Closure and Johnston Atoll Chemical Agent Disposal System (2002) / Chapter Skim
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3 Planning the Closure Operation
3 Planning the Closure Operation
Pages 13-23
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From page 13... ...
Issues related to the execution of a closure plan and postclosure activities are covered in Chapters 4 and 5. CLOSURE OBJECTIVES Key objectives for the closure of a chemical agent disposal facility can be found in Chapter 4 of the Guide to Closure Planning (U.S.
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From page 14... ...
Heavily weighting superior contractor safety and environmental performance is an applicable consideration for award and incentive fees in contracts for closures of chemical agent disposal facilities. The present contract calls for reimbursement of all allowable expenses, excluding contractor costs disallowed by the federal acquisition regulations, such as business development costs.
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From page 15... ...
satisfaction with the operations contractors · the unique nature of closure activities for agentcontaminated facilities the probability that there will be concurrent disposal of agent-contaminated materials and closure activities time and cost constraints inherent in closure planning the time and effort required to obtain authorization for cost-plus-fixed-fee contracting Considering the remote location of JACADS, the problems involved in coordinating multiple contractors on the island, and the time and cost penalties inherent in educating another contractor, continuation of the operating contract (with appropriate changes to accommodate closure) appears to be justified.
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From page 16... ...
The Army has not reported any characterization results of measured agent contamination levels of equipment and surface areas. Permitting Consiclerations During the development of the closure plan, changes were identified that necessitated a change to the JACADS RCRA permit.
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From page 17... ...
Six permit modifications required to support closure were submitted to EPA by the Army. The permitting plan, Appendix 1 of the JACADS Closure Campaign Facility Closure Plan, shows that three were submitted in April 2000 (C-2022, C3-034, and C2-035)
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From page 18... ...
Appendixes to the Facility Closure Plan cover the following areas: permitting plan; sampling and analysis plan; corrective measures study; final release criteria; and closure schedule. SAMPLING AND ANALYSIS PLANS In conducting sampling for preclosure activities (such as the RCRA facility investigation (RFI)
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From page 19... ...
i4The term "replicate requirements" refers to the number of analytical samples required to provide statistically significant results with the required degree of precision. 19 TABLE 3-3 Agent Degradation Products Listed in the RCRA Facility Investigation Sampling and Analysis Work Plan ADP Abbreviation Chemical Name Agent Source TDG IMPA MPA EMPA DESH EA-2192 Thiodiglycol Isopropyl methylphosphonic acid Methylphosphonic acid Ethyl methylphosphonic acid 2-diisopropylaminoethanethiol S - (diisopropylaminoethyl)
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From page 20... ...
The characterizations will be based in part on analysis of concrete core borings taken from selected locations. Acliacent Sources of Contamination Although the Army is responsible for closure of only the JACADS area of Johnston Island, a closure plan that integrates Air Force and Army closure activities would provide opportunities for cost savings.
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From page 21... ...
SCHEDULE AND COST ESTIMATES Closure operations at JACADS began approximately in January 2001 and are estimated by the Army and WDC to be completed in October 2003, a total of 33 monthsi7 (Bush21 man, 2001~. The closure criteria given in the Facility Closure Plan states as follows (U.S.
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From page 22... ...
, PMCD has issued requirements that apply to both the operation and the closure of the disposal facilities. The risk management requirements published in Chemical Agent Disposal Facility Risk Management Program Requirements (U.S.
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From page 23... ...
Thus, a security presence appears to be warranted until final ownership of the island is established. JACADS will require a continuing security contingent following the departure of USACAP to protect workmen and other island residents until the JACADS facility has been declared closed and its property transferred to the installation commander.
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