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HomeMy WebLinkAboutDSHW-2024-005387Amanda Burton DEPARTMENT OF THE AIR FORCE 75TH CIVIL ENGINEER GROUP (AFMC) HILL AIR FORCE BASE UTAH Chief, Environmental Branch 75 CEG/CEIE 7290 Weiner Street, Building 383 Hill Air Force Base UT 84056-5003 Mr. Doug Hansen Department of Environmental Quality Division of Waste Management and Radiation Control P .O. Box 144880 Salt Lake City UT 84114-4880 Dear Mr. Hansen 19 March 2024 As required by Condition 11 .O.2 .a through 11.O.2 .c of the Resource Conservation and Recovery Act Permit for the Utah Test and Training Range (UTTR) (EPA ID UT0570090001), I hereby certify the following for calendar year 2023: -Hill Air Force Base (AFB) and the UTTR have a program in place to reduce the volume and toxicity of hazardous waste that is generated to the degree that it is economically practicable and that the current methods of treatment are the most practicable methods available, which minimize the present and future threat to human health or the environment (11.O.2.a). -Open Burn (OB) and Open Detonation (OD) treatment is the only practicable method or combination of methods currently available to minimize the present and future threat to human health and the environment. Please see the attached 2023 UTTRITTU Alternative Technologies Report for an evaluation and development status of potential alternative technologies (11.O.2 .b). -Hill AFB and the UTTR have a program in place to investigate available technologies, other than OB and OD of energetic wastes, to reduce the volume and toxicity of released treatment residues and discharges (11 .O.2.c). Hill AFB and the UTTR employ a full-time environmental compliance team that evaluates each waste management decision in an effort to reduce the volume and toxicity of generated wastes, as stated above. Both facilities are evaluated on a recurring basis through an environmental management system (EMS) guided by a multidisciplinary cross-function team. The EMS is the primary mechanism by which waste reduction initiatives are tracked. Based on the attached evaluation of alternative technologies, we continue to conclude that OB and OD of large rocket motors and other energetic waste items treated at the UTTR Thermal Treatment Unit (TTU) are the only practicable treatment methods currently available . The attached evaluation, prepared in conjunction with the US Amry Joint Munitions Command, included updates on current demilitarization technologies and planned testing efforts for FY24 andFY25. OB and OD operations at the TTU are conducted in a manner that is designed to completely treat missile motors, leaving minimal residual waste . Clearance operations are conducted to minimize untreated waste residue at the TTU site and soil sampling is conducted to characterize chemical residuals. Permit related corrective action at Solid Waste Management sites within the UTTR and at Military Munitions Response Program (MMRP) sites are also conducted in a manner intended to minimize waste and maximize recycling when deemed sage by Explosive Ordnance Disposal Personnel. I hereby certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Attachment: 2023 UTTR/TTU Alternative Technologies Report Sincerely BURTON .AMANDA .( Dig itally signed by HRISTINE 12700230 BURTON .AMANDA.CHRISTINE.12 • 70023068 68 Date: 2024 .03 .19 12 :11 :29 -06'00' AMANDA C BURTON, NH-III, DAF Chief, Environmental Branch Hill Air Force Base, Utah 2023 Utah Test and Training Range/ Thermal Treatment Unit, Alternative Technologies Report TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS ...................................................................................................... Ill 1.0 PURPOSE ................................................................................................................................ 6 2.0 BACKGROUND ........................................................................................................................ 9 3.0 DEPARTMENT OF DEFENSE DEMILITARIZATION PROGRAM OVERVIEW ....................................... 10 4.0 EXPLOSIVES SAFETY CONSIDERATIONS .................................................................................... 12 5.0 DESCRIPTION OF UTTR'S MUNITIONS WASTE STREAM .............................................................. 14 6.0 ALTERNATIVE TECHNOLOGIES OVERVIEW ................................................................................ 15 7 .0 ALTERNATIVE TECHNOLOGIES EVALUATION ............................................................................. 16 7.1.1 Contained Detonation ............................................................................................ 18 7.1.2 Contained Burning (Subpart 0) Employing Incineration ............................................ 19 7.1.3 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units for Submunitions ................................................................................................... 20 7.1.4 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units forMLRS ................................................................................................................ 20 7.1.5 Contained Burning (Subpart X) -Thermal Treatment Closed Disposal Process .................................................................................................................. 20 7.1.6 Contained Burning (Subpart X) -Static Detonation Chamber ................................... 21 7.1.7 Contained Burning (Subpart X) -Munition Destruction System (MDS) ..................... 22 7.1.8 Contained Burning (Subpart X) Ammonium Perchlorate Rocket Motor Destruction (ARMD) ..................................................................................................... 22 7.1.9 Contained Burning (Subpart X) Thermal Treatment of Bulk Propellant ..................... 22 7.1.10 Contained Burning (Subpart X) DlO0 Controlled Destruction Chamber in Static Burn Configuration ....................................................................................... 23 7.1.11 Decineration .......................................................................................................... 23 7.1.12 Industrial Super Critical Water Oxidation ................................................................ 24 7.1.13 Propellant Reformulation ....................................................................................... 25 7.1.13.1 Blasting Agent Manufacturing Facility, Hawthorne AD ............................................. 25 7.1.13.2 Slurry Explosion Module & Energetics Processing Module, ANMC ............................... 25 7.1.133 Propellant Conversion to Fertilizer .......................................................................... 26 7.1.14 Caustic Hydrolysis of Aluminum-Bodied Munitions .................................................. 26 7.1.15 Cryofracture ........................................................................................................... 26 7.1.16 Mobile Plasma Treatment System .......................................................................... 27 7.1.17 MuniRem ............................................................................................................... 27 7.1.18 High Pressure Water Jet Washout ............................................................................. 27 7.2 EVALUATION OF THE RECOMMENDATIONS IN THE LATEST NASEM REPORT ON ALTERNATIVE TECHNOLOGIES ............................................................................................. 29 8.0 RECOMMENDATIONS ............................................................................................................ 30 9.0 SUMMARY ............................................................................................................................ 32 10.0 SCHEDULE ............................................................................................................................. 34 11.0 REFERENCES ........................................................................................................................... 35 LIST OF TABLES Table 1. Table 2. Initial Screening of Alternate Technologies ........................................................................ 36 Current Waste Streams Treated at the UTTR/TTU ............................................................... 42 ACRONYMS AND ABBREVIATIONS AAP ACWA AMCOM ANMC APE ARMD BGAD CAL CB CD CDC CDT CWP DDESB DoD EWI FY GAO HE HQ JMC JOCG Army Ammunition Plant Assembled Chemical Weapons Alternatives Aviation Missile Command Anniston Munitions Center Army Peculiar Equipment Ammonium Perchlorate Rocket Motor Destruction Blue Grass Army Depot Caliber contained burn contained detonation Controlled Destruction Chamber closed disposal treatment Contained Waste Processors Department of Defense Explosives Safety Board Department of Defense Energetic Waste Incinerator Fiscal Year United States Government Accountability Office High Explosive headquarters Joint Munitions Command Joint Ordnance Commanders Group iii ACRONYMS AND ABBREVIATIONS (CONTINUED) lbs. LEMC MDS MIDAS MLRS mm NASEM NEW OB OD PEO R3 RCRA RDT&E SDC SMCA Tons USEPA UTTR WMM pounds Letterkenny Munitions Center Munitions Destruction System Munition Items Disposition Action System Multi-Launch Rocket System millimeter National Academies of Sciences, Engineering, and Medicine Net Explosive Weight Open Burning Open Detonation Program Executive Office Reclamation, Recycling, and Reuse Resource Conservation and Recovery Act Research, Development, Test and Evaluation Static Detonation Chamber Single Manager for Conventional Ammunition U.S. tons, also known as short tons {2,000 lbs.= 1 short ton) U.S. Environmental Protection Agency Utah Test and Training Range waste military munition iv This page was intentionally left blank. 1.0 PURPOSE The Utah Test and Training Range (UTTR) has conducted an evaluation of alternative technologies to Open Burning (OB) and Open Detonation (OD) in accordance with the requirements of sections I1.O.2.b and 111.L.1.d of the Resource Conservation and Recovery Act Part B Hazardous Waste Operating Permit for the United States Air Force Utah Test and Training Range, issued by the Utah Department of Environmental Quality, Division of Waste Management and Radiation Control (DWMRC) in September 2013. UTTR annually evaluates alternative technologies to OB/OD to include the following: 1. In accordance with permit section I1.O.2.b, a list and analysis of viable alternatives according to technical feasibility, economic feasibility, impact to employee health and safety and whether the alternative will reduce releases and discharges. 2. An evaluation of all the recommendations in the latest National of Academies of Science, Engineering, and Medicine (NASEM) report on Alternative Technologies; and, 3. A proposed implementation schedule for any selected technologies. As further detailed herein, the DoD's Demilitarization Enterprise is committed to the pursuit of alternative technologies and remains committed at all levels to further reducing its necessary reliance on OB/OD. As stated in this report's referenced publications (Section 7, NASEM 2018, and U.S. Environmental Protection Agency [USEPA] 2019), complete elimination of OB/OD is unlikely, given that there are unstable munitions that may not be safe to handle or transport for treatment by alternative technologies. The DoD depends on the use of Open Burning (OB) and Open Detonation (OD) to safely demilitarize, treat, and destroy DoD military munitions generated in support of its national defense mission that have become excess, obsolete, or unserviceable. Although some types of munitions are conducive to treatment through Closed Disposal Technologies (CDTs), not all munitions can be safely demilitarized through these approaches due to the fact that most simply are not scalable to larger munition items containing high quantities of energetic materials such as those found in large rocket motors. This is especially true when considering the increased exposure to personnel from the additional handling, transport, size reduction, energetic removal and overall operational risks that are normally associated with preparing large munition items for treatment through a CDT process. Also, even where closed disposal technologies are proven to be safe,, and fully compatible with munition configuration and site-specific operation environments, permitted OB/OD sites are still often necessary in order to sustain mission requirements when CDT operations fail or must be taken offline for extended periods due to damage to equipment or replacement of components and parts. 6 New CDT approaches that can provide safe and viable alternatives to the disposition of large rocket motor items are continually evaluated by the Department of Army Explosive Demilitarization Technology Program. This program systematically identifies, researches, develops, tests, evaluates, and deploys new technology approaches for safely and sustainably demilling the stockpile of excess and obsolete military munitions. Under this program, and prior to proceeding to any full-scale development of an alternative CDT, a successful development and testing program must be completed and documented to demonstrate optimal protection of personnel from both explosive and human health hazards. This is especially true for large munition items in the stockpile that contain high quantities of energetic materials such as explosives, propellants and pyrotechnic materials. DoD also continues to allocate significant resources toward the collection and characterization of air emissions from open burning and detonation of military munitions. Under this effort, DoD collaborates directly with researchers from EPA's Research Triangle Park using new cutting-edge drone technology and EPA research techniques to sample air emissions from actual live fire Open Burn and Open Detonation events. This empirical information is used to further refine current understandings of actual releases to the environment from operations. This DoD/EPA collaboration has been ongoing for over a decade and represents a cooperative scientific based approach for ensuring continued protection of human health and the environment during OB and OD operations. These DoD/EPA collaborative efforts also involve the development of new test methods for sampling air emissions in the open environment and the formal publication of newly collected emissions data on EPA's official database according to EPA's new procedures and requirements. Decades of such results and operational experience have continued to demonstrate OB/OD as a safe, compliant and effective method for disposing of waste military munitions. In addition to the ongoing research and evaluation of CDT approaches described in this report, beginning in 2017, the National Academies of Sciences, Engineering, and Medicine was tasked to conduct a 12 month study on Alternatives for the Demilitarization of Conventional Munitions. A committee was convened in August 2017 and issued a final report in January 2019. The study focused on: 7 • A review of the current conventional munitions demilitarization stockpile (note that the strategic missile motors treated at UTTR are not considered conventional weapons), including types of munitions and types of materials contaminated with propellants or energetics, and the disposal technologies used. • An analysis of disposal, treatment, and reuse technologies, including technologies currently used by the DoD and emerging technologies used or being developed by private or other governmental agencies, including a comparison of cost, throughput capacity, personnel safety, and environmental impacts. • An identification of munitions types for which alternatives to open burning, open detonation, or non-closed loop incineration/combustion are not used. • An identification and evaluation of any barriers to full-scale deployment of alternatives to open burning, open detonation, or non-closed loop incineration/combustion, and recommendations to overcome such barriers. • An evaluation whether the maturation and deployment of governmental or private technologies currently in research and development would enhance the conventional munitions demilitarization capabilities of the DoD. Although generally not applicable to the large rocket motors treated at the UTTR Thermal Treatment Unit (ITU), many alternative technologies were evaluated in the study, many of which are variations of the technologies discussed below. They also noted that since the mid-1980s, the use of OB/OD as a demilitarization treatment method has declined from an estimated 80 percent to a current average of about 30 percent. The report also highlighted the unique challenges associated with certain munition items within the DoD demil stockpile due to their size, unique configurations, and special chemical formulations. Alternative treatment technologies for large rocket motors (such as the types treated at the UTTR) were not specifically addressed in the study. Additionally, in December 2019, the US Environmental Protection Agency published a similar study to identify and describe alternative treatment technologies that they believed could help further reduce the reliance on OB/OD for treatment of energetic hazardous wastes. And although the treatment of large rocket motors were not directly addressed in the EPA report, it did reference the very unique challenges and limitations associated with alternative technology applications for larger munition items like those routinely treated at UTTR: The applicability of any technology is dependent upon many site-specific or case-specific variables. These include the configuration of the waste material to be treated, the quantity or the NEW, size, portability of the 8 energetic hazardous waste, and the maturity of the technology for a given application. Thus, even though there are many alternative treatment technologies available today, some energetic hazardous wastes (e.g., certain large caliber munitions and missiles) cannot be treated with these technologies. As such, for DoD and possibly others, OB/OD will remain as the only option for certain energetic hazardous wastes until additional viable alternatives are developed or existing technologies are modified or improved upon. In cases where OB/OD remains the only viable option for certain types of munitions or other explosive waste streams, there are a number of regulatory requirements that have been and continue to be implemented to minimize the release, distribution, and impact of emissions from OB/OD. In September 2023, EPA released the Compendium of Alternative Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes. Most waste streams commonly treated at the UTTRmu are not addressed in the alternative technology compendium. 2.0 BACKGROUND Per the RCRA final rule, May 1980, OB of hazardous waste is prohibited except for the burning and detonation of waste explosives. Operating permits for OB and OD of waste energetic materials may be pursued and issued under RCRA Subpart X. Though the RCRA final rule makes the allowance for OB and OD of waste explosives, the rule was promulgated at a time when safe alternatives did not exist for many energetics. The intent (captured in the final background document for the Subpart P interim status standards), was that safe alternatives to OB/OD would be pursued and monitored (USEPA, 2019). Alternative technologies are perceived as more environmentally friendly than OB/OD, when feasible, because they release fewer emissions. This report serves to document UTTR's efforts to pursue identifying safe and reliable alternatives to OB/OD through coordination with the JMC. This report is not intended to replicate readily available information from referenced documents (Section 7 NASEM, 2018 and USEPA, 2019) which include details related to technologies which are not fully developed or not proven safe and reliable at production levels. In an effort to standardize OB/OD technology evaluations across the services, this report is based on an accepted alternative technologies evaluation format that was previously conducted for the Blue Grass Army Depot (Hydrogeologic Inc., 2023). An overview of DoD's demilitarization mission is provided first, in Section 3, to provide a programmatic perspective to enable discussion of the re-evaluation of alternatives. 9 3.0 DEPARTMENT OF DEFENSE DEMILITARIZATION PROGRAM OVERVIEW The DoD has designated the Secretary of the Army as the Single Manager for Conventional Ammunition {SMCA). As the SMCA, the Army is responsible for funding and executing the Do D's conventional ammunitions requirements, including the demilitarization of conventional ammunition for the DoD. While large strategic missile motors are not included as part of the conventional weapons stockpile, the US Air Force defers to the Army as the subject matter experts on development of alternative demil technologies. The SMCA has designated the Joint Program Executive Office {PEO) Armaments and Ammunition, located at Picatinny, New Jersey as the executor of the SMCA's life-cycle management and conventional munitions demilitarization mission, and execution is coordinated between the HQ Joint Munitions Command (JMC) and the Aviation Missile Command {AM COM). The JMC owns seven depots where the conventional munitions stockpile is stored and manages the stockpile of conventional munitions such as bombs, mines, and artillery projectiles (~90% by weight of the demilitarization stockpile). AM COM manages the stockpile of rockets and missiles (~10% by weight of the demilitarization stockpile). The Demilitarization Enterprise utilizes various tools to assign munition types and families to their specific demilitarization capability treatment applications. This assignment begins with a complete physical and chemical characterization of the waste materials requiring treatment. This detailed hazardous waste characterization (completed through the Munition Items Disposition Action System, or MIDAS database) provides the information needed to begin assessing specific materials requiring treatment, which ultimately drives the demilitarization capability approaches that can be considered as feasible from a safety, environmental compliance, and operational sustainment perspective. Of note, there is a new Alternative Technology evaluation tool/template that is currently under development by DoD that will incorporate formal DoD guidance and will ultimately be used by all Demil installations, further enhancing DoD's existing strategic planning tools to ensure that all munition items needing treatment are comprehensively characterized, evaluated and assessed for closed disposal treatment (CDT) using standardized criteria agreed to by EPA and DoD. The JMC's conventional munitions demilitarization mission is executed at the seven depots, as follows: Tooele Army Depot, Utah; Hawthorne Army Depot, Nevada; Anniston Munitions Center {ANMC), Alabama; Crane Army Ammunition Activity, Indiana; Letterkenny Munitions Center {LEMC), Pennsylvania; and McAlester Army Ammunition Plant {AAP), Oklahoma; and Blue Grass Army Depot (BGAD). Commercial industrial resources such as the explosives destruction facilities currently operated by General Dynamics-Ordnance & Tactical Systems in Missouri and EXPAL Conventional Ammunition Demilitarization in Louisiana also conduct the demilitarization mission. 10 Ammunition products are transferred to the demilitarization stockpile (also known as the BSA account) when they are declared excess, obsolete, unserviceable, or defective by the military Services' Item Managers. Alternatives considered before deciding for demilitarization include (1) use of the items to support training/testing, (2) offer of munitions from one DoD Service to another, (3) offer to other government agencies, (4) foreign military sales, and (5) free transfer to foreign militaries. The munitions are treated at one of the stockpile sites, whether by OB/OD or by an alternative technology or may be shipped to a commercial industrial disposal facility for treatment via alternative technology. The Demil Enterprise incorporates life cycle management practices by pre-positioning demilitarization assets, in as much is feasible. That is, BSA account assets are preferentially stored at locations where they may ultimately be recycled or disposed, where feasible, given the availability of storage capacity. For example, because ANMC operates alternative technologies specific to disposition of the Multiple Launch Rocket System (MLRS), these BSA munitions types are stored, in as much as is feasible, at that location. The Army estimates that the use of OB/OD as demilitarization treatment methods has declined from an estimated 80 percent of demilitarized munitions in the mid-1980s to an average of about 30% in recent years. This drastic reduction in OB/OD is attributed to both increased use of munitions disassembly, enabling the recovery and reuse of energetics and components and use of closed disposal treatment (CDT) where feasible for the munitions. In this regard, diversions away from OB/OD through incorporating additional munitions disassembly steps and enabling recovery/re-use possibilities are to be considered as "alt-techs" as well. Large strategic missile motors treated at the UTTR are not included in the conventional munitions stockpile (BSA account) that is discussed above and are not managed by the Army. Trident motors used in submarine launched intercontinental ballistic missiles (ICBMs) are owned by the US Navy and managed at the UTTR via direct contract with the US Air Force and the motor manufacturer, Northrop Grumman Innovation Systems. Motors from the Minuteman ICBM system are owned and managed directly by the Air Force. 11 4.0 EXPLOSIVES SAFETY CONSIDERATIONS Even as DoD reduces and continues to explore ways to minimize its reliance on OB/OD, the EPA recognizes that there will always be the requirement to use OB/OD methods as the safest options for demilitarizing certain munitions and from the standpoint of protection of the DoD assets, operations personnel, and the general public. DoD is committed to maintaining only mission essential OB/OD units and using CDT when safe and technologically feasible. The use of CDT can expose DoD personnel to an increased risk to the explosive hazards associated with munitions compared to demilitarization by OB or OD. DoD has procured and employs those CDT technologies that meet its requirements safely and effectively. However, numerous military munitions cannot be processed through existing CDT systems due to the extreme forces and pressures generated when demilitarized. CDT systems are generally more appropriate for inventoried stockpiles of homogeneous un-degraded energetic materials than for stressed materials. While potentially applicable to smaller munitions that can be isolated for risk management, the size of ICBM missile motors (up to 84,000 lbs per motor) present unique safety challenges with regard to the use of CDT technologies because of the inherent risk of a catastrophic detonation or fire. While munitions demilitarization by any means requires that munitions be handled, moved, and prepared, alternative technologies generally require more processing prior to energetics destruction. In general, as the number and complexity of processing steps increases, the potential for accidental detonations, deflagrations, and fires also increases. The NASEM report (NASEM, 2018) identifies a number of incidents that have occurred during OB/OD and alternative technology operations since 2004. A majority of the incidents involved workers performing preparation activities. Fewer incidents occurred during OB/OD operations than during contained disposal technology operations and Research, Development, Test and Evaluation (RDT&E) activities. While alternative demilitarization technologies that involve more manual operations and preparation than OB/OD are likely to pose greater safety risks, the NASEM report finds that the Army and its contractors have developed safety procedures for current operations and safety procedures are assumed to be developed for future alternative technologies and that practices are considered generally safe for workers (NASEM, 2018). The committee found in its review, that the Army safety program appears effective and the current safety approvals required by the Department of Defense Explosives Safety Board (DD ESB) are "adequate to minimize explosive accidents and injuries." The committee recognized the crucial role of the DDESB in ensuring adequate protective measures for workers and the surrounding area and thus that DDESB approved alternative technologies (when operated in accordance with approved site plans) meet personnel safety requirements. Some alternative technologies incorporate automated processes which may pose reduced risks as compared with OB/OD. 12 The OB/OD demilitarization operations at UTTR are currently deemed mission essential. The UTTR conducts OB/OD operations in accordance with extensive and stringent controls and safety measures to protect DoD personnel, the public, surrounding communities and the environment. Requirements for routine inspection, controls, and restrictions are detailed in UTTR's hazardous waste operating permit. Furthermore, the treatment capacity of these permitted units {30,000,000 lbs. NEW for OB and 6,552,000 lbs. for OD) has been demonstrated through human and ecological risk assessment per the rigorous USE PA risk assessment process. The results of these risk assessments demonstrate that the UTTR OB and OD units can be operated in a manner that does not pose unacceptable risk to human health and the environment. The risk assessments conservatively evaluated the potential future risks to human and ecological receptors from continued operations using reasonable maximum estimates of exposure, USE PA-approved models, and USE PA protocols. The results of the Human Health Risk Assessment and Screening Level Ecological Risk Assessment are reported in Attachment 10A and 10 B of the UTTR RCRA Subpart X permit application (UTTR, 2023). To safeguard personnel charged with handling and disposal of WMM UTTR implements the cardinal rule of explosives safety by exposing the minimum number of people to the minimum amount of explosive for the minimum amount of time. The OB/OD treatment process minimizes exposure of personnel to potential hazards and the destruction method is recommended by DoD explosives safety policy. Safe operation is the key critical factor when evaluating a particular technology for use within the Demi I Enterprise. Any alternative technology selected for use must obtain DD ESB approval, must be operated within the safety limitations established within the DDESB-issued Explosives Site Plan, and must reliably operate at production levels while maintaining a safe readiness status. In addition, systems must be situated in a location where explosives safety Quantity- Distance (QD) arcs can be maintained. QD arcs are established by the DoD under 4145.26M, "Contractor's Safety Manual for Ammunition and Explosives," as the primary means of mitigating damage to surrounding equipment and structures. A QD arc delineates the area around an operation likely to be affected by the destructive force of an uncontained explosion. 13 5.0 DESCRIPTION OF UTTR'S MUNITIONS WASTE STREAMS The UTTR potential munitions waste stream is described in its RCRA Part B Subpart X Permit, Attachment 2, Waste Analysis Plan. This information is not duplicated here. UTTR's munitions waste streams over the past two decades, and the foreseeable future, consist of excess, obsolete or unserviceable large rocket motors, scrap propellant, and bulk propellant. In accordance with section 11.D.1.a. of the UTTR Hazardous Waste Operating Permit an annual report of the current waste streams that are treated at the UTTRmu, including the annual amount of each waste treated, is submitted to the State of Utah by March 1 of each calendar year (Jacobs, 2024). The current waste streams that are treated at the UTTR/TTU are summarized in Table 2 along with typical item or treatment batch weights and the hazard class (HC) and description as categorized in the characterization report. Table 2 also includes a list of potential alternative technologies for each waste stream as well as a discussion of the limiting factors for those alternative technologies as applied to each waste stream. 14 6.0 ALTERNATIVE TECHNOLOGIES OVERVIEW Current alternative demilitarization methods can be grouped into the following categories: • Explosives removal • Disassembly • Cutting and resizing • Reclamation, Recycling, and Reuse {R3) • Contained burn {CB) including Incineration • Contained detonation {CD) • Contained treatment using methods other than combustion Of these, the first three serve as preparatory or pretreatment technologies prior to energetic destruction or R3 and do not serve in lieu of OB/OD. Examples of energetic removal technologies include: • Autoclave Melt-out of high explosives-following process to provide for an opening in munition body, munitions item is placed into an autoclave where heat/steam are introduced to melt cast explosives out of the munitions body. • Hot-Water and/or High-Pressure Washout of high explosives -following process to provide for an opening in munitions body, hot water and high pressure are introduced to wash explosives fillers or propellant out of the munitions body. Examples of disassembly/cutting/resizing include: • Waterjet, slurry jet, or mechanical cutting-used to cut through munitions bodies and explosives, as appropriate, to provide access to energetic fillers or reduce size. • Manual and automated disassembly-used in munitions-specific configurations to disassemble munitions components. • Cryofracture-used to cool ferrous munitions below their embrittlement temperature, allowing the munitions to be fractured in a hydraulic press. • Ultrasonic Fragmentation -directed ultrasonic used to fragment, remove, and separate energetic fillers from munitions bodies. This technology resulted in an accidental detonation and is no longer being pursued from a demilitarization perspective. Disassembly, cutting, and/or resizing may be required to reduce munitions to a physical size or energetic weight to meet the size/weight limits of alternative energetic treatment technologies. These are not treatment or disposal technologies, nor are they alternatives to OB/OD; therefore, they are not further addressed in this evaluation. Explosives removal and disassembly allow for increased R3 opportunities. R3 is a significant source of return to the DoD, primarily through cost savings of reusable components and scrap metal recycling sales 15 following disassembly. Not all munitions items in the demilitarization inventory lend themselves to disassembly, however. Life cycle management principles now in place in the munitions manufacturing industry were not always present, resulting in munitions items without pre- planned strategies for final disposition. The Demilitarization Enterprise has explored numerous technologies to address complete demilitarization of munitions items. In most cases, a munitions item must be subjected to a variety of processes to provide complete demilitarization including methods to disassemble the item and remove components and energetic fillers. Once disassembled, recovered metal components typically can be recycled. Some energetic fillers can be processed for reuse/reclamation while others must be treated/disposed. Although a variety of technologies have been evaluated to recycle energetic fillers into commercially usable products, very few have proven safe, effective, and reliable. While the NASEM report discusses preparatory technologies used for explosives removal, disassembly, cutting and recycling, the focus of this report is to evaluate alternative technologies that can be used in lieu of OB/OD. UTTR's 2022 alternative technologies evaluation submittal, the NASEM report (NASEM, 2018), and the USEPA follow-on report (USEPA, 2019) can be referenced for information on preparatory technologies. Alternative technologies generally involve some type of contained destruction of the energetic materials, including CB or CD as well as contained methods using treatment other than combustion or detonation. Emissions from CB and CD operations are captured, and gaseous emissions are treated in pollution abatement systems. 7.0 ALTERNATIVE TECHNOLOGIES EVALUATION Alternative technologies evaluated for potential use at UTTR are described in Sections 7.1.1 through 7.1.18 below. Many of the technologies described continue to be included in this assessment only because they were included in previous alternative technology evaluations. Several of the technologies included in this evaluation were never proven or demonstrated and therefore continue to be rejected during annual reassessment. For this iteration of re-assessment, the technology evaluation process was as follows: 16 1. Initial Screening: Alternative technologies identified through research and consultation with the Command were first screened for "availability" and "applicability." Alternative technologies deemed "available" are technologies that are being used, are being considered, or are scheduled to be implemented at other DoD demilitarization installations, or commercial assets available to the Demil Enterprise. To be considered "applicable" in the context of this report, technologies must be capable of and approved by DD ESB to treat/dispose UTTR potential munitions waste streams. To be considered "available" in the context of this report, technologies must achieve a minimal rating of 8 when employing the U.S. Government developed Technology Readiness Level (TRL) (GAO, 2016) scale that is used to measure the maturity of a technology or product. The scale ranges from 1 to 9, with lower ranking assigned to less developed, or lower-maturity level technologies. The rating scale is elaborated below, and ratings are included for the technologies listed in Table 1. Technology Readiness Level (United States Government Accountability Office [GAO], Technology Readiness Assessment Guide, August 2016) 1 Lowest level of technology readiness. Scientific research begins to be translated into applied research and development. Examples include pater studies of technology's basis properties. 2 Invention begins. Once basic principles are observed, practical applications can be invented. Applications are speculative, and there may be no proof or detailed analysis to support the assumptions. Examples are limited to analytical studies. 3 Active research and development are initiated. This includes analytical studies and laboratory studies to physically validate the analytical predictions of separate elements of the technology. Examples include components that are not yet integrated or representative. 4 Basic technological components are integrated to establish that they will work together. This is relatively low fidelity compared with the eventual system. Examples include integration of ad hoc hardware in the laboratory. 5 Fidelity of breadboard technology increases significantly. The basic technological components are integrated with reasonably realistic supporting elements, so they can be tested in a simulated environment. Examples include high fidelity laboratory integration of components. 6 Representative model or prototype system, which is well beyond that of TRL 5, is tested in its relevant environment. Represents a major step up in a technology's demonstrated readiness. Examples include testing a prototype in a high-fidelity laboratory environment or in a simulated operational environment. 7 Prototype near or at planned operational system. Represents a major step up from TRL 6 by requirement demonstration of an actual system prototype in an operational environment {e.g., in an aircraft, a vehicle, or space). 8 Technology has been proven to work in its final form and under expected conditions. In almost all cases, this TL represents the end of the true system development. Examples include development test and evaluation of the system in its intended weapon system to determine if it meets design specifications. 9 Actual application of the technology in its final form and under mission conditions, such as those encountered in operation test and evaluation. Examples include using the system under operational mission capabilities. 17 2. Assessment: Alternativetechnologies not rejected during the initial screening were then evaluated based first on whether the technology already resides within the Demi I Enterprise such that diversion to an alternate facility would be preferred versus procurement of the technology for use at UTTR and second, other extenuating factors that are noted. 7.1.1 Contained Detonation Contained Detonation {CD) chambers are a technological alternative to the OD of munitions and munition components. These technologies and their associated pollution abatement equipment are intended to demilitarize an entire cased munition item (that would otherwise be subjected to OD) in a single processing step if the munition size and NEW are within the capacity of the equipment. Otherwise, one or more preprocessing steps will be required. Because they do not use a "controlled flame device," CD systems are permitted as RCRA Subpart X miscellaneous treatment units rather than as incinerators (NASEM, 2019). Munitions are prepared for detonation by attaching detonators and donor explosives and then placing in the chamber; the chamber is sealed; and the munitions are detonated. All of the explosive wastes such as off gases, dust, and metal fragments are contained within the chamber or a post-chamber expansion vessel following the detonation. Treated waste material can be tested, and if need be, unreacted energetics can be reprocessed prior to release. Although conceptually feasible as a replacement for OD, these chambers have several limitations, including (1) limited throughput resulting from the need to prepare munitions, load them into the chambers, and periodically clean debris following detonations; (2) the need to withstand repeated shocks resulting from detonations with consequent wear and tear on the pressure vessels; and (3) the donor charge being included in the maximum NEW allowed per load {NASEM, 2019). Variations of CD systems have been employed within the DoD for conventional and chemical munitions destruction. Variations include the "Donavan" Controlled Destruction Chamber {CDC) commercially manufactured by the Donovan company, one of which {Dl00) is currently in place at BGAD and permitted in both a detonation and burn configuration, the Explosive Destruction System (EDS) designed by the Army's Recovered Chemical Munitions Directorate and built by Sandia National Laboratory, and the Detonation of Ammunition in a Vacuum Integrated Chamber {DAVI NCH) commercially manufactured by Kobe Steel. These three variations operate in similar fashion and have been constructed in various sizes to accommodate smaller and larger detonations. Transportable models of each have also been constructed. All three variations have been thoroughly described in literature and BGAD's RCRA Subpart X permit application provides detailed information pertaining to the construction and operation of the Dl00 CDC. These three models were all included in an evaluation by DoD for use at BGAD and Pueblo for chemical munitions destruction and are thoroughly described at the following link: 18 https://www.peoacwa.army.mil/wp- content/uploads/nrc report assessment explosive destruction technologies 9march09.pdf. All three models are additionally described in the NASEM 2019 report on Alternatives for the Demilitarization of Conventional Munitions which is available for download from the NASEM website at: https://nap.nationalacademies.org/download/25140 7.1.2 Contained Burning (Subpart O) Employing Incineration Explosive waste incinerators (i.e., thermal destruction in an enclosed device using controlled flame combustion) are available for thermal destruction of bulk energetic waste that would otherwise be subjected to OB and also for very low net explosive weight (NEW) items that pose the potential to detonate but not damage the equipment (e.g., small arms ammunition). For bulk energetic waste (e.g., uncased propellant), such incinerators typically use a grinder to reduce the waste to an appropriate size and/or a slurry-based process to feed energetic waste into the incinerator. Some energetic waste material cannot be disposed of through incineration because it is incompatible with the grinding or incineration process used . Examples of energetic material incompatible with the incineration process are water reactives, rubbery material that is not grindable, and overly sensitive or unstable energetic material. Fluidized bed incineration has also been demonstrated for use with propellants and explosives . Fluidized bed technology uses the thermal capacity of hot fluidizing sand to provide uniform incineration. Research performed in support of this alternative's technology evaluation found no evidence of current use of fluidized bed incineration for production demilitarization at any location . A rotary kiln incinerator/rotary kiln deactivation furnace is an incineration technology in use by the Army and also available in commercial designs. In fact, the Army's own version, the APE (Army Peculiar Equipment) 1236 Deactivation Furnace (a rotary kiln incinerator with a thick- walled combustion chamber), was previously in operation at BGAD, but was mothballed when the unit was not selected for air pollution control upgrades required to meet air standards. Explosive waste incinerators are in use within the Army and at commercial facilities . For example, an incinerator is present at Picattiny Arsenal, New Jersey . Two incinerators for the purpose of disposing of reactive waste are located at the commercial facility operated by General Dynamics Ordnance and Tactical Systems Munitions Services in Joplin, Missouri. One rotary kiln incinerator (main incinerator) is designed for the sole purpose of treating explosive devices, including configured munitions and bulk explosives. A car bottom furnace incinerator is used occasionally to treat large, unusual, or irregular shaped metal pieces and energetic- contaminated solid wastes. Each incinerator has its own waste feeding system; however, exhaust gases from both incinerators are pulled into a shared secondary combustion chamber and air pollution control system . Hawthorne Army Depot operates the Bulk Energetics Demilitarization System (BEDS). The HWAD BEDS plant consists of bulk slurry feed and handling systems followed by rotary kiln, combustion chamber, air pollution control equipment, and plant support systems for the destruction of propellant. 19 7.1.3 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units for Submunitions Submunitions demilitarization has been a focus area for the Enterprise because of international treaty compliance obligations. In 2009, the State of Missouri issued a Class 3 Permit Modification to General Dynamics Ordnance and Tactical Systems Munitions Services (Joplin, Missouri) to allow for the installation of eight Subpart X Miscellaneous Treatment Units (four treatment chambers and two pairs of static kilns), specifically for demilitarization and treatment of M42/M46/M77 submunitions (grenade bodies and fuzes) from Class 1.1 D military munitions. The Static Kiln units consist of an electrically heated, vertically arranged burn chamber into which munition components are fed and ignite upon proper heating. The treatment chambers (or Thermal Treatment Units) consist of a burn chamber and pilot/ignition flame used to ignite the explosives in the submunition or munition component. The process comprises four demilitarization lines able to process up to 500 pounds per hour per line. One air pollution control system pulls exhaust gases from the static kilns and two additional systems pull the exhaust gases from the chambers. 7.1.4 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units for MLRS In addition to submunitions treatment units, Missouri additionally permitted the General Dynamics Ordnance and Tactical Systems Munitions Services (Joplin, Missouri) to install four Subpart X Miscellaneous Treatment Units, specifically for the demilitarization and treatment by enclosed burning of HC 1.3 D MLRS rocket motors. The process comprises two demilitarization lines that are able to process up to 1,005 pounds per hour per line. Two rocket motor saws cut the rocket motors into 8 to 10 segments. The segments are fed into one of two thermal treatment chambers where they are ignited and allowed to burn. One air pollution control system pulls the exhaust gases from the chambers. Rocket motors of various sizes that are HC 1.3 explosives are a potential component of the UTTR munitions waste stream. Typical HC 1.3 motors treated at UTTR range from approximately 4,000 pounds to 50,000 pounds gross weight. Enclosed thermal treatment (i.e., burning) employing ignition other than controlled flame combustion is a demonstrated technology for HC 1.3 rocket motors. The limiting factors for the technology are primarily the size of the rocket motor (not all rocket motors are amenable to resizing), associated heat produced during treatment, and the propellant composition, which dictates air emissions control requirements. Rocket motors that are HC 1.2 pose the potential to detonate and therefore are not typically amenable to enclosed burning unless the rocket motor propellant can be safely extracted from the rocket motor casing. 7.1.5 Contained Burning (Subpart X)-Thermal Treatment Closed Disposal Process In addition to OB/OD waste treatment, ANMC also operates facilities for recycling of specific munitions items. Of note is the Missile Recycling Center (MRC). The MRC provides for recycling of tactical missiles (previously the tube-launched, optically tracked, wire-guided missile and currently the MLRS). The recycling process for the tube launched optically tracked wire guided missile (TOW) consisted of removal of the missile from its fiberglass 20 launch tube and further rendering down of the components including warheads, coupling assemblies, batteries, flight motors, propellants, explosives, copper lining and copper wiring. Non-recyclable, reusable components such as the waste propellants and explosives were disposed of by OB/OD/BD. To further facilitate the current MLRS recycling process, a Thermal Treatment Closed Disposal Process {TTCDP) is planned at ANMC specifically for disposal of M77 submunitions and fuzes downloaded from the M LRS. The TTCDP will have two separate thermal treatment processes for (1) treatment of energetics contained within fuze-less M77 grenade bodies and their copper cones, and (2) treatment of energetics contained within M77 fuze-assemblies. The TTCDP will be comprised of three major component systems: (1) a tunnel furnace, (2) a Munitions Destruction System {MDS), and (3) an off-gas treatment system. Movement of grenade components within the TTCDP will be provided by remotely operated conveyors. The TTCDP will be operated and monitored remotely from the TTCDP human-machine interface located in an onsite control room. The nominal process design capacity for the TTCDP is planned at 2,880 grenades per hour. Within the tunnel furnace, ignition will be accomplished by an electrically heated coil that is moved into the grenade and touches the Comp AS surface area. After ignition, the igniter will be moved away from the burning grenade into its home position. The copper cones will be decontaminated by the hot flame of the burning Comp AS of the grenade underneath. Dynasafe's MDS is an indirectly heated destruction system originally designed for small arms ammunition that will be used to thermally treat the fuzes. The MDS is constructed of rugged, welded steel with three major sub-components: the feed hopper, the detonation chamber, and the dropout flap. The detonation chamber consists of a kiln case with internal fragmentation protection and venting, external lateral bearing construction, and integrated electric heating that is fully insulated. 7.1.6 Contained Burning (Subpart X)-Static Detonation Chamber The SDC unit is currently in operation at the Anniston facility for conventional munitions, post chemical demilitarization operations. The similar design has also been constructed at BGAD in support of the chemical demilitarization program based on Dynasafe's SDC technology. This technology uses indirect heating to destroy munitions and munitions components. Destruction is achieved by heating the energetic material above its auto initiation temperature which results in burning of the energetic material, deflagration, or detonation. The size, shape, confinement, and type of explosives determine the type of reaction. The most common reaction is burning and deflagration. The process also generates a significant amount of off-gas that is transferred to an off-gas treatment system. The SDC process is remotely controlled thereby minimizing material handling. The SDC is not currently in use for production level munitions disposal. The SDCunitattheAnniston facility is designed to accept a maximum gross weight of upto 330 pounds including the feed tray. The explosive capacities for the SDC unit are: • Up to 2.2 pounds of mass detonating material (TNT equivalent, NEW, such as confined Class 1.1 material) per feed cycle • Up to 6. 7 pounds of non-mass detonating material {TNT equivalent, NEW) per feed cycle 21 For the purposes of destruction in the SDC, most Class 1.1 materials that are not confined and Class 1.2 and Class 1.3 materials confined or unconfined are considered non-mass-detonating as they typically deflagrate in the SDC. Exceptions are the primary Class 1.1 explosives, which always mass detonate whether confined or not. The NEW of a munition represents the combined explosive weight of all energetics contained in a munition item or items. 7.1.7 Contained Burning (Subpart X)-Munition Destruction System (MDS) The MDS or small "popping furnace" is off-the-shelf technology that has been successfully demonstrated for small NEW candidate munitions items both internationally and within the Demilitarization Enterprise at ANMC to support their M77 submunition demilitarization process. The system uses high temperatures to detonate small NEW 1.1 HE fuzes and components while collecting emissions through pollution abatement. The MDS is not too unlike the APE 1236 Rotary Kiln just on a much smaller scale and throughput. Its throughput limitations limit its practical application for full scale demilitarization but could serve as an alternative for use when only small quantities of small NEW munitions items (such as what may recovered during routine Depot operations) are generated. 7.1.8 Contained Burning (Subpart X) Ammonium Perchlorate Rocket Motor Destruction (ARMD) The ARMD chamber, constructed, permitted, and operating at LEMC, was specifically designed to dispose of Ammonium Perchlorate (AP)-based rocket motors, such as Multiple Launch Rocket System (MLRS) and Sidewinder rocket motors. The process involves enclosed firing of the rocket into a chamber, processing the combustion gasses through a pollution abatement system, and subsequent disposal of the combustion solids and brine materials. The 18-foot by 118-foot chamber is constructed of 1-inch armored steel on a concrete pad. A rocket motor is ignited in the chamber with the gases captured and scrubbed. The ARMD is designed to process a wide range of rocket motors of various sizes. The ARMD can process intact rocket motors up to a NEW of 680 lbs. of propellant or segments up to 805 NEW of propellant. The ARMD is designed to process approximately 23 different rocket motor variants from the Army, Navy, and Air Force. 7.1.9 Contained Burning (Subpart X) Thermal Treatment of Bulk Propellant Enclosed thermal destruction by burning, utilizing ignition other than controlled flame, is a technology recently installed and used at Camp Minden, Louisiana for the destruction of deteriorated and unstable, uncased propellant. The unit installed at Camp Minden was designed by El Dorado Engineering, Salt Lake City, Utah, and provides for a batch feed system and air pollution control system. El Dorado Engineering offers various designs that are scalable and may accommodate either batch or continuous feed systems. 22 Deteriorated, uncased propellant comprises a small portion of the UTTR waste stream. An enclosed treatment system that includes minimal handling of propellant (i.e., eliminates the need for downsizing, grinding, preparation of slurries) and thus providing for a safe alternative for deteriorated or unstable propellant is a potential option. 7.1.10 Contained Burning (Subpart X) D100 Controlled Destruction Chamber in Static Burn Configuration The Dl00 CDC at BGAD was reconfigured for static burning of rocket motors (without warheads) in advance of a Treatability Study completed in January 2016 to demonstrate the use of the Dl00 for destruction of M67 rocket motors. Specifically, modifications included the installation of a firing stand for securing up to six rocket motors and a heat shield to protect the interior walls of the CDC from direct jet impingement. The existing single ignition system also was replaced with a temporary system capable of sequential firing. Following the conduct of the 2016 Treatability Study and second Treatability Study performed to demonstrate the system for destruction of 2.75-inch rockets, the DDESB approved the use of the Dl00 CDC for static firing of the demonstrated rocket motors with the following limits: M67, 4 rocket motors per cycle; J165, 3 rocket motors per cycle; and 2.75-inch Mk40 MOD 3, 6 rocket motors per cycle. Note that the CDC (Donovan Chamber) has not, at any location, been demonstrated as a safe or reliable technology for the destruction of bulk propellant. 7.1.11 Decineration The Decineration process, developed by U.S. Demil LLC, uses a horizontally mounted rotary kiln to demilitarize small arms ammunition and munitions such as mines, canisters, and fuzes. It differs from the APE 1236 and other kiln-based incineration technologies in that there is not a burner at the discharge end; instead, heat is applied externally to the kiln to decompose long molecular chain energetics such as nitrocellulose and nitramines into shorter chain light hydrocarbons by fracturing carbon-carbon, carbon-nitrogen, and other bonds. The decomposition takes place at temperatures of 450 -750 degrees Fahrenheit without contact between the material being processed and the external heating source. Following treatment in the kiln, particulates are removed via a multi-stage wet scrubber, an induced draft fan, and an electrically initiated catalytic converter. Candidate munitions items tested include small NEW items such as 20mm and 40mm cartridges, primers, blasting caps, and other small munitions. U.S. Demil Decineration technology has undergone two large scale RDT&E tests but has not transitioned out of RDT&E and there are no current plans for further testing. Decineration is considered to be a nonincineration process. The state of Indiana considers the system to be a materials-recovery process not requiring a RCRA permit while Utah considers it to be Subpart X. 23 7.1.12 Industrial Super Critical Water Oxidation (iSCWO) The iSCWO system was previously evaluated by BGAD to reduce the dependency on OB. General Atomics is the systems contractor for the design, manufacturing, and implementation of the iSCWO system. SCWO takes advantage of the unique properties exhibited by water when used above its critical point, 705°F and 3210 pounds per square inch. The organic content of the waste feed is converted to carbon dioxide (CO2), water {H20), and salts with negligible production of carbon monoxide (CO), nitrogen oxide (NOx), or sulfur oxide (SOx). Feed is prepared for the iSCWO in a slurry-grind system, which mixes the solids with water while reducing the particle size prior to injection into the iSCWO system. The 10 gallons per minute iSCWO was proposed to process 1240 pounds per hour of typical propellant. This water slurry is oxidized in the iSCWO by reaction with injected air at high pressure (greater than 3200 pounds per square inch gauge [psig]) and temperature (greater than 1200°F). The reactor products (primarily liquid water) are condensed and filtered through a heavy metal removal system before release to the onsite wastewater treatment facility. This system includes a combination of filters and ion-exchange beds to remove particulate matter and suspended/dissolved metals. Non-condensables, including nitrogen {N2), oxygen (02), CO2, and water vapor are routed to a discharge vent that includes a continuous CO monitor to verify efficient oxidation of the wastes. The iSCWO system, though designed to treat a broader spectrum of propellant types and categories, has not been proven forth is use at a production level suitable for the Demilitarization Enterprise. A RCRA Subpart X permit application for this unit was submitted to KDEP's DWM in July 2007. BGAD and the DWM held several progress update meetings and discussions since the first application submittal. Unfortunately, deficiencies identified by KDEP could not be resolved within a suitable timeframe and funding for the iSCWO was lost. Deficiencies focused on the inability to provide detailed component and emission information for the system as the system was still in a design phase. As the contractor was unable to provide the requested information, BGAD subsequently withdrew its permit application for the iSCWO unit. Based on literature search, the iSCWO has been used to process TNT-contaminated wastewater from a TNT melt-out operation. However, the requirement for a liquid feed and the high cost of operation limited the suitability of the process to very specific items that were able to be safely converted and managed in a slurry. The intended use at BGAD was to ultimately treat bulk propellants. This would have required that the propellant first be size reduced through a grinding operation and then mixed with water before being introduced to the system. This not only increases operations safety risks (grinding of propellants), but also increases the volume of waste to be produced (addition of water). The technology introduces significant operability challenges including safety, maintainability, and reliability issues due to the extreme high temperatures and pressures required for its operations. The Blue Grass Chemical Agent- Destruction Pilot Plant {BGCAPP) SCWO intended for use in the chemical demilitarization program was found to be similarly unreliable. The system did not function as designed and was eventually withdrawn from the permit thereby losing the Research, Development, & Demonstration {RD&D) provisions of the RCRA permit. KDEP then issued a permit modification for a full RCRA Part B permit to ship the hydrolysate off-site, rather than neutralization followed 24 by SCWO, which was the original plan and basis for the RD&D permit. At the BGCAPP community stakeholder quarterly meeting held on September 6, 2023, a briefing on the SCWO update was provided to the group. It was mentioned that "no government or private organizations followed through with a commitment to take the SCWO." The BGCAPP SCWO will not be incorporated into the Demil Enterprises toolbox of alternative technologies. 7.1.13 Propellant Reformulation Several processes have been studied to effectively reformulate military grade propellant for commercial uses such as commercial explosives and fertilizer. Of note is that only specific military energetic formulations could potentially result in effective, efficient, and safe commercial explosives formulations. Unfortunately, the commercial value of reprocessed military propellants and explosives has failed to generate commercial interest. Facilities such as the Blasting Agent Manufacturing (BAM) facility at Hawthorne Army Deport, and the Slurry Explosion Module (SEM) and Energetics Processing Module (EPM) facilities at ANMC further described below, have been shelved until such time that economic value can be derived. 7.1.13.1 BlastingAgent Manufacturing (BAM) Facility, Hawthorne Army Depot The Hawthorne Army Depot in west central Nevada was selected for the demonstration of production-level capability to produce blasting agents for the mining industry from high content (i.e., greater than 60 percent) large grain gun propellants. The blasting agent was intended to compete with, complement, and/or supplement Ammonium Nitrate Fuel Oil formulations with higher detonation velocity, higher relative bulk strength, and water resistance. The BAM process at Hawthorne Army Depot is not currently in operation. The process was completed, and the final safety review and hazards analysis performed. It was during this final review that it was determined that there was an unacceptable risk associated with the potential loss of propellant lot identity that could result when mixing different propellants into the various blasting agent slurry formulations. This risk, along with the problems associated with the fluctuations of the blasting agent mining markets (and subsequent risks arising from the need to stockpile downloaded propellant and the associated potential for speculative accumulation violations), led to the abandoning of the BAM process in 2010. Currently there are no plans to pursue the BAM process as an alternative to OB at Hawthorne Army Depot. 7.1.13.2 Slurry Explosion Module (SEM) and Energetics Processing Module (EPM), ANMC Two major planned modules to the Missile Recycling Center at ANMC included the SEM and EPM. The function of the SEM was to take the various grades of propellants retrieved from the defunct missiles and mix them together for commercial purposes. The EPM was to involve the same process, but with the different types of explosives used in the missiles. Primary limitations to SEM/EPM as an alternative to OB are capacity and formulations; therefore, the SEM and EPM modules have been shelved. 25 7.1.13.3 Propellant Conversion to Fertilizer (PCF) This process involves chemically converting excess gun propellant into fertilizer using a proprietary reagent. Water-wet propellant is reacted with 3 percent humic acid in aqueous solution and potassium hydroxide to denitratethe propellant. After denitration, nitrate and nitrite are incorporated into the humic acid molecular matrix by a chelation process. This results in the fertilizer product. Currently there are no PCF processes operating within the Demil Enterprise. The process is not an alternative to OB for propellants mainly because of a variety of technical challenges associated with the prototype system. There were also concerns regarding the presence of bioaccumulative heavy metals discovered in the final fertilizer product that were suspected of being introduced to the process via the proprietary chemical reagent that was being used in the PCF process. 7.1.14 caustic Hydrolysis of Aluminum-Bodied Munitions Tooele Army Depot in Utah was selected for the demonstration of this destruction technology, which was designed to process munitions with aluminum bodies or possibly others that have an aluminum metal pathway to their energetics. The primary focus of the demonstration project is to focus on Cartridge Actuated Devices and Propellant Actuated Devices. Candidate munitions items are loaded into baskets that are then lowered into a Sodium Hydroxide bath, processed, and removed. The remaining tramp material is then flashed as an extra safety measure to ensure all energetics are gone. The Caustic Hydrolysis process at Tooele is no longer operational but has been used to process vast quantities of aluminum bodied CAD/PAD items within the Demil stockpile. However, these aluminum bodied items have been exhausted at Tooele Army Depot, resulting in the need for either identifying additional aluminum bodied stockpile items that are conducive to the caustic process, or pursuing an upgrade to the current process in order to accommodate a wider variety of non-aluminum stockpile items. Hence, the caustic process at Tooele Army Depot is currently no longer in use as an alternative technology for CAD/PAD items. 7.1.15 Cryofracture Cryofracture involves cooling a munition in liquid nitrogen and fracturing its casing in a press, followed by the decontamination of the fragments by either incinerator or by an alternative system such as a neutralization reactor, followed by a supercritical water oxidation. Cryofracture technology has been developed and field tested by General Atomics, and proven successful for the destruction of small munitions items at Yuma Proving Ground and McAlester Army Ammunition Plant. The cryofracture technology could be similarly applied, rendering munitions items safe for further treatment of the reactive characteristic. 26 Cryofracture itself is not an alternative to OB/OD but is a component of a larger process to destroy munitions items, which are then treated to neutralize or drive off the energetic hazard. Cryofracture is typically used in conjunction with a deactivation furnace. 7.1.16 Mobile Plasma Treatment System Crane Army Ammunition Activity in Indiana was selected for the demonstration of the Mobile Plasma Treatment System. This destruction technology can process smaller pyrotechnics, smokes and dyes, fuzes, small arms ammunitions, and small high explosive items (less than 0.35 pounds NEW Hazard Class 1.1). The principal focus of this technology is the use of a plasma arc torch to melt materials present in the crucible by employing high-temperature plasma, which is formed utilizing electrical energy supplied to the plasma torch, to ionize and heat a process gas to temperatures in excess of 12,000°F. Feed materials are melted by this high-temperature plasma and are contained in a stationary hearth that is connected to the bottom of the primary processing chamber. Inorganic materials collect in the hearth in a hot molten pool that is periodically tapped to form either a non-hazardous vitrified slag or recyclable metal. Effluent gases exiting the primary processing chamber are treated in a pollution abatement system prior to release to the environment. The Mobile Plasma Treatment System at Crane Army Ammunition Activity is not operational. The project was officially canceled 2 years ago by the PM Demi I Office because of a variety of technical challenges associated with trying to bring the prototype system up to a production readiness level of operation. As a result, the process was never formally permitted, nor did it ever reach the Low Rate Initial Production testing milestone that is required before a prototype system can be transitioned to production Demil. 7.1.17 MuniRem MuniRem is a reagent formulation that uses reduction chemistry to neutralize and degrade explosives while stabilizing metals. The product is marketed as scalable for use in neutralizing a broad range of explosives including, but not limited to HMX, RDX, TNT, Nitrocellulose and Nitroglycerin. Demonstrated use includes neutralization of recovered bulk explosives and decontamination of munitions casings or equipment contaminated with energetic materials. 7.1.18 High Pressure Water Jet Washout This alternative uses a high-pressure water jet as a solid rocket motor propellant cutting agent. The system uses multiple water jet lances coupled with an automated control system. The automated control system is a multi-tasking computer that monitors and controls the lance maneuvers and operations. High pressure water washout of HC 1.3 propellants in M LRS rocket motors was demonstrated in full-scale testing using 10K, 20K and 40K psi during FY09. Testing showed that washout is most effective at 10K psi. This process is production capable. Water washout technology for HC 1.1 27 propellants is not currently being pursued. Technology for washout of HC 1.1 propellants was discontinued in FY0G to focus on HC 1.3 propellant washout. High pressure water washout has been previously employed to remove HC 1.3 propellant from large rocket motors and is production capable for metal cases, i.e. Minuteman Ill Stage 1 and Stage 2. Minuteman motors containing HC 1.3 propellant were washed out prior to refurbishment during the Propellant Replacement Program (PRP) conducted from approximately 2000 to 2012. During this program, Stage 1 and Stage 2 Minuteman Ill motors were washed out and the casings were then reused with newly cast propellant and the ammonium perchlorate from the propellant was recovered for reuse. Washout was again used by the Rocket System Launch Program (RSLP) in 2016-2018 to demilitarize Minuteman Stage 1 and Stage 2 motors. 28 7.2 EVALUATION OF THE RECOMMENDATIONS IN THE LATEST NASEM REPORT ON ALTERNATIVE TECHNOLOGIES The NASEM report on alternative technologies includes 30 findings for which the following 8 recommendations have been made: Recommendation 2-1. The Army should include the potential to reduce the use of OB and OD as a criterion used to evaluate candidate projects in the Office of the Product Director for Demilitarization's RDT&E. Recommendation 2-2. The Office of the Product Director for Demilitarization should investigate the use of alternative treatment or disposal methods, including commercial treatment, storage, and disposal facilities, for positively identified pyrotechnic, explosive, or propellant contaminated non-munitions wastes. Recommendation 6-1. The Army should investigate whether permits for existing alternative technology units at Army munition demilitarization depots can be amended to be more flexible regarding the types, frequency, and amounts of munitions that can be treated. Recommendation 6-2. The Army should identify issues that could affect the RCRA permitting process for alternative technologies, including public concerns, and work with regulators in the states with jurisdiction over the seven demilitarization depots to establish requirements for Subpart X applications (e.g., developing scientific and technical analysis documents, emission modeling and estimates, and efficiency documentation for similar units) so as to address issues and questions before they become a problem that could significantly delay permitting alternative technologies. Recommendation 7-1. In keeping with stated strategic goal to increase the use of contained disposal, resource recovery, and recycling consistent with continuing to ensure minimal exposure of personnel to explosive safety risks, the Office of the Product Director for Demilitarization should perform a detailed technical and engineering evaluation of the munitions in the inventory currently demilitarized by open burning or open detonation and evaluate appropriate alternative demilitarization technologies for each munition along with an implementation schedule and budget requirements. This detailed evaluation should include the option of shipping munitions and munitions components to other organic or contractor facilities for demilitarization. 29 Recommendation 9-1. To enable the DoD and Congress to decide what level of resources should be devoted to increasing the use of alternative technologies in lieu of OB and OD, the Office of the Product Director for Demilitarization should prepare an analysis of the full life cycle costs of demilitarization of the munitions in the stockpile using alternative technologies and OB/OD to determine the funding necessary to increase the use of alternative technologies over various periods of time and the impact of that increase on the demilitarization enterprise. Recommendation 9-2. The Office of the Product Director for Demilitarization should develop a detailed implementation plan for transitioning from open burning and open detonation to alternative technologies, with appropriate performance metrics, and institutionalize it throughout the Demilitarization Enterprise. Recommendation 9-3. The Office of the Product Director for Demilitarization should, in coordination with the JMC Public and Congressional Affairs Office, include in its implementation plans proactive public affairs activities that build on the experience of other successful programs in resolving public concerns. Recommendations are directed at the Office of the Product Director for Demilitarization and are being addressed at that level through the Demilitarization Enterprise Strategic Plan metrics and RDT&E initiatives. 8.0 RECOMMENDATIONS UTTR in coordination with JMC, continues to evaluate alternatives to OB and OD for implementation. These are summarized in Table 2. Research and coordination with the Command has prompted no change to recommendations made during the 2022 evaluation. This evaluation of alternative technologies includes the re-evaluation of technologies that UTTR previously rejected as well as new or enhanced technologies with an emphasis on alternative technologies "that are being used, are being considered, or are scheduled to be implemented at other DoD demilitarization installations". Based on the 2023 re-evaluation of alternative technologies as summarized in Table 2, two technologies are recommended for consideration at UTTR as alternatives to OB/OD: • High Pressure Water Jet Washout • Batch or continuous feed CB system These are further discussed below. 30 High Pressure Water Jet Washout: Most recently, under the Propulsion Subsystem Support Contract {PSSC) 2.0 program effort, the necessary tooling and processes were developed to successfully washout a Minuteman Ill Stage 3 composite case motor. The effort was demonstrated on three Minuteman Ill Stage 3 cases and found to be repeatable. Washout of large rocket motors for decommissioning/demilitarization has not been employed at production scale since the RSLP disposal effort. It is the Air Force's understanding that the supplier facility requires equipment refurbishment within the 2024 government fiscal year to remain operational in support of future washout efforts. Further facility upgrades and additional equipment will be required to support the projected Minuteman Ill demilitarization production rates. The necessary facility upgrades will commence upon contract award of the Minuteman Ill Demilitarization effort to the PSSC program office. Contained Burn: The advancement of safe and reliable CB technology has the potential to reduce UTTR's reliance on OB/OD for the smokeless powder waste stream. CB technologies including batch or continuous feed CB systems have been demonstrated for destruction of deteriorated and stable propellants. The Army would be responsible for developing, permitting, and funding a local CB system for the smokeless powder currently generated at TEAD and treated at UTTR. Alternatively, the smokeless powder could be transported to a CB facility if one could be identified with excess treatment capacity. 31 9.0 SUMMARY There are several ongoing initiatives to expand CDT approaches within the Demilitarization Enterprise. The overall strategic planning for transitioning to more CDT approaches continues to be evaluated and developed across the DoD. That is because, as clearly acknowledged in the USEPA's Alternative Technology Report {USEPA, 2019), not every 'available' alternative technology capability "has been shown that it can be successfully operated in a production environment for extended periods of time without significant failures or unreasonable support costs to keep it operational." In other words, alternative technologies that have poor availability, reliability, maintainability, affordability, and supportability are not sustainable systems from an overall life cycle logistics point of view and are therefore, not considered to be production-ready capable solutions. As such, the Army Demilitarization RDT&E program and Enterprise continue to test, evaluate, and deploy technological approaches that are operationally feasible from a safety, environmental and life cycle sustainment point of view. And although the Demilitarization Enterprise is currently well equipped with a broad range of both open and closed disposal capabilities, there are still important "capability gaps" that continually arise due to the dynamic nature of both the BSA stockpile and DoD's ever evolving munitions requirements being supported around the world. These capability gaps are formally assessed on an annual basis including the identification of new and emerging CDT technologies that can be sustainably used to support Army demilitarization and disposal operations both organically and commercially. Specifically, there are significant efforts currently being pursued within the organic base at both Holston AAP and Radford AAP to stand up a new SDC and EWI/CWP capability for treating a broad range of energetic materials. In addition, there are plans/discussions within JMC and the Army's FY 2024 Demilitarization RDT&E program to evaluate and develop new CB capability within the Demi I Enterprise, as well as expand upon and improve other already existing CDT technologies (i.e., APE 1236 Rotary Kiln) to better accommodate the closed treatment of bulk propellants, such as the smokeless powder treated at UTTR. These ongoing RDT&E efforts involve updates to existing CDT feed systems and approaches and upgrades to pollution abatement systems to better accommodate the burn rates of bulk propellants verses HE. 32 As previously noted, decisions regarding the procurement and deployment of CDT systems and work loading among the organic base and commercial capabilities are made at the Army Enterprise level and therefore no implementation schedule can be offered. High pressure water washout with perchlorate recycling may also prove to be a safe and available alternative technology solution for treatment of HC 1.3 missile motors generated from the replacement of the Minuteman Ill system. However, the technical challenges of sustaining this complex alternative approach in an operations environment including the logistics of processing the excess motors generated have yet to be fully determined. It should also be noted that alternative treatments for strategic missile motors containing HC 1.1 propellants will be very difficult to deploy due to the uniquesafety hazards surrounding these propellant formulations. 33 10.0 SCHEDULE Transitioning the Demil Enterprise towards alternative technologies for disposal as opposed to OB and OD of explosives and waste munitions is a strategic endeavor with wide-spread and long- lasting implications to the organic industrial base. Investment decisions of this magnitude must be deliberate and maximize efficiency and effectiveness of the enterprise as a whole, and not sub-optimize individual installation alt tech capabilities and capacities. Currently, the Office of the Project Director for Joint Ammunition and Weapon Systems has stood up a comprehensive Demi/ Enterprise (DE) Alternative Technology Evaluation and Implementation Strategy Integrated Process Team (IPT) that has been formally commissioned to begin assessing safe and available alternative technology solutions that are able to be demonstrated and applied within a full scale demil operations environment. This Enterprise- wide evaluation is anticipated to take 24 months to complete and will identify specific funding requirements and implementation schedules required for timely acquisition of identified alternative technologies that can consistently perform and meet DOD operational needs. And although individual installations will provide input to inform this Enterprise-wide strategy and implementation plan, it should be stressed that installations do not have the ultimate decision authority on what alternative technology capability investments will be made at their individual installations or when .. The following tentative schedule is proposed in furtherance of the identification and implementation of alternative technologies at UTTR. Alternative Technology Under Consideration Schedule High Pressure Washout Facility upgrades pending contract award. Contained Burn Market research on-going under DE Alternative Technology Evaluation and Implementation Strategy IPT 34 11.0 REFERENCES HydroGeoLogic, Inc., 2023, Open Burn and Open Detonation, Evaluation of Alternative Technologies, Revision 2, Bluegrass Army Depot, Richmond, Kentucky, September. Jacobs, 2024, Utah Test and Training Range: Waste Characterization for the Thermal Treatment Unit, Calendar Year 2023, Salt Lake City, Utah, January 16, 2024. Joint Ordnance Commanders Group (JOCG) 2019. Optimization of Department of Defense Open Burning/Open Detonation Units. March. National Academies of Sciences, Engineering, and Medicine (NASEM), 2018. Alternatives for the Demilitarization of Conventional Munitions. Washington, DC : The National Academies Press . https://doi.org/10/17226/25140. Naval Air Warfare Center Weapons Division China Lake, 2004. Evaluation of Alternative Technologies to Open Detonation for Treatment of Energetic Wastes at the Naval Air Weapons Station, China Lake, California . January. Radford Army Ammunition Plant, 2015. Alternative Technologies to Open Burning of Propellants. September. U.S. Environmental Protection Agency (USEPA), 2019 . Office of Resource Conservation and Recovery (5303P), Alternative Treatment Technologies to Open Burning and Open Detonation of Energetic Hazardous Waste. EPA 532-R-19-007. December. U.S . Environmental Protection Agency (USEPA), 2023 . Office of Resource Conservation and Recovery (5303P), Compendium of Alternative Technologies to Open Burning and Open Detonation of Energetic Hazardous Wastes . EPA 530-R-23-027 . September. United States Government Accountability Office (GAO), 2015 . GAO-15-538. Defense Logistics Improved Data and Information Sharing Could Aid in DoD's Management of Ammunition Categorized for Disposal. United States Government Accountability Office (GAO), 2016. Technology Readiness Level , Technology Readiness Assessment Guide, August . 35 Table 1. Initial Screening of Alternative Technologies Section Availability Within the Potential Applicability to where Approved Waste DoD/Technology UTTR Waste Stream Described Alternative Technology Streams Readiness Level (TRL) Result of Screening 7.1.1 Contained Detonation -Dl00 Cased HE up to 45 lbs. Yes. Demonstrated and in use CDC in Detonation Configuration NEW including donor, within the DoD . The Dl00 is on-Not Applicable -The candidate Not recommended for Submunitions site at BGAD with an in-place waste stream is not a current or further assessment. RCRA Subpart X operating reasonably anticipated future permit. However, the system workload is currently not in use for detonation configurations due to issues with system reliability and maintainability. The system is currently undergoing RDTE testing to be repurposed for treatment of small 2.75-inch rocket motors. TRL: 7 7.1.1 Contained Detonation -Cased HE upto 132 lbs. No. Demonstrated and used Not recommended for Detonation of Ammunition in a NEW including donor outside the DoD only. Has Not Applicable -The candidate further assessment. Vacuum Integrated Chamber not been successfully waste stream is not a current or (DAVI NCH) demonstrated to date in a reasonably anticipated future full scale demil operations workload environment. TRL : 9 7.1.1 Contained Detonation -Cased HE upto91bs. NEW Currently not in use within Not Applicable -The candidate Not recommended for Explosive Destruction System including donor the Demilitarization waste stream is not a current or further assessment. (EDS) Enterprise due to issues reasonably anticipated future with system reliability and workload maintainability after repeated use in a demil operations environment. TRL: 9 7.1.2 Contained Burning(Subpart 0)-Stable, uncased propellant Yes. Demonstrated and in use Not Applicable -The candidate .Not recommended for Employing Incineration within the DoD . waste stream is not a current or further assessment . Explosive Waste Incinerator reasonably anticipated future TRL: 9 workload 36 7.1.2 Contained Burning(Subpart 0)-Stable, uncased propellant No. The BEDS system was Not recommended for Employing Incineration via developed in the 1990s but Not Applicable -The candidate further assessment. Bulk Energetics Disposal System was never successfully waste stream is not a current or [BEDS] demonstrated at demil reasonably anticipated future production levels . The workload feasibility and technical challenges associated with mixing, feeding and burning water based slurries proved problematic from both a safety and technical perspective. TRL:6 7.1.2 Contained Burning(Subpart 0)-Very small Net Explosive Yes. Demonstrated and in use Not Applicable -The candidate Employing Incineration Weight (NEW) munitions within the DoD . waste stream is not a current or Not recommended for Rotary Kiln/ Army Peculiar items(e.g., small arms reasonably anticipated future further assessment . Equipment (APE) 1236 ammunition, fuzes) TRL : 9 workload 7.1.3 Contained Burning(SubpartX)-Specific types of Yes . Unique technology that is Not Applicable -The candidate Not recommended for Static Kiln and Thermal submunitions owned/operated by an off-site waste stream is not a current or further assessment. Treatment of Submunitions commercial/ industrial facility reasonably anticipated future and is available for use within workload the Demilitarization Enterprise . 37 Section where Described I Alternative Technology 7.1.4 I Contained Burning(Subpart X)- 7.1.5 7.1.6 7.1.7 7.1.8 Static Kiln and Thermal Treatment of Multi-Launch Rocket System (MLRS) Contained Burning(SubpartX)- Thermal Treatment Closed Disposal Process (TTCDP) Contained Burning(SubpartX)- Dynasafe Static Detonation Chamber (SDC) Dynasafe Munitions Destruction System (MDS) Contained Burning(SubpartX)- Ammonium Perchlorate Rocket Motor Destruction (ARMD) Facility Table 1. Initial Screening of Alternative Technologies Approved Waste Streams MLRS Specific types of submunitions (MLRSM77 Submunitions) Propellant up to approximately24 pounds (lbs .) NEW Very small NEW munitions items (e.g., fuzes) Large, Ammonium Perchlorate(AP) Rocket Motors Availability Within the DoD/Technology Readiness Level (TRL) Yes. Unique technology that is owned/operated by an off-site DoD facility and is available for use within the Demilitarization Enterprise. TRL: 9 Yes. Unique technology that is owned/operated by an off-site DoD facility and is available for use within the Demilitarization Enterprise. TRL: 9 Yes . Technology has been demonstrated successful for production level disposal of a wide variety of munition types within the SOC-specific NEW limits .. Currently owned/operated by an off- site DoD facility t of existing . TRL: 9 Yes. Unique technology that is owned/operated by an off-site DoD facility and is available for use within the Demilitarization Enterprise. TRL: 9 Yes . Unique technology that is owned/operated by a DoD facility and is available for use within the Demilitarization Enterprise. TRL:9 Potential Applicability to UTTR Waste Stream Not Applicable -The candidate waste stream is not a current or reasonably anticipated future workload Not recommended for further assessment. Not recommended for further assessment. Not recommended for further assessment. Result of Screening Not recommended for further assessment. Not recommended for further assessment. Not recommended for further assessment. Not recommended for further assessment. Not Applicable -The candidate I Not recommended for waste stream is not a current or further assessment. reasonably anticipated future workload (not large missile motors) 38 Table 1. Initial Screening of Alternative Technologies Section Availability Within the Potential Applicability to where Approved Waste DoD/Technology UTTR Waste Stream Described Alternative Technology Streams Readiness Level (TRL) Result of Screening 7.1.9 Contained Burning (Subpart X) Stable and deteriorated Yes . Though not currently Yes -The Tooele Army Depot Recommended for -Thermal Treatment of Bulk uncased propellant available within the Demil smokeless powder Dem ii waste further assessment. Propellant (Batch or Continuous Enterprise, this type of stream could potentially Feed) technology has been include the candidate waste demonstrated for destruction stream for which the Alt Tech of military propellant as part of is applicable an emergency treatment campaign at Camp Minden . The design requirements of a Contained Burn System that can meet demi I operational needs is currently under evaluation through the DE Alternative Technology Evaluation and Implementation Strategy IPT TRL: 7 7.1.10 Contained Burning(SubpartX)-Small, Non-AP Rocket Yes . The D100 is on -site at D100 CDC in Static Burn Motors without warheads BGAD with an in-place RCRA Not Applicable -The candidate Not recommended for Configuration Subpart X operating permit. waste stream is not a current or further assessment . However, the system is reasonably anticipated future currently not in use for workload detonation configurations due to issues with system reliability and maintainability. The system is currently undergoing ROTE testing to be repurposed for treatment of small 2 .75-inch rocket motors. TRL : 7 7.1.11 Decineration Fuzes, cartridges, primers, No . The Decineration technology Not recommended for blasting caps, small arms has not been successfully Not Applicable -The candidate further assessment. ammunition demonstrated in a full scale waste stream is not a current or demil operations environment reasonably anticipated future workload TRL: 6 39 7.1.12 General Atomics Industrial Stable, uncased propellant No. The iSCWO has not been Not Applicable -The candidate Not recommended for Supercritical Water Oxidation that can be safely successfully demonstrated in a waste stream is not a current or further assessment. (iSCWO) converted to a liquid feed full scale demil operations reasonably anticipated future environment. workload. TRL: 7 7.1.13 Propellant Reformulation Stable, uncased propellant No. Propellant reformulation Not recommended for Blasting Agent Manufacturing technology has not been Not Applicable -The candidate further assessment. (BAM} Facility demonstrated in an waste stream is not a current or Slurry Explosion Module (SEM) operations environment reasonably anticipated future and Energetics Processing due to risks associated with workload. Module (EPM} loss of propellant Lot Propellant Conversion to identity when mixing Fertilizer (PCF} batches.and other hazards associated with processing uncased propellants under these other unsuccessfully tested alt tech approaches TRL: 5 40 Section where Described I Alternative Technology 7.1.14 I Caustic Hydrolysis 7.1.15 7.1.16 7.1.18 Mobile Plasma Treatment System MuniRemChemical Neutralization High Pressure Water Jet Washout Table 1. Initial Screening of Alternative Technologies Approved Waste Streams Aluminum bodied cartridge/pressure actuated devices (CADs/PADs) Smaller pyrotechnics, smokes and dyes, fuzes, small arms ammunitions, and small high explosive items (less than 0.35 Pounds NEW Hazard Class 1.1) Cased or uncased HE Minuteman Ill, Stage 1, 2, and 3 containing HC 1.3 propellant. Availability Within the DoD/Technology Readiness Level (TRL) Yes. Unique technology that is owned/operated by a DoD facility but is no longer available for use within the Demilitarization Enterprise due to completion of the Aluminum bodied CAD/PAD demi I mission. TRL: 9 No . Pilot scale system was never ransitioned nor successfully ~ emonstrated in a full scale demil operations environment due to a ariety of technical and safety hallenges. TRL: 7 No . MuniRem has not been successfully demonstrated in a production demilitarization environment on large volumes of bulk energetics. Only demonstrated on residue explosives quantities. TRL: Yes. Unique technology that is owned/operated by an off-site commercial/ industrial facility and is available for use within the Demilitarization Enterprise . Potential Applicability to UTTR Waste Stream Not Applicable -The candidate waste stream is not a current or reasonably anticipated future workload Not Applicable -The candidate waste stream is not a current or reasonably anticipated future workload Not Applicable -The candidate waste stream is not a current or reasonably anticipated future workload Yes -The UTTR Demil waste stream could potentially include the candidate waste stream for which the AltTech is applicable Result of Screening Not recommended for further assessment. Not recommended for further assessment. Not recommended for further assessment. Recommended for further assessment. 41 Table 2: Assessment of Current Waste Streams Treated at the UTTRmu (see 2023 Waste Characterization Report (Jacobs, 2024) for waste treatment statistics) Typical Waste Potential Waste Stream Weight Characterization Alternative Technology Availability (lbs NEW*) Report Category Technology Trident Missile Motor 38,914 HC 1.1 (C-4 motor) OD High Pressure Water washout technology for HC 1.1 propellants is (Stage 1) OB Water Jet not currently being pursued . Due to safety Washout concerns and the explosive nature of HC 1.1 propellants there is currently no alternative technology available for large rocket motors that are treated at the UTTR. Trident Missile Motor 24,482 HC 1.1 (D-5 motor) OD High Pressure Water washout technology for HC 1.1 propellants is (Stage 2) OB Water Jet not currently being pursued . Due to safety Washout concerns and the explosive nature of HC 1.1 propellants there is currently no alternative technology available for large rocket motors that are treated at the UTTR . 9,006 High Pressure Water washout technology for HC 1.1 propellants is Trident Missile Motor HC 1.1 (D-5 motor) OD Water Jet not currently being pursued . Due to safety (Stage 3) OB Washout concerns and the explosive nature of HC 1.1 propellants there is currently no alternative technology available for large rocket motors that are treated at the UTTR. 42 Typical Waste Potential Waste Stream Weight Characterization Alternative Technology Availability (lbs NEW*) Report Category Technology HCl.l(Scrap Varies HCl.1 (Scrap Static The Static Detonation Chamber (SDC) has Propellant) (in 2023, this Propellant) OD Detonation demonstrated production-ready, demilitarization of OD waste stream Chamber small cased munition items with low quantities of accounted energetic material but is not feasible for large for 0 .19% of munition items containing high quantities of the waste energetic material like those routinely treated at the treated at UTTR/TTU. Small amounts of HC 1.1 scrap UTTR) propellant may be treated in an SDC however there is no facility currently available to handle the volume of scrap generated at the UTTR Minuteman II (Stage 1) OB 45,802 HC 1.3 (Minuteman motor) High Pressure Washout of large rocket motors for OB Water Jet decommissioning/demilitarization has not been Washout employed at production scale since the Rocket System Launch Program disposal effort. The supplier facility remains operational but requires equipment refurbishment prior to production demilitarization. Further facility upgrades and additional equipment will be required to support the projected Minuteman Ill demilitarization production rates. The necessary facility upgrades will commence upon contract award of the Minuteman Ill Demilitarization effort to the PSSC program office. 43 Typical Waste Characterization Potential Waste Stream Weight Report Category Alternative Technology Availability (lbs NEW*) Technology Minuteman II (Stage 2) OB 13,745 HC 1.3 (Minuteman motor) High Pressure Washout of large rocket motors for OB Water Jet decommissioning/demilitarization has not been Washout employed at production scale since the Rocket System Launch Program disposal effort. The supplier facility remains operational but requires equipment refurbishment prior to production demilitarization. Further facility upgrades and additional equipment will be required to support the projected Minuteman Ill demilitarization production rates . The necessary facility upgrades will commence upon contract award of the Minuteman Ill Demilitarization effort to the PSSC program office. Minuteman Ill (Stage 1) 45,792 HC 1.3 (Minuteman motor) High Pressure Washout of large rocket motors for OB OB Water Jet decommissioning/demilitarization has not been Washout employed at production scale since the Rocket System Launch Program disposal effort. The supplier facility remains operational but requires equipment refurbishment prior to production demilitarization. Further facility upgrades and additional equipment will be required to support the projected Minuteman Ill demilitarization production rates. The necessary facility upgrades will commence upon contract award of the Minuteman Ill Demilitarization effort to the PSSC program office. 44 Typical Waste Characterization Potential Waste Stream Weight Report Category Alternative Technology Availability (lbs NEW*) Technology Class1.3(Smokeless 49,000 Class1.3(Smokeless Contained The TTU treats smokeless powder generated from Powder) OB Powder) OB Burn Tooele Army Depot. A contained burn chamber or System rotary kiln as noted in the EPA Alternative Technology Compendium could be an alternative technology to treat the Tooele Army Depot smokeless powder. However, a contained burn system or rotary kiln is not readily available to treat the volume ofTooele smokeless powder at this time. The design requirements of a flexible Contained Burn System that can meet demil operational needs is currently under evaluation through the DE Alternative Technology Evaluation and Implementation Strategy IPT Classl.3(Scrap Varies Class1.3(Scrap Contained A contained burn system could theoretically be Propellant) OB (In 2023, this Propellant) OB Burn built to treat the HC 1.3 scrap propellant. waste stream System However, such a system is not known to be currently accounted for available. The design requirements of a flexible 7 .03% of the Contained Burn System that can meet demil waste treated operational needs is currently under evaluation at UTTR) through the DE Alternative Technology Evaluation and Implementation Strategy IPT Classl.3 (Polaris A3 20,715 Classl.3 (Polaris High Pressure Washout of large rocket motors for Stage 1) OB Motor)OB Water Jet decommissioning/demilitarization has not been Washout employed at production scale since the Rocket System Launch Program disposal effort. The supplier facility remains operational but requires equipment refurbishment prior to production demilitarization . Washout of a Polaris motor has not been demonstrated on a production scale and given the small quantity of Polaris motors in the stockpile, it would not be feasible to program water jet washout for this waste stream. *Net Explosive Weight 45