P U E B L O C O U N T Y C O L O R A D O

Planning and Development Department Joan W. Armstrong

Director

Bowen Mansion 719.583.6100 (main) 229 West 12th Street 719.583.6376 (fax) Pueblo, CO 81003-2810 http://county.pueblo.org/planning

June 17, 2019 Colonel Christopher Grice, Commander Pueblo Chemical Depot 45825 Highway 96 East Building 1 Pueblo, CO 81006 Walton Levi, Acting PCAPP Site Project Manager Assembled Chemical Weapons Alternative Program (ACWA) 45825 Highway 96 East Process Support Building (PSB) Pueblo, CO 81006 Ken Harrawood, Bechtel Pueblo Team Project Manager 45825 Highway 96 East Process Support Building (PSB) Pueblo, CO 81006 RE: Waste Permit No. CO-13-12-23-01 Certificate of Designation (COD) No. 2019-001 Gentleman:

Pueblo County has reviewed the information submitted by Pueblo Chemical Depot (PCD) regarding the request for Temporary Authorization (TA) to perform early construction of the Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP) Static Detonation Chamber (SDC) Site (EXHIBIT 1). The temporary authorization will allow the first phase early construction of infrastructure associated with the PDC Class 3 modification (19-005) for the three (3) SDC units. The temporary authorization request allows the SDC infrastructure construction to begin while the Colorado Department of Health and Environment, Hazardous Materials and Waste Management Division (the “Division”) performs a Class 3 permit modification review relating to the SDC site and operation, and while Pueblo County continues with its review of Certificate of Designation No. 2019-001. The Division has reviewed and granted a partial approval of the Temporary Authorization to begin early site construction with site grading, grubbing, dust control, utility connections, installation of infrastructure (i.e., roads and parking), and establishment of the SDC Off-gas Treatment System (OTS), and the Waste Laydown Yard (WLY) foundations (EXHIBIT 2). “The Division agrees with the proposed early construction of infrastructure outside of the PCD Chemical Limited Area (CLA). … For areas inside the CLA, the Division has determined that it is appropriate to

Page 2

provide authorization for PCD to proceed with early construction activities, not extending beyond wet cure and removal of formwork for the SDC-OTS Concrete Foundations and Waste Laydown Yard Foundation. …, PCD will submit the Ionex foundation drawings as a part of a future TA request.” Pueblo County staff and Irene Kornelly (Kornelly and Associates Professional Consulting Services) have reviewed the Temporary Authorization and have held discussions with the Board of County Commissioners. With the partial approval of the Temporary Authorization by the Colorado Department of Public Health and Environment, Hazardous Materials and Waste Management Division, Pueblo County hereby approves the Temporary Authorization for the construction of the specific items as are more particularly set forth by the CDPHE Temporary Authorization dated June 6, 2019, a copy of which is attached hereto as EXHIBIT 2 and made a part hereof by reference. Pueblo County approval of the Temporary Authorization as set forth herein is not indicative of its decision to approve COD No. 2019-001 nor shall this Authorization form the basis of an inference that such final approval will be forthcoming. The decision of the applicant to proceed with the SDC early infrastructure construction work is undertaken at its risk. If you have questions or if I may be of further assistance, please contact me at 719-583-6105. We look forward to proceeding with our review of the COD application and to working with you in finalizing the review for presentation to the Board of County Commissioners. Sincerely,

S Joan Armstrong Director c: Board of County Commissioners Cynthia Mitchell, County Attorney Marci Day, Assistant County Attorney Gary Raso, Special Assistant County Attorney Terry Hart, CAC Irene Kornelly, CAC Permitting Workgroup Chair Kevin Mackey, Unit Leader, Hazardous Waste Permitting Unit, Hazardous Materials and Waste Management Division, CDPHE Chris Pulskamp, Pueblo Chemical Depot, 45825 Highway 96 East, Pueblo, CO 81006 Mike Saupe, Bechtel Pueblo Team Rick Workentine, Bechtel Pueblo Team Pat Sullivan, ACWA Jody Carillo, Pueblo Department of Public Health and Environment Attachments: EXHIBIT 1 -- PCD TA Request, d. 4-17-2019 EXHIBIT 2 -- CDPHE Letter, d. 6-6-2019

DEPARTMENT OF THE ARMYU.S. ARMY CHEMICAL MATERIALS ACTIVITY

PUEBLO CHEMICAL DEPOT, BUILDING 145825 HIGHWAY 96 EAST

PUEBLO, COLORADO 81006-9330

Environmental Management OfficeAPRl 7 2019

SUBJECT: Temporary Authorization Request for Class 3 Permit Modification No. 19-005,Static Detonation Chambers, Permit # CO-13-12-23-01, Pueblo Chemical Depot (PCD),Pueblo, CO

CONTROL#: EM019-055

Mr. Kevin MackeyColorado Department of Public Health and EnvironmentHazardous Materials and Waste Management Division4300 Cherry Creek Drive SouthDenver, CO 80246-1530

Dear Mr. Mackey:

Pueblo Chemical Depot submits the attached Temporary Authorization Request forearly construction related to the Class 3 permit modification for addition of three StaticDetonation Chambers. An early construction start will decrease the time required to initiateSDC operations and to complete destruction of the existing chemical stockpile. Theproposed early construction activity will facilitate changes that protect human health andthe environment per Colorado Hazardous Waste Regulations 6 CCR 1007-3§100.63(e){3)(ii)(C).

The point of contact for this submittal is Mr. Chris Pulskamp at (719) 549-4252 orchristopher.j.pulskamp.civ@mail.mil.

'XThristopher A. uriceColonel, U.S. ArmyCommanding

zono'^iY

7

falton W. Levi * Date

Acting PCAPP Site Project ManagerPueblo Chemical Agent-Destruction Pilot Plant

Sincerely

K.E. Harrawood * Date

Project Manager, Bechtel National, Inc.Bechtel Pueblo Team Project Manager

EXHIBIT 1

-2-

Enclosure

cc:

Mr. David Kreutzer (w/o enclosure), CO Office of the Attorney General, Natural Resources,Ralph L. Carr Colorado Judicial Center, 1300 Broadway, 7th Floor, Denver, CO 80203-2104

Ms. Ruth Flanders, CMA, E4586 Hoadley Road. APG, MD 21010-5424Mr. Drew Lyie, CMA, CMA, E4585 Hoadley Road, APG, MD 21010-5424Ms. Joan Armstrong, Pueblo County Department of Planning and Development, 229 West12th Street, Pueblo, CO 81003-2810

Mr. Jesse Newland, US EPA Region 8, 1595 Wynkoop Street, Denver, CO 80202-1129PCAPP Document Control Center, 45825 Highway 96 East, Pueblo, CO 81006-9330PCD Document Control Center, 45825 Highway 96 East, Pueblo, CO 81006-9330

*ln accordance with 6 COR 1007-3 Sections 100.12 and 100.42(k), I certify under penalty of law that, exceptas specifically noted, this document and all attachments were prepared under my direction or supervisionaccording to a system designed to assure that qualified personnel properly gather and evaluate theinformation submitted. Based on my inquiry of the person(s) who manage the system, or those personsdirectly responsible for gathering the information, the information submitted is, to the best of my knowledgeand belief, true, accurate, and complete. I am aware that there are significant penalties for submitting falseinformation, including the possibility of fine and imprisonment for knowing violations.

Temporary Authorization Request

Pueblo Chemical Depot

Hazardous Waste Permit

Permit No. CO-13-12-23-01

EPA ID No. CO8213820725

Temporary Authorization Request Title: Request to Perform Early Construction of the

Pueblo Chemical Agent-Destruction Pilot Plant

Static Detonation Chamber Site at Pueblo

Chemical Depot

Prepared:

Request Prepared by:

Submitted to:

PCAPP SDC TAR

April 2019

Pueblo Chemical Depot and Pueblo Chemical

Agent-Destruction Pilot Plant

Colorado Department of Public Health and

Environment

Pueblo Chemical Depot

HAZARDOUS WASTE PERMIT

TEMPORARY AUTHORIZATION REQUEST

CO PERMIT NUMBER: CO-13-I2-23-01EPA ID NUMBER: CO82I3820725

"I certify under penalty of law that this document and all attachments were prepared under mydirection or supervisionaccording to a system designed to assure that qualified personnelproperly gather and evaluate the infonnation submitted. Based on my inquiry of the person orpersons who manage the system, or those persons directly responsible for gathering theinformation, the information submitted is, to the best of my knowledge and belief, true, accurateand complete. I am aware that there are significant penalties for submitting false information,including the possibility of fine and imprisonment for knowing violations."

2.0)9o^/7Walton W. Levi DateActing Site Project Manager for Pueblo ChemicalAgent-Destruction Pilot Plant

7^/? 07 / 7Christopher A. Grice V DateColonel, CMPueblo Chemical Depot

PCAPP SDC TAR

PUEBLO CHEMICAL DEPOT

TEMPORARY AUTHORIZATION REQUEST

REQUEST TO PERFORM EARLY CONSTRUCTION OF THE PUEBLO CHEMICALAGENT-DESTRUCTION PILOT PLANT STATIC DETONATION CHAMBER SITE

1.0 INTRODUCTION

Under the Colorado Hazardous Waste Regulations 6 CCR 1007-3 §100.63(e), the PuebloChemical Depot (PCD) hereby requests a temporary authorization from the ColoradoDepartment of Public Health and Environment (CDPHE) to perform phased early constructionat the Pueblo Chemical Agent-Destruction Pilot Plant (PCAPP) Static Detonation Chamber(SDC) site. The temporary authorization is requested to allow the PCAPP SDC site to begin thefirst phase of construction associated with the PCD Class 3 modification (19-005).

2.0 BACKGROUND

PCD along with the Pueblo Chemical Agent-Destruction Pilot Plant submitted a Class 3 PermitModification Request (19-005) to CDPHE to add three SDC units to the PCD Hazardous WastePermit. The SDC is a system designed to safely treat/destroy munitions and other items thatcontain chemical agent fill with or without energetic components.

Three SDC units will augment PCAPP Main Plant operations. They will accomplishtreatment/destruction of stockpile munitions, overpacked munitions (leakers and rejects),recovered chemical munitions and other miscellaneous items (ignition cartridges, propellant).Munitions or components that contain or are contaminated with mustard agent (distilled sulfurmustard [HD] or mustard-T mixture [HT]) from PCAPP operations will also be destroyed in theSDCs.

3.0 RATIONALE FOR REQUESTING TEMPORARY AUTHORIZATION

CDPHE Air Quality will issue a construction permit for the SDCs under 5 CCR 1001-5Regulation 3 which allows 18 months to complete construction of the SDC units. An earlyconstruction start will decrease the time required to initiate SDC operations and to completedestruction of the existing chemical stockpile. The proposed early construction activity willfacilitate changes that protect human health and the environment per Colorado HazardousWaste Regulations 6 CCR 1007-3 §100.63(e)(3)(ii)(C).

4.0 PROPOSED CONSTRUCTION ACTIVITY

The PCAPP SDC site will be located to the south of the PCD Chemical Limited Area (CLA),also known as "G-Block" and west of PCAPP. Figure 1 shows the location of the PCAPP SDCproject. Figures 2 and 3 depict the planned layout of the PCAPP SDC site.

PCAPP SDC TAR

The PCAPP SDC site will require the construction of structures, roads and infrastructure tosupport PCAPP SDC operations. Major components of the PCAPP SDC site are shown inFigures 2 and 3. Site construction will initially involve site grading, grubbing, dust control,stormwater pollution prevention, utility connections and infrastructure (roads and parking).Installation of utilities, site access roads and support equipment (fire tank water, light poles,emergency diesel generators, portable trailers, field office, changehouse) will begin once theCDPHE air construction permit is approved. As shown in Table 1, roads, structures andequipment required to support the fature installation of the SDCs do not have hazardous wastepermit requirements for installation. The items listed below do not require Facility ConstructionCertification (FCC) documentation.

Table 1. SDC construction not requiring a Temporary Authorization

Emergency Diesel Generators (3)

Engineering Support Trailer/Changehouse

Security Fencing and Electronic Security System (ESS)

Field Support Trailer

Utility Connections

Site Access Roads

Support Equipment (fire water, lighting)

The purpose of this temporary authorization request is to begin Phase 1 of the project covered inthe Class 3 permit modification (19-005). Phase 1 requires CDPHE approval of the PCAPPprepared Facility Construction Certification (FCC) matrices shown in Table 2. Each FCCMatrix must be approved prior to construction of each section.

Table 2. CDPHE Temporary Authorization

Concrete Foundations and Pads for Environmental Enclosures

Lightning Protection System

Waste Laydown Yard/Geotechnical

5.0 PROPOSED START FOR CONSTRUCTION ACTIVITY

A construction start date for Phase 1 items is June 3, 2019.

6.0 COMPLIANCE WITH COLORADO HAZARDOUS WASTE REGULATIONS

6 CCR 1007-3 PARTS 264 and 266

The PCAPP SDC site operations and compliance with Part 264 requirements are described in thePCD Class 3 Permit Modification Request (19-005), dated April 2019.

During construction activities, any hazardous wastes generated will be managed according to6 CCR 1007-3 § 262 Standards Applicable to Generators of Hazardous Waste and the PCDHazardous Waste Permit.

PCAPP SDC TAR 2

As indicated in 6 CCR 1007-3 Part 266.10(c), Part 266 does not apply to the PCAPP SDC siteand operation as it is a Federal facility.

PCAPP SDC TAR

Munitions Storage Area

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Figure I. General Location for PCAPP SDC Site

PCAPP SDC TAR

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EXHIBIT 2