2
Overall Closure Planning for Baseline Facilities

BACKGROUND

Successful closure of the baseline chemical agent disposal facilities will require programmatic, facility-specific, and task-level planning. At the program level, the U.S. Army’s Chemical Materials Agency (CMA) management staff has articulated certain expectations it has of each site preparing to undergo site closure through its Strategic Plan for 2010 to 2015 and other CMA policy guidance (CMA, 2009). Closure planning by each of the four chemical agent disposal facilities must integrate these expectations while addressing the unique or specific processes and circumstances that exist at each site.

Plans for all four of the baseline facilities must address the safety of workers and the community and the requirements of applicable regulations. In addition, they must include, at a minimum, the following planning elements:

  1. An overall site-specific closure plan that describes, at a high level, the closure strategy for the site, consistent with any articulated CMA direction;

  2. A decommissioning plan that describes the process to take the facility, including units and equipment out of service;

  3. A decontamination plan that addresses how hazardous substances (both agent and non-agent) will be removed or destroyed prior to demolition and subsequent management of waste/material; and

  4. A demolition plan that describes the approach to removing equipment and razing structures.

The committee asked the Army to provide the status of planning for each of the above key elements and several other associated facility-specific planning elements, shown in Column 1 of Table 2-1, for each baseline facility. The Army’s response is provided in Columns 2 through 6 of Table 2-1. Planning components completed as of June 16, 2010, when the committee ceased gathering information, are indicated in Table 2-2. As shown, each of the facilities is in a different state of closure planning. Site-specific closure planning is most advanced at the Pine Bluff facility, followed by the Umatilla, Anniston, and Tooele facilities, respectively. Relevant to the statement of task, most of the planning components in Tables 2-1 and 2-2 were not yet developed for the Tooele facility by this date.

PROGRAMMATIC PLANNING

A programmatic plan sets CMA leadership’s standards and expectations for closure planning at the four baseline facilities. The committee believes that at a minimum, a programmatic plan should include: any pertinent Army policy statements, goals and metrics, expectations on safety and regulatory requirements, and quality assurance.

Key Parameters, Metrics, and Goals—The Army’s Definition of Success

It is critical to the success of any program to identify what is important; put simply, “What does success look like?” A key mechanism for the realization of an



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2 overall closure Planning for Baseline Facilities BacKgrouNd The committee asked the Army to provide the status of planning for each of the above key elements and Successful closure of the baseline chemical agent several other associated facility-specific planning ele- disposal facilities will require programmatic, facility- ments, shown in Column 1 of Table 2-1, for each base- specific, and task-level planning. At the program level, line facility. The Army’s response is provided in Col- the U.S. Army’s Chemical Materials Agency (CMA) umns 2 through 6 of Table 2-1. Planning components management staff has articulated certain expectations completed as of June 16, 2010, when the committee it has of each site preparing to undergo site closure ceased gathering information, are indicated in Table 2- through its Strategic Plan for 2010 to 2015 and other 2. As shown, each of the facilities is in a different state CMA policy guidance (CMA, 2009). Closure planning of closure planning. Site-specific closure planning is by each of the four chemical agent disposal facilities most advanced at the Pine Bluff facility, followed by the must integrate these expectations while addressing the Umatilla, Anniston, and Tooele facilities, respectively. unique or specific processes and circumstances that Relevant to the statement of task, most of the planning exist at each site. components in Tables 2-1 and 2-2 were not yet devel- Plans for all four of the baseline facilities must oped for the Tooele facility by this date. address the safety of workers and the community and the requirements of applicable regulations. In addition, ProgrammaTic PlaNNiNg they must include, at a minimum, the following plan- ning elements: A programmatic plan sets CMA leadership’s stan- dards and expectations for closure planning at the four baseline facilities. The committee believes that at a 1. An overall site-specific closure plan that describes, minimum, a programmatic plan should include: any at a high level, the closure strategy for the site, pertinent Army policy statements, goals and metrics, consistent with any articulated CMA direction; expectations on safety and regulatory requirements, 2. A decommissioning plan that describes the pro- and quality assurance. cess to take the facility, including units and equip- ment out of service; 3. A decontamination plan that addresses how haz- Key Parameters, metrics, and goals— ardous substances (both agent and non-agent) will The army’s definition of success be removed or destroyed prior to demolition and It is critical to the success of any program to iden- subsequent management of waste/material; and tify what is important; put simply, “What does success 4. A demolition plan that describes the approach to look like?” A key mechanism for the realization of an removing equipment and razing structures. 0

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 OVERALL CLOSURE PLANNING FOR BASELINE FACILITIES TABLE 2-1 Status of Closure Planning Documentation for Each Baseline Chemical Agent Disposal Facility Anniston Pine Bluff Tooele Chemical Agent Umatilla Chemical Agent Chemical Agent Chemical Agent Munitions Chemical Agent Planning Disposal Facility Disposal Facility Disposal Facility Disposal System Disposal Facility Component (ANCDF) (PBCDF) (TOCDF) (CAMDS) (UMCDF) Site Facility The RCRA FCP has The Facility Closure The FCP is scheduled Scope is captured The FCP is included in Closure Plan been submitted, approval Plan (PB-PL-110) was for issuance in in the Facility the Decommissioning (FCP) expected in January 2011. issued in February September 2010. Decontamination Plan (UM-PL-108) issued Final plan will follow this 2010. and Disposition Plan in May 2010. approval, estimated (FDDP) issued in for March 2011. March 2010. Closure Planning The ANCDF CPIS The CPIS is included The CPIS is included Scope is captured in The CPIS is included in Implementation was issued in November in the FCP (PB- in the FCP that is the FDDP and was the Decommissioning Strategy (CPIS) 2008. PL-110) and in the scheduled for issue issued in March 2010. Plan (UM-PL-108) issued Decommissioning September 2010 and in in May 2010. Plan (PB-PL-108) the Decommissioning issued in February Plan (scheduled for 2010. issue in August 2010). For the preparation of the CPIS TOCDF used the Capstone document that was developed during the Programmatic Closure Project, the CMA closure guide, and other programmatic documents as a basis. Decommissioning The ANCDF The PBCDF The Decommissioning This scope is captured The Decommissioning Plan Decommissioning Plan Decommissioning Plan is part of the in the FDDP issued in Plan (UM-PL-108), rev. is included in the Facility Plan (PB-PL-108) FDDP. The FDDP is March 2010. 1, was issued in May Disposition Plan issued on was issued in February scheduled for issuance 2010. March 29, 2010. 2010. in August 2010. Decontamination ANCDF is updating the The Decontamination The Decontamination This scope is captured Content on Plan Decontamination Plan that Plan (PB-PL-118) was Plan is part of the in the FDDP issues in decontamination was was included in the Permit issued on February 12, FDDP. The FDDP is March 2010. included in the RCRA modification that was 2010. scheduled for issuance FCP. ODEQ approval of submitted to ADEM for in July 2010. the FCP is expected in review on April 29, 2010. September 2010. Approval is expected by March 2011. Demolition Plan In lieu of a separate The Demolition Plan The TOCDF The CAMDS Content on demolition distinct Demolition Plan will be addressed Demolition Plan is Demolition Plan is was included in the ANCDF will provide in the Final Site part of the Demolition being developed with RCRA FCP. This plan is detailed demolition Decontamination and Disposition Plan. the TOCDF Demolition currently under review by scope of work in the Decommissioning and Issuance on this plan is and Disposition Plan ODEQ. (PMR-09-006). Closure Work Proposal Demolition (DDD) estimated in September and is scheduled to be Approval is expected in and Engineering Work Package (DDD-16- 2010. issued in September September 2010. Packages for the areas to 040). Issuance of this 2010. be demolished along with plan is estimated in an Estimate and a Request January 2011. for Proposal to be put out for bid to qualified demolition contractors. The detailed packages for the MDB and the Pollution Abatement Areas (the only areas to undergo mass demolition) are due to be issued by June 1, 2011. Continued

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES TABLE 2-1 Continued Anniston Pine Bluff Tooele Chemical Agent Umatilla Chemical Agent Chemical Agent Chemical Agent Munitions Chemical Agent Planning Disposal Facility Disposal Facility Disposal Facility Disposal System Disposal Facility Component (ANCDF) (PBCDF) (TOCDF) (CAMDS) (UMCDF) Regulatory Closure The RCRA Closure Plan This plan is included The RCRA Closure The CAMDS RCRA The RCRA Closure Plan was submitted to ADEM in the FCP and in the Plan is scheduled for Closure plan was Plan update has been as part of the Permit Decommissioning submittal in June 2010. approved by DSHW submitted to ODEQ modification submitted Plan (PB-PL-108) that Approval is expected on February 25, 2010. (PMR-09-006). Approval to ADEM in April 2010. were issued in in December 2010. is expected in September Approval is expected in February 2010. 2010. January 2011. Programmatic The TOCDF program- PBCDF continually This review task is This is being performed Because of the Documents Review matic documents have evaluates Closure being performed as as part of the TOCDF similarities between the (TOCDF) been made part of the Lessons Learned part of the develop- effort. There were TOCDF and UMCDF, site library and are during DDD package ment of the Facility site-specific documents Umatilla conducted an in- continuously used for development. Closure Plan. developed for CAMDS depth review of TOCDF development of closure Programmatic modeled from the programmatic documents work packages. documents are TOCDF programmatic and has developed work addressed in the documents that are plans for closure making Facility Closure Plan being used internally. extensive use of these (PB-PL-110), as documents. appropriate. A set of parallel programmatic documents were prepared for PBCDF and are maintained for internal use at PBCDF during development of the DDD packages. This effort is ongoing. Personnel Planning A Transition De-staffing De-staffing plans are De-staffing plans are De-staffing planning The UMCDF De-staffing Plan is planned to be under development at being addressed via for CAMDS is part of Plan has been drafted. incorporated into the PBCDF. Issuance is a Human Resources the overall TOCDF Issuance is expected in Closure Integrated Master anticipated in August initiative. A Project planning effort. July 2010. A Transition Schedule in September 2010. Management Plan has Plan is in draft; issuance 2010. been approved for this is expected in July 2010. effort and a schedule is being developed for issue by September 2010. High-level de-staffing plans have been communicated to the workforce via Visions and Values meetings held in March 2010. This was also communicated to the Citizens Advisory Commission in March and will be updated in the Fall of 2010. Closure Safety Plan ANCDF will use the The CSP is addressed Closure safety plans Safety planning for UMCDF will use the (CSP) existing plan with under the System will be summarized in CAMDS Closure existing plan, revised to appropriate revisions. Safety Implementation the Facility Closure utilizes safety plans address unique closure Revision is scheduled for Plan Volume II (PB- Plan, expected for and procedures conditions. Issuance of March 2011. PL-025), the issuance in September incorporated from the revision is expected Occupational Health 2010. TOCDF. in October 2010. and Hygiene Plan Volume II (PB-PL- 027), and the Accident Prevention Plan Volume II (PB-PL-039).

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 OVERALL CLOSURE PLANNING FOR BASELINE FACILITIES TABLE 2-1 Continued Anniston Pine Bluff Tooele Chemical Agent Umatilla Chemical Agent Chemical Agent Chemical Agent Munitions Chemical Agent Planning Disposal Facility Disposal Facility Disposal Facility Disposal System Disposal Facility Component (ANCDF) (PBCDF) (TOCDF) (CAMDS) (UMCDF) Public Participation ANCDF encourages public Public participation Public participation is Public participation UMCDF does not plan to Plan participation in round in PBCDF closure being addressed as part for CAMDS is being develop a self-standing table meetings, to be held planning is addressed of the human resources addressed along with public participation plan. in the community, with in the Facility Closure initiative. A Project the TOCDF effort. Continued community the goal of discussing the Plan (PB-PL-110). Management Plan has participation in both impact of ANCDF closure This plan is scheduled been approved for this Land Reuse Authority on the employees and the to be issued June 25, effort and a schedule coordination meetings community in general. 2010. is being developed for and in routine Citizens issue by September Advisory Commission 2010. Also closure meetings will form discussions took place the basis for public with the Citizens participation in UMCDF Advisory Commission closure plans. in March and will be addressed again in the Fall of 2010. NOTE: ADEM, Alabama Department of Emergency Management; ANCDF, Anniston Chemical Agent Disposal Facility (Alabama); CAMDS, Chemical Agent Munitions Disposal System (Utah); CPIS, closure planning implementation strategy; CSP, closure safety plan; DSHW, Division of Solid and Hazardous Waste (Utah); FCP, facility closure plan; FDDP, facility decontamination and disposition plan; MDB, munitions demilitarization building; ODEQ, Oregon Department of Environmental Quality; PBCDF, Pine Bluff Chemical Agent Disposal Facility (Arkansas); RCRA, Resource Conservation and Recovery Act; TOCDF, Tooele Chemical Agent Disposal Facility (Utah); UMCDF, Umatilla Chemical Agent Disposal Facility (Oregon). SOURCE: P.C. Mohondro, URS Programmatic Closure Planning Manager, with input from R.J. Gramatges, URS Specialty Group Manager, and from the ANCDF, CAMDS, PBCDF, TOCDF, and UMCDF Site Closure Managers, June 2010. TABLE 2-2 Closure Planning Documents Completed by June 16, 2010, for Each Baseline Chemical Agent Disposal Facility Anniston Pine Bluff Tooele Chemical Agent Umatilla Chemical Agent Chemical Agent Chemical Agent Munitions Disposal Chemical Agent Disposal Facility Disposal Facility Disposal Facility System Disposal Facility Planning Component (ANCDF) (PBCDF) (TOCDF) (CAMDS) (UMCDF) Site Facility Closure 4 4 4 4 Plan (FCP) Closure Planning 4 4 4 4 Implementation Strategy (CPIS) Decommissioning Plan 4 4 4 4 Decontamination Plan 4 4 4 4 Demolition Plan Regulatory Closure 4 4 4 4 Plan Programmatic 4 4 4 4 Documents Review (TOCDF) Personnel Planning Closure Safety Plan 4 4 4 (CSP) Public Participation 4 4 4 Plan NOTE: The committee ceased data gathering for this study on June 16, 2010.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES Recommendation 2-1. Senior Chemical Materials organization’s view of success is the establishment of key parameters and metrics. The management of the Agency management should provide policy guidance closure of the four baseline facilities is a complicated for closure in critical areas such as the unventilated task requiring diverse teams at multiple sites around the monitoring test to ensure that these critical activities country to advance the program in a way that ensures are planned and executed in a uniform manner across the safety and protection of workers and communities. all facilities. The establishment of key parameters and metrics sends a message from the CMA headquarters staff about what In addition to parameters and metrics, it is desirable the program leadership feels is critical to the success of and appropriate to establish measurable goals, or “tar- the facility closure phase of the program. Key parameters gets.” Clearly articulated goals send strong messages and metrics are also an important mechanism to unify and from the CMA leadership and may also be used to drive integrate approaches across the four baseline facilities. continuous improvement. The committee discusses I nitially, CMA envisaged a programmatic plan parameters in Chapter 3. developed for the Tooele Chemical Agent Disposal Finding 2-2. The Chemical Materials Agency’s Strate- Facility that would serve as the basis for plans for the other facilities. This plan was never completed when gic Plan for closure of baseline chemical agent disposal it was determined that the Tooele Chemical Agent Dis- facilities identifies a number of parameters and metrics, posal Facility would not, as previously discussed, be but it does not articulate measurable goals (targets) the first facility to undergo closure.1 Parts of the plan against which progress will be tracked. Goals drive do exist and serve as a basis for planning as deemed behavior and performance. For example, the Army mea- appropriate by each facility. The closure managers and sures 12-month rolling recordable injury rates. However, their senior staffs for the baseline facilities coordinate it is not clear to the committee whether the Army estab- their activities both with a weekly conference call and lishes a target for reduction of the recordable injury rate. regular in-person coordinating meetings. It appears Similarly, the Army measures schedule slippage, but it is to the committee that the senior closure managers are not clear whether it wants to reduce schedule slippage by very competent in coordinating and carrying out the a certain amount over some period of time. planning activities. However, each facility is develop- Recommendation 2-2a. Parameters and the associated ing its plans to meet its particular situation. This is to be expected because of the particular situations at each metrics for successful closure of the Army’s baseline facility. But it would appear that some guidance from chemical agent disposal facilities should be established senior CMA management in policy-critical areas such at the programmatic (headquarters) and site (project) as the unventilated monitoring test (see Chapter 6) levels of the chemical stockpile disposal program would promote uniformity of approach and execution administered by the Chemical Materials Agency. While of planning and, as a result, the closure operations. The the strategic plan addresses key parameters that will be committee believes that at a minimum the program- tracked at the headquarters level, the committee rec- matic plan should include goals and metrics, Army ommends that parameters be established at the project policy, expectations on safety and regulatory require- level that are consistent with the strategic parameters. ments, and quality assurance. These parameters should be tracked and measured at the project level at each of the baseline facilities. Finding 2-1. The closure managers and their teams Recommendation 2-2b. The Army should develop appear to be highly competent and to coordinate their needs and approaches well through frequent contacts specific and quantifiable targets for parameters impor- and meetings. Each site is taking its own approach to the tant to the overall chemical stockpile disposal program planning activities because of differing end use, facil- and for which the Chemical Materials Agency head- ity, and regulatory situations. There does not appear to quarters wants to drive improvement. be sufficient senior policy guidance in key issues such as the critical unventilated monitoring test. essential Program elements and army Policy Programmatic closure planning must provide the 1Personal communication between Rafael Gramatges, Specialty foundation for the development of site-specific closure Group Manager, URS, and Peter Lederman, committee chair, June plans, ensuring consistency in approach and establish- 16, 2010.

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 OVERALL CLOSURE PLANNING FOR BASELINE FACILITIES Finding 2-3c. Waste characterization (both agent and ing requirements of those critical elements that should be evaluated and integrated into every site specific non-agent), decontamination, and associated confirma- plan. Further, any specific policies or strategies that tion monitoring are critical to the safe execution of the the Army would like to see executed in site-specific Chemical Materials Agency strategy for closure. closure plans should be articulated in programmatic R ecommendation 2-3. T he Chemical Materials planning. The CMA’s “Strategic Plan: Fiscal years 2010–2015,” Agency’s closure strategy to emphasize mass demoli- November 2009, describes the vision and mission of the tion should continue to be actively pursued. However, Programmatic Closure Planning process (CMA, 2009). this strategy should be supported in planning and This document articulates a vision that “Creates a safer execution by testing and monitoring necessary for suc- tomorrow by making chemical weapons history.” It cessful execution of the strategy. further articulates the strategic processes that the Army will use to develop its programmatic approach as well Waste characterization is discussed more fully in as establishing management systems to measure prog- Chapters 5 and 6. The Army is proposing to decon- ress toward the CMA vision and mission. taminate the buildings by first removing some of the A December 17, 2008, Memorandum from the Chief, equipment, then checking for agent contamination, and, Secondary Waste, Closure Compliance and Assess- as necessary, decontaminating surfaces using standard ment, titled a “Program Manager for Chemical Stock- caustic decontamination solutions (O’Donnell, 2008). pile Elimination (PMCSE) Chemical Disposal Facility This process will be followed by locating occluded Closure Strategy,” describes the PMCSE’s vision for spaces where agent could be sequestered, and then closure (O’Donnell, 2008). This strategy emphasizes opening and decontaminating those spaces. Finally, the importance of safety and seeks also to minimize ventilated and unventilated monitoring tests, which are cost and schedule by encouraging mass demolition to discussed in detail in Chapter 6, will be performed. the greatest extent possible. Mass demolition enables use of mechanical deconstruction employing conven- FaciliTy-sPeciFic closure PlaNNiNg tional construction equipment to remove structures and minimizes human actions required for deconstruction. The major planning components that the committee The memo states, “Put in simplest form, the strategy believes are necessary to execute a safe and successful uses in situ decontamination followed by confirmatory site closure are listed in Figure 2-1. Starting with the head-space monitoring as a gateway to mass demolition end use in mind, each facility will need to develop: an of the facility” (O’Donnell, 2008). overall facility closure plan, decommissioning plans, decontamination plans, demolition plans, and materials Finding 2-3a. The Chemical Material Agency’s (CMA’s) and waste disposition plans. “Strategic Plan: Fiscal years 2010–2015,” November Each of these “phase” plans should incorporate 2009, describes the Army’s vision and mission for the safety and health, personnel planning (retention, skill programmatic closure planning process. This document sets, etc.), public participation, regulatory require- also articulates the key parameters and metrics that the ments, and any requirements specific to the Army. Army will measure and evaluate at the headquarters Program parameters and metrics should be established level. These key parameters include safety, schedule, and cascaded down from CMA to the facilities. Targets and cost. The CMA’s “Policy Statement #21, Strategic should be established and the metrics monitored for Baseline Accountability,” March 8, 2010, sets forth the achievement and updating where the Army seeks to Army’s expectations on accountability and reporting of drive continuous improvement. Each facility should key parameters to CMA leadership. report performance against parameters and any estab- lished goals back to CMA. Lessons learned should be Finding 2-3b. The Chemical Materials Agency has continually evaluated and incorporated into all com- placed high importance on implementing mass demoli- ponents of site closure planning. Incorporating lessons tion, a strategy that has positive implications for safety, learned from prior facility closures, such as the John- cost, environmental impact, and scheduled completion ston Atoll Chemical Agent Disposal System, is critical of the project. to continuous improvement and ensuring overall suc- cess of the closure program. The committee discusses lessons learned in more detail in Chapter 4.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES SITE END STATE VISION Program metrics requirements Army SITE CLOSURE PLAN Site metrics Safety & health Lessons learned Decommissioning plan Personnel par ticipation plans Monitor & verify Decontamination plan Project metrics Public Deconstruction/demolition requirements Regulatory FIGURE 2-1 Site-specific closure planning. Each of the four baseline facilities is in the process Further, workers who will be involved in these differ- of developing key site-specific documents that will con- ent phases of closure need to understand the different Figureisks that will be encountered and the different health r 2-1 tribute to overall success at both the site level and the programmatic level. However, each site is at a different R01790 safety requirements as closure proceeds. and stage of development of the closure planning docu- bitmapped image with site and CMA staff, the commit- uneditable In discussions ments. Therefore, it is difficult to compare the plans. replacedlearned about the strong commitment to safety by but all type tee and editable please check for keying typos the process, and the committee lauds Based on a review of existing planning documents, those involved in the key elements of site-specific closure planning are this commitment. In reviewing many documents, the discussed below and shown in Figure 2-1. committee has seen safety integrated throughout top level documents, including the CMA Strategic Plan and the “Program Manager for Chemical Stockpile safety Elimination (PMCSE) Chemical Disposal Facility The committee believes that the plan for each phase Closure Strategy,” as well as in specific work proce- of work should incorporate industry-wide best practices dures (O’Donnell, 2008). The committee recognizes to achieve the Army’s safety objectives. As the work that the CMA’s strategy of in situ decontamination toward closure progresses and a facility transitions followed by mass demolition will reduce hazards as from chemical agent demilitarization operations to decontamination activities progress, but that changing decommissioning to decontamination and ultimately hazards related to new and different work processes demolition, the competencies and skill sets needed will result. to safely accomplish the work will change. During Project team members responsible for the execution demilitarization, most activities are standardized and of the work should be trained to recognize situations repetitive. As sites progress into closure activities, the in which something unexpected is occurring, and they types of work hazards will change. The level of per- should have the authority to initiate work stoppages sonal protective equipment necessary will decrease as in these situations. Further, team members should be closure progresses and the facility is decontaminated. prepared to expect an investigation or decision by the The potential hazards will change from agent-related project manager before proceeding. exposures to hazards associated with deconstruction.

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 OVERALL CLOSURE PLANNING FOR BASELINE FACILITIES Personnel areas of depots that are outside the chemical disposal facilities, corrective action, and related disposal activi- There is an active program in place, fashioned ties, but those issues are for the most part beyond the after one used at JACADS, to retain and maintain the scope of the task for this committee. As a site executes well-trained workforce with bonus incentives. As the its deconstruction and demolition plans, there is the facilities transition from demilitarization operations potential for additional truck traffic. There may also to closure, there are likely to be personnel challenges, be concerns about management of noise or dust. It is including losses of talented, competent employees important that the local government and community at before the completion of closure activities. There will large be informed of and engaged in preparing for these also be a need to retrain current employees to work in possibilities before they occur. a less production-focused, more construction-focused The committee believes that in some cases the public environment. Training of personnel (new or existing) may express concerns over the disposition of materi- who will be involved in the progression of activities als that may have been exposed to chemical agent. On from demilitarization to closure is essential. Further- the one hand, where the public believes waste materi- more, management of workforce needs and the poten- als contain agent or other highly toxic substances, tial loss of jobs will likely be a key issue in surrounding they may advocate additional treatment and/or more communities. restrictive disposal practices. On the other hand, where the public believes that materials have been shown to Finding 2-4. There are numerous personnel challenges be clean, the committee, based on years of observing associated with the transition of the baseline chemi- recycling activities, judges that the public is likely to cal agent disposal facility sites from demilitarization support reuse or recycling. operations to closure that include retention of person- In general, given the anticipated future uses of the nel; retraining and matching of skills and competencies chemical agent disposal facility sites and the absence of existing workers to new work; and integration of of groundwater contamination associated with demili- new personnel into the site closure process. Personnel tarization (USACHPPM, 1999), host communities retention and training, and the management of changing are expected to accept closure standards based upon personnel, are critical to program success. industrial/commercial future uses. At Umatilla, the Confederated Tribes of the Umatilla Recommendation 2-4. The management at each base- Indian Reservation (CTUIR) have made their position line chemical agent disposal facility must develop a on closure standards clear. The CTUIR assert their personnel planning document that addresses retention rights under the Treaty of 1855 to the customary use of personnel; matches the skills and competencies of of ceded lands and their resources, including the entire the current workforce to future work; retrains current Umatilla Chemical Depot (UCD). The tribes insist personnel to the new work processes; and integrates that the U.S. government “protect the interests of the new personnel to facility safety procedures. CTUIR by ensuring that lands, water, soil, air, biologi- cal, and cultural resources are clean and safe to use” Public Participation (CTUIR, 2008, p. 1). In general, CTUIR believes that the land should be restored by the Army to its 1855 In general, environmental issues associated with condition, so as to support hunting, gathering, fishing, closure are not a major concern of the communities and other cultural practices, and to protect the area’s surrounding the demilitarization facilities addressed in water resources.3 The proposed reuse plan for the UCD this report.2 However, the communities are concerned sets aside large tracts for management by the U.S. Fish that the end of demilitarization operations will lead and Wildlife Service and the Oregon National Guard, to workforce layoffs and associated economic conse- quences. Furthermore, the communities are to varying 3Tribal governments, in addition to their possible role as regula - degrees concerned about issues related to cleanup of tors, have a distinct decision-making role to play as derived from rights that are specified in treaties with the U.S. government. In 2Committee members visited and met with members of local some instances, these treaty rights may result in legally binding communities at Deseret and Anniston, monitored news reports obligations on the part of the U.S. government that must be ac- from all four sites, and discussed community input with Army and counted for during the conduct of federal facility cleanup activities contractor personnel. (FFERDC, 1996).

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES and the tribes expect access to those lands—although sure and recommends an active program to address use of the National Guard’s ranges may be limited in public concerns by promoting public awareness and both time and space. participation. However, the actual chemical agent disposal facil- ity is proposed for transfer to the Port of Umatilla for regulatory drivers and Work Planning for industrial use, and the tribes acknowledge that this area, compliance largely paved, should be remediated only to industrial standards.4 The CTUIR believes that cleanup resources Each site will be subject to state, federal, and local could be better spent sampling and, if necessary, reme- regulations, including, but not limited to, the Clean diating open lands it believes to be contaminated by Air Act and the Resource Conservation and Recovery the deposition of emissions from the demilitarization Act. There may be state-specific requirements, such incinerators. The tribes have submitted a sampling and as the Uniform Environmental Covenants Act in Ala- analysis plan in support of that goal (CTUIR, 2009). bama and Utah, that each site will need to integrate They view investigation and cleanup of surrounding into site-specific closure plans. Each site will also UCD property as an essential part of the chemical agent need to consider the appropriate regulatory end point disposal facility closure. as required under federal and/or state laws and how While public concerns over closure, beyond those of best to meet those end points. Based on its experience, the committee believes that risk-based5 approaches the CTUIR, have not yet crystallized, it is essential that the Army and its contractors remain prepared for other work best when the future site use and regulatory end issues to arise and continue their extensive community points are integrated with the closure planning. Further, relations activities at all four baseline facilities. Any decommissioning plans that address the end of life mishap associated with closure would immediately of systems/equipment will need to be developed and heighten public concern at these sites and prompt conducted in accordance with the Resource Conserva- more intense oversight. In the committee’s earlier letter tion and Recovery Act regulatory requirements. Issues report (Appendix A), it recommended that the Army associated with regulatory requirements and compli- work with the Utah Citizens Advisory Commission ance are further discussed in Chapter 5. (CAC) “to establish a continuing, constructive public involvement [program] between the end of demilitar- FuTure use aNd closure eNd-use visioN ization and formal closure.” Since then the Army has explained that it intends to extend the life of the CACs In order to effectively conduct closure, knowledge of through closure. The committee is pleased with this the future use of the site (or area) is necessary. Indeed, decision and hopes that the public members of those the future use and end use must drive the plan, and the bodies will continue their efforts after completion of plan must be executed in a way that allows realiza- their original mission: oversight of demilitarization. tion of the end use. Questions such as whether storage igloos or other structures will be reused, or whether or Finding 2-5. At each of the four baseline chemical not the real property will continue as part of military agent disposal facility sites, the Army has created a suc- operations, should be primary factors in the develop- cessful community relations and public participation ment of site-specific closure plans. program through its Citizens Advisory Commission, In addition, the Army needs to consider the assets Outreach Office, and other forums. The Army plans to that exist at a facility as well as the materials, waste, continue these essential activities through closure. residues, and other media that exist or will be generated as part of the closure process. To be efficient, planning Recommendation 2-5. The committee supports the for reuse/recycling of assets, materials, waste, and A rmy continuing public involvement during clo - 4Question-and-answer 5 “Risk-based” session with Rodney Skeen, Manager, closure means closure of a site to a level that re- Engineering and Modeling Program, Department of Science and sults in minimal levels of risk to human health and the environment Engineering, Confederated Tribes of the Umatilla Indian Reserva- so as to require no further action or monitoring on the part of the tion; and Todd Kimmell and Lenny Siegel, committee members, responsible party nor any notice of hazardous waste management May 26, 2010. on the deed to the property.

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 OVERALL CLOSURE PLANNING FOR BASELINE FACILITIES residues should be integrated into the overall closure in the event that the documented site history proves to planning process. be incomplete or inaccurate. Finally, if cleanup is required, knowledge of future site use can be employed to plan for risk-based cleanup selection of decontamination methods that will ensure protection of those who will have access to the site in the future and will be cost-effective. Selection of decontamination methods includes preparation of an equipment decontamination plan and identification of the appropriate methods to be used for documentation of site history decontamination, procedures to document decontami- In order to prepare the facility for decommission- nation, and the future uses planned for the equipment ing, dismantling, and demolition to achieve end-use and the appropriateness of the decontamination criteria requirements and to complete the work without inci- employed. Decontamination methods and monitoring dent or injury, it is essential to review the history of are explored further in Chapter 6. operational practices. This is necessary to establish engineering controls before initiating activities within Decontamination a previously contaminated area, to determine surveys to be done to verify existing conditions—including Decontamination is the removal of hazardous sub- occluded space surveys—and other operational activi- stances (agent and non-agent) that have been deposited ties such as decontamination of equipment and removal or absorbed on internal and/or external surfaces at a of liquids. A thorough review of agent and non-agent facility by use of air-washing, chemical, mechanical, contamination history and lessons learned information and/or thermal methods. In order to determine the obtained from interviews with site personnel will help most effective method for decontamination, the plan facilitate safe closure activities. should consider the documented site operational his- The committee has been told by CMA and facility tory, worker and community safety, regulatory require- staff that there is detailed operational information on ments, and waste management (whether disposal or contamination history for each facility, and due to the reuse/recycling). stringency of the operational controls, there is good information on site history. Occluded Space Survey In addition to understanding documented site his- tory, lessons learned from other sites further advanced The occluded space survey is designed to identify in the closure process provide important information locations where agent liquid may have accumulated to to understand regarding program history. See Chapter ensure effective decontamination. Successful comple- 4 for a discussion of lessons learned. tion of the occluded space survey is key to the mass demolition strategy. A detailed discussion is found in Finding 2-6. An accurate site history is important to Chapter 6. safe and environmentally sound closure. Site-specific records on spills and releases, detailed operational site demolition and equipment/debris removal contamination historical information, and program- matic lessons learned are important to understanding Prior to mass demolition, equipment that has been a site’s history. determined to be contaminated must be dismantled and decontaminated. Similarly, equipment or materials Recommendation 2-6a. The programmatic closure areas that are intended to be reused or redeployed must plan and the site-specific plans should ensure that all be identified and decontaminated. If decontamination available information on site history as well as lessons of any item in the area, such as equipment, equipment learned are incorporated into closure planning. support, or concrete floor, is not possible, the item should be removed and managed as hazardous waste. Recommendation 2-6b. Even though a great amount Subsequent to dismantling, decontamination, and con- of site history is available, each site should develop a firmatory monitoring, the facility/structure is prepared site contingency plan to deal with finding agent con- for mass demolition by deactivating all utilities to the tamination where testing does not indicate its presence area to be decontaminated and isolating the utilities that

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0 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES may be located in the utility corridor. Demolition refers control. This is also a good opportunity to reflect on to the mechanical removal of structures with conven- health, safety, and security issues. tional construction equipment and industrial demolition Finding 2-7. It was not evident to the committee techniques. Planning documents that address mass demolition will need to consider dust suppression, that a project quality assurance plan for closure was noise, and traffic studies and plans. As discussed above, developed for every baseline chemical agent disposal the Army’s preference is to move toward mass demoli- facility site. tion in order to improve safe working conditions and Recommendation 2-7. The Army should create a to minimize manual labor. project management quality assurance plan for each baseline chemical agent disposal facility site, describ- cost and schedule ing the project organization, accountability, and lines of Integrated cost and schedule should be tracked at the responsibilities for closure project execution for routine program level. It is important to forecast and track cost and unforeseen work situations. and schedule against the project schedule and allotted budget. The committee heard from Army and contrac- reFereNces tor staff that they currently use project tracking tools CMA (U.S. Army Chemical Materials Agency). 2009. Strategic Plan Fiscal such as earned value to measure progress against scope, years 2010–2015 Revision 0. Aberdeen Proving Ground—Edgewood schedule, and budget.6 Earned value is a commonly Area, MD. Washington, D.C.: Chemical Materials Agency. accepted project management tool. CTUIR (Confederated Tribes of the Umatilla Indian Reservation). 2009. Annual Report. Pendleton, OR: Confederated Tribes of the Umatilla Indian Reservation. closure Project management and closure Team CTUIR. 2008. Annual Report. Pendleton, OR: Confederated Tribes of the Umatilla Indian Reservation The experience of committee members is that for FFERDC (Federal Facilities Environmental Restoration Dialogue Com- mittee). 1996. The Final Report of the Federal Facilities Environmental successful project execution, the project management Restoration Dialogue Committee: Consensus Precipices and Recom- quality assurance document, in addition to the project mendations for Improving Federal Facilities Cleanup. Available online organization chart, should clearly indicate the roles at http://epa.gov/fedfac/fferdc.htm. Last accessed August 4, 2010. O’Donnell, B. 2008. Memorandum: Program Manager for Chemical Stock - and responsibilities of the project team members. The pile Elimination Chemical Disposal Facility Closure Strategy. Closure decommissioning work packages should contain steps Compliance and Assessments, Chemical Materials Agency. such as daily (or as necessary) project briefing before USACHPPM (U.S. Army Center for Health Promotion and Preventive starting a task and hold points for effective project Medicine). 1999. Derivation of Health-based Environmental Screening Levels for Chemical Warfare Agents, A Technical Evaluation. Aberdeen Proving Ground, MD: U.S. Army CHPPM. 6 Personal communication between Carla Heck, Project Manager, URS, and the committee, January 27, 2010.