Review Criteria for Successful Treatment of Hydrolysate at the Pueblo Chemical Agent Destruction Pilot Plant (2015)

B

Public Interest and Input Documents

Exhibit 1: Committee Approach to Enhancing Public Input: Presentation to the Colorado Citizens’ Advisory Commission, July 30, 2014.

PUEBLO CHEMICAL DEPOT

Chemical weapons waste shipment eyed

National Research Council wants to gauge local attitudes on proposal

BY CHRIS WOODKA

THE PUEBLO CHIEFTAIN

The National Research Council is seeking the views of Pueblo residents on the potential off-site shipment of hydrolysate from the Pueblo Chemical Agent Destruction Pilot Plant after the chemical agent is destroyed.

PCAPP is a facility designed to destroy the stockpile of 780,000 chemical weapons containing 2,600 tons of mustard agent currently stored at the Army’s Pueblo Chemical Depot, 15 miles east of Pueblo. Destruction will begin soon and is expected to be complete by the end of 2017.

Hydrolysate is the waste product that remains following the chemical destruction by hydrolysis of the chemical agent.

The NRC is responsible for determining conditions under which off-site transport of the hydrolysate may be necessary to ensure continued destruction of the stockpile.

“Part of our tasking is to consider stakeholder interests and solicit stakeholder input,” said committee chair Dr. Robert A. Beaudet, an emeritus professor of chemistry at the University of Southern California. “We want to understand the perspectives of the people who live and work in Pueblo.”

The committee also is planning to hold a webinar to describe its efforts and take comments and suggestions if sufficient interest is expressed by members of the Pueblo community. Comments or inquiries should be sent to: Comments_for_NRC_ Hydrolysate_Committee@nas.edu.
cwoodka@chieftain.com

Exhibit 2: Article in The Pueblo Chieftain, September 5, 2014, Publicizing Dedicated E-mail Address for Comments from Stakeholders.

Remarks Made to the
National Research Council
Hydrolysate Committee
By
Irene Kornelly
Chair, Colorado Citizens Advisory Commission

July 29, 2014

The Pueblo community has been an active participant in the destruction of the chemical weapons stored at the Pueblo Chemical Depot from the very beginning of the program. When the Department of the Army originally proposed that the weapons stored at the Depot would be destroyed by incineration, a vocal portion of the community strongly objected to this method. With vigorous lobbying of the Colorado and Kentucky Congressional delegations, the community was pleased to see the passage of legislation that led to the establishment of the Assembled Chemical Weapons Assessment program which became the Assembled Chemical Weapons Alternatives (ACWA) program. Members of the community were active participants in the ACWA Dialogue program and the community followed with great interest as a technology was chosen for Pueblo. On the evening when the CAC voted in favor of the Neutralization/Bio-treatment technology, one of the members gave an impassioned speech and said “it is time to vote for a technology that represents the future and not one that represents the past.” Thus with Department of Defense concurrence, the ACWA program pursued the “technology of the future.”

Originally, the Neutralization/Bio-treatment technology was intended to include not only the neutralization of the agent, but also the energetics and all hydrolysate was to be treated on-site. When DoD determined that the original design was too expensive, all work on the facility came to a halt and the facility was re-designed. With great reluctance the CAC and other stakeholders agreed to off-site shipment of uncontaminated energetics. Work slowly resumed and we are at this moment in time today.

The question of hydrolysate shipment has been under discussion by the ACWA communities - Pueblo and Blue Grass - at least since 2003. Numerous studies have

Exhibit 3: Remarks by Chair of Colorado Citizens’ Advisory Commission to NRC Hydrolysate Committee, July 29, 2014.

been conducted costing an unknown, but presumably, large amount of money. Not to mention the time, attention and effort given to this issue by all parties involved. The most recent was a November 2008 report by Noblis and a November 2008 report by the NRC which looked at all secondary wastes. The November 2008 report indicated that the greatest benefit for both cost and schedule would be realized if the ACWA program acted immediately and that program benefits decreased significantly if actions were delayed. The reports only took the timeline to 2013, but by that time all cost savings were effectively eliminated. A Department of Defense Acquisition Memorandum was issued that clearly indicated that off-site shipment of hydrolysate was no longer under consideration. Now we are back again to look at hydrolysate shipment in the event that the Bio-Treatment Area at the Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP) does not operate successfully. We in the Pueblo community are weary and growing increasingly impatient with continually having to re-address this issue.

The concerns that have been raised about off-site shipment of hydrolysate essentially have remained the same over the years. Of primary consideration must be the issue of dumping our wastes on someone else. While no one is happy that the chemical weapons are stored at the Depot, the issue is a fact and this fact must be dealt with in a responsible manner. Citizens of Pueblo and Colorado, in general, disapprove when someone dumps their trash into a neighbor’s yard, and the reaction is the same when it is suggested that we should dump these industrial wastes (hydrolysate) in another community. This concept is simply wrong. Other concerns that must be addressed are:

1. Identification of transportation routes, both in Colorado and through other states to a Treatment Storage and/or Disposal Facility (TSDF).
2. Identification of the TSDF to be used. The 2008 Noblis report identified three types of TSDF facilities that could potentially accept hydrolysate. These types of facilities included biotreatment facilities, deep-well injection and incinerators. Each of these methodologies has their own pluses and minuses. Deep-well injection and incineration are the most problematic to Pueblo.
3. Assessment of the potential political reaction from other communities affected by plans to move hydrolysate associated with chemical weapons into or through

3. their communities. While Pueblo has a very active Citizen Advisory Commission and an equally active Outreach Office capable of providing information and education to the community, other communities do not have that advantage. Given past experiences, it seems clear that acceptance issues could pose real threats to completing the project in Pueblo in a timely fashion. The community concerns and the delays associated with properly addressing those concerns have the potential to reach beyond the control of the parties currently engaged in the process (DOD, ACWA, the State of Colorado and the Pueblo community), who have the most to gain from transportation. Host communities and communities along transportation routes have little to gain and potentially more to gain from delaying the process if they have concerns (legitimate or not) about the hydrolysate from PCAPP entering or passing through their communities. What are the contingency plans in shipment of hydrolysate to a particular TSDF becomes impossible?
4. The concern about the efficiency and thoroughness of the coordination of all notification, monitoring and management of the hydrolysate shipments, including all of the various federal, state and local agencies that would need to be involved, or should be involved. This issue not only includes the State of Colorado, but all states throughout any proposed transportation routes and the ultimate destination state.
5. The high potential that many communities along the transportation route may want to use this opportunity to enhance their local hazardous waste management and emergency response programs at the expense of this program.
6. The cost of clean-up of a hazardous waste spill as a result of a transportation accident. The costs should be assessed and included as a potential cost to the project. While we have been assured that the shipment of hydrolysis is no more dangerous that shipping “Drano,” I for one do not want spilled Drano in streams or on road surfaces or ditches. It is a dangerous liquid and on the side of each can there are extensive warnings about the toxicity of the contents.

7. The compliance record of the facilities to which the agent hydrolysate might be sent and the financial assurance that the TSDF can not only safely destroy the hydrolysate, but will do so in a timely manner. The compliance record should include OSHA compliance as well as environmental compliance, including Environmental Justice.
8. The potential that the change in the hydrolysate treatment methodology would trigger the need for additional NEPA review as well as changes to the RCRA permit and the Certificate of Designation issued by Pueblo County. The result could be a slow down or interruption in chemical weapons destruction. These delays cost money and pushes out even further ultimate compliance with the Chemical Weapons Convention.

Since the issue under consideration is specifically the potential shipment of hydrolysate should the Bio-Treatment system fail, there are additional concerns that should be addressed.

1. For years the citizens of Pueblo have been assured that the operations of the Bio-Treatment system is no more complicated than a bio-treatment unit at any municipal waste water treatment system throughout the company. In addition Puebioans have been assured that both Bechtel and ACWA have hired the best engineers in the country to ensure that the system will work properly. Now we are asked to consider that the system may not work in accordance with best operating procedures and that we must consider criteria in the event of system failure. These two statements do not compute.
2. One of the first things people in the community asked me when the formation of this committee was announced was “if the ACWA program is rescinding their agreement to treat the hydrolysis on site?” The same question was raised by members of the CAC. Trust between the community and PCAPP is difficult to measure when it is there, but easy to measure when it is not there. A decision to ship hydrolysate would result in a loss of trust between the community and PCAPP.

3. Education and communication are a crucial part of continuing trust and understanding between the community and PCAPP. I am grateful to Mr. Whyne for providing the CAC and the community with a heads-up about the formation of this committee. His assurance that the committee was formed to provide a set of criteria to determine successful treatment of the bio-treatment system and not as a committee to intentionally kill the bio-treatment system was a big factor in community acceptance. While there is still skepticism, the very fact that you are in Pueblo and willing to attend the Permitting Work Group and CAC meetings and allow the public to attend your deliberations goes a long way to eliminate skepticism and distrust.
4. If hydrolysate is shipped to a TSDF, we must consider the loss of water from the facility. The recycling of water was a major component in the selection of a technology for Pueblo where water is a precious commodity. It was previously estimated that shipment of the agent hydrolysate would result in a loss of about 17 acre feet of water. The shipment of hydrolysate would be an expense to the ACWA program because additional costs for water would have to be included. At one time several years ago when it was suggested that the empty tanks could be filled with water on their return trip from New Jersey or Texas, the comment was met with laughter and derision and officials were told in no uncertain terms that water from New Jersey was unacceptable.
5. Lastly, the potential loss of jobs and economic opportunities for the Pueblo community must be addressed if transportation of the hydrolysate is considered a viable option. The citizens of Pueblo have stepped forward for years, allowing these chemical weapons to be stored, handled and disposed of in their backyard. They have directly participated in the construction of the PCAPP facility. That construction project includes the bio-treatment plant. We have built it and we should not be robbed of the economic benefit of operating the plant to its fullest capacity.

Some recommendations that the CAC would ask that the NRC Committee consider when determining the shipment of hydrolysate are:

1. The CAC and stakeholders must be included in establishing the criteria and specific decision points that would be used to determine that hydrolysate shipment is the only remaining option.
2. The CAC and stakeholders must be included in the decision making process should the question of hydrolysate shipment ever need to be addressed.
3. Issues of cost and safety must be considered as well as the impact to local and state law enforcement that will regulate shipment issues.
4. Shipment of the hydrolysate must not be the first and only remedy but the remedy of last resort. Careful analysis should be done in order to determine if there are fixes to the operation. Is one portion of the system inoperable while the rest is operable? Is the inoperable portion so crucial that the remainder of the system cannot be used? All other options must be thoroughly explored and found to be not feasible before the transportation option is ever given serious consideration.
5. Continuous communication must transpire with the community and CDPHE to avoid misunderstandings and obstacles to hydrolysate shipment and facilitate permitting changes that must be approved by the State and County.

On a personal note, I would like to thank you for the opportunity to provide you with the concerns of the CAC. We are a group of citizens that has as its one and only goal the destruction of the chemical weapons stored at the Pueblo Chemical Depot in a safe and environmentally sound manner. Our neighbors and friends work at PCAPP and live in the community and it is our desire to see them come home every evening.

Colorado Chemical Demilitarization

Citizens’Advisory Commission

Irene Kornelly, Chair
1602 Clemson Drive
Colorado Springs, CO 80909
Home 719-591-5157
Cell 719-330-2359
Fax: 719-591-1305
Email: ikornelly@pcisys.net

Members:
Col Jeff Chostner, USAF (Ret.)
Terry Hart, Vice Chair
Kenneth Griffin
John Norton
Joe Schieffelin
Aaron Serna
Ross Vincent

PCAPP Bio-Treatment Area
Concerns of the Colorado Chemical Demilitarization
Citizens’ Advisory Commission (CO CAC)
August 29, 2014

The Bio-Treatment Area (BTA) is the final step in the chemical weapons destruction process at the Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP). The BTA components are the Bio-Treatment System (BTS), the Water Recovery System (WRS) and the Brine Reduction System (BRS). The key to a successful BTA is high- reliability of the processes and the ability of the BTA to meet the output of the neutralization process. Potential failures, risks and mitigation measures to be taken will be a matter of overcoming the limitations of the BTA. In the opinion of the CO CAC, a catastrophic failure of the BTA requiring shipment of the hydrolysate off-site would be a total failure of the biomass or the failure to properly reduce the thiodiglycol (TDG) to 86% or greater. ACWA and PCAPP personnel, however, should be able to mitigate both of these issues.

While it may seem to be a simple matter of shutting down the BTA should one or all parts of the systems fail, there are also risks to the decision to ship the hydrolysate to an unknown destination. These risks come with a monetary cost as well as a loss of schedule. The cost savings that were identified in previous hydrolysate shipment studies are no longer valid as changes had to be made by the end of 2013. The real cost savings identified in these studies were in the reduction in construction costs which are now complete.

Briefly listed, the risks to shipment of hydrolysate are:

• New NEPA documentation - a minimum of an Environmental Assessment would have to be written which could take 6 months or more. Any attempt to push an environmental document without thorough study would cause even a greater delay.
• Class 2 modification of the RCRA permit - another 6 month delay.
• Changes to the Certificate of Designation (CD) by Pueblo County.

Exhibit 4: Follow-up Statement of Concerns from the Colorado Citizens’ Advisory Commission, September 29, 2014.

It is conceivable that some portions of these three tasks could be pursued concurrently, but it is also likely that they will be seen and treated as interdependent at some points in the process, so final completion of one or more of them could be delayed. In addition both the County and CDPHE could grant a Temporary Authority (TA) to PCAPP to begin construction of the loading dock and piping modifications prior to the RCRA approval. However, it is unknown if CDPHE and the County would grant the TA prior to the completion of the NEPA process.

In addition to the changes in MEPA and permitting there are other issues to be considered:

• Modifications would have to be made to the Air Permit.
• Negotiations with the OPCW would have to occur to ensure that the thiodiglycol (TDG) destruction at another facility was tracked as a part of the Chemical Weapons Treaty.
• Costs for the construction of the dock, piping and road access to the dock would have to be included.
• Extensive coordination between federal, state and local agencies would have to occur to ensure that transportation of the hydrolysate was done according to all laws and regulations. The distance between PCAPP and the receiving facility Would determine the complexity of this task.
• Since no water would be recycled due to the shipment of the hydrolysate, water costs for augmentation would have to be negotiated with the Pueblo Board of Water Works.
• Unless an extensive educational campaign was begun, public sentiment in Pueblo would, in general, he opposed to the shipment of hydrolysate. The neutralization/bio-treatment process was presented to Pueblo as a total package. The discussions within the community that have gone on for many years have all reached the same conclusion - do not ship the hydrolysate. A change to this decision would be received with skepticism.

What could go wrong in the BTA and can these potential failures be mitigated? The following is a list of potential concerns in the BTA process, all of which should be able to be mitigated. Bechtel and ACWA are already taking steps to check out each of these concerns with early testing. This knowledge will assist in determining which mitigation measures will have to be taken and what additional maintenance will have to be performed in order to make the BTA process a success.

1. Recycled water does not meet the drinking water standards as established by CDPHE. Can this issue be re-negotiated with CDPHE to meet a lower standard, but still have the Water be re-usable in the hydrolysate process? The answer is probably “yes” and very preliminary discussions have already begun with CDPHE.
2. Air emissions at the BTA do not meet the VIPURA model. Mitigation measures can be taken to ensure that the MPITRA model can be met. The maintenance of the charcoal filters and the use of additional charcoal will add costs to the process.
3. Odors from the BTA are unacceptable and go beyond the boundaries of the Depot. While odor issues are a concern in any bio-treatment area, the extent of the odors can be mitigated so that they are acceptable beyond the boundaries of the Depot.

4. The WRS does not meet the current plan to recover 86% to 95%. In this case costs for water would increase, but this is not a deal breaker. Any recycling of Water is an asset.
5. Equipment within the BTA could fail. Equipment failure can be reduced through a more rigorous maintenance schedule.
6. Corrosion could be a factor. Equipment failure can be reduced through a more rigorous maintenance schedule.
7. Leaks within the BTA. Equipment failure can be reduced through a more rigorous maintenance schedule.
8. pH cannot be controlled. This is an issue of chemistry and ensuring that pH can be controlled.
9. Temperature extremes impact the biomass. Testing is already underway to determine how the extremes in outside temperature coupled with the temperatures created by the biomass and equipment can be mitigated.
10. Inadequate TDG removal which must be at least 86% according to the CWC. If this occurs, this is a potential reason for system failure.
11. Biomass seed does not acclimate to the hydrolysate feed. This is almost a subset of #10 and could also be a potential reason for BTA failure.
12. Solids accumulation in the ICBs. Accumulation can be reduced through a more rigorous maintenance schedule.
13. Sludge accumulation in the WRS. Accumulation can be reduced through a more rigorous maintenance schedule,
14. Fouling in the WRS and BRS. Fouling can be reduced through a more rigorous maintenance schedule.
15. Filter cake has too much liquid. The filter cake can be shipped to a TSDF in a wet-state, but more shipments may be the result.
16. Bio-solids in BRS result in foaming and fouling. Bio-solids can be removed through a more rigorous maintenance schedule.

ACWA, Bechtel Pueblo Team and the CO CAC are of one mind to ensure that the costs to construct the BTA were dollars well spent and that the choice of neutralization followed by bio-treatment was a wise choice made by the community and the Department of Defense. While no one wants to minimize these issues, there is also a determination that all of the potential concerns listed above can and will be resolved to the satisfaction of all stakeholders based on the vast knowledge of those employed to make the BTA a successful part of this process.