Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment (2007)

This report focuses on issues pertaining to the continuing operability of the four chemical agent stockpile incineration facilities that are currently operated by site contractors under contract with the U.S. Army’s Chemical Materials Agency (CMA). These facilities use several incineration furnace systems for the demilitarization (destruction) of the U.S. stockpile of obsolete and aging chemical weapons stored at each site. The report addresses potential weaknesses in the operability of the furnace systems’ infrastructure and equipment, given that the facilities are being operated well beyond their original design lifetimes; assesses the Army’s current and evolving obsolescence management programs;¹ and provides advice on ways these programs may be improved and strengthened to support safe and expeditious completion of stockpile destruction operations and closure of facilities at sites where incineration technology is being used.

The director of the CMA requested that the National Research Council (NRC) assess and evaluate current and proposed policies and approaches by the Army and its contractors to adequately anticipate and address equipment and facilities obsolescence issues at chemical agent stockpile incineration facilities. This assessment examines the extent to which these policies and approaches are consistent with generally accepted practices in the chemical process industry. In conducting this assessment in accordance with the statement of task, the NRC’s Committee on Continuing Operability of Chemical Agent Disposal Facilities and Equipment evaluated current and proposed activities involving:

• anticipation of equipment needs and upgrading facilities in a manner that does not compromise plant safety or environmental compliance, or have severe adverse effects on schedule;

• extension of the operational life of equipment and facilities as necessary while not compromising worker health and safety or environmental compliance;

• strategies to overcome scarce availability of spare parts and/or services for aging systems;

• prioritization plans for addressing obsolescence issues; and

• ensuring plant reliability, availability, and maintainability while upgrading equipment and facilities.

The four incineration facilities that are the main focus of this report all share a common design basis, and specialized major equipment items were procured for all the facilities in the 1990s. The refractory-lined furnaces and after-burners cause some operating constraints because they are susceptible to damage from thermal transients and must be kept hot during short-term changes in processing operations. Most major maintenance is scheduled during agent campaign changeovers when the furnaces are slowly cooled to a shutdown condition.

Similarly, plant personnel are highly trained and experienced in the particular chemical demilitarization operations, which makes it impractical to mothball or decommission a facility until after its mission is completed satisfactorily. Even at that point, some of the facility equipment and well-trained personnel will still be needed for closure activities to clean and remove all contaminated parts of the facility. Delays in processing not only increase program costs but also prolong the risk to the public of exposure to the aging stockpile.

The Army has standard procedures for addressing the

obsolescence of conventional military equipment and munitions, but these do not apply to an operational chemical stockpile processing facility. Normal chemical industry practices for preventing obsolescence in chemical processing plants apply only partially to stockpile disposal processing plants because of the latter’s unique design and finite length of operation. Most chemical and manufacturing plants use well-developed technologies and are designed to operate efficiently and indefinitely with relatively common equipment—not just until a finite task is accomplished.

The most rational approach to mitigating obsolescence for stockpile processing facilities would allow for some equipment obsolescence or degradation as the plants age, as long as programmatic objectives can be ensured. Replacing old but still functional equipment unnecessarily would interrupt plant operations and schedule. Furthermore, such changes often require permit modification at the state level, which may cause an additional extension in schedule.

To accomplish its tasks the committee received briefings from government and contractor personnel associated with the chemical agent stockpile disposal program administered by the CMA. Members of the committee visited all of the four operating incineration system facility sites to gather information on the vulnerability of these facilities to obsolescence and other issues related to continuing operability. The committee focused on program vulnerabilities in four broad issue areas: (1) aging of critical facilities and equipment; (2) diminishing sources for components and spare parts; (3) loss of experienced personnel; and (4) information management.

The committee paid particular attention to operational experience gained at the now fully cleaned and decommissioned Johnston Atoll Chemical Agent Disposal System (JACADS) over the full life cycle of that facility,² and at the Tooele Chemical Agent Disposal Facility (TOCDF) in Utah, which is the oldest plant currently operating and the incineration facility where obsolescence problems are most likely to be encountered first. The committee also visited disposal facilities at Anniston, Alabama (ANCDF); Umatilla, Oregon (UMCDF); and Pine Bluff, Arkansas (PBCDF). The committee learned that programs to anticipate and manage problems associated with obsolescence have been initiated at all of these sites.

In the course of this study, the committee identified potential problems and examined various aspects concerning basic processing operations. It also assessed site-related and programmatic factors and influences affecting the continuing operability of the disposal facilities.

As a practical matter, all facilities and equipment become obsolete at some point in time. Even so, obsolescence does not necessarily mean nonfunctionality, as long as safety, environmental performance, operability, and the overall schedule of operations for a facility are not adversely impacted. Thus, with regard to chemical weapons destruction, the Army’s objective is to ensure the continuing capability to safely and expeditiously process the remaining items in the chemical stockpile. The incineration sites have fairly well defined operational duties, and there is long experience with the equipment such that reliability and failure modes are well known. A proactive obsolescence management program can allow older equipment to function satisfactorily through the finite lifetime of the sites and also identify areas where replacement of equipment is warranted.

The committee investigated current obsolescence-related vulnerabilities in the CMA program as well as reviewed its past experience and future plans. Areas examined included the expected life cycle of the facilities themselves, the availability of spare and replacement equipment parts, disassembly robotics, furnaces and afterburners, and control systems.

The four currently operating incineration plants that are the focus of this study were designed in the 1980s, and major equipment items were procured together in the 1990s. These plants are expected to be in operation for another five or more years to complete stockpile processing and for an additional two to three years to accomplish closure. Considerations for continuing operability must also include location-specific vulnerabilities that might impact operations (e.g., those associated with site security, communications, or the integrity of utilities and emergency systems).

As equipment ages or becomes obsolescent and spare parts are no longer manufactured, the requirement to maintain and share adequate stocks of replacement parts becomes ever more critical. To date there is no evidence that major items critical to the continuing operability of chemical agent stockpile incineration facilities have been unavailable, causing operations to be stopped for a significant time.

Although the robotics and furnaces employed in chemical demilitarization are unique, they are robustly designed and are expected to have adequate operating life if they are maintained and upgraded as needed. The designers and manufacturers of these components are continuing businesses that are available for support and spare and replacement parts production.

Where there are problems due to aging of robotic components, the staff at the uncontaminated chemical demilitarization training facility (CDTF) at the Edgewood Area of

Aberdeen Proving Ground (Maryland), and the associated skunk works operated by General Physics Corporation have facilitated troubleshooting of robotics problems when they are encountered at the sites.³

The incineration facilities use several furnaces to complete the disposal process. A liquid incinerator destroys agent. A deactivation furnace system destroys energetic materials. To decontaminate the metal munition bodies and certain other materials, a metal parts furnace is used. The furnaces are critical to both the operation and the closure of the disposal facilities. In past operations the deactivation furnace system (DFS) kiln shell has exhibited periodic damage from the destruction of residual explosives. A loss of a furnace during operations would delay disposal operations for a significant period because of long procurement times.

The original control system design common to all of the incineration sites is also based on 1980s technology. Some improvements have been made to support continuing operations.

Each of the chemical agent stockpile incineration facility sites operates within a structure of policies, procedures, and training programs. As the facilities and equipment age, changes will be needed to proactively manage obsolescence. Changes to equipment, systems, and procedures are addressed by a process for active management of change, which has direct implications for the personnel involved at all levels. It is not just equipment that becomes obsolescent and requires adaptation; personnel involved in operations, laboratories, and maintenance all have skills and knowledge that change over time. Thus far, interchangeability of spare parts and expertise among the four sites has been useful and could offer considerable future benefits for the continuing operability of these incineration facilities.

The consequences of error in chemical weapons demilitarization are potentially large, and any involved organization must maintain a consistently low error rate over extended time periods to ensure public safety and public confidence. The committee observed that some of the principles that apply to high-reliability organizations were evident at all sites visited.

The CMA has determined that standard Army stockpile obsolescence management programs are not suitable for the demilitarization processing facilities, and has asked each of the sites to begin implementing effective obsolescence management programs that include cooperation with other sites.

The plant configuration is updated as changes are made through a management of change process that is intended to ensure operational safety and regulatory compliance. Each site also has systems in place for managing safety and environmental compliance, as well as to train and retain a knowledgeable workforce.

Aging equipment can continue to be operated safely if a rigorous testing, maintenance, and replacement program is followed. This approach requires, however, that the capabilities of site personnel be continually updated and renewed, especially as employees leave and new ones are hired and as equipment and procedures are updated. Specialized knowledge and skills must also be retained throughout the lifetime of operations and facility closure.

Information management is important to the management of obsolescence at stockpile sites, because it tracks the history of changes in the facilities and personnel over the lifetime of operations. Data of this sort can aid in identifying areas of potential obsolescence, facilitate forward planning, provide a permanent record that documents operations, and allow tracking of abnormal incidents.

The committee conducted a thorough review of the information management systems at the sites. This is an area that has not been thoroughly reviewed as a whole in the past by an NRC committee and includes physical facilities (servers, desktop units, storage, and distribution), software (operating systems and applications), and system development processes. The committee’s major concern relates to the inconsistent way that information management is being practiced within and between sites.

In addition to a concern for the continuing operability of facilities, the management of facility obsolescence is affected on a programwide level by organizational structure, contractual relationships and incentives, community and regulatory relationships, and planning for emergencies and closure.

In the past five years CMA program management has shifted from an earlier model whereby the former management administered through the office of the program manager for chemical demilitarization (PMCD) provided topdown direction to site contractors. The current model involves a much smaller CMA staff that manages site performance through contractual incentives intended to encourage meeting CMA goals. Site management responsibility has shifted largely to individual site managers, with the CMA providing general guidance and oversight.

A result of this is that the strategies for obsolescence management developed at individual sites have significant differences. The CMA is encouraging interchanges among the sites and hopes that each may improve its plans by understanding approaches at other sites.

Continuing operability is as much a function of personnel management challenges and issues as it is of equipment

and supporting hardware concerns. An essential practice in the chemical industry is the tracking of abnormal events, their analysis, and the implementation of changes to minimize their recurrence—so called lessons-learned programs. The CMA lessons-learned program has been reinvented. The original program, while remaining available, is used only rarely. The new system is well designed, and the site managers report both regular additions to the database and increased usage.

The Department of Defense and congressional officials have expressed concern regarding the escalating cost of the chemical stockpile disposal program. Chemical stockpile demilitarization is safety and schedule driven. Although cost cannot be ignored, it has been subordinated to higher-priority project goals, such as ensuring the safety of workers, the public, and the environment. Nevertheless, adequate funding to maintain demilitarization facility operations is necessary to ensure timely elimination of the risk of the chemical weapons stockpile, especially as the stockpile continues to deteriorate.

As noted previously, closure operations of the four incineration facilities start at least four to six years following the publication of this report and continue for an additional two to three years. Steps are needed to ensure that the operational life of certain key equipment extends through the decommissioning and closure of the facilities.

The committee developed findings and recommendations and prioritized each recommendation as being in one of three tiers, with Tier 1 being the highest and most important. Although all the recommendations are important, the committee considers the Tier 1 recommendations to be critical to the life-cycle continuing operability of the chemical stockpile demilitarization program. Tier 2 recommendations are important components supporting the Tier 1 recommendations. Tier 3 recommendations address more detailed items suggested for implementation. Table S-1 shows the hierarchy according to tier level for related recommendations.

The following findings and recommendations are from Chapter 2.

Finding 1. The four operating incineration facilities, although aging, are capable of safe and effective destruction of remaining stockpile inventories and completion of closure activities at each site, if strong and comprehensive obsolescence management programs are implemented. However, each chemical agent disposal facility is susceptible to location-specific external factors that may change over time. A need exists for these factors to be determined and evaluated at each site on a periodic basis.

Recommendation 1. An operational security analysis program should be established for each chemical agent disposal facility to evaluate external factors (including the integrity of critical utilities) that could adversely impact continuing operability. (Tier 3)

Finding 2. The contract with Rockwell Automation for management of control system spares is an effective way to ensure long-term availability of control system spares. This contract is currently subject to annual renewal as part of an existing WGI-JACADS contract.⁴ This holding-pattern approach to a long-term commitment is due in part to an indemnification issue pertaining to issuance of a new longer-term contract.

Recommendation 2. The Chemical Materials Agency should implement a firm long-term contract to handle control system spares management for each of the four incineration facilities and the Chemical Demilitarization Training Facility at the Edgewood Area of Aberdeen Proving Ground. This contract should be structured to provide support through all related closures. (Tier 2)

Finding 3. No systematic approach exists for managing spare parts inventories across the four different chemical agent stockpile incineration facility sites, although there is a clear need for one. The committee found effective systems at some sites, but they are not consistent in parts identification codes, do not integrate information about control system spares, do not have internal trending and tracking capabilities, and only react to loss of suppliers on discovery that a supplier is no longer able to provide needed parts, typically when parts are reordered.

Recommendation 3. The Chemical Materials Agency should implement a more formal inventory management system that models usage, usage variability, lead times, and costs to ensure a very low rate of out-of-stock items. The spare parts inventory should be modeled across the four chemical agent stockpile incineration facility sites to ensure the capability to translate across different identification numbers for the same spare part, and to facilitate the optimum distribution of inventory between site warehouses and the central parts storage warehouse. Such a coordinated spare parts inventory management system should be accessible to and updated regularly by all sites and should indicate the status of key vendors supporting spare parts availability. A proactive program should be instituted to check more regularly whether each inventory item is still available, for example, by telephone or Internet query. (Tier 2)

Finding 4. The Chemical Demilitarization Training Facility/skunk works remains an extremely valuable resource for continued support of the disassembly robotics operation.

Recommendation 4. The Chemical Demilitarization Training Facility/skunk works facility and its knowledgeable personnel should be maintained as a support resource until all chemical agent stocks have been safely removed from storage and processed by the disassembly robotics at all incineration sites. (Tier 3)

Finding 5. Upcoming chemical agent disposal campaigns at ANCDF, UMCDF, and PBCDF have some potential to severely degrade the DFS kiln shells. Procurement of new kiln sections requires a lead time of about a year.

Recommendation 5. The Chemical Materials Agency should implement its plan to order a spare DFS kiln in time for mine disposal operations at ANCDF and continue to evaluate whether additional kilns are needed to support the subsequent campaigns at UMCDF and PBCDF. (Tier 2)

Finding 6. The process control system design is old, but the systems can be satisfactorily maintained and are being upgraded as justified to enhance performance. There is some divergence in the choice of components at individual chemical agent disposal facility sites as upgrades are made, and this may limit future interchangeability of parts and operational knowledge.

Recommendation 6. The Chemical Materials Agency should continue to oversee control system improvements at individual chemical agent stockpile incineration facility sites to ensure that total performance standards are met and that sites coordinate those parts of the control system and its operation that can provide more robust continuing operations at a programmatic level. (Tier 1)

The following findings and recommendations are from Chapter 3.

Finding 7. The Department of Defense (DOD) standards on obsolescence are focused on criteria and considerations concerning obsolete weapons and other military equipment stockpiles. The DOD standards do not address the broader range of issues encountered in an operational processing facility. Another barrier to partial use of these standards is that they categorize the risk of obsolescence in a manner that is the inverse of the stockpile facilities’ long-standing categorization of safety-related risks.

Recommendation 7. The Chemical Materials Agency should disengage from using the inapplicable DOD diminishing manufacturing sources and material shortages standards and develop a program for obsolescence management that is tailored to the needs of the chemical agent stockpile disposal program. (Tier 3)

Finding 8. The site contractors for the chemical agent stockpile incineration facility sites are developing and implementing plans for managing obsolescence at each site. The Army and its contractors recognize that a process to continuously identify and evaluate critical components and parts is necessary to offset increasing vulnerability to obsolescence. Evolving systems at the various sites differ in approach and how critical components and parts are identified. These differences can have adverse implications for future program obsolescence management.

Recommendation 8. The Chemical Materials Agency should implement an effective, consistent, and documented system to manage obsolescence, including the sharing of expertise and spare equipment and parts across the chemical agent stockpile incineration facility sites. (Tier 2)

Finding 9. The chemical agent stockpile incineration facility sites all have adequate safety programs, but there is considerable variability from site to site in definitions of critical safety systems; dissemination and response to site-specific and programmatic safety alerts (advisories); procedures for control of nonroutine hazardous work; details in policies for management of change systems; applicable attributes of high-reliability organizations; and organization and implementation of training programs, including the testing of their effectiveness. As facilities and their equipment continue to age, effective safety programs must be maintained until each facility is fully decommissioned (closed).

Recommendation 9. In the interest of continuing safe operability, facility staff at each chemical agent stockpile incineration facility site should continue to compare their operations and performance with those at other sites and with practices in the broader chemical industry for dealing with hazardous materials to ensure continual improvement in safety performance, consistency in major safety practices, and safety-related cooperation among the sites. (Tier 1)

Finding 10. Only limited evidence was observed regarding programs or measures to share or protect the knowledge base important to the safe and effective functioning of the various communities that together constitute the capabilities on which the operability of chemical agent stockpile incineration facility systems depends.

Recommendation 10. A formal knowledge management program should be implemented by site managers under the guidance of the Chemical Materials Agency to identify various communities of practice among the workforce at chemical agent stockpile incineration facility sites, define the skills these communities encompass, and ensure that the skills of each member in a particular community are made available to the community as a whole as necessary. This program should also monitor the skills inventory in each community with the aim of detecting potential vulnerabilities (e.g., situations where the personnel to deliver any particular mission-critical capability are limited), and implement measures to retain staff and increase capabilities among staff where such vulnerabilities (limitations) are encountered. (Tier 2)

Finding 11. Personnel turnover varies across chemical agent stockpile incineration facility sites, but is generally low. However, this situation may not continue as facilities approach the end of disposal operations. Retention incentives have not yet been applied in an effective manner to help ensure continuing safe operations.

Recommendation 11. The Chemical Materials Agency should ensure that site contractors promptly develop staffing plans capable of being tailored to site-specific needs while recognizing the challenges of maintaining a competent staff throughout operations and closure. (Tier 2)

The following findings and recommendations are from Chapter 4.

Finding 12. The committee found no central or unified approach to identifying information technology solutions and implementing information technology changes at chemical agent stockpile incineration facility sites. This lack can lead to an erosion of compatibility, increased costs, a reduced

potential for interoperability, and other challenges to continued operation.

Recommendation 12. The Chemical Materials Agency should implement a mechanism to coordinate and formally demand consensus in areas of information management where joint operations between the chemical agent stockpile incineration facilities are appropriate. Such mechanisms should be developed, implemented, and reinforced for the remaining life span of the chemical agent stockpile disposal program. (Tier 2)

Finding 13. The server systems at chemical agent stockpile incineration facilities in their present physical state do not constitute a threat to the continuing operability of the facilities as long as budgets and management procedures enable the progressive updating and replacement of systems as needed.

Recommendation 13. Continued vigilant monitoring and maintenance of servers, based on adequate funding and management of core capabilities, is a mandatory element of the continued operability of chemical agent stockpile incineration facilities and should be ensured across sites under guidance from the Chemical Materials Agency. (Tier 3)

Finding 14. While personal computers (PCs) dedicated to typical office applications are generally kept relatively modern and up-to-date at chemical agent stockpile incineration facility sites, certain other PCs in use in laboratories, because of their linkages to dated analytical facilities, are out-of-date to the point that their continued use is problematic.

Recommendation 14. The Chemical Materials Agency (CMA) should devise and implement a life-cycle replacement program for all PCs. Consideration should be given to setting a maximum life span for PCs (e.g., three years) and replacing older machines with current hardware according to a predetermined service cycle. The CMA should specify that when a PC has been retained beyond a reasonable lifecycle expectation because it was required to support dated peripheral devices, software, or other features that are themselves substantially dated, alternatives to those peripheral items, should be identified and if possible acquired so that the overall system can be updated to current standards. (Tier 3)

Finding 15. A wide range of operating systems exist in the chemical agent stockpile incineration facilities, and this variability could pose problems for effective long-term continued operability. At the least, costs and maintenance are complicated by this diversity and apparent lack of integrated planning.

Recommendation 15. The Chemical Materials Agency should conduct an overall evaluation of security requirements, maintenance implications, and impending evolutionary changes in the basic computer operating systems (Windows and Linux) used at chemical agent disposal facilities. A migration path that drives toward a minimally heterogeneous and maximally robust environment should be identified and considered for implementation. (Tier 3)

Finding 16. A variety of data formats are used in different contexts in the chemical agent stockpile incineration facilities, and the prospect of long-term records retention and recovery is complicated by the resulting variability of native data formats.

Recommendation 16. The Chemical Materials Agency (CMA) should consider formally requiring that each copy of an electronic document requiring long-term availability be preserved in an agreed permanent or semipermanent form defined by the CMA (e.g., ASCII or portable document format). (Tier 3)

Finding 17. Service and support capabilities in the information management sector are continually improving.

Recommendation 17. Annually or biennially, the Chemical Materials Agency should survey current information management maintenance options, determine whether costs and benefits in the systems under consideration are consistent with current best practices, and require changes in practice programwide where improvements in reliability or reductions in cost are identified that can secure continued operability. (Tier 3)

The following findings and recommendations are from Chapter 5.

Finding 18. The program manager for chemical stockpile elimination (PMCSE, formerly PMCSD) has a small central staff, which limits the technical expertise that is available within the Chemical Materials Agency (CMA). The PMCSE is responsible to the CMA director for the functioning of the chemical agent stockpile incineration facility sites but has no contracting or other authority to ensure a desired result. The PMCSE must depend on personal persuasion and the responsibility of site contractors, operating under CMA-generated financial incentives, to keep the chemical agent stockpile disposal program functioning safely and effectively.

Recommendation 18. The Chemical Materials Agency (CMA) and Army management of the chemical stockpile elimination program should adjust PMCSE resources and authority, commensurate with CMA responsibility, to manage the program in the interest of the Army and the U.S. citizenry. Adjustments should ensure that an appropriate bal-

ance between assigned responsibility, resource adequacy, and granted authority is attained. (Tier 1)

Finding 19. Adoption of the site-focused management system, while promoting some improvements in the workforce culture and performance at chemical agent stockpile incineration facility sites, risks allowing a degree of independence in contractor decision making and action that could result in a loss of a critical capability for interchangeability crucial to continuing operability.

Recommendation 19. The Chemical Materials Agency should exercise sufficient centralized management control to ensure that there is appropriate programwide interchangeability of resources important to the continuing operability of chemical agent disposal incineration facilities. (Tier 1)

Finding 20. The Chemical Materials Agency has initiated an obsolescence management program that is based on using contractual means to incentivize chemical agent stockpile incineration facility site contractors to develop site-specific programs and then to share approaches and specific strategies across sites. Although the program is still evolving, the sites have begun to approach some obsolescence issues collectively.

Recommendation 20. The Chemical Materials Agency should strengthen its obsolescence management strategies programmatically and at each chemical agent stockpile incineration facility site to incorporate measures for intersite coordination and cooperation to facilitate continuing operability through to the completion of the chemical stockpile disposal program. (Tier 1)

Finding 21. The current lessons-learned system is much better organized and user-friendly than the original system, and is actively used to retain past and current programmatic knowledge of operational and hardware improvements.

Recommendation 21. The current lessons-learned program should be continually evaluated and improved as appropriate to ensure the safety and continuing operability of the chemical agent stockpile incineration facilities as obsolescence challenges increase. Wider topical aspects should be incorporated, including near-miss information and root cause accident analyses. Provision should also be made for incorporation of lessons learned into all training programs, as well as for incentives at the individual employee level when appropriate contributions to the lessons-learned program are made. (Tier 2)

Finding 22. Factors impacting the chemical stockpile disposal program include:

• scheduling pressure driven by compliance with the Chemical Weapons Convention;

• safety demands of dealing with highly toxic materials;

• requirements of detailed and demanding environmental permits;

• high public and political visibility; and

• a mandate to minimize risk to the public, to workers, and to the environment.

To ensure the continuity of operations in view of these circumstances, a stable workforce and a stable, continuous source of funds are required. Failure to provide for funding continuity will undoubtedly lead to program interruption and adversely affect the completion date for demilitarization operations as well as program costs. Adequate, stable, and dependable funding of the chemical stockpile disposal program is an essential element of program success.

Recommendation 22. The Department of the Army, Department of Defense, Office of Management and Budget, and Congress should recognize the critical need for adequate, continuous, and predictable funding of the Chemical Materials Agency as a basis for operational planning essential to accomplishing the mission of chemical agent stockpile disposal. (Tier 1)

Finding 23. Plans for mitigating the obsolescence of key equipment that will be required for closure of chemical agent stockpile incineration facilities, such as the LIC and MPF furnaces with their PAS/PFS systems, have not yet been developed.

Recommendation 23. Key equipment required for closure of chemical agent stockpile incineration facilities should be identified now, and steps to mitigate and manage obsolescence should be extended to include that equipment’s operational life. (Tier 3)