5
Findings and Recommendations

The findings and recommendations presented in Chapters 24 are assembled below and numbered in accordance with the chapter in which they appear.

Finding 2–1. Trial burn results from the 1999 JACADS tests confirmed the required destruction and removal efficiency of 99.9999 percent when 4.2-inch mortar projectiles filled with mustard agent were incinerated through the metal parts furnace at a feed rate of 96 rounds per batch. Subsequently, almost 95,000 mustard projectiles were successfully destroyed in the JACADS MPF by mid-1999.

Recommendation 2–1. Based on the successful JACADS campaigns, the Army should evaluate a process design for Pueblo in which the munitions filled with mustard are processed through an MPF.

Finding 2–2. The 1999 JACADS trial burn did not include introduction of frozen projectiles into the metal parts furnace for final processing. Mustard in the frozen projectiles thawed before entering the MPF.

Recommendation 2–2. The Army should determine whether freezing projectiles before opening the mustard agent cavity to the atmosphere is necessary to mitigate frothing. If so, the Army should determine, by testing, whether frozen projectiles can be processed successfully through a metal parts furnace, or as an alternative, if it is feasible to allow the agent to thaw before the projectiles are fed to a metal parts furnace.

Finding 2–3. HT mustard-filled munitions were not processed at JACADS. HT and HD consist of similar chemicals and will most probably result in much the same products of combustion. Nevertheless, there is no evidence that testing and analysis of HT combustion have taken place.

Recommendation 2–3. Regarding HT, the Army should verify that the combustion of HT will produce results akin to the combustion of HD. These results should be considered in the development of the modified baseline process.

Finding 2–4. The 1999 JACADS trial burn results indicated that mercury and cadmium were emitted at unacceptable levels during the disposal of some mustard agent.

Recommendation 2–4. The Army should prove, through testing, an acceptable technique for capturing emissions of heavy metals—particularly cadmium and mercury—from the metal parts furnace when processing mustard-filled projectiles. An acceptable disposal plan for accumulated heavy metals must be included in the modified baseline process or any other process.

Finding 2–5. Secondary wastes, including dunnage and demilitarization protective ensemble suits, were reported to be successfully processed through the metal parts furnace (MPF) at JACADS, but only limited data on rates, operating conditions, and other parameters for handling these wastes in the MPF have been presented. The best way to handle spent carbon appears to be through the use of a micronizer system.

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, scrubber brine solutions, plant cleaning wastes, and dunnage.

Finding 3–1. The Army has not determined when a commitment to an on-site deactivation furnace system as part of a modified baseline process at Pueblo must be made if a per-



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A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot 5 Findings and Recommendations The findings and recommendations presented in Chapters 2–4 are assembled below and numbered in accordance with the chapter in which they appear. Finding 2–1. Trial burn results from the 1999 JACADS tests confirmed the required destruction and removal efficiency of 99.9999 percent when 4.2-inch mortar projectiles filled with mustard agent were incinerated through the metal parts furnace at a feed rate of 96 rounds per batch. Subsequently, almost 95,000 mustard projectiles were successfully destroyed in the JACADS MPF by mid-1999. Recommendation 2–1. Based on the successful JACADS campaigns, the Army should evaluate a process design for Pueblo in which the munitions filled with mustard are processed through an MPF. Finding 2–2. The 1999 JACADS trial burn did not include introduction of frozen projectiles into the metal parts furnace for final processing. Mustard in the frozen projectiles thawed before entering the MPF. Recommendation 2–2. The Army should determine whether freezing projectiles before opening the mustard agent cavity to the atmosphere is necessary to mitigate frothing. If so, the Army should determine, by testing, whether frozen projectiles can be processed successfully through a metal parts furnace, or as an alternative, if it is feasible to allow the agent to thaw before the projectiles are fed to a metal parts furnace. Finding 2–3. HT mustard-filled munitions were not processed at JACADS. HT and HD consist of similar chemicals and will most probably result in much the same products of combustion. Nevertheless, there is no evidence that testing and analysis of HT combustion have taken place. Recommendation 2–3. Regarding HT, the Army should verify that the combustion of HT will produce results akin to the combustion of HD. These results should be considered in the development of the modified baseline process. Finding 2–4. The 1999 JACADS trial burn results indicated that mercury and cadmium were emitted at unacceptable levels during the disposal of some mustard agent. Recommendation 2–4. The Army should prove, through testing, an acceptable technique for capturing emissions of heavy metals—particularly cadmium and mercury—from the metal parts furnace when processing mustard-filled projectiles. An acceptable disposal plan for accumulated heavy metals must be included in the modified baseline process or any other process. Finding 2–5. Secondary wastes, including dunnage and demilitarization protective ensemble suits, were reported to be successfully processed through the metal parts furnace (MPF) at JACADS, but only limited data on rates, operating conditions, and other parameters for handling these wastes in the MPF have been presented. The best way to handle spent carbon appears to be through the use of a micronizer system. 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, scrubber brine solutions, plant cleaning wastes, and dunnage. Finding 3–1. The Army has not determined when a commitment to an on-site deactivation furnace system as part of a modified baseline process at Pueblo must be made if a per-

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A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot mit for the off-site transport of energetics has not been received. Recommendation 3–1. The Army should develop a process and schedule to determine when a decision must be made between the off-site transport of energetics or their on-site disposal in a deactivation furnace system. To avoid schedule delays, the decision mechanism must account for uncertainties in the permitting process. Finding 3–2. If the Army intends to use the freezing process at Pueblo, data on the behavior of frozen rounds will be essential to confirm the feasibility of a modified baseline process that integrates freezing of the munitions for agent accessing prior to their treatment in the metal parts furnace. Recommendation 3–2. The Army should obtain experimental data on the behavior of frozen mustard rounds fed into the metal parts furnace (MPF). At a minimum, these data should demonstrate that: Frozen rounds (HD and HT) can be processed in the MPF without adverse consequences from the simultaneous presence of agent in solid, liquid, and gas phases, which might lead to spiking of furnace temperatures and pressures from agent confinement and rapid subsequent release in the gaseous phase. Complete volatilization and destruction of the frozen agent in the MPF can be achieved. Solid agent will not be ejected and propelled against internal surfaces of the MPF. Temperatures and residence times necessary to achieve destruction have been determined. Finding 3–3. The committee could not determine whether an experimental program to verify the feasibility of processing frozen mustard rounds in the metal parts furnace would delay the disposal schedule for the Pueblo Chemical Agent Disposal Facility. However, the need for experimental verification is not only a technical consideration, but also a regulatory issue. Although the committee did not evaluate the regulatory climate at Pueblo concerning this issue, obtaining a permit for a one-of-a-kind modified baseline process may be more difficult and more time consuming than obtaining a permit for the baseline system, which has been successfully demonstrated at two facilities and supported with extensive trial burn data. Recommendation 3–3a. The Army should evaluate the risk of delay in obtaining a permit for the proposed modified baseline process at Pueblo that includes the treatment of frozen mustard rounds in the metal parts furnace (MPF). The evaluation should take into account the permitting experience for the process used at JACADS to freeze 201 mustard rounds and feed partially thawed 100-percent-filled mustard agent rounds into the MPF. Recommendation 3–3b. The Army should evaluate the efficacy of allowing frozen munitions to thaw before feeding them into the metal parts furnace of a modified baseline process in a manner similar to the procedure used at JACADS. If the Army intends to include this process step, associated safety, design, maintenance, and regulatory approval issues should be assessed. Finding 3–4. The machines proposed for accessing agent in the modified baseline process differ from the multipurpose demilitarization machines used for this purpose at JACADS. The method proposed for accessing mustard agent should open the munition cavity sufficiently to enable complete destruction of the agent in the metal parts furnace. Recommendation 3–4a. The Army should demonstrate that the method selected for accessing mustard agent opens the munition agent cavity sufficiently to enable complete destruction of the agent in the metal parts furnace. Recommendation 3–4b. If the development and testing of the machines for accessing agent in the modified baseline process would delay disposal operations past the Chemical Weapons Convention deadline, the Army should consider installing another technology at Pueblo. Finding 3–5. Freezing mustard munitions to avoid problems with foaming/frothing of agent is not currently planned for any of the baseline facilities in the continental United States. Recommendation 3–5. The Army should determine whether the method proposed for capturing mustard agent during agent accessing at baseline system facilities could be adapted for use at Pueblo with a potential savings over the cost of developing and testing freezing methods. Finding 3–6. Continuous throughput and safe operation of the metal parts furnace are the most critical aspects of the proposed modified baseline process for Pueblo. The furnace can be sized to operate safely and reliably with substantial loading. Recommendation 3–6. A modified baseline process at Pueblo should include a four-zone (rather than three-zone) metal parts furnace with design provisions to ensure safe shutdown and restarting in the event of operational upsets, such as a loss of electrical power, combustion air supply, or exhaust gas capability. Finding 3–7. The control of emissions of cadmium and mercury by the PFS HEPA and carbon filters has yet to be

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A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot demonstrated. The PFS filters will be tested during systemization at Anniston Chemical Agent Disposal Facility. Recommendation 3–7. Tests and analyses for the control of metal emissions, especially cadmium and mercury (elemental and total) and organics (products of incomplete combustion), should be conducted for the metal parts furnace and afterburner and PAS/PFS prior to completion of the design for the modified baseline process to ensure that emissions are within required limits. Necessary control technologies should be incorporated into the plant design. Finding 3–8. Secondary wastes, which include contaminated dunnage, DPE suits, spent decontamination solution, and contaminated spent carbon, were treated at JACADS using a combination of furnaces and afterburners, or a micronizer and a burner system for spent carbon. Uncontaminated dunnage and spent carbon, slag, and ash were shipped off site to permitted waste disposal facilities after being tested to ensure they were suitable for shipment. Recommendation 3–8. Lessons learned at JACADS from the disposal or decontamination of demilitarization protective ensemble suits and dunnage in the metal parts furnace should be incorporated into the design and operation of the comparable furnace (MPF) of the modified baseline process. Spent decontamination fluid should be injected into the MPF afterburner (or deactivation furnace system [DFS] afterburner) if it cannot be shipped off site. Similarly, contaminated spent carbon can be processed through either the MPF or the DFS if there is one. Uncontaminated dunnage and spent carbon, slag, and ash can be shipped off site to permitted waste disposal facilities after being tested to ensure they meet all requirements for off-site disposal. Finding 3–9. Monitoring systems currently used at existing baseline system facilities appear to be adequate for use in a modified baseline process at Pueblo. The addition of a third, standby automatic continuous air monitoring system unit in the area of the metal parts furnace (MPF) is a reasonable modification in light of the increase in agent throughput over the throughput for the MPF of the baseline system. Notwithstanding the current lack of regulatory requirements for continuous monitoring, further development of monitors for metals and organics is likely to be beneficial for confirming clean emissions. This would also support the Army’s interaction with local citizens by making definitive emissions data more available to the public. Recommendation 3–9. The Army should evaluate state-of-the-art analytical tools for continuous monitoring of emissions of metals, dioxins, and products of incomplete combustion. If they are effective, the Army could install them at chemical agent disposal facilities where applicable. If continuous monitors are not effective, the Army could conduct stack tests for dioxins/furans, mercury, and organics at suitable intervals to provide some additional assurance to the surrounding communities that the modified baseline process is working properly. Finding 3–10. Although the modified baseline concept is derived from the lessons learned at JACADS, no closure plan has been developed. The committee found no evidence of explicit considerations of closure in the design or design criteria of the modified baseline process for the PUCDF. Recommendation 3–10. Engineering, design, and construction plans for the Pueblo Chemical Agent Disposal Facility should incorporate all of the requirements for closure identified at JACADS and other baseline system facilities. Value-engineering studies should be initiated to review all existing designs for conformance to closure principles identified in the forthcoming NRC report on the closure of JACADS. The Army should also initiate closure planning as soon as possible. Finding 3–11. Preproject planning is key to successful large endeavors. OMB Circulars A-94 and A-11 provide guidance for the planning of such projects, particularly with regard to schedules and risk analyses. A planning document of this nature was not provided to the committee. Recommendation 3–11. PMCD should follow the requirements of OMB Circular A-94 and OMB Circular A-11 for capital projects performed by government agencies to improve the prospects for avoiding schedule overruns. Detailed preproject and project plans should be prepared and used as a basis for making important decisions. Finding 4–1. A Phase 1 QRA for using a baseline incineration system at Pueblo has been completed, and the point estimation of the impact on public health indicates that the risk to the public due to accidental releases would be extremely low. The HRA for Pueblo has not yet been completed. Several additional analyses are being conducted to support operational and design decisions for a modified baseline process. It is not clear how the Army is going to use the collective risk information it has or is seeking and in what framework this information will be used. Recommendation 4–1. Before the HRA is completed, the Army should work closely with all stakeholders to decide how the risk of a modified baseline process will be compared with the risk of the baseline incineration system. Such a framework should ensure fair comparison of both configurations as a basis for deciding on the acceptability of the modified baseline process. Finding 4–2. One specific criterion for evaluating the modified baseline design, as documented in the NEPA notice of

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A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot intent for Pueblo, is that the facility be “as safe as” baseline incineration. Because of the very low risk at Pueblo, it is not clear how this and other criteria can be implemented. 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. Finding 4–3. The modified baseline process as currently configured may be simpler than the baseline incineration system. It may possibly be safer if new operations, such as the processing of frozen munitions, are found not to increase risk. Recommendation 4–3. Safety should be given the highest priority during the construction, systemization, operation, and closure of the Pueblo Chemical Agent Disposal Facility, regardless of the technology configuration. Finding 4–4. Some community leaders perceive that the office of the Program Manager for Chemical Demilitarization has not been adequately responsive and forthcoming regarding information requests from concerned citizens and CAC members. Presentations to the public describing the modified baseline process have not been as clear or informative as possible. Recommendation 4–4. The Army should make a greater effort to educate the public about possible disposal processes, as well as the relative risk of continued stockpile storage versus disposal. Army officials responsible for the Chemical Stockpile Disposal Program, in close coordination with the commander of the Pueblo Chemical Depot and other local Army representatives, should strive to maintain and improve open communications with the public, the Citizens Advisory Commission, and interest groups. A Review of the Army’s Public Affairs Efforts in Support of the Chemical Stockpile Disposal Program may be used for guidance. The Army should be particularly responsive to questions and requests for information from local officials and other stakeholders, taking every opportunity to discuss the Chemical Stockpile Disposal Program with the public. All presentations for the public and other stakeholders must be targeted, clear, and of a high professional caliber.