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DSHW-2011-004588 - 0901a06880215dd9
PUBLIC REVIEW DOCUMENT Draft Permit in Response to Class 3 Permit Modification Request TOCDF-DAVINCH-03-1117 Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 PUBLIC COMMENT PERIOD January 10, 2011 TO February 24, 2011 1 ^ateofUtah GARY HERBERT Govemor GREG BELL Lieuteitant Governor Department of Environmental Quality Amanda Smith Executive Director DIVISION OF SOLID AND HAZARDOUS WASTE Scott T Anderson Director Solid and Hazardous Waste Control Board John D Newman Chair Michael D Brehra. P E Vice-Chair Scott Bruce Carlton Christensen Kory Coleman Jeff Coombs MPH,LEHS R. Ryan Dupont, Ph D Larry A Ellertson Brad Mertz Gary Mossor Kevin Murray Dennis Riding Amanda Smith Scott T Anderson Executive Secretary March 15,2011 Colonel Mark B Pomeroy, Commander Deseret Chemical Depot ATTN CMDC-PW,T Johnson 11500 Stark Road Stockton, Utah 84071-9711 and ThaddeusA Ryba,Jr CMA TOCDF Site Project Manager 11620 Stark Road Stockton, Utah 84071 and Gary W McCloskey EG&G Defense Matenals, Inc General Manager TOCDF 11600 Stark Road Stockton, Utah 84071 RE Approval of Class 3 Permit Modification Request TOCDF-DAVINCH-03-1117 Division Trackmg Number 2010 01938 Deseret Chemical Depot - TOCDF UT5210090002 Dear Colonel Pomeroy, Mr Ryba and Mr McCloskey The Division of Solid and Hazardous Waste has completed its review^ of the modification request hsted above A 60-day public comment penod was conducted by the facility from June 10,2010 to August 9,2010 No comments were received by the Executive Secretary A second public TN201100287 DOC 195 North 1950 West • Salt Lake City, UT Mailing Address P O Box 144880 • Salt Lake City UT 84114-4880 TelqAone (801) 536-0200 • Fax (801) 536-0222 'TDD (801) 536-4414 vmmJecf Utah gim Pnnted on 100% recycled paper Utah Department of Environmental Quality Division of Solid and Hazardous Waste FACT SHEET January 2011 Class 3 Permit IVIodification: TOCDF-DAVINCH™-03-1117, Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 Tooele Chemical Agent Disposal Facility (TOCDF) Hazardous Waste Management Permit TOCDF Facility The Tooele Chemical Agent Disposal Facility (TOCDF) is located at the Deseret Chemical Depot (DCD) approximately 15 miles south of Tooele, Utah The TOCDF IS a permitted facility used by the US Army to destroy the military chemical blister and nerve agents stored at the DCD The TOCDF has four incinerators for the treatment of hazardous waste, three tank systems for the storage and treatment of hazardous waste, several miscellaneous treatment units for the treatment of hazardous waste, and is subject to applicable generator requirements and a Hazardous Waste Storage and Treatment Permit Hazardous Waste Permit The TOCDF was issued a Part B Permit in June of 1989 This permit was re-issued in May of 2004 The Utah Division of Solid and Hazardous Waste (DSHW) conducts permitting oversite activities at the TOCDF under the Resource Conservation and Recovery Act (RCRA) The RCRA is a federal law written to protect human health and the environment, reduce waste, conserve energy, and to reduce or eliminate the generation of hazardous waste The RCRA is codified under the Code of Federal Regulations, title 40, parts 260 through 299 The DSHW is authorized by the Environmental Protection Agency to enforce the RCRA in the state The State of Utah has codified its own rules under the Utah Administrative Code, Sections R315-1 to R315-9, R315-12toR315-14,R315-16, R315-50, R315-101, and R315-102 Under State and Federal rules facilities that store hazardous waste for more than 90 days must submit an application for a permit to store the waste (See R315-5-3 34) The TOCDF has several permitted storage areas in its current Part B Permit Class 3 Permit Modification In accordance with the Hazardous Waste Management Rules for the State of Utah (R315-3-4 3), the TOCDF has submitted a Class 3 Permit Modification Request to add an Explosives Destruction Technology (EDT) to its Part B Permit The Class 3 Permit Modification proposes to permit an EDT known as the Detonation of Ammunition in a Vacuum Integrated Chamber or DAVINCH™ as a subpart X treatment unit The TOCDF proposes to use this unit to detonate and treat 155mm projectiles and 4 2 inch mortars filled with mustard chemical agent An EDT is being used to treat these munitions because they cannot be managed using the equipment and processes at the TOCDF due to corrosion and degradation of the munition bodies In addition to the nearly 340 munitions to be treated, the TOCDF proposes to also treat 47 mustard agent sample containers These samples were collected from mustard agent munitions stored at the DCD Due to the configuration in which these samples are stored the EDT was determined to be the safest method to treat this waste stream The unit will be located in Area 10 at the DCD and will be a self contamed unit consisting of a detonation chamber and pollution abatement system Area 10 is adjacent to the TOCDF facility Draft Modification Approval In accordance with (R315-4-1 6), the DSHW has drafted a modification approval The draft approval makes changes to Module Vm of the TOCDF Part B Permit and mcludes a destruction plan, an acronyms and abbreviations list, a monitoring plan, an inspection plan, operational mode diagrams, a closure plan, an emergency response plan, and a training plan Opportunity for Public Hearing In accordance with R315-4-1 12, a public hearing on this draft approval will be held on February 16, 2011 at 6 PM in the South Auditorium at the Tooele County Administration Building, 47 South Main, Tooele, Utah Public Comment Period The public comment penod will begin on January 10, 2011 and will end on February 24, 2011 Copies of the draft approval are available for review from 7 00 AM to 6 00 PM, Monday through Thursday, at the physical address listed below Copies of the draft approval are also available for review from 8 30 AM to 5 00 PM, Monday through Friday, at the Tooele Chemical Stockpile Outreach Office (see address below) A courtesy copy of the draft approval will also be available on the Division of Solid and Hazardous Waste web page at the following address http //www hazardouswaste Utah go v/Public/PublicViewingArea htm Physical Address Department of Environmental Quality, Division of Solid and Hazardous Waste, Multi Agency State Office Building, 195 North 1950 West, 2"" Floor, Sah Lake City, Utah Mailing Address Scott T Anderson Executive Secretary Utah Solid and Hazardous Waste Control Board P O Box 144880 Salt Lake City, Utah 84114-4880 Outreach Office Tooele Chemical Stockpile Outreach Office 54 South Main Street Tooele, Utah 84074 Written comments will be accepted until 6 00 PM on February 24, 2011, and can be either submitted in person at the physical address listed above or mailed to the mailing address listed above At the conclusion of the public comment period the Executive Secretary will consider all comments received prior to making a final decision on the modification request Public Involvement The public is provided additional opportunities for involvement in the decision making process through a mailing list If you would like to be notified of pending decisions and other permitting activities regarding the TOCDF, contact the DSHW and request to be added to the TOCDF mailing list Additional Information This fact sheet contains a summary of the draft permitting decisions regarding the TOCDF Permit Modification Request TOCDF- DAVINCH™-03-1117, Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 If you would like more detailed information or have questions please contact Tom Ball DEQ/DSHW PO Box 144880 195 North 1950 West Salt Lake City, Utah 84114^880 Telephone (801) 536-0251 NOTICE The Executive Secretary of the Utah Solid and Hazardous Waste Control Board has prepared a draft modification m response to a Class 3 Permit Modification Request from Deseret Chemical Depot to modify the Tooele Chemical Agent Disposal Facility (TOCDF) Part B Permit The modification request is titled "Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 " This permit modification proposes to permit an Explosives Destruction Technology for the treatment of approximately 340 mustard filled, 155mm projectiles and 4 2 inch mortars that cannot be treated using the equipment and processes at the TOCDF due to corrosion and degradation of the munition bodies _ In addition, the TOCDF proposes to also treat 47 mustard agent sample contamers The public comment penod for this draft modification will begin on January 10, 2011, when the notice is published in the Salt Lake Tnbune and Deseret News Notice will also be published in the Tooele Transcript Bulletin The comment period will end February 24, 2011 A public hearing on the draft modification will be held at 6 00 pm on February 16,2011 in the South Auditorium of the Tooele County Administration Building, 47 South Main, Tooele Copies of the draft modification will be available for public review throughout the comment period Monday through Thursday from 730am to 530 pm at the following location Utah Department of Environmental Quality Division of Solid and Hazardous Waste Multi Agency State Office Building 195 North 1950 West, 2"" Floor Salt Lake City, Utah A copy of the draft modification will also be available for public review throughout the comment penod Monday through Friday from 8 30 am to 5 00 pm at the following location Tooele Chemical Stockpile Outreach Office 54 South Main Street Tooele, Utah A courtesy copy of the draft modification is available on the Division of Solid and Hazardous Waste web page at the following address http //www hazardouswaste Utah gov/Public/PublicViewingArea htm Wntten comments will be accepted until 6 00 pm on February 24, 2011, and should be submitted to Scott T Anderson Executive Secretary Utah Solid and Hazardous Waste Control Board P O Box 144880 Sah Lake City, Utah 84114-4880 For further information, please contact Tom Ball of the Utah Division of Solid and Hazardous Waste at (801) 536-0251 In compliance with the Amencans with Disabilities Act, individuals with special needs (including auxiliary communicative aids and services) should contact Brooke Baker, Office of Human Resources at (801) 536-4412 (TDD 801-536-4414) at least five working days prior to the end of the comment period Utah Department of Environmental Quality Division of Solid and Hazardous Waste P.O. Box 144880. SLC. UT 841 14-4880 Public Notice of Draft Permit Modification Approval Class 3 Permit Modification Request: TOCDF-DAVINCM ""-03-1117 Install and Operate I'xplosive Destruction Technology Subpart X Unit in Area 10 Facility Proposed Action Where can I find a copy of the draft modification? Tooele Chemical Agent Disposal Facility (TOCDF) 11600 Stark Road, Stockton, Utah 84071 In accordance with R315-4-1.6(c) of the Utah Administrative Code (UAC), the Executive Secretary of the Utah Solid and Hazardous Waste Control Board has prepared a Draft Permit Modification Approval (draft approval) in response to a Class 3 Permit Modification Request from Deseret Chemical Depot to modify the Tooele Chemical Agent Disposal Facility (TOCDF) Part B Permit. The modification request proposes to permit an explosives destruction technology for the treatment of approximately 340 mustard filled 155mm projectiles and 4.2 inch mortars that cannot be treated using the equipment and processes at the TOCDF due to corrosion and degradation of the munition bodies. In addition, the TOCDF proposes to also treat 47 mustard agent sample containers. Copies of the draft approval and Fact Sheet are available for public review at the following locations: • Department of Environmental Quality, Division of Solid and Hazardous Waste, Multi Agency State Office Building, 195 North 1950 West, 2"'' Floor, Salt Lake City, Utah. The draft approval is available for review Monday through Thursday from 7:00 am to 6:00 pm during the public comment period listed below. • Tooele Chemical Stockpile Outreach Office, located at 54 South Main Street, Tooele, Utah. The draft approval is available for review Monday through Friday from 8:30 am to 5:00 pm. Is there an opportunity for a hearing? Who can I talk to about the draft modification? How long is the public comment period? In accordance with R315-4-1.12 UAC, a public hearing on this draft approval will be held on February 16, 2011 at 6:00 pm in the South Auditorium at the Tooele County Administration Building, 47 South Main, Tooele, Utah. Please contact Tom Ball of the Division at (801) 536-0251 if you have any questions concerning this draft permit. The compliance history of the TOCDF during the life of the permit being modified can be obtained by contacting Tom Ball at (801) 536-0251. In accordance with R315-4-1.10(b) UAC, the public is provided 45 days to review the draft approval and submit comments. The public comment period will begin on January 10, 2011 and will end on February 24, 2011. Written comments, addressed to Scott T. Anderson, can be submitted in person at the Division office listed above or mailed to the following address: Executive Secretary, Utah Solid and Hazardous Waste Control Board, P.O. Box 144880, SLC, UT 84114-4880. Written comments will be accepted until 6:00 p.m. on February 24, 2011. TOCDF Demilitanzation Miscellaneous Treatment Units December 2010 MODULE VIII MISCELLANEOUS TREATMENT UNITS VIIIA APPLICABILITY Vlll A 1 The requirements of this module pertain to the miscellaneous units described in Attachment 14 (Miscellaneous Treatment Units) and listed below in Conditions I VIII A 1 athrough VIII A 1 fL VIII A 1 a Two Drum Ventilation System (DVS) Enclosures located m DCD Area 10 Igloo 1632 VIII A 1 b Two Projectile/Mortar Disassembly Machines (PMDs) located in the ECRs Vlll A 1 c Three Multipurpose Demilitarization Machines (MDMs) and the associated Pick and Place Machmes (PKPLs) located in the Munitions Processing Bay (MPB) VIII A 1 d Two Bulk Drain Stations (BDSs) located in the MPB Vlll A I e One Drum Ventilation System Sorting Room (DVSSR) located in DCD Area 10 Igloo 1632 VIII A 1 e 1 Prior to hazardous waste operations in this Igloo, standard operating procedures must be submitted to the Executive Secretary for initial evaluation VIII A I f One Air Operated Remote Ordnance Access System (Cutter Machine), which can be located in either ECR, or in the MPB I VIIIA 1 fg One Autoclave for the treatment of Secondary Waste located in DCD Area 10 Igloo 1631 I VIII A 1 fg 1 Prior to hazardous waste operations in this Igloo, standard operating procedures must be submitted to the Executive Secretary for initial evaluation VIII A I h Reserved VIII A 1 1 One Detonation of Ammunition in a Vacuum Integrated Chamber (DAVFNCH™) for the treatment of over-packed leaking mustard chemical agent munitions and agent samples specified in a DAVINCH Destruction Plan approved by the Executive Secretary VIII A 2 The Pennittee may feed uncut busters from Ml04, Ml 10, mustard 155mm projectiles and 4 2" HT and HD mortars to the DFS VIII A 3 For the DAVINCH™. all requirements addressed in this module are specified in Condition VIII H VIII B ALLOWABLE WASTE FEED VIII B 1 Reserved Module VIII - Page TOCDF Demilitanzation Miscellaneous Treatment Units December 2010 VIII B 2 The Permittee may treat 155-mm projectiles, and 4 2 mch mortars (hazardous waste codes P999, D002, D003, D004, D006 through DOIO, D028, D034, and D039) in the PMDs and the MDMs/PKPLs to comply with rates specified m Modules V and VI for the DFS and MPF VIII B 3 The Permittee may treat ton containers, (hazardous waste codes P999, D002, D003, D004, and D006 through DOIO, D028, D034, and D039) in the BDSs to comply with rates specified in Modules V and VI for the MPF VIII B 4 The Permittee is prohibited from treating waste in the miscellaneous units, identified in Condition VIII A 1 that is not identified in Conditions VIII B 2, VIII B 3, VIII B 5 and VIII B 6 VIII B 5 Wastes treated in the DVS Enclosures and the DVSSR shall be limited to TOCDF-generated secondary wastes with the following waste codes P999, F999, D002, D003, D004, D005, D006, D007, D008, D009, DOIO, DOI 1 and F001-F005 for TOCDF-originated laboratory sample waste VIII B 6 Waste treated in the Autoclave shall be limited to secondary waste with the following waste codes P999, F999, D002, D003, D004, D005, D006, D007, D008, DOIO and DOI 1 after approval VIII B 7 Reserved VIII C IGNITABLE AND INCOMPATIBLE WASTES VIII C 1 Ignitable wastes (DOO 1) shall not be treated in the ECRs or MPB VIII C 2 The Permittee shall place only munitions or bulk containers with one type of chemical agent (e g , GB, VX or Mustard) in the MPB at one time Only one chemical agent may be placed in the ECRs VIII C 3 The Permittee shall not place chemical agent or munitions containing that chemical agent in a container that previously held a different chemical agent or munitions containing a different chemical agent until the container has been decontaminated to less than I VSL VIII D DESIGN AND OPERATING REQUIREMENTS VIII D 1 The Permittee shall comply with the design and operating requirements specified in Attachment 14 (Miscellaneous Treatment Units) of the Permit Vlll D 2 The Pennittee shall comply with the requirements specified in the Attachment 9 (Contingency Plan) when there has been a release that escapes engineering controls or a fire, explosion, or detonation from the operation of the PMDs, MDMs, or BDSs VIII D 3 If equipment in the ECRs or down line of the ECRs shuts down, any munitions or munition components being processed in the ECRs may remain in the ECRs until the equipment in question is operational Alternatively, facility personnel may don appropriate PPE and physically retrieve the munitions or munition Module VIll-Page 2 TOCDF Demilitanzation Miscellaneous Treatment Units December 2010 • The acceptability of the storage container's matenal of construction for treating waste if the Permittee desires to treat the waste in storage contamers, • The optimum placement of the control thermocouples withm the waste bin or waste storage container to determine when a representative section of the waste's mass has reached the treatment temperature, and • The penetration of steam or moisture mto a representative section of the waste(s) mass by either visual inspection of the treated waste(s) or post- treatment inspection of moisture indicators placed into representative sections of the waste(s) for the purpose of testmg VIII D 7 5 b The Permittee shall provide function plan for each new waste stream and a notice to the Executive Secretary a minimum of fourteen days m advance of conducting a function test Following each function test, and prior to off-site shipment of the waste(s) tested, the Pennittee will follow the permit modification requirements to add these waste streams to Table VIII B of this pennit VIII D 7 5 c The Permittee shall continuously operate the Carbon Adsorption Filtration system which supports the Autoclave and DVS/DVSSR operations from the time hazardous waste management activities begin in Igloo 1631 and 1632 to the time hazardous waste management activities cease and 1) both igloos and associated equipment withm the igloos has been decontammated sufficiently to achieve a WPL monitormg level and 2) the filter system activated carbon banks which have been exposed to chemical agent have been removed from the filter system VIII D 8 Reserved VIII E DETECTION, INSPECTION, AND MONITORING REOUIREMENTS VIII E 1 As described in Attachment 14 ( Miscellaneous Treatment Units), the Permittee shall monitor the waste throughput for each miscellaneous unit by use of the Process Data Acquisition and Recording System (PDARS) and the manual records maintained by the control room operators or the Area 10 Igloo (DVS/DVSSR and Autoclave) Operators The Permittee shall use weighing, before and after draining, to quantify the amount of agent removed in the BDSs Vlll E 2 The Permittee shall use the bubbler system and load cells associated with the BDS to determine the quantity of liquid agent drained from a bulk container processed m the BDS The amount of residual liquid and solid heel remaining in the bulk container shall then be determined by comparing the ton container's initial fill weight with the amount of liquid drained If the Permittee is unable to determine the quantity of liquid and solid residual heel in the bulk container or the Dram Tube System (DTS) encounters a solid heel before reaching the programmed drain level, the Pennittee shall orally notify the Executive Secretary within 24 hours The Permittee shall record the bubbler reading and load cell reading for each bulk item drained in the Operating Record If the quantity of agent removed, as determined in Condition VIII E 1, is not consistent with the bubbler system or the DTS programmed drain level, then the Pennittee shall not Module Vlll - Page 6 TOCDF Demilitanzation Miscellaneous Treatment Units December 2010 3) Headspace > 1 0 VSL, treat in a hazardous waste management unit (Autoclave) or TOCDF MPF permitted for treatment for that P999 waste stream VIII E 16 d VIIIE 16 e VIII E 17 VmE 17 a VIIIE 17 b A Secondary Waste Drum Headspace Monitoring method is currently approved by the Executive Secretary for the following waste streams Secondary Waste Drums Having a DSHW-Approved Headspace Agent Monitoring Method for Determination of Drum's Agent Contamination Status 1) DPE Suits/TAP Gear Unapproved P999-characterized secondary waste types not listed in VIII E 16 d shall be treated in a hazardous waste treatment unit (HWMU) permitted for P999 treatment In lieu of performing headspace monitoring, the Permittee may conservatively treat approved waste types in a permitted HWMU as P999 waste Autoclave Inspection and Monitoring Requirements The Permittee shall monitor and record the temperature and time of temperature soak associated with each batch of Secondary Waste treated in the Autoclave The Permittee shall perform post-treatment agent monitoring on the Autoclave headspace to determine the applicable waste management practices for the treated wastes VIII E 17 b I Treated secondary wastes with post-treatment headspace agent monitoring results of less than 0 5 Vapor Screening Limit (VSL) and a demonstrated WCL of less than 20ppb for VX/ GB and 200ppb for mustard may be managed in roll-offs for off-site transport to a Subtitle C TSDF as F999 VIII E 17 b 11 Treated secondary wastes with post-treatment headspace agent monitoring results of less than 0 5 Vapor Screening Limit (VSL), but without a demonstrated WCL of less than 20ppb for VX/ GB and 200ppb for mustard, may be managed in roll- offs for off-site transport to a Subtitle C TSDF as P999/F999 with additional offsite controls (special handling through contract requirement) as an added measure of control to reduce potential contact with waste VIII E 17 b 111 Autoclave treated secondary wastes with post-treatment headspace agent monitoring results equal to or greater than 0 5 VSL shall be retreated in the Autoclave VIII E 17 b IV The Permittee shall notify the Executive Secretary of each instance when a batch of Autoclave treated wastes receives an additional Autoclave treatment The Executive Secretary may require additional testing or an adjustment to Autoclave operating parameters and drum weight limits for secondary waste streams requinng repeated multiple treatments VIII E 18 Reserved Module VIII - Page 10 VIIIF VIIIF TOCDF Demilitarization Miscellaneous Treatment Units December 2010 STORAGE REOUIREMENTS The Permittee may store waste in the form of maintenance residues on the equipment in the ECRs or on the floor of the ECRs provided that Conditions VIII F 2 and VIII F 3 are satisfied VIII F 2 Waste in the ECR sumps shall be removed within 24 hours as required by Module IV VIII F 3 The explosive limits of each ECR, as specified in Attachment 14 (Demilitarization Miscellaneous Treatment Units), shall not be exceeded VIII F 4 The Permittee may store open containers of secondary waste in the DVS enclosures and the DVSSR provided the DVS enclosure, the DVSSR doors, and Igloo doors are properly closed and the igloo carbon adsorption filtration system IS operable with the primary filter online VIII G CLOSURE VIII G 1 At closure, the Permittee shall follow the procedures specified m Attachment 10 (Closure Plan) VIIIH DAVINCH™ VIIIH 1 The Permittee shall install and operate the DAVINCH™ within Area 10 of the Deseret Chemical Depot VIII H 2 Wastes treated in the DAVINCH™ shall be limited to chemical agents, and Propellants. Explosives, and Pyrotechnics (PEP) with the following waste codes P999. F999. D003. and D004 through DOI 1 VIII H 3 The Permittee shall orally report to the Executive Secretary in accordance with Permit Condition IU any release of agent from the DAVFNCH™ Environmental Enclosure or the DAVINCHT^*^ Environmental Enclosure HVAC Filter System Stack that exceeds the 0 5 Vapor Screen Limit for Mustard (H/HT/HD) as specified in Table 1 of this Permit Vlll H 4 The Permittee shall comply with the waste analysis, inspection, preparedness and prevention, personnel training, agent monitoring, and closure requirements as specified in revision 2 of the DAVINCH™ Destruction Plan dated December 2010 and associated annexes with revision numbers as detailed in the TTM DAVINCH"^ Destruction Plan Vlll H 5 For DAVINCHTM operations, the Permittee shall not exceed limits specified in columns 1 through 5 of the table below Module VIII - Page 11 TOCDF Demilitarization Miscellaneous Treatment Units December 2010 DAVINCH™ Operation Limitations ^ 1 2 3 4 5 Munition Overpackts) Aeent No Munitions & Samples Munitions/ Shot Shots/ Day" Agent/ Shot m Total TNTea/ Shot Ob) 4 2" HT Mortar M13A2 or 7x27 HT 117 3 7 174 118 4 2" HD Mortar M13A2 HD 18 3 7 18 118 ECR/ECV Exnlosive Waste 9x41 or 7x27' See Note c See Note c 1 7 See Note c 78 155mm HProio M16A3 H 68 2 7 23 4 128 155mmHProio 9x41 H 27 1 7 117 93 155mm H Proio M16A3/ M10A4 H 16 1 7 11 7 93 155mm H Proio PA37/ 12x56 H 8 1 7 11 7 119 155mm HProlo M16A3/ 12x56 H 79 1 7 11 7 119 HT Samples M2A1 HT 11 4 7 92 46 HD Samnles M2A1 HD 6 4 7 5 1 46 Total • 386 "All values listed in columns 1 through 5 are maximums Does not mclude "Cleansing" shots when only explosives are added to Detonation Chamber to destroy residual agent Either over-pack may be used for over packing ECR/ECV explosive waste This waste stream is limited to explosive or explosive munition components found during the closure of the ECR/ECV and Subpart X Treatment Units withm the ECRs and ECV The number of DAVINCH treatments shall not exceed 6 The 9x41 over-pack has approximately twice the mass as the 7x27 The Total TNTeq/shot associated with the treatment of mortars in either over-pack will not exceed the value shown VIII H 6 The Permittee shall analyze Detonation Off-Gas for the chemical agent before the gases exit the DAVINCH^M Off-Gas Retention Tank 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 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 PMl sampling location using a dilution air to sample volume ratio of YY** VIII H 6 11 The Pennittee shall stop the flow of Detonation Off-Gas from the DAVINCH™ Pollution Abatement Svstem (PAS) Retention Tank if the concentration of the gas entermg 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 sampling location using a dilution air to sample volume ratio of YY** Vlll H 6 111 Detonation Off-Gas having an agent concentration equal to or greater than 0 5 VSL without application of Dilution Air Flow Controllers (DAFCs) at the PMI Module VIII-Page 12 TOCDF Demilitarization Miscellaneous Treatment Units December 2010 sampling 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 analvzed for agent concentration before being released to the environment in accordance with Condition VIII H 6 i VIII H 7 At a minimum the Permittee shall ensure that the near real-time agent monitors located immediately before the inlet to the DAVfNCH™ Pollution Abatement Svstem (PAS) Retention Tank is linked with the DAVrNCHT*^ process control system such that VIII H 7 I The release of Detonation Off-Gas from the Detonation Chamber is timed with the start of the monitor's sampling cycle in a manner that assures the sampling of the off-gas rather than ventilation air VIII H 7 11 The automatic valve located immediately downstream of the Retention Tank outlet closes 1) if agent is detected in the Detonation Off-Gas at a concentration 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 sampling location using a dilution air to sample volume ratio of YY**. 2) if agent monitors PMI. PM3. or PM14 malfunction during release of detonation off-gas prior to making a determination at PMI regarding the presence of chemical agent. 3) if there is a failure of the DAVINCH™ site power VIII H 8 Place holders XX and YY marked with "**" in Conditions VIII H 6 through VIII H 7 shall be specified after the dilution air to sample volume ratio is determmed during systemization and validated during the 28-dav initial baseline study Values for XX and YY shall be incorporated into this permit through a Class 1 with pnor approval Permit Modification Request prior to the start of Agent Operations Module VIII - Page 13 EXPLOSIVE DESTRUCTION TECHNOLOGY (EDT) DESTRUCTION PLAN Submitted to EG&G DM! Inc/URS 11600 Stark Rd Stockton, UT 84071 Subcontract DMB51843 Submitted by (^VERSAR Versar, Inc© 6850 Versar Center Springfield, VA 22151 Revision 2 December 2010 TABLE OF CONTENTS LIST OF TABLES . . . . .IV LIST OF FIGURES . .. . IV EXECUTIVE SUMMARY . . . V 10 INTRODUCTION . . 1 1 1 PURPOSE 1 1 2 ITEMS TO BE DESTROYED 1 121 Target Munitions 2 12 2 Fill Matenals 2 13 APPROVAL PROCESS 4 1 4 HISTORICAL PRECEDENT FOR EDT 5 1 5 SITE DESCRIPTION (INCLUDING SITE PREPARATION REQUIREMENTS) 5 151 Existmg Paved Area 9 15 2' Administrative Area 9 15 3 EDT Site 9 15 4 Staging Area 9 1 5 5 Additional Gate 9 15 6 Restricted Access 9 1 6 EMERGENCY PLANNING AND CONTINGENCY OPERATIONS 9 / 6 / Site Specific Safety Plan 9 16 2 Prevention of Sudden Releases to the Environment 10 16 3 Fire Prevention 12 16 4 Communication System 13 16 5 Spill Response 13 17 MONITORING 14 17 1 Safety Air Monitonng 14 17 2 Monitonng Pomts 14 1 8 EG«&G, TOCDF, AND DCD SUPPORT 15 181 Equipment/Facilities 15 18 2 Utilities 15 18 3 Security 15 18 4 Site Preparation 15 18 5 Operations Support 15 18 6 Plannmg/Permittmg 16 187 EDT Operations 16 2 0 SYSTEM DESCRIPTION 17 21 OVERVIEW 17 2 11 Concept of Operations 17 2 12 System Design Requirements 17 2 2 ENVIRONMENTAL ENCLOSURE (EE) DESCRIPTION 18 22 1 DAVINCH™ Containmenl 18 2 2 2 EE Operatmg Areas 18 2 3 MAINTENANCE REQUIREMENTS 19 2 3 1 Monitoring Fatigue Damage 19 2 3 2 Preventive Mamtenance 19 2 3 3 Equipment Maintenance Schedide 19 TABLE OF CONTENTS (CONTINUED) 4 DESIGN FEATURES 20 24 1 Detonation Chamber 20 242 Clamping System 21 24 3 Munitions Handling/Installation tn Chamber 21 2 44 Chamber Door/Movable Platform 21 24 5 Off-Gas Filter 21 246 Off-Gas Heater 21 247 Cooler 21 248 Off-Gas System 21 2 49 Vacuum Pumps 22 2 4 10 Cold Plasma Oxidizer 22 2 4 11 Cooler 22 2 4 12 Scrubber 22 2 4 13 NaOH Tank ' 22 2 4 14 Off-Gas Blower 22 2 4 15 Retention Tank 23 2 4 16 Heater 23 2 4 17 Carbon Filters 23 2 4 18 Exhaust Air Blower 23 5 , OTHER SUPPORT EQUIPMENT 23 3 0 EDT OPERATIONS ... 25 31 SYSTEM DELIVERY 25 3 11 Transportation and Delivery of Main Chamber and Associated Components 25 3 12 Transportation and Delivery of Off-Gas Treatment Systems 25 313 Delivery of Support Equipment 25 3 2 SYSTEM INSTALLATION 25 3 3 SYSTEMIZATION 27 3 4 OPERATIONAL READINESS REVIEW 27 3 5 OPERATIONS 27 3 5 1 Operational Steps 28 3 5 2 Donor Charge 28 3 5 3 Chamber Preparation for Detonation 29 3 5 4 Implosion with Donor Charge 29 3 5 5 Off-Gas Treatment and Air Flow Phases 29 3 6 THROUGHPUT 33 3 7 OPERATING PROCEDURES 36 3 8 SCHEDULE 36 3 9 CLOSURE 36 3 10 DESCRIPTION OF OCCUPANCY AND DESTRUCTION OF BUILDINGS WITHIN PUBLIC ACCESS EXCLUSION DISTANCE (PAED) 38 3 11 WASTE ANALYSIS PLAN 38 3 12 PERSONNEL LIMITS AND PROTECTIVE EQUIPMENT 45 3 12 1 Airborne Exposure Limits (.4ELs) 45 3 12 2 Exposure Points 45 3 12 3 Personal Protective Equipment 45 11 TABLE OF CONTENTS (CONTINUED) 3 13 MITIGATION OF HAZARDS (INCLUDING CONTINGENCY PLANS) 46 3 13 1 Containment 46 3 13 2^ Safety in Enclosure 46 3 13 3 PPE Fit Testing 46 3 13 4 Emergency and Evacuation 46 3 13 5 Emergency Response Actions 46 3 13 6 Medical Support 47 4 0 ORGANIZATION .. ... 48 4 1 US ARMY 48 4 2 STATE OF UTAH 48 4 3 CONTRACTORS 49 4 4 EDT SITE OPERATIONAL ORGANIZATION 49 5 0 REFERENCES . . ERROR'BOOKMARK NOT DEFINED Ul List of Tables Table 1 Charactenstics of DCD Munitions Table 2 Projected DCD Inventory of Overpack Types and Munitions to be Processed in the EDT Table 3 Overpack Specifications Table 4 Schedule for Preventive Maintenance Table 5 TOCDF EDT Throughput Table 6 Estimated Waste Generated from DAVINCH'^'^ Operations Table 7 TOCDF DAVINCH™ Waste Analysis Summary (On-Site) Table 8 TOCDF DAVINCH™ Waste Analysis Summary (Off-Site) Table 9 Role of Each Operations Group Table 10 Job and Qualifications/Experience 3 4 4 20 35 39 41 42 48 48 List of Figures Figure 1 Munitions to be Destroyed by DAVINCH™ Figure 2 EDT Proposed Site Location at TOCDF Figure 3 EDT Site Location in Area 10 Figure 4 EDT Site Overview Figure 5 Installation and Commissioning Schedule Figure 6 Conceptual Steps of DAVINCH™ Figure 7 Total DAVINCHTM System Figure 8 DAVINCH™ Off-Gas Treatment Phases Figure 9 EDT Block Flow Diagram Figure 10 Inside Chamber before and after Cleansing Shot Figure 11 ECAD Operation Figure 12 TOCDF EDT Overall Organization Figure 13 EDT Site Operation Organization 2 6 7 8 26 28 28 31 32 37 37 46 47 Annexes ANNEX A Acronyms and Abbreviations, Revision 1, November 2010 ANNEX B Monitonng Plan, Revision 2, December 2010 ANNEX C Inspection Plan, Revision 2, December 2010 ANNEX D DAVINCH™ Operational Mode Diagrams, Revision 1, November 2010 ANNEX E Closure Plan, Revision 2, December 2010 ANNEX F TOCDF EDT Emergency Response Plan, Revision 2, December 2010 ANNEX G Training Plan, Revision 2, December 2010 IV EXECUTIVE SUMMARY The United States (US) Army Chemical Matenals Agency (CMA) is responsible for destroying U S chemical warfare matenel The Project Manager - Chemical Stockpile Elimination (PM- CSE), established in 2006 by merging the Chemical Stockpile Disposal Project (CSDP) and the Altemative 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 333 reject munitions that 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 prefened alternative Therefore, the DAVINCH^"'^ Detonation In a Vacuum-Integrated Chamber (DAVINCH^'^) 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-mm 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 descnbed 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 10 INTRODUCTION The United States (US) Army Chemical Matenals Agency (CMA) is responsible for destroying U S chemical warfare matenel 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) m Stockton, Utah EG&G has a requirement for a technology to process 333 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 prefened alternative Therefore, the Detonation In a Vacuum- Integrated Chamber (DAVrNCH"^"^) 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 R315-2-11 (e)( 1) 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 The destruction of CWM is permitted and regulated by the TOCDF Part B 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™ 4.2-inch Mortar 155-mni Projectile Figure 1. Munitions to be Destroyed by DAVINCIF'^ 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. X-rays will be available on-site for regulatory review. Table 1 Characteristics of DCD Munitions Designation Munition Type Fill Explosives Comments Igniter M9 Fuze PDM8 M2A1 4 2-inch Mortar HT, 5 8 lb HD, 6 0 lb Burster Ml4 (threaded on fiize) Explosive Tetryl Explosive Wt 0 141b Propellant M6 Propellant Wt 0 61b Length 21 01 inches(18 inches w/o Ignition cartndge) Width 4 2 inches Total Wt 24 67 lb (22 lb w/o Burster Ml4 (threaded on fiize) Explosive Tetryl Explosive Wt 0 141b Propellant M6 Propellant Wt 0 61b Ignition cartndge and propellant charges) Pnmer M28A2 Fuze None Burster M6 Explosive Tetrytol Explosive Wt 41 lb Length 26 8 inch M104 155-mm Projectiles HD 11 71b Fuze None Burster M6 Explosive Tetrytol Explosive Wt 41 lb Width 6 082 inch Total Wt 95 1 lb Aluminum/Bakelite Fuze Cup MHO 155-mm Projectiles HD, 11 7 lb Fuze None Burster M6 Explosive Tetrytol Explosive Wt 41 lbs Length 26 8 inches Width 6 082 inches Total Wt 94 591b Aluminum/Bakelite Fuze Cup Samples NA 452 ml HD NA NA Samples NA 825 ml HT NA NA Table 2 Projected DCD Inventory of Overpack Types and Munitions to be Processed m 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 117 4 2-inch HD mortar 18 155-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 Table 3 Overpack Specifications Over Pack Type Exterior Length (inches) Flange Diameter (inches) Wall Thickness (inches) Tube Outside Diameter (inches) Empty Weight (lb) 7x27 27 625 104 0 134 7 12 521b 9X41 44 1 13 4 0 134 9 25 100 lb MIO A4 55 3/8 9 75 0 055 8-61/64 381b M16 A3 42 21/32 8 5 0 055 6-7/8 33 lb 12X56 52 25 15 0 0 134 120 135 Ib 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 61b 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 Concunence/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 Pme 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 m 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 pnmary means of destroying the munition, overpacks, and chemical fill through extreme temperatures, and pressures and shock waves As of October 30, 2009, the DAVfNCH™ 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 northern end of TOCDF Area 10 IS operated by DCD and has secure, surety-rated access control, perimeter monitonng, appropriate fencing, and an around-the-clock guard force The EDT will be located in the northern 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) Minimum 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 mches 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. ''-!. *-'i\ Figure 2. EDT Proposed Site Location at TOCDF \ 9A\ 7W Figure 3. EDT Site Location in Area 10 THE Diu«iiK(s) IM m MbiiunoN cwntKD HDKX MC THE KSHin or ^h^wtl wmmiff Tig »M »MiTpi coMsnn or note nta-iTB. DAVINCH SYSTEM TOEDT SERVICES Figure 4. EDT Site Overview As shown in Figure 3, the EDT site will occupy approximately 75,000 ft^ at the northern end of the Open Storage area, adjacent to Building 1835 The site is a former storage area for ton containers (TCs), it is cunently occupied with abandoned storage racks for the TCs, which consist of short sections of railroad tracks and railroad ties This area will be graded after removal of the TC racks The major sections of the site are discussed below 1 5 1 Existing Paved Area At the northern end of the Open Storage Area there is an existing macadam road/parking area This area provides a solid surface for parking and entry into the site, via an existmg gate along Road "D" 1 5 2 Administrative Area Immediately adjacent to the Existing Paved Area is the location for temporary trailers, which will house storage trailers, an office area, and the laboratory This area will be graded, compacted, and built up with gravel to sufficient depth to support the trailers, which will open to the parking area, avoiding the need for concrete or paved walkways 1 5 3 EDT Site The EDT and enclosure will occupy an area roughly 100 ft x 100 ft This section will be graded, compacted, and built up above grade using layered gravel to ensure draining and provide a firm footing for the mobile DAVINCH^M unit 1 5 4 Staging Area Adjacent to the EDT site will be a 200 ft x 200 ft staging area, where utilities will be located Generators, storage tanks for fuel and gases, and other temporary equipment will be located here This area will be graded, compacted, and built up with gravel to a sufficient depth to support the equipment Dunng installation, components that are being staged for assembly will also be located in this section 1 5 5 Additional Gate To provide a logical flow of materials through the site, and to facilitate delivery of munitions, supplies, and other materials to the site, a new gate is proposed for installation m the existing fence adjacent to Road D, approximately 300 ft from the existing gate This gate will provide ingress to and egress from the site 1 5 6 Restricted Access All fencing will be established in accordance with existing DCD access requirements An additional intemal fence will be used to divide the Open Storage Area into a northern (EDT) sector and a southern sector to prevent access to unauthonzed areas 1 6 Emergency Planning and Contingency Operations 1 6 1 Site Specific Safety Plan A Site Specific Safety Plan (SSSP) contains information regarding safety planning for the implementation of the EDT The SSSP contains information 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 16 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 16 2 1 Minimized Handling The DAVnSfCH™ 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^M process does not require the items to be removed from the over- packs prior to treatment 1 6 2 2 Containment The DAVINCH'T'^ 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 of the 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 of the detonation An explosive model ofeach detonation ensures the proper placement, size, and location of linear shaped charges (LSCs), which cut the walls of the 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 mside 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 of the number of munitions and donor charges present at the DAVINCH™ operational site The number of munitions provided to the DAVFNCH™ 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 munitions to be treated by the DAVINCH^'*' for the day are stored within the Environmental Enclosure The donor charges to be used for the day are stored m 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 compnsed 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 inner 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 of the irmer 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 of the campaign The inner chamber is neither a pressure vessel nor an impulsively-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 controlled detonation The DAVFNCH^'^ 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 impuIsively-loaded vessels, which is the first design guidance of this kind worldwide The EDT subcontractor engineers participated in the Task Group of the 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 of the vessel is "leak before burst," whereby the chamber will not catastrophically fail If a failure occurs, any release of contamination from the DAVINCH^M will be captured by the EE Near Real Time Strain Monitoring Failure of the Outer Chamber is minimized by the system unique to the DAVINCH™, which is refened 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 numencal modeling and that have shown fatigue in previous DAVINCH^*^ operations After each shot, an analysis is automatically run toi show the accumulated stress/strain on the system, using the stram 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 DAVINCHTM System • Hold-Test-Release Releases of agent fi-om the DAVINCH'''"'^ stack are also prevented by the Hold-Test-Release concept of operations as allowed by the design of the system After each shot, the off-gas is treated in a senes of treatment trains, which incorporates a Retention Tank that is located downstream of the 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 of the mlet 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 of the MINICAMS^"^ to ensure that detonation gas is sampled If agent is detected m 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 sulfiir-impregnated activated carbon filter before they are released to the environment Releases from the DAVFNCH''''^ 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 of the DAVINCHTM high TNTeq rating of the DAVINCH^M system Detonation Chamber Releases of liquid hazardous wastes are further controlled by the use of an Environmental Enclosure that prevents the mn-on and mn-off of precipitation The DAVINCHTM Detonation Chamber, Cold Plasma Oxidizers, and Retention Tank are located inside the Environmental Enclosure The preparation of the munitions to be treated in the DAVINCHTM occurs within the Environmental Enclosure The DAVINCHTM Pollution Abatement System (PAS), which consists of a cyclone, 10- and 2-micron filter screens, wet scmbber, and fixed-bed carbon filter are housed in two shipping containers Secondary containment is provided for the wet scmbber Release of hazardous waste dunng the transfer of waste residues from the DAVINCH^M Detonation Chamber, and particulate and wet scrubbers is prevented by conducting those activities mside the Environmental Enclosure and shipping container, which house some of the DAVFNCH™ 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 electrical 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 mtermption will be applied to circuits that have a shock or fire hazaid No smoking or open flames will be allowed in the restncted area of the site 16 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 reportmg a possible fire, and response will be coordmated by TOCDF and DCD 1 6 4 Communication Svstem The DAVINCHTM operations site is equipped with communication systems to alert employees to various site conditions, upset conditions, emergencies, and operations updated for TOCDF 16 4 1 The Site Public Address (PA) announcements will be managed fi-om 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 durmg explosive operations An exclusion area will be established based on Department of the Army Pamphlet (DA PAM) 385-64 Site secunty radios for DCD secunty 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 ofa 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 A spill response plan will include response requirements for major spills, minor spills, chemical agent spills, and response plans m the event of a spill 16 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 Neutralizer - sodium bicarbonate, sodium carbonate, or calcium carbonate Alkali (Base) Neutralizer - sodium bisulfate Solvents/Organic Liquid Absorbent - Inert absorbents such as vermiculite, clay, sand, Flor-Dri, and Oil-Dn • Personal Protective Equipment (PPE) Goggles and face shield 13 Heavy neoprene gloves - Disposable PPE Plastic vmyl 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 TOCDF HAZMAT Team will be the pnmary response organization The EDT site SOPs will address administration of first aid, immediate response actions such as evacuation of the area and communication procedures 17 Monitoring Air monitoring will be performed in accordance with the EDT Monitonng Plan, Annex B to this Destmction Plan Edgewood Chemical Biological Center (ECBC) and Versar will provide persormel and equipment for air monitoring for chemical agent Air monitonng 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 MfNICAMS™ and Depot Area Air Monitonng System (DAAMS) The EDT Monitonng 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 administrative controls, and when PPE is used, monitoring shall be in place to ensure that exposure levels are not exceeded 1 7 1 Safety Air Monitoring The MINICAMS™ near real time monitors will be used to monitor the enclosure for the presence of CA, using HD as the target analysis compound The DAAMS tubes will be used to provide confirmation and historical monitoring documentation 1 7 2 Monitonng Points Monitoring points will be located as specified in Annex B Monitonng 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 transport from the igloo area to the EDT site 14 1 8 EG&G, TOCDF, and DCD Support EG&G and DCD will provide site support services m Area 10 and at DCD dunng the EDT project This includes oversight of EDT operations, which consists of ensunng • 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 meet 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/Faci lities The TOCDF/DCD will provide the following equipment/facilities for the project • Temporary personnel facilities including shower/locker trailers 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 82 Utilities The EDT IS designed to be self-sustainmg EG&G will provide services to refill propane, diesei fiiel and water tanks 1 8 3 Security • DCD will provide round-the-clock security at Area 10 during setup, operations and demobilization • Access control will be maintained at Area 10 through badging and escorts for non- Unrestncted Access badged personnel EG&G will coordinate badging and escorting Note that personnel with need for unrestricted access will be part of the DCD Unescorted Access Program (UAP) 18 4 Site Preparation EG&G will provide site preparation and civil construction 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 followmg support durmg 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 training for all EDT personnel (see Armex G, Training Plan) 15 • Medical support via the TOCDF Clinic • Management and fiinding for the disposal of all hazardous waste generated • A temporary 90-day storage location for hazardous waste • Coveralls and cotton goods to be wom by operators dunng 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 18 6 Planning/Permitting The operating contractor will provide the following • The Destmction 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, CMA and EG&G 1 8 7 EDT Operations The EDT contractor will provide operations personnel, equipment, and consumables, including • The crew, which will consist of the necessary trained operators, safety, monitonng, and laboratory personnel to conduct site setup, pre-operational checkout and acceptance, systemization, and the Operational Readiness Review as supported by CMA, DCD, and EG&G • Donor Explosives, movement of the 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 21 Overview The DAVINCHTM system is designed to meet the requirements of the EDT project at TOCDF, including but not limited to mobility, stand-alone capability, safety, environmental protection measures, EE containment while chemical agent is processed, process monitonng analysis of chemical composition, appropriate connection with chemical agent monitoring (i e , process mterlocks) and analysis, UPS backup, and appropriate redundancy to complete the ongoing destmction backup operations 2 1 I Concept of Operations The explosive detonation system concept of operations is to destroy overpacked chemical munitions usmg specialized explosive donor charges m a vacuum-assisted, multiple-layered, armored-steel chamber capable of containing the explosion The extreme 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 DAVINCHTM model DV60 has the capacity to destroy 133 lb (60 kg) of TNTeq of explosive and is capable of destroying all the specified munitions listed in the specification without unpacking munitions or requiring other pre-treatment This can be accomplished 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 Svstem Design Requirements The DAVINCHTM system is designed to meet the requirements of the EDT project at TOCDF The DAVINCHTM DV60 has the capacity to destroy 133 lb (60 kg) TNTeq of explosive and can destroy all the specified munitions listed in Table 2 without unpacking or requiring other pre- treatment 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 diesei generators, storage for water, which will be refilled from the y^.- inch line and spigot located in Area 10, and storage for gases and fuel, including propane and diesei 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 fiilfill the scope of this project This DAVINCHTM will have the capability of destroying 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 (htmg) 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 of the 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 DAVINCHTM Containment The "primary" containment for the munitions is the existing overpacks The "secondary" or DAVINCHTM 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 (descnbed 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 of the EE will be an HDPE interlocking floor, approximately 2 inches thick, underlain with impermeable plastic sheeting The stmcture also provides secondary vapor containment dunng 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 m 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 contamed m separate sections of the EE The off-gas treatment equipment is housed in shipping contamers positioned outside of the 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 includes penodic inspections, and preventive maintenance and corrective maintenance 2 3 1 Monitonng Fatigue Damage DESTINY Real Time Fatigue Monitoring instrumentation system allows the fatigue damage to be monitored during every shot Information regarding the predicted time of crack initiation is assessed as the key indicator for long-term maintenance 2 3 2 Preventive Maintenance The preventive maintenance is performed as categonzed m Table 4 This preventive maintenance program is based on actual operational performance Inspection is performed in accordance with the Inspection Plan provided m Annex C 2 3 3 Equipment Maintenance Schedule The control system and its interface with an off-site system for performance data collection (know as GRAND) offers the information necessary for the equipment maintenance schedule and supports operators in real-time It estimates the maintenance timing based on the database, which incorporates statistical based estimation capabilities The database is updated with operational result input from similar sites worldwide Table 4 Schedule for Preventive Maintenance MAINTENANCE TYPE DAILY WEEKLY MONTHLY BIANNUALLY Maintenance Level A B C D Chamber Inspection - Visual Inspection - Visual Inspection - Cleanmg - Visual Inspection - Cleaning - Diameter Measurement - Visual Inspection - Cleanmg - Diameter Measurement - NDE (MT,PT) - Crack removal, if any Other Equipment Inspection (pump, cold plasma, off-gas filter) - Daily check by list - Check (e g , visual, noise, vibration, temperature, flow rate, leakage) - Removing header dust - Check loosened bolts around valves near detonation chamber - Measurement check (hook opening, chain diameter), periodic inspection (manufacturer's standard) - Drain removal of stack - Cleaning of filter elements - Penodic inspection (manufacturer's standard) - Acetone cleansing mn of vacuum pumps - Change filter elements if necessary - Replacement/ repair as necessary 10-hrs/day Mode Included in the Daily Operation 2 Hours 1 Day 3 Days Quantity of Personnel 2 3 4 8 PPE Yes Yes Yes Yes NDE Non Destruction Examination MT Magnetic Test PT Liquid Penetration Test 2 4 Design Features 2 4 1 Detonation Chamber The system includes two relatively close-fitting vessels The DAVINCHTM detonation chamber has distinctive features such as the double-walled steel chamber with a replaceable irmer vessel that protects the outer chamber from explosion fragments, and the vacuum that is established prior to detonation and sequential detonation to reduce the impulsive load, sound and vibration, and fatigue damage The double-walled chamber design is based on a "leak-before-burst" philosophy It IS cylindrical in shape, with hemisphencal end caps, the DV60 chamber interior volume is approximately 180 ft^ The maximum allowable explosive charge is 60 kg of TNTeq, 20 or approximately 133 lb of explosives The chamber opening is closed with a lid that uses a hydraulic clamping system and casketmg to ensure pressure retention The outer chamber is fixed to the foundation via saddles and is fabncated with laminated, cylmdncal, carbon-steel walls welded to monolithic carbon-steel top and bottom ellipsoidal heads The iimer chamber consists of layered steel and is considered a maintenance item - it is replaceable The replaceable inner liner is also constmcted of special steel, and it is built up m layers to minimize the propagation of any cracks, which are arrested by the discontinuity between the layers 2 4 2 Clamping Svstem The "auto-clamping" lid closure system was designed under recommendation by Lawrence Livermore National Laboratory The earlier DAVINCHTM design used two U-shaped circumferential clamps, and closure was accomplished by manually bolting the clamps together The new system is constmcted using eight independent clamps, configured to allow optimal control of the access door These clamps are dnven by automatic hydraulic or oil pressure This pressure is monitored to ensure that all clamps are functional and supply the required closure pressure 2 4 3 Munitions Handling/Installation in Chamber A scissor-type lift is used to lift the configured munition to a position in the chamber that will allow personnel to hang the munition and explosive using nylon web straps (or other approved hanging materials) along an interior track at the top of the inner liner The detonation chain is set, and the automatic hydraulic clamping system activated remotely to ensure a complete seal 2 4 4 Chamber Door/Movable Platform The hemispherical chamber door is mounted on an articulating mechanism that allows the door to move away from the chamber to provide access to the inner main chamber The main chamber is accessed by a movable robotic access ramp that does not touch the inner chamber 24 5 Off-Gas Fiher An inline filter is used to remove particulates, with filtration specification of 2 micro-meter efficiency > 99 97 % The filter has a backwash function 246 Off Gas Heater A stainless-steel inline electric resistance heater is used to maintain process temperature 247 Cooler An inline gas cooler, using a gas/air shell and tube configuration is used to modulate temperature of the off-gas to maintain process temperature 24 8 Off Gas Svstem The off-gas treatment system consists of a series of filtration banks and a "cold plasma" grid-arc oxidizer, followed by carbon filtration The Retention Tank provides a retention time of up to 10 minutes, slowed by the baffles intemal to the tank, this allows sampling to occur pnor to release, and redirection of the off-gas to the treatment process should any CA be detected 21 2 4 9 Vacuum Pumps Two redundant, inline vacuum pumps are used to evacuate the chamber These are off-the-shelf units with a capacity of 350 Nft"'/min, suction of 1 45 psi, and discharge of 0 2 psi The detonation product gas is extracted by a vacuum pump through an off-gas filter and then is sent to the off-gas freatment system A predetermined amount of oxygen is mixed with the off-gas at the cold plasma oxidizer where the hydrogen and carbon monoxide are oxidized Any CA remaining in the off-gas is destroyed by the cold plasma oxidizer 2 4 10 Cold Plasma Oxidizer The cold plasma oxidizer unit is a unique piece of equipment It is also called a Grid-Arc Plasma and has been developed for reforming some liquid fuels into synthetic gas or partial oxidation of natural gas, and upgrading hydrogen sulfide/methyl-mercaptan It is also now used as an oxidizer The advantages of the cold plasma are low power consumption, compact size, rapid startup time, and there is no need for pretreatment or catalyst However, the vital advantage of the cold plasma is the oxidation process During the oxidation process, the supplied oxygen is converted to oxygen radicals by high energy of electrons, and an oxidation reaction with H2 and CO is triggered, which makes the cold plasma oxidizer completely different from a conventional secondary combustion fumace The detonation product gas is directly mixed with oxygen and injected into the oxidizer as raw gas The ratio of oxygen and detonation product gas is maintained so that excess oxygen remains after the reaction, to ensure complete oxidation The reaction temperature is controlled by an appropriate ratio and flow rate of the detonation product gas and oxygen The oxidizer is initially heated by introducing a mixture of LPG and air Once the desired temperature is reached, the LPG flow is tumed off and the raw gas is introduced The flow rate of oxygen and raw gas are adjusted to maintain the desired stoichiometnc ratio, while the total flow is adjusted to maintain the oxidizer at the desired temperature The two units can operate in a fail-safe mode, where one unit can continue to operate if there is a failure of the other, albeit at a reduced flow rate This ensures that any detonation gas will be treated if either unit fails to operate 2 4 11 Cooler The off-gas is cooled after it passes through the cold plasma oxidizer using an inline gas cooler with a gas/air shell and tube configuration that modulates the temperature of the offgas to maintain process temperature 2 4 12 Scmbber The off-gas is scrubbed using an inline gas scrubber with a sodium hydroxide wash down The cooled gas is neutralized by the scrubber The condensate water generated in gas cooling is circulated through the inside of the scrubber 24 13 NaOH Tank This is a 50L steel tank that holds a 25% concentration NaOH solution used for the scmbber 2 4 14 Off Gas Blower An inline blower is used to maintain flow into the off-gas retention tank Specification is 42000 Nft'^/hr at ambient pressure with a silencer 22 2 4 15 Retention Tank A mild steel off-gas retention tank is used to slow the flow of the off-gas 2 4 16 Heater A stainless steel inline electric resistance heater is used to maintain process temperature To extend the life of activated charcoal, the gas is heated to about 113 °F (45 °C) before entering the filter unit 2 4 17 Carbon Filters A sulfur-impregnated carbon filter bank is used to filter the DAVINCH™ off-gas, with monitoring provided downstream of the filter's exhaust The air filtration system for the EE consists of prefilters, HEPA filters, and carbon filters along with a monitor, port fan, and ductwork A senes of modular chemical air filtration systems will be used, and each system houses two banks of carbon filters, two banks of HEPA filters, and one bank of prefilters Each bank contains nine 18-inch first-time-use filters that have never been exposed to chemical agent A smoke test will be conducted at the initial setup to certify the air filtration system and check airflow velocity to ensure that the EE is able to maintain negative pressure mside the stmcture relative to the outside air The size of the carbon filtration unit is adequate to adsorb any chemical agent that could be released from a leaking munition or item 2 4 18 Exhaust Air Blower An inline blower is used to maintain flow into the Environmental Enclosure HVAC fixed-bed carbon filters The specification is 126000 Nft^/hr 2 5 Other Support Equipment 2 5 1 EDT Control Room The EDT Control Room will consist of a rental trailer equipped with appropriate ventilation This will be the location for the Distributed Control System (DCS) control computers, communications control panel, safety system interfaces, and necessary manuals and SOPs The EDT Control Room will have a security lock, and access will be limited to operators who are trained to operate the system controls and inspectors from the Utah Department of Environmental Quality, in accordance with the SOPs The GRAND and DESTINY systems will be accessed from the EDT Control Room 2 5 2 Generators Redundant 600 kW diesei generators will be installed to provide power to the entire site A modular power distribution trailer will be used to distribute power for the installation 2 5 3 Air Monitoring Shelter Air monitonng equipment will be located in an enclosed shelter, with samplmg lines mnning to the various monitoring locations at the EDT site 2 5 4 Laboratorv 23 A mobile chemical laboratory trailer will be set up at the EDT site to provide air and liquid sample analysis services This laboratory will have its own HVAC system 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 of the DAVINCHTM campaigns and stored in accordance with 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 plarmed 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 trailer will be set up to allow breaks, rehydration, and rest area for the crew 2 5 8 VIP Trailer An observation trailer, 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 Unintermptible Power Supply (UPS) All monitoring equipment will be connected to an UPS All other site equipment (including the air filtration system) will be powered by the backup generator 24 3 0 EDT OPERATIONS The EDT will be operated m accordance with approved SOPs An operatmg order or scenano will be developed for each munition or item, based on the Munitions Assessment Review Board (MARB) data from the x-ray campaign conducted by DCD Each operating order will be located in the EDT Control Room. 3 1. System Delivery The delivery of the system will be accomplished in three phases 3 1 1 Transportation and Delivery of Main Chamber and Associated Components The main chamber is the heaviest component of the DAVINCHTM system, it weighs approximately 75,000 lb, and is approximately 10 feet in diameter, 11 feet high, and 23 feet long The major components of DAVINCHTM (main chamber, saddle, inner chamber, lid, clamping system, entry gantry, and associated piping) will be packaged for shipment at the Kobe Steel, Ltd , Takasago Works, in Kobe, Japan The system will be loaded into custom transportation saddles, stmctures, and packaging to minimize damage during shipment The chamber subsystem will be sea shipped via a common carrier to a US port of entry At the port of entry, a rigging subcontractor will transfer the system to a rail transportation configuration The system will be shipped from the coast by rail to a rail head near DCD (i e , to an industrial area near Tooele, Utah) A qualified heavy load contractor will transport the system component via escorted tmck from the rail head to the DCD Arrangements will be made with the State of Utah and local authorities to ensure safe transport and road capacity The same heavy load contractor will transport withm DCD, and ultimately, to the Area 10 EDT site Special provisions and coordination with DCD will ensure that road and gate configuration meet the requirements of the shipper The rigger will use an appropnate heavy crane to offload the unit onto the steel foundation, which will be installed prior to delivery Steel plating and certain reinforcements may be necessary to ensure road damage is prevented 3 12 Transportation and Delivery of Off-Gas Treatment Systems The off-gas treatment systems will be assembled in Salt Lake City and tmcked to the site over state and DCD roads The weights and dimensions of the off-gas systems are within the capability of a standard 40-foot trailer The off-gas system modular components will be off- loaded at the EDT site with a crane 3 1 1 Delivery of Support Equipment Support equipment, includmg but not limited to, the generators, conexes, containment stmcture, administrative trailers, and utility storage areas will be delivered over state and DCD roads 3 2 System Installation The site will be prepared for installation of the DAVINCHTM m accordance with the civil design, which addresses soil compaction requirements, grading, drainage, and utility locations 25 Layers of road base, gravel and rock will be placed on compacted soil to a sufficient depth to support the static and dynamic loading of the system A heavy steel foundation will be assembled on site, with steel plating on its surface The DAVINCHTM chamber saddle will be placed on the steel foundation, which will have steel penetrations into the soil and road base to ensure thmst blocking The floor of the DAVINCHTM 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 stmcture is assembled Pre-commissioning mcludes mnnmg tests for all the equipment to confirm that no damage occuned durmg transportation, and to validate proper connection of wmng and expected fiinctions Confirmation of piping connection air tightness and vacuum testing will also be conducted Explosive tests will confirm the DAVINCHTM chamber unit, off-gas unit, and utilities supply function as designed Figure 5 shows the phases of installation Period 1st week 2nd week 3rd week Workmg day 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Control /Electrical Room-*- Electricity —*t& Utility —*^ Preparation &Changin£ ^^r> 1 • 1 DAVINCH i Electrical Furnace —^ OfF gas skid • . • ^ Structure of sprung • m Covering over Equipment Membrane of sprung Pipe Connection I—» • *• HVAC system • 1 ^ f Wiring • ' ' • Commissioning —:—•—•—^ Test for each unit ® Power Supply Figure 5 Installation and Commissioning Schedule The chamber is inspected and tested for pressure tightness, and the operating performance of the 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 transportation 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 testmg will be performed The records from assembly, pre-commissionmg, 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 sunogate 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 handlmg operability, including required time and safety • Agent monitonng 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 destroy 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 destmction 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 tmck first entry clearance conducted using a spooled MINICAMSTM 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 Appropnate system checks will begin prior to each shift 27 3.5.1 Operational Steps Figure 6 shows the following conceptual steps of controlled detonation: • Installation of munitions with appropriate donor charge in the detonation chamber. • Evacuation of the air in the chamber and supply of minimum oxygen. • Activation of the controlled detonation explosion. • Evacuating the detonation product gas, sampling of the gas, and transfening it to the off-gas treatment system. Figure 7 shows the DAVINCHTM detonation chamber and the off-gas treatment system. The cold plasma oxidizer is mainly for oxidizing the explosive products of CO and Hi, and it is expected to provide additional agent Destruction Efficiency (DE) for back up. Munitions (CA.HE) Donor charge Vacuuming Minimum oxygen supply Clean off-gas (C02, H20, etc.) Munitions (CA and HE) are destroyed Detonation off-gas Off-gas treatment system (CO,H2,etc.) ----^ / r — — — — — —i » DAVINCH detonation | chamber ; 'open Cold Plasma Oxidizer Solid wastes 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 of the 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 of the LSC charges, to ensure that the overpack and munition is 28 appropnately 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, ensunng complete destmction 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 transfened 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 around 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 mto place m accordance with the plan descnbed 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 electnc 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 then exit the chamber All the explosive operations shall be done using the "buddy system" (two-man rule) Everyone on site will be accounted for prior to detonation 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 extremely 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 around the munition ensures an effective implosion process, reducing the speed and size of detonation fragments, and ensures a longer life of the inner chamber 3 5 5 Off-Gas Treatment and Air Flow Phases 29 The off-gas treatment process treats the detonation product off-gas on a batch-wise basis Figure 8 shows the pre-detonation, detonation, and post-detonation phases of the process Figure 9 shows the four basic treatment units, consistmg of the HVAC unit to draw a continuous flow of air from the EE, Treatment Unit A, which consists of the pre-filter and vacuum pump. Treatment Unit B, which consists of the Cold Plasma Oxidizer and its associated heat exchanger/cooler and blower, Treatment Unit C, which consists of the retention tank, carbon filter bypass and CA monitor, and Treatment Umt D, which consists of an inline charcoal filter and blower A utility system allows gases to be introduced mto the chamber or system During operation, various modes are used to ensure negative air flow when the chamber is open, and to balance the airflow to ensure EE negative pressure A damper is used to control this balance of air flow Annex D contams more detailed flow diagrams showing the various modes descnbed m this section, including flow rates 30 DAVINCH Operational Phase Preparation Pre- Detonation Detonation Treatment Phase Utility Management Preparation Vacuum Extraction Oxygen injection Detonation r. Post- Detonation Off-Gas Treatment-1 r. Post- Detonation mi Off-Gas Treatment-1 mi Off-Gas Treatment-2 Off-Gas Treatment-2 Off-Gas Treatment-3 Off-Gas Treatment-3 Fragment Recovery Figure 8 DAVINCH Off-Gas Treatment Phases 31 HEPA Charcoal —^Blowe^ Filter Filter —^Blowe^ HVAC Stack Damper Detonation Chamber Containment Charcoal Filter UnitD Charcoal Filter Retention Tank Unite Vacuum Pump Unit A O XI d I ze^»[cZie^»^iowe^ Unite Utility Figure 9 EDT Block Flow Diagram 32 3 5 5 1 Dunng 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 m this configuration The exhaust air from the HVAC System (reference Figure 9, HVAC) is maintained at a constant flow rate The air is fed through Unit D during this mode of operation Dunng this phase, munitions are hung, detonators set, and processing activity can occur within the chamber The damper is used in all phases to equalize air flow and maintam negative EE pressure with respect to the extenor 3 5 5 2 The Air Vacuum phase (i e , 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 appropnate 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 monitonng 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 back through Unit B for further treatment m the cold plasma oxidizer The chamber lid remains closed during this sequence 3 5 5 6 After the preliminary CA check in 3 5 5 5, the system operates at full extraction, processing all of the detonation gas through units A, B, and C, and through the final, exterior carbon beds 3 5 5 7 The chamber lid is opened when all of the 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 If decontamination of the chamber is required the chamber lid is closed, and Electrostatically 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 decontaminated, the system is exhausted once again through Units A, B, and C An alternative option for decontamination of the chamber is the use of a cleansing shot 3 5 5 9 The system reverts to the pre-detonation configuration where the exhaust gas is removed as m the pre-detonation mode Fragments are removed by electromagnet and by hand, if large enough 3 6 Throughput 33 Table 5 shows the expected throughput for each munition type, in a single or double overpack, and samples This throughput expectation is based upon the operational experience of 5 years of operations in Japan and one year of operation in Belgium Improvements on automated fragment handling and a larger capacity of off-gas treatment are incorporated into this design Three 4 2- inch HT Motor rounds in M13A2 single over-packs can be detonated in a single shot, and a 155- mm H Projectile in M16A3/12X56 double over-packs can be detonated by one shot, using a total amount of explosives of approximately 118 lb (53 6 kg) TNTeq 34 Table 5 TOCDF EDT Throughput Munition Overpack(s) Agent Number of Munitions & Samples Munitions/ Package Packages/ Shot Mumtions/ Shot Shots/ Day Number/ Day Days Weeks' Shots Agent/ Shot (ib) PEP/ Shot (lb TNTeq) Donor/ Shot (lb) Donor/ Shot (lb TNTeq) LSC/ Shot (lb TNTeq) Total TNTeq/ Shot (lb) 4 2 HT Mortar MI3A2 HT 117 1 3 3 7 21 6 1 5 39 174 2 55c 87 6 8S8 26 2 1176 4 2 HD Mortar M13A2 HD 18 1 3 3 7 21 1 03 6 18 2 55c 87 6 88 8 26 2 1176 ECR/ECV Explosive Waste" 9x41 or 7x27 See Note a 1 1 1 7 7 2 05 7 60 2 55c 65 7 66 6 87 77 9 155mm 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 155mm H Projectile 9x41 H 27 1 1 1 7 7 4 1 0 27 11 7 0 43 . 76 6 77 7 14 6 92 7 155mm H Projectile M16A3/M10A4 H 16 1 1 1 7 7 3 08 16 11 7 0 43 76 6 77 7 14 6 92 7 155mm H Projectile PA37/12x56 H g 1 1 1 7 7 2 05 8 11 7 0 43 102 2 103 6 14 6 1186 155mm H Projectile M16A3/12x56 H 79 1 1 1 7 7 12 30 79 117 0 43 102 2 103 6 14 6 1186 HT Samples M2AI HT 41 4 1 4 7 28 2 05 11 92 0 45 4 46 46 0 HD Samples M2A1 HD 6 4 1 4 7 28 1 03 2 5 1 0 45 4 46 46 0 Total • 386 Totals • 38 95 229 "Either over pack may be used for ECR Explosive Waste This waste stream is limited to explosive or explosive munition components found during the closure of the ECR/ECV and Subpart X Treatment Units within the ECRs and ECVs The number of DAVINCH treatment shall not exceed 6 "•Based on anticipated four days per week munition processing 'PEP weight included propellant Note only one over-packed mortar is known to be configured with propellent 35 3 7 Operatmg 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 Momtormg And Control Operations EDT Air Monitoring Plan and Operations* Analysis Plan and Analysis SOPs* Waste Management Operations Matenal Handling Operations Maintenance Operations Metal Fragment Drum Headspace Monitoring Operations* (The * indicates required approval by DSHW pnor 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 of the generators that support DAYtNCHTM operations • Completion of Installation and Systemization is anticipated to occur the first quarter of Calendar Year (CY) 2011 • The ORR will take place after Installation 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 decontammation 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 monitormg to the Vapor Screen Limit (VSL) for HD All components will be decontaminated to the levels specified in the closure plan. 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 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 of the equipment/ piping. Necessary ports are pre-installed in the equipment and piping to provide an insert point for the nozzle of the ECAD decon wands. As DAVINCH'^'^ has no expansion tank, there is no concem about accumulation of carbon dust with CA or heavy metals from the munitions paint residue in the tank. Figure 10 shows the effect of cleansing shots and Figure 11, an illustration of ECAD. Cleansing Shot 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. Hazardous waste from the PAS will also be managed on-site in accordance with hazardous waste management rules. 37 The chamber and lid systems will be placed on the shipping pads that were used to deliver the components A reversal of the 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 Versar/ECBC 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 retumed 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 of the 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, persormel not directly associated with the chemical operations are not to be allowed withm the PAED The PAED for the EDT maximiun credible event (MCE) is defined in Annex D of the SSSP There are no occupied facilities m 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 Annex C of the SSSP for the EDT Site defines the MCE for Establishing PAED as the detonation of 133 lb of TNTeq The MCE, as defined in DA PAM 385-61, is the potential 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 dismptive 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 3 11 Waste Analysis Plan The DAVINCH™ will treat wastes that were previously charactenzed by TOCDF, and the DAVfNCH^'^ 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 of the 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 charactenzed by these previously sampling and analysis efforts for their treatment in the DAVINCH™ considenng that the issues with mortar charactenzation is the presence of mercury The DAVrNCH^"^ PAS is equipped with sulfiir-impregnated activated carbon filter to control mercury emissions Waste generated by DAVINCH''"'^ operation are metal munition and overpack fragments, condensate formed by the oxidation of the hydrogen contained m the chemical agent, munition burster and explosive LSCs and donor charges, spent scmbber solution, monitoring waste, spent decontamination solution, particulate filters, ash, spent activated carbon, laboratory waste, and discarded PPE The estimated quantities of waste to be generated from the DAVINCH''"'^ operation descnbed 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 (Ib/Bfast) (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 2133 0 55 37 155mm H Projectile 9X41 1179 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 (Ib) • 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 banels 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 dmm's outlet valve The air purge IS then stopped and the valves closed The contents of the 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 dmm to be less than 0 50 VSL, the contents of the dmm are transfened to a roll-off or DOT-approved shipping container for disposal at a Subtitle C Treatment, Storage, and Disposal Facility (TSDF) If the monitonng results show a drum headspace result equal to or greater than 0 5 VSL, for metal fragments and 1 0 VSL for PPE, the dmm and its contents will be transfened to the TOCDF and processed through either the Metal Parts Fumace (MPF) or the Autoclave 39 Condensate from the oxidation of hydrogen in the explosives and agent is combined with scmbber bnne The waste stream exiting the liquid scmbber will be analyzed for agent content, TCLP metals and TCLP organics This waste sfream will be fransferred 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 DAVINCH''''^ 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 of the over-packs contain packing matenal and absorbents that were added to prevent the mumtion from moving inside the over-pack The absorbents used were cloth rags and vermiculite This waste stream 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 transfened 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 DAVINCHTM 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 analytical 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 DAVINCIF^ WASTE ANALYSIS SUMMARY (On-Site) WASTES REQUIRING ON-SITE TREATMENT WASTE STREAM TREATMENT UNIT(S) ANALYTICAL PARAMETERS PREPARATION and ANALYTICAL METHODS FREQUENCY OF ANALYSIS (Establish Profile) SAMPLING METHOD 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 DAVINCH™ 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-inch 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 charactenzed durmg TOCDF Ton Container, HT, and Mortar Campaigns HD mortars charactenzed during Projectile Washout System Testing, data provided to DSHW Not Applicable \ Not Applicable Not Applicable 41 Table 8 TOCDF DAVINCIFM WASTE ANALYSIS SUMMARY (Off-Site) WASTES REQUIRING Ol FF-SITE TREATMENT/DISPOSAL WASTE STREAM GENERATION SOURCE ANALYTICAL PARAMETERS PREPARATION and ANALYTICAL METHODS' FREQUENCY OF ANALYSIS SAMPLING METHOD Munition and Overpack Metal Fragments DAVINCHTM Container Headspace Agent Monitoring PR-010 Each Drum Generated Headspace Monitonng method, ensure representative sample analyzed by MINICAMS™ Spent Decon DAVINCHTM Agent HD PR-016 One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Decon DAVINCHTM TCLP Metals 1311,3010A or 3015A, 60IOC or 6020A, and 7470A One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Decon DAVINCHTM TCLP Organics 1311,5030B/8260B, and3510C/8270D One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Decon DAVINCHTM pH 9040C One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Monitoring/Laboratory Waste Aqueous DAVINCH™ Agent HD PR-016 One sample from each container generated Coliwasa Monitoring/Laboratory Waste Aqueous DAVINCH™ TCLP Metals 1311,3010A or 3015A, 6010C or 6020A, and 7470A One sample from each container generated Coliwasa Monitoring/Laboratory Waste Aqueous DAVINCH™ TCLP Organics 1311,5030B/8260B, and35]0C/8270D One sample from each container generated Coliwasa Monitoring/Laboratory Waste Aqueous DAVINCH™ pH 9040C One sample from each container generated Coliwasa Monitoring/Laboratory Waste Aqueous DAVINCH™ Ignitability 101 OA or1020B One sample from each container generated Coliwasa Monitoring/Laboratory Waste Solid DAVINCHTM Agent HD PR-016 One sample from each container generated Coliwasa 42 Table 8 TOCDF DAVINdF^ 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 Spent Scrubber Brine and Condensate DAVINCH™ Agent HD PR-016 One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Scrubber Brine and Condensate DAVINCH™ TCLP Metals 1311,3010A or 3015A, 60IOC or 6020A, and 7470A One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Scrubber Brine and Condensate DAVINCH™ TCLP Organics 1311,5030B/8260B, and3510C/8270D One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Spent Scrubber Brine and Condensate DAVINCH™ pH 9040C One sample from each of 3 containers generated, composited into one sample set for analysis Coliwasa Detonation Chamber and PAS Particulate Filter Ash/Over-Pack Packing Material DAVINCHTM Agent HD PR-016 One sample from each of 4 containers generated, composited into one sample set for analysis Trier or coring device Detonation Chamber and PAS Particulate Filter Ash/Over-Pack Packing Material DAVINCHTM TCLP Metals 131],3010A or 3015A, 60IOC or 6020A, and 7470A One sample from each of 4 containers generated, composited into one sample set for analysis Trier or coring device Detonation Chamber and PAS Particulate Filter Ash/Over-Pack Packing Material DAVINCHTM TCLP Organics 1311, 5030B/8260B, and3510C/8270D One sample from each of 4 containers generated, composited into one sample set for analysis Trier or coring device Spent DAVINCH™ PAS Activated Carbon DAVINCHTM Agent HD See Note 2 Core sample from each container generated during change out, composited into one sample set for analysis Trier or coring device Spent DAVINCH™ PAS Activated Carbon DAVINCHTM TCLP Metals 1311,3010A or 3015A, 60IOC or 6020A, and 7470A Core sample from each container generated during change out, composited into one sample set for analysis Trier or coring device Spent DAVINCH™ PAS Activated Carbon DAVINCHTM Total Metals 3050B or 3051 A, 60IOC or 6020A, and 747 IB Core sample from each container generated during change out, composited into one sample set for analysis Trier or coring device Spent DAVINCH™ PAS Activated Carbon DAVINCHTM TCLP Organics 1311,5030B/8260B, and3510C/8270D Core sample from each container generated during change out, composited into one sample set for analysis Trier or coring device Spent Environmental Enclosure HVAC System Carbon Environmental Enclosure Carbon Filter Units Agent HD See Note 2 Core sample from each contamer generated during change out. Tner or cormg device 43 Table 8 TOCDF DAVINCHTM 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 composited into one sample set for analysis Notes 1 Reserved 2 Agent monitoring results may be used to demonstrate spent carbon is not contaminated with agent m lieu of performing an analysis for chemical agent Agent contaminated, spent carbon will be place in storage until a DSHW approved method is available for analysis of agent on an activated carbon matrix 44 # 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), sann (GB), VX, and blister agent sulfur mustard (including H, HT, and HD) for demilitanzation workers and the general public (Reference 4) Exposure critena include short-term exposure limits (STELs) and immediately dangerous to life or health (IDLH) values These new cntena augment revised long-term cnteria, which include Worker Population Limits (WPLs) and General Population Limits (GPLs) The cnteria were revised using vanous nsk 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 cnteria 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 nsk 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 mg/m^ WPL(8hr) 0 0004mg/m^ GPL OOOOlmg/m^ 3 12 2 Exposure Points The DAVINCHTM process potential exposure points are • Leaking Overpack/at Delivery - Overpacked munitions are delivered to the DAVfiSfCHT"^ in a box tmck The overpacked munitions will be checked prior to placement in the tmck The sealed storage compartment is monitored for agent upon amval at the DAVINCH^^ If the monitoring results are confirmed to be greater than or equal to 0 5 VSL the delivery is not accepted and the contents of the truck are retumed to DCD and processed by the DAVINCH"^^ at a later date • Leaking after Receipt from DCD - If the leak occurs within the DAVrNCHT"^ Environmental Enclosure the overpacked mumtion 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 • Leaking after Entry into Chamber - If agent is detected in the chamber after hanging the munition, the DAVINCHTM' 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 of the 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 DAVINCHTM sites 3 12 3 Personal Protective Equipment 45 The PPE for the operator crews v^U consist of supplied PPE, including but not limited to coveralls and cotton goods to be wom by operators dunng 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 DAVINCHTM 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 DAVFNCHTM 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 unit, waste handlmg, and the off-gas treatment are contained in a temporary plastic-film (with aluminum- or steel-framed) shehers acting as the EE containment stmcture The airflow from the EE containment provides a design negative pressure -0 10 to -0 5 inWC 3 13 2 Safety m Enclosure Safety systems included in the enclosure have explosion mitigation bamers 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 m 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 at the time of use 3 13 4 Emergencv and Evacuation In the event of an upset condition personnel on site will be notified by the PA system Evacuation will then occur m accordance with the SOP for response to upset conditions requiring evacuation All personnel evacuating from the site 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 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 46 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 tnage 47 4 0 ORGANIZATION The overall orgamzation for the EDT Project at TOCDF is shown in Figure 12 Chemical Materials 3it^lVlanagei| :^ : I Dpm Chftiicat i. epot 'lOCDFH Figure 12 TODCF EDT Overall Organization 4 1 US Army The principal US Army organizations involved m implementing this Plan include the Chemical Materials Agency (CMA), the Tooele Chemical Agent Destruction 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, and chemical/hazardous materials response ECBC provides the assets of CB ARR, for trained CPRP- and explosive- certified operators, monitonng equipment, and mobile laboratory support 4 2 State of Utah The UDEQ will provide environmental regulatory oversight of the DAVfNCHTM operation at TOCDF The DAVINCHTM operation at TOCDF will be conducted under a Modificafron to the RCRA and CAA pennits for TOCDF and DCD, respectively 48 4 3 Contractors The TOCDF Operating Contractor, EG«&G DMI (URS) will provide oversight of the EDT subcontractor, Versar, Inc and its team members ECBC and KOBE Steel LTD 4 4 EDT Site Operational O^anizatibli The EDT Site Operational Organization is shown in Figure 13 The EDT Subcontractor will provide the EDT equipment, and will control operations to ensure that destmction is conducted in a safe and environmentally acceptable manner The total number 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 monitonng on mght shifts and weekends Expfesivei Figure 13 EDT Site Operation Organization 49 5.0 REFERENCES 1 Statement of Work for EDT at TOCDF, EG&G 2 29 Code of Federal Regulations (CFR) 1910, Occupational Safety and Health Standards, Subparts D, E, G, H, I, J, L, M, O, and S, DoD 6055 9-Std, Department of Defense Ammunition and Explosives Safety Standards, Febmary 29, 2008, Chapters 4, 5, 6, 7, 8, 9, and 11 3 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 4 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 5 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 6 DA PAM 385-65, Explosive and Chemical Site Plan Development and Submission, 1 Febmary 2008 7 Explosive Site Safety Plan Developer's Guide, Febmary 2006, Sections 5, 6, 11, and 12, and Appendices A and B 8 AR 415-15, Army Military Constmction Program Development and Execution, Paragraph 2- 16 9 DA PAM 385-65 Explosive and Chemical Site Plan Development and Submission, 1 Febmary 2008 10 TM 5 -1300, Structures to Resist the Effects of Accidental Explosions, 1999 11 MIL-STD-882D, Standard Practice for System Safety, 10 Feb 2000 12 DA PAM 385-16, System Safety Management Guide, 13 November 2008 13 EG-073 R03 C03, Operational Readiness Review Guide 14 Revised AELs for Agents H and HD (Sulfiir Mustard), Federal Register, 69(85), 24164- 24168 50 EDT DESTRUCTION PLAN ANNEX A - ACRONYMS AND ABBREVIATIONS Revision 1 November 2010 ANNEX A - ACRONYMS AND ABBREVIATIONS This Annex presents the Acronyms and Abbreviations used in the TOCDF EDT Destmction Plan and Annexes 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 Amencan National Standards Institute Army Regulation American Society of Mechanical Engineers Alternative 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 Munitions Department of the Army Pamphlet Depot Area Air Monitoring System Detonation of Ammunition in a Vacuum Integrated Chamber di-Butyl 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 Division 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 A-2 ACRONYM/ABBREVIATION DEFINITION HEPA High efficiency particle anesting 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 Operatmg 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 Matenal Safety Data Sheet NaOH Sodium Hydroxide NFPA National Fire Protection Association OSHA Occupational Safety 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 ACRONYM/ABBREVIATION DEFINITION UPS Unintermpted power supply USATCES US Army Technical Center for Explosives Safety VSL Vapor Screening Level WC Inches of water column, as in pressure differential WCL Waste Confrol Limit WPL Worker Population Limit A-4 EDT DESTRUCTION PLAN ANNEX B MONITORING PLAN (Rev. 2) December 2010 SITE-SPECIFIC MONITOMNG PLAN (Rev. 2) 155-mm Leaker Campaign Explosive Destruction Technology (EDT) Operations Deseret Chemical Depot (DCD) Submitted to '\ Zi[vii\on of URS EG&G Defense Materials, Inc A Division of URS, Inc 11600 Stark Rd Stockton, UT 84071 Submitted by ERS AR Versar, Inc 6850 Versar Center Springfield, VA 22151 December 2010 TABLE OF CONTENTS TABLE OF CONTENTS I APPENDICES II LIST OF TABLES II LIST OF FIGURES III 10 INTRODUCTION 1 1 1 BACKGROUND 1 12 PURPOSE 2 13 SCOPE 2 1 4 CHEMICAL AGENTS OF CONCERN 2 1 5 MONITORING OBJECTIVES 3 2 0 ORGANIZATION AND MANAGEMENT RESPONSIBILITIES 3 2 1 CMA 3 2 2 CMA-MONITORING OFFICE 4 2 3 ECBC 4 3 0 MONITORING CONCEPT 4 4 0 MONITORING STANDARDS AND CONTROL LIMITS 5 4 1 AELs FOR CHEMICAL AGENTS 5 4 2 AEL DEFINITIONS 6 5 0 MONITORING AND SAMPLING EQUIPMENT 9 5 1 MINICAMSTM EQUIPMENT DESCRIPTION 9 5 2 DAAMS SAMPLING EQUIPMENT DESCRIPTION 9 5 3 NEAR-REAL-TIME MONITORS , 9 5 4 DEPOT AREA AIR MONITORING SYSTEM 9 5 5 DILUTION AIR FLOW CONTROLLERS (DAFC) 10 5 6 BACKUP EQUIPMENT 10 5 7 MONITORING AND ANALYTICAL EQUIPMENT OPERATIONS A?ffl>MAiNTEN.4NCE (O&M) REQUIREMENTS 10 6 0 MONITORING OPERATIONS/STRATEGIES 15 6 1 NRT/CONFIRMATION 15 6 2 HISTORICAL/CONFIRMATION 15 7 0 MONITORING SYSTEMS 16 7 1 NRT MONITORING 22 7 2 CONFIRMATION AND HISTORICAL MONITORING 25 7 3 FIRST ENTRY 27 7 4 HEADSPACE 28 7 5 PERSONNEL DECONTAMINATION STATION (PDS) 28 7 6 HISTORICAL MONITORING 28 7 7 VAPOR SCREENING OF SAMPLE CONTAINERS 28 8 0 SAMPLE AND ANALYTICAL METHODS 29 9 0 ALARM RESPONSE/REPORTING POSITIVE CHEMICAL MATERIEL RESPONSES 29 9 1 MONITORING LEVELS 29 9 2 MINICAMST^M ALARM SETPOINTS 29 9 3 NRT NOTIFICATIONS 29 9 4 CONFIRMATION AND HISTORICAL NOTIFICATIONS 29 9 5 WPL EXCURSIONS 32 10 0 MONITORING OF POTENTIALLY EXPOSED WORKERS 32 110 QUALITY CONTROL REQUIREMENTS 32 111 CERTIFICATION REQUIREMENTS 32 11 2 CALIBRATION AND TEST METHODS 35 11 3 QC SAMPLING 36 11 4 SAMPLE HANDLING AND STORAGE 38 11 5 STATISTICAL VALIDATION 40 11 6 QC OF DAAMS TUBES 40 11 7 TUBE CONDITIONING 41 12 0 DOCUMENTATION 42 12 1 GENERAL MONITORING DOCUMENTATION 42 12 2 EQUIPMENT DOCUMENTATION 42 12 3 REFERENCE STANDARDS 42 13 0 TRAINING REQUIREMENTS 42 APPENDICES APPENDIX 1 ACRONYMS/ABBREVL^TIONS/TERMS 43 APPENDIX 2 REFERENCES 47 LIST OF TABLES 4-1 H/HD/HT AELs 7 4- 2 H/HD/HT AELs 8 5- 1 Description and Requirements for Monitoring and Sampling Equipment 11 5- 2 Support Gases Equipment Requirements 14 6- 1 Monitoring Application and Monitor Type 16 7- 1 Summary ofMomtonng Strategy for DAVINCH™ DCD EDT Operations 18 9-1 Reserved 9-2 DAAMS Tube Analysis Matnx 31 11-1 QC Requirements for lOP MT-02 33 11-2 QC Requirements for lOPMT-13 34 11-3 Samples Sizes for Normal Inspection for Maximum of 2 5 Percent Nonconformance 41 11 LIST OF FIGURES 7-1 Monitoring Locations and Diagram of DAVINCH™ System 17 111 10 INTRODUCTION This document presents a site-specific plan for air and waste monitonng at the site of the Detonation of Ammunition in a Vacuum Integrated Chamber (DAVINCH''''^) Explosive Destmction Technology (EDT) System at the Deseret Chemical Depot (DCD), Stockton, Utah This plan addresses the monitonng requirements as specified m the U S Army Chemical Matenals Agency (CMA) Programmatic Monitoring Concept Plan (MCP), the CMA Programmatic Laboratory and Monitonng Quality Assurance Plan (LMQAP), and the Edgewood Chemical Biological Center (ECBC) Envu-onment Momtormg Laboratory, Laboratory and Monitoring Quality Control Plan (LMQCP) for Chemical Materials Agency (CMA) and for Chemical Agent Standard Analytical Reference Material (CASARM) 1 1 Background EG&G DMI, a contractor to the U S Army and operator of the Tooele Chemical Demilitanzation Facility (TOCDF), located on the DCD, has a requirement for a technology to process 333 reject munitions that either exhibited or have a high probability of exhibiting conditions that do not allow them to be processed using baseline practices The TOCDF researched other technologies used to destroy leaking and overpacked chemical weapons, including Explosive Destmction Technology (EDT) that has been or is cunently being used in the United States, United Kingdom, Belgium, and Germany Explosive Destmction Technology evolved from an increasing need to safely destroy recovered chemical warfare material (RCWM) The EDTs have safely destroyed RCWMs in Pine Bluff, Arkansas, Waianae, Hawaii, Porton Down, United Kingdom, Poelkapelle, Belgium, and Munster, Germany Riot control and various mustard agents (with and without energetics) have also been safely destroyed by EDTs These EDTs have also proven effective for destmction of conventional weapons EG&G DMI has subcontracted with Versar, Inc , to provide EDT services to include a detonation chamber, exhaust gas filtration system, environmental enclosure with engineered cascade ventilation system, all necessary subsystems and operators as a complete package, this package will be delivered to, installed, systemized, operated, closed, and removed from the DCD in Stockton, Utah The EDT system to be provided by Versar (i e , DAVINCH™, model DV60 ) will process the chemical warfare matenal (CWM) inventory of 155-mm Projectiles and 4 2-inch Mortars (leakers and rejects) and agent samples stored at the TOCDF and identified for explosive system destmction disposal by the Munitions Assessment Review Board (MARB) The chemical agent of concem for these munitions is mustard The EDT process at DCD is to mn parallel to TOCDF's current baseline schedule so as not to impact TOCDF mission completion by the CWC treaty date 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 extreme pressures, temperatures, and shock waves generated by the donor charge destroy the overpack, munition body, explosives/burster charges contained m the munitions, and chemical agent fill in microseconds Operations will be controlled from a remote control room that contains all human- machine interface, process monitoring, CCTV, and communication equipment The DV60 has the capacity to destroy 133 lb (60 kg of TNT equivalent) of explosives and all of the specified 1 munitions listed in the RFP 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 momtonng will be performed at levels required for unmasked workers, designated as "no respiratory protection" in airbome exposure limit (AEL) tables All MINICAMS™ momtonng systems will operate continuously under normal baseline and, therefore, will be challenged during non-operational hours Chemical agent products are not intended to be stored on-site m the Environmental Enclosure (EE) dunng non-operational hours 12 Purpose The purpose of this plan is to provide the strategy to monitor for potential airbome vapor concenfrations and generated waste products for the chemicals of concem during operation of the DAVrNCH'^^M 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 mdicate whether or not EDT operations are m confrol 13 Scope This plan establishes momtonng objectives, procedures, and responsibilities for the execution of a monitonng 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 DAVnSfCH'TM 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 the levmstem process contains about 30 percent sulfur impunties 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 impunties • 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 Monitormg Objectives Monitonng dunng DAVrNCH'^^M gj)j operations will be performed to ensure that chemical matenal destmction operations are being safely conducted, and to detect any conditions that may cause a release of chemical matenal Momtonng of the DCD EDT site will ' • Provide worker protection • Protect the environment from a potential chemical agent release • Provide early warning 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 penod of time, dependmg on the level of protechon wom by personnel In general, unmasked workers should not exceed established Worker Population Limits (WPL) 2 0 ORGANIZATION AND MANAGEMENT RESPONSIBILITIES The EDT operations at DCD will requu-e 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 of the 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 monitonng QA requirements for monitoring activities Advising on laboratory-related quality assurance/quality confrol (QA/QC) practices Recommending QA/QC practices for use in supporting the EDT momtormg activities Monitonng 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 Monitonng Branch ECBC will Collect, validate on site, and retain all monitoring data and monitonng QC data generated during the project Provide guidance for monitoring operations conducted on-site Provide framed and certified personnel to set up, calibrate, and challenge monitonng equipment, and collect momtonng 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 analyzmg Depot Area Au* Momtonng System (DAAMS) tubes 3 0 MONITORING CONCEPT Monitonng 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 of personnel, 4 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, Paragraph 6-1) To effectively implement the cardmal prmciple, engmeermg confrols, admimstrative confrols, and PPE are used in combination, and each play a cntical support role Engmeenng and admimsfrative controls shall be implemented, when practical, to minimize • Number of personnel involved m operations, • Personnel 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 engmeenng and admimstrative 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 admimsfrative controls, and when PPE is used, momtonng shall be used to ensure that levels, as defined m section 4 0, are not exceeded Placement of each momtonng/sampling point shall be based on potential chemical migration points, and designated momtormg points shall be verified via the use of sulfur hexafluonde (SF6) or smoke tests When monitonng 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), and Vapor Screening Limit (VSL) 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 m the area for the 8-hour period should not exceed the 8-hour WPL exposure limit for the level of protection wom by the worker If the exposure limit is exceeded, implementation of corrective actions is required 4 2 AEL Definitions 4.2.1 General Population Limit (GPL) The GPL is an allowable 72-hour, time-weighted-average concenfration for the general population The limit applies to the entire population, includmg all ages and medical conditions The 12-hour GPL for HD is 2 x 10'^ mg/m^ 4.2.2 Worker Population Limit (WPL) The WPL is the average allowable concenfration that an unmasked worker could be exposed to for an 8- to 12-hour workday, 40 hours per week for 30 years, without adverse effects The WPL for the DCD EDT Site has been adjusted to reflect a 10- to 12-hour work shift However, smce operators will not spend more than 8 hours undergoing destmction operations, the 8-hour WPL for HD (i e 4 X I0"^mg/m^) will be used, 4 2 3 Short-Term Exposure Limit (STEL) The STEL is the maximum concenfration to which unprotected chemical agent workers may be exposed to for up to 15 mmutes, continuously The STEL for mustard agent is 3 x 10'^ mg/m^ Only one exposure daily is allowed at the STEL for mustard 4 2 4 Vapor Screening Limit (VSL) The VSL is a vapor concenfration term that is independent of time It may be used to defme the level to which an item is momtored to determme the agent contamination level The VSL for mustard agent is 3 x 10' mg/m 4 2 5 Immediately Dangerous to Life and Health (IDLH) The IDLH is the maximum concenfration, m the event of respirator failure, where a person could escape withm 30 mmutes without a respirator and without experiencmg any escape-irnpamng (e g , severe eye imtation) or irreversible health effects The IDLH level is 0 7 mg/m for mustard agent Table 4-1 H/HD/HT AELs' Sulftir Mustard (H, HD, HT)' Criteria GPL WPL STEL' IDLH' Exposure Level (mg/m3) 0 00002 Averaging Tune 12 hours Recommended Monitonng Method Histoncaf 0 0004 8 hours Histoncaf or Near-real- time 0 003 <15 mmutes Near-real-time 07 <30 minutes Near real-tune Although the Centers for Disease Control and Prevention (CDC) do not specifically recommend additional reduction factors for statistical assurance of action at the exposure limit, exposures to sulfur mustard should be mimmized given the uncertamties in nsk assessment, particularly as related to charactenzing 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 hazard under nonnal ambient conditions For sulfur mustard and T mixtures, air momtonng for sulfur 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-shifl The mustard IDLH is based only on non-carcinogenic effects No IDLH has been established for carcinogens Historical monitoring typically is used for time-weighted-average (TWA) monitonng where the sample analyzed represents an extended time penod, for example, 8 or 12 hours Results are not known until laboratory analysis is completed after the sampling event The AELs using histoncal 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 m sigmficant health effects unless such exposures occur continuously for long time periods Table 4-2 H/HD/HT AELs H/HD/HT GPL (12 hours) WPL (12 hours) WPL (8 hours) WPL (4 hours) WPL (2 hours) STEL" (15 mmutes) Variable General Population 2x 10' No Respiratory Protection 2 7 x IQ-" 4x10-'* 8 X 10-'* •I 6x10"^ Air-Purifying Respirator 3 X lO"" Air-Purifying Respirator For sulfur mustards, air-purifying respirators are for escape purposes only Self-Contained Breathing Apparatus or Supplied-Air Respirator with Escape Bottle 0 27 04 08 16 3 0 Demilitarization Protective Ensemble 20x 10" 40 80 160 30 0 Vapor Screening Limit (VSL) 100 0^ 3x 10-^ " Exposures at the STEL shall occur not more than one time per day The Centers for Disease Control and PrevenUon (CDC) may publish updated numbers Implemented as a ceiling value Notes Airbome exposure limits (AELs) are taken from Army Regulation 385-61 (12 October 01) and 69 FR 29164-29168 (03 May 04) All AELs are concentration and time values, not concentration only values Administrative controls may be used to limit potential exposure to workers However, because administrative controls cannot be used to limit the duration of potential public exposure, only the worker population limit (WPL) protective action level is significantly affected by administraUve controls, which limit the duration of potenfial exposure The maximum use concentration is the product of the AEL and the assigned protection factor for the respirator The assigned protection factors used m this table are taken fi-om 68 FR 34036-34119, 6 June 2003 The mixture HT shall be monitored as HD 5 0 MONITORING AND SAMPLING EQUIPMENT The chemicals of concem at the DCD EDT site will be momtored usmg the following equipment • MINICAMS™, and • DAAMS tube sample collection followed by analysis with GC/MS The MINICAMS^"^ is considered a Near-Real-Time (NRT) agent monitor The DAAMS is used as a histoncal method and for confirmation of NRT alarms and histoncal concentrations greater than the reportable limit(s) The following paragraphs describe the momtonng equipment in more detail 5 1 MINICAMS™ Equipment Descnption The MINICAMS™ is an automated gas chromatograph (GC) that operates by alternating 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 Dunng 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 earned 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 histoncal monitoring at WPL The DAAMS stations are comprised of solid sorbent (TENAX) DAAMS tubes, sample mamfolds, sequencers, pumps, and flow control devices Air monitormg with DAAMS employs air aspiration through the DAAMS tube for a predetermined penod 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 matenal at the prescnbed momtonng levels Laboratory analysis uses thermal desorption of the analj^es from the sorbent tubes into a GC/MS 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 the WPL, VSL, and IDLH concenfrations of the mustard chemical agents 5 4 Depot Area Air Monitoring System Depot Area Air Momtormg System (DAAMS) collects air samples to detect chemical agents, for confirmafron of NRT momtor alarms Analysis of DAAMS samples provides confirmation of agent if concentrafrons are at or above the defined Reportmg Limit (RL) The RL for Histoncal WPL DAAMS is 0 5 WPL The RL for NRT confirmation DAAMS is any positive response based on a minimum peak area above the instrument noise level to be determmed durmg method development Instrumentation used for agent confirmation is GC- Mass Selective Detector (GC-MSD) 5.5 Dilution Air Flow Controllers (DAFC) Both the NRT monitor and DAAMS use dilution airflow confrollers The purpose of the dilution flow confrollers is to mject dry air mto the sample sfream to prevent the hqmd m the sample from condensing m the samplmg equipment, keeping the sample above the dew point The dilution flow confrollers are designed such that the flow control device has a feedback signal to a flow meter This feedback signal causes the ratio of the sample flow to stay constant once the two are locked together Therefore, the unit compensates for any intermptions in the sample flow and mamtams the correct ratio The agent concenfration m the DAAMS tubes is calculated usmg the volume of sample air, not the dilution au" The same theory of operation holds tme with the NRT monitors The NRT monitors are calibrated regardless of the quantity of dilution air The dilution air can be considered a earner for the sample The agent concentration is based on the volume of the sample 5 6 Backup Equipment The fiinction of the NRT monitor is to rapidly detect agent Should a needed instmment fail, the first response is to froubleshoot and repair it in place Should the estimated repair time be in excess of 1 Yi hours the NRT monitor shall be replaced with an NRT momtor from the contingency If an NRT designated as a RCRA station in this plan is off Ime, except for those used for spoolmg, for more than 1 Yi hours the associated DAAMS tubes will be pulled and analyzed, once the monitor is back on Ime, as the primary momtor 5 7 Monitormg and Analytical Equipment Operations and Mamtenance (O&M) Requirements This section summanzes the sampling and analytical equipment required for venfying control of agent migration in air and in process effluents for DCD EDT site activities All hardware associated with air monitonng and laboratory equipment will be maintained in accordance with the manufacturers' operations and maintenance (O&M) manual recommendations and ECBC associated lOPs Table 5-1 provides general descnptions, operational requirements, and preventive maintenance requirements Table 5-2 provides equipment requirements for support gases 10 TABLE 5-1 Description and Requirements for Monitoring and Sampling Equipment Manufacturer Mimmum Operational Monitoring Operational Components Specifications Requirements Preventive NRT Monitors Operational Components Electrical Requirements • Routine • PCT is replaced • Preconcentrator • Cntical NRT Calibration as needed, based upon • MINICAMS Tubes/Sample Tubes monitors equipped with • Daily Challenges challenge performance > XSD • Sample Loops UPS • Calibration of • Capillary Columns • Power IS provided mass flow meter to DCD • Mass Flow Controller in accordance with elevation • Dilution Air Flow manufacturer • The sample Controller specifications exhaust must be filtered. Temperature retumed to the sampling • Use operational point, or vented to Support Gases performance characteristics appropriated engmeenng • Purifiers (optional) to determine if the NRT is controls • Leak Detectors operating within control • Compressed Gas • Doors to Regulators environmentally controlled Regulators NRT monitor shelter must remain closed at all time. except during personnel entry/egress • Condensation shall be minimized and if observed, conective actions will be taken immediately 11 TABLE 5-1 Description and Requirements for Monitoring and Sampling Equipment (continued) DAAMS Manufacturer Minimum Operational Monitoring Operational Components Specifications Requirements Preventive Depot Area Air DAAMS Tubes Power Requirements • The sample • Daily checking Monitorine • 6-mm TENAX • Power is provided exhaust must be filtered. of flow rates, critical Svstem in accordance with retumed to the sampling orifices, fittings, and (DAAMS) Sequencers manufacturer point, or vented to fermles • Director and control specifications appropriate engineering • Vacuum pump. flow pattern • Critical DAAMS controls sequencer, and sample equipped with UPS fransfer line preventive DAAMS Manifold Vacuum Pumps maintenance will be • Provides stable Temperature • Used m performed in accordance support system • Temperature is conjunction with a flow with manufacturer • Designed to provide maintained to minimize control device or critical specifications a directional sample flow condensate formation onfice • Require air. patter and distribute the • Should maintain mtrogen, or other inert sample flow Manifold critical ratio of inlet to gas flow through tube sample flow • Fabricated from outlet vacuum across the and thermal desorption NOx Filter stainless steel orifice of tube for conditioning • Change-out frequency is based on a site-Hoses specific basis • Used to connect sequencer sample ports to the DAAMS manifold • Silastic tubing must not be used upstream of the DAAMS tube • UmtS that demonstrate detectable leaks, poor flow rates, or broken sections are repaired or replaced 12 TABLE5-1 Description and Requirements for Monitoring and Sampling Equipment (continued) Monitoring Operational Components Manufacturer Specifications Mmimum Operational Requirements Preventive GC Analytical Systems • FPD • MSD • XSD Operational • Sample inlet • Capillary column • Column switching system • Support gases • Integration system • Thermal transfer system • Exhaust • Cryofocusing .b Roughing pump Power Requirements • Power IS provided in accordance with manufacturer specifications • Confirmation monitonng is equipped with UPS" • Power board is 120 volts altemating cunent Room Temperature • Between 68° and 80°F during operational periods May be exceeded if system performance is acceptable In accordance with manufacturer specifications • Exhaust IS vented to appropriate engineering controls • Temperature flow rate, and desorption time shall be optimized on a site-specific basis In accordance with manufacturer specifications • Performed on an "as-needed basis" in accordance with the O&M Manuals • Roughing pump oil is exchanged to maintain vacuum efficiency " The unintenuptible 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 13 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 two-• Will be pre- • Air Hydrocarbon Traps • Simple soap solution stage regulators or cleaned tubing • Nifrogen • Frequency of • Electronic leak equivalent • All fittings will • Helium change-outs are identified detector be Swagelok fittings in the Site-Specific Quality or equivalent Cryofocusing requires Control Plan Utilization liquid nitrogen or • Use based on • Completed in carbon dioxide instmmentation accordance with performance manufacturer specifications Support gases are and requirements handled and stored in accordance with the Site Chemical Hygiene Plan, which incorporates • 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 *Gas generators will be operated in accordance with manufacturer specifications 14 6 0 MONITORING OPERATIONS/STRATEGIES Placement of each momtonng 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, momtonng locations should be located m 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 cntical NRT momtonng eqmpment will be connected to an unintermptible power supply (UPS) During DCD EDT operations, monitoring will be conducted based on the agent being desfroyed (i e, HD) The NRT monitonng for HD' will be conducted with MINICAMS™ umts equipped with halogen selective detectors (XSDs) Additionally, confirmation DAAMS tubes will be co-located at each NRT momtonng location ^ Histoncal 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 momtonng application and type of momtor to support each application The monitoring types discussed in the following paragraphs will be employed during DCD EDT operations 61 NRT/Confirmation The NRT/confirmation locations shall consist of an instrument that satisfies the monitonng requirement identified for NRT monitors and incorporate a confirmation momtormg 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 6 2 Historical/Confirmation Histoncal monitoring will be performed by DAAMS sampling and subsequent analysis by gas chromatograph/mass spectrometer (GC/MS) A separate confirmation method is not required when GC/MS is employed When class III methods are used for NRT confirmation samples, any positive response will be considered a confirmed detection as specified in section 5 4 ' HT will be monitored as HD ^ When collecting DAAMS tubes for HD detection, a nitrogen oxide (NO^) filter will be installed at the distal end of each sampling location 15 Table 6-1 Monitoring Application and Monitor Type Analyte Momtor/Equipment Notes NRT Momtonng HD/HT MINICAMS® configured with a PCT and XSD Confirmation of NRT Alarm and Histoncal Monitonng HD DAAMS, GC/MS Qualitative confirmation of the MINICAMS® alarm and Quantitative histoncal DAAMS " HT will be monitored as HD Notes DAAMS = Depot Area Air Monitoring System GC/MS = Gas Chromatograph/Mass Spectrometer HD = Distilled Sulfiir Mustard (Bis(2-Chloroethyl) Sulfide) HT = ({Bis[2-(2-Chloroethylthio)ethyl]Ether}) NRT = Near- Real-Time PCT = Preconcentrator Tube XSD = Halogen Selective Detector 7 0 MONITORING SYSTEMS The following paragraphs descnbe the momtonng systems that will be employed dunng DCD EDT operations Monitoring locations during chemical agent operations are illustrated in Figure 7-1 A summary of the monitonng systems is provided in Table 7-1 Detailed discussions of the monitoring systems and locations are provided in the following paragraphs 16 SciadtHn) aofi i4fi 20ft 15Z4 *Ofl 16fl [Z4384J littdlo SUnd off IHstuiee • v, [4267J L6096J [12192J 14877J [Z4384J littdlo SUnd off IHstuiee • v, [4267J L6096J [12192J Ventilation Area £3 III AIU I T U C AIU I T U C M 1 \\m ^ Unite: I \ UnitCl Reteatioa Tanle ContaiDer SlMgered i' DnitB Off-Cu Treatment ponteiner Off-Gaa Treatment Area "•Q^ Control Rooin(2?) ^QiHectric Rooin(lF) J ]!oad()leT) PienarstiDn Container \ Sandbag 3 Da^Boz 65ft(>61tt) 119812J 1 Dsf Box n •Baxidset(?agiDgl IS :Panel eg :ccrv (^:Arsa Ifcnitoring (Pli):Procoss Monitoring !—! ! ! Ill { 1 -a 1 ! s \ 1 ca 1 i i L.j •1 for V. I. P Trailer mm'/ vth SIMMS "WlS^WojectsL-r Enginwrinq SidiM cn FBORcn DEPummtT DAVINCH SYSTEU TOEDT SERVICES Master Plot Plan PF3400 100 DB41 -PROOl # I H EC U z o o s C C ct o 6X) G 'C o *2 o s Table 7-1 Summary of Monitormg Strategy for DAVINdF"^ DCD EDT Operations Station # MINICAMS™ DAAMS Instrument Location Area Monitored Power Source Monitormg Level Alarm Level DAAMS Mode RCRA Stations Smoke Test Requir'd Comment AMI No 1 N/A Monitoring Trailer Delivery Van UPS VSL 05 N/A ' No No Note ,14 AM2 No 2 NO 1 Momtormg Trailer UPA Area UPS VSL 05 MINICAMS TM Confirmation No Yes AM3 No 3 NO 2 Monitoring Trailer Preparation Area UPS VSL 05 MINICAMS TM Confirmation No Yes AM4 No 4 N/A Monitoring Trailer Changing Room UPS VSL 05 N/A No No Note 10 AM5 No 5 N/A Monitoring Trailer Air Shower Room UPS VSL 05 N/A Yes No Note 10 AM6 No 6 NO 3 Monitoring Trailer Detonation Chamber Area (DOOR) UPS VSL 05 MINICAMS TM Confirmation No No Note 4 AM7 No 1 N/A Monitoring Trailer Headspace UPS VSL 02 05 1 0 N/A Yes No Note 2,3 AMIO No 1 N/A Monitoring Trailer Airlock 2 UPS VSL 05 N/A No No Note 2 AMll No 1 N/A Monitoring Trailer UnitG UPS VSL 05 N/A ' No No Note2 18 Station # MINICAMSTM DAAMS Instrument Location Area Monitored Power Source Monitoring Level Alarm Level DAAMS Mode RCRA Stations Smoke Test Requir'd Comment AMI 3 No 1 N/A Monitoring Trailer Davinch Lid Shroud UPS VSL 05 N/A No No Note 2 AM8 No 7 No 4 Monitoring Trailer Airlock 1 UPS VSL 05 MINICAMS TM Confirmation No Yes AM9 No 8 No 5A and 5B Monitoring Trailer Containment Room UPS VSL/WPL 05 MINICAMS TM Confirmation No Yes Notes AM12 N/A No 20 N/A Laboratory N/A WPL 05 Historical No No Note 8 PMI No 9/No 17 No 6 Monitoring Trailer Upstream of Retention Tank UPS VSL 05 MINICAMS TM Confirmation Yes No Note 5,13 PM2 No 10 No 7 Monitoring Trailer Chamber Discharge during venting UPS VSL 05 MINICAMS TM Confirmation No No Note 6 PM3 No 11 No 8 Monitoring Trailer Process Discharge UPS VSL 05 MINICAMS TM Confirmation Yes No PM4 No 12 No 9 Monitoring Trailer Mid bed of HVAC Filter El UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9, 12 PM5 No 12 No 10 Monitoring Trailer Mid bed of HVAC Filter El UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PM6 No 12 No 11 Monitoring Trailer Mid bed of HVAC Filter El UPS VSL 05 MINICAMS • TM Confirmation Yes No Note 9,12 19 Station # MINICAMSTM DAAMS Instrument Location Area Monitored Power Source Monitoring Level Alarm Level DAAMS Mode RCRA Stations Smoke Test Requir'd Comment PM7 No 13 No 12 Monitoring Trailer Mid bed of HVAC Fiher E2 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PM8 No 13 No 13 Monitoring Trailer Mid bed of HVAC Filter E2 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PM9 No 13 No 14 Monitoring Trailer Mid bed of HVAC Filter E2 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PMIO No 14 No 15 Monitoring Trailer Mid bed of HVAC Filter E3 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PMll No 14 No 16 Monitoring Trailer Mid bed of HVAC Filter E3 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PM12 No 14 No 17 Monitoring Trailer Mid bed of HVAC Filter E3 UPS VSL 05 MINICAMS TM Confirmation Yes No Note 9,12 PM13 No 15 No 18 Momtormg Trailer HVAC Discharge UPS VSL 05 MINICAMS TM Confirmation Yes No Note 7 PM14 No 16 No 19A and 19B Monitoring Trailer Stack UPS VSL/WPL 05 MINICAMS TM Confirmation Yes No Note 8 Critical DAAMS PM15 N/A No 21 N/A PrefilterEl UPS VSL N/A process Yes No Note 11 20 Station # MINICAMSTM DAAMS Instrument Location Area Monitored Power Source Monitoring Level Alarm Level DAAMS Mode RCRA Stations Smoke Test Requir'd Comment PMI 6 N/A No 22 N/A Prefilter E2 UPS VSL N/A process Yes No Note 11 PM17 N/A No 23 N/A Prefilter E3 UPS VSL N/A process Yes No Note 11 Notes 1 With DAAMS capability 2 Spooled location 3 Headspace monitoring (4 hours @70°F) Clearance levels are 0 2 VSL for exterior of drums, 0 5 VSL for chamber sohd waste mside drums, and 1 0 VSL for other (PPE) drummed waste 4 No smoke test requu-ed, will position accordmg to proximity to chamber opening/door For daily entry clearance/mamtenance this station may be used with DAAMS for WPL momtormg 5 Controls the release of detonation gas to sync with MC cycle In the event of alarm, recirculation loop automatically acdvates 6 Personnel entry chamber clearance spooled based on chamber status 7 Upstream of process discharge 8 WPL DAAMS station must be collected continuously and analyzed on a daily basis for this station 9 One MINICAMSTM 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 10 Personnel pomt source 11 These process samples are to determine if agent is being loaded onto carbon filters Once agent is detected, no further monitormg is required 12 If NRT midbed alarms NRT will be spooled to post bed locations 13 If the process stream contains too much moisture, a DAFC may be used 14 NRT confirmation based on comparison of results obtamed Irom differently configured NRTs aboard Real Tune Analytical Platform (RTAP) provided by DCD RTAP monitor sample the same sample since sample is contained in box truck's storage compartment 21 7 1 NRT Monitoring The NRT monitonng 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 monitonng will take place at the locations discussed in the following paragraphs Table 6-1 details the MINICAMS™ configurations for momtormg chemical agents All NRT stations will be configured with un-interruptible power supplies 7.1 1 Workspace Process Area (Dehvery Van) The NRT monitonng of the Delivery Van will be performed using an HTSL interfaced with a MINICAMS^**" located in the Momtonng Container/Station The monitoring at this location will be performed at the VSL 7 12 Workspace Process Area (Unpack Area (UPA)) The NRT monitoring of the Unpack Area will be performed using an HTSL interfaced with a MfNICAMS^"^ located in the Momtonng Container/Station The monitoring at this location will be performed at the VSL 7 13 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 Momtonng Container/Station The momtormg at this location will be performed at the VSL 7 14 Workspace Process Area (Airlock 1) The NRT monitoring of Airlock 1 will be performed using an HTSL interfaced with a MfNICAMS^"^ located in the Momtonng Container/Station The monitoring at this location will be performed at the VSL 7.1 5 Facility Support Area (Changing Room) The NRT monitonng of the Changing Room will be performed using an HTSL interfaced with a MINICAMS™ located in the Momtonng Container/Station The monitoring at this location will be performed at the VSL 7 16 Facility Support Area (Air Shower Room) The NRT monitoring of the Air Shower Room will be performed using an HTSL interfaced with a MINICAMS™ located in the Monitonng Container/Station The monitonng at this location will be performed at the VSL 22 717 Process Area (Detonation Chamber Door) The NRT momtonng of the Detonation Chamber/Containment Area will be performed using an HTSL interfaced with a MINICAMS™ located in the Momtonng 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 m front of the Detonation Chamber door The monitoring at this location will be performed at the VSL 7.1.8 Workspace Process Area (Post Treatment Area) The NRT Headspace Monitoring of the fragments in the Post Treatment Area will be performed usmg an HTSL interfaced with a MfNICAMS^'^ located in the Monitonng Container/Station The Headspace Monitonng at this location will be performed at the VSL 719 Workspace Process Area (Airlock 2) The NRT monitonng of Airlock 2 will be performed using an HTSL interfaced with a MINICAMS''"'^ (spooled) located in the Monitonng Container/Station The monitoring at this location will be performed at the VSL 7.1.10 Laboratory Work Area Laboratory areas where the RDT&E dilute levels are not exceeded do not require NRT monitonng However, the ECBC laboratory will be monitored using histoncal DAAMS 7 111 Ventilation Exhaust Filter System 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 MINICAMS 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 at or above the action level of the MINICAMS, the sampling location is changed to the post bed 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 7 1111 Upstream of Retention Tank 23 The NRT monitoring will be performed upstream from the Retention Tank Monitoring will be performed using an HTSL interfaced with a MINICAMS''^'^ The momtonng will be performed at this location at the VSL 71112 Chamber Discharge during Venting The NRT monitoring of the Chamber Discharge dunng venting will be performed using an HTSL interfaced with a MINICAMS^"^ The monitonng will be performed at this location at the VSL dunng operations This location will also be used to perform first entry momtonng into the DAVINCH chamber 71113 Process Discharge The NRT monitoring of the Process Discharge will be performed using an HTSL interfaced with a MINICAMS''"'^ The monitonng will be performed at this location at the VSL 71114 Midbed of HVAC Filter The NRT monitoring will be performed at the midbed location of the air filtration unit using an HTSL interfaced with a MINICAMS™ The momtonng will be performed at this location at the VSL 71 11 5 HVAC Discharge The NRT monitoring will be performed at the HVAC Discharge of the air filtration unit using an HTSL interfaced with a MFNICAMS^''^ The monitonng will be performed at this location at the VSL 7 1 11 6 Stack The NRT monitoring will be performed at the Stack location of the air filtration unit using an HTSL interfaced with a MINICAMS''^'^ The monitonng will be performed at this location at the VSL and WPL 7 1 12 First Entry First entry monitoring will be conducted, prior to personnel entry, to determme 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 of the 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 monitonng is not immediately required but can be performed after the NRT response indicates possible chemical agent contamination 7.1.13 Headspace Headspace momtormg may be used to screen samples to determine such information as 24 operational constraints, PPE requirements, and handling precautions Headspace monitoring shall be performed in accordance with table 7-1 on solid samples that have been bagged or contained in an agent-tight bamer of sufficient volume to permit sample air to be withdrawn while minimizing dilution with incoming air Headspace monitoring requires one complete sampling cycle of the NRT Prior to monitoring for one complete sampling cycle, the sample line should be purged to ensure that a clean representative sample is taken Histoncal momtonng can be performed instead of NRT momtonng Headspace monitonng for the purpose of decontamination venfication shall include all of the following - the Item has been surface decontaminated by locally approved procedures - the Item has been bagged or contained in an agent-tight bamer of sufficient volume to permit sample air to be withdrawn while minimizing dilution with in-commg air - the Item shall be allowed to off-gas for a minimum of 4 hours at temperatures at or above 70 degrees Farenheit 7 114 Waste Drums NRT monitonng of waste drums will be performed using an HTSL interfaced with a MINICAMS^"^ (spooled) located in the Momtonng Container/Station The momtormg at this location will be performed at the VSL after the drums have been tented Waste drums will be cleared to 0 2 VSL at the extenor of 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 monitonng m the Air Shower Room The monitoring at this location will be at the VSL 7 1.16 Unit G NRT monitoring will be performed at Unit G using an HTSL interfaced with a MINICAMS™ (spooled) located in the Monitonng Container/Station The monitoring at this location will be performed at the VSL 7 2 Confirmation and Historical Monitoring Confirmation monitonng is performed to validate or invalidate a positive measurement from another monitoring system, either an NRT method or histoncal method Sampling is accomplished by the collection of an air sample m the immediate vicinity of the NRT monitor or historical samplmg 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 25 by a method different from the pnncipal method (NRT or histoncal) to mcrease the likelihood of detecting mterferences and only upon a principal method (NRT or historical) positive response Confirmation monitoring samples shall be given pnonty over all routine samples For class III confirmation samples, any positive response as defined in section 5 4 shall be considered a confirmed detection Confirmation DAAMS tubes are continually aspirated throughout the work day In the event of 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 storage enclosure of the delivery van is monitored before the enclosure is opened to ensure that none of the overpacked mumtions and samples developed leaks dunng transport Delivery van storage enclosure NRT monitor alarms are confirmed using a DCD Real Time Analysis Platform System (RTAPS) or DAAMS 7 2.2 Workspace Process Area [Unpack Area (UPA)] The DAAMS tubes will be used for qualitative confirmation analysis of chemical agents The sample mlet will be co-located with the MINICAMS™ HTSL distal end When the co-located MfNFICAMS^'^ 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 (Airlock 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 MfNICAMS™ alarms, the DAAMS tube will be retrieved to confirm or refute the alarm 7 2 5 Process Area (Detonation Chamber/Containment Area) The DAAMS tuSes will be used for qualitative confirmation analysis of chemical agents The sample inlet will be co-located with the MfNICAMS^"^ 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 26 Laboratory areas where the RDT&E dilute levels are not exceeded do not require monitonng However, the ECBC laboratory will be monitored using historical DAAMS 7.2.7 Ventilation Exhaust Filter System The ventilation exhaust filter system includes the facility's ventilation system exhaust where CWM is processed for demilitanzation It does not include the laboratory ventilation system or other buildings in the facility where CWM is not processed 7 2 71 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 Dunng chamber venting, the door to the Detonation Chamber is open and EE air is drawing through 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 tube will be retrieved to confirm or refute the alarm 7 2 7 3 Reserved 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 MfNICAMS^'^ alarms, the DAAMS tube will be retrieved to confirm or refiite 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 MFNICAMS^"^ 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 alarm confirmation and for historical data DAAMS tubes will be used for qualitative confirmation of NRT alarms and for historical monitoring to the WPL The DAAMS NRT confirmation sample inlet will be co-located with the MINICAMS™ HTSL distal end When the co-located MINICAMS^M alanns, the confinnation DAAMS tube will be retrieved to confirm or refute the alarm 7 3 First Entry See 7 1 12 27 7.4 Headspace Headspace monitonng may be used to perform things like screen samples to determine operational constraints, PPE requirements, and handling precautions Headspace monitoring shall be performed in accordance with table 7-1 on solid samples that have been bagged or contained m an agent-tight banier of sufficient volume to permit sample air to be withdrawn while minimizing dilution with incoming air Headspace monitoring is required for one complete sampling cycle of the NRT Prior to monitonng for one complete sampling cycle, the sample line should be purged to ensure that a clean representative sample is taken Histoncal momtonng can be performed instead of NRT monitonng Headspace monitonng for the purpose of decontamination venfication shall include all of the following - the item has been surface decontaminated by locally approved procedures - the Item has been bagged or contained in an agent-tight bamer 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 5 Personnel Decontamination Station (PDS) In the event of a potentially exposed worker, MfNICAMS"^"^ will be available to conduct NRT monitonng in the Air Shower/Changing Rooms The momtormg 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 penod of time and subsequent analysis is conducted offline at the site laboratory Historical monitoring is designed to tngger activities to investigate the source of contamination that may be found below the alarm level of the NRT system All historical DAAMS samples must be analyzed within 72 hours of sampling termination During agent operations and until the EE has been determined to have no agent contamination for closure (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 containers and any liquid process sample containers prior to transfer 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 28 environmental enclosure Vapor screenmg will be performed on items that have been bagged or contained m an agent-tight bamer of sufficient volume to permit sample air to be withdrawn while minimizing dilution with incoming air Vapor screemng can be performed with either MINICAMS™ or DAAMS tubes If results provide a concentration greater than or equal to 0 5 VSL, corrective actions shall be implemented (e g , confirmation, repeat decontamination process, and re-monitor) 8 0 SAMPLE AND ANALYTICAL METHODS The ECBC Sample and Analytical Methods will be used to characterize the waste pnor to shipment of waste off-site 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 Momtonng at the VSL will be performed in areas where worker protection momtonng is required The VSL IS intended for applications and/or locations that require momtonng for an environmental release, engmeermg controls (e g, filters), process upset condition, or vapor decontamination classification monitonng 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 analyte concentration 9 2 MINICAMS™ Alarm Setpoints Dunng EDT operations at DCD, the following alarm levels will be used • 0 5 VSL will be used m all areas where worker protection is being performed (all locations inside the EE and the PDS) • 0 5 VSL will be used in all process monitoring areas (within the air filtration units) 9 3 NRT Notifications In the event of an alarm, the MfNICAMS™ operator will notify the EDT Control Trailer In addition, EG&G will be notified for all confirmed NRT alarms 9 4 Confirmation and Historical Notifications 29 The support laboratory will notify the EDT Control Trailer of the results of all DAAMS tube analyses If the samples were confirmation samples, the Versar EDT Site Manager will notify EG&G of the results If the samples were analyzed only for histoncal purposes, the Versar EDT Site Manager will notify EG&G 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 30 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 handling unit Co-located confirmation DAAMS Tubes Contingency Visually observe item leaking inside EE All historical DAAMS stations in EE and EE exhaust filtration system Contingency Failure of engineering controls in EE All historical DAAMS stations in EE and EE exhaust filtration system Quality Assurance Requirement For each set of histoncal DAAMS tubes a corresponding QP will be sampled and analyzed on the stack All other DAAMS station QPs will be rotated on a daily basis for each method Notes DAAMS - Depot Area Momtormg System EDT - Explosive Destruction Technology EED - Environmental Enclosure 31 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 Momtonng of potentially exposed workers will be conducted m accordance with the DA Memorandum Performance Standard for Monitoring Potentially Exposed Workers, 13 September 2007 11.0 QUALITY CONTROL REQUIREMENTS All momtonng operations will be conducted in accordance with the ECBC LMQCP, the CMA LMQAP, and applicable lOPs The ECBC will incorporate the data generated into the momtonng 40-year data storage program, should access to additional information be required The QC requirements for applicable ECBC lOPs (lOP MT-66, and lOP MT-13) are provided in Tables 11-1 and 11-2, respectively 111 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 successful precision and accuracy (P&A) study and initial baseline study Method certification will be required before the method can be used in support of operations Method validation will be demonstrated through the continuing baseline study 1111 Precision and Accuracy (P&A) Method Certification All NRT and histoncal 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 III methods Class III method results that yield a positive response will be considered confirmed detections The P&A studies will be performed on-site at the EDT location 1112 Baseline Method Certification and Validation All methods shall successfiilly satisfy the regular initial baseline study method certification requirements as shown in Table 13-3 of the CMA LMQAP before the methods are allowed to support operations 32 Table 11-1 QC Requirements for MINICAMS lOP MT-66 QC Sample Frequency Acceptance Limits Corrective Action Sampling Flow Rate Measurements During Daily Calibration HD 400±100mL/min Adjust and recheck before starting calibration and analysis Calibration Challenge (1 0 Z) Following daily calibration 0 75 to 1 25 Z Investigate and perform and document corrective action Repeat calibration if required Daily challenge" After the end of daily operations or if no operations occur, at least 12 hours after calibration challenge 0 75 to 1 25 Z Investigate and correct cause Recalibrate if necessary Note on data forms and qualify data ^ Reserved b Distal end line challenges will be performed on a bi-weekly basis for PM 1 and PM14 All other stations will be performed a minimum of every 60 days Note HD - distilled sulfur mustard mL/min - milliliter per minute QC - quality control 33 Table 11-2 QC Requirements for DAAMS Analysis lOP MT-13 QC Sample Frequency Acceptance Limits Corrective Action Sampling Flow Rate Measurements Before and after sample collection Starting and ending flow rates within 10% of the target flow rate Repeat sampling unless samples are one of a kind If one of a kind, flag data Five Point Initial Calibration (ICAL) When instrument parameters change After Preparation of new standards R2>0 99 Investigate and correct the cause Repeat ICAL Initial Calibration Verification (ICV) At the start ofeach day of analysis After ICAL Each target analyte ±15% of true value Recalibrate Continuing Calibration Venfication (CCV) At the end of a sample batch or every 12 hours, whichever is shorter Each target analyte ±15% of true value If results >115% of true value, recalibrate Sample results may be reported If results <85%o of true value, recalibrate Analyze second sample tube for each sample analyzed Method Blank At least one before analyzing samples Absence of target analytes and interferences Investigate and conect Repeat method blank to verify acceptable performance Quality Process (QP) - Similar to Matrix Spike 1 each per batch of 20 or fewer samples Recovery 60- 140% Venfy spiking solutions Analyze second QP tube If results are confirmed spike and analyze second sample tube from location where QP was taken Notes QC - Quality Control 34 Durmg 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 composed 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 of the monitoring systems The continuing baseline study begins immediately after successful completion of the imtial baseline and will be conducted m accordance with table 13-3 of the CMA LMQAP For momtonng cessation of less than 60 days, NRT method re-certification shall be perfonned in accordance with CMA LMQAP, Table 13-5 112 Calibration and Test Methods The laboratory shall have an established calibration program Air momtormg 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 instructions on using and operating all relevant equipment, handling and prepanng calibration items, and calibrating equipment All up-to-date instructions, 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 monitonng staff shall use documented procedures and legally defensible statistical techmques 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 retneve 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 fimctiomng 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 • Previous releases of software packages are maintained if data reprocessing is required EDT personnel shall establish and implement appropnate procedures for the maintenance and security of data, including the prevention of unauthonzed access to and amendment of computer records 35 11.2.1 Calibration of Near Real Time Instruments NRT systems used to support class I air monitonng methods shall be calibrated using a minimum of two injections at the 1 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 1122 Calibration of GC/MS Systems GC/MSD systems used to analyze class I air samples shall be calibrated using a mimmum three point calibration curve with masses covenng the analytical range for each chemical to be analyzed At least one mass equivalent will be at or below the action level Calibration regression lines shall provide a conelation coefficient value of 0 990 or greater 113 QC Sampling All instruments used for the analysis of chemical agents shall be subject to penodic 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 of the data • Provide an indication of the need for conective actions • Determine the effectiveness of corrective actions when they are implemented The laboratory and monitonng 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, Matnx spikes (MSs), Field spikes [quality plant (QP)], and Laboratory spikes [quality laboratory (QL)] Detailed defimtions and descnptions of QC samples are available in the CMA LMQAP 36 113 1 NRT Methods All NRT momtors v^ll 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 before operations begin for the day the instrument must be brought into control before operations can commence If two consecutive challenges fail to meet acceptance criteria at the end of the day then corrective action and data qualification is required for all readings above 0 5Z The QP challenge shall deliver agent to the instrument at 1 0 Z 11.3.2 Historical/Confirmation Methods • OP Samples All histoncal/confirmation methods will be challenged via QP samples in accordance with the CMA LMQAP, Table 12-1 All confirmation QP samples must be given pnonty and analyzed as soon as possible, but not later than 72 hours after sampling completion A QP sample challenge failure will require conective 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 instruments used for analysis as part of histoncal or confirmation methods shall be challenged with QL samples [initial calibration venfication (ICV) or continuous calibration venfication (CCV) samples] to assess the laboratory's cross-contamination and bias 11.3 3 In-Control Critena and Notification The term in-control is used to indicate that the laboratory and momtonng analytical activities are v^thin the pre-established statistical control limits and meet baseline study requirements When instrumental methods are in-control, the analytes are detected and accurately quantitated if present in a sample To protect personnel at the site, the monitormg equipment must be operating and in control before operations start each day and remain m control for the operational period The EDT personnel report to the Versar EDT Site Manager the status of the monitoring and analytical instrumentation on a daily basis The ECBC will record the control status of the laboratory and monitoring equipment in a daily operational log If the laboratory or monitonng equipment is determmed 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 113 31 Monitormg Equipment In-Control Critena/LCOs The EDT momtonng equipment is in-control if the following criteria are met • The MINICAMS™ alarm systems have successfully passed their daily initial baseline challenge 37 • The alarm confirmation and histoncal sample stations are onlme and operating • The QC sample results reported back to the site from the laboratory are acceptable • The momtormg teams have qualified personnel onsite to mamtain momtormg operations in accordance with this SSMP 113 3 2 Laboratory In-Control Criteria/LCOs The laboratory is m-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 m accordance with this SSMP The in-control status of the laboratory will be recorded in the instrument data sheets on a daily basis pnor to sample analysis Traceability will mclude calibration of analytical instruments and qualifications of the operators 113 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 imtial QL sample conditions will be run as soon as possible Immediate conective actions will be taken to identify the source of the 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 114 Sample Handling and Storage All laboratory and monitonng 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 monitormg program The laboratory and momtonng personnel are required to ensure that COC is properly conducted The receiving 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 Shippmg Contamers and Custody Seals for Non-agent Analysis Cleaned sample bottles will be sent to the field in shipping containers that will be used for retum of samples to the laboratory Each sample container will contain packing matenal to protect the . 38 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 penod. Volume of sample. Sample location. Operator's ID Agent and monitoring level. Sample type, and Preservative, if any Deviations from SOPs, secunty, and unusual environmental conditions shall also be included in the sample collection record 114 2 Sample Identification A unique sample ID number will be affixed to the sample or sample container To ensure traceability and uniqueness of the 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 of the sample COC form 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 conections are made to the data, the enor 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 114 3 Sample COC Documentation The COC documentation will be stnctly 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 Orgamzation 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 air bills will be retained as part of the COC documentation for samples 39 that have been shipped off-site 11.44 Sample Storage The laboratory shall be responsible for the documentation, secunty, 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 conective actions The laboratory will submit the QC data to the CMA mandated statistical program from baselme through closure at https //home cma army miVqcdrs 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 bi-weekly 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 115 2 Statistical Analysis of Calibration Curve Data Calibration curve data for the analytical equipment used m the sample measurement process will be analyzed statistically Once the laboratory has defined the calibration method for an instmment, acceptance cnteria for the calibration curve data will also be developed The chemical matenal raw calibration data shall be generated from the laboratory specified calibration curves Algonthms used for calibration curves shall satisfy the calibration requirements specified for each analytical method 11 5.3 Data Validation Data validation of laboratory and monitonng data shall be performed daily 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 conective 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 momtonng data, all equations and calculations must be validated dunng intemal audits of the laboratory and monitoring teams The internal data validation review will be documented m the laboratory or monitoring files, whichever is appropriate If the internal data validation identifies an enor, the CMA-Monitoring Office or designee will be notified All actions taken to correct the error shall be documented 116 QC of DAAMS Tubes New DAAMS tubes shall be subjected to the following tests The number of tubes to be pulled 40 for testing is provided in Table 11-3 Sampling/acceptance and inspection requirements consist of • The Sample number, which is in accordance with Amencan National Standards Institute (ANSI)/Amencan Society for Quality Control (ASQC) Zl 4, acceptable quality level of 2 5 percent nonconformance • Visual inspection for loose packmg, warped tube ends, and loose sorbent material • A pressure-drop test to ensure sufficient airflow through the tube For DAAMS 6-mm tube Tenax® TA, the pressure drop may not exceed 15 mches of mercury (Hg) Table 11-3 Samples Sizes for Normal Inspection for Maximum of 2 5 Percent Nonconformance , , General Inspection Rejection Number* Lot or Batch Size Level 1. Number of Samples 2 to 8 2 9 to 15 2 16 to 25 3 26 to 50 5 51 to 90 5 91 to 150 8 151 to 280 13 2 281 to 500 20 2 501 to 1,200 32 3 ' Reject the entire lot if this number of samples is found to be defective 117 Tube Conditioning After the representative tubes from a lot pass visual mspection and pressure drop testmg, they will be conditioned in a flow of nitrogen at 290 °C for 20 mmutes, followed by a 5-minute coolmg penod All tubes 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 for PMI and PMI4 which will be sample line challenged bi-weekly 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 1 OZ and will demonstrate recovery of 0 60 to 1 40Z 41 12 0 DOCUMENTATION 12 1 General Monitonng Documentation Dunng operations, ECBC personnel will maintain documentation of all monitonng activities The documentation will include activity information on daily air monitonng, 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 information will be documented by ECBC support laboratory personnel The laboratory will document and maintain all acceptance test results for the equipment Information regarding each instmment 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 altemates will be accounted for, undamaged, and properly labeled at all times 12 4 Laboratory Wastes Waste generated by air monitoring operations will be managed in accordance with EG&G Part B Pennit and R315-5 13 0 TRAINING REQUIREMENTS All EDT monitonng personnel are required to meet the mimmum traimng 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 momtonng personnel must also meet the training cntena detailed in the ECBC LMQCP 42 APPENDIX 1. ACRONYMS/ABBREVIATIONS/TERMS 43 APPENDIX 1. ACRONYMS/ABBREVIATIONS/TERMS AEL airbome exposure limit ANSI Amencan National Standards Institute ASC Allowable Stack Concentration ASQC Amencan Society for Quality Control CASARM Chemical Agent Standard Analytical Reference Material CCV continuous calibration verification CDC Center for Disease Control CFR Code of Federal Regulations CMA U S Army Chemical Materials Agency COC Cham of Custody DA Department of the Army DA Pam Department of the Army Pamphlet DAAMS Depot Area Air Monitoring System DCD Deseret Chemical Depot DHHS Department of Health and Human Services DQO data quality objective ECBC Edgewood Chemical Biological Center EE Environmental Enclosure FPD flame photometric detector GA tabun GB sarin GC gas chromatograph GC/MS gas chromatograph/mass spectrometer GD soman 44 HAZWOPER Hazardous Waste Operations and Emergency Response HD distilled sulfur mustard (Bis(2-chloroethyl) sulfide) Hg mercury HT {bis[2-(2-chloroethylthio)ethyl]ether} HTSL heat-traced sample transfer line ICAL Imhal Calibration ICV initial calibration venfication ID Identification IDLH Immediately Dangerous to Life and Health lOP Intemal Operating Procedure LCO limiting condition of operation LMQAP Laboratory and Monitormg Quality Assurance Plan LMQCP Laboratory and Monitoring Quality Control Plan (for Chemical Materials Agency (CMA) and for Chemical Agent Standard Analytical Reference Matenal (CASARM)) MAP Mobile Analytical Platform MARB Materiel Assessment Review Board MCP Monitoring Concept Plan MS Matnx Spike MS Mass Spectrophotometry NRT near-real time OSHA Occupational Safety and Health Administration P&A precision and accuracy PCT Pre-Concentrator Tube PDS Personnel Decontamination Station PMNSCM Project Manager for Non-Stockpile Chemical Materiel PPE personal protective equipment QA quality assurance 45 QA/QC quality assurance/quality control QC quality control QL quality laboratory QP quality plant RDT&E research development, test, and evaluation RTAP Real-Time Analytical Platform SOP Standing Operating Procedure SSHO Site Safety and Health Officer SSMP Site-Specific Monitonng Plan SEL Source Emission Limit STEL short-term exposure limit TWA Time Weighted Average USEPA U S Environmental Protection Agency VSL Vapor Screening Level VX O-ethyl S-(2-diisopropylaminoethyl)methylphosphonothioate WPL worker population limit XSD halogen selective detector 46 APPENDIX 2. REFERENCES 47 APPENDIX 2. REFERENCES ANNEXE Site-Specific Monitoring Plan for the Explosive Destruction System at Dugway Provmg Ground, U S Army Chemical Materials Agency Project Manager for Non- Stockpile Chemical Materiel Site-Specific Monitormg Plan for the Explosive Destruction System at Dugway Proving Ground, Final Revision 2, March 2009 CMA, Programmatic Monitoring Concept Plan, most recent version Department of the 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 Airborne Exposure Limits for GB, GA, GD, GF, VX, H, HD, andHT, 14 December 2004 DA, Memorandum, Subject Performance Standard for Momtormg Potentially Exposed Workers, 13 September 2007 DA Pamphlet 385-61, Toxic Chemical Agent Safety Standards, 17 December 2008 U S Army Chemical Matenals Agency (CMA), Programmatic Laboratory 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 48 EDT Destruction Plan Annex C Inspection Plan EDT DESTRUCTION PLAN ANNEX C INSPECTION PLAN Revision 2 December 2010 C-i EDT Destruction Plan Annex C Inspection Plan TABLE OF CONTENTS TABLE OF CONTENTS . . .. .C-n LIST OF TABLES . . . . C-u 10 INTRODUCTION . . C-1 2 0 GENERAL INSPECTION REQUIREMENTS . C-1 3 0 SCOPE ... . . C-1 4 0 TYPES OF PROBLEMS TO BE IDENTIFIED .. . C-2 5 0 FREQUENCY OF INSPECTION . . C-2 6 0 CORRECTIVE ACTIONS C-2 7 0 INSPECTION FORMS AND INSPECTION DOCUMENTATION . C-2 LIST OF TABLES Table C-1 Inspection Items for the TOOELE DAVINCH EDT C-3 C-ii EDT Destruction 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 mspection schedule designed to detect equipment detenoration 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 critena 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 Destruction Plan Annex C InspecUon Plan • Secunty fencing and signs, and • Emergency backup power 4.0 TYPES OF PROBLEIMS 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 conect problems before they cause harm to human health or the environment Inspection frequencies of mdividual items may vary, but are based upon the rate of possible detenoration of the equipment and the probability of an environmental or human health incident if a problem remains undetected dunng inspection 6.0 CORRECTIVE ACTIONS Conective actions are measures taken to address and resolve any issues discovered dunng inspection to prevent a malfunction or deteriorated/defective equipment from potentially causing a release of hazardous matenals or otherwise posing a threat to human health and the environment Conective actions may include necessary repairs or fiirther investigation of potential problems All conective actions are recorded and described on the inspection forms, these forms are dated and signed by the inspector, who also follows up on the conective 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 Destructio^wan Annex C Inspection Plan Table C-1 Inspection Items for TOCDF DAVINCH EDT Item Number Item Description Inspection Frequency Types of Problems (Inspection Criteria) Detonation Chamber and Interior Equipment 1(a) Mam Chamber Outer Shell Daily when in use Visually inspect exterior including tubmg, hoses, and valves for evidence of corrosion and leakage, this includes other physical damage such as tears, stresses, gouges, dimples, rips, cracks, and fasteners 1(b) Mam Chamber Inner Lmer Daily when m use Visually inspect mtenor for evidence of physical damage such as cracks, gouges, and dunples, beyond expected depth 1(c) Main Chamber Lid Daily when in use Conduct inspection and cleanmg of sealing surfaces, and inspect inner lid lmer for evidence of physical damage such as cracks, gouges, and dunples, beyond expected depth 2 Pass-through for Detonation Daily when m use Conduct high-potential test through open vessel door, conduct contmuity check of feed-through and detonator terminal blocks for proper functioning Off-Gas Treatment Systems 3 EDT Off-Gas Treatment Contamer Unit A Daily when in use Visually inspect for evidence of corrosion, leakage, or other physical damage such as cracks, gaps, or holes 4 EDT Process Ventilation Unit B Daily when in use Visually inspect for evidence of corrosion, leakage, or other physical damage such as cracks, gaps, or holes 5 EDT Process Ventilation Units CI and C2 Daily when m use Visually inspect for evidence of corrosion, leakage, or other physical damage such as cracks, gaps, or holes 6 EDT Off-Gas Treatment Container UnitD Daily Visually inspect for evidence of corrosion, leakage, or other physical damage such as C-3 EDT DestrucnonTTan Annex C Inspecnon Plan Hera Number Item Description Inspection Frequency Types of Problems (Inspection Criteria) when in 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 malflincnon, 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 Utilities 11 Generators Weekly Inspect for spills, proper operadon, electncal output, fiiel consumption abnormalities 12 UPS Weekly Check for battery life and mdicators, correct voltage, check for leaks/corrosion m battery area Communicanons 13 Link to TOCDF Control Room Daily Ensure Imk working to TODCF Control Room C-4 EDT Destructioi^ Annex C Inspection Plan Item Number Item Description Inspection Frequency Types of Problems (Inspection Criteria) 14 PA Daily Test PA 15 Alarm Panels Weekly Check function of alarms 16 Alarm Homs Weekly Check function of homs 17 CCTV Weekly Check for operability, visual clarity, pan and zoom if applicable 18 Radios/Cell Phones Daily Check for operability Secunty 19 Fences Weekly Check for integrity, obstmction, gaps 20 Lightmg Weekly Check for operability 21 Waming Signs Weekly Check for presence and legibility Fire Protection/Safety Equipment 22 Fire Extinguishers Weekly Check pressure, general condition, and service date 23 Persormel Decontammation Station Weekly Check for availability of decon solution, access, and operability 24 Spill Kits Fire Extinguishers Safety Equipment Weekly Check for inventory, condition, and expiration dates 25 Environmental Enclosure Weekly Check for breaches, weather damage, leakage C-5 EDT DESTRUCTION PLAN ANNEX D TOCDF EDT OPERATIONAL MODE DIAGRAMS Revision 1 November 2010 ANNEX D. TOCDF EDT OPERATIONAL MODE DIAGRAMS This Annex presents a set of operational mode diagrams to conespond to the explanation of the air fiow modes of operation during the detonation process, discussed in the EDT Destruction Plan, Paragraph 3 5 5 D-1 r it 1 y: If. Damper Detonatibh Ghamber ^ -I iV" -> Containment i- r^^Filt^r .\^i r^^Filt^r •i I I .1 I -A',' f St ( 111* I *• • r 1 ( - t'% 't I 0 Gharcqal ; Filter'^ 1 I Blower Charcoah Filter :4r I*- Retention , Tank Unit D' Unit Filter Vacuum Pump Oxidizer M-CooflerM Blower y^ . v#f UnitA Unit B D-2 tr 'f; r :.-4 DAVtNCH OPil^riON? PHlASl ^4 Preparation^fprQperation Before Detonation Detonation i After Detonation '° if ''.Si -A -It T ^ ?, i-:> ,3* •".•-V-/ ' if* Snaalil! Ph^^4 .4,- . ,1*- -yi,. V- Utility. Management '.m U r,. Preparation Air Vacuum Oxygen injection Detonation Off-Gas Treatment-1 Off-Gas Treatment-2 Off-Gas Treatment-3 Recovery of Fragment - '" D-3 Utility UnitB n Heat Keeping Operation D-4 Air Vacuum Channber lid closed, chamber under vacuum draw, HVAC flow continuous, damper modulates flow Blower Stac 17800Nm3/h 3800Nm3/h Gharcoal Filter Unit D 600Nm3/h Vacuum f^"*^^ Pump Blower 200Nm3/h Charcoal Filter UnitG Gontainment UnitA Utility Oxidizer Unit B In Heat Keeping Operation D-5 D-6 UnitB In Heat Keeping Operation D-7 D-8 D-9 D-10 D-11 D-12 D-13 EDT DESTRUCTION PLAN ANNEX E - CLOSURE PLAN Revision 2 December 2010 TABLE OF CONTENTS TABLE OF CONTENTS E-i LIST OF FIGURES E-ii LIST OF TABLES E-ii LIST OF APPENDICES E-ii 10 INTRODUCTION E-1 11 GENERAL DESCRIPTION E-1 12 CLOSURE STRATEGY E-1 2 0 CLOSURE PERFORMANCE STANDARDS E-5 3 0 DISPOSAL OR DECONTAMINATION OF EQUIPMENT, STRUCTURE, AND WASTE E-8 4 0 CLOSURE SCHEDULE OF ACTIVITIES E-8 5 0 CONFIRMATION ACTIVITY E-9 E-i List of Figures Figure E-1 Overview of Closure Strategy for DAVINCHTM EDT E-3 List of Tables Table E-1 Closure Standards for DAVINCH™ EDT Table E-2 Air Monitoring Sampling Requirements Table E-3 Sampling and Analysis Methods Table E-4 Closure Schedule Overview E-5 E-7 E-7 E-8 List of Appendices APPENDIX E-1 EDT SAMPLING PROCEDURES E-10 E-ii 10 INTRODUCTION This Closure Strategy descnbes performance standards and procedures to close the DAVINCH''''^ 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 matenals, perform venfication samplmg 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 appropnate procedures will operate the system The DAVINCH™ will remain under Govemment control (expected to be the Edgewood Chemical Biological Center in Edgewood, Maryland), therefore, the standard for decontamination of the equipment for removal is 200ppb or less than 1 0 VSL for HD 1 1 General Description The EDT will be located m Area 10 at DCD It will be used to destroy overpacked chemical munitions and vanous 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 Destruction 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 constituents, 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 appropnate 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 Closure Achieved^ ^ Determined through air momtonng, sampling, operational log review ^ Air monitonng via MINICAMS™ and DAAMS, and analysis of samples ^ Rmse water will be sampled and analyzed Results compared to closure standards (See Table E- EDT or component can be removed from EE and removed from site 1) Figure E-1 Overview of Closure Strategy for DAVINCFF^ EDT E-3 Decontamination procedures involve • Tenting, allowing 4 hours for equilibration at a minimum of 70°F then conducting head space monitonng using MINICAMS to less than 1 VSL for HD for two successive MINICAMS cycles Conducting monitonng at a mmimum of 70°F using MINICAMS to less than 1 VSL for HD for 24 hours • If MINICAMS readings are 1 0 VSL or greater, then decontamination actions are executed including, but not limited to the following 1) Performing decontamination of the chamber and chamber door through Electrostatically Charged Aerosol Decontamination (ECAD), which uses a proprietary method of applying decontamination fluids to the chamber and its interior passages The ECAD uses a statically charged particle generator to ensure that decontamination solution adheres to the inner surface of the chamber and the inner liner(s) for the chamber and lids 2) Disassembling components of the 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 3) Conducting "cleansing shots" which are explosive detonations without munitions to clean the mterior of the chamber, and use the detonation process to remove any contaminants 4) Cleaning sample and drain lines 5) 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 • Perfomnng air momtormg, samplmg, and pertinent assessments to confirm that the standards for removal are met, these assessments include, but are not limited to, rmsate sampling, filter media sampling, visual assessment of system condition to ensure that no visible residue remains in the chamber or piping, review of monitoring records to determine potential for system intemal contamination and headspace monitonng • 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 (US) Army Field Manual (FM) 3-5 For example, sodium hypochlorite (NaOCl), a standard decontaminant for chemical agent, is identified as a suitable decontaminant The decontamination/cleamng 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, E-4 and removed from the EE Wastes wall be properly characterized as outlined m the Waste Management Plan (Section 3 11 of the EDT Destmction Plan) and temporanly 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 rmsate sampling, if necessary, are identified in Appendix E-1 Momtonng results will be compared against the closure performance standard values listed in Table E-1, if monitonng analytical results do not meet the closure performance standards in Table E-1, equipment will be decontaminated until they are met The EDT will be deemed closed when air monitonng, 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 momtormg and nnse water sample results are received The EE will be decontaminated to the less than 1 0 VSL level for retum to ECBC Once the EDT unit is certified closed to less than 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/nnse waters, used PPE, and wipes, rags, and other absorbent and cleanmg 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 plus any additional codes determined by waste charactenzation Table E-1 Closure Standards for DAVINCHTM EDT Media and Parameter Performance Standard Equipment - Mustard (HD/HT) Less than 1 VSL headspace air monitoring Liquid Waste - Mustard (HD/HT) 200 ppb 2 0 CLOSURE PERFORMANCE STANDARDS Closure of the EDT unit and associated equipment will be deemed complete when air monitoring and nnsewater sampling results meet the closure performance standards identified in Table E-1, E-5 for movement to a govemment facility Air will be monitored for specific periods as detailed in Table E- 2 Closure performance standards for air monitonng of chemical agents are based on headspace vapor sampling and analysis and are established as screening to less than 1 VSL Sampling conducted to determine decontamination and closure is summanzed in Table E-3 E-6 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 reach equilibnum for 4 hours at or above 70°F before monitoring After the conditions hsted in this table are estabhshed, MINICAMS or Depot Area Air Monitoring System (DAAMS) samples will be collected MINICAMS alarms will be confirmed using DAAMS If results meet closure performance standards in Table E-1, the structure or equipment is considered closed Table E-3 Sampling and Analysis Methods Sample Source Number of Samples Sampling Method/ Equipment^ Analytical Parameters Analytical Method^ Sample Holding Time Headspace Gas Sample of EE and EDT Equipment See paragraph 1 2 Low-level air monitor/using MINICAMS™ or DAAMS Chemical Agents • EDT-TOCDF- PR007- ECBC TOP MT-11 DAAMS - TUBE MONITORING • EDT-TOCDF- PR008 MINICAM S • EDT-TOCDF-PR- 022 ANALYSIS OF CWM ON DAAMS N/A Rinse Waters Two Grab Chemical Agents EDT-TODCF-PR016- ECBC lOP MT-08- ANALYSIS PLAN AND ANALYSIS SOP N/A Mobile laboratory will perform confirmation agent analysis for all wastes, usmg state-approved analytical methods ^ DAAMS will be used to confinn MINICAMS™ alarm Mustard, HT will be measured HT will be measured as HD ' SPS/IOP's are Intemal Operating Procedures from Edgewood Chemical Biological Center and adopted for EDT Copies will be provided prior to initiation of operations "* All closure generated wastes must be fully characterized in accordance with TOCDF Part B Permit requirements and state and federal regulations prior to disposal E-7 Upon closure of the EDT unit and associated equipment, there will be no hazardous wastes or hazardous waste constituents, including decontamination wastes, remaining Pnor to beginning closure, all treatment residues and related wastes will be removed from the EDT site All wastes generated during closure activities, such as spent decontamination solutions and rinse waters, will be containerized, sampled, analyzed, characterized, and managed appropriately, based on waste classification and in accordance with applicable regulatory requirements Spent decontamination solutions and rmse waters will be managed as hazardous waste Closure wastes will be placed in a less-than-90-day waste storage area pending shipment to a permitted TSDF During closure activities, personnel will use appropnate personal protective clothing and equipment as determined by the EDT Site Safety and Health Officer Department of the Army Pamphlet (DA Pam) 385-61, Toxic Chemical Agent Safety Standards, will be followed, as well as Occupational Safety and Heahh Administration (OSHA) safety standards 3 0 DISPOSAL OR DECONTAMINATION OF EQUIPMENT, STRUCTURE, AND WASTE Soil removal should not be necessary during closure because the EDT operations are enclosed (the enclosure consists of ceiling, sides, ground cover, and flooring) and conducted on a closed- off-gas treatment system with secondary containment Any incidents involving chemical agent release or hazardous waste during operations would be managed under Emergency Response and Contingency Actions, outlined m the site-specific SSSP 4 0 CLOSURE SCHEDULE OF ACTIVITIES Table E-4 presents the notional schedule of closure actions by day Table E-4 Closure Schedule Overview Item Day Completed Initiate Closure Activities Day 0 Conduct Decontamination Day 5 Oversight and Review Day 5-7 Pack EDT equipment Day 6 EG&G Removal ail waste from EDT Site Day 8 Complete Closure Activity Day 10 E-8 5 0 CONFIRMATION ACTIVITY The Versar© Program Manager, EDT, will ensure that confirmation activities have been accomplished These activities include confirming that Spills, releases, and cleanup activities were noted and evaluating them The EDT procedures for closeout (servicing, cleanmg/decontaminating, and preparing the EDT and associated equipment for reuse and demobilization) were followed The EDT was "air monitored to venfy adequacy of cleaning/decontamination Air monitoring results were documented and the recorded values met the closure performance standards Decontamination nnsate and any de-ionized water rmsate sampling results met the closure performance standards Wastes generated from closure activities were transfened to a less-than-90-day waste storage area pending shipment off-site When the closure performance standards for air monitoring and decontamination rmsate sampling have been met, the Versar© EDT Program Manager will certify in writing that the EDT was closed in accordance with the approved closure strategy and all applicable regulations A licensed Utah 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-9 APPENDIX E-1 EDT SAMPLING PROCEDURES E-10 APPENDIX E-1 EDT SAMPLING PROCEDURES Purpose Sampling will be conducted to validate closure of the EDT and associated equipment in accordance with this procedure Objectives Monitoring will be conducted to determine if the VSL screening limit for the following equipment has been met EDT Main chamber mside walls, EDT Main chamber door/1 id, Hose and lines. Personnel decontamination station. Laboratory, EE Any areas that require additional decontamination will be treated with rmsate/decon solution Once the decontamination rmsate samples have been collected from the previously-listed EDT components/areas, the nnsate wastes can be commingled into a single container for easier management If required, the Operating Subcontractor (i e , Versar) will collect RCRA charactenzation sample(s) from the rmsate 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 Sampling Method E-11 MINICAMS headspace momtonng 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, Cham(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 mbber 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 overnight 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 at or 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-12 Environmental Enclosure The enclosure will be monitored for 24 hours without any readings at or above the 1 0 VSL screening limits If the enclosure is deemed to be contaminated additional decontammation will take place Sampling Lines Contaminated sample lines will be disposed of in accordance with hazardous waste mles Waste Management and RCRA Characterization All closure generated wastes will be placed in a DOT-approved container The container will be labeled as hazardous waste pending RCRA charactenzation The waste container will be transfened to EG&G personnel for management E-13 EDT DESTRUCTION PLAN ANNEX F TOCDF EDT EMERGENCY RESPONSE PLAN Revision 2 December 2010 TABLE OF CONTENTS TABLE OF CONTENTS F-I LIST OF TABLES F-II LIST OF APPENDICES . F-II 1 0 INTRODUCTION F-i 11 SPECIFIC CONTINGENCY PLANS F-2 / / / Preventative Measures F-2 112 Emergency Planning F-3 113 Response Actions F-4 1 2 WORKER POPULATION LIMIT (WPL) EXCURSION PLAN F-9 12 1 Purpose of WPL Excursion Plan F-9 12 2 Terms F-9 12 3 Operating Procedures F-9 F-l List of Tables Table F-l Emergency Notifications F-2 List of Appendices APPENDIX F-l Example Notice of WPL Notification F-l 1 APPENDIX F-2 Emergency Response Equipment Locations and Evacuation Routes F-l3 F-ii 10 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, unplanned release of hazardous materials, hazardous waste, or hazardous waste constituents during operations of the Explosive Detonation Technology (EDT) at TOCDF These actions pertain to all operations of the EDT at TOCDF, and they apply to all site personnel, visitors, contractors, and extemal support personnel The EDT will be located in Area 10 of the Deseret Chemical Depot (DCD) The system will be used to destroy overpacked chemical munitions 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 of the Destmction Plan The EDT Site Manager or Safety and Health Officer (SHO) will be responsible for ensunng that the appropriate procedures are followed The TOCDF Control Room will be notified if any emergency or release condition occurs Table F-l 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 mnoff 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 run-on as well as prevent the creation of any contaminated mnoff Engmeenng and administrative controls are m 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 F-l Table F-l Emergency Notifications Event Reporting Comments Fire TOCDF Control Room (435-833-7700) DCD Fire Response dispatched Medical TOCDF Confrol Room An Ambulance dispatched Chemical Release TOCDF Control Room TOCDF HAZMAT response team dispatched Chemical Spill of Indusfrial Compounds TOCDF Control Room TOCDF HAZMAT response team dispatched if required All Other Emergencies TOCDF Control Room TOCDF Emergency Response will assist m determmmg response level Accident Reportmg EDT Site Manager EDT SHO Operating Contractor PM Operatmg Confractor SHO TOCDF Confrol Room Notify as soon as possible after accident or ilhiess occurs Do not delay emergency assistance to make notifications, reporting shall be made by EDT Site Manager Chemical Event EDT Site Manager EDT SHO Operatmg Contractor PM Operatmg Confractor SHO TOCDF Control Room Do not delay emergency assistance to make notifications Notification of 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 Operatmg Contractor PM Operatmg 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 Notification of Other Facilities/Buildings in Event of Emergency TOCDF Control Room The TOCDF Control Room shall be responsible for notifying other facilities/buildings of EDT emergencies to include, but not be limited to, Autoclave, DVS/DVSSR and ATLIC personnel * * For additional notification requirements, see Section I I 3 11 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 1 1 1 Preventative Measures The following measures will be implemented to prevent or limit an emergency incident • Stnctly adhering to the Standard Operating Procedures (SOPs), including use of PPE F-2 dunng all EDT site activities Use of controlled access (i e , the persormel decontamination station airlock to the environmental enclosure must be passed through by personnel as they enter and exit the enclosure) Determining the evacuation route and rallying point, and communicating it to workers dunng the daily safety bnefing Keeping standard absorbent materials, shovels, and overpacks on-site to contain a spill or leak A review of the EDT consumable list and venfication checklist will be used to ensure appropnate inventones of these matenals Discontinuing operations when inclement/hazardous weather conditions pose a threat to the safe workmg environment Some of the items to be considered prior to determining if work should contmue are heat stress, severe weather conditions, such as high wmd, fog, and heavy ram, and potential for electncal storms 1 1 2 Emergencv Plannihg Response actions by EDT at TOCDF personnel for spills or releases will depend on whether the release occurs withm or outside of engmeenng control, it can be safely managed using EDT site persormel 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 matenals released to the environment and extent of injuries Releases or spills occumng withm 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 personnel 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 of the 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-3 833-7700) as indicated in Table F-l (see previous) 112 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 m an emergency • Facility changes in its design, constmction, operation, maintenance, or other circumstances in a way that matenally 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 Note 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 of the Code of Federal Regulation (CFR), Part 270 42, Appendix I, B 6 112 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 extemal support personnel for the following categories events involving Chemical Warfare Material (CWM), events involving non-CWM, medical assistance, fire/explosion, severe weather, and extemal arsenal events 113 1 General Spill or Release Response The following actions will be followed for spills or releases that occur within engmeenng controls and/or that can be reasonably handled using EDT site personnel and resources on hand • Notify the TOCDF Control Room • Weanng appropnate 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 MfNICAMS to less than 1 0 VSL level F-4 • For container spills, placing containers in overpack or removing container contents, if necessary, using a portable pump, and transfemng matenal to a new container If the matenal was released to secondary containment (for contents released from a container), released material either will be pumped out of the containment area using a portable pump or absorbed usmg compatible absorbent materials such as pillows, socks, or granules • Decontaminating equipment and clothmg 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 matenal into DOT-approved containers and managing appropriately in accordance with applicable permits and mles pertaining to hazardous waste management and spill reporting for hazardous material 113 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 hom (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 amval of medical personnel unless physical injuries prevent safe movement of the casualty Operators not showing symptoms of agent exposure will be processed through the Personnel Decontamination Station and will stand by for further instmction 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 113 3 Events Involving Non-CWM Matenals 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 occuned 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 • Skin Contact - Use copious amounts of soap and water Wash and nnse affected area thoroughly, and then provide appropnate medical attention An eye wash will be provided at the EDT personnel decontamination station Eyes should be nnsed for 15 minutes upon exposure Drenching, if required, will be performed at the personnel decontammation 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 matenals are involved, process through the Personnel Decontammation Station immediately If no chemical matenals are involved, processing through the Personnel Decontamination Station is not required 113 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) (landlme) through the TOCDF Control Room For medical emergencies involving CWM exposures, personnel shall follow the TOCDF Contingency Plan Additionally, procedures relative to medical monitonng and post- exposure results are established by the TOCDF Medical Director and will be adhered to in the event of individual exposure 113 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 sound an alarm (i e , an air hom) The operator must inform the EDT Site Manager of the size and location of the 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 of the 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 of the 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 persormel, including visitors, on the site Regardless of the size of the fire, the TOCDF Control Room will be called They will be informed of the nature of the fire and whether or not items containing chemical agents are involved F-6 If a shot is determined to be a partial detonation, SOP procedures will be followed In the event that such a partial detonation occurs, procedures and nsk assessments are in place to enter the chamber and address the issue It is not considered an emergency condition unless a release or explosive hazard exists, which will be addressed as part of this plan The Hazard Assessment has determined that this is an imlikely occunence 1 1 3 6 PPE Failure If any site worker experiences a PPE failure that affects the protective ability of the equipment, that person will immediately inform the Crew Chief and report to the Personnel Decontamination Station for assistance Re-entry to the EDT operations area will not be permitted until the equipment has been repaired or replaced and the EDT Crew Chief has granted permission 113 7 Physical Injury Emergency first aid shall be applied onsite as necessary A first-aid kit is available at the Personnel Decontamination Station For minor non-emergency physical mjunes requiring medical treatment beyond on-site first aid, the casualty will be transported to the nearest healthcare facility The TOCDF Control Room will be notified of all injuries 113 8 Severe Weather The TOCDF Control Room will inform the EDT Control Room of weather advisories such as severe weather watches or warnings The EDT Site Manager and SHO will consider this information and make modifications to the work schedule as appropnate to ensure worker safety Dunng severe weather, when notified, all personnel exposed to the elements will report to the designated safe location When lightning is detected, all EDT operation activities will cease The EDT Site Manager will develop a list of key personnel and ensure employee awareness In the event that TOCDF is closed (due to severe weather), the EDT Site Manager will notify key personnel to report to the site to ensure continued safety of any CWM and ensure that cntical equipment (such as monitormg equipment and ventilation equipment) is maintained These personnel will be on hand once the order to reopen the base is given, so activities at the EDT site can proceed with a minimum of mtermption Any munitions in overpacks that are on site in the event of an evacuation or work stoppage of operations due to severe weather conditions will be secured in the enclosure If evacuation is not called for, then CPRP members will monitor the status of the munitions If munitions/overpacks are set up with explosives and not yet placed in the chamber, the explosives operator will remove any detonators and render the item safe before evacuation, or, during severe weather If the munition/overpack is in the chamber, the chamber door will be closed and secured by the DCS In all cases, health and safety concems will ovenide any actions taken to secure munitions 113 9 Extemal TOCDF Emergencies The potential exists that an accident or incident somewhere else on TOCDF will require evacuation of the EDT site The TOCDF Control Room will inform the EDT Control F-7 Room of such emergencies should they occur 113 10 Evacuation Plan Personnel assigned to the EDT site will be mstmcted in evacuation signals, procedures, and routes from the EDT site An evacuation route from the EDT site will be determined pnor 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 persormel 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 m 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 of the 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 113 11 Notification and Reporting The primary responsibility for notification will lie with the Crew Chief with assistance from all other field personnel Table F-l (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 Combmed Stack that is equal to or greater than 0 5 Vapor Screening Limit (VSL) Required reports are made in accordance with R315-8-4 7(i) & Q) 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 Control Room will notify the DCD EOC 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 TOCDF F-8 1 1 3 12 Cntique of Response and Follow-up Formal accident investigation will be conducted by the CMA/supporting safety office in accordance with procedures identified m 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 pnor to resumption of EDT operations Approval of The Executive Secretary is required pnor 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 12 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/m^ • 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 appropnate 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 appropnate emergency response be initiated 12 3 Operating Procedures 12 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 • ECBC will immediately notify EG&G of the WPL excursion • ECBC 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 conected See Appendix F-l for an example of a Notice of Restnction • ECBC will notify the EDT Site Manager and provide the F-9 - Location of excursion, - Penod of time for excursion, - Name of agent involved, - WPL in mg/m\ - Amoimt of excess in mg/m^ ^ Proposes actions to prevent future excursions. Safety POC and telephone number, - Medical POC, and - Statement concemmg health impact and concunence of competent medical authonty Appendix F-l shows an example of a Notice of Excursion 1 2 3 2 Investigation of WPL Excursions Investigations of all WPL excursions will be performed to determine the cause, control the source of the excursion, and prevent future occunences Techniques for controlling excursions might include conducting additional monitonng, reviewing operational procedures, evaluating engmeenng controls, and/or other procedures as determined by the SHO and EDT Site Manager All information relevant to the investigation will be provided to the TOCDF Clinic Instances of excursions will be reviewed or analyzed to determine any trends F-10 APPENDIX F-l NOTICE OF WPL EXCURSION F-11 NOTICE OF EXCURSION Location Penod of ttme excursion occurred Chemical agent observed WPL for Chemical agent (mg/m3) Amount Detected (mo/m3) Amount of exceedance (mg/m3) Statement of proposed action to limit future excursions Medical POC Phona number and statement of health signiflcance of excursion (including CMA concurrence) Safiety POC Phone number. RESTRICTED AREA Entrance Requirements: F-l 2 APPENDIX F-2 EMERGENCY RESPONSE EQUIPMENT LOCATIONS AND EVACUATION ROUTES 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 personnel 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 appropnate 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 Pnmary ^®conclary ""^ It 5"^ F-IS I Q Unit Fire Extinguisher Locations Spill Kit Location Emergency Exit Routes Figure F-2-3. Evacuation Pathways for EDT Environmental Enclosure F-16 Figure F-2-4. Evacuation Route for DCD Including Area 10 F-17 EDT DESTRUCTION PLAN ANNEX G OPERATOR TRAINING PLAN Revision 2 December 2010 OPERATOR TRAINING PLAN Subcontract No DMB51843 Submitted to EG&G Defense Matenals, Inc /URS 11600 Stark Rd Stockton, UT 84071 Submitted by (^VERSAR Versar, Inc © 6850 Versar© Center Springfield, VA 22151 December 2010 TABLE OF CONTENTS TABLE OF CONTENTS . . I LIST OF TABLES . II LIST OF FIGURES. . ..... . . II LIST OF ACRONYMS . . .II 10 OPERATOR TRAINING OVERVIEW . 1 11 APPLICABLE DOCUMENTS 2 12 REFERENCES 3 2 0 EDT-SPECIFIC TRAINING REQUIREMENTS 3 2 1 EDT PROCESS TRAINING 3 211 Statement of Purpose 3 2.1 2 Process Overview and Training Objectives 3 2 2 JOB TITLES AND DUTIES 6 2 3 EDT-SPECIFIC TRAINING CONTENT, FREQUENCY, AND TECHNIQUES 9 2 31 Classroom Training Modules 9 232 EDT On-Site/OJT 10 2 4 EDT-SPECIFIC TRAINING MATERIALS IO 2 5 TRAINING STAFF 14 3 0 SITE-SPECIFIC TRAINING REQUIREMENTS . 14 3 1 CHEMICAL SITE-SPECIFIC TRAINING REQUIREMENTS 14 311 CEA Door Guard Training Course 14 312 Escort Training Course 15 313 Site-Specific Briefings 15 3 2 OTHER SITE-REQUIRED TRAINING 15 4 0 IMPLEMENTATION OF THE TRAINING PROGRAM 24 APPENDIX 1 25 APPENDIX 2 27 List of Tables Table 1 EDT Site Operational Training Objectives/Training Levels Table 2 Training Cumculum for Classroom Lectures Table 3 Training Cumculum for Site-Specific Training Table 4 Training Matenals Table 5 Site-Specific Training Requirements 8 9 11 13 17 List of Figures Figure 1 Process Overview and Training Objectives for Operators Figure 2 EDT Operational Organization 5 7 List of Acronyms CAIRA Chemical Accident or Incident Response and Assistance CBARR Chemical Biological Applications Risk Reduction Business Unit CEA Chemical Exclusion Area CLA Chemical Limited Area CPRP Chemical Personnel Reliability Program CSM Chemical Surety Materiel DAVINCH™ Detonation of Ammunition in Vacuum Integrated Chamber DCD Deseret Chemical Depot DCS Distributed Control System DESTINY Near Real Time Strain Monitonng System ECBC Edgewood Chemical Biological Center EDT Explosive Detonation Technology EG&G EG&G Defense Matenals, Inc /URS GRAND Global DAVINCH™ EDT Data System H&S Health and Safety LSC Linear Shaped Charges OSHA Occupational Health and Safety Administration OJT On the Job Training PPE Personal Protection Equipment RCRA Resource Conservation and Recovery Act T-CEA Temporary CEA TOCDF Tooele Chemical Agent Destruction Facility 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 engmeenng Training Plan for operators of the 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 of the training program for EDT operators at TOCDF 1 Versar© proposes usmg qualified, trained operators from the Edgewood Chemical Biological Center (ECBC) Chemical Biological Applications & Risk Reduction (CBARR) operators, supported by Versar© personnel A memorandum of understanding 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 persormel, trainmg certifications, and Competent Person Traming will be provided before deployment A Traimng 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, descnbed in this Operator Traimng Plan, • DCD- and TOCDF-required framing, including site-specific training required by the operating contractor [i e. Site Visitor Orientation Training (SVOT)], chemical exclusion area operations, SOW Appendix B, Badging and Site Access, and Appendix E, Training and 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 of the 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 amval 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 Trainmg) (in) 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 Traming) 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&G, which includes Appendices B and E TOCDF Traming Plan, Attachment 7, TOCDF (May 2009), 29 Code of Federal Regulations 1910 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, Structures 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-CONTINGENCY 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- Matenal Handling Operations EDT-TODCF-PR013 - Maintenance Operations EDT-TOCDF-PRIO - Metal Fragment Drum Headspace Monitoring Operations 12 References Kobe Steel Ref V00_DV1 l-PR-01_Training Plan, January, 2009 2 0 EDT-SPECIFIC TRAINING REQUIREMENTS The training program is designed to tram experienced EDT operations personnel, site supervisory personnel, and other site staff in the specific operational charactenstics, processes, maintenance, and systems nianagement necessary to conduct safe and secure Detonation of Ammunition in a Vacuum Integrated Chamber (DAVINCH™) EDT operations in a chemical surety program This will be completed using a combination of classroom instruction and closely supervised on-the-job traimng (OJT) The program provides for initial framing for the operators, it does not address recumng 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 11 Statement of Purpose The purpose of this training is to instruct operations supervisors, engineering and maintenance personnel, and system operators in the operating principles of the DAVfNCH''"'^ 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 DAVfNCH^'** 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 DAVfNCH™ 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 concem, 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 12 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-/DAVINCH™-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 truck used to transport the mimitions using a Miniature Chemical Agent Monitonng System (MINICAMS™) to ensure safe first entry into the truck A forklift-trained operator with ammunition training, CPRP certifications, and OSHA framing, weanng appropnate Personal Protective Equipment (PPE), moves the pallet or box containing the overpacked mumtions (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 framing, CPRP, OSHA, and ammumtion-handlmg/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 of the 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 mumtion 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 MfNICAMS™, 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 m full view of the two operators standing adjacent to the platform at the level of the chamber enfrance 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 mumtion to hang in place Specific training will be required for that process Receipt of OP Munitions at Unpack TO D A C O First Entry Clearance with MINICAMS™ TO D C O Move OP Munitions to Processing Area TO D A C O Install LSC and Donor Charge TO D A C O Move Donor Charge and LSC from Day Box TO D A C O Move Donor- configured munition to EDT processing area TO D A C O Install munition in chamber TO D A C O Set detonator wiring TO D A C O Operate DAVINCHTM Chamber TO D, A,C,0 T Establish TEA, Control Room Operations TO D A C O Open Chamber Door Remove Scrap (Magnet) TO D A C O First Entry Clearance with MINICAMS™ and Confined Space Oversight TO D C O Move Scrap to Waste Processing Area TO D C O Transfer Scrap to Waste Drums TO D C O Waste Clearance with MINICAMS™ TO D C O Personnel Decontamination TO D AC O Traimng Obiectives D- DCD site training, OSHA, and baseline training A- Ammunition/Explosive C- CPRP O- Operations/DAVINCH™ Figure 1 Process Overview and Training Objectives for Operators After hanging the munition in the chamber, a trained operator will test the continuity of the detonation cable pass-through, and ensure that the leads are shorted at the EDT Control Room When completed, a public address system (PA) will be used to relay this information to the EDT Control Room Once that is validated as safe, the operator will cormect the detonation cord chain to the leads at the pass-through and then exit the chamber The movable platform will be withdrawn by the operators These operators will observe the closure of the chamber lid and then exit the Environmental Enclosure through the personnel decontamination area The operators injthe Confrol Room will validate that the chamber is clear of personnel and equipment pnor to closing the lid Once the lid is closed, the Temporary Exclusion Area (TEA) is maintained at the perimeter of the mam enclosure, and door guards are posted at the control- point door The EDT will then cycle through its process of evacuation, stabilization, and conect pressure/vacuum setting Just pnor to detonation sequencing, the EDT control operators will test the continuity of the explosive lead circuit and attach the detonation tngger mechanism Once clear, the EDT operators will initiate the detonation sequence, ensunng safe position and accountability for all operators, observers, and other staff The EDT Control Room will perform the necessary pre-detonation checks Once all checks have been cleared, the EDT Site Manager or designee will then indicate that the detonation will occur The PA system will be used to provide various warnings, followed by a countdown and detonation Once the chamber has completely cycled through its process, three operators will enter the EDT containment area in PPE A magnet system will be used to remove ferrous metal fragments Two more operators will then enter the chamber after the interior of the chamber has been determined to be safe to enter based on MINICAMS™ results obtained from a sampling location that IS downstream from the particle filter These operators will manually remove any remaining waste that might be impeding the operation Waste materials will be transfened by operators in PPE to the waste container in the chamber area, and a trained operator will move the waste contamer to the Waste Processing Area for headspace analysis in drums designed for that purpose The solid waste will be headspace screened to 0 5 VSL in accordance with procedures The waste storage area of the Environmental Enclosure will be managed in accordance with 90 day storage area requirements Operators will screen the extenor of the waste containers to less than 0 2 VSL level and use a forklift to move the waste, once cleared, to the extenor of the enclosure for pickup by TOCDF Waste Management operations The waste will then be tumed over to TOCDF Waste Management personnel who will anange for any additional analyses required and for off-site disposal All personnel will then exit via the control point, and the system can either be shut down for maintenance, or the process can begm for the next shot A maximum of seven shots per day can be accomplished 2 2 Job Titles and Duties Training courses are to be held for the followmg different levels of personnel, based on their assignments and responsibilities, as noted in the foUov^ng paragraphs and Figure 2 The on-site organization and framing objectives will consist of categones identified in Table 1 below As shown in the table, the plan includes four levels of framing, each optimized for the different assignments of personnel as follows • Supervisor Course for the supervisory and engmeenng 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 Familianzation Course for Momtonng personnel and site personnel who do not handle munitions, operate controls, or perform chemical duties CPRP Control Room *Medium Level Same personal as site manager and safety (ECBC) EG&G Project Manager (Versar) ^*High Level - •.• -'..if Safety Manager (Explosive Environmental) A/ers in Site Manager (Kobe Steel) i Shift Supervisor (Kobe Steel) Site Manager (ECBC) |*Medium Level Safety (ECBC) •Medium Level A (ECBC) B (ECBC) C (ECBC) Analysi s/Monitonng Sampling *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 descnbed in Section 3 0 Included will be site- specific framing for the unique aspects of the EDT as implemented on the TOCDF site, including chemical-area-specific training, door guarding, escorting, RCRA Class III Permit modification and Air Permit modification instruction, and framing 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 Traming • 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 ECBC Monitoring, Laboratory and QC Personnel (CPRP) Monitoring • EDT Familianzation Course • Site-Specific Training • Escort Training • D, 0 Training Obiectives D- DCD site training, OSHA, baseline training A- Ammunition/Explosive C-CPRP O- Operations/DAVINCHTM As shown m Table 1, the plan includes three levels of training, each optimized for the different assignments of personnel as follows • High level course for the engmeenng personnel two persons (Versar, project manager and safety manager) • Medium level course for supervising personnel two persons (site manager and safety) • Low level course for operating personnel 6 persons- EDT operators • Monitoring and analyst personnel Momtormg personnel are assumed to have sampling and analysis training and experience will be assigned, therefore, no additional formal training is necessary beyond baseline TOCDF/DCD site training requirements, and proficiency on the instrumentation and processes used during monitonng 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 of the Supervisor, EDT Operator, and Familiarization classroom traming modules is presented in Table 2 These are the cunently contemplated subject areas for instruction, but may be augmented as the scheduled training draws nearer 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 bnef • Supervisory • EDT Operators Operation Procedures • Division of Work on Site • Standard Operation Procedures • Startup and Shutdown • DCS • DESTINY • GRAND User Manual (1 day) Course Curriculum Matenal/Duration • EDT Operators EDT Safety • Hazards of Chemical Agent (Area) • Hazards of Explosion/Gas Leaks • Donor Explosive Handling and Storage User Manual (1 day) • EDT Operators Mamtenance • Where and how to check the EDT conditions/PM schedule • Dust and Liquid/Drain Removal Design Documents (1 day) • Supervisory • EDT Operators • Familiarization Course • Agent Analysis & Monitonng • Request for Analysis & Momtonng Sampling Method Paper (1 day) 2 3 11 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 DAVINCH''"'^ 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 internet [Disfributed Control System (DCS), DESTINY, GRAND] 2 3 12 Classroom Training Location A fully-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 OJT will follow the classroom training modules at ECBC For this requirement, the cumculum 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, engmeenng documentation and manuals, flow charts and process flow diagrams, plans and procedures, and related matenals These matenals will be distnbuted to the operators as necessary, and copies of the matenal will also be retained on-site m the Control Room/break room areas for easy reference The site will also be the repository for the framing 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 Traming Manager's ongoing programs Any proposed modification to the traming cumculum 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 • Familianzation Kanda Video • Supervisory • EDT Operator • Familiarization Belgium Video • Supervisory • EDT Operator • Familianzation Process Flow Diagram • Supervisory • EDT Operator • Familianzation 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 Pomts • 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 Training Staff A Training Supervisor will be assigned to coordinate and manage the trainmg program for the EDT Team The Training staff will include engmeenng and operational specialists with expenence at both Kanda Harbor, Japan, and Poelkapelle, Belgium These frainers will have an excellent command of English to minimize any communication issues between trainers and students The training staff has expenence m developing and implementing training for operators from the Belgian Ministry of Defense and for the Kobe Steel staff in Japan These expenenced trainers will be available during the framing process for individual consultation and coaching should that be necessary Example resumes of the training staff are provided in Appendix 2 The sample resumes identify the type and level of persormel available from Versar© and Kobe Steel to conduct the training process 3 0 SITE-SPECIFIC TRAINING REQUIREMENTS 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 m 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 maintaimng 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 11 CEA Door Guard Training Course This course provides the trainee with information for performance as a CEA Door Guard Upon completion of this traming, the trainee will be able to 14 • Discuss key words and definitions • Descnbe the Duress System, including the rules, and how and when it is used • Descnbe the general and special CEA Door Guard requirements and responsibilities • Descnbe the process for maintaining secunty of a CEA Door in "Access" dunng an emergency/exercise • Discuss previous CEA Door Guard violations and noncompliances 3 12 Escort Training Course Upon completion of this presentation, the trainee will be able to • Differentiate between a CLA, CEA, and T-CEA • Descnbe the Duress System and how to use it • Identify the level of authorization indicated by a proximity badge (CLA, CEA, T-CEA, escort/no-escort required) • Identify the basic elements of the 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 of the "Checklist for Escorting" and Lessons Learned 3 13 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 Part B Permit and Air Permit requirements This will include • 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 of the Site Training Program for the personnel assigned to the EDT program The requirements for each position will be analyzed for applicability of the 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 pnor to operations 15 Exhibits 1 and 2 to Appendix E are presented below Each employee will have the appropnate training documented on these forms, which will be provided to EG&G pnor to operations These forms will be used to document and substantiate the training for the EDT team 16 Table 5 - Site-Specific Traming No. Req'mt Training EDT Training Objective T-2 29 CFR 1910 120 (q)(6)(i) OSHA/RCRA Awareness Training A certificate of completion from a qualified course for each Versar© Team employee As stated m Appendix C, all Versar© Team personnel receiving One-year Temporary or Permanent badges must complete an 8-hour training class to fulfill the requirements of 29CFR1910 120(p)(8)(iii) and (q)(6)(i) This OSHA Awareness level training may be accomplished via any training course which satisfies the specified OSHA regulations Versar© Team personnel shall submit documentation which shows they have had the required training withm the last 12 months The Subcontractor shall take refresher training as required during the performance of this contract to ensure that a 12 month period does not lapse since the Subcontractor last completed the trainmg class Personnel who do not have this traimng will be enrolled in EG&G HAZCOM, CPRFA, and/or SORT-R T-3 29 CFR 1910 120 (P)(7)(i) OSHA/RCRA Operations Training A certificate of completion from a qualified course for each Versar© Team employee In accordance with 29 CFR 1910 120(p)(7)(i), employees exposed to health hazards or hazardous substances must receive 24 hours of framing to enable them to perform their assigned duties and ftjnctions in a safe and healthful manner so as not to endanger themselves or other employees This OSHA Operations level trainmg may be accomplished via any training course which satisfies the specified OSHA regulations Versar© Team personnel shall submit documentation which shows they have had the required training withm the last 12 months The Personnel shall take refresher fraimng as required during the performance of this contract to ensure that a 12 month penod does not lapse since the Personnel last completed the framing class EG&G SORT-0 may be used for this training T-4 29 CFR 1910, 29 CFR 1926 Competent Person A completed Competent Person Form (Training Appendix Exhibit 1) for each individual designated by the Subcontractor to OSHA regulations require that the Subcontractor have a "Competent Person" perform various activities related to the safe execution of work activities Versar© will complete and submit a completed Competent Persons Form (Exhibit 1 to the SOW Appendix E) for each person who is designated the Competent Person for the specified activity Versar© will provide competent or designated persons as required by all OSHA regulations but as a minimum shall provide competent persons for the following areas of competency, as required by the Tasking a Asbestos- 1926 1101 b Cranes - 1910 179, 1910 180, 1926 550, 1926 753 c Material/Personnel Hoists - 1926 552 d Demolition - 1926 850, 852, 858, 859 17 No Req'mt | Training EDT Training Objective perform the specified activities e Scaffolding - 1926 450, 451,454 f Electncal - 1926 404 g Ladders- 1926 1053, 1060 h Fall Protection - 1926 500, 502, 503, 1060 1 Slings & Rigging - 1910 184, 1926 251 j Lead- 1926 62 k Welding/Cutting - 1910 253, 254, 255, 1926 354 1 Excavations/Trenches - 1926 650, 651, 652 m Compressed Air - 1926 803 n Ionizing Radiation - 1926 53, 1910 1096 0 Cadmium-1926 1127 p General Health & Safety - 1926 20 T-5 29 CFR 1910 1200 Hazards Communication A completed Training Form (Training Appendix Exhibit 2) for each Subcontractor and Sub-tier Subcontractor employee 29 CFR 1910 1200 mandates that the Subcontractor establish a comprehensive Hazard Communication Program, which includes contamer labeling and other forms of warning, material safety data sheets and employee traimng Versar© will submit a completed Subcontractor Training Form (Exhibit 2) for each Subcontractor and Sub-tier Subcontractor employee T-6 29 CFR 1910 146, 29 CFR 1926 21 (b)(6) Confined Space Traimng A completed Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable OSHA regulations 29 CFR 1910 146 and 29CFR1926 21(b)(6) require that all employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subconfractor and Sub- tier Subcontractor employee required to have this training The Confined Space course offered by EG&G will be used to accomplish this requirement for operators not yet certified 18 No Req'mt Training EDT Training Objective Subcontractor and Sub-tier Subcontractor employee T-7 29 CFR 1910 178 (1) Forklift Training A completed Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable Subcontractor and Sub-tier Subcontractor employee OSHA regulation 29 CFR 1910 178(1) requires that the Subcontractor shall ensure that each powered industrial truck operator is competent to operate a powered industrial truck safely, as demonstrated by the successfiil completion of the training and evaluation specified The Subcontractor shall maintain records which document the training for each individual designated to operate a forklift The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subcontractor and Sub- tier Subcontractor employee required to have this traimng The Forklift Traimng course offered by EG&G will be used to accomplish this requirement for operators not yet certified T-8 29 CFR 1910 147 Lockout/Tagout Training A completed Subcontractor Trainmg Form (Training Appendix Exhibit 2) for each applicable Subcontractor and Sub-tier Subcontractor employee OSHA regulation 29 CFR 1910 147 requires Subcontractors to establish a program and utilize procedures for affixing appropriate lockout devices or tagout devices to energy isolating devices, and to otherwise disable machines or equipment to prevent unexpected energization, start-up or release of stored energy in order to prevent injury to employees It further requires that the Subcontractor shall provide traimng to ensure that the purpose and function of the energy control program are understood by employees and that the knowledge and skills required for the safe application, usage, and removal of the energy controls are acquired by employees The Subcontractor shall maintain records which document the training for each individual designated to perform these activities The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subcontractor and Sub-tier Subcontractor employee required to have this training The Lockout/Tagout course offered by EG&G will be used to accomplish this requirement for operators not yet certified T-9 29 CFR 1926 503 Fall Protection Training A completed OSHA regulation 29 CFR 1926 503 requires that the Subcontractor shall provide a training program for each employee who might be exposed to fall hazards The program shall enable each employee to recognize the hazards of falling and shall train each 19 No Req'mt Training EDT Training Objective Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable Subcontractor and Sub-tier Subcontractor employee employee in the procedures to be followed in order to minimize these hazards The Subcontractor shall maintain records which document the framing for each individual designated to perform these activities The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subcontractor and Sub- tier Subcontractor employee required to have this traimng The EG&G Fall Protection Course will be used to accomplish this requirement for operators not yet certified T-11 29 CFR 1910 134 Respiratory Protection A completed Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable Subcontractor and Sub-tier Subcontractor employee 29 CFR 1910 134 mandates that employers requiring their employees to wear respiratory protection develop and establish a written Respiratory Protection Program The program shall include medical screening, pulmonary function test (PFT), training, and fit testing The Subcontractor is required to maintain records which document all OSHA required activities The Subcontractor shall submit a completed Subcontractor Trainmg form (Exhibit 2 to this Appendix) for each Subcontractor and Sub-tier Subcontractor employee required to have this training Subcontractors performing tasks which require respiratory protection shall supply respirators for their personnel T-12 29 CFR 1910 332 Electrical Traming A completed Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable 29 CFR 1910 332 requires employees shall be framed in and familiar with the safety- related work practices required by 1910 331 through 1910 335 and NFPA 70E, "Electrical Safety Requirements for Employee Workplaces" that pertain to their respective job assignments The Subcontractor shall ensure that all Subcontractor and Sub-tier Subcontractor employees have had the required traimng The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subcontractor and Sub-tier Subcontractor employee required to have this framing 20 No Req'mt Training EDT Training Objective Subcontractor and Sub-tier Subcontractor employee T-13 29 CFR 1926 1101 A completed Subcontractor Training Form (Training Appendix Exhibit 2) for each applicable Subcontractor and Sub-tier Subcontractor employee 29 CFR 1926 1101 requires that employees shall be trained m and familiar with the hazards associated with asbestos and the specific procedures implemented to protect employees from exposure to asbestos, such as appropriate work practices, emergency and clean-up procedures, and personal protective equipment to be used The Subcontractor shall ensure that all Subcontractor and Sub-tier Subcontractor employees have had the required training The Subcontractor shall submit a completed Subcontractor Training form (Exhibit 2 to this Appendix) for each Subcontractor and Sub-tier Subcontractor employee required to have this training 21 Training Appendix Exhibit 1 Competent/Designated Person Acknowledgement Form Definition A Competent or Designated Person is a person who has the ability and training to recognize hazards and the authority to correct them Responsibihty The designated Competent/Designated Person is responsible for recognizing and correcting safety hazards This person has the authonty to stop work in the event of any potential safety concem on the job site This representative is considered the contact person for EG&G Management on safety-related issues and shall be on-site whenever the Area of Competency is involved with the project This form must be completed by the Subcontractor and the Subcontractor's designated Competent Person(s) Where a Subcontractor is responsible for sub-tier Subcontractors, it is necessary to maintain additional designated Competent Persons and forms for each additional tier Each Subcontractor must submit this completed form prior to beginning any work on the project and must update it any time there is a change in the designated representative{s) Supervisor Acknowledgement representing Subcontractor Supervisor (Pnnted Name) Subcontractor Name have assigned the below listed personnel to be the Competent/Designated Person(s) in the areas indicated I acknowledge that this individual has been thoroughly trained and is experienced m hazard recognition He/she has authonty to stop work and correct hazards m the event of a potentially hazardous situations or imminent danger Subcontraclor Supervisor (Signature) Competent/Designated Person(s) Acknowledgement I(we), the undersigned individual(s), acknowledge that I(we) have been thoroughly trained and have experience to perform the duties as a Competent/Designated Person m the area(s) indicated below l(we) understand that l(we) have the responsibility and authonty to correct hazards and stop work in the event of potentially hazardous situations or immment danger Area qf Competency a Asbestos 1926 1101 1 Slings & Rigging 1910 184, 1926 251 b Cranes 1910 179, 1910 180, 1926 550, 1926 753 J Lead 1926 62 c Material/Personnel Hoists 1926 552 k Welding/Cutting 1910 253,254,255, 1926 354 d Demolition 1926 850, 852, 858, 859 1 Excavations/Trenches 1926 650, 651,652 e Scaffolding 1926 450 451,454 m Compressed Air 1926 803 f Electrical 1926 404 n Ionizing Radiation 1926 53, 1910 1096 g Ladders 1926 1053, 1060 0 Cadmium 1926 1127 h Fall Protection 1926 500, 502, 503, 1060 p General Safety & Health 1926 20 Competent Person (Signature) Competent Person (Print Name) Area(s) of Competency (enter letter indicating competency) Date 22 Training Appendix Exhibit 2 Training Acl^nowledgement Form Requirement The Occupational Safety and Health Administration (OSHA) regulations require that employees be trained to perform certam activities This training varies depending on the activity Sometimes a wntten program, which completely delineates the processes and procedures to be used for the traimng and testing, is required In other cases, the required training is undefined and may simply be verbal instruction or ensunng that written instructions have been read In some cases, there are requirements to provide refresher training (usually annually) Responsibility The Subcontractor has the responsibility to be aware of all applicable traming requirements specified by OSHA Furthermore, the Subcontractor has the responsibility to ensure that their employees are aware of the required trainmg, have received all of the required traming This mcludes ensuring that the traming is current and documentation of the training is maintained as required by the applicable regulation The employee shall not be allowed to perform any activity for which they have not had the required training and that training must be current This form must be completed by the Subcontractor and the Subcontractor's employees who will be performing the activities for which OSHA-specified training is required Where a Subcontractor is responsible for sub-tier Subcontractors, the Subcontractor shall ensure that all such sub-tier Subcontractors and their employees complete this form Each Subcontractor must submit this completed form pnor to beginning any work on the project, he/she must update it any time there is a change in the personnel assigned to perform the designated tasks Supervisor Acknowledgement I, , representing , Sutxonuactor Supervisor (PniMcd Name) Subcomiaclor Name have assigned the following personnel to perform activities that require specific OSHA training in the areas indicated I acknowledge that this indivKJual has been thoroughly trained in accordance with the requirements of the applicable OSHA regulations Subcontractor Supervisor (Signature) Employee(s) Acknowledgement I (we), the undersigned individual(s), acknowledge that I (we) have been thoroughly trained and have experience to perform the duties in the area(s) indicated below Area of Training T-5 Hazards Communication 1910 1200 T-11 Respiratory Protection 1910 134 T-6 Confined Spaces 1910 146, 1926 21(b)(6) T-12 Electncal 1910332 T-7 Forklift Operation 1910 178(1), 1926 602 T-13 Asbestos 1926 1101 T-8 Lockout/Tagout 1910 147 T-14 Lead 1926 62 T-9 Fall Protection 1926 503 T 15 Cadmium 1926 1127 T-10 First Aid 1910 151, 1926 50 T-16 Powder Operated Tools 1926 302(e)(1) Trained Person (Signature) Trained Person (Print Name) Area(s) of Training (list applicable T #s) Date 23 4 0 IMPLEMENTATION OF THE TRAINING PROGRAM Training operations for the EDT project will begin pnor to systemization, continue through it, and end when site operations commence The Traimng Supervisor will schedule and manage training activity pnor to and dunng site activity Any replacement persormel 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, Trainmg and Certification Requirements Operators, site supervisors, and site management personnel will be required to complete the initial phases of the training program pnor 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 of the employees filling each job • A wntten job descnption for each job title • A wntten descnption of the type and amount of EDT, site access, and other training given to each person named • Records that document the successful completion of the training and experience required for each person named • The training records and documents shall be kept at least until closure of the 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 APPENDIX 1 CBARR TRAINING REQUIREMENTS 25 CBARR TRAINING REQUIREMENTS Chemical Biological Applications & Risk Reduction (CBARR) operations at Edgewood Chemical Biological Center (ECBC) provides in-house framing as a baselme 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 m 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 In accordance with AR 50-6, all CPRP personnel will have completed core safety, secunty, 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 appropnate • Agent-handling training and certification • OSHA 40-hour traming and annual certification • Explosive traming, including Ammunition, Arms, and Explosives (AA&E) • Related training in the any areas of technical proficiency as required (e g , forklift operations) • Site-Specific Training per Section 3 Prior to deployment, the training records, cumculum plan, and training 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 APPENDIX 2 SAMPLE EDT TRAINER RESUMES 27 PROPOSED TITLE/POSITION Trainer, Supervisor and Chemical Operations Supervisor Name Education/Qualifications B S , Chemistry, South Carolina State University, 1967 M S , Education, South Carolina State University US Army Traimng Courses (chemical surety, US Army Ranger Course, NBC training) Present Position in Offeror's Company Vice President, Chemical Operations Relevant Experience Mr j^^l oversees all chemical surety operations at VERSAR©, including the m-house surety,laboratory, operations involving KSL EDT overseas, operations at Dugway Proving Ground and Non-Stockpile demil programs He provides training to in-house and contractor personnel Additional duties mclude for oversight of the training and supervision of technicians in the handling of materials and samples exposed to chemical and biological agents, and monitoring of all laboratory operations for compliance with local, state and federal regulations The following is a partial list of the supported key projects Tooele Chemical Agent Destruction Facility EDT Project Responsible for chemical operations, monitoring planning and technical support to the EDT program Kanda Harbor Chemical Destruction Program Responsible for oversight of MINICAMS operations, training personnel for operations at Kanda involving momtormg, and management of the project Chemical Demilitarization on the Non-Stockpile Chemical Materiel Program, for which GEOMET was responsible for mobile analytical laboratory operations, air monitonng, associated chemical surety materiel activities, and other relevant laboratory services. Improved Toxicological Agent Protective Suit Program and STEPO Program-Natick, Non-Stockpile Program - Chemical agent analysis of environmental samples from Spring Valley site in Washington, DC and biological agent analysis of samples from a site at Ft Detrick, USACE Various Assignments, US Army Chemical Corps During service in the Army, acquired more than 23 years of experience m NBC matters including a wide range of chemical surety related training programs As Chief, Chemical-Biological Division, U S Army Chemical School, supervised an instructor staff of 85 with responsibility for training soldiers m chemical warfare and chemical and biological defense, directly supervised the training of chemical laboratory specialists m the 28 school's chemical laboratory Administered the establishment and monitonng of NBC contamination survivability cntena for the Department of the Army to ensure the incorporation of NBC matenel survivability cntena in the design, acquisition and procurement process for new items of Army matenel, and to ensure the evaluation of non-NBC survivable fielded equipment for retrofit of survivability charactenstics Personally evaluated and formulated solutions for high visibility DoD problems pertaining to chemical stockpile demilitanzation, chemical stockpile retrograde, preparation of supplemental environmental impact statement which supported the decision to build binary chemical production plants at Pine Bluff Arsenal, preparation and submission of the presidential certification to the congress for production of the 155 mm binary artillery projectile, and GAO questions about the binary chemical program 29 PROPOSED TITLE/POSITION Trainer, DAVINCHTM Operations Name Education/ Qualifications Visitmg Student / 1991/St Cathenne's College, Oxford M S /1989/Mechanical Engineering/ Kyoto University, Japan B S /1987/ Mechanical Engineenng/Kyoto University, Japan First Class Explosives Control Officer Present Position in Offeror's Company Relevant Experience Manager at Engineering Department, Nuclear and CWD business umt Mr ^^^^1 has over 15 years of experience with heavy engineering associated with detonation chambers, donor explosive charge analysis, structural engineering, research and development for fatigue and damage evaluation of the EDT system, test and evaluation of the DAVINCH''''^'^'^ system for detonation and simulant/sunogate testmg, donor charge design, and activated carbon filtration He is also a First Class Explosives Control Officer (Japan), and holds a Master's Degree in mechanical engineering from Kyoto University, Japan He trains operators and engineers in DAVINCH™ technology Japanese Chemical Weapons Destruction Project, Kanda, Japan - Mr imillH serves a lead applications engineer for the EDT system at Kanda The system has safely and successfiilly destroyed approximately 600 chemical munitions containing HD and L using vacuum-assisted detonation The munitions were recovered from the sea using a container system designed to keep the munition at the appropnate pressure and temperature to ensure that they are stable when brought to the surface Mr Hl^^l designed and improved donor charge using gel-based explosives to destroy chemical bombs by controlled detonation He was also in charge of modeling and ensuring that the technical aspects of detonation were applied Mr also managed detonation tests on vanous chemical munitions using controlled detonation technology He also directed the DAVrNCH™"^"^ R&D work on detonation chamber, includmg fatigue damage evaluation using strain measurement and finite element analysis of the structure Incinerators and melting furnaces and R&D Mr provided design and R&D engmeenng for development of a sewage sludge incinerator and melting fumace R&D work including activated carbon filter technology to removal of dioxins from exhaust gas, and ultrasonic / heat treatment for sewage sludge Environmental R&D Mr provided engineering and technical support for projects relevant to environment recovery He also set up training requirements and coursework for personnel for better performance in R&D 30 PROPOSED TITLE/POSITION- Trainmg Engmeer, DAVINCHTM Name Education/Qualifications M S /1984/ Mechanical Engmeenng /Tokushima University, Japan Thermal Energy Manager First Class Explosives Control Officer Present Position in Offeror's Company Relevant Experience Manager at Engmeenng Department, Nuclear and CWD business unit Mr ^^^^B has played a significant role in designing and constructing power plants and heating and cooling plants as a project engineer and manager He has been in charge of design process at the Chemical Weapons Destruction Project in Kanda, Japan He was instrumental in transfemng the technology and training at Poelkapelle, Belgium Chemical Weapons Destruction Project, Kanda, Japan As a Process Designer, Mr is in charge of process design He is reviewing new equipment for the off-gas treatment facility being designed for THALES, (SECOIA Project) and conducting research on the possible miniaturization and simplification of the off-gas treatment process by applying a Cold Plasma Fumace R&D of Off-Gas Treatment played a key role in the 1st test off-gas treatment test of Cold Plasma at USA and the 2nd test Chemical agent destruction test of Cold Plasma at GEOMET Mr ^HIH managed the off-gas treatment test on new technology using Cold Plasma He checked the decomposition rate of Cold Plasma fumace by mixed gas of Mustard (HD) and Lewisite (L) He also designed compact and simplification of the off-gas system Cogeneration Facility Work for Daian Plant, Daian, Japan As Project Manager/Designer, Mr HUH is responsible for playing numerous roles, from involvement in preliminary design to the construction, commissioning and maintenance of a cogeneration facility for a plant, as well as dealing with the plant licensing with govemment authonties Research Connected to Coal Fly Ash, Kobe, Japan Mr [^^m was a Researcher with responsibility for engaging in R&D in the manufacturing of an artificial and lightweight aggregate from coal fiy ash, studying ways to promote the effective use of coal fly ash in concrete and tiles via electrostatic separation, and decarbonizing coal fly ash by electrostatic separation and assessing those modified coal fly ash Development of a Sewage Gas Pretreatment Unit, Kobe, Japan Mr served as a Researcher/Project Engmeer with responsibility for establishing a sustainable, stable operation for cogeneration using gas engine, developing a sewage gas pretreatment unit to remove minute amounts of hazardous elements in sewage gas, and demonstrating the operation of cogeneration technology 31 PROPOSED TITLE/POSITION EDT Safety Confrol Manager Name Education/Qualifications Totton Prefectural High School in Yonago Diploma of Industrial Chemistry Explosive Control Officer Special Industnal Waste Manager Received training and practice with respect to the OCW destruction conducted by dstl (Defence Science and Technology Laboratory Present Position in Offeror's Company Relevant Expenence Safety Confrol Manager for Chemical Weapon, Kobe Steel Mr j^^^B is an Explosives Control Officer with more than 45 years experience in the field He has received traming from and performed OCW destmction in accordance with practices established by the Defence Science and Technology Laboratory His career highlights include directing and controlling the safety of destmction operations at CWD facility and marine operations Chemical Weapons Destruction Project, Kanda, Japan. On this project, Mr mm directed and controlled the safety aspects of destmction operations at a CWD facility and marine operations uncovering and recovering approximately 600 old chemical weapons His duties also included directing the transport of the bombs to CWD facility and interacting with domestic officers He also assisted m the transportation of old chemical weapons found at Kanda port to Sasebo Maritime Self-Defense Force for investigation of munitions Beer Bottled Chemical Agent Recovery/Destruction and Contaminated Soil Decontamination Project, Samukawa, Japan Mr mH designated Project Manager and Safety Control Manager, with responsibility for recovering and destroying approximately 800 of beer bottled chemical agent found underground He also decontaminated soil contaminated by chemical warfare agent developed by Impenal Japanese Army Inspection of Abandoned Chemical Weapons, Wuhan, China Mr l^^^l inspected abandoned chemical weapons in China and conducted sealed packaging for those mvmitions Chemical Weapons Destruction Project, Lake Kussharo, Japan As designated Safety Control Manager for the chemical weapon, Mr monitored the safe and successful destmction of 26 chemical munitions Fertilizer Plant in several foreign countries. Overseas During a posting in Zambia, supported the constmction and operation of a fertilizer plant Also served as Section Chief in Singapore for the constmction of polypropylene plant 32 Employment History 2005-Present CWD Project in Kanda 2001-2005 Kobe Steel, Ltd Nuclear and CWD Business Umts 1968-2000 Kobe Steel, Ltd Industnal Machinery Plant Department (Overseas) 1964-1967 Kobe Steel, Ltd Engineering Department 1961-1963 Kobe Steel, Ltd Industrial Machinery Plant Department (Overseas) 33 DKAWIMlKS)*! :KCIlMSEIITOrKOaESTEEL,LTD. DAVINCH SYSTEM TOEDT SERVICES ess Flow Diagram (1) (Main Process) I DHAinNGKO. PF3400 ICQ DB31 -EAlOl Unit B "[=|unit C2 Unit D [=0 Ventilation -0.1—0.5 inchAq (-2.54~-12.7 mmAq) 1-09630620 DAVINCH SYSTEM TOEDT SERVICES Process Flow Diagrai (Ventilation) PF3400 100 DB31 -EA102 Valve and Attachnnent Synnbol Symbol Name (S) Process Monit orinq Point (Sq) Scmplinq Point _ .--Area_Monitq,rj,na Flexible Tube (FX) \ (Rubber Hose) (HS) j Glove Valve ^(T) Gheck Valve (C) CM Boll Valve (B) w Butterfly Valve (W) Relief Valve (R) Ferrule (FE) Control Valve (FV.TV) ON-OFF Valve (HV) Pressure Reducing Valve (PV) Regulator (RG) S' Y-Type Strain er (SR) Solenoid Valve (SO) Silencer (SL) FC(Srro.''«) FC:Air Fail Glose. Power Fail Glose FO:Air Fail Open. Power Fail Open NC:Air Fail Lock, Power Fail Close 0 Air Intake Filter (AF) a Converter (SC) H Flexible Pipe (FP) Pressure Relie f Damper (PRD) ^ Cupla (CP) ] o Field Indicatio n B Control Room Indication(DCS) e Field Panel Inc ication Inverter Note) Open and close limit switches are applied for each ON—OFF valve. Piping Symbol Exemplar 1"-OG-001-CS1-H3 Piping Size-Fluid Symbol-Serial Number-Piping Class-Insulation Class Fluid Synnbol Symbol Name OG Off-Cos VT Ventilation WW Waste Water DR Drain GO Oxygen CN Nitrogen lA nstrument Air CW(S or R) Cooling Water(S:Service , R:Return) PG Propane Gas IW ndustrial Water CA Cooling Air PA Process Air .Intake Air NOH NaOH Piping Class Symbo Name GS1 ASME B36.10 ,A53 typeF ,A53 Gr.A typeE GS2 ASME B36.10 ,A53 typeF(GLV) ,A53 Gr.A typeE(GLV) GS3 ASME B36.10 ,A53 typeF{GLV) .Galvanized Steel Sheet (Spiral Duct) CS4 ASME 836.10 ,A135 Gr.A GS5 ASME B36.10,A135 Gr.A GS6 ASME B36.10 ,A53 typeF ,A135 Gr.A + Epoxy Lining ANSI 150LB SCH 10 RJ CS7 ASME B36.10 ,A53 typeF ,A135 Gr.A + Epoxy Lninq ANSI 600LB SCH 40 RJ S2 ASME B36.10 ,A312 Gr.TP304 for Oxyqen Une S3 ASMEB36.10,A312Gr.TP316L Insulation Class Symbol Nome HI Thermal Insulation (Below 100 degrees centigrgde) H2 Thermal Insulntion (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 Gl Prevention of Freeze 8 Dew Condensation SP Noise Reduction Design Progress :Hazardous Area • Preparation Container (ClassHDivl) • Preparation Area (ClassIDiv2) • Detonation Containment (ClassIDiv2) • Off-Gas Treatment Area (Class! Div2) DAVINCH SYSTEM TOEDT SERVICES Pipe & Instruments Diagram(1) P&ID Explanatory notes PF3400 100 PB33 -EAOOl strain Monitoring System DESTINY M230 M23' Network Hand Lifter A Dust Capture Recipient Hydraulic Pump Waste Handling Forklift Ml 40 P211 IVI216 Drum Porter M215 DeMign I'rogri-sK Design Progress Design Progress Design Progress Sri I /: DAVINCH SYSTEM TOEDT SERVICES & Instruments Diagram(3) Area 20 Detonation PF3400 100 PB33 -EA003 -|H430 > —m— |R360 A/B > ill.l ™ T Room Ventilation -0.1~-0.5 inctiAq (-2.54—12.7 mmAq) -lUcUy--' HVAC(Reqd¥^l\^Gde M520C I I I I I I I I I I I I I I I I I I I I I I M . I I |llll|ll>l|llll|ll Ill-Sign ['rofirtss Design Progress Design Progress Design Progress IwasaM/u % Ueda X %1 IVd. MitMii ' -0963062U stack S540 DAVINCH SYSTEM TOEDT SERVICES ipe & Instruments Diagram(8; ja 50 Containment & Ventilati PF340()| ipp |l)H:i3 yEAOpS^ MOTOR FOR SUDING DECK HYDRAULIC CYLINDER HYDRAULIC CYLINDER Press: 7MPa 1 L Dia :100mm Press; 3MPa Dia: mm Stroke:500mm : : >0«.,.5.. ;: f/l20 HYDRAUUC CYUNDER HYDRAULIC CYUNDER Dia:IIO-80mm St'ok; ioOu-r ELECTRIcaINSTRUMENT LIST DLL CURTAIN HYDRAULIC POWER UNIT SYMBOL NAME SPECIFICATION Q'TY M01 OIL POMP MOTOR 1 bkw, 4P, AC480/440V60HZ. 1 M02.U03 SUDING DECK MOTOR 1. bkw, i|P, AC480/440V.60HZ.I/120 2 OIL TANK HEATER 2kw, AC480/440V I S0L1~S0L11 SOLENOID VALVE (OIL) DC24V 1 1 ZS01~ZS16 SWITCH (FOR CWMPl' DC24V I 6 ZS17~ZS20 SWITCH (FOR CHAMBER UD) DC24V 4 ZS21~ZS41 SWlTCHfFOR SLIDING DECK) DC24V 2 1 PS01~PS04 OIL PRESS, SWITCH iiciHy 4 3WV01 3-WAY VALVE 1 MG01 MAGNET DClBOV 1 M04 ROLL CURTAIN MOTOR 0. 2kw, 4P, AC480/440V.60HZ.1/40 1 S'OLI 1 SOLENOID VALVE (AIRl DCP4V 1 ZS42~ZS45 SWITCH (FOR ROLL CURTAIN) 4 1-09630620 DRAWING{S] U DAVINCH SYSTEM TOEDT SERVICES ipe & Instruments Diagram(10) Lid And Deck Operation Unit mo. I IBM I DRtWMCNO. i PF3400|ipp |DB33 TEAOIO^ STATEMENT OF HEARING OFFICER FOR PUBLIC HEARING Tooele Chemical Agent Disposal Facility, Utah Public Hearing to Accept Comments On A Class 3 Permit Modification Request To Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 February 16,2011 Tooele County Administrative Building South Auditorium 6 00PM Heanng Officer Tom Ball Ladies and Gentlemen, I call this hearing to order My name is Tom Ball I represent the Utah Solid and Hazardous Waste Control Board and have been appointed by the Executive Secretary of the Board to be the heanng officer for this proceeding This hearing is being held under the authonty of Title 19, Chapter 6, Section 104 of the Utah Code Annotated, 1953 as amended The Tooele Chemical Agent Disposal Facility (or TOCDF) submitted a Class 3 Permit Modification request to install and operate an Explosive Destruction Technology or EDT as a subpart X treatment umt m Area 10 The request proposes to permit an EDT known as the Detonation of Ammunition in a Vacuum Integrated Chamber or DAVINCH The TOCDF proposes to use this unit to treat by detonation several 155mm projectiles and 4 2 inch mortars filled with mustard chemical agent An EDT is being used to treat these munitions because they cannot be managed using the equipment and processes at the TOCDF due to corrosion and degradation of the mumtion bodies In addition to the nearly 340 munitions to be treated, the TOCDF proposes to also treat 47 mustard agent sample contamers These samples were collected from mustard agent munitions stored at the DCD Due to the configuration in which these samples are stored the EDT was determined to be the safest method to treat this waste stream Additionally, during closure activities at the TOCDF a small amount of explosive matenal has been discovered Because the Deactivation Fumace has been shut down this material must be treated by the EDT The unit will be located in Area 10 at the DCD and will be a self contained unit consisting of a detonation chamber and pollution abatement system Area 10 IS adjacent to the TOCDF facility The Executive Secretary of the Utah Solid and Hazardous Waste Control Board has created draft permit conditions and a destruction plan in accordance with the Utah Hazardous Waste Management Rules These proposed language changes to the TOCDF Part B Permit and the destruction plan documents are currently open for review The purpose of this hearing is to receive public comments on the draft permit language and the destruction plan A copy of the Fact Sheet for this modification is available near the entrance of this room Copies of the draft permit language are also available here for public review The notice of this heanng and public comment period was published on January 10, 2011, in the Salt Lake Tribune and the Deseret News Notice was also published m the Tooele Transcript Bulletin Notice of this hearing was also broadcast on KSL radio Additionally, notice of this hearing was mailed to members of the public who in the past have indicated a desire to be notified of such activities The public comment penod for this modification began on January 10,2011, and will conclude February 24,2011 Copies of the draft permit language have been available for examination and public review dunng the comment penod at the office of the Division of Solid and Hazardous Waste located at 195 North 1950 West, Sah Lake City, Utah, and at the Tooele Chemical Stockpile Outreach Office located at 54 South Main Street, Tooele, Utah Opportunity will be provided to any person desiring to participate in this hearing If anyone desires to make an oral comment at this hearing, please indicate on the attendance list These proceedings are being recorded and a transcnpt of the proceedings will be available for public inspection at the offices of the Division of Solid and Hazardous Waste, at the address previously mentioned This IS an administrative heanng and as such there will be no cross examination of any participants Those who have questions or comments to make should state their names and direct their comments to me I ask that you confine your remarks to this modification and limit your remarks to 10 minutes or less Comments that are not pertinent may be ruled out of order It is the policy of the Department of Environmental Quality that this heanng remain in session for at least one hour If, during that hour, there comes a time when there is no one desinng to make a comment or ask a question, the hearing will be recessed At the end of the hour or when there is an indication that someone would like to make a comment, the hearing will be reconvened and the record reopened This heanng will be concluded after all those who desire to make a comment have done so Is there anyone at this time that wishes to make an oral statement for the record"^ COMMENTS - No Comments Were Made Is there anyone (else) wishing to make a statement at this time*^ If there is no one (else) wishing to participate at this time, we will consider this hearing recessed and will reconvene at 6 55 PM to see if others, who might have joined us, wish to participate by makmg a statement RECESS 6 10pm RECONVENE 6 55 PM Ifl could have your attention, I will reconvene this hearing Is there anyone at this time that wishes to make an oral statement for the record*^ COMMENTS - No Comments Were Made If there are no additional comments, this hearing will be considered closed Any additional wntten comments will be accepted until 6 00 p m , February 24, 2011 Written comments may be submitted in person to the Division of Solid and Hazardous Waste, Second Floor of the Multi Agency State Office Buildmg or they may be mailed to Scott T Anderson, Executive Secretary, Utah Solid and Hazardous Waste Control Board, P O Box 144880, Salt Lake City, Utah 84114- 4880 This heanng is adjourned Thank you Adjourned at 6 57 PM, February 16,2011 Tooele Chemical Agent Disposal Facility, Utah Public Hearing on a Class 3 Permit Modification Request To Install and Operate Explosive Destruction Technology Subpart X Unit in Area 10 Tooele County Administrative Building South Auditorium February 16, 2011 6 00 PM NAME MAILING ADDRESS COMMENT (Yes or No) T~'^.. ELhn^J^^ ^OCl^ K0_ 'i.'^c Vct^fti TfcC-k^ Alp V Page J_ of I NO COMMENTS WERE RECEIVED DURING THE PUBLIC COMMENT PERIOD