procedures for closure would include an appropriate emphasis on safety, which were not discussed fully in the closure documents and presentations obtained while this letter report was being prepared. Approval of the basic closure plan is expected to be requested from the UDEQ in June 2010. The target date for planning completion is January 2011, and the expanded plans will include development of new documentation for unit-by-unit closure and the closure implementation schedule.
TOCDF closure planners are maintaining good relations and cooperation with the UDEQ. Closure operations, including those for the munitions demilitarization building, are projected to begin in September 2011, but some advance work was being carried out as this report was being prepared (as discussed below). The metal parts furnace and liquid incinerators will be closed later in the schedule (mid-2013) to allow for their availability to process closure waste process.
Present planning for TOCDF closure is based on a strategy of decontamination by moving progressively from the most contaminated to the least contaminated areas and structures. In general, this will involve removal of any residual agent and explosive material residues, followed by removal of agent-exposed equipment and subsequent decontamination of occluded spaces and exposed surfaces. Scabbling will be used if in-progress sampling shows it is needed.3 When an area and structure have been completely decontaminated, the strategy for decontaminating the cascaded ventilation systems is to use a final washdown, certify that occluded spaces have been appropriately decontaminated, and, finally, use ventilated and unventilated testing to measure internal ambient air agent concentrations in a controlled manner.
Certain closure tasks, such as decontamination and removal of equipment, will be performed under partial-closure plans when possible without disrupting disposal operations. Already a number of such tasks have been completed. Early closure activities are projected to continue through August 2011.
A large quantity of stored legacy secondary waste, secondary waste being generated during continuing munitions disposal operations, and waste from TOCDF closure operations is projected to be either processed on-site and/or shipped off-site. Treatment, if necessary, and shipment of such wastes will take place during continuing disposal operations as scheduling opportunities present themselves or, alternatively, during closure operations. Secondary waste from all sources is projected to be disposed of by the third quarter of 2014.
The time line for TOCDF closure indicated above takes into consideration uncertainties concerning the UDEQ determinations on allowable standards for secondary waste treatment and off-site disposal. Site deconstruction is projected to continue until June 2014, with final administrative closure of TOCDF in February 2016. Notwithstanding the planning described above, and based largely on committee members’ collective experience and observations in obtaining permit changes, the committee believes that the current schedule is optimistic. Moreover, certain members of the public are known to take great issue with some of the activities surrounding the chemical demilitarization program. Generally speaking, the more contentious the issues, the longer the permitting processes are likely to take.