Pueblo Stockpile

The process to select a technology for the Pueblo Chemical Agent Disposal Facility (PUCDF) was defined in a notice of intent (NOI) published in the Federal Register on April 20, 2000. Environmental impact statements required by the National Environmental Policy Act will be developed for all the candidate technologies. The final choice will be made by the DoD from the technologies certified to be as safe and cost efficient as the baseline incineration system, as well as capable of completing destruction of the Pueblo stockpile either by the CWC treaty deadline (April 29, 2007) or the date that would be achievable by the baseline system, whichever is later. The decision tentatively will be made in early fiscal year 2002. 

The modified baseline process with a single four-zone MPF shows considerable promise and should be considered for destroying the Pueblo stockpile. Certain features of the process do require additional study, as recommended below. 

Although the total tonnage of mustard agent contained in the munitions at Pueblo is not large (2,611 tons), the number of munitions (approximately 780,000 mortar shells and artillery projectiles) is the second largest stored at any of the eight continental U.S. stockpile sites. A description of the munitions in the Pueblo stockpile is provided in Appendix A. 

A brine reduction area, in which brine is evaporated and dried to salt, is a feature of the JACADS and TOCDF baseline system designs. The brine qualifies as a RCRA hazardous waste and can be shipped off site (after appropriate testing) and disposed of in a permitted TSDF. This is now being done at TOCDF, is planned at the other baseline system sites, and is the preferred alternative for the modified baseline process at Pueblo. The amount of brine expected over the life of Pueblo stockpile disposal operations is 14.5 million gallons (WIPT, 2000a, 2000b, 2000c). 

Recommendation 4-2. The Army should expedite obtaining necessary risk information so interested parties can compare the baseline incineration system and the modified baseline process. An important step for ensuring that the necessary risk information is obtained in a timely manner is the establishment of a comprehensive risk management framework. Such a framework would clearly identify the risk measures of interest and reflect the criteria specified in Public Law 105-261 and the NEPA NOI concerning a disposal facility for the Pueblo stockpile. 

Recommendation 2-5. The Army should determine whether adequate data are available from JACADS to support the efficacy of processing secondary wastes in the metal parts furnace. If not, the Army should determine the additional tests required to confirm a disposal process. A plan based on these results should also be developed for handling and disposing of all secondary wastes from processing the Pueblo stockpile, including demilitarization protective ensemble suits and hoses, spent carbon filter materials, scmbber brine solutions, plant cleaning wastes, and dunnage. 

Table A-l lists the kinds and numbers of munitions in the Pueblo stockpile.

Finding (Pueblo) EH-2. Results from the energetics hydrolysis test program thus far have shown that hydrolysis rates are consistent with the proposed designs for overall throughput rates necessary to meet the current disposal schedule for the Pueblo stockpile. 

Materials of construction for the plant equipment have been selected to provide reliable operation, so that the Pueblo stockpile can be disposed of by the CWC treaty deadline. If the EDS test results indicate that the composition of feed streams will damage the equipment, more resistant materials of construction will be specified. Moreover, further refinements in the process are expected to result in changes in materials of construction that will be incorporated into the next developmental engineering phase for the WHEAT technology package. 

As a result of Public Laws 104-201 and 104-208, DoD created the Assembled Chemical Weapons Assessment (ACWA) program to select and evaluate technologies that would be appropriate for destroying the stockpiles at Pueblo Chemical Depot and Blue... 

The Army, through the Program Manager for Chemical Demilitarization (PMCD), is responsible for destroying the U.S. stockpile of chemical munitions at nine storage sites. The portion of the stockpile at the Pueblo Chemical Depot in... 

Overall, the modified baseline process concept is likely to be a workable means of destroying the assembled chemical munitions stockpile at Pueblo. As previously noted, the modified baseline process is based on the extensive lessons learned from the processing of mustard agent munitions at JACADS. Even so, some development work will be necessary. The committee believes that with rigorous planning and execution these tasks can be accomplished. 

The Phase 1 quantitative risk assessment for Pueblo and several other stockpile sites with assembled chemical munitions completed several years ago showed that the stockpile at Pueblo presents risk to public health several orders of magnitude lower than any other site. This is because it contains only mustard agent, which is less volatile than other agents, and therefore would not be carried very far in the event of a fire or explosion. Nevertheless, the Army has undertaken several risk and safety assessments to meet the legislative requirement that the technology chosen for Pueblo be as safe as or safer than the baseline system. The committee believes that the incineration technologies under consideration will have very low risk and will meet reasonable interpretations of safety criteria, even if the actual risk numbers marginally exceed the baseline criteria. 

Neutralization-based technologies (alternatives to incineration) are being installed at the chemical stockpile site in Newport, Indiana, where bulk-only VX nerve agent is stored, and in Aberdeen, Maryland, where bulk-only mustard agent is stored. The selection of technologies for the last two sites, at Pueblo, Colorado, and Blue Grass, Kentucky, is under way. 

The National Research Council (NRC) is assisting the Army in the selection of a technology for Pueblo with two committees the standing Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee) and the Committee on Review and Evaluation of Alternative Technologies for the Demilitarization of Assembled Chemical Weapons Phase II (ACWII Committee). This report was prepared by the Stockpile Committee, which has provided scientific and technical advice and counsel to the Army s Chemical Stockpile Disposal Program since 1987. The membership of the committee is periodically adjusted to provide the requisite expertise for each study. 

The modified baseline process for Pueblo that the committee examined was developed from successful operations of the baseline system at JACADS and lessons learned during the processing there of mustard-filled munitions. Solutions developed and tested at JACADS for problems encountered during the disposal of mustard-filled munitions were the basis for process modifications and arc considered to be applicable to the PCD stockpile. The committee s principal observations from the JACADS experience arc as follows ... 

The Stockpile Committee is preparing a report for release in 2001 on the ongoing closure activities for JACADS. This report could provide useful guidance to the Army for making timely closure decisions regardless of the technology selected for implementation at Pueblo. 

The facility] would have to be determined to be as safe as and as cost efficient as baseline incineration. It must also be capable of completing destruction of the Pueblo Chemical Depot stockpile by the later of the Chemical Weapons Convention destruction date or the date the [PCD] stockpile would be destroyed if baseline incineration was used. 

A site-specific Phase 1 QRA for a baseline incineration system at Pueblo was prepared and published in 1998 (SAIC, 1998). The causes of potential accidents considered included failures of equipment, human error, and external phenomena such as earthquakes and airplane crashes. Intentional acts, such as sabotage, were not included, nor were nonagent health risks (which will be covered in the HRA). The Phase 1 QRA concluded that the probability of one or more public fatalities from operation of the baseline system is very much lower than the risk of storing the stockpile for 20 years. However, the probability of fatalities at Pueblo under either scenario was estimated to be very much lower than at the other baseline sites (Table 4-1). 

As Table 4-1 shows, it is much less risky to destroy the stockpiled agents at these sites than to continue storing them. The table also shows that a baseline facility at Pueblo has the... 

The discussion and development of the framework for risk comparisons must involve community stakeholders. The Pueblo city and county government and many members of the community are anxious for demilitarization activities to be completed as soon as possible in a way that ensures the safety of all concerned. Although some redevelopment on the PCD site has already begun, full commercial development of the site cannot begin until demilitarization of the PCD stockpile is completed. 

Stakeholders that provided input for this study were the PCD, the Chemical Stockpile Emergency Preparedness Program (CSEPP), the Colorado Department of Public Health and Environment (DPHE), the Working Integrated Project Team, the Colorado Citizens Advisory Commission (CAC), and, most importantly, people who live in Pueblo. 

At meetings in September and December 2000 attended by members of the Stockpile Committee and PMCD and PM AC W A representatives and their contractors attempted to explain the technologies under consideration in the EIS process for the Pueblo site. The technologies and the EIS process are very complex, and some CAC members and members of the audience appeared to be somewhat confused. Personnel associated with the PUCDF project had some difficulty describing clearly the features of the designs and justifications for them, as well as putting levels of risk in perspective. The following concerns were expressed by CAC members about the modified baseline process ... 

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