3
Important Parameters for Successful Closure

BACKGROUND

The committee provided a series of key parameters for overall management of the current and upcoming chemical agent disposal facility closures in an earlier interim letter report (Appendix A). As an initial basis for developing these parameters, the committee considered the lessons learned by the U.S. Army Chemical Materials Agency (CMA) from 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 Facility (ABCDF), which was the first neutralization-based disposal facility, and the Newport Chemical Agent Disposal Facility (NECDF), another neutralization-based facility, were also considered.

The committee has modified the original list of parameters given in the interim report and developed a structured approach that presents the parameters and the associated metrics more effectively. Using these in conjunction with the experiences gained from previous closures, along with earlier programmatic plans for closure of TOCDF and CAMDS and the knowledge and experience of the committee members, the committee developed recommendations that it believes can improve the current and future closures of disposal facility sites. It is imperative to track the critical criteria, including the agency and regulatory requirements, necessary to successfully managing a closure project.

The committee continues to emphasize that the foremost goal of the parameters and metrics is to promote a safe and successful program for facility closure. To accomplish this, the effective use of well-developed management reports can serve as a feedback mechanism for the continuous improvement of closure activities and, where necessary, can serve as a mechanism for stopping work until appropriate corrective actions can be made. The role of a management reporting process is best described by the plan-do-check-act cycle used by many organizations and described at the American Society for Quality website.1 As originally identified in the interim letter report, metrics are of two kinds: leading metrics, which help to predict performance, and lagging metrics, which indicate the actual performance. While the committee considers the listed parameters and corresponding metrics to be important, it notes that they need not be considered all-inclusive.

KEY PARAMETERS

The parameters in Table 3-1 and Table 3-2 are shown along with associated metrics as a starting point for the management of closure activities at the program and project levels. It is imperative that different parameters be tracked at the appropriate management and activity levels. This section develops a parameter framework for both the program and the project level that is defined later. The list of parameters has been revised from the original list in the interim letter report and includes

1

A discussion of the plan-do-check-act cycle is found at http://www.asq.org/learn-about-quality/project-planning-tools/overview/pdca-cycle.html.



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3 important Parameters for successful closure BacKgrouNd accomplish this, the effective use of well-developed management reports can serve as a feedback mecha- The committee provided a series of key parameters nism for the continuous improvement of closure activi- for overall management of the current and upcoming ties and, where necessary, can serve as a mechanism for chemical agent disposal facility closures in an earlier stopping work until appropriate corrective actions can interim letter report (Appendix A). As an initial basis for be made. The role of a management reporting process developing these parameters, the committee considered is best described by the plan-do-check-act cycle used the lessons learned by the U.S. Army Chemical Materi- by many organizations and described at the American als Agency (CMA) from closure of the Johnston Atoll Society for Quality website.1 As originally identified Chemical Agent Disposal System (JACADS), which in the interim letter report, metrics are of two kinds: was the first full-scale incineration-based disposal leading metrics, which help to predict performance, and facility. The Aberdeen Chemical Agent Disposal Facil- lagging metrics, which indicate the actual performance. ity (ABCDF), which was the first neutralization-based While the committee considers the listed parameters disposal facility, and the Newport Chemical Agent Dis- and corresponding metrics to be important, it notes that posal Facility (NECDF), another neutralization-based they need not be considered all-inclusive. facility, were also considered. The committee has modified the original list of Key ParameTers parameters given in the interim report and developed a structured approach that presents the parameters and The parameters in Table 3-1 and Table 3-2 are shown the associated metrics more effectively. Using these in along with associated metrics as a starting point for the conjunction with the experiences gained from previous management of closure activities at the program and closures, along with earlier programmatic plans for project levels. It is imperative that different parameters closure of TOCDF and CAMDS and the knowledge be tracked at the appropriate management and activity and experience of the committee members, the com- levels. This section develops a parameter framework for mittee developed recommendations that it believes both the program and the project level that is defined can improve the current and future closures of disposal later. The list of parameters has been revised from the facility sites. It is imperative to track the critical crite- original list in the interim letter report and includes ria, including the agency and regulatory requirements, necessary to successfully managing a closure project. The committee continues to emphasize that the fore- 1A discussion of the plan-do-check-act cycle is found at http:// most goal of the parameters and metrics is to promote www.asq.org/learn-about-quality/project-planning-tools/overview/ a safe and successful program for facility closure. To pdca-cycle.html. 

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES TABLE 3-1 Program-Level Parameters and Metrics Metric Definition Type Safety, Health, and Security Near-miss Number of unsafe Leading conditions Incident investigations completed within 30 days Percent complete Leading Cross-training for workforce/supervisors Percent complete Leading Random drug testing Percent complete Leading Occluded space survey process yes/No Leading Unventilated monitoring test process yes/No Leading Numbers of recordable injuries (RIs) Number Lagging Number of lost workday cases Number Lagging Days away from work due to workplace incident/injury Number Lagging Fatalities (all causes) Number Lagging Training and Development Continuing education Hours/year Leading Communication Safety culture survey 1-5 scale Leading Leadership communication sessions Number/year Leading Cost Federal requirements Standard metrics Lagging Program cost objectives Program cost targets Lagging metrics Schedule Schedule status Percent complete Lagging Earned value Compare progress to Lagging expenditures Environmental Compliance Establish facility future use for all sites (RCRA and BRAC) yes/No Leading Establish RCRA closure performance standards for all sites yes/No Leading Develop RCRA permit closure plan for all sites and coordinate with state regulators yes/No Leading Develop supplemental closure plans at each site and coordinate with state regulators yes/No Leading Develop plan in coordination with state regulators at each site to minimize waste/maximize reuse and recycling yes/No Leading Develop plan in coordination with state regulators at each site for disposition of waste yes/No Leading Management Develop roles and responsibilities for key personnel yes/No Leading Develop quality assurance management program including design control, training, document control, revision yes/No Leading control, performance review, and internal audits for a comprehensive quality assurance program TABLE 3-2 Project-Level Parameters and Metrics for the Chemical Agent Disposal Facilities Metric Definition Type Safety, Health and Security Near-miss Number of unsafe Leading conditions Incident investigations completed within 30 days Percent complete Leading Cross-training for workforce/supervisors Percent complete Leading

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 IMPORTANT PARAMETERS FOR SUCCESSFUL CLOSURE TABLE 3-2 Continued Metric Definition Type Appropriate personal protective equipment for all tasks yes/No Leading Closure of open safety items in a timely manner Percent complete Leading First aid cases Number Recordable injuries and exposuresa Number Lagging Lost-time injuriesa Number Lagging Fatalities (all causes) Number Lagging Hazardous assessment plan yes/No Leading Occluded space survey #1 yes/No Leading Occluded space survey #2 Number of failures Lagging Unventilated monitoring test Number of failures Lagging Maintenance Planning and scheduling all maintenance yes/No Leading Appropriate maintenance for deconstruction equipment Percent complete Leading Appropriate calibration and checking of monitoring equipment yes/No Leading Preventive/predictive maintenance program for key equipment Percent complete Leading Monitoring/audit of maintenance plan Percent complete Leading Training and Development Cross-training for critical operation deconstruction positions yes/No Leading Proper certification for employees and contractors yes/No Leading Hazardous waste certification for appropriate workers yes/No Leading Workforce training on the facility and on non-normal situations yes/No Leading Workforce training for deconstruction personnel yes/No Leading Communication Schedule(s) communications with local citizens advisory commission yes/No Leading Proactive two-way communications with neighboring communities yes/No Leading Proactive and frequent communications by senior site personnel with the state regulatory personnel yes/No Leading Regularly scheduled two-way communications with workforce yes/No Leading Cost Periodic cost spending plan yes/No Leading Track costs to spending plan yes/No Lagging Schedule Develop project schedule milestones yes/No Leading Track engineering changes Percent complete Lagging Track project schedule milestones Percent complete Lagging Environmental Compliance Establish closure performance standards for closure wasteb yes/No Leading Closure plans included in RCRA permit, supplemented by more detailed plans b yes/No Leading Closure addressed in other applicable permitsb yes/No Leading Approval of waste analysis plan and characterization protocolsb yes/No Leading Approval of monitoring plans for other appropriate media yes/No Leading Establish where generator knowledge can be usedb yes/No Leading Develop plans for optimizing reuse and recycling yes/No Develop protocols for segregation of hazardous and nonhazardous waste materialsb yes/No Leading Monitor compliance with RCRA permit closure plan Monitor percent Lagging compliance and notices of violation Monitor compliance with other permits Monitor percent Lagging compliance and notices of violation yes/No Leading Management Develop effective records retention process yes/No Leading Regularly review lessons learned database for effectiveness yes/No Leading Review material management process including reuse/recycling yes/No Leading aOSHA requirement. bPer state approval.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES safety, health, and security additional parameters from the list developed in the NRC report Evaluation of Safety and Environmental Metrics The CMA programmatic staff, along with the site for Potential Application at Chemical Agent Disposal management personnel and workers at chemical agent Facilities (NRC, 2009). That report served as an excel- disposal facilities, continues to promote an operational lent framework for operating disposal facilities as well culture focused on safety, health, and security. The as a starting point for closure planning. Appendix B of performance record of the various sites during the dis- the present report includes the complete list developed posal operations phase demonstrates the management in that study. This current report expands the list with focus and employee awareness of the safety programs. additional critical management parameters required for Table 3-3 summarizes site injury rates for the baseline closure. The overriding purpose of the parameters and chemical disposal sites through the first quarter of metrics is to instill a culture of continuous improvement 2010. These data indicate the performance of opera- for all aspects of closure and deconstruction, including tions management in maintaining a safe work environ- safety, regulatory, and program and project management. ment. However, a major concern related to safety not The list developed by the committee is more complete present in the day-to-day operations is the new and non- than the one previously developed in the interim report; repetitive activities during closure, which can result nevertheless, it still need not be considered all-inclusive. in unexpected situations that present safety issues. An The following findings and recommendations are pro- effective safety program for closure requires that both vided by the committee for consideration by the Army. leading and lagging metrics be tracked, documented, reported in a timely manner, and communicated as part Finding 3-1. A formal and structured system of param- of the process. As reported in the interim letter report, eters and metrics, including leading as well as lagging satisfactory results concerning safety, health, and secu- metrics, provides important guidance for planning, rity are supported by the establishment of systematic organizing, and implementing efficient closure of base- data collection, site observations, incident reporting, line incineration chemical agent disposal facilities. and an effective investigation process. This requires the involvement of the entire organization from the Recommendation 3-1. The Army should consider the programmatic and site management personnel, proj- parameters and metrics presented in this report as it ect planners, operational personnel, contractors, and plans and executes the closure of the baseline chemical all workers involved in the execution of the closure agent disposal facilities. activities. As the site transitions from operations to closure, the potential for unforeseen/unexpected safety Finding 3-2. Tracking and reporting parameters and occurrences may increase in number and complexity, metrics will facilitate the safe and successful manage- requiring close surveillance and awareness on the part ment of the closure of the Army’s baseline incineration of not only the closure teams but also the existing chemical agent disposal facilities. operations teams. Recommendation 3-2a. At a minimum, the Army should track parameters and metrics used for disposal maintenance facility closure at two levels: the program level and the project level. Thereafter, it should determine whether The successful closure of the baseline incinera- additional parameters and metrics are required. tion disposal facilities requires correct execution of all maintenance work activities on equipment that Recommendation 3-2b. The Army should ensure that will impact the closure. Execution includes effective appropriate and timely management reports are devel- planning and timely scheduling of all maintenance oped that enable tracking results for parameters and work on key equipment used for disposal operations, metrics to be used to make management decisions and closure, and monitoring. In the deconstruction busi- take necessary actions. ness, many safety and regulatory problems can be prevented through well-managed maintenance work Following is a summary of each of the categories processes. Additionally, negative impacts on schedule of parameters. can be minimized when critical equipment is properly maintained. Benchmark studies have shown that results

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 IMPORTANT PARAMETERS FOR SUCCESSFUL CLOSURE TABLE 3-3 Chemical Demilitarization Site Recordable Injury Rates as of March 31, 2010 Employee Hours Worked Since Current Highest Lowest Highest Lowest 1-Month RIRa 1-Month RIRb 12-Month RIRc 12-Month RIRd Facility Last LWC (hr) 12-Month RIR ANCDF 4.5 million 0.69 5.18 0.0 1.75 0.27 (988 days) NECDF 1.9 million 0.33 4.45 0.0 1.95 0.18 (914 days) PBCDF 3.0 million 0.13 3.32 0.0 1.17 0.00 (770 days) 14.54e/11.26 TOCDF 8.9 million 0.76 0.0 4.82 0.46 (1,624 days) UMCDF 6.2 million 1.06 3.83 0.0 2.25 0.34 (1,369 days) NOTE: LWC, lost workday case; RIR, recordable injury rate. aHighest 1-Month RIR in entire facility operational history. bLowest 1-Month RIR in entire facility operational history. cHighest 12-Month RIR in entire facility operational history. dLowest 12-Month RIR in entire facility operational history. eThe higher number includes 11 cases of food poisoning that occurred at a safety celebration. The lower number excludes these 11 cases. SOURCE: Cheryl Maggio, Deputy Project Manager Chemical Stockpile Elimination, CMA, May 28, 2010. are optimized by having 80-85 percent of all required ity at baseline chemical agent disposal facilities. The maintenance activities planned and scheduled.2 committee continues to believe that concerted efforts should be made to train the deconstruction workforce on hazards and awareness pertinent to the site and Training and development facility situations. Cross-training between personnel The basis for successful completion of closure of familiar with operations and individuals responsible baseline chemical agent disposal facilities is the active for closure constitutes a critical interface for promot- involvement and proper preparation of each site’s ing safe and successful outcomes for closure activities. entire workforce. Strategic elements identified by the Training requirements for closure operations are very committee that should be tracked and reported include different from operational activities and therefore must the employee selection, training, and development be closely monitored. An example of the importance of process. workforce training is the criticality of the unventilated The leading and lagging metrics provided in Table monitoring process for the closure facilities and the 3-1 for this parameter represent critical items that, when need to develop solid training materials (as discussed successfully addressed, will result in a more qualified in detail in Chapter 6). workforce and a higher probability of success. For example, the technical aspects, complexity, and unique communications safety and environmental requirements of a facility clo- sure mandate that the workforce be properly selected The committee believes that a strong, positive com- and prepared through education and training. That munication strategy engages a full range of stakehold- training drives performance results for new activities, ers involved in the execution of the closure programs. especially when new personnel are involved, is a well- The committee appreciates the strong, positive safety established fact, and closure will constitute a new activ- culture that has been developed at TOCDF, CAMDS, and other CMA sites, and it believes that that culture will continue into the closure phase as long as the fre- 2A discussion of benchmark studies that establish optimal levels quent formal and informal sharing of information and of maintenance is available online at http://www.reliabilityweb.com/ ongoing dialogue continue. Additionally, the closure excerpts/excerpts/Maintenance_Benchmarks.pdf. Last accessed management must actively lead and support commu- July 1, 2010.

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 REVIEW OF CLOSURE PLANS FOR THE BASELINE INCINERATION CHEMICAL AGENT DISPOSAL FACILITIES nications with all key stakeholders, including federal successful closure include obtaining regulatory agree- and state authorities and local community groups. Good ment with the closure plans with the state authorities communications build trust and provide more oppor- on a timely basis. This requires close coordination with tunities to understand the changing nature of risk. The the state regulatory community to obtain early agree- committee has selected the metrics identified as critical ment on the anticipated future use for the facility and to ensuring a proactive communication strategy. the related closure performance standards that must be achieved. State environmental regulatory authorities have been engaged throughout the process in the review cost of plans and specifications for the closure. Program cost objectives comprise a key strategic Just as important as the closure performance stan- parameter for successful completion of the site closure as dards are reaching agreement with the state regula - indicated in the committee’s interim report for successful tory authorities on the manner in which performance completion of the site closure. The committee was nei- standards will be achieved. Throughout the closure ther tasked nor provided with the financial data necessary process, compliance monitoring will be required. The to assess how the programs are progressing in terms of metrics provided herein are designed to track timely cost management. The committee believes strongly that selection of future use, agreement on the performance the various levels of management, including CMA at the standards, and the manner in which the performance program level and the prime and subcontractors at the standards will be achieved, leading eventually to final project level, should be able both to forecast anticipated facility closure. costs and to effectively understand, manage, and explain The committee’s metrics for environmental compli- all expenditures during the implementation of program ance are based in part on the recommendations estab- and project work and have a robust cost control system. lished within the NRC report Evaluation of Safety and It is imperative that all federal financial requirements be Environmental Metrics for Potential Application at met for the projects to be successfully undertaken in the Chemical Agent Disposal Facilities (NRC, 2009). closure and closure process. management schedule The responsibility of management is to set the tone Based on the complexity and cost of the satisfactory and direct the site effort for all work activities. The met- completion of the chemical agent disposal facilities rics listed for this parameter offer ways to consider how site closures, the committee believes that the leader- management measures its activities and their effective- ship needs to develop and adhere to a comprehensive ness. Management is responsible for developing and schedule. Additionally, how management addresses structuring parameters and metrics for each segment of programs and project changes and delays within the the workforce. Not all of the workforce can or should closure process are critical to timely and cost-effective receive and react to all of the information resulting completion and are therefore identified as a parameter from the metrics discussed in this chapter. However, to be tracked. Safety becomes a critical item when each parameter and each metric must be reviewed for tracking schedule changes and when pressure develops its intended audience. to complete an activity on time. Closure program quality is a key strategic element for successful program completion. Quality elements such as adequate and appropriate analytical capabilities, environmental compliance inventory and material management, records retention, Environmental compliance issues associated with and lessons learned comprise critical management the closure of the baseline chemical agent disposal items that can significantly affect the efficiency of the facilities are a priority for management. The track- overall closure effort. Careful materials management ing of performance in this regard will be critical. The is a key to successful facilities closure and manage- CMA closure team and the teams at each facility have ment control while quality protocols for segregation of evidenced a strong understanding of regulatory compli- generated hazardous and nonhazardous materials must ance and monitoring requirements. Key attributes for be implemented. This will require proper identification

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 IMPORTANT PARAMETERS FOR SUCCESSFUL CLOSURE and inventory control of these materials. The commit- of resources across projects as well as supervision of tee has identified a set of key metrics to be tracked for links between the projects and the overall costs and successful closure. risks of the project. Closure and deconstruction activi- ties require the possession or acquisition of an under- standing of the unique aspects of these operations, and grouPiNgs oF ParameTers therefore the parameters and metrics must reflect such The large number of parameters and associated met- an understanding. At the program level, the intent is rics to be tracked and reported over the course of the to focus more on the leading metrics in the hopes of closure of chemical agent disposal facilities will result anticipating future issues. in the generation of significant amounts of informa- tion. In managing the closure operations, management Project level should divide the parameters and metrics into two lev- els: the program level and the project level. The com- The key difference between a program and a project mittee did not attempt to address task-level activities. is the finite nature of the project. A project is designed However, the Army and its closure contractors should to deliver an output or deliverable, and its success will do so to track the key parameters identified and the be determined in terms of delivering the right output at corresponding metrics. the right time and at the right cost. Project-level metrics will primarily be the responsibility of the contractors, both prime and subcontractors, to track the results and Program level manage accordingly. The project-level metrics will be Program management is the process of managing more heavily weighted to lagging metrics and focused one or more related projects, often with the intention on continuous improvement. of improving an organization’s performance. The man- agement of the site and the CMA is concerned with the aggregate result or end use. Typically, a program reFereNce approach is broken down into projects that reflect the NRC (National Research Council). 2009. Evaluation of Safety and Envi- overall objective. The emphasis for the program man- ronmental Metrics for Potential Application at Chemical Agent Disposal agement staff involves coordination and prioritization Facilities. Washington, D.C.: The National Academies Press.