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.



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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. -7-

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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) First aid cases by body part   Site orientation for visitors and workforce Recordable injuries and exposures   Incident investigations completed within 30 days Lost-time injuries (number)   Cross training for workforces and supervisors Days away from work due to workplace  incident/injury Appropriate personal protective equipment for all tasks (goal is 100  percent) Fatalities (all causes)   Closure of open safety items in a timely manner Transportation incidents on-site/off-site   Random drug testing Fires (ranging from smoke through explosion)  Security (actual breach of fence line, procedures)   Communications for Periodically survey employees, supervisors, and managers with Document frequency of safety communication promoting safety culture respect to criteria important to a strong safety culture sessions where employee leadership and participation are encouraged   Maintenance Planning and scheduling of all maintenance work Audit maintenance process regularly   Appropriate maintenance for construction equipment Monitor maintenance  Preventive maintenance program for key equipment  Predictive maintenance program for key equipment  Appropriate calibration and checking of instrumentation and controls   Training and development Cross train and educate for critical operation and deconstruction Not applicable 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 -8-

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Parameter Leading Metrics Lagging Metrics   Communications with Scheduled communications with a local community action Measure response to meetings scheduled with various stakeholders committee with a consistent agenda stakeholders  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   Quality criteria Identify complete inventory of units to be closed and the end state Track engineering changes  plan for each Regularly track project schedule milestones from  Ensure the environmental health and safety management system is preplanning to completion complete and operating with appropriate data analysis and management  Develop project schedule milestone projections for the next period (week, month)   Cost criteria Project program costs over similarly selected periods and verify Track program costs over selected periods   Operations and Monitor lockout-tag-clear-and-try process Document excursions outside operating conditions   deconstruction Establish and document safe operating conditions for all major Document frequency and duration of safety process equipment interlock bypasses   Establish expected frequency and duration of “hot” electrical work Document frequency and duration of “hot” electrical work  Track deconstruction progress (e.g., weight, volume, or number of units) -9-

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Parameter Leading Metrics Lagging Metrics   Management Ensure that supervisors and managers have appropriate experience Monitor implementation of personnel development with respect to operations, maintenance, or laboratory skills for high- and retention plan hazard processes  Develop processes by which top managers regularly audit and assess all key activities   Environmental regulatory Establish facility end-state conditions Monitor compliance with RCRA permit   compliance Establish performance standards for closure wastes Monitor compliance with closure plans   Modify Resource Conservation and Recovery Act (RCRA) permit to Monitor compliance with other permits include detailed closure plans  Modify other applicable permits to include closure   Monitoring plan compliance Develop waste analysis plan and waste characterization protocols Monitor implementation of waste analysis plan  Develop monitoring plans for air and other media   Analytical Establish criteria for use of generator knowledge Not applicable  Identify validated analytical methods to be used  Obtain regulatory acceptance of validated analytical methods   Materials management Identify reuse and recycling options for deconstruction materials Implement control of inventory of hazardous and  nonhazardous 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 a A 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). -10-

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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. -11-

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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. -12-

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Analytical For closure wastes, there are several methods for determining whether the waste poses residual hazards. Typically, generator knowledge 2 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. -13-