The Pueblo Chemical Agent-Destruction Pilot Plant’s (PCAPP) Biotreatment Area (BTA) will breakdown hydrolysate, the product of chemical agent neutralization process, into water, salts and organics. Contingency planning was initiated for the highly unlikely possibility the BTA experiences a failure.
The National Academies of Sciences, Engineering, and Medicine (NASEM) conducted a study, “Review Criteria for Successful Treatment of Hydrolysate at the Pueblo Chemical Agent-Destruction Pilot Plant.” The NASEM committee found that because of the first-of-a-kind application of a combination of technologies, it would be prudent to establish a backup plan to the secondary on-site treatment processes.
As a result of this recommendation, the PCAPP team developed an off-site shipment contingency plan should the BTA fail. As part of this planning, a Record of Environmental Consideration (REC) was developed to reference previous construction and operation actions analyzed under the National Environmental Policy Act, which addresses the construction of the loading station terminal.
A REC is a signed statement submitted with project documentation that briefly documents that an Army action has received environmental review.
As a contingency backup, the construction of a loading station terminal for the shipment of mustard agent hydrolysate from PCAPP to an off-site Treatment, Storage, and Disposal Facility (TSDF) is being considered.
An evaluation of the transport of treated hydrolysate from PCAPP to TSDFs, up to 2,000 miles away, was conducted. The results indicate the transportation risk is acceptable and no mitigation measures are necessary.