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HomeMy WebLinkAboutDSHW-2024-005010• Mr. Douglas J. Hansen DEPARTMENT OF THE ARMY TOOELE ARMY DEPOT/HEADQUARTERS 1 TOOELE ARMY DEPOT, BUILDING 1 TOOELE, UT 84074-5003 February 27 , 2024 Director, Division of Waste Management & Radiation Control Utah Department of Environmental Quality ATTN: Gabrielle Marinick P.O. Box 144880 Salt Lake City, UT 84114-4880 Dear Mr. Hansen : Div of Waste Manag m nt and Rad,at,on Control FEB 2 7 2024 As per the State of Utah Administrative Rules , R315-264-73 , as incorporated by reference (40 CFR 264. 73 (b)(9)}, certification is provided here with an active program to reduce hazardous waste generated is in place at Tooele Army Depot-South (TEAD- S) Area . Further, waste management methods are the most practicable currently available for employees to facilitate in minimizing the present and future impact from waste generation to human health and the environment. A key focus of the minimization program is product substitution. TEAD-S requires anyone purchasing a hazardous material not previously in use at TEAD-S to go through an approval process which encompasses environmental , safety , and industrial hygiene review. That process was established to ensure the minimum usage of hazardous materials on the depot. In addition , TEAD-S is routinely reviewing hazardous materials currently in use to determine if a less hazardous material is available for substitution . In accordance with TEAD-S RCRA part B permit Module I1.L.3 .a-e , TEAD-S is also required to submit a report evaluating Alternative Technolog ies to Open Burn and Open Detonation . This report is enclosed in with this certification lette r. This statement of hazardous waste minimization certifies all activities conducted under permits owned and operated by Tooele Army Depot-South Area . Should you have any questions regarding this matter, please contact Jay Nelson of my staff at (435) 833-3248 . • • Respectfully, Lonnie Brown Chief, Environmental Management Division *CERTIFICATION STATEMENT •1 CERTIFY UNDER PENAL TY OF LAW IBAT IBIS DOCUMfu'IT AND ALL ATTACHMENTS WERE PREPARED UNDER MY DIRECTION OR SUPERVISION ACCORDING TO A SYSTEM DESIGNED TO ASSURE THAT QUALIFIED PERSONNEL PROPERLY GATHER A"lD EVALUATE THE INFORMATION SUBMITTED. BASED ON MY INQUIRY OF TI-IE 2PERSON OR PERSONS WHO MANAGE THE SYSTEM, OR IBOSE PERSONS DIRECTLY RESPONSIBLE FOR GATHERING THE INFORMATION SUBMITTED IS, TO IBE BEST OF MY KNOWLEDGE AND BELIEF, TRUE, ACCURATE, AND COMPLETE. I AM AW ARE IBAT THERE ARE SIGNIFICANT PENAL TIES FOR SUBMITTING FALSE INFORMATION, INCLUDING IBE POSSIBILITY OF FINE AND IMPRISONMENT FOR KNOWING VIOLA TIO NS. I • Open Burning and Open Detonation Evaluation of Alternative Technologies Prepared for: Tooele Army Depot Tooele, Utah February 2024 I This page was intentionally left blank. I TABLE OF CONTENTS ACRONYMS AND ABBREVIATIONS .................................................................................................... IV 1.0 PURPOSE .............................................................................................................................. 1 2.0 BACKGROUND ...................................................................................................................... 2 3.0 DEPARTMENT OF DEFENSE DEMILITARIZATION PROGRAM OVERVIEW ................................... 2 4.0 EXPLOSIVES SAFETY CONSIDERATIONS .................................................................................. 4 5.0 DESCRIPTION OFTEAD'S MUNITIONS WASTE STREAM ........................................................... 6 6.0 ALTERNATIVE TECHNOLOGIES OVERVIEW .............................................................................. 9 7.0 ALTERNATIVE TECHNOLOGIES EVALUATION ......................................................................... 11 7.1.1 Contained Detonation ......................................................................................... 11 7.1.2 Contained Burning (Subpart O) Employing lncineration ...................................... 12 7.1.3 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units for Submunitions .................................................................................................. 13 7.1.4 Contained Burning (Subpart X) -Static Kiln and Thermal Treatment Units for MLRS ............................................................................................................... 14 7.1.5 Contained Burning (Subpart X)-Thermal Treatment Closed Disposal Process ................................................................................................................. 14 7.1.6 Contained Burning (Subpart X) -Static Detonation Chamber ............................ 15 7.1. 7 Contained Burning (Subpart X) -Munition Destruction System (MDS) .............. 15 7.1.8 Contained Burning (Subpart X) Ammonium Perchlorate Rocket Motor Destruction (ARMD) ............................................................................................. 16 7.1.9 Contained Burning (Subpart X) Thermal Treatment of Bulk Propellant .............. 16 7.1.10 Contained Burning (Subpart X) D100 Controlled Destruction Chamber in Static Burn Configuration ..................................................................................... 16 7.1.11 Decineration ........................................................................................................ 17 7.1.12 Industrial Super Critical Water Oxidation ............................................................ 17 7.1.13 Propellant Reformulation .................................................................................... 18 7.1.8.1 Blasting Agent Manufacturing (BAM) Facility, Hawthorne Army Depot .............. 18 7.1.8.3 Propellant Conversion to Fertilizer (PCF) ............................................................. 19 7.1.14 Caustic Hydrolysis of Aluminum-Bodied Munitions ............................................ 19 7.1.15 Cryofracture ......................................................................................................... 20 7.1.16 Mobile Plasma Treatment System ....................................................................... 20 7.1.17 MuniRem ............................................................................................................. 20 7.1.18 Soukos Castilia Demilitarization System 7.2 EVALUATION OF THE RECOMMENDATIONS IN THE LATEST NASEM REPORT ON ALTERNATIVE TECHNOLOGIES .......................................................................................... 22 8.0 RECOMMENDATIONS ........................................................................................................... 25 9.0 SUMMARY ........................................................................................................................... 26 10.0 SCHEDULE ............................................................................................................................ 27 11.0 REFERENCES ........................................................................................................................ 28 LIST OF FIGURES Figure l. OB and OD Demilitarization by Pounds NEW (2013 -2023) .............................................. 7 Alternative Technologies Evaluation Tooele Army Depot I TABLE OF CONTENTS (CONTINUED) Figure 2. Figure 3. TEAD OB and OD Treatment Quantity, Tons FY 2013 -FY 2023 ......................................... 8 TEAD Demilitarization 2013 -2023 by Lbs. NEW ................................................................ 8 LIST OF TABLES Table 1. Table 2. Table 3. TEAD OB and OD Total Treatment Quantity FY 2005 -FY 2021 (tons) .............................. 7 Initial Screening of Alternative Technologies ................................................................... 30 Assessment of Alternative Technologies .......................................................................... 30 Alternative Technologies Evaluation Tooele Army Depot ii I This page was intentionally left blank. I ACRONYMS AND ABBREVIATIONS AAP Army Ammunition Plant ACFT Anti-Aircraft ACWA ADAM AMCOM ANMC APE APERS ARMD BGCAPP CAL CB CBU CD CDC CDT CSI CWP DoD DoDIC DPICM DU EWI FY GAO HE HGL HQ JMC JOCG Assembled Chemical Weapons Alternatives Area Denial Artillery Munition Aviation Missile Command Anniston Munitions Center Army Peculiar Equipment Anti-personnel Ammonium Perchlorate Rocket Motor Destruction Blue Grass Chemical-Agent Destruction Pilot Plant Caliber Contained burn Cluster Bomb Unit Contained detonation Controlled Destruction Chamber Closed disposal treatment Compliance Schedule Item Contained Waste Processors Department of Defense DoD Identification Code Dual Purpose Improved Conventional Munition Depleted Uranium Energetic Waste Incinerator Fiscal Year United States Government Accountability Office High Explosive HydroGeologic, Inc. Headquarters Joint Munitions Command Joint Ordnance Commanders Group Alternative Technologies Evaluation Tooele Army Depot 2 I ACRONYMS AND ABBREVIATIONS (CONTINUED) lbs. LEMC MDS MIDAS MLRS mm NASEM NEW OB OD PAO PEO R3 RCRA RDT&E SDC SF SMCA TEAD Tons UDEQ USEPA 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 Public Affairs Office Program Executive Office Reclamation, Recycling, and Reuse Resource Conservation and Recovery Act Research, Development, Test and Evaluation Static Detonation Chamber Static Fire Single Manager for Conventional Ammunition Tooele Army Depot U.S. tons, also known as short tons (2,000 lbs.= 1 short ton) Utah Department of Environmental Quality U.S. Environmental Protection Agency Waste military munition Alternative Technologies Evaluation Tooele Army Depot V I Certification Statement (40 CFR 270.ll(d)(l)) I certify under penalty of law that this document and all attachments were prepared under my direction or supervision according to 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. Alternative Technologies Evaluation Tooele Army Depot 2 I • This page was intentionally left blank . I 1.0 PURPOSE Tooele Army Depot (TEAD) manages two different RCRA Subpart A/B Hazardous Waste Permits TEAD North OB/OD Range (Permit# 3212320894), and TEAD South OD Range (Permit# UT5210090002), and is conducting an evaluation of alternative technologies to Open Burning (OB) and Open Detonation (OD) in accordance with the requirements of TEAD North and TEAD South's RCRA Subpart A/B permits. This document will serve as the Alternative Technology Evaluation for both TEAD North and South, and will conform to TEAD North's Alternative Technology Permit Requirements, which states: The Permittee shall submit a report evaluating Alternative Technologies to Open Burn and Open Detonation (OB/OD) treatment. This report shall be submitted as new alternative technologies are developed, if waste streams change, or five years after the most recent Alternative Technologies report was submitted. At a minimum, the report shall: 1. Identify all waste streams currently treated by OB/OD at TEAD-N. 2. Identify and evaluate any and all alternative technologies to OB/OD for each identified waste stream, at the point of generation. 3. Provide narrative explaining why each technology would or would not be effective for the specified waste stream. If the technology is not feasible, the report must describe the limiting factors. 4. If TEAD-N determines one or more alternative technologies are viable for a specific waste stream, the Permittee shall include language explaining why the technology is not currently implemented at TEAD-N. 5. If the report finds that no alternative technologies would be feasible or effective, the report can certify that OB/OD is the only technology available to treat the specified waste stream. (TEAD-North 2023) As further detailed herein, the DoD's Demilitarization Enterprise, of which TEAD is a component, 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. Alternative Technologies Evaluation Tooele Army Depot 1 I • 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 TEAD's efforts to pursue identifying safe and available alternatives to OB/OD through coordination with the headquarters (HQ) for demilitarization offices for sustainable alternative technologies to OB/OD. 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 that are not fully developed nor proven at production levels. 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. 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 DoD's conventional ammunitions requirements, including the demilitarization of conventional ammunition for the DoD. Alternative Technologies Evaluation Tooele Army Depot 2 ' • • .. ·. 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 (AMCOM). 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). TEAD is one of the seven JMC depots. Decisions related to where within the Demilitarization Enterprise workload is executed and placement of alternative technologies are made at these command levels. The JMC's conventional munitions demilitarization mission is executed at the seven depots, as follows: Tooele Army Depot, Utah (TEAD); 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. Ammunition products are transferred to the 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 available feasible, and sustainable from a safety, environmental compliance, and operational sustainment perspective. Of note, there is a new Alternative Technology Evaluation tool that is currently under development (being led through the Department of Defense Explosives Safety Board and Army Demilitarization Enterprise subject matter experts) that will further enhance DoD's existing strategic planning tools that are already used to ensure that all munition items needing treatment are comprehensively characterized, evaluated, and assessed for closed disposal treatment (CDT) before initiating demilitarization. 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 stored at locations where they may ultimately be recycled or Alternative Technologies Evaluation Tooele Army Depot 3 I • • disposed, where feasible, given the availability of storage capacity. For example, because ANAD 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 ANAD. TEAD stores an estimated 9.3 percent of the conventional munitions' demilitarization stockpile (as of 12/31/23), some portion of which will ultimately be demilitarized at TEAD, while some portion will be diverted to an alternate facility. From 2020 through 2023, TEAD has shipped (diverted) an estimated 3,121 tons of demil assets for disassembly at another JMC organic installation. An estimated 4,050 tons were shipped (diverted) to an off-site commercial facility for demilitarization utilizing a closed disposal technology. Munitions items shipped off-site for demilitarization by alternative technologies include, but are not limited to, lSSMM projectiles, rocket motors, propelling charges, cluster munitions, and various size cartridges. 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 also considered as "alt-techs" . 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 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, many 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. OB/OD has been a common demilitarization technology for decades and has been in use at TEAD since inception in the early 1940s. OB at TEAD North consists of spreading waste propellants between 14 Burn Pans (7 at a time) approximately 16ft x 4ft x 11 inches deep. Also, in congruent with TEAD's OB operations, TEAD also ships propellant to UTTR (Utah training and Testing Range) to help with OB operations. TEAD's OD is primarily conducted at TEAD South and consists of placement of WM M in a series of 20 pits with donor charges, covering these with Alternative Technologies Evaluation Tooele Army Depot 4 I • • soil, and remote detonation. OB/OD operations are technically simple, consistent with the general safety principle of ensuring minimal exposure of personnel to explosive risk (because handing is minimal} and is relatively inexpensive to conduct as compared to many alternatives (United States Government Accountability Office [GAO], 2015). 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 DD ESB are "adequate to minimize explosive accidents and injuries." The committee recognized the crucial role of the DD ESB in ensuring adequate protective measures for workers and the surrounding area and thus that DD ESB 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. The OB/OD demilitarization operations at TEAD are currently deemed mission essential. TEAD 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 TEAD's hazardous waste operating permit. Furthermore, the treatment capacity of these permitted units, TEAD North (360,000 lbs. NEW for OB, 675,000 lbs. for OD, and 362,400 lbs. for Static Fire} and TEAD South (7,200,000 lbs. of assorted WMM 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 TEAD 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 assuming an additional 30-year active life and using reasonable maximum estimates of exposure, USEPA-approved models, and USEPA protocols. The Requirements for Human Health Risk Assessment and Screening Level Ecological Risk Assessment are reported in each of TEAD's RCRA Subpart A/ B permits respectively, TEAD Alternative Technologies Evaluation Tooele Army Depot 5 I • North's requirements are stated in Module VI (TEAD, 2019), and TEAD South, in Module VII. (TEAD, 2018) It is important to note that the use of OB and OD at TEAD as a treatment process is used for a variety of reasons to include safety as stated in the TEAD North UDEQ RCRA Subpart A/B permit: 1.1.4.1 Safety is the most important consideration. Strict observance of proven OB and OD procedures has resulted in an excellent safety record being earned by the personnel who have helped to treat the many millions of pounds of waste military energetic materials safely over the last four decades at numerous Department of Defense (DOD) installations. 1.1.4.2 These types of operations are extremely versatile; large or small quantities of the myriad types of materials can be treated easily and safely. 1.1.4.3 Because of their inherent simplicity, OB and OD are extremely reliable processes not subject to equipment downtime. (TEAD, 2019) 5.0 DESCRIPTION OF TEAD'S MUNITIONS WASTE STREAM and has been issued a permit that provides flexibility to treat a variety of munitions items. The potential munitions waste stream is thoroughly described in Part C, Waste Analysis Plan and this information is not duplicated here. TEAD's munitions waste stream over the past decade and reasonably foreseen future consists of unstable propellant generated as a result of refurbishment of projectiles and medium-sized, cased high explosives munition cartridges, projectiles, rocket motors, bombs, and mines and their components (e.g., fuzes, boosters, primers). A graph depicting TEAD's OB and OD demilitarization operations volume expressed in Net Explosive Weight for the past 10 years (2013 -2022) and 2023 to date is shown in Figure 1. The graph depicts a significant drop to almost zero in OD operations at TEAD North, this is due to the beginning of OD operations at TEAD South. TEAD South OD operations start 2019 and go through 2023, and are depicted in figure la . Alternative Technologies Evaluation Tooele Army Depot 6 I 2500000 2000000 1500000 1000000 500000 0 Figure 1. OB, SF and OD Demilitarization by LBS . New TEAD North {2013-2023) 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 ■ OB NEW LBS ■ NORTH OD NEW LBS ■ South OD NEW ■ SF NEW LBS As depicted in Figure 1, the bulk of TEAD 's demilitarization mission is (and is reasonably expected to continue to be) associated with OB of stable propellant charges removed from munitions items during demilitarization. TEAD provides the ability to safely destroy some propellants on-site, while the rest is shipped to Utah Training and Testing Range (UTTR) Approx. 90 miles to TEAD's west, which is a critical m ission for the Demilitarization Enterprise. The OD waste stream is (and is expected to continue to be) comprised of a variety of small and medium cased munitions. OB/OD treatment quantities in tons from Fiscal Year (FY) 2013 through FY 2023. The treatment quantities are presented in Table 1 and the trend graph is shown in Figure 2. The trend line demonstrates an increase starting in 2019 due to the permitting of TEAD South OD Range Table 1. TEAD OB and OD Total Treatment Quantity FY 2013 -FY 2023 (tons) Year tons FY13 249 FY14 283 FYlS 221 FY16 362 FY17 207 Alternative Technologies Evaluation Tooele Army Depot Year FY18 FY19 FY20 FY21 FY22 tons Year tons Year 157 FY23 481 889 879 1035 685 tons 7 I 1200 100 0 800 600 400 200 0 FY13 Figure 2. TEAD OB, SF, and OD Treatment Quantities FY 2013-FY 2021 (TONS) FY14 FYlS FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23 TEAD North's OB/OD permit authorizes up to 1,397,000 lbs. NEW combined OB, OD, and SF capacity per calendar year. TEAD South's OD permit authorizes up to 7,200,000lbs. NEW broken down over several categories as seen in Figure 3. Analysis of TEAD's OB/OD treatment records for the last eleven years (2013 -2023) shows actual demilitarization ranging from a low of approximately 314,867 lbs. NEW in 2018 to 2,071,063 lb. NEW in 2021. An eleven-year trend graph is presented in Figure 4. Figure 3 Category Description A High Explosive Cased: Cased munitions with a high explosive filler. Includes cartridges, bombs, and rocket motors . High Explosive Donor: Uncased high explosives including bulk explosives. Mines: Items with a common name including the term mine. Generally th in walled. Typical NEWs ranging from 1.4 lbs. to 24 lbs . oer item . Grenades: Items with a common name including grenade . Typically weight less than one pound . B Impulse Cartridges: Items with a common name including impulse. C Incendiaries/Tracers : Items used as incendiaries and tracers. D Fuse/Fuze: Items with a common name including fuse /fuze. E Simulators: Items with a common name including the term simulator. Detonators/Blasting Caps: Items with a common name includin g F blasting cap , detonating cord, percussion primer and used as part of detonation trains. Typically low NEWs/item ratios generally ranging around 0.01 to 0.0001 lbs. NEW/item. Adapter/Booster: Items with a common name including adapter, G booster tape, and booster guided. Typically contain less than I lb . NEW per item. 'Maximum pit loading of 5,000 lb s. NEW for 20 pits per day. bSee the Open Detonation Risk Management Plan for in format ion on the derivation of these quantities .. Alternative Technologies Evaluation Tooele Army Depot Annual Quantity•,b (NEW lb/ year) 5,976,000 72,000 216 ,000 216,000 216,000 144,000 360,000 8 I 2500000 2000000 1500000 1000000 500000 0 Figure 4. TEAD DEMILITARIZATION 2013-2023 by Lbs. NEW 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 6.0 ALTERNATIVE TECHNOLOGIES OVERVIEW Current alternative demilitarization methods can be grouped into the following categories: • Explosives removal • Disassembly • Cutting and resizing • 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 remova l technologies include: • Autoclave Melt-out of high explosives -following process to provide for an opening i n 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 safely remove explosive fillers out of the munitions body . Examples disassembly/cutting/resizing include: Alternative Technolog ies Evaluation Tooele Army Depot 9 I • 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 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 and effective from an overall energetic performance point of view. None were discussed in the NASEM report and no additional information pertaining to technologies for reformulation of energetics beyond what was presented. 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. The NASEM report (NASEM, 2018) and USE PA follow-on report (USE PA, 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. The re-evaluation of alternative technologies previously identified (including those previously rejected) and evaluation of new Alternative Technologies Evaluation Tooele Army Depot 10 I or enhanced technologies, if any, are presented in Section 4 and are presented in these three major groupings. 7.0 ALTERNATIVE TECHNOLOGIES EVALUATION Alternative technologies evaluated for potential use at TEAD are described in Sections 7.1.1 through 7.1.15 below. The technology evaluation process was as follows: 1. Alternative technologies identified through research and consultation with the Command were first screened for: o General applicability to the TEAD energetic waste streams (i.e., the likelihood that TEAD would receive the technology's candidate waste stream as workload}, and o The technologies current availability for implementation in a true demil operations environment. That is, whether sufficient information is available to properly assess the technology and whether the technology has been demonstrated as safe and sustainable for use beyond a research and development or pilot scale demonstration environment. The initial screening of technologies is presented in Table 2. 2. Alternative technologies not rejected during the initial screening were then assessed based, again, on whether the technology's candidate waste stream corresponds to the reasonably foreseen TEAD waste stream and 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 TEAD. The rationale for recommending alternative technologies for further detailed analysis for future use at TEAD is articulated in the last column of Table 3. 7.1.1 Contained Detonation Contained Detonation (CD} chambers are a technology 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 Alternative Technologies Evaluation Tooele Army Depot 11 I 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) limited system reliability due to the need to withstand repeated structure shocks resulting from detonations with consequent wear and tear on the pressure vessels; and (3} system maintainability challenges due to repeated damage from overpressures and fragmentation after minimal operations resulting in increased risk of maintaining system within required specifications for safe operations. 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 Blue Grass Army Depot (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 (DAVINCH} commercially manufactured by Kobe Steel. These three variations operate in similar fashion and have been constructed in various sizes to accommodate different configurations and volumes of munition items. 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: 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 (EWI} (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 reactive, rubbery material that is Alternative Technologies Evaluation Tooele Army Depot 12 I • 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 for uniform incineration. Research performed in support of this alternative 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), Is currently in operation at TEAD under their RCRA Subpart A/B permit. EWls are in use within the Army and at commercial facilities. For example, an incinerator is present at Picatinny 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. 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 a 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. Alternative Technologies Evaluation Tooele Army Depot 13 I • 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 Class 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 Class 1.3 explosives are a potential component of the TEAD munitions waste stream. Enclosed thermal treatment (i.e., burning) employing ignition other than controlled flame combustion is an available technology for Class 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 Class 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 Anniston Army Depot (ANAD) in Anniston, Alabama, currently conducts OB and OD/BD under RCRA Hazardous Waste Facility Permit Number AL3 210 020 027. In addition to waste treatment, ANAD 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 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 O8/OD/BD. To further facilitate the current MLRS recycling process, a Thermal Treatment Closed Disposal Process (TTCDP) was successfully deployed at ANAD for disposal of M77 submunitions and fuzes downloaded from the MLRS. The TTCDP consists of 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. Moreover, the TTCDP is composed 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 is provided by remotely operated conveyors. The TTCDP is operated and monitored remotely from the TTCDP human-machine interface located in an onsite control room. Within the tunnel furnace, ignition is accomplished by an electrically heated coil that is moved Alternative Technologies Evaluation Tooele Army Depot 14 I • into the grenade and touches the Comp AS surface area. After ignition, the igniter is moved away from the burning grenade into its home position. The copper cones from the submunitions are then decontaminated by the hot flame of the burning Comp AS of the grenade underneath. Dynasafe's MOS is an indirectly heated destruction system originally designed for small arms ammunition that is used to thermally treat the fuzes. The MOS 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 Currently in operation at ANAD, the SOC 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 SOC process is remotely controlled thereby minimizing material handling. The SDC at ANAD is currently not in use for conventional ammunition demil in an operations environment. The SOC system at ANAD is designed to accept a maximum gross weight of up to 330 pounds including the feed tray. The explosive capacities for the SOC 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 For the purposes of destruction in the SOC, 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 SOC. 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 (MOS) The Munition Destruction System (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 MOS 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 available alternative for use when only small quantities of small NEW munitions items (such as what may recovered during routine Depot operations) are generated. Alternative Technologies Evaluation Tooele Army Depot 15 ' • 7.1.8 Contained Burning (Subpart X) Ammonium Perchlorate Rocket Motor Destruction (ARMD) The Ammonium Perchlorate Rocket Motor Destruction (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. Deteriorated, uncased propellant comprises a significant portion of the TEAD 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 for a significant portion of TEAD's munitions waste stream. 7 .1.10 Contained Burning (Subpart X) Dl00 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 DD ESB 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. Alternative Technologies Evaluation Tooele Army Depot 16 ' • Note that the CDC (Donovan Chamber) has not, at any location, been demonstrated as a safe or sustainable 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. Decineration has been tested on select munition items in an RDTE environment but has never been reliably operated in a true demil operations environment . 7.1.12 Industrial Super Critical Water Oxidation 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 pr<;>perties 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 for this use at a production level suitable for the Demilitarization Alternative Technologies Evaluation Tooele Army Depot 17 ' • • Enterprise. A RCRA Subpart X permit application for this unit was submitted to KDE P'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 Kentucky Energy and Environmental Cabinet's Environmental Protection Division (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. Although the iSCWO system had already been approved by the Kentucky Division for Air Quality as an operational unit and registered as EU24 in the revised Title Vair permit (Revision 2) issued in December 2007, BGAD has withdrawn its permit application for the iSCWO. The SCWO technology.is an available treatment process for some waste feed streams. For example, SCWO has been successfully used to process TNT-contaminated wastewater from a TNT melt-out operation. The requirement for a liquid feed and the high cost of operation limits the suitability of the process to very specific items that can be safely converted and managed as a slurry and exist in bulk (to reduce costs). 7 .1.13 Propellant Reformulation Several processes have been studied and demonstrated to effectively reformulate military grade propellant for commercial uses such as commercial explosives and fertilizer. Of note is that only specific military energetic formulations will 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 Anniston Army Depot further described below, have been shelved until such time that economic value can be derived. 7.1.8.1 Blasting Agent 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 h, 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 Alternative Technologies Evaluation Tooele Army Depot 18 ' • • plans to pursue the BAM process as a safe and sustainable alternative to OB at Hawthorne Army Depot. 7 .1.8.2 Slurry Explosion Module (SEM) and Energetics Processing Module (EPM), Anniston Army Depot Two major planned modules to the Missile Recycling Center at Anniston Army Depot 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. 7.1.8.3 Propellant Conversion to Fertilizer (PCF) This process involves chemically converting excess gun propellant into fertilizer using a proprietary a-HAX reagent. Water-wet propellant is reacted with 3 percent humic acid in aqueous solution (Actosol) and potassium hydroxide to denitrate the propellant. After denitration, nitrate and nitrite are incorporated into the humic acid molecular matrix by a chelation process. This results in the Actosol 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 bringing the prototype system to a Demi I production readiness level. 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 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, it has been used to process vast quantities of aluminum bodied CAD/PAD items within the Demil stockpile. However, these aluminum bodied items have almost 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. The caustic process has proven to no longer be an available option for Tooele Army Depot due to the depleted stockpile of aluminum bodied Alternative Technologies Evaluation Tooele Army Depot 19 ' • • munitions, The Hydrolysis machine has been emptied, cleaned and partially dismantled, and is in the midst of the closure of the environmental permitting. Please note what equipment is remaining has not been utilized since March of 2015. 7.1.15 Cr yofracture 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 su ch 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 destr uction of small munitions items at Yuma Proving Ground and McAlester Army Ammunition Plant. 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 Tr eatment 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 exiti ng 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 and reliability 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 M uniRem Muni Rem is a reagent formulation that uses reduction chemistry to neutralize and degrade explosive s 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 Alternative Technologies Evaluat ion Tooele Army Depot 20 I • • Nitroglycerin. Demonstrated use includes neutralization of recovered bulk explosives and decontamination of munitions casings or equipment contaminated with energetic materials. 7.1.18 Soukos Castalia Demilitarization System Soukos is currently working on permitting and contracting of the Castalia Demilitarization System for demilitarization of US Government assets at TEAD. Preliminary steps have been taken to include discussions with the State of Utah concerning modifications to the RCRA Part B permit for TEAD South, and baseline sampling plans. However, at this time, no permits have been approved, construction of the facility at TEAD has not been completed, the Castalia Demilitarization System has not completed manufacturing, and the status on when it will be available to the USG is unknown. The Soukos Robots Demil USA Castalia system is a high-rate, continuously operated demilitarization system for conventional ammunition. The system is comprised of equipment within five modules that are interconnected with flexible piping as well as power and control cables. Ammunition enters a rotary feed system and is dropped into an armored destruction chamber filled with emulsion fluid that is being pumped in a turbulent flow and exposed to electromagnetic (EM} energy pulses. The EM pulses impart a high rotational spin and velocity on the ammunition inside the chamber causing them break apart due to repeated impacts with the destruction chamber walls and other ammunition pieces remaining in the chamber. This process acts to very rapidly expose the energetic materials to the emulsion solution which uses a hydrolysis neutralization reaction both in the destruction chamber and throughout the emulsion supply loop. The emulsion fluid is continuously pumped through the system at very high rates. A perforated grate at the bottom outlet of the destruction chamber allows metal pieces smaller than the grate openings will exit the destruction chamber. The emulsion solution with energetic hydrolysis products as well as suspended solid energetic materials continues from the destruction chamber into a cyclone separator which separates the suspended solids and more dense liquids from the water-based emulsion solution. The slurry then enters an electric arc as a secondary destruction process, while the lighter, emulsion is recycled back to the emulsion supply tank. The electric arc consists of two electrodes with a very high voltage differential and an air stream passing through the gap between the electrodes. The air stream acts as the plasma gas created by the electric arc. The slurry containing energetics is sprayed into this plasma gas which is greater than 2,000 °C which means that all organics will be destroyed. Exhaust leaving the electric arc unit will enter a thermal oxidizer using ambient air to assure the complete breakdown in the presence of oxygen is occurring with all the exhaust components. This is followed by an oxidation chamber where ambient air is used to cool the exhaust and provide additional oxygen to the exhaust components. The exhaust then is treated in a catalytic converter where it is sprayed with another, separate supply of high pH emulsion fluid to neutralize any acids re-formed during the hydrolysis process. This second emulsion supply is not connected to the destruction module emulsion loop and will be free of energetic materials or products of neutralization. The cooled and neutral exhaust then goes through a salt removal Alternative Technologies Evaluation Tooele Army Depot 21 I • • process followed by a dehumidification step before passing through a bank of particulate and carbon filter beds prior to release. Metals from the munition bodies exit the destruction module and are taken via an enclosed metal conveyor to a thermal treatment unit using induction heating. Metals will be heated to 538°C for a period of 15 minutes to assure destruction of residual chemical agent and energetics. 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 . Alternative Technologies Evaluation Tooele Army Depot 22 ' • • 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. As one part of the larger Demilitarization Enterprise, TEAD supports the Office of the Product Director for Demilitarization in execution of the demilitarization mission. Specific TEAD support functions that advance the recommendations above include: • Identify opportunities for expanding the use of alternative technologies through RDT&E funds. For example, TEAD has identified an opportunity for RDT&E funds to support engineering upgrades to its APE-1236 rotary kiln incineration furnace that would increase production levels when operating the system in a burn configuration (i.e., breach loading door). Current efforts across the industrial base APE-1236 improvements include modifying the feed system, upgrading the pollution abatement system, and other minor modifications. (Recommendation 2-1). • Conduct technology evaluations to identify candidates suitable for TEAD munitions waste stream (Recommendations 2-2 and 7-1). • TEAD continues to identify opportunities for expanding the applicability of the APE- 1236 to include other munition types, frequency, and amounts that can be treated. Treatability Studies are conducted in coordination with UDEQ to evaluate the use of the APE-1236 for additional items. This is a time-consuming and inefficient process, especially considering this is performed on each individual item being targeted for treatment. It is worth noting that TEAD would like to explore alternative approaches for identifying and adding items for the APE-1236 in a more efficient manner with UDEQ .. (Recommendation 6-1) • TEAD works closely with UDEQ regulators in all matters regarding RCRA permitting to include subpart x alternative technology considerations. Tooele has been in the process of permitting the Soukos Castilia Alternative Tech operation which includes Alternative Technologies Evaluation Tooele Army Depot 23 ' • I emissions test and modeling, permit modifications, and system testing, all of which are done with cooperation of TEAD and the State of Utah. (Recommendation 6-2) • TEAD is responsive to the Office of the Product Director requests generally tasked through the demilitarization support offices at JMC headquarters for data calls to address various logistical considerations and life cycle costs that will enable decision- making for the use of alternative technologies and plans. (Recommendation 9-1 and 9-2) • Tooele Army Depot Public Affairs Office (PAO) has implemented a local community outreach program through Tooele Army Depot (TEAD) website, social media pages, and local communication platforms. These initiatives have been effective in reaching out to the public for addressing concerns and questions with the Open Burn/Open Detonation (OB/OD) operations. TEAD information platforms are used for posting/publishing permit related documents to keep citizens updated on the legal status and restrictions for the conventional munitions demilitarization operations. (Recommendation 9-3) Through annual news releases, information posted on the TEAD public website and social media pages, the PAO makes itself known as the primary phone contact for community citizens wanting more information or wishing to voice their concerns. As such, the PAO is in direct contact with local citizens whose lives are being impacted. While this particular function cannot be labeled proactive, it is a critical element in assuring the community that they can talk to someone who understands their concerns and can help explain the demilitarization process and the overall mission. The PAO provides callers with a claim form for either personal injury or property damage as well as other helpful information. o Annual early spring news release to local media announcing start of new season. o In-person and phone interviews with local radio and television media explaining the mission and the safety surrounding the operations. o Daily "pinned-to-the-top" postings on the TEAD social media pages that provide local citizens awareness detonation plans and when the detonations can be expected. o The posting of information brochures and documents on the TEAD public website that allows the reader to gain a deeper understanding of military demilitarization and the potential environmentally friendly alternatives that are being looked at for the future (in process of updating outdated information). In addition to citizens becoming more knowledgeable of TEAD conventional demilitarization mission, it allows for a better understanding in an effort to result in fewer upset citizens and less complaint calls. Alternative Technologies Evaluation Tooele Army Depot 24 ' • • 8.0 RECOMMENDATIONS TEAD, in coordination with JMC, continues to evaluate alternatives to OB and OD that are available for implementation. This alternative technology evaluation, as well as the independent evaluations being performed by other JMC installations, are living documents. Therefore, the information in this and other documents may change based on new or updated information and/or evaluations. In order to comply with TEAD's RCRA permit, TEAD will submit annually, a report with the evaluation of alternatives to OB/OD units. This report will include an analysis of technologies and evaluate their feasibility, and sustainability with regards to technical and economical considerations and the impact to employee health and safety. If an alternative is not considered then TEAD will be required to rationalize the reason for this rejection. The evaluation of alternatives includes both the feasibility of implementing the technologies at TEAD and shipping suitable munitions to other installations for demilitarization as required by the TEAD RCRA part A/B Permits. Based on the 2023 re-evaluation of alternative technologies as summarized in Table 3, four technologies were recommended for consideration at TEAD as alternatives to OB/OD: • Contained Burning (Subpart X) Thermal Treatment of Bulk Propellant (CB) • Dl00 CDC (in Static Fire Configuration) • Incinerator (EWI, APE-1236 Rotary Kiln) • Static Detonation Chamber (SDC) These are further discussed below. CB: The advancement of safe and reliable CB technology has the potential to most significantly reduce TEAD's reliance on OB. CB technology including batch or continuous feed CB systems have been demonstrated for destruction of deteriorated and stable propellants. The primary challenge associated with the Demilitarization Enterprises' existing CB technology centers around the difficulty of feeding bulk propellants and their propensity to flash when being fed into existing thermal processes. Bulk propellants have been fed into APE 1236 furnaces in the past using small consumable cups in an effort mitigate the risk of flashing at feed. But this approach is extremely inefficient and still exposes personnel to unacceptable risks over time. Nor can it accommodate the quantities and timeliness needed for disposing of unstable bulk propellants that exhibit a potential safety risk in storage. There are, however, CB technologies available through commercial demilitarization contracts that can treat certain bulk propellants. Market research is on-going by TEAD to evaluate CB technology to develop potential investment strategies within PD Demi I and the Joint Munitions Command/ Army Materiel Command. D100 CDC in Static Fire Configuration: The DlO0 CDC is an existing and permitted alternative treatment technology at BGAD. The reliability and maintainabilityof the CDC in detonation Alternative Technologies Evaluation Tooele Army Depot 25 ' • • configuration, however, has not proven operationally sustainable over time. In addition, and as previously noted in Section 1, repurposing of the CDC system at BGAD for CB of rocket motors (i.e., uncontaminated M67 rocket motors generated during MSS rocket demilitarization campaigns at the BGCAPP facility) has yet to be completed. Production-level demonstration is a key component to advancing the DlO0 CDC technology for use in a controlled burn configuration and BGAD has secured the necessary resources to facilitate such a demonstration to prove-out the technology for demilitarization of double-based propellant rocket motors (no warhead). Until the DlO0 CDC reliability and maintainability can be further verified in a relevant production demil operations environment for extended periods of time without a significant failure it is not considered a sustainable technological solution for TEAD waste streams. Specifically, the igniter dud rate issue that was observed during the pilot scale testing and likely modifications to the system to support production level demilitarization operations would need to be resolved before transitioning the concept to production operations. Continued testing of the DlO0 CDC for this new static fire application is ongoing. Incineration : As mentioned in section 7.1.2, A rotary kiln incinerator/rotary kiln deactivation furnace is an incineration technology in use by the Army and also available in several unique commercial designs with pollution abatement systems that can be tailored to address specific waste stream emission profiles. The Army's own version, the APE (Army Peculiar Equipment) 1236 Deactivation Furnace (a rotary kiln incinerator with a thick walled combustion chamber), Is currently in operation at TEAD under their RCRA Subpart A/B permit. SOC: There are ongoing discussions between JMC, the Joint PEO Armaments and Ammunition and the PEO Assembled Chemical Weapons Alternatives (ACWA) regarding the feasibility of reusing one of the SDC units currently in use at BGAD to support the chemical demilitarization mission at the BGCAPP. The overall feasibility of reusing one of the specially designed SDC units for conventional demilitarization at BGAD is still under strategic and technical evaluations but are expected to be completed well before the SDC unit would be available for reuse, which is currently expected to be in the FY 2026 timeframe. The reuse of the PEO ACWA SDC unit is primarily contingent upon the unit's ability to be transitioned to and reconfigured for conventional demilitarization munition items while remaining in good working order after its years of chemical demilitarization support. The SDC can treat a broad spectrum of demilitarization stockpile items, including some bulk propellants. However, reliability and maintainability of SDC units on a variety of standard conventional munition items, including those that produce high over pressures and fragmentation continue to be a concern from both a systems safety and availability perspective. 9.0 SUMMARY There are several ongoing initiatives to expand or considerations to expanding CDT approaches within the Demilitarization Enterprise, including at TEAD. 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 Alternative Technologies Evaluation Tooele Army Depot 26 I • • 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 feasible production-ready capability 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 investments (i.e., construction costs of over $200M) currently being made 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 develop new CB capability within the Demil 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. These ongoing RDT&E efforts involve updates to existing CDT feed systems and approaches (including slurry feeding) and upgrades to pollution abatement systems to better accommodate the burn rates of bulk propellants verses HE. Work loading among the organic base and commercial capabilities are made at the Command level and therefore no accurate implementation schedule can be offered at this time. 10.0 SCHEDULE The following tentative schedule is proposed in furtherance of the identification and implementation of alternative technologies at TEAD. Currently, the Office of the Project Director for Joint Ammunitions Weapons Systems is completing a study to assess technologies and develop overall Enterprise-wide technology needs. This study is anticipated to take 24 months to complete. Funding requirements and schedules are deliverables under this study . Alternative Technologies Evaluation Tooele Army Depot 27 I • • 11.0 REFERENCES Tooele Army Depot-North Area {TEAD) 2023. TEAD Hazardous Waste RCRA Part B permit Module I1.L RECORDKEEPING AND REPORTING, General Facility Conditions. EPA ID #UT3213820894 Tooele Army Depot-North Area {TEAD) 2019. TEAD Hazardous Waste RCRA Part B permit Module VI.G Environmental Monitoring Requirements, Open Burn open Detonation, EPA ID# UT3213820894 Tooele Army Depot-South Area {TEAD) 2018 . TEAD Hazardous Waste RCRA Part B permit Module VII Attachment 2 Environmental Performance Standards, Open Detonation, EPA ID# UT5210090002 Blue Grass Army Depot {BGAD), 2017a. BGAD Hazardous Waste Facility Permit RCRA Hazardous Waste Treatment Permit Application for Conventional Munitions by Open Burning and Open/Buried Detonation, EPA ID# KY8-231-820-105, Volume I and Volume II. June . BGAD, 2017b. Air Modeling and Risk Assessment for the Open Burning Unit, Open Detonation/Buried Detonation Unit, and Controlled Destruction Chamber. June. Joint Ordnance Commanders Group {JOCG) 2019. Optimization of Department of Defense Open Burning/Open Detonation Units. March. Kentucky Department for Environmental Protection {KDEP), 2019. KDEP , Division of Waste Management, Open Burn/Open Detonation Permit, USEPA ID #KY8-213-820-105 and Class 1 Modification thereto. May. National Academies of Sciences, Engineering, and Medicine {NASEM), 2018. Alternatives for the Demilitarization of Conventional Munitions. Washington, DC: The National Academies Press. doi: 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 . Alternative Technologies Evaluation Tooele Army Depot 28 I • • 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. 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. Alternative Technologies Evaluation Tooele Army Depot 29 I • • Table 2. Initial Screening of Alternative Technologies 7.1.1 7.1.1 7.1.1 7.1.2 7.1.2 7.1.2 7.1.3 Contained Detonation -D100 CDC in Detonation Cased HE up to 45 lbs. NEW Configuration including donor, Submunitions Contained Detonation -Detonation of Ammunition in a Cased HE up to 132 lbs. NEW Vacuum Integrated Chamber (OAVINCH) including donor Contained Detonation -Explosive Destruction System (EDS) Contained Burning (Subpart 0)-Employing Incineration Explosive Waste Incinerator Cased HE up to 9 lbs. NEW including donor Stable, uncased propellant Contained Burning {Subpart O) -Employing Stable, uncased propellant Incineration Bulk Energetics Disposal System [BEDS] Contained Burning (Subpart 0)-Employing Very small Net Explosive Weight Incineration (NEW) munitions items (e.g., Rotary Kiln/Army Peculiar Equipment (APE) 1236 small arms ammunition, fuzes) Contained Burning (Subpart X) -Static Kiln and Thermal Submunitions Treatment of Submunitions Alternative Technologies Evaluation Tooele Army Depot Yes-The TEAD Demi\ waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Yes-The TEAD Demil waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Yes-The T£AD Demil waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Yes-The TEAD Demil waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Yes-The TEAD Demil waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Yes-The TEAD Oemil waste stream could potentially include the candidate waste stream for which the Alt Tech is a licable Yes-The TEAD Demil waste stream could potentially include the candidate waste stream for which the Alt Tech is applicable Currently not in use within the DOD Not recommended for further assessment Demilitarization Enterprise for detonation configurations due to issues with system reliability and maintainability after repeated use over time. Demonstrated and in use outside of the Not recommended for further assessment. DoD. Reliability and maintainability issues are anticipated based on past experience with contained detonation system performance in a DoD operations environment where large volumes of energetic materials are being treated at high fr uencies. Currently not in use within the DOD Not recommended for further assessment. Demilitarization Enterprise due to issues with system reliability and maintainability after repeated use in a demil operations environment .. Demonstrated and in use in different Recommended for further assessment (see configurations and waste stream treatment Table 3). applicability within the DoD. The BEDS system was developed in the Not recommended for further assessment. 1990s but was never demonstrated at demil production levels. The feasibility and technical challenges associated with mixing, feeding and burning water based slurries proved problematic from both a safety and technical ers ctive. Demonstrated and in use at TEAO Recommended for further assessment (see Table 3). Unique technology that is owned/ operated Not recommended for further assessment. by an off-site commercial demil facility but applicable to only specific submunition items that are not lanned for demi! at TEAD 30 I • • 7.1.5 7.1.6 7.1.7 7.1.8 7.1.9 7.1.10 7.1.11 Contained Burning (Subpart X) -Thermal Treatment Closed Disposal Process (TTCDP) Contained Burning (Subpart X) -Dyna safe Static Detonation Chamber (SOC) Dynasafe Munitions Destruction System (MDS) Contained Burning (Subpart X)-Ammonium Perchlorate Rocket Motor Destruction (ARMD) Facility waste stream is not a current or reasonably anticipated future workload Submunitions Yes-The TEAD Demil waste stream could potentially include the Candidate waste stream for which the Alt Tech is applicable Propellant up to approximately Yes-The TEAD Demit waste stream 24 pounds (lbs.) NEW could potentially include the candidate waste stream for which the Alt Tech is applicable Very small NEW munitions items Yes-The TEAD Demil waste stream (e.g., fuzes) could potentially include the candidate waste stream for which the Alt Tech is a plicable large, Ammonium Perchlorate Not Applicable-The candidate (AP) Rocket Motors waste stream is not a current or reasonably anticipated future workload Contained Burning (Subpart X) -Thermal Treatment of Stable and deteriorated uncased Yes-The TEAD Demil waste stream Bulk Propellant (Batch or Continuous Feed) propellant could potentially include the candidate waste stream for which the Alt Tech is applicable Contained Burning (Subpart X) -D100 CDC in Static Small, Non-AP Rocket Motors Yes-The TEAD Demil waste stream Burn Configuration without warheads could potentially include the candidate waste stream for which the Alt Tech is applicable Decineration Fuzes, cartridges, primers, Yes-The TEAD Demil waste stream blasting caps, small arms could potentially include the ammunition candidate waste stream for which the Alt Tech is applicable Alternative Technologies Evaluation Tooele Army Depot Unique technology that is owned/operated by an off-site commercial demil facility but applicable to only specific MLRS items that are not planned for demil at TEAO. Unique technology that is owned/operated Not recommended for further assessment. by a DoD facility within the Demilitarization Enterprise but applicable to only specific submunition items that are not planned for demil at TEAD Demonstrated successful for production Recommended for further assessment (see level disposal of a wide variety of munition Table 3). types within the SOC-specific NEW limits. Unique technology owned and operated by Recommended for further assessment (see DoD and incorporated for the treatment of Table 3). very small explosive components. Unique system that is owned/ operated by a Not recommended for further assessment. DoD facility and is available for use within the Demilitarization Enterprise but applicable to only large AP based rocket motors that are not planned for demil at TEAD. Currently being considered within the Recommended for further assessment (see Demilitarization Enterprise. Table 3). Demonstrated only in a pilot scale Recommended for further assessment (see environment to date with further testing Table 3). ongoing for applicability in operations environment. Not considered practicable at this time. The Not recommended for further assessment. Decineration technology has not been demonstrated in a full scale demil operations environment 31 I • • 7.1.12 General Dynamics Industrial Supercritical Water Oxidation (ISCWO) 7.1.13 Propellant Reformulation Blasting Agent Manufacturing (BAM) Facility Slurry Explosion Module (SEM) and Energetics Processing Module (EPM) Propellant Conversion to Fertilizer (PCF) 7.1.14 Caustic Hydrolysis 7.1.15 Mobile Plasma Treatment System 7.1.16 MuniRem Chemical Neutralization 7.1.18 Soukos Castilia Demilitarization System Alternative Technologies Evaluation Tooele Army Depot Stable, uncased propellant that can be safely converted to a liquid feed Stable, uncased propellant Aluminum bodied cartridge/pressure actuated devices Smaller pyrotechnics, smokes and dyes, fuzes, small arms ammunitions, and small high explosive items (less than 0.35 ounds NEW Hazard Class 1.1) Cased or uncased HE Small arms, h,zes, Smokes, cluster munitions Yes-The TEAD Demil waste stream limited available information is available to Not recommended for further assessment. could potentially include the demonstrate use for full scale operation candidate waste stream for which applicable to TEAD's propellant waste the Alt Tech is applicable stream. Safer and more reliable Alternative Technology approaches for addressing propellant waste streams in a demil operation environment now available for consideration. previous attempt to secure a RCRA operating permit for the ISCWO at TEAD was abandoned. Yes-The TEAD Demil waste stream Limited available information is available to Not recommended for further assessment. could potentially include the demonstrate use for full scale operation candidate waste stream for which applicable to TEAD's propellant waste the Alt Tech is applicable stream. Safer and more reliable Alternative Technology approaches for addressing propellant waste streams in a demil operation environment now available for consideration. Yes-The TEAD Demil waste stream This operation was in use and was at TEAD, Not recommended for further assessment. could potentially include the currently not in use and is low due to Candidate waste stream for which Depleted stockpile of aluminum bodied the Alt Tech is applicable munitions. Yes-The TEAD Demil waste stream Piolet scale system was never transitioned Not recommended for further assessment. could potentially include the or demonstrated in a full scale demil candidate waste stream for which operations environment due to a variety of the Alt Tech is applicable technical and safety challenges Ves-TheTEAD Demil waste stream Not considered at this time. Muni Rem has Not recommended for further assessment could potentially include the not been demonstrated in a production candidate waste stream for which demilitarization environment on large the Alt Tech is a plicable volumes of bulk ener etic materials. Yes-The TEAD Demil Waste stream Unique system, contractor owned and Not Recommended for further assessment. could potentially include the operated currently in the permitting and candidate waste stream for which planning phase at TEAD. the Alt Tech is applicable. 32 I • • 7.1.2 7.1.6 7.1.7 Contained l;lurl'.ling (SUllpart.O. - Employing Incineration Explosive Waste Incinerator Contained Buming.(Sui>l)art 0)- Employing Incineration Rotary Kiln/Army Peculiar Equipment (APE)l236 Contained Burning (Subpart X) - Dynasafe Static Detonation Chamber (SOC) Dynasafe Munitions Destruction System (MOS) Alternative Technologies Evaluation Tooele Army Depot Table 3. Assessment of Alternative Technologies Very small Net Explosive Weiglit (NEW) munitions iten)S (e.g., small arms ammunition, fuzes) Propellant up to approximately 24 pounds (lbs.) NEW Very small NEW munitions items (e.g., fuzes) Yes Yes No Technology resides wi.thlnthe Demll Enter11rise. Candidate waste ,streams generated at TEAD that are not prohibited from transp0rt could be (liverted to existing systems within the Demilitarization.Enterprise. The bulk of prqpellant generated at TEAO is not considered astable" APE l236is on site atTEAD unqer a RCRA Sul)part B operating permit. The system ls cutn!ntly in operation, Candidate waste streams not prohibited from transport that exist can be diverted to this system . Technology resides within the Demit EnterpriseCandidate waste streams generated at TEAD that are not prohibited from transport could be diverted to existing systems within the Demilitarization Enterprise. Though SDCs already reside within the Demil Enterprise. The feasibility of repurposing other potentially available SDCs that were originally designed for Chemical Demilitarization for use in support of Conventional Ammunition Demil (CAD) continues to be evaluated. Technology resides within the Demi! Enterprise but is utilized in a very specific application that could not accommodate the introduction of other ancillary waste streams. Another system would need to be developed and deployed to accommodate waste streams generated at TEAD 33 I • • 7.1.9 7.1.10 Contained Suring (Subpart X) - Thermal Treatment of Bulk Propellant (Batch or Continuous Feed) Contained Burning (Subpart X) -Dl00 CDC in Static Burn Configuration Alternative Technologies Evaluation Tooele Army Depot Stable and deteriorated uncased propellant Small, Non-AP Rocket Motors without warheads No Not Applicable Though the MDS already resides within the Demil Enterprise, the system is an off-the-shelf, small system that could be utilized for only infrequently generated, small NEW items. Moreover, existing closed disposal capabilities already existing at TEAD (i.e., APE 1236 Rotary Kiln) would be able to provide a more robust and flexible treatment approach for the same kind of waste streams that a MDS would be able to accommodate. TEAD burns a significant amount of stable uncased propellant. A contained burning system could result in significant diversion from the OB waste stream. The Dl00 CDC is on-site at BGAD with an in-place RCRA Subpart X operating permit. The DlO0 CDC in Static Burn Configuration is scheduled for further assessment, including emissions testing to further demonstrate its use in a demil operations environment.