring H.AZMAT
release reporting, the control room will notify the DCD EOC ani.1 the CMA Shift Engineer ani.1
pro\ii.le a copy ofthe e\ent report. .All reporting to the .Army, local. State, ani.1 Fetleral agencies
will be handled by DCD."
1 1) Page F-7 ani.1 F-S. Section 1.1.3.1 2 has been nuxlifiei-l to state that ".Appro\ al of The
E.\ecuti\ e Secretaiy is rei.|uirei.l prior to the resumption of EDT operations.
12) Page F-S. Section 1.2.1. "at T(!)CDF" i.leletei.1 at the eni.1 ofthe paragraph.
LV) Paee F-9. Revised to"monthlv".
TABLE OF CONTENTS
T.\BLE: OF CONTENTS F i
LIST OF T.\BLES F N
LIST OF .\PPENDICES F N
1.0 INTRODUCTION F i
1.1 SPECIFIC-Co^mNCElNC•^ PL\NS F-2
/././ PiYVfiiiiiiivf Mi'diiiin F-J
1.1.2 EiiiiTi^i'iiry Plmiiiiiiii F-.^
/./..i Ri'i/joiiii' ^nioiii f-V
1.2 WORKZR POPliLATION Ll\nT(\\ PL) EXCliRSION PL\N F-9
1.2.1 Purpose of n PL F\runion Plan F-9
I.:.: Tfi-iiii F-9
Opfniiiiiii Prori'diiin F-9
F-i
List of Tables
Table F-1. Emergency Notifications F-2
List of Appendices
APPENDIX F-1. Example Notice of WPL Notification F-10
APPENDIX F-2 Emergency Response Equipment Locations and Evacuation Routes F-15
F-ii
• ( Formatted
1.0 INTRODUCTION
This Emergency Response Plan describes the emergency response and contingency
actions that will be followed in the event of a fire, explosion, or any unexpected,
implanned release of hazardous materials, hazardous waste, or hazardous waste
constituents during operations ofthe Explosive Detonation Technology (EDT) at TOCDF.
These actions pertain to all operations ofthe EDT at TOCDF, and they apply to all site
personnel, visitors, contractors, and external support personnel.
The EDT will be located in Area 10 ofthe Deseret Chemical Depot (DCD). The system
will be used to destroy overpacked chemical mimitions and samples from the DCD
Chemical Stockpile. The operational waste will be handled in accordance with the
TOCDF Waste Management Plan and Chapter 3.11 ofthe Destruction Plan.
The EDT Site Manager or Safety and Health Officer (SHO) will be responsible for
ensuring that the appropriate procedures are followed. The TOCDF Control Room will
be notified if any emergency or release condition occurs. Table F-1 lists the
organizations to be contacted when emergencies or releases occur. A copy of this plan
will be maintained at the TOCDF EDT Control Room at the site.
All EDT operations are performed in a manner designed to control and eliminate escape
of hazardous waste and hazardous constituents into the environment. EDT operations at
TODCF will take place inside an Environmental Enclosure (EE) comprised of a ceiling,
sides, and flooring that will protect the hazardous waste management unit from
precipitation and run-on as well as prevent the creation of any contaminated runoff. All
EDT operations are performed in a manner designed to control and eliminate escape of
hazardous waste and hazardous constituents into the environment. The EDT operations
at TODCF will take place inside an EE comprised of a ceiling, sides, and flooring that
will protect the hazardous waste management unit from precipitation and nm-on as well
as prevent the creation of any contaminated runoff. Engineering and administrative
controls are in place to control, minimize, or eliminate the possibility of contamination to
groundwater, surface waters, or the atmosphere from EDT operations; they include:
• An air filtration system with carbon filtration;
• Trained explosive handling and chemical operators;
• Appropriate Personal Protective Equipment (PPE);
• Approved work procedures; and
• Prohibition of open flames, cutting, welding, smoking, and radiant heat inside the EE.
Formatted: Centered, Space After:
6 pt
F-1
Table F-1. Emergency Notifications Formatted: Font: Bold
Event Reporting Comments
Fire TOCDF Control Room
(435-833-7700) DCD Fire Response dispatched
Medical TOCDF Control Room DCD Ambulance dispatched
Chemical Release TOCDF Control Room TOCDF HAZMAT response team
dispatched
Chemical Spill of Industrial
Compoimds TOCDF Control Room TOCDF HAZMAT response team
dispatched if required
All Other Emergencies TOCDF Control Room TOCDF Emergency Response will
assist in deteimining response level
EDT Site Manager
EDT SHO
Notify as soon as possible after
accident or illness occms. Do not
Accident Reporting Operating Contractor PM
Operating Contiactor SHO
delay emergency assistance to make
notifications; reporting shall be made
TOCDF Control Room by EDT Site Manager
EDT Site Manager
EDT SHO
Operating Contractor PM
Operating Contiactor SHO
TOCDF Control Room
Do not delay emergency assistance to
make notifications. Notification of
Chemical Event
EDT Site Manager
EDT SHO
Operating Contractor PM
Operating Contiactor SHO
TOCDF Control Room
reportable spills must be made even
when cleanup is handled by EDT
operations personnel; reporting shall
be made by EDT Site Manager
Non-Emergency Change in PPE
level
EDT Site Manager
EDT SHO
Operating Contractor PM
Operating Contractor SHO
Approval of change must be received
before operations resume. Notification
shall be made by EDT Site Manager
Daily Start of Operations
Daily End of Operations TOCDF Control Room Daily Reporting
The TOCDF Control Room shall be
Notification of Other responsible for notifymg other
facilities/buildings of EDT
emergencies to include, but not be
limited to, Autoclave, DVS/DVSSR
and ATLIC persoimel. *
Facilities/Buildings in Event of TODCF Coiitiol Room
responsible for notifymg other
facilities/buildings of EDT
emergencies to include, but not be
limited to, Autoclave, DVS/DVSSR
and ATLIC persoimel. *
Emergency
responsible for notifymg other
facilities/buildings of EDT
emergencies to include, but not be
limited to, Autoclave, DVS/DVSSR
and ATLIC persoimel. *
.* For additional notification requirements, see Section 1.1.3.11. <^
A
1.1 Specific Contingency Plans
Contingency plans for the site include measures to prevent emergencies or, if any
emergency occurs, to limit the negative impact. The major aspects of these plans are:
• Preventive Measures - Measures that should prevent or limit an emergency incident.
• Response Actions - Specific actions to be taken in an emergency situation.
• Notification - Response organizations or personnel to be notified in case of
emergency.
I.I.I Preventative Measures
The following measures will be implemented to prevent or limit an emergency incident:
• Strictly adhering to the Standard Operating Procedures (SOPs), including use of PPE
'( Formatted; Space Before: 3 pt
•{ Formatted; Font: Not Bold
{ Formatted: Normal
F-2
during all EDT site activities
Use of controlled access (i.e., the personnel decontamination station airlock to the
environmental enclosure must be passed through by personnel as they enter the
enclosure).
Determining the evacuation route and rallying point, and communicating it to workers
during the daily safety briefing.
Keeping standard absorbent materials, shovels, and overpacks on-site to contain a
spill or leak. A review ofthe EDT consumable list and verification checklist will be
used to ensure appropriate inventories of these materials.
Discontinuing operations when inclement/hazardous weather conditions pose a threat
to the safe working environment. Some ofthe items to be considered prior to
determining if work should continue are heat stress; severe weather conditions, such
as high wind, fog, and heavy rain; and potential for electrical storms.
1.1.2 Emergency Planning
Response actions by EDT at TOCDF personnel for spills or releases will depend on
whether the release occurs within or outside of engineering control, it can be safely
managed using EDT site persoimel and resources on hand, and the release involves
chemical agent. Any spills or releases will be immediately assessed by the EDT Site
Manager or designee to determine the following information:
• Material(s) involved;
• Exact source of release;
• Quantity of release; and
• Release classification:
Release to the environment (not wholly contained in the EE) or release contained;
extent of any materials released to the environment and extent of injuries.
Releases or spills occurring within engineering controls or for an incident at the
EDT site that can be managed using available EDT site supplies and resources
will be managed by EDT site persoimel. The TOCDF Control Room will be
notified if any emergency condition occurs and of all spill of hazardous materials
or hazardous wastes.
Spills beyond the management capability ofthe EDT Site Manager will be managed by
TOCDF personnel under their emergency response procedures. Spills or releases outside
of EDT engineering controls or those that cannot be managed using EDT site personnel
and resources will be handled in accordance with the TOCDF Emergency Response Plan.
The TOCDF and DCD emergency responders, including fire and medical personnel, will
be on duty during EDT operations. The DCD Fire Department and the TOCDF Clinic
will provide the emergency and medical response to the TOCDF EDT at the request of
the EDT Site Manager through the TOCDF Control Room office.
If the incident is beyond the capabilities of TOCDF response personnel, the EDT Site
Manager or designee will contact the TOCDF Control Room. Emergency responders
may be reached by calling the DCD Fire Department via the TOCDF Control Room (435
F-3
'[ Formatted; Font: Bold
Formatted: Font: (Default) Times
New Roman, Not Bold
833-7700) as indicated in Table F-1 (see previous).
1.1.2.1 Amendment of Emergency Response and Contingency Action
These emergency response and contingency actions will be reviewed and amended, if
necessary, when:
• Applicable regulations are revised.
• Actions fail in an emergency.
• Facility changes in its design, construction, operation, maintenance, or other
circumstances in a way that materially increases potential for fires, explosions, or
release of hazardous materials or hazardous waste/constituents, or changes response
necessary in an emergency.
• List of emergency equipment changes.
j^ote: Revisions to this Emergency Response Plan constitute a revision to the TOCDF
RCRA Permit and must be done through permit modification procedures specified in
Title 40 ofthe Code of Federal Regulation (CFR), Part 270.42, Appendix I, B^6. ^ ^ -- -fFoi^atted; Font: Not Bold
1.1.2.2 Emergency Equipment at EDT Site at TOCDF
Spill kits will be located inside the EE and the decontamination stations. The spill kit
will contain spill pillows and assorted items to facilitate the containment and reduction of
liquid spills. Additionally, shovels, brooms, portable decontamination sprayers, and
other such equipment will be located at the EDT site to further aid in the containment of
any liquid spills. Other emergency equipment will be provided on an as-needed basis by
TOCDF emergency response services.
1.1.3 Response Actions
This section describes response actions that will be used for incidents or events requiring
some action by EDT site personnel, visitors, contractors, and external support personnel
for the following categories: events involving Chemical Warfare Material (CWM);
events involving non-CWM; medical assistance; fire/explosion; severe weather; and
external arsenal events.
1.1.3.1 General Spill or Release Response
The following actions will be followed for spills or releases that occur within engineering
controls and/or that can be reasonably handled using EDT site personnel and resources on
hand:
• Notify the TOCDF Control Room
• Wearing appropriate protective clothing per the direction of Site Safety and Health
Officer.
• Containing the spill in the smallest area possible using absorbent socks, berms, or
other means.
• Repairing or plugging the leak, if possible.
• Decontaminating the release area using installation policies and DA Pam 385-61,
including use of approved decontamination methods, including use of
decontamination solutions, and post-decontamination monitoring via MINICAMS to
the 1.0 VSL level, at 1.0 WPL, /is needed. , . - \ Deleted;
F-4
• For container spills, placing containers in overpack or removing container contents, if
necessary, using a portable pump, and transferring material to a new container. If the
material was released to secondary containment (for contents released from a
container), released material either will be pumped out ofthe containment area using
a portable pump or absorbed using compatible absorbent materials such as pillows,
socks, or granules.
• Decontaminating equipment and clothing as directed by the EDT Site Manager as
applicable.
• Managing spent chemical agent decontamination solutions and other waste
decontamination solutions as hazardous waste.
• Placing absorbed or pumped material into DOT-approved containers and managing
appropriately in accordance with applicable permits and rules pertaining to hazardous
waste management and spill reporting for hazardous material.
1.1.3.2 Events Involving CWM
If exposure to chemical agent is suspected, or symptoms of agent exposure develop,
operators will hold their breaths and immediately don escape masks, sound the air horn
(one long blast) or give verbal waming (if workspace alarm has not soimded), and report
to the Personnel Decontamination Station area or rally point.
The Crew Chief/SHO will notify the TOCDF Control Room of the suspected or known
release and of any casualty requiring immediate medical attention. Casualties will be
processed through the Personnel Decontamination Station, and decontamination will not
be delayed until the arrival of medical personnel imless physical injuries prevent safe
movement ofthe casualty. Operators not showing symptoms of agent exposure will be
processed through the Personnel Decontamination Station and will stand by for further
instruction. The EE provides engineering control so that personnel outside the EE will
not be exposed to hazardous concentrations of chemical agent vapors.
Under no circumstances will incoming personnel or visitors be allowed to proceed into
the Chemical Response Zone (CRZ) once the emergency signal has been given unless
authorized. Further emergency response to chemical agent release and injuries will be
directed by the TOCDF Control Room.
1.1.3.3 Events Involving Non-CWM Materials
When an incident occurs involving non-chemical agent hazardous materials (for example,
chemical reagents, industrial solvents, decontamination agents, fuels) in a quantity that
cannot be managed by EDT site personnel and resources on hand, the EDT Site Manager
will contact the TOCDF Control Room that assistance is required. Otherwise, the
TOCDF Control Room will be notified that a spill occurred and the EDT operators will
respond using materials contained in the spill kits and follow the general spill or release
response steps.
Typical responses to chemical exposure emergencies shall include:
• Inhalation - Move to fresh air and call for emergency assistance as indicated in the
subsequent paragraphs.
F-5
• Sldn Contact - Use copious amounts of soap and water. Wash and rinse affected area
thoroughly, and then provide appropriate medical attention. An eye wash will be
provided at the EDT personnel decontamination station. Eyes should be rinsed for 15
minutes upon exposure. Drenching, if required, will be performed at the personnel
decontamination station.
• Ingestion - Call for emergency assistance and process through the personnel
decontamination station immediately.
• Puncture Wound or Laceration - Call for emergency assistance as indicated in the
subsequent paragraphs. If chemical materials are involved, process through the
Personnel Decontamination Station immediately. If no chemical materials are
involved, processing through the Personnel Decontamination Station is not required.
1.1.3.4 Industrial Accidents and Medical Emergencies Assistance
If a worker is injured or becomes ill on the job, trained co-workers will implement first
aid/CPR if necessary. Emergency medical guidance and assistance will be provided by
the TOCDF emergency services. The DCD Fire Department will be contacted at (435-
833-7700) (landline) through the TOCDF Control Room.
For medical emergencies involving CWM exposures, personnel shall follow the TOCDF
Contingency Plan. Additionally, procedures relative to medical monitoring and post-
exposure results are established by the TOCDF Medical Director and will be adhered to
in the event of individual exposure.
1.1.3.5 Potential or Actual Fire or Explosion
Evacuation diagrams will be posted conspicuously throughout the EDT at TOCDF site.
A common rally point shall also be identified. The EDT has been designed to minimize
the possibility of a fire associated with the system. The EDT uses electrically-powered
equipment, combustible liquids, and compressed gas in various operations.
When a fire is spotted by a team member, he or she will soimd an alarm (i.e., an air hom).
The operator must inform the EDT Site Manager ofthe size and location ofthe fire. If
the fire is small, the operators may attempt to extinguish it using a portable fire
extinguisher. If this attempt is successful, the crew member will inform the EDT Site
Manager ofthe fire status. If the fire is large, involves materials that present an increased
hazard to the crew member, or the first attempt to control the fire is unsuccessful, the
crew members will evacuate the area and inform the EDT Site Manager.
The EDT Site Manager will contact the TOCDF Control Room and request assistance.
This contact should include a description ofthe type and size of the fire, the location of
the fire, and the method for contacting the EDT Site Manager. The EDT Site Manager
will account for all personnel, including visitors, on the site.
Regardless ofthe size of the fire, the TOCDF Control Room will be called. They will be
informed ofthe nature ofthe fire and whether or not items containing chemical agents are
involved.
F-6
I.I.3.CS PPE Failure
U"an\' site worker e.\periences a PPE failure that alTecls the pn')tecli\e abiliU' ofthe
ei.|uipmenl. that person \\ ill immei.lialel\' irUorm the ("rew ("hiefani-l report to the
Personnel Decontamination Station for assistance. Re-entr\' to the EDT operations area
will not be permittei.1 until the ei.|uipment has been repairei.1 or replacei.1 ani.1 the EDT
("rew ("hief has grantei.1 permission.
1. 1.3.7 Ph\ sical Iniur\'
Emergenc\' first aii.1 shall be appliei.1 onsite as necessar\'. A l1rst-aii.l kit is a\ ailable at the
Personnel Decontamination Station. For minor non-emergenc\' ph\sical injuries
rei.|uiring metlical treatment be\oni.l on-site l1rst aii.1. the casualt>' will be transportei.1 to
the nearest healthcare racilit>'. The T(!)("DF Control Room will be notil1ei.l ofall injuries.
I.I.3.S Se\ere Weather
The T(!)CDF Control Room will irUorm the EDT Control Room ofweather atkisories
such as se\ere w eat her watches or w amings. The EDT Site Manager ani.1 SHO will
consii-ler this information ani.1 make motlifications to the work schetlule as appropriate to
ensure worker saret>'. During se\ere w eat her. w hen notil1ei.l. all personnel e.\posei.l to the
elements will report to the i.lesignatei.1 safe location. WTien lightning is i.letectei.1. all EDT
operation acti\ ities will cease.
The EDT Site Manager w ill i.le\elop a list orke\' personnel ani.1 ensure employee
awareness. In the e\ent that T(!)CDF is closei.1 ulue to se\ere weather), the EDT Site
Manager will notily ke\' personnel to report to the site to ensure continuei.1 saret>' oran\'
CWM ani.1 ensure that critical ei.|uipment (such as monitoring ei.|uipment ani.1 \entilation
ei.|uipment) is maintainei.1. These personnel will be on hani.1 once the on.ler to reopen the
base is gi\ en. so acti\ ities at the EDT site can proceei.1 w ith a minimum of interruption.
1. 1.3.9 E.\ternal TOCDF Emergencies
The potential e.\ists that an accitlent or incipient somewhere else on T(!)CDF w ill rei.|uire
e\acuation ofthe EDT site. The T(!)CDF Control Room will irUorm the EDT Control
F-7
Room of such emergencies should they occur.
1.1.3.10 Evacuation Plan
Personnel assigned to the EDT site will be instructed in evacuation signals, procedures,
and routes from the EDT site.
An evacuation route from the EDT site will be determined prior to operations.
Evacuation procedures are as follows:
• The EDT Site Manager or designee will make the decision to evacuate.
• Upon direction to evacuate, the EDT Site Manager or designee will notify all
personnel in the area of an evacuation by an audible alarm/or vocal command.
• If an incident occurs inside the EE, non-essential personnel (as defined by the EDT
Site Manager) will don protective masks and proceed outside to an upwind assembly
point. All essential personnel will don protective masks (unless already in higher-
level PPE) and will rally at the Personnel Decontamination Station to prepare for
decontaminating the affected area.
• If the incident has occurred outside the EE, the same procedure will be followed and
all non-essential personnel will be evacuated from the assembly point to a safe
distance, upwind ofthe incident. Windsocks located at the site will indicate wind
direction.
• The EDT Site Manager will identify the evacuation route from the EDT site based on
the type of incident and prevailing wind.
• The EDT Site Manager or designee will contact the TOCDF Control Room by phone
or radio and will indicate the number of personnel requiring transportation from the
assembly point as necessary.
• If required, transportation will be provided for all personnel at the designated
assembly point. Personnel who are injured or may have been exposed to hazardous
chemicals or chemical agents will be decontaminated in the EDT Personnel
Decontamination Station, and then will be taken immediately to the TOCDF Medical
Clinic.
1. 1.3.11 Notification and Reporting
The primary responsibility for notification will lie with the Crew Chief with assistance from all
other field personnel. Table F-1 (shown previously) provides infonnation for the responsible
person or agency notification, hi accordance with the appropriate Pennit Conditions, The
Executive Secretary shall be notified within 24-hour if there is a confirmed agent
concentration in the DAVINCH PAS and Environmental Enclosure Combined Stack that
is equal or greater than 0.5 Vapor Screening Limit (VSL). Requued reports are made in
accordance with R315-8-4.7(i) & (j) and TOCDF Part B Permit Conditions.
The operator must note in the operating record the time, date, and details of any incident that
requires implementing the Contingency Plan. For any emergency event requiring HAZMAT
release reporting, the operator will notify the TOCDF Control Room. The TOCDF Contiol Room
will notify the DCD EOC and the CMA Shift Engineer and provide a copy of the event
report. All reporting to the Aimy, local. State, and Federal agencies will be handled by TOCDF.
1. 1.3.12 Critique of Response and Follow-up
F-8
Formal accident investigation will be conducted by the CMA/supporting safety office in
accordance with procedures identified in AR 385-10. Should changes to EDT operations
be required, those changes will be approved by CMA Risk Management Division (RMD),
ECBC Risk Management Office (RMO), and the supporting safety office prior to
resumption of EDT operations. Approval of The Executive Secretary is required prior to
the resumption of EDT operations.
1.2 Worker Population Limit (WPL) Excursion Plan
1.2.1 Purpose of WPL Excursion Plan
The purpose of this plan is to provide information that will be used to investigate, identify,
and control sources of identified excursions of chemical agents above the worker
population limit (WPL) in areas where excursions are not expected during EDT
operations.
1.2.2 Terms
• Worker Population Limit (WPL). The WPL is the maximum allowable 8-hour time-
weighted-average concentration of chemical agent that an unmasked worker could be
exposed to for an 8-hour workday and 40-hour week for 30 years without adverse
effect. The agent of concem at the site is mustard (HD). The WPL for HD and HT,
the agents of interest at TOCDF EDT, is 0.0004 mg/ml
• WPL Excursion. A WPL excursion is defined as readings above 1.0 WPL that do not
coincide with near real-time (NRT) monitoring greater than or equal to the NRT
alarm level.
• WPL Excursion Response. This is defined primarily as a medical response when an
airbome concentration of chemical agent is greater than the established WPL. It does
not necessitate emergency response or an immediate threat to life, but will result in
direction given by a competent medical authority (TOCDF Clinic or other appropriate
medical support) to determine any health risks or potential adverse effects. However,
a WPL excursion greater than the STEL is considered a chemical agent event and
requires that the appropriate emergency response be initiated.
1.2.3 Operating Procedures
1.2.3.1 Notice of WPL/Emergency Response
If air monitoring results indicate an excursion of chemical agent above the WPL in a
location where an excursion was not expected (that is, outside of engineering controls),
the following steps will be followed:
• The monitoring team leader will immediately notify the SHO ofthe WPL excirrsion.
• The SHO will ensure that the area(s) involved in the excursion will be promptly
restricted, transients will be limited, and PPE levels will be increased until the cause
is evaluated and corrected. See Appendix F-1 for an example of a Notice of
Restriction.
• The SHO will notify the EDT Site Manager and provide the:
Location of excursion;
Period of time for excursion;
F-9
Name ofagent in\oKei.k
WTL in mg m"':
.Amount ore.\cess in mg m"\
Proposes actions to pre\ent future e.\cursions:
Salet>' POC ani.1 telephone number:
Mei-lical POC ani.1 contact plan \ ia T(!)CDF Control Room: ani.1
Statement concerning health impact ani.1 concurrence of competent metlical
authorit>'.
Appeni.li.\ F-1 shows an e.\ample of a Notice of E.\cursion
1.2.3.2 ln\ estigation of WTL E.\cursions
ln\estigations ofall WPL e.\cursions will be pertormei.1 to tletermine the cause, control
the source ofthe e.\cursion. ani.1 pre\ent future occurrences. Technii.|ues for controlling
e.\cursions might inclutle contlucting atklitional monitoring. re\ iew ing operational
procei-lures. e\aluating engineering controls, ani.1 or other procei-lures as i.leterminei.1 by
the SHO ani.1 EDT Site Manager. All irUormation rele\ant to the in\estigation w ill be
pro\ii.lei.l to the T(!)CDF Clinic. Instances of e.\cursions will be re\iewei.l or anal\zei.l at
least \u- hihlv to (.letermine an\' trentls.
F-|()
APPENDIX F-1 NOTIC E OF WPL EXC I RSION
F-1 I
APPENDIX F-2 EMERGENCY RESPONSE EQUIPMENT LOCATIONS
AND EVACUATION ROUTES
* ( Formatted; Left
F-13
The EDT Site evacuation routes are shown in Figure F-2-1. The figure shows three
separate potential pathways for egress from the site. The TOCDF Emergency
response/evacuation plan will be used to guide the EDT operations persoimel from Area
10 to a safe haven-
Figure F-2-2 shows the escape pathways for the environmental enclosure. There are four
separate egress points from the enclosure, and the doors swing in the appropriate
direction to ensure a quick exit. The diagram also shows the location of fire
extinguishers.
Figure F-2-3 shows the evacuation route for DCD to included Area 10. Area 10
evacuation routes are determined at the time of the incident and are directed by the
TOCDF Control Room or DCD Emergency Operations Center (EOC)
F-14
Primary
^ ^
F~15
Fire Extinguisher Locations
Q Spill Kit Location
Emergency Exit Routes
~( Formatted; Space Before: 2 pt
Figure F-2-3. Evacuation Pathways for EDT Environmental Enclosure
F-16
Formatted: Font: Not Bold
figure ZZ. Evacuation Route for DCD Including Area 10 -[ Formatted; Font: Bold
'I Formatted; Centered
F-17
REVISION 1
EDT DESTRUCTION PLAN
ANNEX G OPERATOR TRAINING PLAN
November 2010
OPERATOR TRAINING PLAN
Subcontract No: DMB51843
Submitted to:
EG&G Defense Materials, Inc/URS
11600 Stark Rd.
Stockton, UT 84071
Submitted by:
(^VERSAR
Versar, Inc.©
6850 Versar© Center
Springfield, VA 22151
jNFoyember 2010 Deleted: May 10. 2010
REMSIONS
1) Page 2. Section I.I. The list ol" applicable i-locuments has been nuxlil1ei.l to inclutle the
I'ollowing i-locuments:
a. EDT Destruction Plan ani.1 .Annexes
b. EDT-TOCDF-PRool - EDT Conlrol System Operations
c. EDT-TODCT-PRoo: - EDT E.\plosive'Operations
d. EDT-T0CDF-PR()()3-EDT OFFGAS Operations
e. EDT-T0D(T-PR()()4-C0NT1NGENC^' (\intingency Plan
f EDT-T0CDF-PR()()5-Delivery. Assembly, and Checkout
g. EDT-T0CDF-PR()()6- EDT Decontamination
h. EDT-T0CDF-PR()()7- ECBC lOP MT-I I D.AAMS TUBE MONITORING
i. EDT-TOCDF-PR()()S_^[TNI(^AMS
.i. EDT-TOD(T-PR()kS-ECBC lOP MT-oS- .AN.AL^ SIS PL.AN .AND .AN.AL^ SIS
SOP
k. EDT-TOCDF-PRooO - Waste Management Operations
I. EDT-TOCDF-PR()i:- Material Handling Operations
m. EDT-T0DCF-PR()13 - Maintenance Operations
n. EDT-T(!)CDF-PR|() - Metal Fragment Drum Heatlspace Monitoring (!)perations
2) .Appeni.li.\. .A copy ol'the Kobe Steel Training Plan has been ai.klei.1 as .Appeni.li.\ 3.
3) .Anne.\ G. page 6. the lH'th paragraph. Changei.1 to reai.1: The SONLI waste will be heatlspace
screenei.1 to 0.5 \'SL in accori-lance with procei-lures. The waste storage area ol'the
En\ ironmental Enclosure will be managei-l in accori-Lance with 9() i-lay storage area
rei-|uirements. (!)perators will screen the exterior ofthe waste containers to a o. 1 \'SL
le\ el. ani-l use a forklift to mo\ e the waste: once clearei-l. to the exterior of the enclosure
for pickup by T(!)CDF W aste Management operations. . The waste will then be turnei-l
o\ er to T(!)CDF W aste Management personnel who will arrange for any ai-klitional
analyses rei-|uirei-l ani-l for off-site i-lisposal.
4) .Annex G. page 23. Change "began" to "begin.
•Annex G. Section I .o. Ai-kl: The rei-|uirements in Utah R31 5-S-2.7( a) ('3). which inclui-les
4()-hour (!)SH.A training ani-l refresher training carriei-l by all operators prior to arri\ al at
the site: inclui-ling. but not liiuitei-l to:
( i) Procei-lures for inspection, use. repair, ani-l replacement of facility emergency ani-l
monitoring ei-|uipment ( See .Appeni-li.x I. CB.ARR pre-i-leployment training)
( ii) Communications or alann systems: ( See Sec. 3.1.3. Site Specific Training)
(iii) key parameters for automatic waste feei-l cut-off systems: (not applicable)
Cw) Response to fires or explosions: ( See Sec. 3.1.3. Site Specific Training)
(A) Response to grouni-lwater contain ination incii-lents: (See .Appeni-li.x I. CB.ARR pre-
i-leployinent training)
(A i) Shuti-lown of operations ( See Sec. 2.3.1. EDT (!)perator Training)
TABLE OF CONTENTS
TABLE OF CONTENTS I
LIST OF TABLES II
LISTOEHGirRES II
LISTOF ACRON\VIS II
1.0 OPERATOR TRAINING 0\ ER\1E\\ l
1.1 .\PPLIC.\BLE: DociMKMS :
1.2 REFERENCES 3
2.0 EDT-SPECmC TRAINING REQllREMENTS 3
2.1 EDT PROCESS TR.\IJNHNG
2. /. / Statement of Purpose •!
2.1.2 Process Ovenueiv and Training Objectives <
2.2 JOB TITLES .\M)I)I TIES 6
2.3 EDT-SPECIFICTR.\HNHNG CONTENT, FREQLIEINC^ , .\IVDTECI-IJNIQLIES 9
2.3.1 Classroom Training Modules 9
2.3.2 EDT On-Site OJT 10
2.4 EDT-Si'ECN K TR.VIMV; M.\TERI.\I,S m
2.5 TR.\IJNHNG ST.\FF i-i
3.0 SITE-SPECIFIC TRAINING REQllREMENTS 15
3.1 CHEMIC.\L SITE-SPECIFICTR.\HNIJNG REQLIIREMEINTS i^
3.1.1 CEA Door Guard Training Course /.i"
3.1.2 Escort Training Course /.i"
3.1.3 Site-Specific Briefings lo
3.2 OTHER SITE-REQI IRED TR.VIMNC I6
4.0 IMPLEMENT ATION OF THE TR AINING PROGRAM 24
APPENDIX 1 25
APPENDIX 2 2-
.\i'i'LNDi\5 r
List of Tables
Table I
Table 2
Table 3
Table 4
Table 5
EDT Site (!)perational Training (!)biecti\ es Training Le\ els.
Training Curriculum for Classroom Lectures
Training Curriculum for Site-Specific Training
Training Materials
Site-Specific Training Rei-|uireinents \6
List of Figures
Figure I. Process (!)\ er\ iew ani-l Training (!)biecti\ es for (!)perators
Figure 2. EDT (!)perational (!)rganization
List of Acroiivms
(^AIRA Chemical .Accii-lent or Incipient Response ani-l .Assistance
CB.ARR Chemical Biological .Applications Risk Rei-luction Business Unit
CEA Chemical E.xclusion .Area
CL.\ Chemical Limitei-l .Area
CPRP Chemical Personnel Reliability Program
CSM Chemical Surety Materiel
DA\TNCHT^' Detonation of .Ammunition in \'acuuin Integratei-I Chamber
DCD Deseret Chemical Depot
DCS Dislributei-I Control System
DESTINE' Near Real Time Strain Monitoring System
ECBC Ei-lgewooi-l Chemical Biological Center
EDT E.xplosi\ e Detonation Technology
EGSiG Defense Materials. Inc. IT^S
GRAND Global DA\TNCH'r^' EDT Data System
HSiS Health and Safety
LSC Linear Shapei-I Charges
OSHA (!)ccupational Health ani-l Safety .Ai-lininistration
O.IT On the .lob Training
PPE Personal Protection Ei-|uipinent
RCRA Resource Conser\ ation ani-l Reco\eiy .Act
T-CEA Temporaiy- CE.A
TOCDF Tooele Chemical .Agent Destruction Facilit}'
1.0 OPERATOR TRAINING OVERVIEW
The Explosive Destruction Technology (EDT) Statement of Work (SOW), paragraph 3.17,
requires that the contractor provide an operation, maintenance, monitoring, and engineering
Training Plan for operators ofthe EDT. The contractor must also ensure that the EDT is
operated in a manner that protects human health and the environment. This plan addresses the
specifics ofthe training program for EDT operators at TOCDF.
Versar© proposes using qualified, trained operators from the Edgewood Chemical Biological
Center (ECBC) Chemical Biological Applications & Risk Reduction (CBARR) operators,
supported by Versar© personnel. A memorandum of imderstanding between the Deseret
Chemical Depot (DCD) and the ECBC organizations will define the Chemical Personnel
Reliability Program (CPRP) requirements associated with assignment of ECBC personnel. In
addition, a list of personnel, training certifications, and Competent Person Training will be
provided before deployment.
A Training Supervisor will be assigned to coordinate and manage the training program for the
EDT Team. This individual will also participate in the hands-on training provided under this
plan.
This training plan addresses the baseline training requirements for EDT operations personnel,
which are:
• EDT-specific training, described in this Operator Training Plan;
• DCD- and TOCDF-required training, including site-specific training required by the
operating contractor [i..e. Site Visitor Orientation Traimng (SVOT)]: chemical exclusion area , - - 4 Formatted: Font: (Default) Times
operations; SOW Appendix B, Badging and Site Access; and Appendix E, Traming and ^ ^ New Roman, 12 pt, Not Bold
Certification Requirements, including site-specific training.
• CBARR-provided training in CPRP, including Chemical Surety under Army Regulation
(AR) 50-6, Chemical Safety and Chemical Handling; explosive safety training under AR
385-64; Department ofthe Army Pamphlet (DA Pam) 385-64, Ammunition and Explosives
Safety Standard; and other CBARR-required training programs as described in Appendix 1,
CBARR Training Requirements.
• The requirements in Utah R315-8-2.7(a) (3), which includes 40-hour OSHA training and
refresher training carried by all operators prior to arrival at the site; including, but not limited
to:
(i) Procedures for inspection, use, repair, and replacement of facility emergency and
monitoring equipment (See Appendix 1, CBARR pre-deployment training)
(ii) Communications or alarm systems; (See Sec. 3.1.3, Site Specific Training)
(iii) Key parameters for automatic waste feed cut-off systems; (not applicable)
(iv) Response to fires or explosions; (See Sec. 3.1.3, Site Specific Training)
(v) Response to groundwater contamination incidents; (See Appendix 1, CBARR pre-
deployment training)
(vi) Shutdown of operations (See Sec. 2.3.1, EDT Operator Training)
The operator training program described in this plan will address the first two bullets above.
1.1 Applicable Documents
Applicable Documents include:
SOW for EDT at TOCDF, EG«feG, which includes Appendices B and E.
TOCDF Trainmg Plan, Attachment 7, TOCDF (May 2009), 29 Code of Federal Regulations
I9I0.
Occupational Safety and Health Administration (OSHA) Standards, Subparts D, E, G, H, I, J,
L, M, O, and S.
Department of Defense (DoD) 6055.9-Std., Department of Defense Ammunition and
Explosives Safety Standards, 29 February 2008; Chapters 4, 5, 6, 7, 8, 9 and 11.
DA Pam 385-64, Ammunition and Explosives Safety Standards, 15 December 1999,
Chapters 4, 5, 6, 7, 8, 9, and 11, and Appendices B, C, D, and F.
DA Pam 385-61, Toxic Chemical Agent Safety Standards, 17 December 2008, Chapters 3, 4,
5, 6, 7, 8, and 12, and Appendices E, F, G, and H.
DA Pam 385-173, Occupational Health Guidelines for the Evaluation and Control of
Occupational Exposure for Mustard Agents H, HD, and HT, 3 June 2003, Chapter 2.
DA Pam 385-65, Explosive and Chemical Site Plan Development and Submission, 1
February 2008.
Explosive Site Safety Plan Developer's Guide, February 2006, Sections 5, 6, 11, and 12, and
Appendices A and B.
AR 415-15, Army Military Construction Program Development and Execution, Paragraph 2-
16.
DA Pam 385-65, Explosive and Chemical Site Plan Development and Submission, 1
February 2008.
Technical Manual (TM) 5 -1300, Stmctures to Resist the Effects of Accidental Explosions,
1999.
Military Standard (MIL-STD)-882D, Standard Practice for System Safety, 10
February 2000
DA Pam 385-16, System Safety Management Guide, 13 November 2008.
EDT Destruction Plan and Annexes
EDT-TOCDF-PROOl - EDT Control System Operations
EDT-TODCF-PR002 - EDT Explosive Operations
EDT-TOCDF-PR003-EDT OFFGAS Operations
EDT-TODCF-PR004-CONTnsfGENCY Contingency Plan
EDT-TOCDF-PR005-Delivery, Assembly, and Checkout
EDT-TOCDF-PR006- EDT Decontamination
EDT-TOCDF-PR007- ECBC lOP MT-11 DAAMS TUBE MONITORING
EDT-TOCDF-PR008_MINICAMS
EDT-TODCF-PR016-ECBC lOP MT-08- ANALYSIS PLAN AND ANALYSIS SOP
EDT-TOCDF-PR009 - Waste Management Operations
EDT-TOCDF-PR012- Material Handling Operations
EDT-TODCF-PR013 - Maintenance Operations
EDT-TOCDF-PRIO - Metal Fragment Drum Headspace Monitoring Operations
1.2 References
Kobe Steel Ref \'()() D\'l l-PR-ol Training Plan. .lanuaiA-. 2()()9
2.0 EDT-SPECIFIC TRAINING REQUIREMENTS
The training program is designed to train experienced EDT operations personnel, site
supervisory personnel, and other site staff in the specific operational characteristics, processes,
maintenance, and systems management necessary to conduct safe and secure Detonation of
Ammunition in a Vacuum Integrated Chamber (DAVINCIP'^) EDT operations in a chemical
surety program. This will be completed using a combination of classroom instruction and
closely supervised on-the-job training (OJT).
The program provides for initial training for the operators; it does not address recurring training,
since the project is expected to be of short duration. However, this plan can be modified to
include post-processing review training and ongoing training requirements if, after the initial
scope of work is completed, additional processing becomes necessary.
The EDT-specific training locations will be at the existing ECBC CBARR training facility in
Edgewood, Maryland, at the TOCDF EDT site, and at contractor-provided classroom areas,
which will be provided by EG&G.
Included in the training are assessments of each individual's skill and knowledge to determine
that the training program objectives have been met. In addition, this training plan provides for
the recording and documentation of training to meet vendor EDT requirements. The plan and
subcontractor training records are maintained and available at the EDT Control Room on the
DCD EDT site.
2.1 EDT Process Training
2.1.1 Statement of Purpose
The purpose of this traimng is to instruct operations supervisors, engineering and maintenance
personnel, and system operators in the operating principles ofthe DAVINCIF^ and the specific
procedures for its safe and efficient operation. General areas covered include operation,
maintenance, monitoring, and engineering concepts related to the operators.
The DAVINCH'^'" controlled detonation chamber system is sufficiently different from other
systems with which operators may have had some experience, so an understanding of operational
principles and salient differences is important. The DAVINCH™ System is extensively
monitored in real time for chamber and system mechanical integrity, emission of detonation
product gases, and destruction removal efficiency of chemical warfare agents. As safety is of
paramount concern, part of the training will be dedicated to understanding and interpreting any
indication of an upset condition and instructing how to respond quickly and efficiently to such
indicators.
2.1.2 Process Overview and Training Objectives
The DAVINCH^" system operation is staffed with operators, monitoring technicians, and
supervisory personnel. Objectives are identified as:
• D - DCD specific training, OSHA, and site access training;
• C - CPRP Training;
• A - Ammunition and Explosives Handling; and
• O - Operations-ZD AVINCH™-specific training, as noted on Figure 1.
Overpacked chemical munitions (CSM) are received at the Unpack Area of the EDT site.
Trained operators will establish a Temporary Chemical Exclusion Area (T-CEA), clear the box
tmck used to transport the munitions using a Miniature Chemical Agent Monitoring System
(MINICAMS'^") to ensure safe first entry into the truck. A forklift-trained operator with
ammunition training, CPRP certifications, and OSHA training, wearing appropriate Personal
Protective Equipment (PPE), moves the pallet or box containing the overpacked munitions (or
samples) to the Unpack Area. There, a team of two operators, one operating the forklift and the
other a safety/surety observer, will move the overpacked munitions to the Preparation Area. This
will require that these operators have site-specific safety training, CPRP, OSHA, and
ammunition-handling/explosives training, as well as training on the specifics of installing the
charges.
In the preparation area, munitions will be removed from the transport box by a lifter. The two
operators will install the linear shaped charges (LSC), donor charges, detonators, and detonation
cord on the munition. These operators will be required to have site-specific safety training,
CPRP, OSHA, and ammunition-handling/explosives training, as well as training on the specifics
of installing the charges.
After configuring the munition with the charges, operators will move it to the EDT containment
area on a cart. The operators will then raise the explosive-configured munition to the level ofthe
movable platform. This will require that these operators have site-specific safety training, CPRP,
OSHA, and ammunition handling/explosives training, as well as training on the specifics of
lifting the configured munition.
The entry into the chamber will be a confined-space entry, so OSHA confined-space entry
requirements for training will be met. Two operators will enter the chamber, after the exhaust of
the chamber downstream from the particle filter has been monitored clear by MINICAMS™, for
safe first entry. The lifting cart will be positioned on the movable platform by the operators.
Three operators will participate in the entry process: two for entry and one for safety monitoring
during the confined space entry. One operator will operate the movable platform in full view of
the two operators standing adjacent to the platform at the level of the chamber entrance. Once
the munition and lifting cart have been moved into the chamber, the operator will lift the
configured munition until it is horizontally level within the chamber near the top. At that point,
an operator will hand-configure the hanging slings to allow the munition to hang in place.
Specific training will be required for that process.
Mine CiP
Miiiiilioii- lo
Proi;e--iiie
.\ren
T<y. D. .\.L. <i
lii-lall LSC ainl
Donor Cliaree
TO: D. .A. L. n
Fir-1 Eiilr\
Clearance vv i
MINlC.\MSTw
T<y. D.L.ii
Mo\e Donor
cTiaree ainl
LSC from Da\
Box
T<y. D. .A. L. <i
Mo\ e Donor-
con lien reil
EDT
|)rocer:r:ine
iireii
T<1: D. .A. L.il
Sel ilelonalor
vv irins
T<y. D. .\.L. <i
Li|)erale
D.WINCHTw
Cliaiiil>er
TCI: D. .\. C. Ci
E-lal>li-li TE.\.
Conlrol Room
CT)eralion-
T<y. D. .A. L. <i
LT)en Cliaiiil>er
Door
Renio\e
Scra|)
(Maenel)
T<y. D. .A. (
Fir-1 Enlr\
Clearance vv iili
MINlC.\MSTw
ainl Conllneil
S|)ace
Ci\er-ielil
T<y. D.L.ii
Mo\e Scra|) lo
Wa-le
Proce--ine
.\rea
T<y. D.L.ii
Traii-I'er Scra|)
lo Wa-le
Drum-
T<y. D.L.ii
Wa-1e
Clearance vv iili
\nNlC.\MSTw
T<1: D.L.ii
Per-onnel
Deconlaininalion
T<y. D. .A. L. <i
Training (!)biecti\es
D- DCD site training. OSH.A.
ani-l baseline training
.A- .Ammunition E.xpli')si\e
C- CPRP
O- Operations DA\TNCHTM
Figure 1. Process Overview and Training Objectives for Operators
•After hanging the munition in the chamber, a trainei-l operator will test the continuity' of the
i-letonation cable pass-through, ani-l ensure that the leai-ls are shortei-l at the EDT Control Room.
W hen coinpletei-l. a public ai-klress system (P.A) will be usei-l to relay this infonnation to the EDT
Control Room. Once that is \ alii-latei-l as safe, the operator will connect the i-letonation cori-l chain
to the leai-ls at the pass-through ani-l then e.xit the chamber. The ino\ able platfonn will be
wilhi-lrawn by the operators. These operators will obser\e the closure ofthe chamber \k\ ani-l
then e.xit the En\ ironinental Enclosure through the personnel i-lecontain ination area.
The operators in the Control Room will \ alii-Late that the chamber is clear of personnel ani-l
ei-|uipinent prior to closing the lii-l. Once the \k\ is closei-l. the Temporaiy E.xclusion .Area (TE.A)
is inaintainei-l at the perimeter ofthe main enclosure, ani-l i-loor guari-ls are postei-l at the control-
point i-loor. The EDT will then cycle through its process of e\acuation. stabilization, ani-l correct
pressure \ acuuin setting, .lust prior to i-letonation sei-|uencing. the EDT control operators will test
the continuity ofthe e.xplosi\e leai-l circuit ani-l attach the i-letonation trigger mechanism.
Once clear, the EDT operators will initiate the i-letonation sei-|uence. ensuring safe position ani-l
accountability for all operators. obser\ ers. ani-l other staff. The EDT Control Room will perfonn
the necessaiy pre-i-letonation checks. Once all checks ha\ e been clearei-l. the EDT Site Manager
or i-lesignee will then ini-licate that the i-letonation will occur. The P.A system will be usei-l to
pro\ ii-le \ arious warnings, followei-l by a counti-lown ani-l i-letonation.
Once the chamber has completely cyclei-l through its process, three operators will enter the EDT
containment area in PPE. .A magnet system will be usei-l to reino\ e ferrous metal fragments.
Two more operators will then enter the chamber after the interior ofthe chamber has been
i-letenninei-l to be safe to enter basei-l on MTNIC.AMS'''" results obtainei-l from a sampling location
that is i-lownstreain from the particle filter These operators will manually reino\ e any remaining
waste that might be iinpeeling the operation.
Waste materials will be transferrei-l by operators in PPE to the waste container in the chamber
area, ani-l a trainei-l operator will ino\ e the waste container to the W aste Processing .Area for
heai-Lspace analysis in i-lruins i-lesignei-l for that purpose, i lie !e •v:il he ^i-raJ (•Jh.-r
•All personnel will then e.xit \ ia the conlrol point, ani-l the system can either be shut i-lown for
maintenance, or the process can begin for the ne.xt shot. .A ina.xiinuin of se\ en shots per i-Lay can
be accoinplishei-l.
2.2 Job Titles and Dulles
Training courses are to be hekl for the following i-lifferent le\ els of personnel, basei-l on their
assignments ani-l responsibilities, as notei-l in the following paragraphs ani-l Figure 2.
The on-site organization and training objectives will consist of categories identified in Table
Ijpelow. As shown in the table, the plan includes four leye^^ the
different assignments of personnel as follows.
• Supervisor Course for the supervisory and engineering personnel, including the Site
Manager, and Health and Safety (H&S)/Explosive Safety Manager.
• EDT Operator Course for the ECBC CPRP Site Supervisor, ECBC CPRP operators, and
ECBC CPRP Control Room Operators.
• EDT Familiarization Course for Monitoring personnel and site personnel who do not handle
munitions, operate controls, or perform chemical duties.
Deleted: above
EG&G
Project Manager (Versar) *High Level *High Level
Safety Manager (Explosive, Environmental) /Vers|
*TT: -1. T f
Site Manager (Kobe Steel)
Shift Supervisor (Kobe Steel)
Site Manager (ECBC) *MediumLevel
CPRP
Control Room
Safety (E GB C) *Mediiim Level
A (ECBC)
B (ECBC)
C (ECBC)
Analysis/Monitoring
Sampling
*Mediiim Level
Same personal as site
manager and safety
(ECBC)
*Low Level
Each team
consists of two
persons
*Analysis
Specialist
(ECBC)
Figure 2. EDT Operational Organization
Site-Specific Training for all on-site personnel as described in Section 3.0. Licluded will be site-
7
specific training for the unique aspects ofthe EDT as implemented on the TOCDF site, including
chemical-area-specific training, door guarding, escorting, RCRA Class III Permit modification
and Air Pennit modification instruction, and training on hazardous waste management
requirements unique to the State of Utah in regards to the treatment of chemical agents. This
training will be developed by EG&G.
Table 1. EDT Site Operational Training Objectives/Training Levels
Organizational Element Role EDT Training Objective
Site Manager
Responsible for site
operations, management of
on-site activity, and liaison
with EG&G operations
• EDT Supervisor Course
• Site-Specific Training
• D,0
H&S/Explosive Safety
Manager
Responsible for
implementing H&S plan,
chemical safety, and
explosive safety oversight;
liaison with Versar© and
Kobe Steel site personnel
• EDT Supervisor Course
• Site-Specific Training
• D, A, 0
ECBC Site Supervisor
(CPRP)
Responsible for operations
mgmt for EDT, supervises
operators, ensures safety.
Liaison with Versar© and
Kobe Steel site personnel
• EDT Supervisor Course
• EDT Operator Course
• Site-Specific Training
• Escort Training
• D, A, C, 0
ECBC Site Safety
Supervisor (CPRP)
Oversees and supervises
operational safety of EDT
operations process
• EDT Operator Course
• Site-Specific Training
• Escort Training
• D, A, C, 0
ECBC Operators (CPRP)
Munitions handling,
explosive placement, waste
removal, maintenance
support, control room ops
• EDT Operator Course
• Site-Specific Training
• Escort Training
• D, A, C, 0
ECBCJVIonitoring
• EDT Familiarization
Course
Personnel (CPRP) Monitormg" • "Site-Specifio Training |
• Escort Training
• D,0
Training Objectives
D- DCD site training, OSHA, baseline training
A- Ammunition/Explosive
C-CPRP
O- Operations/DAVINCH™
Deleted: and Contractor
^s slKmpi in Table 1 . the plan includes three kyels of jraming. each optimized for the different
assignments of personnel as follows.
• High level course for the engineering personnel: two persons (Versar; project manager and
safetv manager).
• Medium level course for supervising personnel: two persons (site manager and safety)
• Low level course for operating personnel: 6 persons-ff)T operators _
• Monitoring and analyst personnel: Monitoring personnel are assumed to have sampling and
analysis training and experience will be assigned, therefore, no additional fomial training is
necessarv beyond baseline TOCDF/DCD site training requirements, and proficiency on the
instmmentation and processes used during monitoring.
Site Specific Training: Section 3.0 identifies site-specific training requirements for all on-site
personnel.
2.3 EDT-Specific Training Content, Frequency, and Techniques
2.3.1 Classroom Training Modules
The content ofthe Supervisor, EDT Operator, and Familiarization classroom training modules is
presented in Table 2. These are the currently contemplated subject areas for instruction, but may
be augmented as the scheduled training draws nearer.
Formatted: Font: (Default) Times
New Roman
Formatted: Bullets and Numbering
Formatted: Font: (Default) Times
New Roman
Table 2 - Training Curriculum for Classroom Lectures
Course Curriculum Material/Duration
• Supervisory
• Familiarization
General
• Equipment
• Plant Layout
• Operational Overview
• General Safety and Surety Overview
Design Documents
(High: 2 days.
Medium: 1 day)
• Supervisory
Safety Management
• Controlled Area
• Safety Analysis
• Risk Assessment
• Donor Explosive Characteristics
Design Documents
(1 day)
MAXAM brief
• Supervisory
• EDT Operators
Operation Procedures
• Division of Work on Site
• Standard Operation Procedures
• Starmp and Shutdown
• DCS
• DESTEslY
• GRAND
User Manual
(1 day)
Course Curriculum Material/Duration
EDT Safety
• Hazards of Chemical Agent (Area) User Manual
(Iday) • EDT Operators • Hazards of Explosion/Gas Leaks
• Donor Explosive Handling and
Storage
User Manual
(Iday)
Maintenance
• EDT Operators • Where and how to check the EDT
conditions/PM schedule
• Dust and Liquid/Drain Removal
Design Documents
(Iday)
• Supervisory
• EDT Operators
• Familiarization
Course
• Agent Analysis & Monitoring
• Request for Analysis & Monitoring
Sampling Method
Paper
(Iday)
2.3 .1.1 Classroom Training Duration
The Supervisor Course will require 1.5 weeks for completion, and the medium-level course
duration is 1 week. The training will include classroom lectures augmented by audio/visual aids
of actual ongoing operations at DAVINCff'^ operational sites at Kanda Harbor, Japan, and
Poelkapelle, Belgium. Additionally, the trainees will be introduced to the real-time network of
shared experience documentation from the Kanda and Poelkapelle operations, available through
the intemet [Distributed Control System (DCS), DESTINY, GRAND].
2.3 .1.2 Classroom Training Location
A fiilly-equipped classroom is available at the CBARR facility in Edgewood, Maryland. The
classroom has audio-visual and presentation support, and it is adjacent to the CBARR warehouse
and storage areas for hands-on demonstration. Kobe Steel and Versar© instructors will travel to
ECBC to conduct the initial training for high, medium, and low classroom modules. A similar
requirement for classroom training will be coordinated as needed at TOCDF to augment the
initial training.
2.3.2 EDT On-Site/OJT
Supervised OFT will follow the classroom training modules at ECBC. For this requirement, the
curriculum items in Table 3 will be used for the training process.
The EDT Operator course will require two weeks for completion during system
familiarization/systemization. Versar© and Kobe Steel instructors will travel to TOCDF to
conduct the initial OJT. A suitable classroom will be available for lectures. The OJT will take
place at the EDT site in Area 10.
2.4 EDT-Specific Training Materials
The training staff from Versar© and Kobe Steel will develop, produce, and deliver training
materials and documentation as shown in Table 4. These materials will consist of presentations
10
in PowerPoint; video presentations of specific operational overviews from the operational sites at
Kanda Harbor, Japan, and Poelkapelle, Belgium; engineering documentation and manuals: flow
charts and process flow diagrams; plans and procedures; and related materials. These materials
will be distributed to the operators as necessary, and copies ofthe material will also be retained
on-site in the Control Room/break room areas for easy reference.
The site will also be the repository for the training certifications and required forms and, for
TOCDF access, the required training proficiency forms and training materials described below.
All of the training materials will be reviewed and approved by the technical staff of Kobe Steel,
and will be provided to EG&G for review and approval. This will ensure integration with the
EG&G Training Manager's ongoing programs.
Any proposed modification to the training curriculum will be reviewed and approved by EG&G
before implementation.
Table 3 Training Curriculum for On-Site Training
Course OJT Curriculum Material/Duration
• Supervisory
• EDT Operator
• Familiarization
General (Lecture)
• General Information of System
• Introduction Videos
• Layout/Process/Equipment
Design Documents
(0.3 day)
• Supervisory
• EDT Operator
• Familiarization
EDT Specific Site Safety (Lecture) Paper
(0.3 day)
• Supervisory
• EDT Operator
• Familiarization Site Tour (Site) (0.3 day)
• Supervisory
• EDT Operator
Operation Procedure (Lecture)
• Work of Low-Level Operator
• Safety Education for Explosive
• Key Points of HE/CA Destruction
• Key Points of Donor Charge Setting
Paper
(0.5 day)
• EDT Operator
In-Service Training (Time Trial with
PPE, Site)
• Preparation for Donor Charge
• Setting Donor Charge on Overpack
Overpacks and
simulated donor
charge
(3.5 days)
• EDT Operator
On site Training (Site)
• Off-Controlled Area Preparation
• Controlled Area Preparation
• Handling System Operation
(3 days)
11
Course OJT Curriculum Material/Duration
• Daily Check/Maintenance
All Joint Training with other operating
levels (Site) (2 days)
12
Table 4 - Training Materials
Item Course
Operators and Trainers Presentation
• Supervisory
• EDT Operator
• Familiarization
Kanda Video
• Supervisory
• EDT Operator
• Familiarization
Belgium Video
• Supervisory
• EDT Operator
• Familiarization
Process Flow Diagram
• Supervisory
• EDT Operator
• Familiarization
Assembly Drawing of EDT
• Supervisory
• EDT Operator
• Familiarization
General Plot Plan
• Supervisory
• EDT Operator
• Familiarization
Operation Flow Chart • Supervisory
• EDT Operator
User Manual • Supervisory
• EDT Operator
User Manual for DCS • Supervisory
• EDT Operator
Piping & Instrumentation Diagram • Supervisory
• EDT Operator
Key Points • Supervisory
• EDT Operator
Troubleshooting Guide • EDT Operator
User Manual for DESTINY • EDT Operator
User Manual for GRAND • EDT Operator
Maintenance Manual • EDT Operator
Daily Check List • Supervisory
• EDT Operator
Procedure of Startup and Shutdown • Supervisory
• EDT Operator
Understanding the Donor Explosive/MSDS
• Supervisory
• EDT Operator
• Familiarization
13
2.5 Trahiiiig Staff
•A Training Super\ isor. will be assignei.1 lo coori-linale ani.1 manage the training program lor the
EDT Team. The Training slalT will inclutle engineering ani.1 operational specialists with
experience al both Kantla Harbor, .lapan. ani.1 Poelkapelle. Belgium. These trainers will ha\ e an
e.\cellenl commani.1 ol" English lo minimize any communication issues between trainers ani.1
slui-lenls. The training slalThas experience in i.le\ eloping ani.1 implementing training for
operators from the Belgian Minisliy of Defense ani.1 for the Kobe Steel slalT in .lapan. These
e.\periencei.l trainers will be a\ ailable (.luring the training process for ini.li\ ii.lual consultation ani.1
coaching shouki that be necessary. E.\ample resumes ofthe training staff are pro\ii.lei.l in
.Appeni.li.\ 2. The sample resumes ii.lenlify the type ani.1 le\ el of personnel a\ ailable from
\'ersariCi ani.1 Kobe Steel lo contlucl the training process.
14
3.0 SITE-SPECIFIC TRAINING REQllREMENTS
The training program for EDT will be reviewed with the TOCDF Training Manager to ensure
that site conditions, requirements for site-specific training, and permit requirements are met.
Versar© will ensure that all operators and on-site personnel complete required training at
TOCDF in accordance with the SOW Appendix E, Training and Certification Requirements.
The Versar© Training Supervisor will perform an analysis of each employee's training status.
This will ensure that any gaps in training are identified and scheduled to ensure operations are
not affected.
3.1 Chemical Site-Specific Training Requirements
In addition to the EDT-specific training described in Section 2.0, all site personnel must be
trained in requirements listed in the following documents:
• AR 190-59, Chemical Agent Security Program;
• AR 50-6, Chemical Surety;
• System Contractor Surety Project Regulatory Procedure (PRP-SR)-002;
• PRP-SE-006, Chemical Personnel Reliability & UAP [i.e., Unescorted Access] Program;
• Chemical Limited Area (CLA) and Chemical Exclusion Area (CEA) Access Controls and
Management PRP-MG-24, TOCDF Badging Process; and
• The draft Memorandum of Agreement (MOA) or equivalent for maintaining CPRP
compliance with AR50-6.
The site contractor Surety department will provide the training for the areas listed below,
subsequent to DCD in-processing. Two days will be required for this training, which will be
provided on-site at TOCDF/DCD.
3.1.1 CEA Door Guard Training Course
This course provides the trainee with information for performance as a CEA Door Guard. Upon
completion of this training, the trainee will be able to:
• Discuss key words and definitions.
• Describe the Duress System, including the rules, and how and when it is used.
• Describe the general and special CEA Door Guard requirements and responsibilities.
• Describe the process for maintaining security of a CEA Door in "Access" during an
emergency/exercise.
• Discuss previous CEA Door Guard violations and noncompliances
3.1.2 Escort Training Course
Upon completion of this presentation, the trainee will be able to:
. Differentiate between a CLA, CEA, and T-CEA.
• Describe the Duress System and how to use it.
15
• Identify the level of authorization indicated by a proximity badge (CLA, CEA, T-CEA,
escort/no-escort required).
• Identify the basic elements ofthe escort process for UA and CPRP.
• Describe the steps in preparing, entering/exiting, and managing escorted person(s) in a CLA,
CEA and T-CEA.
• Understand the requirements ofthe "Checklist for Escorting" and Lessons Learned.
3.1.3 Site-Specific Briefings
These briefings will address:
• Specific security protocol for entering the Area 10 CLA and conducting operations during
and after normal operating hours. Tour Area 10 as required.
• MOA or equivalent for CPRP-certified workers.
• CPRP medical support.
• Specific requirements associated with the TOCDF RCRA and Air Pemiit requirements. _ , - j Deleted: EDTRCRA CLASS m
This will include: Penmt modification
• A discussion on the State of Utah hazardous waste codes unique to chemical agent and
their treatment residues, P999 and F999, respectively.
• A discussion on what the reportable spill quantity is for agent (any spill) and agent
treatment residues (1 kilogram).
• A discussion on what the different alarm tones mean, and the muster points and
evacuation routes applicable to the DAVINCH™ site.
• Operator familiarization with hazardous waste generator waste management
requirements (e.g., satellite accumulation points, 90-day storage) from OSHA and
RCRA training.
3.2 Other Site-Required Training
Table 5 provides an overview ofthe Site Training Program for the personnel assigned to the
EDT program. The requirements for each position will be analyzed for applicability ofthe
following courses, specifically, those involved with Competent Person training. As stated above,
the gap analysis conducted by the Training Supervisor will establish training requirements for
individual staff members prior to operations.
Exhibits 1 and 2 to Appendix E are presented below. Each employee will have the appropriate
training documented on these forms, which will be provided to EG&G prior to operations.
These forms will be used to document and substantiate the training for the EDT team.
16
Table 5 - Site-Specific Training
No. Req'int Training EDT Training Objecti\ e
T-: :9CFR1
910.1:()(
q X6Xi)
OSHA RCRA
.Aw areness
Training: .A
certificate of
completion from a
i.|ualifiei.l course for
each \'ersar:0 Team
employee.
.As statei.1 in .Appeni.li.\ C. all \'ersar:0 Team personnel recei\ ing (!)ne-\ear Temporar\' or
Permanent batlges must complete an S-hour training class to fulfill the rei.|uirements of
29CFR1 91 (). 1 2()(pXSXiii) and (qX^^Ki)- This OSH.A .Awareness le\el training may be
accompiishei.1 \ia an\' training course which satisfies the specifiei.1 (!)SH.A regulations.
\'ersar:0 Team personnel shall submit tlocumentation which shows the\' ha\e hai.1 the
rei.|uirei.l training w ithin the last 1 2 months. The Subcontractor shall take refresher training
as rei.|uirei.l (.luring the performance of this contract to ensure that a 12 month perio(.l (.loes
not lapse since the Subcontractor last complete(.l the training class. Personnel who (.lo not
ha\e this training will be enrolled in EG&G HAZCOM CPRFA. and or SORT-R
T-3 29CFR1
910.12()(
pX^Xi)
OSHA RCRA
(!)perations
Training: .A
certificate of
completion from a
(.|ualiJle(.l course for
each \'ersar:0 Team
emplo\ee.
In accor(.lance w ith 29CFR1 91 o. 1 2o(p)(7)(i). emplo\ ees e.\pose(.l to health hazar(.ls or
hazar(.lous substances must recei\ e 24 hours of training to enable them to perform their
assigne(.l (.luties an(.l functions in a safe an(.l healthful manner so as not to en(.langer
themsekes or other emplo\ ees. This (!)SH.A (!)perations le\el training ma\' be
accomplishe(.l \ ia an\' training course w hich satisfies the specil1e(.l (!)SH.A regulations.
\'ersar:0 Team personnel shall submit (.locumentation w hich show s the\' ha\ e ha(.l the
re(.|uire(.l training w ithin the last 1 2 months. The Personnel shall take refresher training as
re(.|uire(.l (.luring the performance of this contract to ensure that a 1 2 month perio(.l (.loes not
lapse since the Personnel last complete(.l the training class. EG&G S(!)RT-(!) ma\' be use(.l
for this training.
T-4 29CFR1
910.
29CFR1
926
Competent Person:
.A complete(.l
Competent Person
Form (Training
.Appen(.li.\ E.\hibit
1) for each
in(.li\i(.lual
(.lesignate(.l by the
Subcontractor to
perform the
specil'ie(.l acti\ ities.
(!)SH.A regulations re(.|uire that the Subcontractor ha\ e a "Competent Person" perform
\arious acti\ities relate(.l to the safe e.\ecution of work acti\ities. \'ersar:0 w ill complete
an(.l submit a complete(.l Competent Persons Form (•E.\hibit 1 to the S(!)\\' .Appen(.li.\ E) for
each person w ho is (.lesignate(.l the Competent Person for the specifie(.l acti\ it>'. \'ersar:0
w ill pro\ i(.le competent or (.lesignate(.l persons as re(.|uire(.l by all (!)SH.A regulations but as a
minimum shall pro\i(.le competent persons for the follow ing areas of competence as
re(.|uire(.l by the Tasking:
a. Asbestos - 1926.1 lol
b. Oanes - 191o.l79. 191o.lSo: 1926.550: 1926.753
c. Material Personnel Hoists - 1926.552
d. Demolition - 1926.S5o. S52. S5S. S59
1 7
No. Req'int Training EDT Training Objecti\e
m.
n.
o.
P-
Scaffolding - 1926.45o. 451. 454
Electrical - 1926.4o4
Ladders - 1926.1o53. 1 060
Fall Protection - 1926.5oo. 5o2. 5o3. 1 060
Slings & Rigging - 191o. 1S4: 1926.251
Lead - 1926.rS2^
Welding Cutting - 1910.253. 2.^4. 255: 1926.354
E.\ca\ ations Trenches - 1926.65o. 651. 652
Compressed .Air - 1926.So3
Ionizing Radiation - 1926.53: 191o. 1()96
Cadmium - 1926.1 127
General Health & Saler\- - 1926.2o
T-5 29C
910,
0
FRl Hazards
Communication: .A
complete(.l Training
Form (Training
.Appen(.li.\ E.\hibit
2) for each
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
29CFR1 91 o. 1 2oo man(.lates that the Subcontractor estabi ish a comprehensi\ e Hazar(.l
Communication Program, w hich inclu(.les container labeling an(.l other forms of w arning.
material salet>' (.lata sheets an(.l emplo\ee training. \'ersar:0 w ill submit a complete(.l
Subcontractor Training Form ( E.xhibit 2) for each Subcontractor an(.l Sub-tier
Subcontractor emplo\ ee.
T-6 29C
910.
29C
926.
•)('6)
FRl
146.
FRl
21(b
Conlme(.l Space
Training: .A
complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
OSLLA regulations 29(TR 191 o. 146 and 29(TR 1926.21 ( bX6) require that all emplovees
re(.|uire(.l to enter into corUlne(.l or enclose(.l spaces shall be instructe(.l as to the nature ofthe
hazar(.ls in\dKe(.l. the necessar\' precautions to be taken. an(.l in the use of protecti\ e an(.l
emergenc\' e(.|uipment re(.|uire(.l. The Subcontractor shall submit a complete(.l
Subcontractor Training form (•E.\hibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-
tier Subcontractor emplo\ ee re(.|uire(.l to ha\e this training. The CorUlne(.l Space course
olTere(.l by EG&G w ill be use(.l to accomplish this re(.|uirement for operators not \ et
certifie(.l.
No. Req'int Training EDT Training Objecti\e
Subcontractor
emplo\ee.
T-7 29(TR 1
91o.l7S(
Forklift Training: .A
complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
OSH.A regulation 29CFR 191o. 1 7S(I) requires that ihc Subcontractor shall ensure that each
powere(.l in(.lustrial truck operator is competent to operate a powere(.l in(.lustrial truck safelw
as (.lemonstrate(.l by the successful completion ofthe training an(.l e\aluation specifie(.l. The
Subcontractor shall maintain recor(.ls w hich (.locument the training for each in(.li\ i(.lual
(.lesignate(.l to operate a forklift. The Subcontractor shall submit a complete(.l Subcontractor
Training form ( E.xhibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-tier
Subcontractor emplo\ ee re(.|uire(.l to ha\e this training. The Forklift Training course olTere(.l
by EG&G w ill be use(.l to accomplish this re(.|uirement for operators not \ et certifie(.l.
T-S 29(TR 1
910.147
Lockout Tagout
Training: .A
complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
(!)SH.A regulation 29CFR 191 o. 147 re(.|uires Subcontractors to establish a program an(.l
utilize proce(.lures for airi.\ing appropriate lockout (.le\ ices or tagout (.le\ ices to energ\'
isolating (.le\ ices. an(.l to otherw ise (.lisable machines or e(.|uipment to pre\ent une.\pecte(.l
energization, start-up or release of store(.l energ\' in or(.ler to pre\ ent injurx' to emplo\ ees. It
further re(.|uires that the Subcontractor shall pro\ i(.le training to ensure that the puqiose an(.l
function ofthe energ\' control program are un(.lerstoo(.l by emplo\ees an(.l that the
know le(.lge an(.l skills re(.|uire(.l for the safe application, usage. an(.l remo\al ofthe energ\'
controls are ac(.|uire(.l by emplo\ ees. The Subcontractor shall maintain recor(.ls w hich
(.locument the training for each in(.li\ i(.lual (.lesignate(.l to perform these acti\ ities. The
Subcontractor shall submit a complete(.l Subcontractor Training form ( E.xhibit 2 to this
.Appen(.li.\) for each Subcontractor an(.l Sub-tier Subcontractor emplo\ ee re(.|uire(.l to ha\e
this training. The Lockout Tagout course oirere(.l by EG&G w ill be use(.l to accomplish this
re(.|uirement for operators not \ et certil'ie(.l.
T-9 29(TR 1
926.503
Fall Protection
Training: .A
complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
(!)SH.A regulation 29CFR 1926.5o3 re(.|uires that the Subcontractor shall pro\ i(.le a training
program for each emplo\ ee w ho might be e.\pose(.l to fall hazar(.ls. The program shall
enable each emplo\ ee to recognize the hazar(.ls of falling an(.l shall train each emplo\ ee in
the proce(.lures to be followe(.l in or(.ler to minimize these hazar(.ls. The Subcontractor shall
maintain recor(.ls w hich (.locument the training for each in(.li\ i(.lual (.lesignate(.l to perform
these acti\ ities. The Subcontractor shall submit a complete(.l Subcontractor Training form
No. Req^int Training EDT Training Objecti\e
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
(•E.\hibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-tier Subcontractor emplo\ee
re(.|uire(.l to ha\e this training. The EG&G Fall Protection Course w ill be use(.l to
accomplish this re(.|uirement for operators not\ et certifie(.l.
T-1 1 29(TR 1
910.134
Respirator\'
Protection: .A
complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
29CFR1 91 o. 134 man(.lates that emplo\ers re(.|uiring their emplo\ees to wear respirator\'
protection (.le\elop an(.l establish a written Respirator\' Protection Program. The program
shall inclu(.le me(.lical screening. pulmonar\' function test (PFT). training. an(.l fit testing.
The Subcontractor is re(.|uire(.l to maintain recor(.ls which (.locument all (!)SH.A re(.|uire(.l
acti\ities. The Subcontractor shall submit a complete(.l Subcontractor Training form
(E.xhibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-tier Subcontractor emplo\ee
re(.|uire(.l to ha\e this training.
Subcontractors performing tasks w hich re(.|uire respirator\' protection shall suppl\'
respirators for their personnel.
T-1 2 29(TR 1
910.332
Electrical Training:
.A complete(.l
Subcontractor
Training Form
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
29CFR1 91 0.332 re(.|uires emplo\ ees shall be traine(.l in an(.l familiar w ith the salet> -relate(.l
work practices required by 191o.331 through 1910.335 and NFP.A 7oE. "Electrical Salet>-
Re(.|uirements for Emplo\ ee Workplaces" that pertain to their respecti\ e job assignments.
The Subcontractor shall ensure that all Subcontractor an(.l Sub-tier Subcontractor
emplo\ ees ha\ e ha(.l the re(.|uire(.l training. The Subcontractor shall submit a complete(.l
Subcontractor Training form (•E.\hibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-
tier Subcontractor emplo\ ee re(.|uire(.l to ha\e this training.
T-13 29(TR 1
926.1 lo
.A complete(.l
Subcontractor
Training Form
29CFR1 926.1 lol re(.|uires that emplo\ees shall be traine(.l in an(.l familiar w ith the hazar(.ls
associate(.l with asbestos an(.l the specific proce(.lures implemente(.l to protect emplo\ees
from e.\posure to asbestos, such as appropriate work practices. emergenc\' an(.l clean-up
No. Req'int Training EDT Training Objecti\e
(Training .Appen(.li.\
E.\hibit 2) for each
applicable
Subcontractor an(.l
Sub-tier
Subcontractor
emplo\ee.
proce(.lures. an(.l personal protecti\e e(.|uipment to be use(.l. The Subcontractor shall ensure
that all Subcontractor an(.l Sub-tier Subcontractor emplo\ees ha\e ha(.l the re(.|uire(.l
training. The Subcontractor shall submit a complete(.l Subcontractor Training form
(E.xhibit 2 to this .Appen(.li.\) for each Subcontractor an(.l Sub-tier Subcontractor emplo\ee
re(.|uire(.l to ha\e this training.
Tniiiiiiig .Appendix
Exiiibit 1
C'oiiipeteiit/Designiited Pei'soii .Ackiio>vledgeiiieiit Foi'iii
Definition
.A (;'oiii|)eleiil or De-ieimled Per-oii i- n per-oii vvlio lin- llie nhilih. niid Irniiiiiie lo recoaiize liaznrd- niid llie nulliorih. lo correcl
llieiii.
Responsibility
The de-iainled (;'oiii|)eleiil De-ieimled Per-oii i- re-poii-ihle I'or recoeiiiziiie niid correcl iiie -;il'el> liaznrd-. Tlii- per-oii I in- llie
nulliorih. lo -lop vvork in llie e\eiil ol'mii. poleiMini -nl'eh. concern on llie.ioh -ile. Tlii- rei)re-eiilnli\e i- coii-idered llie coiilnci
per-oii I'or EG.^G Mniineeiiieiil on -nl'eh.-relnled i"Ue- mid -I ml I he on—ile vvlieiie\er llie .Aren or(;'oiii|)eleiic\ i- iii\ol\ ed vviili
llie proiecl.
Tlii- I'onii iiiu-l he coiiipleled h\ llie Suhcoiilrnclor niid llie Suhcoiilrnclor"- de-ieiinled (;'oiii|)eleiil Per-oiii-1. Where n
Suhcoiilrnclor i- re-poii-ihie I'or -uh-lier Suhcoiilrnclor-. il i- iiece"nn. lo iiiniiilniii nddilioiinl de-ieiinled (;'oiii|)eleiil Per-oii- mid
Ton 11- I'or encli nddilioiinl I ier. &ncli Suhcoiilrnclor iiiu-l -uhiiiil llii- coiiipleled I'onii prior I o heeiiuiiiie mi\ vvork on llie proiecl
niid iiiii-l iipdnle il mi> lime lliere i- n dim ice in llie de-i&iinled repre-eiilnli\ e(-i.
Supervisor Acknowledgement
repre-eiiliiie
lin\ e n"ieiied llie helovv li-ied per-oiuiel Io he llie (;'oiiipeleiil De-ieiinled Per-oiii-i iii llie nren- iiidicnied. I nckiiovv ledee llinl II
iiidi\ idiinl I in- heeii lliorouelil\ Imiiied ni id i- experienced in I inznrd recoaiil ion. He -he I in- nulliorih. lo -lop vvork mid correcl
linznrd- in llie e\eiil ol'n poleiilinll> linznrdoii- -iliinlioii- or iiiuiiiiieiil dmicer
Competent/Designated Person(s) Acknowledgement
livvei. llie 111ider-ialed iiidi\ idunli-i. nckiiovv ledee llinl livvei lin\ e heeii ihoroueliK Irniiied mid lin\e experience Io perl'onii llie
dulie- n- n (;'oiiipeleiil De-ieiinled Per-oii in llie nreni-i iiidicnied helovv. Iivvei uiider-lmid llinl livvei lin\ e llie re-poii-ihilih. niid
nulliorih. lo correcl linznrd- mid -lop vvork iii llie e\ eiil orpoleiilinll\ linznrdou- -ilunlioii- or iiiuiiiiieiil dniieer:
-IJVI; of i.'oiiipfifiicy
n. .A-he-lo-|c:().l liil 1. SliiiQ- Ricciiic icMi.m: ic:().:.';i
h. (;'rmie-ICMi.rc: ICMi.lSii.
1 1. ic:().".';.^ i. Lend ic: ().(>:
c. Mnlerinl Per-oiuiel Hoi-I-k. Weldiiie (;'ulliiie ichi.i'^.vi'^-i.:.';.';: ic:()..v';-i
d. Deiiiolilioii ic:().s.';(i. s.'^:. s.'^s. s.'^c 1. Excn\nlioii- Treiiclie-|c:().().';(i. h.'^l. (1^2
e. ScniVoldiiie IcZh.-l.'^ii.-l.'^l. -I.'^-I III. (;'oiiipre"ed .Air ic:().S( i.i
r. Eleclricnl ic:().-hM II. loiiiziiic Rndinlioii ic:()..';.v ichi.hi%
e. Lndder-1 (iZh. 1 n.";.;. i(i()(i 0. (^'ndiiiiiuii ic:(). 112"
li. Fnll Proleclioii 1 <'2()..''n(i. ^{\2. .''H.v |(i()(i p. GeiiernI Snl'el\ Henllli ic:().:(i
C'oiiipeleiil Person
(SieiiHliire)
C'oiiipelPiil Person
(Priiil Naiiie)
.\reH(s) orC'oiiipeleiio
(eiiler leller iiiclicHliiic compeleiio)
DHle
Tniiiiiiig .Appendix
Exiiibit 2
Tnilniiis .Acknowledgement Form
Requirement
The (iccupniioiinl Snl'eh. mid Henllli .Adiiiiiii-lrnlioii K iSKA i reeulnlioii- require llinl eiiiplo\ ee- he Imiiied lo perl'onii cerlniu
ncli\ ilie-. Tlii- Irniiline \nrie- dei)eiidiiie on llie ncli\ ih. Soiiieliiiie- n vvrilleii proermii. vvliicli coiiiplelel\ deliiienle- llie
proce—e- mid procedure- lo he u-ed I'or llie Irniiline niid le-liiie. i- required. In oilier cn-e-. llie required Irniiiiiie i- luideliiied mid
iiin\ -iiiipl\ he \erhnl iii-lniclioii or eii-uriiie llinl vvrilleii iii-lniclioii- lin\ e heeii rend. In -oiiie cn-e-. lliere nre requireiiieiil- lo
pro\ ide rel're-her Irniiiiiie iu-unll\ muiunlK i.
Responsibility
The Suhcoiilrnclor lin- llie re-poii-ihilih. lo he nvvnre ol'nll npplicnhle Irniiiiiie requireiiieiil- -pecilled h\ (iSKA. Furllieniiore.
llie Suhcoiilrnclor lin- llie re-poii-ihilih. lo eii-ure llinl llieir eiiiplo\ee- nre nvvnre ol'llie required Irniiiiiie. Iin\e recei\ ed nil ol'lhe
required Imiiiiiie. Tlii- include- eii-iiriiie Uml llie Irniiiiiie i- curreiil niid dociuiieiilnlioii ol'lhe Irniiiiiie i- iiiniiilniiied n- required
h> llie npplicnhle reeulnlioii. Tlie employee SIIHU IIOI be Hllo»ecl lo per Tor in HII> Hc1i\il> Tor »liicli llie> Imve iiol IIHCI Uie
required IrHiiiiiic HIICI IIIHI IrHiiiiiic iiiiisl be nirreiil.
Tlii- I'onii iiiu-l he coiiipleled h\ llie Suhcoiilrnclor mid llie Suhcoiilrnclor"- eiiiplo\ee- vvlio vvill he perl'onnine llie ncli\ ilie- I'or
vvliicli (iSKA—pecilled Irniiiiiie i- required. Wliere n Suhcoiilrnclor i- re-poii-ihie I'or -uh-lier Suhcoiilrnclor-. llie Suhcoiilrnclor
-linll eii-ure llinl nil -ucli -uh-lier Suhcoiilrnclor- mid llieir eiiiplo\ee- coiiiplele llii- I'onii. Encli Suhcoiilrnclor iiiu-l -uhiiiil llii-
coiiipleled I'onii prior Io heeiiiiiiiie nin. vvork on llie proiecl: he -he iiiii-l iipdnle il mn. lime lliere i- n climiee in llie per-oiiiiel
n"ieiied lo perl'onii llie de-ieiinled In-k-.
Supervisor Acknowledgement
rei)re-eiiliiie
lin\ e n"ieiied llie rollovviiie per-oiiiiel lo perl'onii ncli\ ilie- llinl require -pecilk (iSKA Irniiiiiie in llie nren- iiidicnied. I
nckiiovvledee llinl llii- iiidi\ idiinl lin- heeii lliorouelil\ Irniiied in nccordmice vviili Uie requireiiieiil - ol'lhe npplicnhle (iSKA
reeulnlioii-.
Employee(s) Acknowledgement
I ivvei. llie luider-ieiied iiidi\ idunli-i. ncknovv ledee llinl I ivvei lin\e heeii lliorouelil\ Irniiied mid lin\e experience Io perl'onii llie
dulie- in llie nren(-i iiidicnied hehm:
^ir<i of Truiiiiiiv
Hnznrd- (;'oiiuiiiuiicnlioii |Chi. i:("i T-l 1 Re-pirnlor\ Proleclioii 1 c h 1.1 .^-1
T-() (;'oiiruied Spnce-|CMi.l-l(). |c:().:iihii()i T-i: Eleclricnl |Chi..vi:
T--Forklill (ipernlion icMi.rsih. ic:().()(i: T-I.i .A-he-lo-|c:().l Mil
T-S Lockoul Tneoul 1 c h 1.1 -1" T-N Lend ic :().(>:
T-O Fnll Proleclioii ic:()..';(i.^ T-l.'; (^'ndiiiiiiiii ic:().i 12"
T-hi Fir-I .Aid ichi. i.'^i. 1 (':()..';(1 T-U) Povvder (ipernled Tool-i'':()..i(i:ieii 11
Trniiied Per-oii iSieiinlurei Trniiied Per-oii iPriiil Nniiiei .Areni-i orTrniiiiiie
ili-l npplicnhleT =-i
Dnie
4.0 IMPLEMENTATION OF THE TRAINING PROGRAM
Training operations for the EDT project will begin prior to systemization, continue through it,
and end when site operations commence. The Training Supervisor will schedule and manage
training activity prior to and during site activity. Any replacement personnel will be required to
'catch up' with the staff on-site via a similar gap analysis and tailored plan.
All EDT site personnel will be required to meet the minimum site access standards required in
the EDT SOW, including the elements of site-specific training required by SOW Appendix B,
Badging and Site Access; and Appendix E, Training and Certification Requirements. Operators,
site supervisors, and site management personnel will be required to complete the initial phases of
the training program prior to systemization.
The following information and documents shall be maintained and available on-site at the EDT
Control Room:
• Job title for each position at the EDT facility.
• Roster showing the names ofthe employees filling each job.
• A written job description for each job title.
• A written description of the type and amount of EDT, site access, and other training given to
each person named.
• Records that document the successful completion ofthe training and experience required for
each person named.
• The training records and documents shall be kept at least until closure ofthe facility.
• Training records on former employees shall be kept at least three years from the date the
employee last worked at the facility. Copies will be held by Versar© as directed. Some
records may require longer retention times.
• The Training Plan shall be maintained, and made available for access, by the EDT
subcontractor after closure.
24
.\PPEIVDI\ 1
CB.\RR TR.\IN1NG REQl IREMENTS
CBARR TRAINING REQUIREMENTS
Chemical Biological Applications & Risk Reduction (CBARR) operations at Edgewood
Chemical Biological Center (ECBC) provides in-house training as a baseline for deployment of
certified chemical and explosive operators to work sites in the continental United States
(CONUS) and outside (OCONUS).
The CBARR provides staffing of Chemical Personnel Reliability Program (CPRP)-certified
personnel with training in chemical agent handling, safety and health, explosive operations, and
other tailored training modules depending on the need.
Each certified operator will have the following basic coursework documented prior to the
commencement of DAVINCH™ EDT operator training:
• PRP-specific training, hi accordance with AR 50-6, all CPRP personnel will have completed
core safety, security, and emergency training, which will be documented per local Standard
Operating Procedures, plans, and regulations, including requirements of 2-16, Technical
Proficiency; and 10-2, CAIRA Exercises, as appropriate.
• Agent-handling training and certification.
• OSHA 40-hour training and annual certification.
• Explosive training, including Anmiunition, Arms, and Explosives (AA&E).
• Related traimng in the any areas of technical proficiency as required (e.g., forklifi:
operations).
• Site-Specific Training per Section 3.
Prior to deployment, the training records, curriculum plan, and traimng certifications issued by
instructors for the CPRP elements of the proposed operators and supervisors will be reviewed by
Versar© and forwarded to EG&G for approval.
26
.\PPEIVDI\ 2
S.UIPLE EDT TR\INER RESITVIES
27
PROPOSED TITLE/POSITION: Trainer. Supervisor and Chemical Operations Supen isor
Name:
E(.lucation (^ualiUcations: B.S.. Chemistry. South Carolina State Uni\ersity. 1967
MS.. E(.lucatiorL South Carolina State Uni\ ersit\'
US .Amiy Training Courses (chemical surety. US .Army Ranger Course.
NBC training)
Present Position in (!)lTeror's
Com pany:
\'ice Presi(.lent. Chemical (!)perations
Rele\ ant E.\perience: Mr. o\ ersees all chem ical surety operations at \ERS.ARiCi.
inclu(.ling the in-house surety laboratoiy. operations in\ ol\ ing kSL EDT
o\erseas. operations at Dugway Pro\ing Groun(.l an(.l Non-Stockpile
(.lemil programs. He pro\i(.les training to in-house an(.l contractor
personnel. .A(.l(.litional (.luties inclu(.le lor o\ ersight ol" the training an(.l
super\ ision of technicians in the han(.lling of materials an(.l samples
e.\pose(.l to chem ical an(.l biological agents. an(.l monitoring of all
laboratoiy operations for compliance with local, state an(.l re(.leral
regulations. The following is a partial list of the supporte(.l key projects.
Tooele Cheinic;il .\geiil Desl ruction FiiciliK EDT Project.
Responsible for chemical operations, monitoring planning an(.l technical
support to the EDT program.
K;iiid;i Hiirbor Cheinic;il Destruction Progriim. Responsible for
o\ ersight of MTNIC.AMS operations, training personnel for operations at
kan(.La in\ol\ ing monitoring. an(.l management ofthe project.
Cheinic;il Deinilit;iriz;itioii on the Non-Stockpile Cheinic;il M;iteriel
Progriim. for which GE(!)MET was responsible for mobile analytical
laboratory operations, air monitoring. associate(.l chemical surety materiel
acti\ ities. an(.l other rele\ ant laboratoiy ser\ ices:
Iinpro\ed To\icologic;il .\gent Protecti\e Suit Progriim an(.l STEPO
Program-Natick:
Non-Stockpile Progriim - Chemical agent analysis of en\ ironmental
samples from Spring \'alley site in Washington. DC an(.l biological agent
analysis of samples from a site at Ft. Detrick. US.ACE
N'lirious .\ssigninents, US .\rmy Cheinic;il Corps. During ser\ ice in
the .Army. ac(.|uire(.l more than 23 years of experience in NBC matters
inclu(.ling a wi(.le range of chemical surety relate(.l training programs. .As
Chief. Chem ical-Biological Di\ ision. U.S. .Army Chem ical School.
super\ise(.l an instructor staff of S.^ with responsibility for training
sokliers in chemical warfare an(.l chem ical an(.l biological (.lelease:
(.lirectly super\ ise(.l the training of chemical laboratory specialists in the
2S
school's chem ical laboratoiy. .A(.lm inistere(.l the establishment an(.l
monitoring of NBC contain ination sur\ i\ ability criteria for the
Department of the .Army to ensure the incoqioration of NBC materiel
sur\ i\abilit\' criteria in the (.lesign. ac(.|uisition an(.l procurement process
for new items of .Army materiel: an(.l to ensure the e\ aluation of non-NBC
sur\ i\ able fiel(.le(.l e(.|uipment for retrofit of sur\ i\ ability characteristics.
Personally e\aluate(.l an(.l formulate(.l solutions for high \ isibility DoD
problems pertaining to chem ical stockpile (.lem ilitarization. chem ical
stockpile retrogra(.le. preparation of supplemental en\ ironmental impact
statement which supporte(.l the (.lecision to buiki binaiy chem ical
pro(.luction plants at Pine Bluff .Arsenal, preparation an(.l submission of
the presi(.lential certification to the congress for pro(.luction of the 1 .^.^ mm
binary artillery projectile. an(.l G.\0 (.|uestions about the binaiy chemical
program.
PROPOSED TITLE/POSITION: Trainer. D.A\TNCHT^' Operations
Name:
E(.lucation (Qualifications: Msiting Student 1991 St.Catherine's (\illege. CKford
M.S. 19S9 Mechanical Engineering Kyoto Uni\ ersity. .lapan
B.S. 19S7 Mechanical Engineering Kyoto Uni\ersity. .lapan
First Class E.\plosi\ es Control (!)lTicer
Present Position in (!)lTeror's
Com pany:
Rele\ ant E.\perience:
Manager at Engineering Department. Nuclear an(.l CWT) business unit
Mr. ^^^^1 has o\er 1.^ years of experience with hea\y engineering
associate(.l with (.letonation chambers, (.lonor e.\plosi\e charge analysis,
structural engineering, research an(.l (.le\elopment for fatigue an(.l (.lamage
evaluation ofthe EDT system, test and evaluation ofthe D.A\TNCH'r"^"
system for (.letonation an(.l simulant surrogate testing, (.lonor charge (.lesign.
an(.l acti\ate(.l carbon filtration. He is also a First Class E.\plosi\es Control
(!)lTicer (Japan). an(.l hokIs a Master's Degree in mechanical engineering
from k\oto Uni\ersit\'. .lapan. He trains operators an(.l engineers in
D.AMNCHT" technology.
.liipiinese Cheinic;il \\ eiipons Destruction Project, K;ind;i, .J;ip;in - Mr.
^^^^1 ser\ es a lea(.l applications engineer for the EDT system at kan(.la.
The system has safely an(.l successfully (.lestroye(.l appro.\imately 600
chemical munitions containing HD an(.l L using \acuum-assiste(.l (.letonation.
The munitions were reco\ere(.l from the sea using a container system
(.lesigne(.l to keep the munition at the appropriate pressure an(.l temperature to
ensure that they are stable when brought to the surface. Mr.
(.lesigne(.l an(.l impro\ e(.l (.lonor charge using gel-base(.l e.\plosi\ es to (.lestroy
chemical bombs by controlle(.l (.letonation. He was also in charge of
nuxlelineand ensuring that the technical aspects of (.letonation were applie(.l.
Mr. ^^^^1 also manage(.l (.letonation tests on \arious chemical munitions
using control le(.l (.letonation technology. He also (.lirecte(.l the
D.AMNCH"^"^" R&D work on detonation chamber, including fatigue
(.lamage e\ aluation using strain measurement an(.l finite element analysis of
the structure.
Incinenitors ;ind melting furiKices ;ind R&D: Mr. pro\ i(.le(.l
(.lesign an(.l R&D engineering for (.le\elopment of a sewage slu(.lge
incinerator an(.l melting fumace. R&D work inclu(.ling acti\ ate(.l carbon filter
technology to remo\ al of (.lio.xins from e.Khaust gas. an(.l ultrasonic heat
treatment for sewage slu(.lge.
En\'ironinent;il R&D: Mr. pro\'i(.le(.l engineering an(.l technical
support for projects rele\ ant to en\ ironment reco\ ery. He also set up training
re(.|uirements an(.l coursework for personnel for better perfomiance in R&D.
30
PROPOSED TITLE/POSITION: Tminine Engineer. D.A\TNCHT"
Name:
E(.lucation (Qualifications: M.S. 19S4 Mechanical Engineering Tokashima Uni\ ersity. .lapan
Thermal Energy Manager
First Class E.\plosi\ es Control (!)lTicer
Present Position in (!)lTeror's
Com pany:
Rele\ ant E.\perience:
Manager at Engineering Department. Nuclear an(.l CWT) business unit
Mr. ^^^^^ has playe(.l a significant role in (.lesigning an(.l constructing
power plants an(.l heating an(.l cooling plants as a project engineer an(.l
manager. He has been in charge of (.lesign process at the Chemical
Weapons Destruction Project in kan(.la. .lapan. He was instrumental in
traasfeming the technology an(.l training at Poelkapelle. Belgium.
Cheinic;il \\ eiipons Destruction Project, K;ind;i, .J;ip;in. As a Process
Designer. Mr. is in charge of process (.lesign. He is re\ iewing
new e(.|uipment for the off-gas treatment facility being (.lesigne(.l for
TH.ALES. (•SEC(!)I.A Project) an(.l con(.lucting research on the possible
miniaturization an(.l simplification of the off-gas treatment process by
applying a Cokl Plasma Furnace.
R&D of Orr-G;is Tre;itinent. Mr. playe(.l a key role in the
1st test off-gas treatment test of Cokl Plasma at US.A an(.l the 2n(.l test
Chem ical agent (.lestruction test of Cokl Plasma at GE(!)MET. Mr.
^^^^^1 manage(.l the off-gas treatment test on new technology using
Cokl Plasma. He checke(.l the (.lecomposition rate of Cokl Plasma fumace
by mL\e(.l gas of Mustar(.l (HD) an(.l Lewisite (L). He also (.lesigne(.l
compact an(.l simplification ofthe off-gas system.
Cogener;ition Fiicilit> \\ ork for Diiiiin Pliint, D;ii;in, .J;ip;in. As Project
Manager Designer. Mr. is responsible for playing numerous
roles, from in\ol\ement in preliminaiy (.lesign to the construction,
commissioning an(.l maintenance of a cogeneration facility for a plant, as
well as (.lealing with the plant licensing with go\ ernment authorities.
Rese;irch Connected to Co;il FK .\sh, Kobe, .J;ip;in. Mr. was
a Researcher with responsibility for engaging in R&D in the
manufacturing of an artificial an(.l lightweight aggregate from coal lly ash:
stu(.lying ways to promote the elTecti\ e use of coal lly ash in concrete an(.l
tiles \ ia electrostatic separation: an(.l (.lecarbonizing coal lly ash by
electrostatic separation an(.l assessing those mo(.lifie(.l coal lly ash.
Development of ii Sewiige Giis Pretreiitment Unit, Kobe, .J;ip;in. Mr.
^^^^^1 ser\'e(.l as a Researcher Project Engineerwith responsibility for
establishing a sustainable, stable operation for cogeneration using gas
engine: (.le\ eloping a sewage gas pretreatment unit to remo\e minute
amounts of hazar(.lous elements in sewage gas: an(.l (.lemonstrating the
operation of cogeneration technology.
PROPOSED TITLE/POSITION: EDT Safetv Conlrol Manager
Name:
E(.lucation (Qualifications: Tottori Prefectural High School in ^'onago
Diploma of In(.lustrial Chemistry
E.\plosi\ e Control (!)lTicer
Special In(.lustrial W aste Manager
Recei\e(.l training an(.l practice with respect to the OCW (.lestruction
con(.lucte(.l bv (.IstI ( Defence Science an(.l Technoloi:\' Laboratory'
Present Position in (!)lTeror's
Com pany:
Rele\ ant E.\perience:
Safety Control Manager for Chem ical W eapon. Kobe Steel
Mr. ^^^1 is an E.\plosi\ es Control (!)lTicer with more than 4.^ years
experience in the fiekl. He has recei\ e(.l training from an(.l perfonne(.l OCW
(.lestruction in accor(.lance with practices establishe(.l by the Defence Science
an(.l Technology Laboratoiy. His career highlights inclu(.le (.lirecting an(.l
controlling the safet\' of (.lestruction operations at CWT) facilit}' an(.l marine
operations.
Chemiciil \\ eiipons Destruction Project, K;ind;i, .J;ip;in. On this project.
Mr. ^^^1 (.lirecte(.l an(.l controlle(.l the safety aspects of (.lestruction
operations at a CW'D facility an(.l marine operations unco\ering an(.l
reco\ering appro.\imately 600 okl chemical weapons. His (.luties also
inclu(.le(.l (.lirecting the transport ofthe bombs to CWT) facilit}' an(.l interacting
with (.lomestic officers. He also assiste(.l in the transportation of okl chemical
weapons foun(.l at kan(.la port to Sasebo Maritime Self-Defense Force for
in\ estigation of munitions.
Beer Bottled Chemic;il .\gent Reco\er\7Destruction ;ind Contiiminiited
Soil Decont;imin;ition Project, S;imuk;iw;i, .J;ip;in. Mr. was
(.lesignate(.l Project Manager an(.l Safety Control Manager, with responsibility
for reco\ering an(.l (.lestroying appro.\imately Soo of beer bottle(.l chemical
agent foun(.l un(.lergroun(.l. He also (.lecontaminate(.l soil contaminate(.l by
chemical warfare agent (.le\ elope(.l by Imperial .lapanese .Army.
Inspection of .\b;indoned Chemic;il \\ eiipons, \\ ulnin, Chiini. Mr.
^^^1 inspecte(.l aban(.lone(.l chemical weapons in China an(.l con(.lucte(.l
seale(.l packaging for those munitions.
Chemic;il \\ eiipons Destruction Project, Luke Kussh;iro, .liipiin. As
(.lesignate(.l Safety Control Manager for the chemical weapon. Mr.
monitore(.l the safe an(.l successful (.lestruction of 26 chem ical munitions.
Fertilizer Plant in se\ eral foreign countries. (!)\ erseas. During a posting in
Zambia. supporte(.l the construction an(.l operation of a fertilizer plant. .Also
ser\ e(.l as Section Chief in Singapore for the construction of polypropylene
plant.
Employment Histoiy 2()().';-Present: CWT) Project in kan(.La
2001-200.';: Kobe Steel. Ltd. Nuclear and CW D Business Units
196S-2000: Kobe Steel. Ltd. Industrial Machineiy Plant Department
(Oerseas)
1964-1967: Kobe Steel. Lt(.l. Engineering Department
1961-19cS3: Kobe Steel. Ltd. Industrial Machineiy Plant Department
(•(!)\erseas)
.\PPENDI\ 3
KOBE STEEL TR\IN1NG PL.\N FOR EDT
34
SRD ANGI£
PROJECTION
i3
#
nnaioN NOTE
vm
TTJA
NONE
_ Projects Department Engineering Section
0. MO.
1-09630620
CWD PROJECTS DEPARTMENT
THE DliAWIKG(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF KOBE STnULTD. THEY SHAU. NOT BE DISCL0SED,REPRODUCED OR USED.IN
ANY MANNER WrTHOUT THE PRIOR WRfTTEN CONSEHT OF KOBE STEELLTD.
DAVINCH SYSTEM
TOEDT SERVICES
Process Flow Diagram (l)
(Main Process)
PF3400 100
I I
DB31 -EA101<S> -I I I I I I L
1/1 0 I ' I I ' I ' I I I I I I I I I I I I I I I I I
I/a 0 s 10 IB
111111111111111111111
1/5 0 « 10 IS to
3RD ANGLE
PROJECTION
A it
(PM4)(PM5)(^
CA CA CA
Al Al Al
5201A 5202A 5203A
HVAC
M520A
Unit E3r
CA CA CA
Unit CI Unit C2 Unit D
Detonation Containment
(2066 m^) *2
Unit A
Al Al Al
5201C 5202C 5203C
—i—
HVAC
M520C
Ventilation
-0.1—0.5 inchAq
(-2.54—12.7 mmAq)
Process ^
"cA
Al
5204
PMI^
CA
Al
5401
<§)
<§)
Stack
S540
CWD PROJECTS DEPARTMENT mmto CWD PROJECTS DEPARTMENT
THE DRAWING(S] AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF KOBE STEEULTD. THEY SHAU. NOT BE DISCLOSED.REPRODUCED OR USED.IN
ANY MANNER WTTHOUT THE PRIOR WRIHEN CONSENT OF KOBE STEELLTD.
nnsioMxon ENGINIKBING DCPARTMENT
NONE
_ rejects Department Engineering Section
0. HO.
1-09630620
DAVINCH SYSTEM
TOEDT SERVICES
Process Flow Diagram (2)
(Ventilation)
JOB NO.
PF3400
AREA
100
DRATHNG NO. ML
DB31 -EA102<^
1/1 0 I ' I ' I ' I ' I ' I 1/3 0
I I I j I I I
10
j 111111111 j 111111
1/5 0 5 10 15
3RD ANGLE
PROJECTION
Valve and Attachment Synnbo
Symbol Name
(PM) Process Monitoring Point
(so) Samp inq Point
.^^Area^Jyl^jnltorlng
Flexible Tube TFX) )
(Rubber Hose) (HS) j
Glove Valve (T)
Check Valve (C)
Ball Valve (B)
Butterfly Valve (W)
Relief Valve (R)
03 Ferrule (FE)
Control Valve (FV,TV)
ON-OFF Valve (HV)
Pressure Reducing Valve (PV)
Regulator (RG)
Y—Type Strainer (SR) m \M Solenoid Valve (SO)
Silencer (SL)
FC(orFa"^NC)
FC:Air Fail Closes Power Fail Close
FO:Air Fail Opens Power Fail Open
NC:Air Fail Locks Power Fail Close
/ Air Intake Filter (AF)
Converter (SC)
Flexible Pipe (FP)
Pressure Relief Damper (PRD) \
\ -EE-Cuplo (CP) ]
O Field Indication
Control Room Indication(DCS)
e Field Panel Indication
INV Inverter
Note)
Open and close limit switches are applied for
each ON-OFF valve.
^ ft
Piping Symbo
Exemplar
1"-OG-001-CS1-H3
Piping Size—Fluid Symbol—Serial Nunnber—Piping Class—Insulation Class
Fluid Synnbo
Symbol Name
OC Off-Gas
VT Ventilation
WW Waste Water
DR Drain
GO Oxygen
ON Nitrogen
lA Instrument Air
CW(S or R) Cooling Water(S:Service , R:Return)
PC Propane Gas
IW Industrial Water
CA Cooling Air
PA Process Air ,Intake Air
NOH NaOH
Piping Class
Symbol Name
CS1 ASME B36.10 ,A53 typeF ,A53 Gr.A typeE
CS2 ASME B36.10 ,A53 typeF(GLV) ,A53 Gr.A typeE(GLV)
CS3 ASME B36.10 ,A53 typeF(GLV) .Galvanized Steel Sheet (Spiral Duct)
CS4 ASME B36.10,A135 Gr.A
CSS ASME B36.10.A135 Gr.A
CS6 ASME B36.10 ,A53 typeF ,A135 Gr.A + Epoxy Lining ANSI 150LB SCH 10 RJ
CS7 ASME B36.ro ,A53 typeF ,A135 Gr.A + Epoxy Lining ANSI 600LB SGH 40 RJ
S2 ASME B36.10 .A312 Gr.TP304 for Oxygen Line
S3 ASMEB36.10,A312Gr.TP316L
nsu ation C ass
Symbol Name
H1 Thernnal Insulation (Below 100 degrees centigrade)
H2 Thermal Insulation (Below 150 degrees centigrade)
H3 Thermal Insulation (Below 200 degrees centigrade)
H4 Thermal Insulation (Below 250 degrees centigrade)
H5 Thermal Insulation (Below 300 degrees centigrade)
PP Personal Protection
C1 Prevention of Freeze & Dew Gondensation
SP Noise Reduction
:Hazardous Area
» Preparation Container
(GlassIDivl)
" Preparation Area
(ClassIDiv2)
° Detonation Containment
(Class! Div2)
° Off—Gas Treatment Area
(GlassIDiv2)
Unit
/ / / /
Design Progress 7/ 8
2010 Iwasaki fB Ueda /^ ^tayams Hayashi Ueda Hayashi
<i> Design Progress 5/21
2010 Iwasaki
5/
/21 Ueda [atayame Hayashi Ueda
5/
/21 Hayashi
<s> Design Progress 4/2
2010 Iwasaki
4/
/2 Ueda % [atayams Hayashi % Ueda Hayashi
First issue 2/25
2010 Sasaki /25 Iwasaki /25 Ueda /25 Hayashi /25 Ueda /25 Hayashi
BEV.
NO. REVISION NOTE
DESIGNED CHECKED APPROVED REVIEWED BEV.
NO. REVISION NOTE ENGINEERING DEPARTlfENT
sous NONE
S^Prqjects Department
Engineering Section
NAME
0. NO.
1-09630620
T.NO.
•1013 Technology Park Dr. Qlen Allen. Virginia 23069
Phone: [phone]
ANDAttOClATiS FaX: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USED.IN
ANY MANNER WITHOUT THE PRIOR WRIHEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(1)
P&ID Explanatory notes
JOB NO.
PF3400 J L
AREA
100
I 1—.
DRAlflNG NO.
DB33 -EA001<^ J 1 I I I I L I ' I M M • I ' I I I I I t I I I I I I I I M I |nn|iin|nn|nn|
SRD ANGLE
PROJECTION
- - t-H - - 'p
141 Handlifter B
x2
170 Cylinder Cart Ml40 Handlifter A
x3 Changing
Room
* IS
^ it
<8>
<S>
REV.
NO.
Design Progress
Design Progress
First issue
REVISION NOTE
5/21
2010
4/2
2010
2/25
2010
Iwasaki
Iwasaki
Sasaki
DESIGNED CHE(XED
^^21
^25
Ueda
Ueda
Iwasaki ^25
2 [atayama /2
Ueda
21 [atayami ^i Hayashi
^25
Hayashi
Hayashi
APPROVED
ENGINEERING DEPARTMENT
^21
^25
Ueda
Ueda
Ueda
'^21
^25
Hayashi
Hayashi
Hayashi
REVIEWED
SCALE
NONE
^(^^Projects Department
Engineering Section
NAME
0. NO.
1-09630620
T. NO.
1013 Technology Park Dr.
Qlen Allen, Virginia 23069
Phone: [phone]
ANDAtfOCIATIt Fax: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USED.IN
ANY MANNER WITHOUT THE PRIOR WRITTEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(2)
Area 10 Pre Treatment
JOB NO.
PF3400 ' ' ' • ' AREA
100
DRAWING NO.
DB33 -EA002<|>
I ' I ' I
1/10 1 2 1/S 0
II I I I I M I I ( M I I
5 10 15
|n(l|MII|MM|MII
1/5 0 5 IG i5 r
SRD ANGLE
PROJECTION
It
strain Monitoring System DESTINY
M230 M231
GRAND
M232
Networi<
Detonation Containnnent
Lid and Deck Operation Unit E CAD
M211 M250
Hand Lifter A
MUO
Dust Capture Recipient
M240
Hydraulic Punnp
P211
Waste Handling Eorklift
M216
- o ppg
o
Drum Porter
M215
F410
Sheet (7)
F320
Sheet (5)
C810
Sheet(9)
Z850
Sheet(9)
Z870
Sheet(9)
Ventilation
Sheet (8)
Air Shower
Room
(AMS)
koKo^
Forklift
M120
Air Shower
M160
REV.
NO.
Design Progress
Design Progress
Design Progress
Design Progress
First issue
REVISION NOTE
7/ 8
2010
6/14
2010
5/21
2010
4/2
2010
2/25
2010
Iwasaki
Iwasaki
Iwasaki
Iwasaki
Sasaki
DESIGNED CHECKED
^21
'25
Ueda
Ueda
Ueda
Ueda
Iwasaki
8 [atayams
14 [atayama
'25
21 [atayam8/2i
Ueda
Hayashi
Hayashi
2 [atayama / 2 Hayashi
Hayashi
25|Hayashi
APPROVED
ENGINEERING DEPARTMENT
'21
'25
Ueda
Ueda
Ueda
Ueda
Ueda
'21
'25
Hayashi
Hayashi
Hayashi
Hayashi
Hayashi
REVIEWED
SCALE NONE
Projects Department
Engineering Section
NAME
0. NO.
1-09630620
T. NO.
•1013 Technology Park Dr.
H H M Qlen Allen, Virginia 23069 • Phone: [phone]
ANDAfSOCIATiS Fax: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USEDJN
ANY MANNER WITHOUT THE PRIOR WRITTEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(3)
Area 20 Detonation
JOB NO.
PF3400
I L_J ' '
AREA
100
DRAWING NO.
DB33 -EA003^
J I J I I L
1/1 0 I ' I ' I ' I I ' I
4 5
I 111 I I
i/3 0 6 I
10 15
I IIII I I II I I II II I II II I
i/5 0 6 10 20
1/S 0
III1111IIIIIII11II11
l/fi 0 6 10 le 20
SRD ANGLE
PROJECTION
^ ft
Unit B
C810 >
5/4"-IA-8Q9-CS2
*1
csj
1/2"-IA-809-CS2
Sheet(9)
B348
-Dech-BVC01
CNI
Z860
oo
D-3/8"-IA-5Q4-CS2
12"-CA-314-CS4-PP
12"-CA-306-CS4-PP
'ATM
'ATM
NOx CO O2 SOx HCL Dust
Al
3801
Al
3802
Al
3803
Al
3804
Al
3805
Al
4501
Sheet(9)
P33QA/B >ll^
Sheet(5)
Z870
Sheet(9)
AT-4501
Sheet(7)
Sheet(7)
<8>
<3>
<8>
REV.
NO.
Design Progress
Design Progress
Design Progress
Design Progress
First issue
REVISION NOTE
7/ 8
2010
6/14
2010
5/21
2010
4/2
2010
2/25
2010
Iwasaki
Iwasaki
Iwasaki
Iwasaki
Sasaki
DESIGNED CHECKED
'21
'25
Ueda
Ueda
Ueda
Ueda
Iwasaki
^atayama
14 [atayama
'25
21 [atayama
[atayama
Ueda '25
Hayashi
Hayashi
21 Hayashi
Hayashi
Hayashi
APPROVED
ENGINEERING DEPARTMENT
'14
'21
'25
Ueda
Ueda
Ueda
Ueda
Ueda
'21
'25
Hayashi
Hayashi
Hayashi
Hayashi
REVIEWED
SCALE
NONE
BY
rejects Departnnent
Engineering Section
NAME
0. NO.
1-09630620
T. NO.
1013 Technology Park Dr.
Qlen Allen. Virginia 23069
Phone: [phone]
ANDAffOClATif Fax: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USEDJN
ANY MANNER WITHOUT THE PRIOR WRIHEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(6)
Area 30 Off Gas Treatment(2)
JOB NO.
PF3400
I I I I I
AREA
100
DRAWING NO. mm DB33 -EA006<§>
I ' I
i/i 0 i 1/3 0
I I I i I I I I I I I I I I
3 Id 1/6
I I I I I 11 I I I 11 I I I I
30 15 "I
SO
I ll ' I '
1/1G 1 2
I I I I I I I I I I I I I I I
i/3 Q 5 10 15
I I I I I I I I I I I I i I I I I I I I
1/5 0 5 in m m
3RD ANGLE
PROJECTION
^ if
B450
HS 01
Sheet(7)
10"-Vr-516-CS3
18"-\Ar-502-CS3-H1
18"-Vr-503-CS3-H1
18"-Vr-504-CS3-H1
<S>
REV.
NO.
Design Progress
Design Progress
Design Progress
Design Progress
First issue
REVISION NOTE
7/ 8
2010
6/14
2010
5/21
2010
4/2
2010
2/25
2010
Iwasaki
Iwasaki
Iwasaki
Iwasaki
Sasaki
DESIGNED CHECKED
'14
'21
'25
Ueda
Ueda
Ueda
Ueda
Iwasaki
8 [atayama / B Hayashi / B
'14 [atayama
'25
21 [atayama
2 [atayama
Ueda '25
Hayashi
21 Hayashi
Hayashi
Hayashi
APPROVED
ENGINEERING DEPARTMENT
'21
'25
Ueda
Ueda
Ueda
Ueda
Ueda
'21
'25
Hayashi
Hayashi
Hayashi
Hayashi
Hayashi
REVIEWED
SCALE NONE
Projects Department
Engineering Section
NAME
O.NO.
1-09630620
T.NO.
12"-Vr-405-CS3
o o
LO
(PMI 3)
CA
Al
5204
"1
(PM14)
CA
Al
5401
B541 CP-501
BVCOli
3/8"-(
4". B542 CP-502.
4" B543 CP-503/
1"-CS1
Stack
S540
•1013 Technology Park Dr.
H H B Allen, Virginia 23069 • Phone: [phone]
ANDAfSOCIATIf Fsx: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCL0SED,REPR0DUCED OR USEDJN
ANY MANNER WITHOUT THE PRIOR WRITTEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(8)
Area 50 Containment & Ventilation
JOB NO.
PF3400 I I I I
AREA
100
DRAWING NO.
DB33 -EA008<^ J L
1/1 0 I M M • I M
1 S 3 4 5
I I I I I I I I I I I I I I I I
1/3 0 5 10 15 1/5 0
I I I I I I I I I I I I I I I I I
5 10 m so
1"-IW-835-CS2 SRD ANGLE
PROJECTION
^ it
Tank Truck Area"CHAMBER Sheet(3)
Csl
1 1/2"-IW-831-CS2 ^ —^ 1X1-
For the chamber
and floor cleaninq
BVC01
Unit 0
l"-IW-834-CS2
F270 Make-Up
B83Sf!vCP-815
2"-G0-873-S2
l"-GN-854-CS2 R220
1"-IA-804-CS2 R220
1/2--IA-805-CS2 ,^3^^
BVC01
1"-IA-813-CS2
1"-GN-857-CS2 M260
1"-IW-836-CS2 B837
BVC01
/floor cleaning
Unit A Sheet(5)
1/2"-GN-855-CS2 P330 A/B
1/2"-GN-856-CS2
1 1/2"-CWR-305-CS2
1 1/2"-CWS-822-CS2
F320
P330 A/B
P330 A/B
1 "-IA-806-CS2
1/2"-IA-807-CS2
P330 A/B
1/2--IA-808-CS2 B^9^^^ ^^^^^
F320
BVC01
Unit B Sheet(6)
1"-G0-874-S2
1"-PG-861-CS5
R360 A/B
1/2"-IA-809-CS2
R360 A/B
1/4"-IA-814-CS2
R360 A/B
1/2"-IA-815-CS2 g^OpQ
D373
1"-IW-833-CS2 B836 BVCOI,^
~"'^BVC01 <§>
D373,V363 •• ke-Up
Unit C2
1/2"-IA-810-CS2
Sheet!
FOR INST.
BVCOl
Unit D Sheet(7)
Air Connpressor Unit
C810
(110mVhx0.69MPa) /
nstrument Air
Storage Tank
V812
1/2"-IA-811-CS2 F420
1/2--IA-812-CS2 g^^pQp INST.
BVC01
Plastic Drum Plastic Drum Plastic Drum
<s>
REV.
NO.
Design Progress
Design Progress
Design Progress
Design Progress
First issue
BEVISIONNOTE
7/ 8
2010
6/14
2010
5/21
2010
4/2
2010
2/25
2010
Iwasaki
Iwasaki
Iwasaki
Iwasaki
Sasaki
DESIGNED CHECKED
6
14
^21
'25
Ueda
Ueda
Ueda
Ueda
Iwasaki
8 [atayams
14 [atayami
"25
21 [atayama/21
2 [atayama
Ueda
14
^25
Hayashi / B
Hayashi
Hayashi
Hayashi
Hayashi
APPROVED
ENGINEERING DEPARTMENT
'21
'25
Ueda
Ueda
Ueda
Ueda
Ueda
14
'21
'25
Hayashi
Hayashi
REVIEWED
SCAI£ NONE
Projects Department Engineering Section
NAME
0. NO.
1-09630620
T. NO.
1013 Technology Park Dr.
Qlen Allen. Virginia 23069
Phone: [phone]
ANDAStOClATif Fax: [phone]
CWD PROJECTS DEPARTMENT
THE DRAWIN6(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USEDJN
ANY MANNER WITHOUT THE PRIOR WRIHEN CONSENT OF KOBE STEELLTD.
TITLE
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(9)
Area 80 Utility
JOB NO.
PF3400
I I I I I
AREA
100
DRAWING NO.
DB33 -EA009<^ 1 L I I I M M I I I M M I M iiiiliiMiiininii
SRD ANGLE
PROJECTION
SLIDING DECK
TRANSFER SYSTEM
HYDRAULIC CYLINDER
Press: 7MPa
Dia:32mm
Stroke:720mnn
HYDRAULIC CYLINDER
Press: 7MPa
Dia:50mm
Stroke:880mm
CHAMBER CLAMP
HYDRAULIC LOCK SYSTEM
CHAMBER LID
TRANSFER SYSTEM
^zsYzs_
.35 A36.
MOTOR FOR SLIDING DECK
MOTOR P0WER:1.5kw
R.P.M: 1800/15
REDUCING: 1/120
HYDRAULIC CYLINDER
Press: 21 MPa
Dia:140mm
Stroke: 100mm QTY:16sets
HIGH PRESS. HOSE^
HYDRAULIC CYLINDER ^
Press: 7MPa
Dia :100mm
Stroke:360mm
HIGH PRESS. HOSE
ltd
UUL
LIFER
Press: 3MPa
Dia: mm
Stroke:500mm
A
V
LID OPNE/CLOSE LID MOVING
MOTOR FOR SLIDING DECK
MOTOR POWER: 1.5k w
R.P.M: 1800/15
REDUCING; 1/120
019.2/012.7
LOW PRESS. HOSE
Rcl/2
t
HYDRAULIC CYLINDER
Press: 7MPa
Dia:110-80mm
Stroke:3900mm
HYDRAULIC CYLINDER
Press: 7MPa
Dia:80mm
Stroke: 1300mm
026.8/019
LOW PRESS. HOSE
Rc3/4
m
o
019.2/012.7
LOW PRESS.HOSE
Rcl/2
t
SET
1~7MPa
t
01
013,2/06.3
LOW PRESS. HOSE
Rc 1/2
013,2/06.3
LOW PRESS. HOSE
Rc 1/2
m
MAGNET
013.2/06.3
LOW PRESS.HOSE
Rcl/2
t
ELECTRIC&INSTRUMENT LIST ROLL CURTAIN SYSTEM
HYDRAULIC POWER UNIT
SYMBOL
M01
M02,M05
HT01
S0L1-S0L11
ZS01-ZS16
ZS21-ZS41
PS01'-PS04
3WV01
MG01
M04
S0L11
ZS42'-ZS45
NAME
OIL POMP MOTOR
SLIDING DECK MOTOR
OIL TANK HEATER
SOLENOID VALVE (OIL)
SWITCH (FOR CLAMP)
SWITCH (FOR CHAMBER LID)
SWITCHfFOR SLIDING DECK)
OIL PRESS. SWITCH
3-WAY VALVE
MAGNET
ROLL CURTAIN MOTOR
SOLENOID VALVE (AIR)
SWITCH (FOR ROLL CURTAIN)
SPECIFICATION
1 5kw, 4P, AC480/440V,60Hz,
1. 5kw. 4P, AC480/440V.60HZ.1/12Q
2kw. AC480/440V
DC24V
DC24V
DC24V
DC24V
DC24V
DC 180V
0. 2kw, 4P. AC480/440V.60HZ.1/4Q
DC24V
DC24V
QTY
2
1 1
1 6
4
2 1
4
4
REV.
NO.
Design Progress
First issue
BEVISIONNOTE
5/21
2010
2/25
2010
Takeda
Sasaki
DESIGNED CHECKED
'21
^^25
Ueda
Iwasaki '25
21 [atayama
Ueda
'21 Hayashi
25 Hayashi
APPROVED
ENGINEERING DEPABTIIENT
'21
'25
Ueda
Ueda
'21
'25
REVIEWED
SCALE
NONE
Projects Department
Engineering Section
NAME
O.NO.
1-09630620
T. NO.
SYMBOL
: MOTOR
HYDRAULIC PUMP
(PISTON PUMP)
? ? m
cz 1 in:
J-L
3-POSITION VALVE(4-PORT)
(WITH SOLENOID VALVE)
2-POSITION VALVE(4-PORT)
(WITH SOLENOID VALVE)
: 3-PORT VALVE
• 2-POSITION VALVE (4-PORT)
)(
3-POSITION VALVE (4-PORT)
FLOW CONTROL VALVE
: PILOT CHECK VALVE
: RELIEF VALVE
: CHECK VALVE
: PRESSURE GAUGE
: OIL HEATER
: AIR BREATHER
OIL FILTER
OIL LEVEL GAUGE
T2 P Tl
SOL
1 1
AIR SUPPLY
(INSTRUMENT AIR)
•1013 Technology Park Dr.
mm ^ Qlen Allen, Virginia 23069
•%# Phone: [phone]
ANDAffOClATif Fax: [phone]
S>-KOBH
CWD PROJECTS DEPARTMENT
THE DRAWING(S) AND THE INFORMATION CONTAINED HEREIN ARE THE PROPERTY OF
KOBE STEEULTD. THEY SHALL NOT BE DISCLOSED.REPRODUCED OR USEDJN
ANY MANNER WITHOUT THE PRIOR WRIHEN CONSENT OF KOBE STEELLTD.
TITUS
DAVINCH SYSTEM
TOEDT SERVICES
Pipe & Instruments Diagram(10)
Lid And Deck Operation Unit
JOB NO.
PF3400
I I I I I
AREA
100
DRAWING NO.
DB33 -EA010<J>
J I I L
1/1 0 I ' I ' I ' I ' I ' I 4
I I II
1/S 0
I I I I I I I II II I
fi IQ 15
I I I I I I I I I II I I I I I I 1 I
/5 G & 10 15 20