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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities 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: An overall site-specific closure plan that describes, at a high level, the closure strategy for the site, consistent with any articulated CMA direction; A decommissioning plan that describes the process to take the facility, including units and equipment out of service; 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 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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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities TABLE 2-1 Status of Closure Planning Documentation for Each Baseline Chemical Agent Disposal Facility Planning Component Anniston Chemical Agent Disposal Facility (ANCDF) Pine Bluff Chemical Agent Disposal Facility (PBCDF) Tooele Chemical Agent Disposal Facility (TOCDF) Chemical Agent Munitions Disposal System (CAMDS) Umatilla Chemical Agent Disposal Facility (UMCDF) Site Facility Closure Plan (FCP) The RCRA FCP has been submitted, approval expected in January 2011. Final plan will follow this approval, estimated for March 2011. The Facility Closure Plan (PB-PL-110) was issued in February 2010. The FCP is scheduled for issuance in September 2010. Scope is captured in the Facility Decontamination and Disposition Plan (FDDP) issued in March 2010. The FCP is included in the Decommissioning Plan (UM-PL-108) issued in May 2010. Closure Planning Implementation Strategy (CPIS) The ANCDF CPIS was issued in November 2008. The CPIS is included in the FCP (PB-PL-110) and in the Decommissioning Plan (PB-PL-108) issued in February 2010. The CPIS is included in the FCP that is scheduled for issue September 2010 and in the Decommissioning Plan (scheduled for 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. Scope is captured in the FDDP and was issued in March 2010. The CPIS is included in the Decommissioning Plan (UM-PL-108) issued in May 2010. Decommissioning Plan The ANCDF Decommissioning Plan is included in the Facility Disposition Plan issued on March 29, 2010. The PBCDF Decommissioning Plan (PB-PL-108) was issued in February 2010. The Decommissioning Plan is part of the FDDP. The FDDP is scheduled for issuance in August 2010. This scope is captured in the FDDP issued in March 2010. The Decommissioning Plan (UM-PL-108), rev. 1, was issued in May 2010. Decontamination Plan ANCDF is updating the Decontamination Plan that was included in the Permit modification that was submitted to ADEM for review on April 29, 2010. Approval is expected by March 2011. The Decontamination Plan (PB-PL-118) was issued on February 12, 2010. The Decontamination Plan is part of the FDDP. The FDDP is scheduled for issuance in July 2010. This scope is captured in the FDDP issues in March 2010. Content on decontamination was included in the RCRA FCP. ODEQ approval of the FCP is expected in September 2010. Demolition Plan In lieu of a separate distinct Demolition Plan ANCDF will provide detailed demolition scope of work in the Closure Work Proposal and Engineering Work Packages for the areas to be demolished along with an Estimate and a Request 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. The Demolition Plan will be addressed in the Final Site Decontamination Decommissioning and Demolition (DDD) Package (DDD-16-040). Issuance of this plan is estimated in January 2011. The TOCDF Demolition Plan is part of the Demolition and Disposition Plan. Issuance on this plan is estimated in September 2010. The CAMDS Demolition Plan is being developed with the TOCDF Demolition and Disposition Plan and is scheduled to be issued in September 2010. Content on demolition was included in the RCRA FCP. This plan is currently under review by ODEQ. (PMR-09-006). Approval is expected in September 2010.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Planning Component Anniston Chemical Agent Disposal Facility (ANCDF) Pine Bluff Chemical Agent Disposal Facility (PBCDF) Tooele Chemical Agent Disposal Facility (TOCDF) Chemical Agent Munitions Disposal System (CAMDS) Umatilla Chemical Agent Disposal Facility (UMCDF) Regulatory Closure Plan The RCRA Closure Plan was submitted to ADEM as part of the Permit modification submitted to ADEM in April 2010. Approval is expected in January 2011. This plan is included in the FCP and in the Decommissioning Plan (PB-PL-108) that were issued in February 2010. The RCRA Closure Plan is scheduled for submittal in June 2010. Approval is expected in December 2010. The CAMDS RCRA Closure plan was approved by DSHW on February 25, 2010. The RCRA Closure Plan update has been submitted to ODEQ (PMR-09-006). Approval is expected in September 2010. Programmatic Documents Review (TOCDF) The TOCDF programmatic documents have been made part of the site library and are continuously used for development of closure work packages. PBCDF continually evaluates Closure Lessons Learned during DDD package development. Programmatic documents are addressed in the Facility Closure Plan (PB-PL-110), as 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. This review task is being performed as part of the development of the Facility Closure Plan. This is being performed as part of the TOCDF effort. There were site-specific documents developed for CAMDS modeled from the TOCDF programmatic documents that are being used internally. Because of the similarities between the TOCDF and UMCDF, Umatilla conducted an indepth review of TOCDF programmatic documents and has developed work plans for closure making extensive use of these documents. Personnel Planning A Transition De-staffing Plan is planned to be incorporated into the Closure Integrated Master Schedule in September 2010. De-staffing plans are under development at PBCDF. Issuance is anticipated in August 2010. De-staffing plans are being addressed via a Human Resources initiative. A Project Management Plan has been approved for this 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. De-staffing planning for CAMDS is part of the overall TOCDF planning effort. The UMCDF De-staffing Plan has been drafted. Issuance is expected in July 2010. A Transition Plan is in draft; issuance is expected in July 2010. Closure Safety Plan (CSP) ANCDF will use the existing plan with appropriate revisions. Revision is scheduled for March 2011. The CSP is addressed under the System Safety Implementation Plan Volume II (PB-PL-025), the Occupational Health and Hygiene Plan Volume II (PB-PL-027), and the Accident Prevention Plan Volume II (PB-PL-039). Closure safety plans will be summarized in the Facility Closure Plan, expected for issuance in September 2010. Safety planning for CAMDS Closure utilizes safety plans and procedures incorporated from TOCDF. UMCDF will use the existing plan, revised to address unique closure conditions. Issuance of the revision is expected in October 2010.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Planning Component Anniston Chemical Agent Disposal Facility (ANCDF) Pine Bluff Chemical Agent Disposal Facility (PBCDF) Tooele Chemical Agent Disposal Facility (TOCDF) Chemical Agent Munitions Disposal System (CAMDS) Umatilla Chemical Agent Disposal Facility (UMCDF) Public Participation Plan ANCDF encourages public participation in round table meetings, to be held in the community, with the goal of discussing the impact of ANCDF closure on the employees and the community in general. Public participation in PBCDF closure planning is addressed in the Facility Closure Plan (PB-PL-110). This plan is scheduled to be issued June 25, 2010. Public participation is being addressed as part of the human resources initiative. A Project Management Plan has been approved for this effort and a schedule is being developed for issue by September 2010. Also closure discussions took place with the Citizens Advisory Commission in March and will be addressed again in the Fall of 2010. Public participation for CAMDS is being addressed along with the TOCDF effort. UMCDF does not plan to develop a self-standing public participation plan. Continued community participation in both Land Reuse Authority coordination meetings and in routine Citizens Advisory Commission meetings will form the basis for public participation in UMCDF closure plans. 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 Planning Component Anniston Chemical Agent Disposal Facility (ANCDF) Pine Bluff Chemical Agent Disposal Facility (PBCDF) Tooele Chemical Agent Disposal Facility (TOCDF) Chemical Agent Munitions Disposal System (CAMDS) Umatilla Chemical Agent Disposal Facility (UMCDF) Site Facility Closure Plan (FCP) Closure Planning Implementation Strategy (CPIS) Decommissioning Plan Decontamination Plan Demolition Plan Regulatory Closure Plan Programmatic Documents Review (TOCDF) Personnel Planning Closure Safety Plan (CSP) Public Participation 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 organization’s view of success is the establishment of key parameters and metrics. The management of the closure of the four baseline facilities is a complicated task requiring diverse teams at multiple sites around the country to advance the program in a way that ensures the safety and protection of workers and communities. The establishment of key parameters and metrics sends a message from the CMA headquarters staff about what the program leadership feels is critical to the success of the facility closure phase of the program. Key parameters and metrics are also an important mechanism to unify and integrate approaches across the four baseline facilities. Initially, CMA envisaged a programmatic plan developed for the Tooele Chemical Agent Disposal Facility that would serve as the basis for plans for the other facilities. This plan was never completed when it was determined that the Tooele Chemical Agent Disposal Facility would not, as previously discussed, be the first facility to undergo closure.1 Parts of the plan do exist and serve as a basis for planning as deemed appropriate by each facility. The closure managers and their senior staffs for the baseline facilities coordinate their activities both with a weekly conference call and regular in-person coordinating meetings. It appears to the committee that the senior closure managers are very competent in coordinating and carrying out the planning activities. However, each facility is developing its plans to meet its particular situation. This is to be expected because of the particular situations at each facility. But it would appear that some guidance from senior CMA management in policy-critical areas such as the unventilated monitoring test (see Chapter 6) would promote uniformity of approach and execution of planning and, as a result, the closure operations. The committee believes that at a minimum the programmatic plan should include goals and metrics, Army policy, expectations on safety and regulatory requirements, and quality assurance. Finding 2-1. The closure managers and their teams appear to be highly competent and to coordinate their needs and approaches well through frequent contacts and meetings. Each site is taking its own approach to the planning activities because of differing end use, facility, and regulatory situations. There does not appear to be sufficient senior policy guidance in key issues such as the critical unventilated monitoring test. Recommendation 2-1. Senior Chemical Materials Agency management should provide policy guidance for closure in critical areas such as the unventilated monitoring test to ensure that these critical activities are planned and executed in a uniform manner across all facilities. In addition to parameters and metrics, it is desirable and appropriate to establish measurable goals, or “targets.” Clearly articulated goals send strong messages from the CMA leadership and may also be used to drive continuous improvement. The committee discusses parameters in Chapter 3. Finding 2-2. The Chemical Materials Agency’s Strategic Plan for closure of baseline chemical agent disposal facilities identifies a number of parameters and metrics, but it does not articulate measurable goals (targets) against which progress will be tracked. Goals drive behavior and performance. For example, the Army measures 12-month rolling recordable injury rates. However, it is not clear to the committee whether the Army establishes a target for reduction of the recordable injury rate. Similarly, the Army measures schedule slippage, but it is not clear whether it wants to reduce schedule slippage by a certain amount over some period of time. Recommendation 2-2a. Parameters and the associated metrics for successful closure of the Army’s baseline chemical agent disposal facilities should be established at the programmatic (headquarters) and site (project) levels of the chemical stockpile disposal program administered by the Chemical Materials Agency. While the strategic plan addresses key parameters that will be tracked at the headquarters level, the committee recommends that parameters be established at the project level that are consistent with the strategic parameters. These parameters should be tracked and measured at the project level at each of the baseline facilities. Recommendation 2-2b. The Army should develop specific and quantifiable targets for parameters important to the overall chemical stockpile disposal program and for which the Chemical Materials Agency headquarters wants to drive improvement. Essential Program Elements and Army Policy Programmatic closure planning must provide the foundation for the development of site-specific closure plans, ensuring consistency in approach and establish- 1 Personal communication between Rafael Gramatges, Specialty Group Manager, URS, and Peter Lederman, committee chair, June 16, 2010.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities ing requirements of those critical elements that should be evaluated and integrated into every site specific plan. Further, any specific policies or strategies that the Army would like to see executed in site-specific closure plans should be articulated in programmatic planning. The CMA’s “Strategic Plan: Fiscal Years 2010–2015,” November 2009, describes the vision and mission of the Programmatic Closure Planning process (CMA, 2009). This document articulates a vision that “Creates a safer tomorrow by making chemical weapons history.” It further articulates the strategic processes that the Army will use to develop its programmatic approach as well as establishing management systems to measure progress toward the CMA vision and mission. A December 17, 2008, Memorandum from the Chief, Secondary Waste, Closure Compliance and Assessment, titled a “Program Manager for Chemical Stockpile Elimination (PMCSE) Chemical Disposal Facility Closure Strategy,” describes the PMCSE’s vision for closure (O’Donnell, 2008). This strategy emphasizes the importance of safety and seeks also to minimize cost and schedule by encouraging mass demolition to the greatest extent possible. Mass demolition enables use of mechanical deconstruction employing conventional construction equipment to remove structures and minimizes human actions required for deconstruction. The memo states, “Put in simplest form, the strategy uses in situ decontamination followed by confirmatory head-space monitoring as a gateway to mass demolition of the facility” (O’Donnell, 2008). Finding 2-3a. The Chemical Material Agency’s (CMA’s) “Strategic Plan: Fiscal Years 2010–2015,” November 2009, describes the Army’s vision and mission for the programmatic closure planning process. This document also articulates the key parameters and metrics that the Army will measure and evaluate at the headquarters level. These key parameters include safety, schedule, and cost. The CMA’s “Policy Statement #21, Strategic Baseline Accountability,” March 8, 2010, sets forth the Army’s expectations on accountability and reporting of key parameters to CMA leadership. Finding 2-3b. The Chemical Materials Agency has placed high importance on implementing mass demolition, a strategy that has positive implications for safety, cost, environmental impact, and scheduled completion of the project. Finding 2-3c. Waste characterization (both agent and non-agent), decontamination, and associated confirmation monitoring are critical to the safe execution of the Chemical Materials Agency strategy for closure. Recommendation 2-3. The Chemical Materials Agency’s closure strategy to emphasize mass demolition should continue to be actively pursued. However, this strategy should be supported in planning and execution by testing and monitoring necessary for successful execution of the strategy. Waste characterization is discussed more fully in Chapters 5 and 6. The Army is proposing to decontaminate the buildings by first removing some of the equipment, then checking for agent contamination, and, as necessary, decontaminating surfaces using standard caustic decontamination solutions (O’Donnell, 2008). This process will be followed by locating occluded spaces where agent could be sequestered, and then opening and decontaminating those spaces. Finally, ventilated and unventilated monitoring tests, which are discussed in detail in Chapter 6, will be performed. FACILITY-SPECIFIC CLOSURE PLANNING The major planning components that the committee believes are necessary to execute a safe and successful site closure are listed in Figure 2-1. Starting with the end use in mind, each facility will need to develop: an overall facility closure plan, decommissioning plans, decontamination plans, demolition plans, and materials and waste disposition plans. Each of these “phase” plans should incorporate safety and health, personnel planning (retention, skill sets, etc.), public participation, regulatory requirements, and any requirements specific to the Army. Program parameters and metrics should be established and cascaded down from CMA to the facilities. Targets should be established and the metrics monitored for achievement and updating where the Army seeks to drive continuous improvement. Each facility should report performance against parameters and any established goals back to CMA. Lessons learned should be continually evaluated and incorporated into all components of site closure planning. Incorporating lessons learned from prior facility closures, such as the Johnston Atoll Chemical Agent Disposal System, is critical to continuous improvement and ensuring overall success 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 FIGURE 2-1 Site-specific closure planning. Each of the four baseline facilities is in the process of developing key site-specific documents that will contribute to overall success at both the site level and the programmatic level. However, each site is at a different stage of development of the closure planning documents. Therefore, it is difficult to compare the plans. Based on a review of existing planning documents, the key elements of site-specific closure planning are discussed below and shown in Figure 2-1. Safety The committee believes that the plan for each phase of work should incorporate industry-wide best practices to achieve the Army’s safety objectives. As the work toward closure progresses and a facility transitions from chemical agent demilitarization operations to decommissioning to decontamination and ultimately demolition, the competencies and skill sets needed to safely accomplish the work will change. During demilitarization, most activities are standardized and repetitive. As sites progress into closure activities, the types of work hazards will change. The level of personal protective equipment necessary will decrease as closure progresses and the facility is decontaminated. The potential hazards will change from agent-related exposures to hazards associated with deconstruction. Further, workers who will be involved in these different phases of closure need to understand the different risks that will be encountered and the different health and safety requirements as closure proceeds. In discussions with site and CMA staff, the committee learned about the strong commitment to safety by those involved in the process, and the committee lauds this commitment. In reviewing many documents, the committee has seen safety integrated throughout top level documents, including the CMA Strategic Plan and the “Program Manager for Chemical Stockpile Elimination (PMCSE) Chemical Disposal Facility Closure Strategy,” as well as in specific work procedures (O’Donnell, 2008). The committee recognizes that the CMA’s strategy of in situ decontamination followed by mass demolition will reduce hazards as decontamination activities progress, but that changing hazards related to new and different work processes will result. Project team members responsible for the execution of the work should be trained to recognize situations in which something unexpected is occurring, and they should have the authority to initiate work stoppages in these situations. Further, team members should be prepared to expect an investigation or decision by the project manager before proceeding.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities Personnel There is an active program in place, fashioned after one used at JACADS, to retain and maintain the well-trained workforce with bonus incentives. As the facilities transition from demilitarization operations to closure, there are likely to be personnel challenges, including losses of talented, competent employees before the completion of closure activities. There will also be a need to retrain current employees to work in a less production-focused, more construction-focused environment. Training of personnel (new or existing) who will be involved in the progression of activities from demilitarization to closure is essential. Furthermore, management of workforce needs and the potential loss of jobs will likely be a key issue in surrounding communities. Finding 2-4. There are numerous personnel challenges associated with the transition of the baseline chemical agent disposal facility sites from demilitarization operations to closure that include retention of personnel; retraining and matching of skills and competencies of existing workers to new work; and integration of new personnel into the site closure process. Personnel retention and training, and the management of changing personnel, are critical to program success. Recommendation 2-4. The management at each baseline chemical agent disposal facility must develop a personnel planning document that addresses retention of personnel; matches the skills and competencies of the current workforce to future work; retrains current personnel to the new work processes; and integrates new personnel to facility safety procedures. Public Participation In general, environmental issues associated with closure are not a major concern of the communities surrounding the demilitarization facilities addressed in this report.2 However, the communities are concerned that the end of demilitarization operations will lead to workforce layoffs and associated economic consequences. Furthermore, the communities are to varying degrees concerned about issues related to cleanup of areas of depots that are outside the chemical disposal facilities, corrective action, and related disposal activities, but those issues are for the most part beyond the scope of the task for this committee. As a site executes its deconstruction and demolition plans, there is the potential for additional truck traffic. There may also be concerns about management of noise or dust. It is important that the local government and community at large be informed of and engaged in preparing for these possibilities before they occur. The committee believes that in some cases the public may express concerns over the disposition of materials that may have been exposed to chemical agent. On the one hand, where the public believes waste materials contain agent or other highly toxic substances, they may advocate additional treatment and/or more restrictive disposal practices. On the other hand, where the public believes that materials have been shown to be clean, the committee, based on years of observing recycling activities, judges that the public is likely to support reuse or recycling. In general, given the anticipated future uses of the chemical agent disposal facility sites and the absence of groundwater contamination associated with demilitarization (USACHPPM, 1999), host communities are expected to accept closure standards based upon industrial/commercial future uses. At Umatilla, the Confederated Tribes of the Umatilla Indian Reservation (CTUIR) have made their position on closure standards clear. The CTUIR assert their rights under the Treaty of 1855 to the customary use of ceded lands and their resources, including the entire Umatilla Chemical Depot (UCD). The tribes insist that the U.S. government “protect the interests of the CTUIR by ensuring that lands, water, soil, air, biological, and cultural resources are clean and safe to use” (CTUIR, 2008, p. 1). In general, CTUIR believes that the land should be restored by the Army to its 1855 condition, so as to support hunting, gathering, fishing, and other cultural practices, and to protect the area’s water resources.3 The proposed reuse plan for the UCD sets aside large tracts for management by the U.S. Fish and Wildlife Service and the Oregon National Guard, 2 Committee members visited and met with members of local communities at Deseret and Anniston, monitored news reports from all four sites, and discussed community input with Army and contractor personnel. 3 Tribal governments, in addition to their possible role as regulators, have a distinct decision-making role to play as derived from rights that are specified in treaties with the U.S. government. In some instances, these treaty rights may result in legally binding obligations on the part of the U.S. government that must be accounted for during the conduct of federal facility cleanup activities (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 use of the National Guard’s ranges may be limited in both time and space. However, the actual chemical agent disposal facility is proposed for transfer to the Port of Umatilla for industrial use, and the tribes acknowledge that this area, largely paved, should be remediated only to industrial standards.4 The CTUIR believes that cleanup resources could be better spent sampling and, if necessary, remediating open lands it believes to be contaminated by the deposition of emissions from the demilitarization incinerators. The tribes have submitted a sampling and analysis plan in support of that goal (CTUIR, 2009). They view investigation and cleanup of surrounding UCD property as an essential part of the chemical agent disposal facility closure. While public concerns over closure, beyond those of the CTUIR, have not yet crystallized, it is essential that the Army and its contractors remain prepared for other issues to arise and continue their extensive community relations activities at all four baseline facilities. Any mishap associated with closure would immediately heighten public concern at these sites and prompt more intense oversight. In the committee’s earlier letter report (Appendix A), it recommended that the Army work with the Utah Citizens Advisory Commission (CAC) “to establish a continuing, constructive public involvement [program] between the end of demilitarization and formal closure.” Since then the Army has explained that it intends to extend the life of the CACs through closure. The committee is pleased with this decision and hopes that the public members of those bodies will continue their efforts after completion of their original mission: oversight of demilitarization. Finding 2-5. At each of the four baseline chemical agent disposal facility sites, the Army has created a successful community relations and public participation program through its Citizens Advisory Commission, Outreach Office, and other forums. The Army plans to continue these essential activities through closure. Recommendation 2-5. The committee supports the Army continuing public involvement during closure and recommends an active program to address public concerns by promoting public awareness and participation. Regulatory Drivers and Work Planning for Compliance Each site will be subject to state, federal, and local regulations, including, but not limited to, the Clean Air Act and the Resource Conservation and Recovery Act. There may be state-specific requirements, such as the Uniform Environmental Covenants Act in Alabama and Utah, that each site will need to integrate into site-specific closure plans. Each site will also need to consider the appropriate regulatory end point as required under federal and/or state laws and how best to meet those end points. Based on its experience, the committee believes that risk-based5 approaches work best when the future site use and regulatory end points are integrated with the closure planning. Further, decommissioning plans that address the end of life of systems/equipment will need to be developed and conducted in accordance with the Resource Conservation and Recovery Act regulatory requirements. Issues associated with regulatory requirements and compliance are further discussed in Chapter 5. FUTURE USE AND CLOSURE END-USE VISION In order to effectively conduct closure, knowledge of the future use of the site (or area) is necessary. Indeed, the future use and end use must drive the plan, and the plan must be executed in a way that allows realization of the end use. Questions such as whether storage igloos or other structures will be reused, or whether or not the real property will continue as part of military operations, should be primary factors in the development of site-specific closure plans. In addition, the Army needs to consider the assets that exist at a facility as well as the materials, waste, residues, and other media that exist or will be generated as part of the closure process. To be efficient, planning for reuse/recycling of assets, materials, waste, and 4 Question-and-answer session with Rodney Skeen, Manager, Engineering and Modeling Program, Department of Science and Engineering, Confederated Tribes of the Umatilla Indian Reservation; and Todd Kimmell and Lenny Siegel, committee members, May 26, 2010. 5 “Risk-based” closure means closure of a site to a level that results in minimal levels of risk to human health and the environment so as to require no further action or monitoring on the part of the responsible party nor any notice of hazardous waste management on the deed to the property.
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities residues should be integrated into the overall closure planning process. Finally, if cleanup is required, knowledge of future site use can be employed to plan for risk-based cleanup that will ensure protection of those who will have access to the site in the future and will be cost-effective. Documentation of Site History In order to prepare the facility for decommissioning, dismantling, and demolition to achieve end-use requirements and to complete the work without incident or injury, it is essential to review the history of operational practices. This is necessary to establish engineering controls before initiating activities within a previously contaminated area, to determine surveys to be done to verify existing conditions—including occluded space surveys—and other operational activities such as decontamination of equipment and removal of liquids. A thorough review of agent and non-agent contamination history and lessons learned information obtained from interviews with site personnel will help facilitate safe closure activities. The committee has been told by CMA and facility staff that there is detailed operational information on contamination history for each facility, and due to the stringency of the operational controls, there is good information on site history. In addition to understanding documented site history, lessons learned from other sites further advanced in the closure process provide important information to understand regarding program history. See Chapter 4 for a discussion of lessons learned. Finding 2-6. An accurate site history is important to safe and environmentally sound closure. Site-specific records on spills and releases, detailed operational site contamination historical information, and programmatic lessons learned are important to understanding a site’s history. Recommendation 2-6a. The programmatic closure plan and the site-specific plans should ensure that all available information on site history as well as lessons learned are incorporated into closure planning. Recommendation 2-6b. Even though a great amount of site history is available, each site should develop a site contingency plan to deal with finding agent contamination where testing does not indicate its presence in the event that the documented site history proves to be incomplete or inaccurate. Selection of Decontamination Methods Selection of decontamination methods includes preparation of an equipment decontamination plan and identification of the appropriate methods to be used for decontamination, procedures to document decontamination, and the future uses planned for the equipment and the appropriateness of the decontamination criteria employed. Decontamination methods and monitoring are explored further in Chapter 6. Decontamination Decontamination is the removal of hazardous substances (agent and non-agent) that have been deposited or absorbed on internal and/or external surfaces at a facility by use of air-washing, chemical, mechanical, and/or thermal methods. In order to determine the most effective method for decontamination, the plan should consider the documented site operational history, worker and community safety, regulatory requirements, and waste management (whether disposal or reuse/recycling). Occluded Space Survey The occluded space survey is designed to identify locations where agent liquid may have accumulated to ensure effective decontamination. Successful completion of the occluded space survey is key to the mass demolition strategy. A detailed discussion is found in Chapter 6. Demolition and Equipment/Debris Removal Prior to mass demolition, equipment that has been determined to be contaminated must be dismantled and decontaminated. Similarly, equipment or materials areas that are intended to be reused or redeployed must be identified and decontaminated. If decontamination of any item in the area, such as equipment, equipment support, or concrete floor, is not possible, the item should be removed and managed as hazardous waste. Subsequent to dismantling, decontamination, and confirmatory monitoring, the facility/structure is prepared for mass demolition by deactivating all utilities to the area to be decontaminated and isolating the utilities that
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Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities may be located in the utility corridor. Demolition refers to the mechanical removal of structures with conventional construction equipment and industrial demolition techniques. Planning documents that address mass demolition will need to consider dust suppression, noise, and traffic studies and plans. As discussed above, the Army’s preference is to move toward mass demolition in order to improve safe working conditions and to minimize manual labor. Cost and Schedule Integrated cost and schedule should be tracked at the program level. It is important to forecast and track cost and schedule against the project schedule and allotted budget. The committee heard from Army and contractor staff that they currently use project tracking tools such as earned value to measure progress against scope, schedule, and budget.6 Earned value is a commonly accepted project management tool. Closure Project Management and Closure Team The experience of committee members is that for successful project execution, the project management quality assurance document, in addition to the project organization chart, should clearly indicate the roles and responsibilities of the project team members. The decommissioning work packages should contain steps such as daily (or as necessary) project briefing before starting a task and hold points for effective project control. This is also a good opportunity to reflect on health, safety, and security issues. Finding 2-7. It was not evident to the committee that a project quality assurance plan for closure was developed for every baseline chemical agent disposal facility site. Recommendation 2-7. The Army should create a project management quality assurance plan for each baseline chemical agent disposal facility site, describing the project organization, accountability, and lines of responsibilities for closure project execution for routine and unforeseen work situations. REFERENCES CMA (U.S. Army Chemical Materials Agency). 2009. Strategic Plan Fiscal Years 2010–2015 Revision 0. Aberdeen Proving Ground—Edgewood Area, MD. Washington, D.C.: Chemical Materials Agency. CTUIR (Confederated Tribes of the Umatilla Indian Reservation). 2009. Annual Report. Pendleton, OR: Confederated Tribes of the Umatilla Indian Reservation. CTUIR. 2008. Annual Report. Pendleton, OR: Confederated Tribes of the Umatilla Indian Reservation FFERDC (Federal Facilities Environmental Restoration Dialogue Committee). 1996. The Final Report of the Federal Facilities Environmental Restoration Dialogue Committee: Consensus Precipices and Recommendations for Improving Federal Facilities Cleanup. Available online at http://epa.gov/fedfac/fferdc.htm. Last accessed August 4, 2010. O’Donnell, B. 2008. Memorandum: Program Manager for Chemical Stockpile Elimination Chemical Disposal Facility Closure Strategy. Closure Compliance and Assessments, Chemical Materials Agency. USACHPPM (U.S. Army Center for Health Promotion and Preventive 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.