Defense Environment Alert
February 26. 2002

MODIFIED BASELINE IS VIABLE TECHNOLOGY OPTION FOR PUEBLO, NRC SAYS

A National Research Council (NRC) panel, in a recent letter to the Army's environment and installations head, says continued progress makes the Army's so-called modified baseline incineration process for destroying chemical weapons a "viable technical option" that "should be considered for adoption at the Pueblo Chemical Agent Disposal
Facility" in Colorado. The review comes not long before the Defense Department is slated to make a final decision on which destruction technology to use at Pueblo, and as public support for using a non-incineration destruction technology there is soaring. I

In a Feb. I letter to Mario Fiori, assistant secretary of the Army for installations and environment, Peter Lederman, chair of the NRC's chemical weapons stockpile committee, updates the Army on recommendations the panel made in August 2001, regarding modified the baseline technology (Defense Environment Alert, Sept. 11, 2001, p10). The update is based on additional testing the Army has conducted and is intended to provide additional "independent evaluation of the current status of the modified baseline process to support" the upcoming Defense Acquisition Board decision on which destruction technology to employ at Pueblo, the letter says. The letter is available on InsideEPA.com. See page 2 for details. A different NRC panel recently issued an update on the potential use of non-incineration technology at Pueblo (see related story).

"Development of a mature and final plan for a modified baseline disposal facility at Pueblo remains a work in progress," Lederman writes. "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,"' he says, quoting from the August 2001 report. "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 letter, in addition to recommending that the technology is a viable option for Pueblo, makes five other recommendations. They are as follows:

• "The Army should complete the combustion tests as quickly as possible.
• "To conform vendor claims, the Army should evaluate operating data from units using impregnated activated carbon to determine its efficacy in adsorbing mercury.
• "The Army should accelerate its evaluation and acquisition of continuous emission monitors for heavy metals and organics." The letter notes that evaluation of these monitoring devices "remains in a preliminary stage," and that further technology evaluation is needed for both heavy metals and products of incomplete combustion. "This is important for a facility at Pueblo as well as for all other [Army] baseline system disposal facilities and should be accelerated," the NRC says.
• "The Army should complete its trial bum evaluation of heavy metal removal at the earliest possible time.
• "The Army should continue to respond to overall NRC recommendations regarding the modified baseline process, barring the selection of a different process technology."

While the NRC notes that the Army is addressing the most pressing technical issues, it reminds the Army that there are other recommendations in its 2001 report that could still affect weapons disposal at Pueblo. For example, the NRC said in August that "the Army should consider carefully the impact of a probable delay in permitting a modified baseline process at Pueblo." The letter says "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.... However, the committee believes that political opposition could have adverse effects on the permitting process."

The letter also says that the Army has not yet reported on whether it has begun establishing a comprehensive risk management framework, as recommended in the August report. "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."