FROM OPEN TO CLOSED
prior to release, regulations will be revised to promote the broader use of these alternatives, where applicable, through specified procedures to evaluate alternative treatment technologies.
In June 2022 and then updated in April 2023, the EPA initiated the Revisions to Standards for the Open Burning/Open Deto- nation of Waste Explosives, which proposed changes to open burning and open detonation permitting rules to increase control of air emissions through greater adoption and use of alternative technologies with the intent to further decrease or eliminate the use of open burning and open detonation. One of the proposed changes includes regulating the requirements for and parameters of an alternative technology evaluation for each permitted and interim open burning and open detonation facility.
REACTION RESPONSE Te demilitarization enterprise created an alternate technology evaluation and implementation strategy integrated process team (Alt Tech IPT) to respond to these future requirements. Te Alt Tech IPT consists of the following government entities within the demilitarization enterprise: Product Director Demilitariza- tion within the Joint Program Executive Officer for Armaments and Ammunition, Joint Munitions Command, Army Mate- riel Command, U.S. Army Combat Capabilities Development Command and consulting partners. Te Alt Tech IPT will address the following objectives:
• Identify safe and viable alternate technologies that are applica- ble to the demilitarization stockpile and document a strategy and timeline for implementation at the demil depots to tran- sition away from open burning and open detonation practices.
• Conduct a study that can be used by the demilitarization depots to comply with existing alternative technology eval- uation requirements in facility Resource Conservation and Recovery Act (RCRA) and air permits.
• Meet, to the extent practicable, the guidelines in the EPA’s proposed open burning and open detonation permit rule for the conduct of alternative technology evaluations, pending finalization.
OUTPUTS AND SOLUTIONS Investing in alternative, closed disposal technologies for the organic industrial base addresses a mandate driven by the proposed EPA rule revision to maximize closed disposal tech- nologies and minimize use of open burning and open detonation. To that end, the Alt Tech IPT will perform the following tasks over the next 18 months:
Stockpile analysis and waste stream characterization: Te Alt Tech IPT will conduct a stockpile analysis of over 7,000 items and 320,000 short tons and make the determination whether any alternative technology identified by the assessment is appli- cable to stockpiled items.
Alternative technology identification and evaluation: Tis will leverage previously conducted studies such as the 2019 NASEM report and alternative technology reports prepared for Army facilities like Holston Army Ammunition Plant in King- sport, Tennessee, and various demilitarization depots under the terms of their existing RCRA permits. Te evaluation of poten- tial alternative technologies will assess whether the technology is commercially available and being used successfully (either within or outside of the continental United States) and the likelihood of acquisition success. Alternative technologies that are currently under research, development, test and evaluation (RDT&E) efforts (organic or commercial) also will be considered. Tese activities are funded out of Product Director Demilitarization’s RDT&E budget (line PE/SSN 0605805/F24). In addition, exist- ing capabilities located at the organic depots will be evaluated, including currently active capabilities and those not in active use or those that have been laid away.
Applicability review: Any potentially viable alternative tech- nologies identified will be evaluated against the stockpile for applicability and effectiveness using the criteria established per the stockpile analysis/waste stream characterization. Future reevaluation will be necessary as more data becomes avail- able (i.e., comprehensive alternative technology analysis will be repeated every five years).
Explosive safety siting analysis: Te evaluation will include a technology siting assessment that will identify possible loca- tions at the demil depots for alternative technology construction and implementation. An explosives safety quantity-distance (ESQD) arc analysis is required for current explosive operations and storage locations, based on the maximum net explosives weight authorized at each facility. Te ESQD arcs define the DOD’s minimum acceptable levels of protection from intentional and unintentional detonations, which help minimize injuries to personnel not related to explosive operations and ensures the related explosives workers are properly protected during demil operations.
Acquisition strategy and implementation timeline develop- ment: Based on the resulting matrix of applicable technologies versus stockpile items, an implementation plan will be developed.
28 Army AL&T Magazine Spring 2024
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