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Closure and Johnston Atoll Chemical Agent Disposal System 6 Lessons Learned GENERAL CONSIDERATIONS Much effort has been (and continues to be) expended to plan the closure of JACADS in advance and in great detail, and much will certainly be learned in the course of closure operations and facility closeout. With eight continental U.S. sites for disposal of the remaining U.S. chemical stockpile now operating, under construction, or planned, significant economies in time and cost associated with their eventual closure may be obtained through careful and timely dissemination of the lessons learned from closure activities at JACADS. Hand in hand with lessons learned is the preplanning process for facility projects requiring major capital outlays. Preplanning is a recognized industry best practice that is applicable to different types of facilities, technologies, and projects (DuPont, 1995). It is intended to meet many stakeholder needs, to avoid injuries, and to save time and money. PREPLANNING PROCESS Outlined below are some key elements of a generic preplanning process that can be addressed concurrently. For each project, the development of additional supporting detail for these elements is led by the owner and contractor project leader: agreed-upon and documented project definition, including a procedure for updating if the definition changes initial and documented assessment of high hazards agreed-upon and documented scope that matches project definition site selection process: location, orientation, closure thinking cost estimate complete prior to starting work, with agreed-upon cost control plan funding and financial strategy to manage project cash flows agreed-upon schedule plan and procedures for assessing and altering schedule thorough safety, health, and environmental planning for project personnel and neighbors, including ergonomic, worker protection, and ecosystem assessments information technology plan that includes documentation, data sharing, and a process for collaboration among sites inclusive identification of project teams and training in teamwork roles and responsibilities assessment of the state of project technology and a plan to mitigate uncertainties construction or demolition plan that includes needed heavy lifts, restricted access, and special permits permitting plan covering environmental, construction/ demolition, occupancy, and other requirements special equipment plan for unique fabrications or tools required and for tracking material and equipment with long delivery times maintenance plan that takes into account reliability of processes operations plan that includes operations planning/ facilities loading and readiness to operate procurement/acquisition plan personnel plan covering hiring, training, reward and recognition, change management, work environment, retention and morale process for identifying hurdles and including a process for approving baseline changes crisis management and contingency plans that spell out procedures to manage emergencies, including roles and responsibilities, communication needs, who makes what decisions, who deals with authorities, and who manages press contacts community involvement plan
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Closure and Johnston Atoll Chemical Agent Disposal System dismantlement and closure plan for final disposition of site, equipment, and personnel SPECIFIC CLOSURE LESSONS LEARNED FROM THE JACADS EXPERIENCE The following lessons learned became apparent to the committee during its review of JACADS closure activities to date: Planning for closure should take place from the very beginning, that is, at project conception, through design, and throughout the operations and closure phases. This planning should be reflected as early as possible in the operating RCRA permit. Also, to the maximum extent practical, secondary wastes should be identified in the initial RCRA permit so disposal can be done continuously and concurrently with operations. End use and end state must be determined at the earliest possible time during the assessment and decision making stages to facilitate planning. Public outreach, including an in-place emergency plan, is essential throughout the operations and closure planning process. Planning should include resource allocation, if necessary, as well as a program to retain key personnel. To facilitate cost control, a total project technical baseline should be established at the earliest possible time; from this, a cost and schedule baseline can be developed and maintained throughout the project. Integrated project team (IPT) meetings provide a useful forum for both intra-agency and interagency communication. The purposes of these meetings must be understood by those involved if maximum benefit is to be obtained. The role and responsibilities of each individual attending the meeting should be carefully addressed. Initially, JACADS IPT meetings were small and focused on coordinating actions; they evolved into very large meetings that had significant logistical requirements and more of an educational and public information role. Early involvement of EPA and other stakeholders in closure planning is essential. Contingency planning and training are crucial to maintaining safe operating conditions during closure. Procurement during operations requires review and coordination to ensure against generating new wastes requiring special treatment, perhaps even permit modification. As-built drawings and photographs made during construction are of great value in closure planning. They should be created according to a plan during construction and any plant modification, and carefully filed for use during closure planning and execution. The final closure reports will be of significant value in closure planning for other sites. In addition, any supplementary reports that are prepared, such as lessons learned, would also be of value. The closure section of the original JACADS RCRA permit required significant modification; a detailed and complete closure plan should be incorporated into the permit for other sites. Early permit modification requests should be processed to minimize surprises and delays near the end. A high premium should be placed on capturing and disseminating lessons learned from JACADS closure. To the extent possible, other disposal sites could incorporate applicable JACADS experience in their original permit applications or in early permit modifications; doing so would help avert indecision and potential schedule delays and additional cost impacts associated with late permit modification development and processing. Careful attention must be paid during the planning phase to the identification of all waste streams to facilitate timely permit processing. Early efforts are required to identify appropriate points of contact, especially with outside agencies such as EPA. The structure for disseminating information from JACADS to other sites is important and needs to be improved. In particular, the Army should have a well-defined means of making key personnel, such as the plant manager and the closure manager, available periodically to the other sites and other PMCD contractors for information exchange.
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