Implementation of Explosive Destruction Technology for Mustard Projectiles March 4, 2014
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The document summarizes plans to implement an explosive destruction technology (EDT) to destroy over 15,000 mustard projectiles at the Blue Grass Chemical Agent-Destruction Pilot Plant (BGCAPP). BGCAPP awarded a contract to UXB International in November 2013 to provide a static detonation chamber (SDC) for this purpose. Regulatory permitting processes are underway, including a RCRA Part B permit modification and Title V air permit revision. Key engineering documents like process flow diagrams, piping and instrumentation diagrams, and mass and energy balances will be included to support permit applications. Operations are scheduled to begin in winter 2016/early 2017 once the SDC system has been designed, constructed, tested, and permitted.
Implementation of Explosive Destruction Technology for Mustard Projectiles March 4, 2014
- 1. 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
- 2. A Partnership for Safe Chemical Weapons Destruction 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. 2
- 3. A Partnership for Safe Chemical Weapons Destruction Preliminary schedule 3 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
- 4. A Partnership for Safe Chemical Weapons Destruction 4 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
- 5. A Partnership for Safe Chemical Weapons Destruction Explosive Destruction Technology – regulatory permitting process (cont.) 5 Resource Conservation Recovery Act (RCRA) Part B Permit Application/Class 3 Modification Request
- 6. A Partnership for Safe Chemical Weapons Destruction 6 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.)
- 7. A Partnership for Safe Chemical Weapons Destruction 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 7
- 8. A Partnership for Safe Chemical Weapons Destruction Explosive Destruction Technology – Mass and Energy Balance 8 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.
- 9. A Partnership for Safe Chemical Weapons Destruction Static Detonation Chamber/ Pollution Control System in Dynasafe workshop 9 Pollution Control System ISO Containers SDC 1200 C with steel structure
- 10. A Partnership for Safe Chemical Weapons Destruction Static Detonation Chamber 1200 C similar to BGCAPP unit 10
- 11. A Partnership for Safe Chemical Weapons Destruction 11 Questions/Discussion