Implementation of Explosive Destruction Technology for Mustard Projectiles

March 4, 2014

Presented to:

Chemical Destruction Community Advisory Board’s Explosive Destruction Technology Working Group

Presented by:

John McArthur, Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP)

Neil Frenzl, BGCAPP

Allison Respess, BGCAPP

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Explosive Destruction Technology at Blue Grass

ACWA determined it was appropriate to direct Bechtel Parsons to move forward with process to select an EDT to destroy mustard projectiles at Blue Grass

More than 15,000 155 mm mustard projectiles, with fewer than 200 in over-pack containers, along with two Department of Transportation, known as DOT, bottles containing mustard agent will be processed through the EDT

PEO ACWA decision considerations included: Environmental Assessment and resulting Finding of No Significant Impact and stakeholder involvement

BPBG awards a contract to UXB International in Nov 2013 for a Static Detonation Chamber.

Design, permitting and preparation of Site Plan Safety Submission began with first UXB technical submittals in December 2013.

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Preliminary schedule

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Activity Date Status

NEPA Process (FONSI Issued) March 2012 – Oct. 21, 2013 Completed

Limited Notice to Proceed October 30, 2013 Completed

Contract Award to UXB International, Inc. November 2013 Completed

Blue Grass Static Detonation Chamber (SDC) System Design

November 2013 - December 2014 Working

RCRA Part B Permit Modification Late February 2014 – Spring 2016 Upcoming

Title V Air Permit February 2014 – Fall 2014 Upcoming

Manufacturing, Assembly, and Factory Acceptance Testing

Spring 2014 – Spring 2015 Upcoming

Construction, Installation, and Systemization

Fall 2014 – Fall 2016 Upcoming

SDC Equipment Delivery Spring/Summer 2015 Upcoming

Start of Operations Winter 2016/Early 2017 Upcoming

End of Operations Fall 2017 Upcoming

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Activity Start Date Finish Date

Pre-application meeting announcements:newspapers, radio, T.V., mailing list

Mid March 2014 Mid March 2014

60-day public comment review and consideration period

Mid March 2014(60-days begins with publication of meeting announcements)

Mid May 2014

Submittal of Class 3 Permit Modification Request to Kentucky Department for Environmental Protection (KDEP)

Mid March 2014 Mid March 2014

KDEP review of Class 3 Permit Modification Request

Mid March 2014

Mid Sept. 2014 –application review time 365 days(divided into two periods of 6 months each) but Regulatory Review times are variable and beyond BGAD/BPBG control

Prepare and Submit to KDEP a Temporary Authorization Request to Begin Construction – (after submittal of Permit Modification Request with expeditious review as stated in Federal Regulatory Requirements)

Late March 2014 Late May 2014

KDEP review and approval of Temporary Authorization Request

Late May 2014 Late September 2014

Pre-application meeting Mid April 2014(30 days after announcements)

Late April 2014

KDEP considers and responds to public comments

Mid May 2014 Mid July 2014(generally 30 to 60 days following close of comment period)

Schedule ― Request for Class 3 Modification to BGAD RCRA Hazardous Waste (Part B) Permit

Explosive Destruction Technology –regulatory permitting process

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Explosive Destruction Technology –regulatory permitting process (cont.)

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Resource Conservation Recovery Act (RCRA) Part B Permit Application/Class 3 Modification Request

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Activity Start Date Finish Date

Prepare Title V Revision Application Early March 2014 Early March 2014

Government review/comment resolution Early March 2014 Early May 2014

KDEP deems application complete (60 day) Early May 2014 Early July 2014

KDEP issues Draft Permit (60 Day) Early July 2014 Early September 2014

Note: Cabinet must issue or deny permit within 18 months of submittal of complete application.

Schedule – Title V Air Permit, Major Modification

Explosive Destruction Technology –regulatory permitting process (cont.)

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Key Engineering attributes for permits

Selected 30 percent design documents included in Request for Class 3 Modification to BGAD RCRA Hazardous Waste Permit

Submission includes:– Process flow diagrams– Piping and instrument diagrams– Mass and energy balance

30 percent design documents reviewed and updated as part of standard engineering processes

Permit Modification Request updated once design is finalized

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Explosive Destruction Technology –Mass and Energy Balance

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Mass and Energy Balance:– The M&EBs are a summary of all the streams that enter,

pass through, and leave the system.– They must account for both mass flows and energy

requirements.– The M&EBs are included with the process flow diagrams

and are the starting blocks for the preliminary design.– They define not only the flow quantities,

but also the temperature and pressures of the streams.

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Static Detonation Chamber/Pollution Control System in Dynasafe workshop

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Pollution Control SystemISO Containers

SDC 1200 C with steel structure

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Static Detonation Chamber 1200 C similar to BGCAPP unit

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Questions/Discussion