Review of Closure Plans for the Baseline Incineration Chemical Agent Disposal Facilities (2010) / Chapter Skim
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Appendix A: Reprinted 2010 Letter Report
Appendix A: Reprinted 2010 Letter Report
Pages 63-79
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From page 63... ...
appendix a reprinted 2010 letter report The following report is a reprint of National Research Council, "Review and Assessment of Closure Plans for the Tooele Chemical Agent Disposal Facility and the Chemical Agent Munitions Disposal System: Letter Report" (The National Academies Press, Washington, D.C., 2010) , available online at http://www.nap.edu/catalog.
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From page 64... ...
Army's chemical demilitarization activities and operated between 1979 and the Committee on Review and Assessment of Closure Plans for the Tooele Chemical 2005. The CAMDS site encompasses 61 hazardous waste management units, a Agent Disposal Facility and the Chemical Agent Munitions Disposal System addresses ventilation system, and a number of buildings, some of which were used in testing some of the issues pertaining to closure at the TOCDF and CAMDS facilities.
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From page 65... ...
The Tooele Chemical Agent Disposal Facility/Chemical Agent In this interim study, the committee also considered prior closure experiences for Munitions Disposal System management should establish a cross-training and hazards three other chemical agent disposal facilities: the prototype baseline Johnston Atoll familiarization program to ensure continued strong safety performance and effective Chemical Agent Disposal System on Johnston Island in the Pacific Ocean and the utilization of personnel. hydrolysis-based facilities in Aberdeen, Maryland, and Newport, Indiana, where, respectively, bulk mustard agent and VX nerve agent were destroyed.
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From page 66... ...
The risk of exposure to chemical agents during closure operations is expected C Committee on Review and Assessment of Closure Plans for the Tooele Chemical to be significantly lower than what potentially could be encountered during agent Agent Disposal Facility and the Chemical Agent Munitions Disposal System disposal operations. The regulatory standards and practices used by the state of Utah for D Acknowledgement of Reviewers controlling agent-contaminated materials were developed early in the program when there was little experience with managing the risks of materials exposed to agent.
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From page 67... ...
Army Chemical Materials Agency (CMA) at earlier facility closures, specifically, the closure of the Johnston Atoll Chemical Agent Disposal System (JACADS)
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From page 68... ...
Communications for Periodically survey employees, supervisors, and managers with Document frequency of safety communication promoting safety culture respect to criteria important to a strong safety culture sessions where employee leadership and participation are encouraged Maintenance Planning and scheduling of all maintenance work Audit maintenance process regularly Appropriate maintenance for construction equipment Monitor maintenance Preventive maintenance program for key equipment Predictive maintenance program for key equipment Appropriate calibration and checking of instrumentation and controls Training and development Cross train and educate for critical operation and deconstruction Not applicable positions Continuing education: at least 40 hours per year of technical coursework Workforce training on the facility and on non-normal process situations for operation personnel, including drills for abnormal conditions Workforce training on the facility and on non-normal process situations for deconstruction personnel, including emergency and abnormal conditions -8
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From page 69... ...
Parameter Leading Metrics Lagging Metrics Communications with Scheduled communications with a local community action Measure response to meetings scheduled with various stakeholders committee with a consistent agenda stakeholders Communications with the state of Utah regulatory personnel on a regular and as needed basis Regularly scheduled two-way communications with the workforce throughout the life cycle of the site Track the lessons-learned program to ensure that the lessons are utilized throughout the chemical demilitarization program Quality criteria Identify complete inventory of units to be closed and the end state Track engineering changes plan for each Regularly track project schedule milestones from Ensure the environmental health and safety management system is preplanning to completion complete and operating with appropriate data analysis and management Develop project schedule milestone projections for the next period (week, month) Cost criteria Project program costs over similarly selected periods and verify Track program costs over selected periods Operations and Monitor lockout-tag-clear-and-try process Document excursions outside operating conditions deconstruction Establish and document safe operating conditions for all major Document frequency and duration of safety process equipment interlock bypasses Establish expected frequency and duration of "hot" electrical work Document frequency and duration of "hot" electrical work Track deconstruction progress (e.g., weight, volume, or number of units)
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From page 70... ...
0 Parameter Leading Metrics Lagging Metrics Management Ensure that supervisors and managers have appropriate experience Monitor implementation of personnel development with respect to operations, maintenance, or laboratory skills for high- and retention plan hazard processes Develop processes by which top managers regularly audit and assess all key activities Environmental regulatory Establish facility end-state conditions Monitor compliance with RCRA permit compliance Establish performance standards for closure wastes Monitor compliance with closure plans Modify Resource Conservation and Recovery Act (RCRA) permit to Monitor compliance with other permits include detailed closure plans Modify other applicable permits to include closure Monitoring plan compliance Develop waste analysis plan and waste characterization protocols Monitor implementation of waste analysis plan Develop monitoring plans for air and other media Analytical Establish criteria for use of generator knowledge Not applicable Identify validated analytical methods to be used Obtain regulatory acceptance of validated analytical methods Materials management Identify reuse and recycling options for deconstruction materials Implement control of inventory of hazardous and nonhazardous materials Develop protocols for segregation of generated hazardous and nonhazardous materials Obtain prior regulatory agreement for reuse, recycling, or disposal of all materials Identify means for control of inventory of hazardous and nonhazardous materials Establish a time line for risk-based disposition of all materials resulting from closure a A leading indicator is a prospective metric or set of metrics that can be used to develop strategies for project success; a lagging indicator is a retrospective metric or set of metrics that can point to a need for corrective action (NRC, 2009)
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From page 71... ...
successful program completion. The technical aspects of the TOCDF and CAMDS closure operations mandate that the workforce be properly prepared through education Environmental Regulatory Compliance and training provided by their employer.
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Current Operations TOCDF began agent disposal operations in August 1996 and completed disposal of GB nerve agent and munitions in March 2002. Disposal operations for VX nerve agent began in March 2003 and were completed in June 2005.
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TOCDF closure plans within to process closure waste process. the existing (prepermit modification)
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From page 74... ...
its use as a pilot plant, resulting in use for a wide variety of Closure Planning Status chemical demilitarization operations; and (3) its configuration as multiple interconnected buildings having a common ventilation system and common utility services that require careful attention to the order of shutting down parts of the system.
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From page 75... ...
8 Utah officials have indicated that they will soon be ready to act on permit closure plans when applying for the permit. The plan then becomes part of the permit modification approvals, following RCRA public involvement and administrative actions.
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From page 76... ...
Waste Characterization. Since the early days of the chemical demilitarization program, Community involvement at the Utah demilitarization facilities is conducted the Army, being concerned primarily with worker exposure to agent vapor hazards, has primarily through the Citizens Advisory Commission (CAC)
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closure of NECDF for potential use during TOCDF and CAMDS TOCDF (Tooele Chemical Agent Disposal Facility)
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, Brighton, Michigan NECDF Newport Chemical Agent Disposal Facility RCRA Resource Conservation and Recovery Act Staff SWMU solid waste management unit MARGARET N NOVACK, Study Director (until January 2010)
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Attachment D Acknowledgement of Reviewers This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the National Research Council's (NRC's) Report Review Committee.
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