Summary

DESTRUCTION OF THE U.S. CHEMICAL STOCKPILE

The Department of Defense, through the Assembled Chemical Weapons Alternatives (ACWA) program, is currently in the process of constructing two full-scale pilot plants at the Pueblo Chemical Depot in Colorado and the Blue Grass Army Depot in Kentucky to destroy the last two remaining inventories of chemical weapons in the U.S. stockpile. Destruction of this stockpile, originally comprising over 31,000 tons of chemical agents stored at eight chemical weapons depots in the continental United States and on Johnston Island in the Pacific Ocean (southwest of Hawaii), has been ongoing for two decades, and is being performed in accordance with requirements of the Chemical Weapons Convention treaty, to which the United States is a signatory. Approximately 10 percent of the original stockpile is stored at the Pueblo Chemical Depot and the Blue Grass Army Depot, with approximately 90 percent stored at sites being served by the U.S. Army Chemical Materials Agency (CMA) disposal facilities. As of January 12, 2011, the CMA had destroyed 83 percent of the stockpile being treated at its facilities.1

Disposal operations at the six other continental U.S. sites and Johnston Island, managed by the CMA, either have been completed or are nearing completion. The disposal facilities at these sites were either based on incineration technology to destroy the chemical agents and associated energetics (propellants and/or explosives) or used chemical neutralization (hydrolysis) to destroy nerve and mustard agents stored in bulk containers.

In contrast, the Pueblo and Blue Grass Chemical Agent Destruction Pilot Plants (PCAPP and BGCAPP) will use neutralization technology to destroy the agents that are contained in various types of assembled chemical munitions—that is, rockets, projectiles, and mortar rounds. Consequently the processing equipment employed at PCAPP and BGCAPP will be newer or of different design than the equipment at the other disposal facilities. These pieces of process equipment are referred to as first-of-a-kind (FOAK) equipment. The FOAK equipment the committee believes could pose the most significant challenges to operations at PCAPP and BGCAPP is described in Table S-1.

For reasons such as the use of FOAK equipment and, more broadly, in recognition of the need to conscientiously adhere to congressional mandates that destruction of chemical agent and munitions be executed with maximum protection for workers, the public, and the environment, the Program Manager for Assembled Chemical Weapons Alternatives requested that the National Research Council (NRC) undertake a study to guide the development and application of process safety metrics for PCAPP and BGCAPP. Another reason for requesting this report was the NRC report issued in 2009 Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities, which responded to a request by the CMA for recommendations on additional metrics

1

See http://www.cma.army.mil/home.aspx for updated information as the program progresses.



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Summary DESTRUCTION OF THE U.S. CHEMICAL agents and associated energetics (propellants and/or STOCKPILE explosives) or used chemical neutralization (hydroly- sis) to destroy nerve and mustard agents stored in bulk The Department of Defense, through the Assembled containers. Chemical Weapons Alternatives (ACWA) program, is In contrast, the Pueblo and Blue Grass Chemical currently in the process of constructing two full-scale Agent Destruction Pilot Plants (PCAPP and BGCAPP) pilot plants at the Pueblo Chemical Depot in Colorado w ill use neutralization technology to destroy the and the Blue Grass Army Depot in Kentucky to destroy agents that are contained in various types of assembled the last two remaining inventories of chemical weap- chemical munitions—that is, rockets, projectiles, and ons in the U.S. stockpile. Destruction of this stockpile, mortar rounds. Consequently the processing equipment originally comprising over 31,000 tons of chemical employed at PCAPP and BGCAPP will be newer or of agents stored at eight chemical weapons depots in the different design than the equipment at the other dis- continental United States and on Johnston Island in the posal facilities. These pieces of process equipment are Pacific Ocean (southwest of Hawaii), has been ongoing referred to as first-of-a-kind (FOAK) equipment. The for two decades, and is being performed in accordance FOAK equipment the committee believes could pose with requirements of the Chemical Weapons Conven- the most significant challenges to operations at PCAPP tion treaty, to which the United States is a signatory. and BGCAPP is described in Table S-1. Approximately 10 percent of the original stockpile For reasons such as the use of FOAK equipment and, is stored at the Pueblo Chemical Depot and the Blue more broadly, in recognition of the need to conscien- Grass Army Depot, with approximately 90 percent tiously adhere to congressional mandates that destruc- stored at sites being served by the U.S. Army Chemi- tion of chemical agent and munitions be executed with cal Materials Agency (CMA) disposal facilities. As of maximum protection for workers, the public, and the January 12, 2011, the CMA had destroyed 83 percent environment, the Program Manager for Assembled of the stockpile being treated at its facilities.1 Chemical Weapons Alternatives requested that the Disposal operations at the six other continental National Research Council (NRC) undertake a study U.S. sites and Johnston Island, managed by the CMA, to guide the development and application of process either have been completed or are nearing completion. safety metrics for PCAPP and BGCAPP. Another The disposal facilities at these sites were either based reason for requesting this report was the NRC report on incineration technology to destroy the chemical issued in 2009 Evaluation of Safety and Environmental Metrics for Potential Application at Chemical Agent Disposal Facilities, which responded to a request by 1See http://www.cma.army.mil/home.aspx for updated informa - the CMA for recommendations on additional metrics tion as the program progresses. 1

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2 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS TABLE S-1 First-of-a-Kind Equipment and Processes That Could Pose Significant Challenges for PCAPP and BGCAPP FOAK Equipment Site(s) Function Notes Rocket cutting machine BGCAPP To separate rocket motors from This is an entirely new piece of (RCM) the warhead. equipment. Linear projectile mortar BGCAPP To disassemble projectiles This is a new unit that replaces the disassembly (LMPD) PCAPP and mortars and remove their PMD machine used at the baseline machine bursters. incineration sites operated by CMA. Munitions washout station BGCAPP To remove the burster well This is an entirely new piece of (MWS) PCAPP from projectiles, drain the equipment. It replaces the PMD chemical agent, and wash out machine used at the baseline any agent residues. incineration sites operated by CMA. Energetics batch hydrolyser BGCAPP To neutralize energetics and This is an entirely new piece of (EBH) any chemical agent in the metal equipment. parts of the rockets and fuzes from projectiles. Metal parts treater (MPT) BGCAPP To decontaminate projectile This is an entirely new piece of bodies and secondary waste equipment. by heating to over 1000°F for more than 15 minutes. Munitions treatment unit PCAPP To decontaminate projectile This is an entirely new piece of (MTU) bodies and secondary waste equipment. by heating to over 1000°F for more than 15 minutes. Supercritical water BGCAPP To treat agent and energetics This is an entirely new piece of oxidation (SCWO) hydrolysates before releasing equipment and process. them for final disposal. Immobilized-cell PCAPP To treat mustard hydrolysate This is an entirely new piece of bioreactors (ICBs) before releasing it for final equipment and process. disposal. that could further improve the safety and environmental American Institute of Chemical Engineers, etc.) that could be used by ACWA. programs at those sites. The statement of task for the Committee to Assess As previously indicated, both PCAPP and BGCAPP Process Safety Metrics for the Blue Grass and Pueblo will use chemical neutralization technology instead Chemical Agent Destruction Pilot Plants (the commit- of incineration to destroy chemical agents and, in the tee) is the following: case of BGCAPP, to destroy certain energetics. Neu- tralization involves the hydrolysis of chemical agent The National Research Council will establish an ad hoc and energetics using hot water for mustard agent and committee to: caustic for nerve agent and energetics. PCAPP plans • eview and evaluate plans for the use of process safety R to ship the energetics removed from munitions for metrics to be employed at the two Assembled Chemical disposal offsite and will use biotreatment to destroy Weapons Alternatives (ACWA) pilot plant facilities, the products of mustard agent neutralization, known as • xamine and assess the process safety metrics used in E hydrolysate. BGCAPP will use neutralization followed commercial and industrial operations for potentially ap- by the treatment of the resultant agent and energetics plicable process safety metrics, and • ssess new initiatives at national organizations (i.e., A

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3 SUMMARY BACKGROUND INFORMATION RELATED TO hydrolysates by supercritical water oxidation.2 Imple- PROCESS SAFETY METRICS mentation of these primary and secondary destruction methods also entails numerous ancillary processes and There are two types of process safety metrics: lead- activities—for example, munitions disassembly and ing and lagging.3 Defining appropriate and effective waste management, which in turn require the use of leading and lagging process safety metrics has been additional FOAK equipment and processing. a subject of great interest in recent years, particularly The term FOAK implies the use of new technologies in the chemical and petroleum industries, since those or new applications of existing technologies that could industries handle or produce reactive, toxic, and flam- be problematic with respect to functionality, reliabil- mable materials that, if released, can cause multiple ity, availability, and maintainability. This means that fatalities and/or injuries and have significant envi- adjustments ranging from procedural modifications to ronmental consequences. Further details on efforts varying degrees of redesign might be required as such to formalize and implement industrywide approaches equipment is developed, tested, and integrated into to process safety metrics are provided in Chapter 4. actual agent processing operations. One example of A good example of a lagging process safety metric FOAK equipment, the linear projectile mortar disas- that has been in use for over a decade is the number sembly machine, is undergoing testing at the Annis- of unplanned major chemical or energy releases. This ton Chemical Agent Disposal Facility. As a result of metric has included unintended releases of hazardous this testing, 164 specific operating criteria have been chemicals that exceed the threshold quantity listed in reviewed, 20 documented lessons learned will be 40 CFR 302.4, which designates CERCLA4 hazardous applied to the design and operation of the system at substances or events that result in serious injury or PCAPP, and more than 110 significant code changes damages in excess of $25,000. have been identified. Although not all FOAK equip- While many of the processes that will be employed ment will be tested in an operational setting prior to for the disposal of chemical agent and munitions at systemization, as the linear projectile mortar disassem- PCAPP and BGCAPP are fundamentally different bly machine has been, laboratory testing and evaluation from those used at the other chemical agent disposal of all FOAK equipment is performed to identify issues facilities, some similarities do exist with the processes and needed adjustments before the equipment is placed that have been employed at those sites. The committee in operation. believed that evaluating the experience with process PCAPP and BGCAPP will both undergo preop - incidents at those other sites could prove useful and erational systemization before starting actual agent would offer guidance on what process safety metrics disposal operations. Systemization involves progres- might be useful for PCAPP and BGCAPP. The com- sive testing—from the demonstration of components mittee further believed that an analysis of relevant to subsystems to the entire system, using surrogate chemical events at those sites could provide insights munitions—to bring each system to its fully operational on the process steps and operational systems that are design function. Both facilities will follow a progres- most subject to failure, and might identify opportunities sion of steps consisting of the installation of process where the use of leading and lagging metrics could help equipment, integration of process equipment, and to prevent failures. overall plant operation using agent surrogates instead of The NRC Committee on Evaluation of Chemical actual chemical agent. During this phase of the project, Events at Army Chemical Agent Disposal Facilities the systems used to operate the plant will be tested and (the chemical events committee) examined documen- configured. tation on all of the chemical events that had occurred since commencement of destruction operations through the end of 2001 and issued its report, Evaluation of Chemical Events at Army Chemical Agent Disposal 3“Leading metric” and “lagging metric” are defined in Appendix A. 2Neutralization 4CERCLA is the Comprehensive Environmental Response, Com- was used to destroy the chemical agents at two other sites, at Aberdeen Proving Ground, Maryland, and Newport, pensation, and Liability Act, commonly known as Superfund; 40 Indiana. These two sites, however, had only bulk agent stored in CFR 302.4 lists dangerous chemicals and gives threshold quantities ton containers, not assembled munitions. for the purpose of defining a process safety incident.

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4 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS Facilities, in 2002. The present committee reviewed • quipment malfunction. This was the second most E that report to identify which of the events could be prevalent causal factor at other chemical agent classified as process incidents. It also requested an disposal facilities, approximately 26 percent of update on process-related chemical events from all cur- the total. While the definition of equipment mal- rently operating sites and from the sites that completed function used at these facilities did not include destruction after 2001. Significantly, the frequencies design deficiencies, it should be noted that design of incident types, activities, and causal factors for deficiencies caused equipment malfunctions in process-related chemical events since 2001 mirror some instances. Equipment malfunctions and those that were noted in the 2002 Chemical Events design deficiencies together were involved in report. From these data, it appears that the frequency approximately 31 percent of the total incidents and type of factors that cause process safety events are reviewed. Conducting design audits and basing independent of the type of facility (neutralization or metrics on the results could assist in finding incineration), the type of chemical weapon (mustard design deficiencies before they cause an equip- agent or nerve agent), or how the agent is stored (in ment malfunction or other process incidents or assembled munitions or bulk). Consequently, PCAPP upsets. A system of process safety-critical equip- and BGCAPP can reasonably be expected to experience ment inspections is key to minimizing equipment the same types of events that have similar causal fac- malfunctions. tors. However, because the processes to be employed • uman factors (human error, mindset, and H at PCAPP and BGCAPP are unique, and FOAK equip- improper technique). H uman factors, which ment will be used extensively, it may be reasonable to include the three causal factors listed in the paren- expect more events at the outset and a possible shift in theses above, altogether accounted for approxi- the frequency of causal factors. For example, design mately 37 percent of the causal factors. Metrics deficiencies might be more prevalent in new facilities derived from training activities and job cycle with new equipment, processing steps, and unit opera- checks could be useful in developing actions to tions than in older or second-generation facilities using mitigate these types of causal factors and to iden- proven, refined technologies and processes. Some of tify areas where annual or more frequent periodic the personnel who will systemize and operate PCAPP training should be improved or changed. and BGCAPP will come from operating chemical • ommunications deficiencies. This causal factor C demilitarization facilities, providing an experience base made up approximately 4 percent of the total. in chemical demilitarization at the two sites. These types of deficiencies are not typically documented until after a failure, but they should be considered as integral to a full complement of DERIVING PROCESS SAFETY METRICS process safety metrics. Among the possibilities RELEVANT TO PCAPP AND BGCAPP are audits of communications systems (active The committee’s examination of causal factors and passive) and documenting communications related directly to earlier experience with chemical failures. agent and munition destruction provides an excellent basis for the development of process safety metrics at Based on experience, a number of leading metrics PCAPP and BGCAPP. Some key causes of process recommended in the documents of the Center for safety incidents at former and currently operating Chemical Process Safety and the American Petroleum chemical agent disposal facilities identified from that Institute and discussed in Chapter 4 could also be rel- experience are discussed below. evant to PCAPP and BGCAPP. These leading metrics include process safety near-miss events, closure of action items, completion of emergency response drills, • tandard operating procedure (SOP) deficiencies. S SOP deficiencies were the most prevalent causal management of change, and metrics related to other factor identified, approximately 27 percent of the management systems. total. For PCAPP and BGCAPP, developing and Managerial leadership is responsible for setting the implementing metrics that enable early identifica- tone and articulating performance expectations in an tion and avoidance of deficiencies in SOPs could organization. When process safety metrics are set for be very useful. an organization, the operation’s line leadership must

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5 SUMMARY set performance milestones and regularly review the ing causal factors similar to those experienced at the operation’s performance against those milestones with Chemical Materials Agency sites. Also, there may be the organization’s managerial leadership. Furthermore, an increase in the frequency of events and a shift in the the chemical, petroleum, and related industries have relative frequency of causal factors. learned that maintaining a staff of trained process Finding 4-1. At the present time, there is no defini- safety professionals is vital to the avoidance of pro- cess incidents. Several other industries—for example, tion of a process safety incident other than “release of the nuclear power industry—and government facili- agent” within the Assembled Chemical Weapons Alter- ties engaged in hazardous processes have been hiring natives program. Establishing or adopting a common full-time staff members to develop and monitor their definition for process safety incidents would improve process safety programs, although they have not done consistency of reporting and sharing of lessons learned so as quickly as the chemical and petroleum industries. within the program. Recommendation 4-1. The Program Manager for FINDINGS AND RECOMMENDATIONS Assembled Chemical Weapons Alternatives should All of the committee’s findings and recommenda- adopt the definitions of Tier 1-4 process safety events tions are listed below. They are numbered according to in Recommended Practice 754, Process Safety Perfor- their order in the chapters in which they appear. mance Indicators for the Refining and Petrochemical Industries, a joint recommendation of the American Finding 2-1. Because of the unique nature of the pro- National Standards Institute and the American Petro- cesses at the Pueblo Chemical Agent Destruction Pilot leum Institute, with the exception that the reporting Plant and the Blue Grass Chemical Agent Destruction threshold for chemical agents should be defined as any Pilot Plant and the extensive use of first-of-a-kind unintended release. equipment, the use of both leading and lagging pro- Finding 4-2. D eveloping metrics for the Pueblo cess safety metrics will be important in achieving the congressional mandate to safely destroy the chemical Chemical Agent Destruction Pilot Plant and the Blue weapons stockpiles at the respective sites. Systemiza- Grass Chemical Agent Destruction Pilot Plant based on tion affords an excellent opportunity to implement and operating experience at other chemical agent disposal evaluate leading and lagging process safety metrics. facilities would help to avoid failures that lead to pro- cess safety incidents. Recommendation 2-1. During systemization, the Recommendation 4-2. The Program Manager for Program Manager for Assembled Chemical Weapons Assembled Chemical Weapons Alternatives should Alternatives should develop and implement extensive take into account the causal factors in past process process safety metrics that can be evaluated for rel- safety incidents at chemical agent disposal facilities evance and utility. Metrics that are found to be mean- when devising process safety metrics for the Pueblo ingful should be carried forward to operations. While Chemical Agent Destruction Pilot Plant and the Blue both leading and lagging metrics should be developed Grass Chemical Agent Destruction Pilot Plant. and implemented to the extent possible, both the Pueblo Finding 4-3. Many process safety metrics that could be Chemical Agent Destruction Pilot Plant and the Blue Grass Chemical Agent Destruction Pilot Plant should used by the Pueblo Chemical Agent Destruction Pilot emphasize developing leading metrics to guide them in Plant and the Blue Grass Chemical Agent Destruction process safety management. Pilot Plant are available to the public, including those in the list of metrics in the Center for Chemical Process Finding 3-1. The causal factors involved in past events Safety publication Guidelines for Process Safety Met- at chemical agent disposal facilities are not process rics. These metrics could complement process-specific specific. Consequently, the Pueblo Chemical Agent metrics developed at the respective sites. Destruction Pilot Plant and the Blue Grass Chemi- Recommendation 4-3. The Pueblo Chemical Agent cal Agent Destruction Pilot Plant can reasonably be expected to experience the same types of events hav- Destruction Pilot Plant and the Blue Grass Chemical

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6 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTS Recommendation 4-5. The Program Manager for Agent Destruction Pilot Plant should adopt the met- rics listed below and develop process-specific leading Assembled Chemical Weapons Alternatives and site and lagging metrics. The ACWA program should also management should perform periodic reviews of pro- consider a metric associated with emergency planning cess safety metrics utilized at PCAPP and BGCAPP and response as well as published lists of process safety and implement action plans as appropriate to drive metrics and should adopt those that appear to be of continuous improvements. value to these sites. Finding 4-6. The chemical and petroleum industries • ount of process safety near-miss events. C have found it very beneficial to have employees on • raining records such as validation of job cycle T staff with process safety expertise. These individuals checks and completion of training, including partner with senior management and are accountable refresher training. for monitoring industry best practices in process safety • ob procedures: J and for implementing those that are applicable within –Statistics on whether a procedure was used and, their facilities. These individuals are also tasked with if it was, was the procedure the correct one? assisting in embedding process safety into the organi- –Validation that procedures are current and zation’s culture by organizing and leading grassroots accurate. process safety teams while reviewing outcomes and • tatistics on the closure of action items. S metrics with management. • ercent of inspections of safety-critical equip- P Recommendation 4-6. The Program Manager for ment completed on time. • ercent of sampled management of change P Assembled Chemical Weapons Alternatives should instances that met all requirements and quality maintain process safety expertise at the programmatic standards. level to ensure effective implementation of process safety metrics. To be successful, process safety experts Finding 4-4. The United Kingdom Health and Safety must partner with and be supported by management. Executive’s Health and Safety Guidance 254 (UK HSE Finding 4-7. There are a number of resources that the HSG 254) provides a methodology to develop process- specific leading and lagging metrics. Program Manager for Assembled Chemical Weapons Alternatives can use to learn about best practices for Recommendation 4-4. Given that the two facilities process safety management in the chemical and petro- are pilot facilities and make extensive use of first-of-a- leum industries. Process safety technology conferences kind equipment, the Pueblo Chemical Agent Destruc- such as the American Institute of Chemical Engineers’ tion Pilot Plant and the Blue Grass Chemical Agent annual Global Congress of Process Safety and others Destruction Pilot Plant should review their hazard hosted by organizations such as the Center for Chemi- assessment documents to identify and consider imple- cal Process Safety and the Mary Kay O’Connor Pro- menting leading or lagging metrics specific to each cess Safety Center provide ongoing programming on piece of equipment or area of the plant. These efforts process safety and the identification of best practices. should follow the approach outlined in the United Recommendation 4-7. The Program Manager for Kingdom’s Health and Safety Executive Health and Safety Guidance 254 (UK HSE HSG 254), Developing Assembled Chemical Weapons Alternatives should undertake a review of best practices in process safety Process Safety Indicators: A Step-by-Step Guide for Chemical and Major Hazard Industries. management, especially in the chemical and petroleum industries. These practices are described in the Center Finding 4-5. A formalized mechanism for a periodic for Chemical Process Safety book Guidelines for Risk review of process safety metrics by management is Based Process Safety. Those that are applicable should an established best practice in industry to verify that be incorporated into the Pueblo and Blue Grass Chemi- management is involved and can drive continuous cal Agent Destruction Pilot Plants. improvement.