With the issuance of the facility contract modification in Dec 2018, Holston Army Ammunition Plant instituted a revised waste material evaluation plan to ensure continued improvement in environmental safety and emissions. Chief among Holston’s efforts is the establishment of a comprehensive process to divert materials from open burning to solid waste landfill disposal, reducing the amount of burned waste and related emissions.
Holston originally sent all materials from the main production area to the open burning ground due to the potential for contamination with explosives. Items contaminated with explosive waste range from personal protective equipment used during production to building material waste when old explosives production buildings are demolished. The items were burned to comply with former safety instructions and ensure the safety of materials being disposed or recycled. However, changes in safety instructions allowed some of these items to be diverted to the landfill without significant risk to the safety of the workers handling them.
Impetus for this change comes from Department of Defense Instruction 4140.62 and its predecessors. Holston already made changes in response to previous direction establishing instructions for identifying Material Potentially Presenting an Explosives Hazard. Following this direction, the installation began implementing the MPPEH program in early 2019, thus establishing a complete system for identifying and diverting potentially explosives contaminated waste to on-site landfill disposal. The updated DODI 4140.62 included more flexibility for implementing MPPEH evaluation.
According to Environmental Engineer Laura Peters, “The instruction defines MPPEH as an interim classification only, which must be evaluated as either Material Determine to be an Explosive Hazard or Material Documented as Safe. Evaluations as MDEH or MDAS can be performed based on generator knowledge and/or two successful 100% inspections by qualified explosives safety trained individuals.” The facility contract modification in December 2018 is really what made the implementation of the MPPEH program at Holston possible.
To date, Holston has trained more than 250 production personnel in MPPEH. Since April 2019, trained experts at each production building are identifying waste for diversion from open burning. During operations, workers sort and segregate waste into dedicated containers for MDAS and MDEH, after which qualified safety personnel screen and evaluate the sorted material prior to final disposition.
As of February 2020, Holston had evaluated more than 80 percent of the installation’s production facilities. The rest should be completed midyear. At the incorporation buildings, where materials are combined, 25 percent of bag liners are now diverted from open burning. Applying the MPPEH program to Holston’s building demolition project resulted in the diversion of 98 percent of a building’s debris to landfill disposal. Without the MPPEH program, all of this material would have been burned at the open burning ground. Another demolition project is ongoing and includes four buildings. It is anticipated that 95 percent of the waste from these buildings will also be diverted.
The results are significant and ongoing. “Since rolling out the new MPPEH Management Plan in April of 2019, HSAAP has successfully diverted 2,018 cubic yards of material from the Open Burning Grounds. Additional diversion potential is expected as the new program progresses. From an environmental perspective, there will obviously be less material being open burned, leading to less emissions from thermal treatment activities,” said Peters.
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