A Modified Baseline Incineration Process for Mustard Projectiles at Pueblo Chemical Depot (2001)

The United States is a signatory to the 1997 international Chemical Weapons Convention (CWC), which mandates the destruction of all chemical agent and munitions stockpiles by April 29, 2007. The Army has undertaken a program funded by the Congress to meet that deadline. Of the original 31,496 tons of chemical agents in the nine U.S. stockpiles, more than 7,000 tons, approximately 22 percent, have been destroyed in two chemical agent disposal facilities, the Johnston Atoll Chemical Agent Disposal System (JACADS) on Johnston Island (part of Johnston Atoll) southwest of Hawaii and the Tooele Chemical Agent Disposal Facility (TOCDF) in Utah.¹ These facilities and three similar facilities under construction in Anniston, Alabama; Pine Bluff, Arkansas; and Umatilla, Oregon, use or will use the baseline incineration system to process the stockpiles at those sites.

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.

In April 2000, the Army published a notice of intent (NOI) to prepare a site-specific environmental impact statement (EIS) for a facility to destroy the mustard agent and munitions stored at Pueblo Chemical Depot (PCD) in accordance with National Environmental Policy Act (NEPA) requirements. Four technology options are under consideration: the baseline incineration system, a modified baseline process, and the two neutralization-based² processes noted above. The NOI also listed the possibility of continued storage of the munitions.

The Army originally intended to use the baseline incineration system at Pueblo but later reconsidered. For various reasons, the choice of a technology has still not been formalized. This report was written in response to a request by the Army’s Program Manager for Chemical Demilitarization (PMCD) that the National Research Council evaluate a proposed modified baseline process for the disposal of the stockpile of mustard agent munitions at PCD. The modified baseline process is a simplified, second-generation version of the baseline incineration system developed in response to lessons learned during the processing of mustard agent munitions at JACADS.

The Assembled Chemical Weapons Assessment (ACWA) Program was funded under Public Law 104–208 and subsequent congressional legislation to pursue the development of alternative technologies for the disposal of assembled chemical weapons. The Program Manager for Assembled Chemical Weapons Assessment (PMACWA), who is responsible for conducting research and development for the ACWA Program, reports to the Under Secretary of Defense for Acquisition, Technology, and Logistics, not to the Army. PMACWA published a second, separate NOI in April 2000 announcing its intent to prepare a programmatic EIS to cover the design, construction, and operation of one or more pilot test facilities for the ACWA technologies selected for implementation at any of the stockpile sites. Se-

lected technologies must meet the requirements specified in Public Law 105–261:

1. as safe and cost effective for disposing of assembled chemical munitions as is incineration of such munitions; and

2. as capable of completing the destruction of such munitions on or before the later of the date by which incineration were used or the deadline date for completing the destruction of the munitions under the Chemical Weapons Convention; and…

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.

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 (ACW II 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 ACW II Committee advises the U.S. Department of Defense (DoD) on its ACW A Program. Since 1997, the ACW II Committee and its predecessor (the ACW I Committee) have followed the development of several alternative (to incineration) technologies for the demilitarization of assembled chemical weapons. In parallel with this modified baseline process report, the ACW II Committee is preparing a report to evaluate the two ACWA technologies being considered for Pueblo.

The statement of task for a study of the modified baseline process was agreed upon by the NRC and the PMCD:

The Stockpile Committee should:

• review documented lessons learned by the PMCD during baseline incineration system disposal operations for mustard projectiles conducted at the Johnston Atoll Chemical Disposal System (JACADS)

• assess tailoring by the PMCD of the lessons learned at JACADS for disposal of the mustard projectiles located at the Pueblo Chemical Depot

• monitor developments with respect to the NEPA [National Environmental Policy Act] EIS process for a chemical disposal facility at the Pueblo site that will consider not only a modified baseline incineration system but also the original baseline system and demonstrated ACWA technologies

• receive briefings from PMCD project personnel, NEPA document preparers, and other stakeholder parties

• conduct site visits as required

• review and evaluate design information generated by the Army for preparing permit applications and complying with the NEPA process in terms of technical feasibility, preliminary safety evaluations, and environmental compliance

• prepare a report for release

In keeping with its statement of task, the committee gathered and reviewed information from numerous sources. In June 2000, the committee was briefed in detail on munition-processing experiences at JACADS that led to the concept of a modified baseline process (personal communication from Gary W.McCloskey, PMCD JACADS Site Project Manager, June 22, 2000). In July and November 2000, PMCD and its contractors provided focused technology briefings to committee members on developments pertaining to the modified baseline process. Committee members also attended meetings in September and December 2000 at which PMCD presented technology reviews to industrial contractors interested in constructing or operating the Pueblo Chemical Agent Disposal Facility (PUCDF). Committee members visited PCD in October and December 2000 and met with PCD management, regulatory representatives, and emergency response personnel. During these visits, committee members also attended meetings of the Colorado Chemical Demilitarization Citizens Advisory Commission (CAC), which are open to the public. Finally, the committee received additional data and information at its regular committee meetings in June and October 2000 and January and March 2001.

Chapter 2 reviews the lessons learned at JACADS. Chapter 3 assesses the adoption of these lessons into the modified baseline process and evaluates the design information available at the time the report was prepared. Chapter 4 presents the results of stakeholder interactions, as well as safety and risk management considerations. Findings and recommendations are provided in each chapter and compiled in Chapter 5.

This evaluation represents the committee’s understanding of the conceptual design of the modified baseline process based on information made available at the time the report was prepared. Because preliminary cost estimates and schedule information were not made available, the committee could not evaluate cost and schedule implications.