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THE NATIONAL ACADEMIES PRESS • 500 Fifth Street, NW •
Washington, DC 20001

NOTICE: The project that is the subject of this report was approved
by the Governing Board of the National Research Council, whose
members are drawn from the councils of the National Academy of
Sciences, the National Academy of Engineering, and the Institute of
Medicine. The members of the committee responsible for the report
were chosen for their special competences and with regard for
appropriate balance.

This study was supported by Contract No. W911NF-14-1-0280

between the National Academy of Sciences and the U.S. Army. Any
opinions, findings, conclusions, or recommendations expressed in
this publication are those of the author(s) and do not necessarily
reflect the views of the organizations or agencies that provided
support for the project.

International Standard Book Number-13: 978-0-309-31788-7

International Standard Book Number-10: 0-309-31788-6
Epub ISBN: 0-309-31791-6

Limited copies of this report are available from the Board on Army
Science and Technology, National Research Council, 500 Fifth Street,
NW, Room 940, Washington, DC 20001; (202) 334-3118.

Additional copies of this report are available from the National

Academies Press, 500 Fifth Street, NW, Keck 360, Washington, DC
20055; (800) 624-6242 or (202) 334-3313 (in the Washington
metropolitan area); http://www.nap.edu.

Copyright 2015 by the National Academy of Sciences. All rights

reserved.

Printed in the United States of America

THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and
Medicine

The National Academy of Sciences is a private, nonprofit, self-

perpetuating society of distinguished scholars engaged in scientific
and engineering research, dedicated to the furtherance of science
and technology and to their use for the general welfare. Upon the
authority of the charter granted to it by the Congress in 1863, the
Academy has a mandate that requires it to advise the federal
government on scientific and technical matters. Dr. Ralph J. Cicerone
is president of the National Academy of Sciences.

The National Academy of Engineering was established in 1964,

under the charter of the National Academy of Sciences, as a parallel
organization of outstanding engineers. It is autonomous in its
administration and in the selection of its members, sharing with the
National Academy of Sciences the responsibility for advising the
federal government. The National Academy of Engineering also
sponsors engineering programs aimed at meeting national needs,
encourages education and research, and recognizes the superior
achievements of engineers. Dr. C. D. Mote, Jr., is president of the
National Academy of Engineering.

The Institute of Medicine was established in 1970 by the National

Academy of Sciences to secure the services of eminent members of
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pertaining to the health of the public. The Institute acts under the
responsibility given to the National Academy of Sciences by its
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and, upon its own initiative, to identify issues of medical care,
research, and education. Dr. Victor J. Dzau is president of the
Institute of Medicine.
The National Research Council was organized by the National
Academy of Sciences in 1916 to associate the broad community of
science and technology with the Academy’s purposes of furthering
knowledge and advising the federal government. Functioning in
accordance with general policies determined by the Academy, the
Council has become the principal operating agency of both the
National Academy of Sciences and the National Academy of
Engineering in providing services to the government, the public, and
the scientific and engineering communities. The Council is
administered jointly by both Academies and the Institute of
Medicine. Dr. Ralph J. Cicerone and Dr. C. D. Mote, Jr., are chair and
vice chair, respectively, of the National Research Council.

www.national-academies.org
COMMITTEE ON REVIEW CRITERIA FOR SUCCESSFUL
TREATMENT OF HYDROLYSATE AT THE PUEBLO AND BLUE
GRASS CHEMICAL AGENT DESTRUCTION PILOT PLANTS

ROBERT A. BEAUDET, University of Southern California, Pasadena

(retired), Co-Chair
TODD A. KIMMELL, Argonne National Laboratory, Washington, D.C.,
Office, Co-Chair
EDWARD J. BOUWER, Johns Hopkins University, Baltimore, Maryland
JUDITH A. BRADBURY, Independent Consultant, Knoxville,
Tennessee
REBECCA A. HAFFENDEN, Argonne National Laboratory, Santa Fe,
New Mexico
HANK C. JENKINS-SMITH, University of Oklahoma, Norman
KIMBERLY L. JONES, Howard University, Washington, D.C.
MURRAY G. LORD, Dow Chemical Company, Freeport, Texas
TRISHA H. MILLER, Sandia National Laboratories, Shoreview,
Minnesota
ROBERT PUYEAR, Independent Consultant, Chesterfield, Missouri
WILLIAM R. RHYNE, Independent Consultant, Kingston, Tennessee
PHILLIP E. SAVAGE, Pennsylvania State University, State College
PHILIP C. SINGER, University of North Carolina at Chapel Hill
(retired)

Staff
NANCY T. SCHULTE, Study Director
NIA D. JOHNSON, Senior Research Associate
DEANNA P. SPARGER, Program Administrative Coordinator
BOARD ON ARMY SCIENCE AND TECHNOLOGY

DAVID M. MADDOX, Independent Consultant, Arlington, Virginia,

Chair
JEAN D. REED, Independent Consultant, Arlington, Virginia, Vice
Chair
DUANE ADAMS, Independent Consultant, Arlington, Virginia
ILESANMI ADESIDA, University of Illinois at Urbana-Champaign
STEVEN W. BOUTELLE, Cisco Consulting Services, Herndon, Virginia
EDWARD C. BRADY, Strategic Perspectives, Inc., McLean, Virginia
W. PETER CHERRY, Independent Consultant, Ann Arbor, Michigan
EARL H. DOWELL, Duke University, Durham, North Carolina
JULIA D. ERDLEY, Pennsylvania State University, State College
LESTER A. FOSTER, Electronic Warfare Associates, Herndon, Virginia
JAMES A. FREEBERSYSER, BBN Technology, St. Louis Park,
Minnesota
PETER N. FULLER, Cypress International, Springfield, Virginia
W. HARVEY GRAY, Independent Consultant, Oak Ridge, Tennessee
JOHN J. HAMMOND, Independent Consultant, Fairfax, Virginia
RANDALL W. HILL, JR., University of Southern California, Institute for
Creative Technologies, Playa Vista
JOHN W. HUTCHINSON, Harvard University, Cambridge,
Massachusetts
BRUCE D. JETTE, Synovision Solutions, Burke, Virginia
ROBIN L. KEESEE, Independent Consultant, Fairfax, Virginia
WILLIAM L. MELVIN, Georgia Tech Research Institute, Smyrna
WALTER F. MORRISON, Independent Consultant, Alexandria, Virginia
ROBIN MURPHY, Texas A&M University, College Station
SCOTT PARAZYNSKI, University of Texas Medical Branch, Galveston
RICHARD R. PAUL, Independent Consultant, Bellevue, Washington
DANIEL PODOLSKY, University of Texas Southwestern Medical
Center, Dallas
LEON E. SALOMON, Independent Consultant, Gulfport, Florida
ALBERT A. SCIARRETTA, CNS Technologies, Inc., Springfield, Virginia
JONATHAN M. SMITH, University of Pennsylvania, Philadelphia
DAVID A. TIRRELL, California Institute of Technology, Pasadena
MICHAEL A. VANE, DynCorp International, Lorton, Virginia
JOSEPH YAKOVAC, JVM LLC, Hampton, Virginia

Staff
BRUCE A. BRAUN, Director
CHRIS JONES, Financial Manager
DEANNA P. SPARGER, Program Administrative Coordinator
 Preface

When I had to rotate off the Board on Army Science and

Technology in 1995, the program director asked me if I would like to
chair the first Assembled Chemical Weapons Assessment (ACWA)
Committee. The U.S. Congress had just passed Public Laws 104-201
and 104-208 establishing ACWA. Of course I said I would be happy
to. From that time on, I have been involved with ACWA in one way
or another.
Finally, after all these years, the Army is preparing to destroy the
chemical stockpile at the Pueblo Chemical Depot. The facility, called,
in full, the Pueblo Chemical Agent Destruction Pilot Plant (PCAPP),
will destroy its stockpile of 155-mm and 105-mm artillery shells and
4.2-in. mortars, all of which contain one form or another of the
chemical agent mustard. The munitions are robotically opened and
the mustard collected. The next step in the destruction process is
the neutralization of the mustard with lye to produce a product
called the hydrolysate. The second step, biotreatment of the
hydrolysate, is a first-of-a-kind system that has not been extensively
tested with the hydrolysate. The concerns noted by the earlier
committee are held by this committee as well and are summarized in
this report. Thus, there is some concern that this biotreatment will
not mineralize the hydrolysate to water, carbon dioxide, and salts. In
that case, the Army wants to hedge its bets by considering offsite
transportation and disposal of the hydrolysate. Thus, it asked the
National Research Council (NRC) to form an ad hoc committee to
recommend when the hydrolysate could be sent offsite. The
committee has bent over backward to include and interact with the
public, the stakeholders, and the Citizens’ Advisory Commissions in
Pueblo and Blue Grass. This report presents the committee’s findings
and a recommendation.
Unfortunately, during the course of this study, I developed a
medical problem that prevented me from traveling and being further
involved with the study. And fortunately, Todd Kimmell came to my
rescue and took over the chairing of this committee. Like me, Todd
has also been involved with the ACWA since the beginning of the
program, but from a different perspective. He was part of the team
that developed the initial environmental impact studies that
supported the selection of the ACWA alternative technologies. He
also has a great deal of experience with NRC committees, having
been a member since 2001 of nonstockpile, stockpile, and ACWA
committees. I am greatly indebted to Todd for continuing this work,
and I know I leave the committee in good hands.
Todd and I and the committee thank all the PCAPP staff, including
Rick Holmes, the PCAPP Project Manager; George Lecakes, the
PCAPP Chief Scientist; Bruce Huenefeld, the PCAPP site manager;
Paul Usinowicz, the PCAPP technical advisor; and Irene Kornelly and
Ross Vincent, both members of the Colorado Citizens’ Advisory
Commission, for having patience with us and for answering our
numerous and sometimes naïve questions.
Also, we thank the NRC staff, including the study director, Nancy
Schulte; the program administrative coordinator, Deanna Sparger;
and the senior research associate, Nia Johnson, for their continuous
support, patience, and assistance in producing this report.

Robert A. Beaudet, Co-Chair

Todd A. Kimmell, Co-Chair
Committee on Review Criteria for Successful
Treatment of Hydrolysate at the Pueblo and Blue
Grass Chemical Agent Destruction Pilot Plants
 Acknowledgment of Reviewers

This report has been reviewed in draft form by individuals chosen

for their diverse perspectives and technical expertise, in accordance
with procedures approved by the National Research Council’s (NRC’s)
Report Review Committee. The purpose of this independent review
is to provide candid and critical comments that will assist the
institution in making its published report as sound as possible and to
ensure that the report meets institutional standards for objectivity,
evidence, and responsiveness to the study charge. The review
comments and draft manuscript remain confidential to protect the
integrity of the deliberative process. We wish to thank the following
individuals for their review of this report:

Cheryl A. Burke, Dow Chemical Company,

Charles R. Cantor, Sequenom, Inc.,
Raymond M. Hozalski, University of Minnesota,
Douglas M. Medville, MITRE Corporation (retired),
Leonard M. Siegel, Center for Public Environmental Oversight,
Vernon L. Snoeyink, University of Illinois, and
William J. Walsh, Pepper Hamilton LLP.

Although the reviewers listed above have provided many

constructive comments and suggestions, they were not asked to
endorse the conclusions or recommendations nor did they see the
final draft of the report before its release. The review of this report
was overseen by Hyla S. Napadensky, Napadensky Energetics, Inc.
Appointed by the NRC, she was responsible for making certain that
an independent examination of this report was carried out in
accordance with institutional procedures and that all review
comments were carefully considered. Responsibility for the final
content of this report rests entirely with the authoring committee
and the institution.
 Contents

SUMMARY

1 INTRODUCTION
Related NRC 2013 Report
Need for the Present NRC Study
Organization of This Report
Reference

2 BACKGROUND
Brief Description of the PCAPP Process
Production and Characterization of Hydrolysate
Description of the Immobilized Cell Bioreactors
Description of the Brine Reduction System
References

3 STAKEHOLDER INTERESTS AND ISSUES

Background
Methodology
Summary
Findings and Recommendations
References
4 REGULATORY REQUIREMENTS FOR OFFSITE HYDROLYSATE
SHIPMENT AND TREATMENT
Introduction
RCRA Permitting
NEPA Requirements
Pueblo County Certificate of Designation
Organisation for the Prohibition of Chemical Weapons
References

5 TRANSPORTATION OF CHEMICAL MATERIALS

Regulations of the U.S. Department of Transportation
Historical Transportation of Chemical Munition Materials
Identification of Hydrolysate Transportation Risks
Related Prior NRC Findings and Recommendations
References

6 HYDROLYSATE TREATMENT PERFORMANCE GOALS

Decision Framework for Determining Successful Plant Operation
Performance Criteria for Hydrolysate
Preoperational Testing Data That Factor into the Decision Process
References

7 FAILURE RISKS, SYSTEMIZATION, AND CONTINGENCY

OPTIONS
Failure Risks, Systemization, and Contingency Options in the
Immobilized Cell Bioreactor
Failure Risks, Systemization, and Contingency Options in the
Water Recovery and Brine Reduction Systems
Offsite Shipment as a Contingency Option
References

APPENDIXES

A Statement of Task
B Public Interest and Input Documents
C Biographical Sketches of Committee Members
D Committee Meetings
 Tables, Figures, and Box

TABLES
S-1 Graded Success Scale for Use in Evaluating Overall Operation
and Individual Treatment Processes (ICBs, WRS, BRS)
S-2 Summary of Potential Technical Factors Leading to System
Failure in the Immobilized Cell Bioreactor Units, and
Contingency Options
S-3 Summary of Potential Technical Factors Leading to System
Failure in the Brine Reduction System, and Contingency
Options

1-1 Inventory of Assembled Chemical Weapons at Pueblo

Chemical Depot

2-1 HD Hydrolysate Characterization from 2003 Biotreatment

Testing and RCRA RD&D Permit Waste Analysis Plan
2-2 Key Design Operating and Feed Characteristics for the
Immobilized Cell Bioreactor Units
2-3 Issues Identified in a Review of the Immobilized Cell
Bioreactors and Biotreatment of the Hydrolysate
2-4 Issues Identified in a Review of the Brine Reduction System

5-1 Comparison of Chemical Agent Liquid Treatment Content

5-2 Historical Shipment Data
5-3 Estimated PCAPP Truck Shipments
5-4 Highway Hazmat Incident Summary by Transportation Phase
in 2013

6-1 Graded Success Scale for Use in Evaluating Overall Operation

and Individual Treatment Processes (ICBs, WRS, and BRS)
6-2 Description of How Data Generated During Systemization
Could Be Used to Reduce the Risk of Ineffective Operation or
System Failure, and Possible Alternatives to Reduce These
Risks

7-1 Summary of Potential Technical Factors Leading to System

Failure in the Immobilized Cell Bioreactor Units, and
Contingency Options
7-2 Summary of Potential Technical Factors Leading to System
Failure in the Brine Reduction System, and Contingency
Options

FIGURES
2-1 PCAPP biotreatment area process diagram

4-1 Transitioning of RCRA permit

6-1 Decision framework

7-1 PCAPP BTA process diagram

BOX
6-1 Performance Criteria for Hydrolysate
 Acronyms and Abbreviations

ABCDF Aberdeen Chemical Agent Disposal Facility

ACWA Assembled Chemical Weapons Alternatives1
APG Aberdeen Proving Ground

BGAD Blue Grass Army Depot

BGCAPP Blue Grass Chemical Agent Destruction Pilot Plant
BGCDF Blue Grass Chemical Disposal Facility
BRS brine reduction system
BTA biotreatment area

CAC Citizens’ Advisory Commission

CDPHE Colorado Department of Public Health and
Environment
COD chemical oxygen demand
CSEPP Chemical Stockpile Emergency Preparedness Program
CSTR continuous-flow stirred tank reactor
CWC Chemical Weapons Convention

DAP diammonium phosphate

DOT Department of Transportation

EIS environmental impact statement

EPA Environmental Protection Agency

FAA Federal Aviation Administration

FEA Final Environmental Assessment
FEIS Final Programmatic Environmental Impact Statement
FEMA Federal Emergency Management Program
FMCSA Federal Motor Carrier Safety Administration
FRA Federal Railroad Administration

GAC granular activated carbon

GB nerve agent (sarin)

H Levinstein mustard agent

HD distilled mustard agent
HT distilled mustard mixed with bis(2-
chloroethylthioethyl) ether

ICB immobilized cell bioreactor

LDR Land Disposal Restriction (RCRA)

MCL Maximum Contaminant Level

MINICAMS miniature continuous air monitoring system(s)
MWS munition washout station

NECD Newport (Indiana) Chemical Depot

NECDF Newport (Indiana) Chemical Agent Disposal Facility
NEPA National Environmental Policy Act
NRC National Research Council

OPCW Organisation for the Prohibition of Chemical Weapons

PCAPP Pueblo Chemical Agent Destruction Pilot Plant

PCD Pueblo Chemical Depot
PEO ACWA Program Executive Office for Assembled Chemical
Weapons Alternatives
PHMSA Pipeline and Hazardous Materials Safety
Administration

QTRA quantitative transportation risk analysis

RCRA Resource Conservation and Recovery Act

RD&D Research and Development and Demonstration
(RCRA)
REC record of environmental consideration

RMA Rocky Mountain Arsenal

TDG thiodiglycol
TDS total dissolved solids
TOC total organic carbon
TSDF treatment, storage, and disposal facility

TSS total suspended solids

VSS volatile suspended solids

VX nerve agent

WRS water recovery system

________________
1 Before June 2003, Assembled Chemical Weapons Assessment.
 Summary

One of the last two sites with chemical munitions and chemical
materiel is the Pueblo Chemical Depot (PCD) in Pueblo, Colorado.
The stockpile at PCD consists of about 800,000 projectiles and
mortars, all of which are filled with the chemical agent mustard.
Under the direction of the Assembled Chemical Weapons Alternatives
(ACWA) program, the Army has constructed the Pueblo Chemical
Agent Destruction Pilot Plant (PCAPP)1 to destroy these munitions.
The primary technology to be used to destroy the mustard agent at
PCAPP is hydrolysis, resulting in a secondary waste stream referred
to as hydrolysate.
PCAPP features a process that will be used to treat the hydrolysate
and the thiodiglycol (TDG)—a breakdown product of mustard—
contained within. The process is a biotreatment technology that uses
what are known as immobilized cell bioreactors (ICBs). After
biodegradation, the effluent flows to a brine reduction system (BRS),
producing a solidified filter cake that is intended to be sent offsite to
a permitted hazardous waste disposal facility. Water recovered from
the brine reduction system is intended to be recycled back through
the plant, thereby reducing the amount of water that is withdrawn
from groundwater. These processes will occur within the
biotreatment area (BTA) of PCAPP. The entire process is detailed in
Chapter 2.
 While hydrolysis itself is a proven technology, as is biotreatment,
never before have these technologies been combined. Considering
the first-of-a-kind nature of the application of this combination of
technologies for destruction of the mustard at PCAPP and TDG
within the hydrolysate, ACWA program officials have been concerned
that the operation may not function as designed, and have been
particularly concerned with the back end of the process,
biotreatment followed by brine reduction and water recovery. ACWA
commissioned a National Research Council (NRC) study, completed
in 2013, Review of Biotreatment, Water Recovery, and Brine
Reduction Systems for the Pueblo Chemical Agent Destruction Pilot
Plant. The authoring committee identified a number of concerns in
this report, but, overall, it had no overarching concerns that the
process would not work on mustard hydrolysate.
The ACWA program managers and the PCAPP facility, including its
contractor design, construction, and operations staffs, believe that
the facility will perform successfully. The NRC committee writing this
report believes that there is a high probability that the PCAPP facility
should be able to perform successfully. However, there is still a
possibility that the biotreatment, water recovery, and/or brine
reduction processes may not perform satisfactorily.
In the event that one or more of these systems is shut down,
even for a short period of time, destruction of the primary stockpile
at PCD may need to be halted unless there is sufficient storage
capacity for hydrolysate while agent hydrolysis continues, or there is
an alternative means for treatment of the hydrolysate. The
committee believes that destruction of the stockpile at PCD must
continue, because it is destruction of the munitions and the agent
that will reduce the primary risk to the local community. Hence, even
though the PCAPP facility is expected to be operated successfully, it
is prudent, even necessary, to establish a backup plan. Installing
additional hydrolysate storage capacity is an option but would
require additional regulatory permitting, and there may be a limit to
how much or how long hydrolysate can be stored.
Finding 1-3. Destruction of the munitions and the agent will
eliminate the primary risk to the local community. Hence, even
though the PCAPP facility is expected to perform successfully, it will
be prudent, even necessary, to establish a backup plan—an
alternative to the onsite treatment processes intended for the
hydrolysate.

An alternative to onsite hydrolysate treatment that may be quickly

implementable would be to ship the hydrolysate offsite to an existing
prequalified, permitted treatment, storage, and disposal facility
(TSDF). To study this alternative, the ACWA program asked the NRC
to form an ad hoc committee, the Committee on Review Criteria for
Successful Treatment of Hydrolysate at the Pueblo and Blue Grass
Chemical Agent Destruction Pilot Plants (referred to in this report as
“the committee”), to assess the PCAPP process and the potential for
offsite transport of the hydrolysate. The committee’s statement of
task can be found in Appendix A.

STAKEHOLDER CONCERNS

Key in the offsite decision process is to consider the concerns of

the local community. As explained in Chapter 3, the local citizenry in
the Pueblo area are represented by a Citizens’ Advisory Commission
(CAC), formed in 2003, that is composed of nine members appointed
by the state governor. The CAC has been and continues to be the
focal point for public discussion of PCAPP issues.
The committee held its first meeting with ACWA and PCAPP
representatives in Pueblo in July 2014 to facilitate local attendance.
It had purposely scheduled the meeting during a period when the
CAC had scheduled one of its public meetings. In this manner, NRC
committee members were able to attend the CAC meeting, introduce
committee members, provide a brief overview of the study, respond
to questions, and emphasize the importance of community input.
Equally important, CAC members were invited to join the meetings
with ACWA and PCAPP, where they could listen in on the
presentations and participate in open discussion. Two members of
the CAC, including the chair, attended the 2-day open meetings.
From these interactions, it has become clear to the committee that
the CAC and PCAPP staff have developed a sound working
relationship. The committee believes that this working relationship
will serve as a strong foundation for a credible consultation process
should issues arise with operation of the PCAPP and the BTA.
The committee also learned during these interactions that the CAC
continues to maintain its long-standing opposition to offsite
shipment of hydrolysate. The committee recognizes the concern of
the CAC, especially members’ skepticism concerning the need for
offsite shipment of hydrolysate, but it also believes that the PCAPP
facility and the ACWA community are firmly behind the commitment
to make the hydrolysis, biotreatment, and brine reduction processes
work. Nevertheless, the committee also believes that a backup plan
is needed.
At the same time, it is prudent and even necessary for PCAPP
officials and ACWA to maintain discussions with the CAC and put in
place an institutional mechanism that would aim to ensure regular,
open communication throughout operations and help to avoid the
potential for misinterpretation of motives and decisions, thereby
enhancing the probability of achieving common program goals,
despite different priorities. Such a mechanism would be
supplementary to, yet part of, the CAC and would build on the sound
relationships that PCAPP and the CAC have worked so hard to
develop.

Recommendation 3-1. In consultation with the CAC, ACWA should

institutionalize an explicit consultation process that focuses on the
potential for offsite shipment. This process should be established
immediately and give stakeholders a clearly defined and meaningful
role. The consultation process should (1) be supplementary to the
more general role of the CAC; (2) provide to the CAC regular
updates on the status of operations as they bear on the possible
need for offsite shipments; and (3) be explicitly designed to ensure
there are no surprises on the part of stakeholders if they are called
on to consider offsite shipments.

REGULATORY ISSUES

As discussed in Chapter 4, regulatory requirements for offsite

hydrolysate shipment and treatment are complex. Requirements
stem from the Resource Conservation and Recovery Act (RCRA), as
administered by the Colorado Department of Public Health and
Environment (CDPHE), the National Environmental Policy Act (NEPA),
and the Pueblo County Board of County Commissioners Certificate of
Designation. In addition, the Organisation for the Prohibition of
Chemical Weapons (OPCW) has requirements applicable to the
treatment of the hydrolysate, whether onsite or offsite.
Should the offsite shipment of hydrolysate become necessary, it is
clear that PCAPP’s RCRA permit would need to be modified. Approval
of a permit modification might take 3 to 6 months or more. Further,
additional NEPA documentation might be needed to support the
offsite option, as this option was never fully evaluated in the
PCD/PCAPP environmental impact analyses performed earlier in
support of the PCAPP technologies. The NEPA documentation
process, if necessary, is also time-consuming and may take months,
depending on the level of controversy.

Recommendation 4-2. PCAPP should process a permit

modification for the RCRA Research and Development and
Demonstration (RD&D) permit that would allow for the offsite
transport of hydrolysate as a backup plan. The modification
application should contemplate a temporary authorization for site
preparation, preconstruction, and similar activities while PCAPP is
operating under the RD&D permit.
RCRA permit modifications and NEPA documentation that support
the backup plan of offsite shipment must be in place as soon as
practical, and all regulatory requirements must be identified and
prebriefed with the CDPHE, the CAC, ACWA, and Pueblo County, so
that should the decision be made that there is no other option,
implementation can be rapid, with no delay for the destruction
mission.

TRANSPORTATION ASSESSMENT

One of the primary concerns regarding potential offsite

transportation of hydrolysate is the risk of a transportation accident.
Chapter 5 summarizes previous offsite shipments of hydrolysate
from other chemical demilitarization facilities (Aberdeen Proving
Ground, Maryland, and Newport Chemical Depot, Indiana), and
offsite shipments of similar agent-associated fluids such as waste
liquids from operation of the explosive destruction system. This
summary demonstrates that hydrolysate and similar fluids have been
shipped offsite without incident many times in the past.
That is not to say that a transportation accident could not occur,
however. But it is important to understand that the hazard here is
not from the presence of mustard within the hydrolysate; during the
hydrolysis process, mustard is reduced to levels that are below the
detection limit of sophisticated analytical instruments. And, although
the presence of TDG is a concern, the primary hazard during
transportation of hydrolysate comes from the caustic nature of the
hydrolysate.
PCAPP hydrolysate may or may not be considered a Class 8
(corrosive) material, but for purposes of risk identification, Class 8 is
assumed.2 Examples of Class 8 materials are hydrochloric acid, nitric
acid, sulfuric acid at a concentration of >51 percent, and solid
sodium hydroxide.
The hazards due to hydrolysate exposure are modest compared to
exposure to materials such as concentrated sodium hydroxide, a
typical Class 8 material, which may be considered a greater hazard.
While the hydrolysate risks may be considered moderate, the
committee concurs with a previous committee, NRC (2008), which
recommended that ACWA perform a quantitative transportation risk
assessment for hydrolysate, including a quantitative assessment of
the human health consequences of hydrolysate. It should also
prepare a prototypical emergency response plan for hydrolysate
shipment (NRC, 2008). These documents will help facilitate
discussions with the public and regulators about the possible
alternative of shipping hydrolysate offsite. As with regulatory
documentation, the transportation assessment and emergency
response plan should be prepared as a backup plan and be ready to
go should it be determined that offsite transport of hydrolysate is
needed (NRC, 2008).

CRITERIA FOR SUCCESS FOR PCAPP

Success for PCAPP operations is defined in Chapter 6. The primary

criteria for successful treatment of hydrolysate are meeting RCRA
permit requirements and ACWA requirements for treatment of the
hydrolysate. This includes the production of a filter cake that meets
regulatory requirements that the cake contain no free liquids and the
production of process water from the BRS that is of good enough
quality that it can be recycled to the plant. In addition, the overall
schedule for destruction of the munitions at PCAPP must be met.
Chapter 6 sets up a decision process for evaluating treatment
alternatives. It includes a number of criteria for evaluating these
alternatives, including the offsite option for hydrolysate treatment. A
graded evaluation of system risk allows stakeholders to qualitatively
rate the potential for overall program success at any point in the
project. This type of graded evaluation will facilitate communication
between stakeholders and allow them to track and document PCAPP
progress in a transparent and consistent way throughout the course
of the project. Table S-1 exemplifies a graded scale for success that
could be used for the PCAPP project.

Finding 6-4. In its recent white paper on risk reduction and

mitigation, PCAPP has done a thorough job of identifying potential
failure risks and providing targeted strategies to mitigate these risks
in the BTA (PCAPP, 2014). Employing the decision-making framework
outlined previously, the overall systemization plan, and the BTA risk
reduction and mitigation plan provides targeted strategies for PCAPP
to mitigate any operational problems that become apparent during
surrogate testing and systemization.

TABLE S-1 Graded Success Scale for Use in Evaluating Overall

Operation and Individual Treatment Processes (ICBs, WRS, and BRS)
Grade Definition
0 Success is practically certain (very low possibility of
project failure): Operations are proceeding as expected.
No PCAPP actions needed.

1 High likelihood of success (low possibility of project

failure): Actions should be taken by PCAPP to prepare
ahead of time for implementation of contingencies in the
event of failures. For example, PCAPP might begin to
prepare permit modifications and planning documents,
including building plans for piping and shipping.

2 Success is uncertain (moderate possibility of project

failure): Actions should be taken to prepare for
implementation of contingency operations. For example,
PCAPP might begin processing environmental
documentation and finalizing contingency plans,
purchasing needed materials, and implementing changes
to the infrastructure.

3 Success is unlikely with current operations (high

possibility of failure of the project): Actions are taken to
accelerate the implementation of contingency operations.
For example, construction of needed facilities is
completed as quickly as possible, and environmental
approvals are expedited if they have not already been
obtained.
NOTE: WRS, water recovery system.
FAILURE RISKS AND CONTINGENCY OPTIONS

In Chapter 7, the committee begins with the graded scale for

success that it introduced in Chapter 6 and discusses a number of
potential failure risks within the BTA at the PCAPP facility. PCAPP
itself identified several such sources of possible failure in the BTA
along with contingency options in its aforementioned white paper on
risk reduction and mitigation. PCAPP’s plan is to troubleshoot the
majority of these risks during facility systemization.
The hydrolysate generated by agent neutralization is a unique and
complex mixture. While ICBs have been used successfully in the past
to treat complex hazardous organic wastes, they have not been used
to treat mustard hydrolysate, aside from bench-scale testing by
ACWA. Hence, there are a number of technical factors that could
lead to incomplete hydrolysate treatment. These include hydrolysate
toxicity to microbial biomass, the need for careful pH and
temperature control, nutrient and oxygen limitations, biomass
buildup and sloughing, start-up and acclimation issues, and release
of odorous compounds. The committee believes that to address
these factors, which could inhibit efficient ICB operations, PCAPP
should develop risk mitigation plans. These plans need to be in place
prior to system start-up so that agent neutralization operations are
not delayed.
Another potential issue with the BTA is the complexity of the
hydrolysate feed. Biodegradation of the hydrolysate has been carried
out in a laboratory setting, but it has never been done with ICBs
under full-scale operating conditions. To address this, PCAPP plans to
test a number of key process variables, identify potential failure
points, and determine optimal ways to operate the downstream
processes at PCAPP. The culmination of these measures is testing
with actual TDG in a surrogate hydrolysate. This testing will be
conducted under full-scale conditions, which the committee believes
should allow for rapid start-up and steady-state operation of the
ICBs when munitions processing begins. Nevertheless, PCAPP should
have contingency plans in place prior to start-up, ready to be
implemented immediately should ICB operation be suboptimal during
the risk reduction and mitigation testing with the surrogate
hydrolysate.

Recommendation 7-1. PCAPP should develop contingency plans

to mitigate risk in the event that one or more of the above factors
inhibits efficient ICB operations. Such plans should be in place prior
to system start-up so that agent neutralization operations are not
unduly delayed.

The committee believes that some operational strategies could be

implemented in the unlikely event of insufficient biotreatment or if
operational problems arise. The technical factors leading to
insufficient treatment in the ICBs along with the contingency options
are summarized in Table S-2. Each factor is also evaluated against
the performance criteria described in Chapter 6 and assigned to a
performance category based on the overall risk to PCAPP operations.
Similar to the ICBs, there are also failure risks with operation of
the WRS and the BRS, and there are also contingency options that
may be taken to address these risks. As explained in Chapter 7,
downstream from the ICBs, the WRS and BRS will enable PCAPP to
recover and recycle most of the process water into munitions
processing. The WRS primarily serves as a holding tank where
effluent from the ICBs and other processes are collected, mixed, and
stored before being transferred to the BRS. Aside from addition of
acid and stripping of carbon dioxide, no treatment or processing
takes place in the WRS. As a result, failure risks and contingency
options are identified only for the BRS.
Technical factors that may lead to insufficient treatment of the ICB
effluent include liquid droplet carryover in the evaporator and
crystallizer; failure or excessive replacement frequency of the
granular activated carbon (GAC) adsorbers; high chloride content
leading to corrosion; excessive biomass or organic compounds
leading to fouling, foaming, or odors; and excess liquid in the filter
cake. PCAPP should develop risk mitigation plans in the event that
one or more of the above factors inhibits efficient BRS operations. As
with the ICBs, these plans need to be in place prior to system start-
up.

Recommendation 7-3. PCAPP should develop contingency plans

to mitigate risk in the event that one or more of the above factors
inhibit efficient BRS operations. Such plans should be in place prior
to system start-up so that agent neutralization operations are not
unduly delayed.

If the BRS does not perform as designed, recycling the water

within the plant at PCAPP may be problematic. This failure will place
much greater strain on the aquifer from which PCAPP withdraws
water. Moreover, the effluent from the ICBs will also need to be
shipped offsite for treatment and disposal. Because the hydrolysate
is diluted eightfold prior to entering the ICBs, the liquid volume
leaving the ICBs is much larger than the original hydrolysate volume.
Therefore, in the event of BRS failure, the committee believes that it
would be prudent to consider shipping undiluted hydrolysate offsite
for treatment and disposal rather than continuing to operate the
ICBs on-site. This action would minimize the total volume of material
that needs to be shipped offsite and it would minimize the fresh
water intake by the plant.
The BRS is expected to operate as planned, but there may be
some issues that, while serious, could be mitigated and would not
result in total BRS failure. The technical factors leading to incomplete
treatment in the ICBs, their impacts, and contingency options are
summarized in Table S-3. Each factor is also evaluated against the
performance criteria described in Chapter 6 and assigned to a
performance category based on the overall risk to PCAPP operations.

TABLE S-2 Summary of Potential Technical Factors Leading to

System Failure in the Immobilized Cell Bioreactor Units, and
Contingency Options
NOTE: DAP, diammonium phosphate.

The committee believes that PCAPP has adequately researched

potential issues with BTA operations and believes that the risk
reduction and mitigation measures to be conducted during
systemization will help identify these issues. And while it believes
that, overall, PCAPP is well positioned for successful operations, the
contingency measures identified above would help to resolve any
issues quickly.

OFFSITE SHIPMENT AS A CONTINGENCY OPTION

 The committee acknowledges that there are many uncertainties
surrounding the start-up and performance of each separate
component within the BTA and that one or more contingency options
may have to be implemented. Each decision may have to consider a
continuum of options, from quick operational tweaks to improve
performance (e.g., changing chemicals to maintain pH levels), to
more long-term operational changes (e.g., longer retention times)
and infrastructure changes (e.g., installing a clarifier) to
accommodate performance issues, to interim actions while other
contingency options are being implemented (e.g., constructing and
employing additional hydrolysate storage capacity), to, finally,
instituting offsite shipment of hydrolysate.

TABLE S-3 Summary of Potential Technical Factors Leading to

System Failure in the Brine Reduction System, and Contingency
Options

NOTE: TSDF, treatment, storage, and disposal facility; TOC, total organic content;
TSS, total suspended solids.
 The committee believes that the optimum outcome is that the
existing BTA operates without the need to implement the offsite
option. It considers offsite shipment of hydrolysate to be the last
resort, the final option on the continuum. However, if offsite
shipment of hydrolysate is implemented, one very crucial decision
that will need to be made is whether the offsite shipment is
temporary or permanent. The committee acknowledges the
possibility that once the decision to implement offsite hydrolysate
shipment is made, it may be necessary to make that process
permanent due to cost, the need for stability, or other
considerations. The committee also acknowledges that the fix or set
of fixes needed for the BTA might take only a few days, or weeks, or
even a month or two, and that it might be possible, after some
delay, to start the process again and continue with onsite
hydrolysate treatment.
Implementing offsite transport of hydrolysate will affect plant,
paper, and people, as discussed in Chapter 7, and the effort to
implement offsite transport will be considerable. If offsite transport is
implemented as a temporary fix, with the intent of restarting the BTA
processes, the effort to switch back to the BTA would also be
considerable. Depending on the length of the delay and whether
staff furloughs or layoffs have occurred, original staff may no longer
be available. Besides, if the BTA processes are restarted, there is no
guarantee that the fix will even work, and PCAPP may need to
restart offsite shipment again. Still, the committee believes that
there may be circumstances under which restarting the BTA
processes, after some delay, may be feasible. The committee
discussed at length whether a change to offsite shipment could be
temporary, or whether this change should be permanent. However,
the committee acknowledges that at this time it is impossible to
predict the exact circumstances of a failure once the plant enters
systemization or actual operations. It therefore concluded that it
would make no specific recommendation concerning the exact
nature, extent, or permanence of any option, including
implementation of permanent, offsite shipment of hydrolysate.
Recommendation 7-7. To preserve the ability to ship hydrolysate
offsite for treatment in the event that offsite shipment is found to be
the only viable option, steps should be taken as soon as possible.
Examples of such steps include initiating permit modifications;
drafting alternative standard operating procedures; preparing
transportation risk documentation; designing process safety controls,
spill containment, and fall protection for hydrolysate loading
facilities; and communicating with stakeholders about if and when
this option would be utilized, including how the stakeholders would
be involved in the decision process.

REFERENCES
NRC (National Research Council). 2008. Review of Secondary Waste Disposal
Planning for the Blue Grass and Pueblo Chemical Agent Destruction Plants.
Washington, D.C.: The National Academies Press.
PCAPP (Pueblo Chemical Agent Destruction Pilot Plant). 2014. White Paper Bio-
Treatment Area Risk Reduction and Mitigation. 24852-30H-BTA-V0001. Rev.
000. April.

________________
1 PCAPP is named a pilot plant because some of the processes used for
destroying the agent and munition bodies have not been used, or used in
combination with each other, before.
2 Class 8 hazmat is defined in 49 CFR 173.136 as a liquid or solid that causes
(1) full thickness destruction of human skin within a specified period of time or (2)
a specified corrosion rate of steel or aluminum.
 1

Introduction

The U.S. effort to destroy its chemical weapons and materiel was
already well under way when, in 1993, it signed the Chemical
Weapons Convention (CWC),1 an international treaty outlawing the
production, stockpiling, and use of chemical weapons. The weapons
and chemical materiel at five of the nine U.S. storage sites have now
been destroyed by robotically opening the munitions, then removing,
collecting, and incinerating the chemical agent, and at two other
storage sites by hydrolyzing the agent with hot water or caustic. The
remaining two sites with chemical munitions and chemical materiel
are the Pueblo Chemical Depot (PCD) in Pueblo, Colorado, and the
Blue Grass Army Depot (BGAD) in Richmond, Kentucky.
In 1996, in response to local opposition to the use of incineration,
the U.S. Congress passed Public Laws 104-201 and 104-208. These
laws froze funds for construction of chemical agent destruction
facilities at PCD and BGAD and directed the Army to demonstrate at
least two alternatives to incineration for the destruction of the agent.
Thus, in 1996, a program then called the Assembled Chemical
Weapons Assessment (ACWA) program was established to evaluate
other means of destroying the chemical agent.
 The ACWA program manager asserted early on that stakeholders
would have their voice considered in the decision-making process.
During the initial phases of the ACWA program, a panel called the
Dialogue Group was established to give stakeholders a voice in all
decision making. The Dialogue Group included representatives of
local citizens, federal, state, and local regulators, the Army, and the
National Research Council (NRC). After the technologies had been
selected, the Dialogue Group was disbanded in favor of Citizens’
Advisory Commissions (CACs), which were based in Colorado and
Kentucky. Both CACs include former members of the Dialogue Group.
The ACWA program has resulted in the selection of alternatives to
incineration at the two sites and has since June 2003 been referred
to by the same acronym, ACWA, but with a slightly different
wording: the Assembled Chemical Weapons Alternatives program.
The stockpile at PCD consists of about 800,000 projectiles and
mortars, all of which are filled with the chemical agent mustard. The
munitions consist of 105-mm and 155-mm artillery shells and 4.2-in.
mortars. The total amount of chemical agent is approximately 2,600
tons. Two forms of mustard are included: HD, distilled mustard, with
the chemical formula Cl-CH2-CH2-S-CH2-CH2-Cl, and HT, an ether
form of HD, (Cl-CH2-CH2-S-CH2-CH2)2O. All the projectiles and three-
quarters of the mortars contain HD; the rest of the mortars contain
HT. All the munitions and their quantities are listed in Table 1-1.
The facility to destroy the munitions at PCD is called the Pueblo
Chemical Agent Destruction Pilot Plant (PCAPP). At the writing of this
report, the plant has been constructed and is now completing
systemization. Risk reduction and mitigation studies are being
conducted concurrent with systemization. Processing of the mustard
munitions through the plant is scheduled to begin in September
2015.2 It is expected that it will require between 4 and 5 years to
completely destroy the PCD stockpile. The PCAPP process involves
hydrolysis of the mustard, followed by biotreatment of the residual,
known as hydrolysate, in immobilized cell bioreactors (ICBs), and
treatment of the ICB effluent in a brine reduction system (BRS).
While destruction of the mustard itself is conducted under the
auspices of the CWC, because the hydrolysate contains thiodiglycol
(TDG), a Schedule 2 compound3 under the CWC, the biodegradation
process is also subject to CWC oversight. The TDG will be
biodegraded within the ICBs.

TABLE 1-1 Inventory of Assembled Chemical Weapons at Pueblo

Chemical Depot

NOTE: HD, distilled mustard agent; HT, distilled mustard mixed with bis(2-
chloroethylthioethyl) ether.

The PCAPP process is described in Chapter 2 of this report. A

subsequent report will address destruction of the stockpile at the
BGAD facility, known as the Blue Grass Chemical Agent Destruction
Pilot Plant (BGCAPP).

RELATED NRC 2013 REPORT

Treatment of the hydrolysate at PCAPP involves biotreatment

followed by brine reduction and water recovery. The biotreatment
system, including the BRS and a water recovery system (WRS), was
extensively reviewed by an NRC committee in 2013 (NRC, 2013).
Relevant findings and recommendations from that study are
repeated in this report as necessary.

NEED FOR THE PRESENT NRC STUDY

Although biotreatment of toxic chemicals, brine reduction, and

water recovery are established technologies, never before have
these technologies been combined to treat mustard hydrolysate. And
while extensive testing of these systems has been conducted by
ACWA in a laboratory setting, the process has never been operated
at full scale. The ACWA program managers and the PCAPP facility,
Random documents with unrelated
content Scribd suggests to you:
 “Thank you! Glad to know I’m light!” cried the irrepressible Tavia.
“Hope it wasn’t my head you referred to.”

“No—er—not exactly—that is—Oh, well, get out if you like, miss,”

said the puzzled Jake, who did not exactly understand Tavia’s
chattering.

“I’m going to,” she retorted, “come on, girls.”

“In those dark woods, with horrid, creepy, crawling things!” cried
Edna. “Never. I can almost see a snake now! Oh!”

“Silly!” snapped Tavia, as she made her way out of the car. She
stood watching Jake make his preparations for replacing the
damaged tire, and even offered to help him work the lifting jack.

“I wonder why she likes to do that?” asked Nita of Dorothy.

“I don’t know, I’m sure,” was the answer, while Tavia actually did
work the handle of the implement that raised the auto wheel clear
from the ground.

“I guess it’s because ‘Jake’ is a boy’s name, and Tavia is so fond of

the boys—in a nice way, of course,” Nita made haste to add. “You
know what I mean, Doro.”

“Yes, of course,” laughed Dorothy. “You needn’t have explained.

Tavia is such a—problem.”

“I fancy we all are—in different ways,” came the remark. “I know

my people say I am. But Tavia!”

“There is only one!” laughed Dorothy softly.

“And a good thing there are no more,” spoke Nita, as she looked
closely at her chum, wondering, as others had done that day, what
was troubling Dorothy.
 For that something was troubling our heroine was evident. It
plainly showed on her face, though she tried to hide it and be her
usually jolly self—jolly, however, in a way different from Tavia.

“Want me to hold the jack?” came from Tavia, in business-like

tones, as she watched Jake deftly go about the work.

“No, thank you, miss. It’s a self-regulating one,” he replied. “It’ll

hold itself. But you might hold one of the oil lanterns so I can see to
unscrew these lugs.”

“I knew there was something queer about this auto,” came from
Tavia with a laugh. “It’s been putting on ‘lugs,’ as the boys say. It got
too gay, and had a puncture. Isn’t that it, Jake?”

“Yes, miss, I guess so, but if you wouldn’t mind, please, holding
that light a little more over this way, I could see better.”

“That’s the time Tavia got a ‘call-down,’ to use some of her own
slang,” commented Molly. “But, Doro, what are ‘lugs,’ pray tell?”

“I guess Tavia used it meaning ‘airs,’ or something like that,” was

the reply. “Will you be much longer, Jake?”

“No, I’ll soon have it on,” the man said, and he was as good as his
word. Then Tavia scrambled up to her seat, after insisting on helping
Jake to put away his tools, and the car started off again, amid heart-
felt murmurs of thanks from the rather tired young ladies.

The machine was gliding over the hills through the moonlight, and
soon the towers of Glenwood would be seen. The “Light House,” the
girls always called the big light in the tower that gleamed until the
village bell struck midnight.

Cologne was in the rear seat with Dorothy. Molly Richards made
the trio, while next came Nita, Lena, and a little frightened girl, all
the way from Georgia. It was her first term, and all the escapades
did not help to make her impression of school life in the North any
the less mystifying.

“What’s up now?” asked Molly, as the big machine came to

another sudden stop.

“Jake sees something,” replied Dorothy. “He has the queerest

habit of seeing things that no one else can see.”

“Yes, there he is getting out. A chicken likely,” put in Nita.

For a few moments the girls waited rather anxiously. Then the
chauffeur came back to the car.

“What is it?” called a chorus.

“Can’t just say yet,” answered Jacob, “but I think it’s one of them
velvet poodles that someone has dropped out of a car.”

“Oh, do let me have it,” begged Jean, who, being with Jake
naturally felt the best right to his find.

“I’ve got to look him over, and see as he isn’t hurt,” replied the
driver. “A little fluff of a thing like this doesn’t lie in the road, when
he’s got the use of his legs.”

“Let us see him, Jake,” implored Tavia. “You know I always take
good care of the Glen dogs—when there are any.”

“So you do—so you do. Well, here it is, as I must be getting on.
But be careful he doesn’t snap. Can’t tell about toy dogs. They’re not
hounds, you know,” and he handed first to Dorothy and she in turn
handed back to Tavia, the little, silken animal that Jake had picked
up on the lonely road.

Jean was piqued. She intended to conquer even Jake, and she
really did like a white toy dog. First she had been obliged to go to
Glenwood in the motor, when she had been all settled for the night,
and wanted to wait for the morning train. Next, she sat outside with
the driver and he refused her simplest request.

“It’s all because of that Dale girl,” she muttered to herself, while
she smiled at Jake. “Won’t you let me drive the car a little way,
please?” she asked. “I am used to motors, and I love to drive on
these hard clean roads.”

Jake looked at her keenly. “I’ve no doubt but you can drive,” he
replied, “but you see I’m responsible to Mrs. Pangborn, and it would
be a queer story for me to tell, if anything happened, that I had let a
school-girl run the big car at this hour of the night.”

Of course the front windows being down, and Jake speaking with
unmistakable distinctness, everyone in the car heard the reply to
Jean.

Tavia was too busy with the poor little white dog to notice. She
had made a bed for him, and indeed the little thing unmistakably
needed rest. He sighed and panted, then he licked the girl’s hands.

“Poor, little thing,” said Edna, “do you suppose some chauffeur
dropped him, and never missed him?”

“They go so fast, over country roads at night that there is no

telling what happens,” replied Tavia. “But he’s mine, or Doro’s. She
has a dog so much like him at home that he may help to cheer her.”

“But won’t Jake want him?” whispered Edna.

“Jake would eat out of Doro’s hands,” answered Tavia in low

tones. “Don’t you remember, last Winter, how she saved his children
from that fire in the auto house? How she went up the ladder——”

“Oh, of course, but we all helped,” objected Edna.

 “We helped when Dorothy showed us how. Now look here Edna. I
don’t want you to think that I believe Dorothy Dale to be perfect, but
the fact is—I have my first flaw to discover.”

“Hurrah! Hurray! Horroo!” Edna said quietly. “Tavia, you have,

after all, something tangible. It’s love!”

“If you wake my dog it will not be love for you,” threatened the
other.

“Say, look at Jean! I think she’s asleep on Jake’s shoulder. Won’t

that be a leader for our—hazing!”

“There’s the lights!” called a quartette, for indeed the tower light
of Glenwood shone brightly at the next turn.

Suddenly all the balcony lights were flashed on!

Then such cheers! Jake clung to the wheel as if the car might shy
at the noise.

“Glenwood! Glenwood! Rah! Rah! Rah!

Back again, back again, Margery Daw!
Left the boys behind us! Hah! Hah! Hah!”

It was a school cry.

“Careful, careful!” cautioned Jake. But Mrs. Pangborn was there to

welcome one and all.
 CHAPTER VI

CHOCOLATES AND SANDWICHES

It was past nine o’clock when the Glenwood girls reached the hall,
and was, therefore, too late to go in for any of the pranks usually
indulged in on the first night. To be sure there was some fun.
Cologne managed to lay hold of some small boxes, that looked
surprisingly like confections. They were placed on a table, waiting to
be claimed, and it seemed no harm for her to claim them. Dorothy
refused to take part in the “raid,” but Tavia and Edna did not have to
be coaxed.

“They’re Jean’s, I’ll wager,” whispered Tavia, “but the wrapper is

off, and we can easily prove an alibi. Let’s see where they’re from,
any way.”

“Oh, there’s a note,” declared Cologne. “I’m going to put them

back. I’ll have nothing to do with robbing the mails.”

A piece of paper fell from between two of the boxes, as Tavia cut
a pink cord that held them together.

“All the more fun,” said Tavia hiding the ill-gotten goods in the fold
of her blouse as a teacher passed, and said good-night.

“Better get it hid in some place,” suggested Edna. “If Dick comes
along she’ll smell the stuff.”

“Put it back! Put it back,” begged Cologne. “Somehow I feel we

had better not try to have fun on Jean’s account. She might make
trouble for us.”
 “Who cares about her trouble,” snapped Tavia. “Besides, we don’t
know to whom the stuff belongs. There, I’ll put the note on the
table, I guess that’ll be sweet enough for her.”

Scarcely had this speech been finished when a gliding figure, in a

gorgeous red kimono, turned into the corridor where the three girls
stood. It was Jean Faval. She came directly up to the table, smiled
pleasantly, said something about being tired, picked up the note and
turned away, with a most surprisingly pleasant and affable good
night.

The girls were speechless!

“What do you think of that?” exclaimed Edna, as soon as she

could command her tongue.

Tavia carefully took the boxes out of her blouse, and very gingerly
set them down again on the table.

“There,” she said, “Miss Jean Faval there’s your candy! I believe
it’s poisoned!”

“Why Tavia——”

“Yes, I wouldn’t be a bit surprised if she had fixed up those boxes

herself, with the idea that we, or my little dog might bite. But we
won’t. Let them stay there,” and the three sauntered off to room
nineteen—the one occupied by Dorothy and Tavia.

They found Dorothy ready for bed, but Tavia insisted on telling the
story of the “poisoned candy.”

“What utter nonsense!” declared Dorothy. “Perhaps it did not

belong to Jean Faval at all.”

“But the note,” insisted Cologne. “That seemed to belong to her,

and it was in the boxes.”
 “At any rate,” spoke Dorothy, “I want to go to bed, and I’ll be glad
to excuse the invaders. Tavia, if you so much as drop a handkerchief,
I shall report you, for I am not only tired, but have a headache.”

Edna and Cologne got up from the rug they had been sitting on.
Cologne had allowed her heavy brown hair to fall to her waist, and
Edna had likewise made that same preparation for retiring.

Tavia stifled a yawn. “I’m not a bit sleepy,” she declared. “And I
think, after all, I’ll just take a chance at those chocolates. I’m
starved for sweets.”

“Oh, Tavia! Don’t!” implored Edna. “I think we got off well enough
to leave well enough alone.”

But Tavia was already poking her head out of the door.

“There she goes,” she whispered, “I just caught a flash of that

fire-alarm kimono. Now wait till we hear her shut her door, and then
for the sweets.”

Cologne made a move to grasp Tavia’s skirt but failed. Dorothy sat
up and shook her head helplessly. “I may as well give up sleep until
that girl knows all about those plagued chocolates,” she said with a
sigh. “I can’t see why she is so interested.”

Tavia was back almost instantly.

“They’re gone!” she gasped. “They’re haunted I think—unless the

Jean changed her mind and is now howling in throes of suicide.
There I heard a howl. You two better not be caught in the corridors,
or you may be implicated,” and with this, she, in her careless way,
almost brushed the two girls out and locked the door.

But over in her own corner, under her own lamp, Tavia read a
name on a slip of paper. Then she put it in her letter box, and turned
out the lights.
 Two more days and school would formally open. That which
followed the arrival of some belated girls from the West dawned as
perfect as a September day could blaze, and Dorothy was at her
window, looking over the hills before Tavia had so much as given a
first yawning signal of waking.

A soft, misty atmosphere made the world wonderful under the

iridescent blades of light that fell from the sunrise.

“It seems a shame to stay indoors,” reflected Dorothy, “and it will

be two hours before breakfast. I’ll just slip into a gingham, and take
a walk over to the barns. Jacob will be out with the horses and
dogs.”

Few of the girls were awake as she passed lightly through the
halls. Maids were already busy with sweepers and brushes.

Dorothy knew many of the help, and bade them a pleasant good
morning. From the broad veranda she stopped to look at the
growing day.

“I think I won’t go to the stables,” she decided. “I’ll go out and get
a bunch of late flowers. Mrs. Pangborn is so fond of them.”

Down the roadway she ran. The whistle of an engine attracted her
attention.

“Why,” she mused, “there is the new station, and a train stopping!
What an innovation for Glenwood! I must go over and see what the
station looks like.”

A narrow path led through the elders and birches. Bluejays were
out-doing one another with their screeching, while birds that could
sing kept a scornful silence. Everything was so heavy with nature.
Dorothy almost forgot that it was to-day she had promised to tell
Tavia of her troubles!
 Passing through the lane brought her out into an open roadway,
newly made. A pretty little stone station, the rural and artistic kind,
filled in the space beyond, and a high terrace, unfinished, showed
that Glenwood station was to be carefully kept.

The train that Dorothy had heard whistling was just coming in.
The new station was not yet opened, but a short distance from it
was an improvised lunch room, a sort of shack made of unpainted
boards, and thin awnings. The train stopped, and the conductor
hurried to the little lunch room. Dorothy saw that a girl, alone, stood
behind the queer, long, board table, and that beside her was a
telegraph instrument. Seeing Dorothy she called to her.

“Could you come here for a few minutes?” she asked. “I have an
important train message and no one to leave the shop to.”

“Of course,” replied Dorothy, not comprehending just what was

wanted, but hurrying across the tracks to the shanty.

“You see,” began the girl, “father is sick, but we have to keep our
contract with the road, or lose the privilege in the new station. We
have to have a lunch room, and a newspaper stand and also attend
to messages. This I just received. I will have to deliver it on my
bicycle. I am so glad you came along. No one is apt to be out so
early. If any one wants coffee could you serve it?”

Dorothy was taken by surprise. To be left in charge of a country

railroad lunch counter!

“I’ll do the best I can,” she answered, noticing that the black-
haired girl had a deep line across her brow. “But I’m afraid——”

“Oh, don’t be afraid of anything,” interrupted the girl, who was

already mounting her wheel, and handing a bunch of keys to
Dorothy. “There’s another train due soon, but I’ll try to be back. In
the shed, at the rear, is our dog. He will know you all right when he
sees you behind the counter, but he won’t let any one else in. Good-
bye for a few minutes, and I can’t tell you how glad I am you came
along. I just feel that you have saved the depot for us,” and with one
strong stroke her wheel glided down the hill, and a bit of yellow
paper, the train message, showed in the small pocket of her red
jacket. The first train had already pulled out.

Then Dorothy was alone in the lunch house at 6:15 A. M.

 CHAPTER VII

RUNNING A LUNCH COUNTER

For some minutes the absurdity of the situation scarcely dawned

upon Dorothy. But the screeching of an approaching train promptly
reminded her of her newly-acquired duties.

“Suppose the passengers should want papers,” she thought. “I

had better look at the bundles.”

An old man thrust his face in under the wooden flap that was up
in the day time, and put down at night.

“A good cup of coffee, and quick there!” he demanded. “I have

got to get away ahead of that train.”

Dorothy turned to the big coffee urn, and for the first time noticed
that there was a fire under it.

The next thing Dorothy did was to look at the man who had given
her the first order at the improvised restaurant. He was smiling at
her—a frank, pleasant smile, that had in it not the least suggestion
of familiarity.

“Well?” he asked questioningly. “Did I startle you?”

“Not exactly,” was her answer. “That is—well, I’m not really used
to this sort of work, and——”

“You don’t know how to run that machine—isn’t that it?” he asked,
nodding brightly. “Confess now, that you don’t know how to get
coffee out of it.”
 “That’s it,” said Dorothy with an air of relief that he had divined
her trouble. “There are so many attachments to it that I really don’t
know which one to turn to get the coffee out.”

“In the first place,” spoke the man, “is there coffee in it?”

“I think so.”

“I mean coffee with water on it—coffee to drink?”

“Yes, the young lady who runs it, and who had to get off in a
hurry to deliver a message, said so.”

“Good! That’s one point solved. Now then, there is no question

but what the coffee is hot. I can see the alcohol flame under it. The
next thing is how to get it out.”

“I believe so,” agreed Dorothy with a smile. “Suppose I turn this

faucet.”

“No, don’t!” cried the man suddenly. “It may not be the right one,
and you might scald yourself. Let me come in and maybe I can find
the right thing to twist.”

“No! Don’t!” exclaimed Dorothy.

“Why not? ’Fraid I might get burned? I don’t mind.”

“No, it isn’t that,” and she was conscious of a movement under the
counter.

“Well, then, is it because you think I don’t know how to run that
machine? I confess that I haven’t a working knowledge of it. A
planing mill is more in my line. Now if you were to ask me to get you
out so many feet of inch pine, tongue and groove, or something like
that, I could do it in no time, but I will admit that getting coffee out
of a contraption like that is a little beyond me. An old fashioned pot
is simpler. Still, if I came behind, I might help you.”

He made a motion as if he were coming in.

“Don’t!” cried Dorothy again, and the dog growled.

“Oh, I see,” said the man. “He doesn’t like strangers. Well, maybe
I can help you from outside here. I’ve no desire to be made into
mincemeat so early in the morning.”

“What shall I do?” asked Dorothy, rather helplessly.

“About the dog?”

“No, about this coffee urn. What shall I turn first?”

“Try that faucet there,” suggested the man, pointing to the largest
one, of a number that adorned the shining bit of machinery.

Dorothy did so, forgetting to hold a cup under it. A stream of cold
water spurted out.

“Wrong guess!” exclaimed the man. “I might have known, too.

There’s a glass gage there, and I can see water in it now. I should
have looked at that first. You might have been wet.”

“I’m not salt,” returned Dorothy, laughingly.

“More like sugar, I should say,” spoke the man. “Tut! Tut!” he
exclaimed, as he saw a frown pass over Dorothy’s face. “No harm
intended. Besides, I’m nearly old enough to be your father. Now
about the coffee. I really need some and I haven’t much time to
spare.”

“Suppose I try this faucet?” suggested Dorothy, and she put her
hand on a second shining handle.
 “Do,” begged the hungry man.

With a menacing hiss some hot water spurted out.

“Look out!” the hungry one called. “You’ll be burned!”

Dorothy got back out of the way just in time.

“There’s the right one!” the first customer exclaimed, as he

pointed to the lowest faucet of all. “If I had kept my wits about me
I’d have seen. The coffee shows in the gage glass. Besides, it’s the
lowest one down, and, naturally, the coffee goes to the bottom of
the urn. Try that one.”

Dorothy did, but there was no welcoming stream of the juice of

the aromatic berry. She was beginning to get nervous.

“The other way,” directed the man. “It’s one of those patent
faucets, I guess. Turn it the other way.”

She did so, and a brown stream, hot and fragrant, trickled out. It
splashed on the board counter.

“I guess you’d better take a cup,” said the man with a smile.
“We’ve found the right place this time, and there’s no use wasting
the coffee. Sorry I’ve been such a bother, but I really would use a
cup.” Dorothy laughed frankly. Her nervousness was passing away.

On a side shelf of the queer little restaurant she saw that the iron-
china cups were piled up. She reached for one, filled it with the
smoking coffee, and handed it to the man outside the flap.

“Sandwich!” he demanded. “This coffee makes a fellow want to

eat, instead of quenching his appetite.”

Dorothy looked around and smelled ham. The bread was in a box,
and almost fell at her feet as she searched for it.
 “Plenty of mustard,” demanded the customer, and this time the
strange waitress began to think she would fail to fill the order.

“I can’t seem to find the mustard,” she said lamely.

“You’re a stranger here then? I thought the other one had a

different head on her,” replied the man, who was now helping
himself to the loaf of bread that Dorothy had laid down preparing to
cut it. “Well, I think I can find that mustard,” and he turned to the
little side door. As he did so the big black dog growled again and
barred his way inside the shanty.

“He’s tied,” said Dorothy, “but I think it will be best for me to look
on the shelf there, where the canned goods are. Yes, it’s here,” and
she brought down a big yellow bottle of sandwich-flavoring stuff.

“Here, I’ll cut the ham. I’ve got to get away. I’m late now,” and he
proceeded to “cut the ham” after the manner in which he had
attacked the bread. Dorothy was afraid she had made a great
mistake. There would be nothing left for the train people if he kept
on.

Finally he managed to get another cup of coffee, he poured the

condensed milk into it thick and fast, then he asked;

“How much?”

“I really don’t know,” Dorothy replied, “but if you have been in the
habit of eating here just whatever you always pay will do.”

“Guess you had better charge it then,” he said, and before she had
time to reply he was off down the track, wiping his mouth with his
red handkerchief as he went.

“This is not just my sort of position,” mused Dorothy, cleaning up

the refuse left on the counter. “I hope I won’t have to pay the
damages.”
 The incoming train left her no further time for reflection, for, as it
pulled in and stopped at the station, a crowd of men, evidently night
workers, scrambled for the lunch counter.

“Coffee and rolls!”

“Coffee and cheese cake!”

“Coffee and franks for me!”

“Coffee! coffee! coffee!”

Dorothy was actually frightened. These men wanted breakfast,

and had only a few minutes in which to get it. How could she wait
on them?

Long arms were reached inside the open window, and cups and
saucers brought down to wait for the coffee.

“I’m not the girl who—who—runs this place,” Dorothy said, timidly,
as one very rough-looking man shouted again his order. “I only
stepped in to—watch the place, until the other girl gets back. I do
wish she would come,” and, filling a big pitcher with the coffee from
the urn she placed it before the hungry men.

“But we can’t eat again until noon,” declared a big fellow, who
spoke with the unmistakable Maine tang, “and this joint is run
special for car men. I’ll have them folks reported,” and he brought
his hand down on the counter so that the heavy cups danced.

“Oh, please don’t do that!” begged Dorothy, “for the young lady
said her father was ill, and I am sure something important has
detained her. I will do the very best I can.”

The train blew a warning whistle. Dorothy put everything she

could find on the counter. “I’ll pay for it if I have to,” she was
thinking. “Certainly I must avoid—a panic.”
 A young man, well dressed, was coming along now. Her heart
gave a great bound. What would he want?

She turned to put more water in the coffee urn.

“Have you the morning papers?” asked the newcomer.

His voice made her start. She turned and faced—Mr. Armstrong!

“I’m afraid I won’t be able to unwrap the papers,” she said,

blushing furiously. “Isn’t this dreadful, Mr. Armstrong?”

“Surprising, I’m sure,” he replied, smiling. “You have more than

your hands full.”

Dorothy tried to explain, but her confusion was now more than
excitement—it was akin to collapse.

“Perhaps I could help you,” suggested her friend of the bridge-

bound train. “I am not in a hurry. Mother is on ahead, and I can wait
for the next accommodation.”

“Oh, if you only would! I cannot find anything more to eat,” and
she brushed back her hair, in lieu of rolling up her sleeves.

“You can’t go in there,” growled one of the train men. “There’s a

dog that don’t like dudes.”

Another toot, and the men rushed off, half emptied cups in hand,
sandwiches in pocket, and the rack of pastry left empty, inside the
counter, where it had fallen as the last pie was grabbed from its
wires.

“The cups,” called Dorothy. “They are taking them away!”

“Don’t worry about that,” Mr. Armstrong told her. “Likely they will
toss them out the car windows. They’re that sort that never breaks.
But I’m glad they’re gone. You look quite done out.”
 “And just think! I have been away from the hall for the past hour.
They will think I’m drowned, or lost or——”

“Eloped,” finished the young man. “Well, I’m sure you did this to
help someone, and if your success as a lunch counter manager is
doubtful, no one could criticise your courage. Now, you had better
shut this place up, before another avalanche swoops down, and, if
you don’t mind, I’ll walk along with you. I can get the seven-ten
easily, and have the pleasure of an early walk. To be honest,
travelling on that train was not altogether pleasant.”

“I certainly must get back,” Dorothy replied. “But how am I to lock

this place up? I do wish that girl would come back.”

She looked anxiously over the hills. There was a wheel coming.
Yes, and that was the girl, with the blue suit.

“Oh, there she comes!” went on Dorothy. “Whatever will she think
of this wreck and ruin?”

“From remarks I heard among the trainmen she may be glad they
got coffee,” said Mr. Armstrong.

The bicycle had stopped now. The girl jumped off, and hurried to
Dorothy.

“Oh,” she sighed, “I am so sorry I kept you so long, but father is

so ill!” and they noticed that, in spite of the exertion of riding, she
was very pale.

“I’m afraid I didn’t do very well,” ventured Dorothy.

“That train was the track foreman’s. It was all right; no matter
what you did as long as you kept the window open,” said the girl
gratefully. “But I am afraid I have gotten you into trouble. Do you go
to Glenwood?”
 “Yes,” replied Dorothy.

“I thought so. Well, the young ladies are looking for you. I heard
one say——”

She stopped suddenly, looking at Mr. Armstrong.

“What?” asked Dorothy, but no direct answer was given, for school
girls were seen coming over the hill, and it was Jean Faval who was
first to hail the finding of Dorothy, and she, also, who first reported
that she was in the company of a young man!
 CHAPTER VIII

DOROTHY’S WORRIES

It did look strange. Dorothy had gone out before any of her
companions were about, and now, after being away two hours she
was found returning in the company of a young man.

It might have been different if Tavia, and the girls who had met
Mr. Armstrong on the train, had chosen to go toward the depot
instead of seeking Dorothy in the opposite direction; but when Jean
Faval met her, there were with Jean three of the new girls, and of
course, they neither knew Dorothy nor her companion.

Small things grow quickly when they have plenty of room, and
Dorothy’s escapade, being the one thing worth talking of at
Glenwood, soon amounted to a sensational story, fanned by the
gossips and nurtured by her rival in the school.

What girl has gone through school without some such similar
experience? And does it not always occur at the most unexpected
times?

Are there always, and everywhere, “school rivals?”

Mr. Armstrong said good-bye to Dorothy at the tanbark path that

led to Glenwood Hall. Excited over her strange experience, Dorothy
had no thought of what others might wonder! Where had she been?
Why did she leave the grounds so early? What was Dorothy worrying
about?

“See here, Doro,” Tavia confronted her, as together they prepared

for breakfast—late at that. “What ails you? You promised to tell me
to-day.”

“What ailed me, Tavia, does not exactly ail me now. I have just
learned how some girls have to make a living.”

Saying this Dorothy sank back, rather unlike herself, for the
morning had been warm, and her duties anything but refreshing.

“Dorothy, tell me, what is it?” demanded Tavia.

“You look at me as if I were a criminal,” replied the blonde Dalton

girl. “I can never be coerced,” she finished.

“Dorothy, you are so unlike yourself. And you have no idea how
much trouble that Jean Faval can make,” insisted Tavia, with more
spirit than she usually showed.

Dorothy stopped in her hair-fixing. “Tavia,” she said, emphatically,

“I have friends enough here,” and she glanced at the school-girl
picture-lined wall, “and I am not afraid of Jean Faval.”

Dorothy was always pretty, sometimes splendid, and again tragic—

Tavia decided she was one in all at that moment.

“Good!” declared her champion. “Don’t worry, Dorothy, but if you

could just tell me——”

Dorothy stopped and looked into the glass without seeing

anything.

She was worried, but since she had tried to run a lunch room, and
had discovered how hard some girls, as young as herself, had to
work, the thought that some day she too, might have to do
something to earn money, did not seem so appalling. Should she tell
Tavia?

“I am waiting, Doro,” Tavia said. “Now confess.”

 “It’s really nothing so very serious, dear,” she replied, “but you
know father is getting old and—he has put all his money into the
Marsall Investment Company, of New York. Just before I left home
father heard—that the money may be—lost!”

“All your money?”

“Yes, isn’t that dreadful? Of course, if it is lost we could never live

with Aunt Winnie. We would be too proud, although she and the
boys have always been so lovely to us. Yet to have no home makes
it different.”

“But, Dorothy, I can’t believe that will happen. Your father has
always been so wise,” and Tavia smoothed the ribbon on Dorothy’s
light hair. “If it should happen——”

“If it should, I would certainly go to work,” Dorothy declared,

firmly. “I should never let Joe leave school, and stay on here myself.
Besides, Joe could not do very much,” she sighed. “I am so afraid for
father—afraid the crash would——”

“Now, Doro, it is not like you to plan trouble,” Tavia interrupted,

“so let us forget it. I am afraid you will have some queer eyes made
at you when you go down to breakfast,” Tavia finished.

“It certainly was rather an unfortunate start for the first morning,”
Dorothy agreed. “But, Tavia, I wish you could have seen me. If Mr.
Armstrong had not just come along then, I would have run away,
and left the whole place to those greedy men. I could not have
stood it five minutes longer.”

“It must have been funny. I’ll have to take my lunch down there
some early morning. Maybe another nice Mr. Armstrong might come
along. But say, Doro, did you hear about the hall table candy?”

“No; what happened to it?”

 “It seems that Jean got it mixed up in her satchel with some hair
tonic that leaked from a bottle. She says she left it on the table,
because there was no scrap basket there—in the hall, and she didn’t
know where to put it. When I took the hair tonic-soaked candy away
Jean declares she thought one of the maids had thrown it out, as
you could easily smell the hair tonic. I didn’t smell it, neither did
Ned, but there was quite a time about it, as Jean got worried when
she thought it over. That was why she came out the second time.
But then they were gone—perhaps some of the girls took them. You
never heard so much talk over a little spill of hair tonic.”

“Did Jean ask Mrs. Pangborn about it?”

“Of course, and Mrs. Pangborn was more frightened than Jean, for
she said the stuff might have a poison in it. Now everyone is waiting
to see who will drop dead,” and Tavia laughed as if such an
occurrence would be very funny.

“Let’s hurry. We will get the second table now, and it’s such a
beautiful day to be out,” Dorothy said. “I feel better, really, for
having told you about my worries. Perhaps I will get a letter with
good news.”

“I hope so. But let me tell you something. If we really need money
I’ll advertise the little dog. Jake says he’s a thoroughbred.”

“He may be some child’s pet, and you ought to advertise him,
anyhow,” Dorothy said. “There are Cologne and Edna. They have
finished.”

They stopped at the door of the breakfast room.

“Oh you little runaway!” exclaimed Cologne to Dorothy. “We

thought you were on your honeymoon by this time.”

“That was a neat trick,” Edna added jokingly, “to go out before
daylight, and come back with such a yarn! You ought to hear what