Update on NRC Recommendations for a Modified Baseline Process at Pueblo Chemical Depot (2002)

Advisers to the Nation on Science, Engineering, and Medicine

National Academy of Sciences

National Academy of Engineering

Institute of Medicine

National Research Council

In August 2001, the National Research Council’s Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program completed and published a study assessing a modified baseline process for destruction of the mustard agent stored at Pueblo Chemical Depot in Colorado (NRC, 2001). The Defense Acquisition Board (DAB) of the Department of Defense was charged with deciding on the appropriate technology for application at Pueblo and had originally planned to make its decision in September 2001. The committee recommendations in August were timely and appropriate to assist in making that decision. Subsequently, the DAB decision was deferred until late January 2002. In briefings to the committee on October 24–25 (Herbst, 2001; O’Shea, 2001; Thomas, 2001) and on November 14 (Handa, 2001), the Army Program Manager for Chemical Demilitarization (PMCD) and members of his staff noted significant progress in response to committee recommendations made in the August report (NRC, 2001). This letter represents an update and presents the NRC’s independent evaluation of the current status of the modified baseline process to support the DAB decision.

The Executive Summary of the August 2001 report stated that the committee believes “that a modified baseline process, derived from the baseline incineration system, is a workable concept for destroying the chemical stockpile at Pueblo Chemical Depot.” A proviso to this statement noted the need to successfully overcome the challenges summarized in the 20 findings and 22 recommendations collected in Chapter 5 of the report. These findings and recommendations do not carry equal weight in the technology decision. Those that are most critical address issues necessary to assure decision makers

that the modified baseline process will prove to be as safe and as cost efficient as the baseline incineration system from which it was derived. The committee stands by the original position that the modified baseline process can potentially destroy the chemical weapons material at Pueblo at an earlier date than the baseline system.

The committee notes that the recommendations it considers most critical to the technology decisions are being addressed by the Army. Experimental tests have been conducted with single projectiles filled with agent surrogate, and multiprojectile tests were to be carried out during the December 2001 to January 2002 time frame to verify the modeling effort. In addition to the fundamental Recommendation 2–1, calling for evaluation of a process design for the destruction of mustard-filled munitions using a four-zone metal parts furnace, which the Army is pursuing, the six other recommendations considered most critical to the technology decision can be grouped into three sets:

• Recommendations 2–2 and 3–2 say the Army should examine the need to freeze the mustard agent; if this is determined to be the best approach, experimental data should be obtained on the behavior of the frozen mustard rounds when they are fed into the metal parts furnace.

• Recommendations 2–4 and 3–7 say the Army should prove, through testing, an acceptable technique for capturing heavy metals, especially mercury and cadmium, from the incinerator’s gaseous effluent.

• Recommendations 3–4a and 3–4b say the Army should decide on a preferred technique for accessing the agent cavity in frozen rounds and that it should ensure timely development of required machinery and tools to enable the chosen technique to meet the current Chemical Weapons Convention treaty deadline.

The committee believes that carrying out the above-recommended activities is basic to making the proposed modified baseline process suitable for adoption. Progress in responding to the committee recommendations is noted as follows:

• The Army has adopted in situ freezing of mustard agent in munitions as a key element of the modified baseline process. This technique is the basis for ongoing design of the process at Pueblo. The theoretical combustion model developed by Continental Research and Engineering Company has been adjusted to consider the introduction of frozen rounds to the metal parts furnace (MPF). To date, the results of tests with frozen surrogate are consistent with theoretical model conditions and results. These tests have been carried out with single projectiles, highly instrumented to provide data. They demonstrated that melting precedes vaporization and that no plugs of frozen material are ejected from the projectiles. Further testing to validate these results, feeding six projectiles at a time into a furnace, was scheduled to have been completed at the Hazen Labs in December 2001 (Herbst, 2001). Phase change tests were to have been finished on November 30, 2001; multiprojectile combustion tests, in December 2001; and complete modeling, in January 2002 (Thomas, 2001). Successful multiprojectile combustion tests are essential to moving the design of the MPF forward.

• Tests were conducted at the Tooele Chemical Agent Disposal Facility in July 2001 using spiked agent feed to determine the level of heavy metal removal expected for the modified baseline. Compliance with current emission standards was achieved for the metals tested, which included cadmium, cobalt, copper, lead, manganese, nickel, and zinc. For each metal evaluated, greater than 99.9 percent removal was achieved. Emission levels of lead were measured at 1.3E-04 Ib/hr, for example, and those of cadmium at <5.3E-06 Ib/hr (EG&G, 2001). Mercury removal was not evaluated. Surrogate spiked with metals, including mercury, will again be tested at the Anniston Chemical Agent Disposal Facility in a trial burn planned for completion in March 2002. The pollution abatement system will be tested both with and without its associated carbon filter system. Results will be obtained both for plain activated carbon in the filter system and for activated carbon impregnated with potassium iodide and/or sulfur. Preliminary tests, subject to confirmation by trial burn results, show that capture of heavy metals to the required standard is feasible (Thomas, 2001).

• A decision has been made on the process for accessing the agent cavity, based on proof-of-principle testing conducted in May and June of 2001. Work is proceeding on the design of special machinery to punch the round and crumple the burster well in order to access the agent. Tests with frozen agent surrogate on the three types of projectiles showed no failures in obtaining access. Twenty tests were conducted with both the 105- and 155-mm projectiles and ten with the mortar rounds. The design will incorporate a means of catching the small amount of frozen agent that can spray out of an overfilled projectile. Prototype design was initiated in November 2001, with completion expected in February 2002. Production schedules project delivery of this system at least three months in advance of the completion of construction of a modified baseline process at Pueblo (Thomas, 2001). Although the committee is unable to state definitively for this report whether these time estimates are realistic, given the simplicity of the proposed system, they appear to be.

The remaining recommendations from the August 2001 report are considered important; some address administrative and management issues and would be applicable to any of the technology options under consideration for the Pueblo site. These recommendations and the current status of work by the Army to respond to them are as follows:¹

• Recommendation 2–3 says the Army must verify that the modified process is as applicable to HT-filled munitions as it has been shown to be for HD. Surrogates for HT have been tested by Continental Research and Engineering, and results are promising. Single projectile tests with surrogate have shown that there is no sudden liquid or vapor release when frozen rounds are placed in a furnace at operating temperature; rather, the material inside melts and then vaporizes. Thermal diffusivity data for the surrogate and agents support the conclusion that there should be no appreciable difference in this behavior for munitions filled

with surrogate and those filled with either HT or HD agent. Trial burn tests will be required to confirm this conclusion prior to final design completion (Herbst, 2001).

• Recommendation 2–5 says the Army must verify that secondary wastes can be disposed of satisfactorily in the metal parts furnace (MPF). Operations at the Johnston Atoll Chemical Agent Disposal System (JACADS) have established the feasibility of disposal of secondary waste in the MPF (O’Shea, 2001).

• Recommendation 3–1 says a decision is needed regarding options for the disposal of energetics. The Army reports proceeding on two options simultaneously: (1) incorporating a deactivation furnace system (DFS) into the overall modified baseline process and (2) shipping material off-site for destruction at an approved facility for energetics disposal. The Army reports that work is proceeding well on obtaining regulatory approval from Colorado officials for either option. Further testing will be required during operation to ensure that the material proposed for off-site shipment meets regulatory requirements. Should the modified baseline process be selected, a decision between options is scheduled for not later than the second quarter of fiscal year 2003 (EG&G, 2001).

• Recommendation 3–3a says the Army should consider carefully the impact of a probable delay in permitting a modified baseline process at Pueblo. The Army believes that its close and continuing communication process with Colorado regulatory officials means there will be no serious permitting delays due to technical factors (Thomas, 2001). However, the committee believes that political opposition could have adverse effects on the permitting process (CAC, 2001).

• Recommendation 3–3b says the Army should evaluate the introduction of thawed munitions into the MPF, which was the procedure used at JACADS. PMCD considered this option and rejected it in favor of introducing frozen rounds, as originally contemplated. Studies to date indicate that the MPF can handle frozen rounds (Thomas, 2001). The Army believes that to freeze rounds simply to access the agent cavity and then thaw them before introduction to the MPF would complicate the process unnecessarily. The committee notes that, while this is the probable resolution of the issue, results of the Health Risk Assessment (HRA) currently under way will be necessary for regulatory approval of this operating procedure.

• Recommendation 3–5 says the Army should evaluate alternative methods of capturing mustard agent when the agent cavity is exposed if freezing is not adopted. Munition freezing is the only option currently under consideration by the Army.

• Recommendation 3–8 says lessons learned at JACADS regarding disposal of secondary wastes should be applied to the design of facilities at Pueblo for the modified baseline process. The Army appears to be doing this effectively. Proof of the effectiveness of JACADS waste disposal processes is emerging as JACADS proceeds with closure (O’Shea, 2001). The single secondary waste that must be handled differently from how it was done at JACADS is spent decontamination solution (SDS). This waste was processed through the liquid incinerator (LIC) afterburner at JACADS and at the Tooele baseline facility. Since a LIC is not included in the modified baseline design, the Army proposes to

inject the SDS into either the MPF or the DFS afterburner. The efficacy of this proposed solution remains to be proven. Disposal of SDS via the MPF or the DFS is so similar to its disposal through the LIC, which was a success, that the committee expects a successful test. Testing remains necessary, however.

• Recommendation 3–9 says the Army should seek to install continuous monitoring devices to record emissions of heavy metals as well as other sensitive products of incomplete combustion; alternatively, if the technology required for continuous monitoring is unavailable, the Army should at least plan for periodic stack tests to detect and measure these emissions. Evaluation of possible devices and technology to provide continuous emissions monitoring remains in a preliminary stage. Further technology evaluation is required both for heavy metals and products of incomplete combustion (EG&G, 2001). This is important for a facility at Pueblo as well as for all other PMCD baseline system disposal facilities and should be accelerated.

• Recommendations 4–1 and 4–2 say the Army should establish a comprehensive risk management framework. Such a framework would facilitate the tasks of identifying risk elements and developing the criteria for risk comparisons mandated by Public Law 105–261 and the Notice of Intent issued pursuant to the National Environmental Policy Act. Progress on this recommended activity has not yet been reported by the Army.

• Recommendations 3–10, 3–11, 4–3, and 4–4 admonish the Army to prepare from the beginning for facility closure, relying heavily on JACADS lessons learned and value-engineering techniques. Office of Management and Budget (OMB) circulars on capital project development should be followed in the project planning process. Safety must be given the highest priority during all aspects of project planning, design, construction, operations and maintenance, and closure. Effective public involvement must remain a high and continuing priority effort. Specifically, these four recommendations deal with facility closure, preproject planning, safety, and public interaction, all of which are important, continuing obligations of the PMCD. Varying degrees of attention and success have been noted in Army briefings; however, in all four areas, efforts are continuing and will be applicable to any technology selected. These recommendations also apply to Army actions throughout the life cycle of the Chemical Stockpile Disposal Program, from design and construction completion, systemization, and commencement of operations, to the initiation of closure.

The Army has responded to the August 2001 NRC report and has taken a series of actions on the committee’s recommendations. Development of a mature and final plan for a modified baseline disposal facility at Pueblo remains a work in progress. Some additional efforts are required to assure that the modified baseline process can be implemented as envisioned. The committee remains satisfied that “a modified baseline process, derived from the baseline incineration system, is a workable concept for destroying the chemical stockpile at Pueblo Chemical Depot (NRC, 2001, p.1).” While challenges remain, the committee believes that the Army has made progress since the

August 2001 report was issued, and it identified no insurmountable problems. The trends reported by the Army at its October 24–25, 2001 briefings and during a committee member visit with PMCD staff on November 14, 2001, are favorable (Handa, 2001). Progress is noteworthy, but combustion tests with multiple frozen projectiles, critical to the MPF design evaluation, were still to be carried out. Removal of mercury and other heavy metals from the gas stream remains to be demonstrated in the trial burn to be conducted at the Anniston Chemical Agent Disposal Facility.

1. The modified baseline process has progressed to become a viable technical option and should be considered for adoption at the Pueblo Chemical Agent Disposal Facility.

2. The Army should complete the combustion tests as quickly as possible.

3. To confirm vendor claims, the Army should evaluate operating data from units using impregnated activated carbon to determine its efficacy in adsorbing mercury.

4. The Army should accelerate its evaluation and acquisition of continuous emission monitors for heavy metals and organics.

5. The Army should complete its trial burn evaluation of heavy metal removal at the earliest possible time.

6. The Army should continue to respond to overall NRC recommendations regarding the modified baseline process, barring the selection of a different process technology.

Respectfully yours,

Peter B.Lederman, Ph.D.,

Chair

Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program (Stockpile Committee)

CAC (Citizens Advisory Commission). 2001. Draft letter from the Colorado Chemical Demilitarization Citizens Advisory Commission to the Defense Acquisition Board Concerning the Destruction of Chemical Weapons Stored at the Pueblo Chemical Depot, undated, presented at a meeting of the CAC, Avondale, Colo., on December 6, 2001.

EG&G. 2001. Tooele Chemical Agent Disposal Facility (TOCDF) LIC Metal Demonstration Test report. Tooele, Utah: EG&G Defense Materials, Inc.

Handa, O. 2001. Modified Baseline Process. Briefing by Om Handa and other staff, Program Manager for Chemical Demilitarization, to the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Aberdeen Proving Ground, Md., November 14.

Herbst, C. 2001. Experimental and Theoretical Investigations Addressing Issues Related to the Processing of Frozen Mustard Rounds in the Pueblo MPF. Briefing by Christopher A.Herbst, Continental Research and Engineering Co., to the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Woods Hole, Mass., October 24.

NRC (National Research Council). 2001. A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot. Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program. Washington, D.C.: National Academy Press.

O’Shea, L. 2001. JACADS Closure Campaign. Briefing by Leo O’Shea, JACADS Closure Phase Project Manager, Washington Demilitarization Company, to the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Woods Hole, Mass., October 25.

Thomas, T. 2001. Pueblo Modified Baseline Update. Briefing by Timothy Thomas, Operations Division Chief, Office of the Project Manager for Chemical Stockpile Disposal, to the Committee on Review and Evaluation of the Army Chemical Stockpile Disposal Program, Woods Hole, Mass., October 24.