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Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
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Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS

CLOSURE PARAMETERS AND RELATED METRICS

In satisfying the statement of task, the committee identified a series of key parameters for overall program management of the closure of the Tooele Chemical Agent Disposal Facility (TOCDF) and the Chemical Agent Munitions Disposal System (CAMDS). The committee considered the lessons learned by the U.S. Army Chemical Materials Agency (CMA) at earlier facility closures, specifically, the closure of the Johnston Atoll Chemical Agent Disposal System (JACADS), which was the first full-scale incineration-based disposal facility; the Aberdeen Chemical Agent Disposal System (ABCDF), which was the first neutralization-based disposal facility; and the Newport Chemical Agent Disposal Facility (NECDF), another neutralization-based facility. It used the information from these closure experiences and committee member expertise and knowledge of the plans and activities for TOCDF and CAMDS as the basis for developing the parameters in Table 1, which are discussed below.

The parameters in Table 1 are shown along with associated metrics for promoting a safe and successful program for facility closure. These metrics are of two kinds: leading metrics, which help predict performance, and lagging metrics, which indicate the actual performance. While the metrics listed are considered important by the committee, they should not be considered all-inclusive. Moreover, it is important to note that as has been the practice during agent disposal operations, all plans and actions regarding closure need to be fully documented for future use and analysis.

Safety, Health, and Security

The committee believes that safety must continue to be at the forefront during closure operations. Both leading and lagging metrics for safety, health, and security (as well as other parameters) need to be tracked and documented as part of the normal deconstruction process. While not an exhaustive list, the metrics provided in Table 1 for this parameter represent a strong start. Good outcomes concerning safety and health are supported by the establishment of systemic data collection, site observations, and incident reporting and investigation processes. Also, the committee believes that the existing operations workforce should be briefed on the hazards of the deconstruction activities.

Communications for Promoting Safety Culture

The committee likewise believes that a strong, positive, safety culture will continue to prevail at TOCDF/CAMDS if the management maintains an active and involved safety communication and audit program. A good safety and operations culture rests on frequent formal and informal sharing of information and ongoing dialogue.

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
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Letter Report on TOCDF-CAMDS Closure Planning

MAR Draft: January 7, 2010

TABLE 1 Facility Closure Parameters and Associated Leading and Lagging Metricsa

Parameter

Leading Metrics

Lagging Metrics

Safety, health, and security

  • Near misses (potential injury, potential exposure, potential breach)

  • Site orientation for visitors and workforce

  • Incident investigations completed within 30 days

  • Cross training for workforces and supervisors

  • Appropriate personal protective equipment for all tasks (goal is 100 percent)

  • Closure of open safety items in a timely manner

  • Random drug testing

  • First aid cases by body part

  • Recordable injuries and exposures

  • Lost-time injuries (number)

  • Days away from work due to workplace incident/injury

  • Fatalities (all causes)

  • Transportation incidents on-site/off-site

  • Fires (ranging from smoke through explosion)

  • Security (actual breach of fence line, procedures)

Communications for promoting safety culture

  • Periodically survey employees, supervisors, and managers with respect to criteria important to a strong safety culture

  • Document frequency of safety communication sessions where employee leadership and participation are encouraged

Maintenance Planning and scheduling of all maintenance work

  • Appropriate maintenance for construction equipment

  • Preventive maintenance program for key equipment

  • Predictive maintenance program for key equipment

  • Appropriate calibration and checking of instrumentation and controls

  • Audit maintenance process regularly

  • Monitor maintenance

Training and development

  • Cross train and educate for critical operation and deconstruction positions

  • Continuing education: at least 40 hours per year of technical coursework

  • Workforce training on the facility and on non-normal process situations for operation personnel, including drills for abnormal conditions

  • Workforce training on the facility and on non-normal process situations for deconstruction personnel, including emergency and abnormal conditions

  • Not applicable

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×

Parameter

Leading Metrics

Lagging Metrics

Communications with various stakeholders

  • Scheduled communications with a local community action committee with a consistent agenda

  • Communications with the state of Utah regulatory personnel on a regular and as needed basis

  • Regularly scheduled two-way communications with the workforce throughout the life cycle of the site

  • Track the lessons-learned program to ensure that the lessons are utilized throughout the chemical demilitarization program

  • Measure response to meetings scheduled with stakeholders

Quality criteria

  • Identify complete inventory of units to be closed and the end state plan for each

  • Ensure the environmental health and safety management system is complete and operating with appropriate data analysis and management

  • Develop project schedule milestone projections for the next period (week, month)

  • Track engineering changes

  • Regularly track project schedule milestones from preplanning to completion

Cost criteria

  • Project program costs over similarly selected periods and verify

  • Track program costs over selected periods

Operations and deconstruction

  • Monitor lockout-tag-clear-and-try process

  • Establish and document safe operating conditions for all major process equipment

  • Establish expected frequency and duration of “hot” electrical work

  • Document excursions outside operating conditions

  • Document frequency and duration of safety interlock bypasses

  • Document frequency and duration of “hot” electrical work

  • Track deconstruction progress (e.g., weight, volume, or number of units)

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×

Parameter

Leading Metrics

Lagging Metrics

Management

  • Ensure that supervisors and managers have appropriate experience with respect to operations, maintenance, or laboratory skills for high-hazard processes

  • Develop processes by which top managers regularly audit and assess all key activities

  • Monitor implementation of personnel development and retention plan

Environmental regulatory compliance

  • Establish facility end-state conditions

  • Establish performance standards for closure wastes

  • Modify Resource Conservation and Recovery Act (RCRA) permit to include detailed closure plans

  • Modify other applicable permits to include closure

  • Monitor compliance with RCRA permit

  • Monitor compliance with closure plans

  • Monitor compliance with other permits

Monitoring plan compliance

  • Develop waste analysis plan and waste characterization protocols

  • Develop monitoring plans for air and other media

  • Monitor implementation of waste analysis plan

Analytical

  • Establish criteria for use of generator knowledge

  • Identify validated analytical methods to be used

  • Obtain regulatory acceptance of validated analytical methods

  • Not applicable

Materials management

  • Identify reuse and recycling options for deconstruction materials

  • Develop protocols for segregation of generated hazardous and nonhazardous materials

  • Obtain prior regulatory agreement for reuse, recycling, or disposal of all materials

  • Identify means for control of inventory of hazardous and nonhazardous materials

  • Establish a time line for risk-based disposition of all materials resulting from closure

  • Implement control of inventory of hazardous and nonhazardous materials

aA leading indicator is a prospective metric or set of metrics that can be used to develop strategies for project success; a lagging indicator is a retrospective metric or set of metrics that can point to a need for corrective action (NRC, 2009).

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×

Maintenance

Many injuries can be prevented through well-managed maintenance work processes. Basic maintenance begins with planning and scheduling, and it is a good goal to have at least 85 percent of all maintenance activities planned and scheduled at least one week in advance. To minimize worker exposure, it would be advantageous to implement both preventive and predictive maintenance programs for equipment that will operate during closure, such as the metal parts furnace.

Training and Development

Training and development of the workforce is a key strategic element for successful program completion. The technical aspects of the TOCDF and CAMDS closure operations mandate that the workforce be properly prepared through education and training provided by their employer. Additionally, it is imperative that an effective communication strategy be developed to ensure that there is open two-way dialogue with the workforce, regulators, and the community on critical issues. The committee believes that a concerted effort should be made to train the deconstruction workforce on hazards awareness pertinent to the site situation. This cross training between personnel familiar with operations at the site and the deconstruction workforce is believed to be essential for the safe outcomes that all stakeholders are interested in seeing. Establishing a program to assess the effectiveness of the training provided is also necessary.

Communications with Various Stakeholders

TOCDF/CAMDS management must actively lead and support communications with key stakeholders. Good communications build trust and provide more opportunities to understand the changing nature of risk.

Quality Criteria

Program quality is a key strategic element for successful program completion. Quality elements, such as adequate and appropriate analytical capabilities and retention of key personnel, comprise critical program management items that can significantly affect the outcome. Integrating quality into the operation supports all activities for continuous improvement.

Cost Criteria

Program cost objectives are a key strategic parameter of the successful completion of site closure. Management should be able to both forecast anticipated costs and to effectively explain all expenditures—both committed and expended—during any period.

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×

Operations and Deconstruction

The committee identified some common work activities for this parameter and listed them in Table 1). If done safely, these activities can lead to a safe and reliable closure operation.

Management

With all work activities, management sets the tone and leads the site effort by its example and their leadership. The metrics listed for this parameter in Table 1 offer ways to consider how management may want to measure their activities and their effectiveness along with exercising appropriate oversight of all leading and lagging metrics in Table 1.

Environmental Regulatory Compliance

Obtaining regulatory agreement to the closure plan in a timely manner is key to achieving efficient closure. This requires close coordination with the regulatory community to obtain early agreement on closure performance standards. Before closure performance standards can be negotiated, the end state must be established. Based on this anticipated end use, environmental standards and guidelines can be established, closure plans completed, and permits modified. Continued monitoring for meeting the permit requirements will minimize delays.

Monitoring Plan Compliance

Development of the waste analysis plan requires agreement between the site contractor, the Army, and the Utah Department of Environmental Quality (UDEQ). This requires determination of what is to be analyzed and what analytical methods are to be used. If methods have to be developed or validated, this activity requires a long lead time. If waste is to be shipped off-site, the recipient of the off-site waste may require additional testing and certification of the waste.

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×

Analytical

For closure wastes, there are several methods for determining whether the waste poses residual hazards. Typically, generator knowledge2 and standard methods such as those provided in the EPA publication SW-846 are used to determine if a waste meets the release criteria. When these are not available, new methods may have to be developed and validated. This may be time- and resource-intensive.

Materials Management

Careful materials management is a key to successful facilities closure. Decontamination, reuse, recycle, and disposal options for equipment and secondary waste materials generated during closure should be identified. Protocols for segregation of generated hazardous and nonhazardous materials should then be implemented, including planning for prevention of cross-contamination. This will require proper identification and inventory control of these materials. A time line for risk-based disposition of all materials resulting from closure should be developed. Prior regulatory agreement and approval should be obtained for reuse, recycling, and disposal of all materials. In addition, protocols that have been established to prevent releases from stored waste should be continued.

2

“Generator knowledge” is an evaluation method for hazardous waste that is commonly accepted and defined by the EPA and individual states based on some or all of the following information (EPA, 2005):

1. Facility process flow diagram or narrative description of the process generating the waste (should be used in most cases).

2. Chemical makeup of all ingredients or materials used in the process that generates the waste (should be used in most cases).

3. List of constituents that are known or believed to be by-products or side reactions of the process that produces the waste.

4. Material safety data sheets and/or product labels or substances used in the process that generates the waste.

5. Data obtained from approved methods of sampling and laboratory analysis of waste generated from the same process using the same ingredients/materials.

6. Data obtained from literature regarding waste produced from a similar process using the same ingredients/materials.

7. Documentation of product specifications or input materials and output products.

Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 7
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 8
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 9
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 10
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 11
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 12
Suggested Citation:"Assessment Criteria and Status Review of Closure Planning for TOCDF and CAMDS." National Research Council. 2010. Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12838.
×
Page 13
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The Chemical Materials Agency (CMA), requested the National Academies' Board on Army Science and Technology to examine the current state of closure activities for the Tooele Chemical Agent Disposal Facility (TOCDF) and the Chemical Agent Munitions Disposal System (CAMDS). In this brief interim report, the Committee on Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System addresses some of the issues pertaining to closure at the TOCDF and CAMDS facilities. It also provides insights into what the committee believes are important parameters to ensure the success of the CMA's closure program for these and CMA facilities at other locations. This interim report is to be followed by another report, which will use these parameters to conduct a comprehensive assessment of closure activities and issues.

For this interim report, the committee examined the current status of closure plans for both the TOCDF and CAMDS based on presentations by key members of CMA staff and the systems contractor. It then developed a set of parameters based on this high-level evaluation to help ensure a consistently effective approach to the closures of the four currently operating CMA chemical agent disposal facilities. The committee also assessed regulatory requirements imposed by the state of Utah, where TOCDF and CAMDS are located.

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