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Edited: 10/20/2019 1:54 PM
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ROBERT LINN
Brass Deformer

​My unit is looking at using a brass deformer 

IAW the DAP 385-64

Chapter 4

Safety Site Planning

(13) Establishes or designates locations for equipment (such as, brass deformers) used to process spent cartridge cases, range residue, and so forth


Question: If the brass is already Certified and verified explosive free,  as it would be going to DLA, why would the unit need a DDESB  safety site plan?

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  • ROBERT LINN
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ROBERT LINN

​My unit is looking at using a brass deformer 

IAW the DAP 385-64

Chapter 4

Safety Site Planning

(13) Establishes or designates locations for equipment (such as, brass deformers) used to process spent cartridge cases, range residue, and so forth


Question: If the brass is already Certified and verified explosive free,  as it would be going to DLA, why would the unit need a DDESB  safety site plan?

410/20/2019 1:51 PM10/20/2019 1:54 PMNoAsk the Community
53.0937955443509
34/27/2019 12:49 PM
Posted: 10/29/2019 10:20 AM
Picture Placeholder: JAMES TOLLETT
JAMES TOLLETT

Appears to be a disconnect within the regulations, OR, the Army has elected to make the requirement more restrictive. To your original question I'd say "becuse the DA Pam says you are required to have one". The services can absloutly add requirements above DOD guidance.

Once ​I dug into the DESR 6055.09 it would appear that a site plan would NOT be required if specific requirements were met.

V4.E5.18.3.1. Demilitarization processing operation locations meeting the requirements of paragraphs V4.E5.18.1. and V4.E5.18.2., and located outside of IBD from all PESs, do not require submission of a site plan to the DDESB as addressed in paragraph V1.E5.3.9.

The 18.1 and 18.2 referanced state: 

V4.E5.18.1. A demilitarization operation for processing expended .50-caliber and smaller cartridge cases can be treated as a non-explosive operation provided:
V4.E5.18.1.1. Cartridge casings to be processed are screened prior to processing. Screening is intended to ensure that only .50-caliber and smaller are processed, and to remove unused .50-caliber and smaller cartridges.
V4.E5.18.1.2. Demilitarization processing equipment is tested to be capable of containing overpressure, fragment, and thermal hazards associated with a worst-case reaction involving a single live round of the most energetic cartridge that could be processed in the equipment.

I'd recommend reaching out to your supporting Safety office and DAC for specific guidance.

Picture Placeholder: JAMES TOLLETT
  • JAMES TOLLETT
/_layouts/15/images/person.gif" alt="Picture Placeholder: JAMES TOLLETT" />
JAMES TOLLETT

Appears to be a disconnect within the regulations, OR, the Army has elected to make the requirement more restrictive. To your original question I'd say "becuse the DA Pam says you are required to have one". The services can absloutly add requirements above DOD guidance.

Once ​I dug into the DESR 6055.09 it would appear that a site plan would NOT be required if specific requirements were met.

V4.E5.18.3.1. Demilitarization processing operation locations meeting the requirements of paragraphs V4.E5.18.1. and V4.E5.18.2., and located outside of IBD from all PESs, do not require submission of a site plan to the DDESB as addressed in paragraph V1.E5.3.9.

The 18.1 and 18.2 referanced state: 

V4.E5.18.1. A demilitarization operation for processing expended .50-caliber and smaller cartridge cases can be treated as a non-explosive operation provided:
V4.E5.18.1.1. Cartridge casings to be processed are screened prior to processing. Screening is intended to ensure that only .50-caliber and smaller are processed, and to remove unused .50-caliber and smaller cartridges.
V4.E5.18.1.2. Demilitarization processing equipment is tested to be capable of containing overpressure, fragment, and thermal hazards associated with a worst-case reaction involving a single live round of the most energetic cartridge that could be processed in the equipment.

I'd recommend reaching out to your supporting Safety office and DAC for specific guidance.

ROBERT LINN86010/29/2019 10:20 AM10/29/2019 10:20 AM
11/18/2008 3:51 PM1
ROBERT LINN
Posted: 10/29/2019 10:26 AM
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ROBERT LINN

Thanks James! Hope all is well.

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ROBERT LINN

Thanks James! Hope all is well.

ROBERT LINN86010/29/2019 10:26 AM10/29/2019 10:26 AM
4/27/2019 12:49 PM1
JAMES TOLLETT
Posted: 11/5/2019 8:35 AM
Picture Placeholder: CARL THOMAS
CARL THOMAS

​I do not think there is a disconnect with Army Guidance (DA Pam 385-64) and the DESR 6055.09. Reasoning:  DA Pam 385-64, Chapter 4, para 4-1.a.13 requires a site plan for a brass deformer if it is within IBD from PES's (My Opinion). If the brass deformer is outside of IBD from PES's, and meets the requirements listed in DESR V4.E5.18.1 and 18.2 a site plan would not be required.  (I do agree, we need to submit a change to DA Pam 385-64, para 13 to read "Establishes or designates locations for equipment (such as, brass deformers, and so forth) used to process spent cartridge cases, range residue within IBD of PES's".   If the deformer is outside of IBD, you will not require a site plan. 

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  • CARL THOMAS
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CARL THOMAS

​I do not think there is a disconnect with Army Guidance (DA Pam 385-64) and the DESR 6055.09. Reasoning:  DA Pam 385-64, Chapter 4, para 4-1.a.13 requires a site plan for a brass deformer if it is within IBD from PES's (My Opinion). If the brass deformer is outside of IBD from PES's, and meets the requirements listed in DESR V4.E5.18.1 and 18.2 a site plan would not be required.  (I do agree, we need to submit a change to DA Pam 385-64, para 13 to read "Establishes or designates locations for equipment (such as, brass deformers, and so forth) used to process spent cartridge cases, range residue within IBD of PES's".   If the deformer is outside of IBD, you will not require a site plan. 

ROBERT LINN86011/5/2019 8:35 AM11/5/2019 8:35 AM
5/7/2009 11:04 AM1
ROBERT LINN
Posted: 11/5/2019 9:25 AM
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ROBERT LINN

Thank you Carl. Hope all is well.

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ROBERT LINN

Thank you Carl. Hope all is well.

ROBERT LINN86011/5/2019 9:25 AM11/5/2019 9:25 AM
4/27/2019 12:49 PM

 

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