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Introduction

THE CHEMICAL WEAPONS STOCKPILE DISPOSAL PROGRAM

In 1985, under a congressional mandate (Public Law 99-145), the Army instituted a sustained program to destroy elements of the chemical munition stockpile. In 1992, Congress enacted Public Law 102-484, which extended this program to destroy the entire stockpile.

In 1990, the chemical agent and munitions stockpile contained in excess of 31,000 tons of chemical agents stored at eight chemical weapons depots operated by the Army in the continental United States and on Johnston Island in the Pacific Ocean (southwest of Hawaii). Chemical weapons that had been stored overseas were brought to Johnston Island and destroyed by the Johnston Atoll Chemical Agent Disposal System (JACADS). Approximately 10 percent of the original stockpile is stored at the Pueblo Chemical Depot (PCD) and the Blue Grass Army Depot (BGAD), and approximately 90 percent of that stockpile was stored at sites being served by Chemical Materials Agency (CMA) disposal facilities. As of January 12, 2011, CMA had destroyed 83 percent of the stockpile being treated at its facilities.1

The stockpile originally contained two types of chemical agents: cholinesterase-inhibiting nerve agents (GB and VX) and blister agents, primarily mustard (H, HD, and HT) but also a small amount of lewisite. Both types of chemical agents are liquids at room temperature. To store the agent, the stockpile originally consisted of (1) bulk (“ton”) containers of nerve and blister agent and (2) munitions, including rockets, mines, bombs, projectiles, and spray tanks loaded with either nerve or blister agents. Many of the munitions contain both chemical agent and energetic materials (propellants and/or explosives), a combination whose safe and efficient destruction poses special challenges.

JACADS completed its mission of destroying approximately 4 percent of the nation’s chemical agent stockpile that had been stored on Johnston Island in November 2000. Of the eight U.S. chemical agent weapons storage sites in the continental United States, three have completed destruction operations (Aberdeen, Maryland; Newport, Indiana; and Pine Bluff, Arkansas); disposal facilities are currently in operation at Anniston, Alabama; Tooele, Utah; and Umatilla, Oregon; and two chemical agent destruction pilot plants, the subjects of this report, are under construction at Pueblo, Colorado, and Richmond, Kentucky. All mines, bombs, and spray tanks have been destroyed. All rockets and nerve agent have been destroyed except for those in the stockpile at BGAD.

The largest stockpile site in the continental United States is the Deseret Chemical Depot near Tooele, Utah. This site initially stored 13,616 tons of agent. This component of the stockpile is being destroyed by the Tooele Chemical Agent Disposal Facility, which started operation in August 1996. The Tooele facility is currently destroying mustard agent. The other disposal facilities at Aberdeen, Maryland; Anniston, Alabama; Pine Bluff, Arkansas; Newport, Indiana; and Umatilla,

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



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1 Introduction THE CHEMICAL WEAPONS STOCKPILE perature. To store the agent, the stockpile originally DISPOSAL PROGRAM consisted of (1) bulk (“ton”) containers of nerve and blister agent and (2) munitions, including rockets, In 1985, under a congressional mandate (Public Law mines, bombs, projectiles, and spray tanks loaded with 99-145), the Army instituted a sustained program to either nerve or blister agents. Many of the munitions destroy elements of the chemical munition stockpile. contain both chemical agent and energetic materials In 1992, Congress enacted Public Law 102-484, which (propellants and/or explosives), a combination whose extended this program to destroy the entire stockpile. safe and efficient destruction poses special challenges. In 1990, the chemical agent and munitions stockpile JACADS completed its mission of destroying contained in excess of 31,000 tons of chemical agents approximately 4 percent of the nation’s chemical stored at eight chemical weapons depots operated agent stockpile that had been stored on Johnston Island by the Army in the continental United States and on in November 2000. Of the eight U.S. chemical agent Johnston Island in the Pacific Ocean (southwest of weapons storage sites in the continental United States, Hawaii). Chemical weapons that had been stored over- three have completed destruction operations (Aber- seas were brought to Johnston Island and destroyed by deen, Maryland; Newport, Indiana; and Pine Bluff, the Johnston Atoll Chemical Agent Disposal System Arkansas); disposal facilities are currently in operation (JACADS). Approximately 10 percent of the original at Anniston, Alabama; Tooele, Utah; and Umatilla, stockpile is stored at the Pueblo Chemical Depot (PCD) Oregon; and two chemical agent destruction pilot and the Blue Grass Army Depot (BGAD), and approxi- plants, the subjects of this report, are under construc- mately 90 percent of that stockpile was stored at sites tion at Pueblo, Colorado, and Richmond, Kentucky. All being served by Chemical Materials Agency (CMA) mines, bombs, and spray tanks have been destroyed. All disposal facilities. As of January 12, 2011, CMA had rockets and nerve agent have been destroyed except for destroyed 83 percent of the stockpile being treated at those in the stockpile at BGAD. its facilities.1 The largest stockpile site in the continental United The stockpile originally contained two types of States is the Deseret Chemical Depot near Tooele, chemical agents: cholinesterase-inhibiting nerve agents Utah. This site initially stored 13,616 tons of agent. (GB and VX) and blister agents, primarily mustard This component of the stockpile is being destroyed by (H, HD, and HT) but also a small amount of lewisite. the Tooele Chemical Agent Disposal Facility, which Both types of chemical agents are liquids at room tem- started operation in August 1996. The Tooele facility is currently destroying mustard agent. The other disposal facilities at Aberdeen, Maryland; Anniston, Alabama; 1See http://www.cma.army.mil/home.aspx for updated Pine Bluff, Arkansas; Newport, Indiana; and Umatilla, information as the program progresses. 7

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8 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTSS Oregon, have collectively destroyed more than 79 per- near an OSHA recordable injury rate of 0.5. To assist cent of the original stockpile. JACADS, Aberdeen, and in achieving this goal, the NRC was asked to review Newport have been closed. existing safety and environmental metrics at operating C hemical agent destruction pilot plants that chemical agent disposal facilities and to recommend employ nonincineration alternative destruction tech - additional metrics and/or program modifications, if nologies are currently under construction at the PCD necessary. The NRC issued its report, Evaluation near Pueblo, Colorado (the Pueblo Chemical Agent of Safety and Environmental Metrics for Potential Destruction Pilot Plant), and at BGAD in Richmond, Application at Chemical Agent Disposal Facilities, Kentucky (the Blue Grass Chemical Agent Destruc - in April 2009. tion Pilot Plant). Consequently, destruction operations Having been provided with the 2009 report, and for have not yet begun at these sites. This report concerns reasons such as the use of first-of-a-kind equipment the appropriate process safety metrics for use at these and the need to conscientiously adhere to congressional two sites.2 mandates that the destruction of chemical agent and munitions be executed with maximum protection to workers, the public, and the environment, the Program THE SAFETY CHALLENGE—PROCESS SAFETY Manager for Assembled Chemical Weapons Alterna- METRICS tives (PMACWA) determined that it would be useful for The law mandating the destruction of chemical the NRC to conduct a study on process safety metrics to agent and munitions requires that the destruction be guide it in formulating a process safety plan for PCAPP executed with maximum protection to workers, the and BGCAPP. Accordingly, PMACWA asked the NRC public, and the environment. In the initial years of the to undertake a study that would guide its develop- stockpile disposal program, reports by NRC’s Commit- ment and application of process safety metrics. Since tee on Review and Evaluation of the Army Chemical the PCAPP and BGCAPP sites are presently under Stockpile Disposal Program repeatedly encouraged the construction, PMACWA has a timely opportunity to Army and its contractors to pay increased attention to develop process safety metrics to measure and monitor safety and to engage in processes aimed at continuous process safety performance. improvement with respect to safety.3 More recently Because process safety metrics can measure the that committee’s successor committee, the standing e ffectiveness of process safety program manage - Committee on Chemical Stockpile Demilitarization, ment, they are increasingly being used by industry. and numerous ad hoc NRC committees concerned with An independent investigation following an industrial chemical demilitarization have continued to emphasize accident at the BP refinery at Texas City, Texas, on safety. March 23, 2005, underscored the inadequacy of injury The Army and its contractors have responded so rates alone to measure process safety performance and effectively that the remaining operating facilities have called attention to the value of process safety metrics. attained Occupational Safety and Health Adminis- Specifically, the ensuing report by the BP Independent tration (OSHA) recordable injury rates of less than Refiners Safety Review Panel (the Baker panel report) one injury per 200,000 hours worked. Even so, in stated: the interest of continuous improvement, in 2007 the BP primarily used injury rates to measure process safety Army expressed a desire and intent to achieve safety performance at its U.S. refineries before the Texas City performance that is equal to, or better than, that of accident. Although BP was not alone in this practice, BP’s reliance on injury rates significantly hindered its perception the best industrial companies, which are consistently of process risk. BP tracked some metrics relevant to process safety at its U.S. refineries. Apparently, however, BP did not understand or accept what this data indicated about the risk 2Information about the history of the Assembled Chemical Weap- of a major accident or the overall performance of its process ons Alternatives (ACWA) program may be found at http://www. safety management systems. As a result, BP’s corporate pmacwa.army.mil/index.html, including http://www.pmacwa.army. safety management system for its U.S. refineries does not mil/info/dl/acwa_brochure_121310.pdf and http://www.pmacwa. effectively measure and monitor process safety performance army.mil/info/dl/ACWA_Overview_Fact_Sheet_FINAL_2010.pdf. (Chemical Safety Board, 2007, p. xiv) 3The Committee on Review and Evaluation of the Army Chemi - cal Stockpile Disposal Program interacted with the Program Man - ager for Chemical Demilitarization and the CMA.

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9 INTRODUCTION STATEMENT OF TASK example, by tracking performance through periodic measurements. The statement of task for the Committee to Assess A basic principle of a good safety culture is that Process Safety Metrics for the Blue Grass and Pueblo safety cannot be delegated and is the responsibility of C hemical Agent Destruction Pilot Plants is the both line management and operations personnel. Line following: management must take an active leadership role to ensure the effectiveness of a process safety manage- The National Research Council will establish an ad hoc ment system. Metrics for monitoring the effectiveness committee to: of key process safety programs can be used by man- agement for accomplishing continuous improvement. • eview and evaluate plans for the use of process safety R metrics to be employed at the two Assembled Chemical A focused effort on both leading and lagging metrics is Weapons Alternatives (ACWA) pilot plant facilities, needed.4 Developing and implementing leading metrics • xamine and assess the process safety metrics used in E is more complex and challenging than developing and commercial and industrial operations for potentially ap- implementing lagging metrics, but the former have plicable process safety metrics, and been shown to provide better overall awareness and • ssess new initiatives at national organizations (i.e., A serve as an early warning of potential process safety American Institute of Chemical Engineers, etc.) that could be used by ACWA. incidents, allowing for preventative actions. Similarly, well-designed lagging metrics also provide valuable information about the process, which, if trends are PROCESS SAFETY MANAGEMENT measured, could serve as an indicator of continuous This report is focused on metrics to manage opera- improvement. tions from the process safety perspective. As will be The primary mission for chemical demilitarization discussed more fully below, process safety is a disci- operations is to destroy the agent and dispose of the plined framework for managing the integrity of operat- associated munitions safely. Well-designed leading ing systems, processes and personnel handling hazard- process safety metrics can provide an early warning of ous substances, and operations by applying good design potential process safety incidents. principles, engineering, and operating practices. At An effective process safety program, as outlined PCAPP and BGCAPP, process safety encompasses all above, requires a strong commitment to the shared aspects of the process from the delivery of the chemi- values and behaviors of a work culture that is pursu- cal weapons from storage, to shipping solid and liquid ing safe operating excellence. Such efforts explicitly waste streams for final disposal. Process safety includes require (1) a willingness to devote time and resources keeping materials inside their primary containment, to the safety system; (2) constant, focused management preventing the unintended release of chemical agent, involvement; and (3) the active participation of all and safely handling all materials and chemicals related employees. Successful process safety operations must to the process. Historically, the CMA has focused its continuously assess the effectiveness of the process safety program on the prevention of agent releases, safety management program and the organization’s the safe handling of energetics, and the safe closure of ability to focus on safety, including but not limited chemical agent disposal facilities that have completed to operational discipline and adherence to standards operations. and performance metrics. Actions to remediate non- The systematic application of process safety prin - conformances must be clearly spelled out along with ciples encompasses the various controls and monitor- responsibility for implementing them and time lines for ing of the operations, the data on process compliance, completing them. The success of a safety program will and the effectiveness of these systems. The focus is rest on an organization’s ability to maintain operational on performance—that is, on operating excellence that excellence through demonstrated operational discipline goes beyond strict compliance with regulations or at the management, supervisory, and process levels procedures. The mindset of the organization and its (operators, maintenance, etc.). Some key operational ability to focus on and devote time to process safety is discipline elements include personal responsibility essential. The site management must be fully involved for understanding risks and the purpose of controls; in a manner that fosters continuous improvements—for 4“Leading metric” and “lagging metric” are defined in Appendix A.

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10 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTSS teamwork; active communication with other employees • ell-defined operating boundaries using critical W involved in the process; use of updated procedures; and operating parameters; training to ensure operators have the knowledge and • formal certification program to ensure employ- A skills necessary to safely operate the process. Such ees are trained in and knowledgeable about their discipline is based on the deeply rooted dedication and respective job duties; and commitment of every member of the organization to • etailed material balances and throughput D carry out each task the right way each time. analyses. Site plans at PCAPP and BGCAPP include the develop- PROCESS SAFETY MANAGEMENT AT PCAPP ment of process safety management systems that will AND BGCAPP address OSHA PSM system requirements. Although During site visits to Pueblo, Colorado, and Rich- the mustard agent to be processed at PCAPP is not mond, Kentucky, to meet with staff supporting PCAPP covered by the OSHA PSM standard, PCAPP plans and BGCAPP, the committee learned that process to establish a process safety management system to safety management considerations have been incorpo- meet the intent of the OSHA PSM regulations. Dur- rated. The intent at both sites is to operate under the ing its visits to PCAPP and BGCAPP, the committee principles and guidelines set forth in OSHA’s Process saw that both sites recognized the need for process S afety Management (PSM) of Highly Hazardous safety metrics and that they are in the initial stages of Chemicals, which is located in 29 CFR 1910.119. The developing and implementing such metrics. Both sites sites’ process safety management practices include, but had developed metrics to measure the effectiveness of are not limited to, the following: several of the OSHA PSM required elements and are looking for additional guidance from this committee. • echnical risk reduction tests and studies; T • irst-of-a-kind process equipment evaluations; F COMMITTEE MAKEUP AND MEETING SCHEDULE • pplication of lessons learned from the Aberdeen A AND REPORT SCOPE AND APPROACH and Newport neutralization sites5 and the baseline incineration design and operations; As is suggested by the statement of task, a committee • esign criteria that meet national codes and local D with very specific expertise was required to undertake regulations; the task (see Appendix B). • azard and operability analysis to assess equip- H Four meetings were held, and individual committee ment and process hazards; members interacted extensively between meetings. • nternal design reviews to ensure that plant design I The first meeting focused on gathering information minimizes adverse safety impacts that would and developing an understanding of the processes to affect the ability to start up, operate, and maintain be employed at PCAPP and BGCAPP. Between the the sites; first and second meetings, the committee requested • se of management of change;6 U and received a considerable amount of information on • rocess control systems designed to ensure over- P the two sites. all operational control and coordination from the Two members of the committee conducted a site visit control room, and monitoring of critical safety- to CMA at the Aberdeen Proving Ground in Maryland, related systems and agent-monitoring systems;7 where they evaluated process safety-related incidents at CMA sites since 1990 that were relevant to the work of the committee. 5The Aberdeen and Newport sites, like PCAPP and BGCAPP, The purpose of the second meeting of the commit- used neutralization (hydrolysis) instead of incineration as the pri - tee, held one day in Pueblo, Colorado, and a second mary process for agent destruction. day in Richmond, Kentucky, was to interact directly 6This is a process to analyze and manage the results of any with ACWA project management personnel to gain an change to the physical plant, process, or people with the potential understanding of the operating processes at PCAPP to introduce health, safety, security, environmental, or operational hazards, whether on a permanent, temporary, or emergency basis. and BGCAPP. 7An example of a critical safety-related system would be a com - At the third meeting, the committee focused on the puter, software, or mechanical system the failure of which could results of the process safety incident analyses and data result in death, serious injury, or environmental damage.

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11 INTRODUCTION gathered on process hazards and on assessing how well and energetics, treatment of empty munition bodies, the draft report met the statement of task. destruction of agent, and secondary processing prior to At the fourth and final meeting, the committee release of the waste for disposal. Munitions storage is reviewed the report draft, discussed and agreed on not managed by PMACWA and so is beyond the scope findings and recommendations, and set the stage for of this report. Also, since the use of explosive destruc- achieving concurrence soon after via virtual meetings tion technologies for destroying munitions containing and teleconferences. agent has been studied extensively by other NRC com- Numerous teleconferences and virtual meetings mittees, the committee did not include an assessment were also conducted between committee meetings; of this in this report. these involved committee members, NRC staff, the The committee was somewhat constrained by the A rmy representatives, and PCAPP and BGCAPP fact that with planned start-up dates of 2014 and 2018 at personnel. PCAPP and BGCAPP, respectively, many operational This report assesses initiatives undertaken by other aspects of the plants are still being defined. As a result, process safety-related organizations, such as the Ameri- specifying metrics would be premature, so the commit- can Institute of Chemical Engineers (specifically, its tee’s recommendations could not be overly specific and Center for Chemical Process Safety), the American are instead more aligned with the members’ experience Petroleum Institute, and the United Kingdom Health in other chemical operations. The committee, therefore, and Safety Executive, and discusses the applicability has mainly provided guidelines and suggestions for of chemical and petroleum industry metrics to PCAPP selecting and developing process safety metrics. and BGCAPP. The committee reviewed process safety-related OVERVIEW OF REPORT incidents at CMA facilities since 1990 and their associ- ated key causal factors and suggested metrics based on This report highlights the use of process safety those factors. The committee also drew on its discus- metrics to provide timely feedback to operations man- sions with project and operations management staff at agement on the effectiveness of their process safety PCAPP and BGCAPP to aid in the identification of management system. Chapter 1 describes the U.S. specific process operations that would benefit from the chemical weapons stockpile stored in military depots application of process safety metrics. in the United States. It includes a brief overview of Using this information, the committee prepared a list the chemical weapons disposal program developed in of process safety metrics it believes should be adopted response to congressional mandate. The congressional at the sites (Recommendation 4-3) and suggested other mandate (P.L. 102-484) includes a requirement to pro- possible metrics and approaches to generating metrics vide maximum protection to workers, the public, and for consideration and use at the sites (Chapter 4). Addi- the environment. It also provides background informa- tionally, two of the processing steps that will be used, tion on the role that the NRC has played in assisting the hydrolysate handling and the energetics batch hydroly- Army to conduct chemical agent disposal operations sis, were selected by the committee to provide guidance safely, the origin of the present report and the purpose on identifying process safety metrics. These examples to be served by it, and the activities to be undertaken should help to clarify the process for developing pro- by the committee in fulfillment of its statement of task. cess safety metrics. It is the committee’s expectation It also discusses what process safety management and that site operations management will conduct thorough its associated metrics encompass and why they are an reviews of the process at both PCAPP and BGCAPP to important part of a high-functioning worksite safety identify the leading and lagging process indicators nec- culture. essary for the effective management of process safety. Chapter 2 presents a high-level review of the process This study did not include an independent evalua- trains for chemical demilitarization at PCAPP and tion of the agent destruction processes planned for use BGCAPP. Although both facilities will use neutraliza- at the two sites. The committee used the sites’ process tion processes to dispose of chemical agent, further pro- designs as the basis for its work on metrics and focused cessing of the resulting hydrolysate to ensure destruc- on the processes that fall under PMACWA’s manage- tion of agent will be accomplished using biotreatment ment: receipt of munitions for processing, removal technology at PCAPP and supercritical water oxidation of agent and energetics, treatment of recovered agent at BGCAPP. Process flow diagrams for the two plants

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12 PROCESS SAFETY METRICS AT THE BLUE GRASS AND PUEBLO CHEMICAL AGENT DESTRUCTION PILOT PLANTSS are provided. First-of-a-kind equipment and operations established by national and professional organizations, are also reviewed for the additional risk first-of-a-kind such as the American Institute of Chemical Engineers’ equipment can present. Center for Chemical Process Safety, the American In Chapter 3, a review of the process safety events Petroleum Institute, and the United Kingdom Health that occurred at the CMA neutralization and incinera- and Safety Executive. The committee then provides tion sites illustrates some causes of process safety inci- guidance to PMACWA to help in the selection of dents that might also occur at PCAPP and BGCAPP. process safety metrics and related methodologies for There are also valuable lessons to be learned from PCAPP and BGCAPP. experiences with those parts of the disposal process used at the CMA neutralization and incineration sites REFERENCE that are similar to the processes planned for use at Chemical Safety Board. 2007. The Report of the BP US Refiners Inde- PCAPP and BGCAPP. pendent Safety Review Panel. Available online at http://www.csb.gov/ In Chapter 4, the committee reviews the process assets/document/Baker_panel_report1.pdf. Last accessed on October safety metrics applied in industry, as well as those 28, 2010.