EFFICIENT WITH FIRE: Open burning of inoperable ammunition at Letterkenny Munitions Center. (Photo by Letterkenny Munitions Center)
Determining alternative technology solutions for the Army’s disposal of excess, obsolete and defective munitions.
by James Terhune
The Department of Defense sustains combat readiness through safe and efficient disposal of excess, obsolete and defective munitions at a rate sufficient to keep pace with new generations of munitions and to control overall stockpile growth. Open burning and open detonation are critical capabilities to safely accomplish the mission at the required rate to effectively support combat readiness.
In open burning, materials are destroyed by self-sustained combustion after being ignited. In open detonation, explosives and munitions are destroyed by a detonation of added explosive charges. Open detonation is also used in emergency situations to destroy munitions and improvised explosive devices deemed unsafe to move.
Historically, the Army has relied on open burning and open detonation as the most inexpensive processes to demilitarize ammunition. The demilitarization enterprise enables readiness by reducing unserviceable and obsolete stocks in storage, freeing up critical storage space for joint service new production, war reserve and training munitions. Demilitarization, commonly called “demil,” reduces life, safety and health risks by removing aging stocks from storage and increases depot capabilities by making room for good service stocks to be properly stored and aligned to operations.
Over the past twenty plus years, research, development, test and evaluation investments have been made to further the capabilities of alternative, closed disposal technologies with limited success. Two major projects are the Munitions Cryofracture Demilitarization Facility at McAlester Army Ammunition in McAlester, Oklahoma, and the Ammonium Perchlorate Rocket Motor Destruction capability at the Letterkenny Munitions Center in Chambersburg, Pennsylvania. A large portion of funds are used to maintain and improve the existing Rotary Kiln Incinerators, which are the primary closed disposal capabilities used at various organic industrial base locations.
CALL TO ACTION
Previous regulations from the U.S. Environmental Protection Agency (EPA) provided a variance to the prohibition on the open burning of hazardous waste when no alternatives for the safe treatment of waste explosives existed.
According to the EPA, recent findings from the National Academies of Sciences, Engineering and Medicine (NASEM) have determined that safe alternatives are now available for many energetic or explosive waste streams. By waste streams, we mean the gases, liquids or solids that are the byproducts of a demilitarization treatment operation or processes. Because there are safe alternatives available and in use today that capture and treat emissions 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 Detonation 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.
ELIMINATING STOCKPILE
Open detonation of obsolete munitions at Tooele Army Depot. (Photo by Tooele Army Depot)
REACTION RESPONSE
The demilitarization enterprise created an alternate technology evaluation and implementation strategy integrated process team (Alt Tech IPT) to respond to these future requirements. The IPT consists of the following government entities within the demilitarization enterprise: Product Director Demilitarization within the Joint Program Executive Officer for Armaments and Ammunition, Joint Munitions Command, Army Materiel Command, U.S. Army Combat Capabilities Development Command and consulting partners. The Alt Tech IPT will address the following objectives:
- Identify safe and viable alternate technologies that are applicable to the demilitarization stockpile and document a strategy and timeline for implementation at the demil depots to transition 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 evaluation 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 technologies 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: The 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 applicable to stockpiled items.
Alternative technology identification and evaluation: This 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 Kingsport, Tennessee, and various demilitarization depots under the terms of their existing RCRA permits. The evaluation of potential 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. These activities are funded out of Product Director Demilitarization’s RDT&E budget (line PE/SSN 0605805/F24). In addition, existing 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 technologies 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 available (i.e., comprehensive alternative technology analysis will be repeated every five years).
Explosive safety siting analysis: The evaluation will include a technology siting assessment that will identify possible locations 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. The 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 development: Based on the resulting matrix of applicable technologies versus stockpile items, an implementation plan will be developed. This will include determining where alternative technologies will be installed and how the projects will be executed. Both an acquisition strategy and a funding plan also will be developed, and from this an implementation timeline will be established. Construction usually requires funding from DOD’s Military Construction program and is a lengthy process to receive and implement. The demilitarization enterprise is requesting Procurement of Ammunition Army (PAA) funding on Product Director Demilitarization’s EP1700 funding line during the recent fiscal year 2026-30 Program Objective Memorandum funding requests. An act of Congress would be required to allow PAA funds to be used for construction, alternate technology or otherwise.
CLOSED DISPOSAL
Example of a Closed Disposal Technology at McAlester Army Ammunition Plant in Oklahoma. Pictured here are the McAlester Ammunition Peculiar Equipment (APE) 1236 Rotary Kiln Incinerator thermal treatment system and the Munitions Cryo-Fracture Demilitarization Facility, which prepares munitions for feeding into the APE1236 for demilitarization. (Photo by Brent Hunt, Tooele Army Depot)
CONCLUSION
In the 1980s, regulations allowed the permitting of open burning and open detonation to demilitarize munitions. On May 19, 1980, 45 Federal Register 33063-33285, page 33217, allowed the open burning and open detonation of waste explosives, within specified distance and weight limitations, during an interim status permitting period. On Dec. 10, 1987, in 52 Federal Register 46.946, 46.949-50, 46.957-58, the EPA concluded that facilities conducting open burning and open detonation of waste explosives would receive permits under the RCRA Subpart X provisions as miscellaneous units. Since then, DOD has been proactively reducing the number of permitted open burning and open detonation units from 114 to 34, a 70% reduction. Moreover, DOD facilities reduced the quantity of munitions treated by open burning and open detonation by 58% over the past 20 years.
The demilitarization industrial base is currently facing both technological and funding constraints in the implementation of additional closed disposal technology solutions. By developing a comprehensive acquisition strategy and funding plan, it will enable Army leaders to make informed decisions on the necessity and urgency of funding future demilitarization technology projects.
For more information, email the author at james.c.terhune2.civ@army.mil.
JAMES TERHUNE is the product director demilitarization within the Project Director Joint Services. He holds an M.S. in technology management from the Stevens Institute of Technology and a B.S. in industrial engineering from Lehigh University. He is a 2021 graduate of the Defense Acquisition University Senior Service College Fellowship. He is certified as Advanced in program management and as Practitioner in engineering and technical management and business – financial management.
