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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment 5 Programwide Influences on Continuing Operability Beyond concerns for the obsolescence of facilities, equipment, and personnel skills, knowledge, and abilities, managing for continuing operability is affected by organizational structure, contractual relationships and incentives, community and regulatory relationships, and planning for emergencies and closure. These concerns directly impact overall performance, and thus influence the organizational response to obsolescence and continuing operability challenges. This chapter will address these overarching issues that affect the overall chemical stockpile disposal program. Programwide organization has a major influence on site interrelationships, the capability of subordinate management to perform according to expectations, and the job satisfaction of personnel. Managers need full authority commensurate with assigned responsibility, and they need the resources—financial as well as personnel—to accomplish assigned duties. The unique nature of the stockpile demilitarization processes—including the specialized types of equipment and knowledge, skills, and abilities required for plant operation—and the finite life expectancy of the disposal facilities, drive important program management decisions. Failure to recognize these facts and to consider them in program management organization and procedures will affect facility obsolescence and continuing operability in several ways. Loose configuration management will diminish intersite flexibility. An inappropriate balance between authority and responsibility will lead to frustration and loss of key personnel, inexorably risking the need for a program schedule extension and the possible erosion of desirable safety attitudes and actions. Organizational imbalance and complexity can result in confusion regarding accountability and difficulty in assuring management coverage of critical continuing operability issues. Contractor guidance through the use of contract incentive language risks a misunderstanding of incentive intents, and the possibility of incentive misstatement, all of which can have impacts on continuing operability performance and cost. PROGRAM MANAGEMENT Evolution of the Present Program Management Structure Responsibility for achieving the multiple program objectives associated with the stockpile disposal program (e.g., protection of workers, the public, and the environment; CWC treaty obligations; cost control) rests with the U.S. Army. Initially the program manager for chemical demilitarization (PMCD) was delegated this responsibility by the Secretary of the Army, and authority and resources necessary to accomplish the mission were provided. Work was accomplished by private sector site contractor teams, under the close supervision of PMCD staff, many of whom were experienced in chemical demilitarization operations. Multiple contractors were employed to design, construct, operate, and maintain facilities, all under PMCD supervision. An Army field office located at each site provided additional oversight on costs and contractual issues. After the first sites became operational and construction of the remaining incineration sites was well underway, subsequent resource limitations forced this centralized management structure to rely less on government employee staff and to depend more heavily on multiple contractors and subcontractors to accomplish its mission. Beginning in mid-2002 a shift began toward increased reliance on site contractors and decreased PMCD authority and staff. The PMCD office was disestablished, and in December 2003 the Chemical Materials Agency (CMA) was created to manage the chemical stockpile disposal program.1 Thus, rather than depend on contractor performance under the close supervision of PMCD representatives, the great majority of responsibil- 1 CMA Performance-based Contracting Approach, presentation by Brad Pierce, U.S. Army Field Support Command, CMA, to the committee, March 30, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment ity moved to the contractor. The PMCD, and later the CMA, retained authority to make key decisions affecting contract cost. The CMA also retained responsibility for oversight of the quality assurance program, authority and responsibility for governmental functions, and overall program responsibility to the Secretary of the Army, the Secretary of Defense, and the Congress. The CMA, acting through the newly created project manager for chemical stockpile disposal (PMCSD), since renamed the project manager for chemical stockpile elimination (PMCSE), continued to manage the overall schedule, budget, and risk and configuration management programs. With this change, the oversight of both stockpile storage and demilitarization operations came under the same organizational structure (i.e., the CMA). Figures 5-1 and 5-2 show previous and present organizational structures. The current structure (Figure 5-2) inserts contractual incentives between what was formerly (pre-2002) direct operational control of the sites, as shown in Figure 5-1. Contract provisions thus became the major vehicle for guiding site performance and for encouraging cooperation among sites. Such cooperation constitutes an important element for managing coordinated responses to the problems of potential obsolescence associated with the similar processing equipment at the sites as well as issues concerning the aging of the stockpile itself. It is also noteworthy that site contractors already had been operating in location-specific regulatory and community environments, and had developed varying approaches that were tailored to local conditions. Contracts were rewritten to reflect the intended changes (CMA, 1995). Contractors were protected and their financial risk reduced to a large degree by the cost reimbursable provisions of the contract. The stockpile demilitarization site contracts are all cost reimbursable, so the contractor is entitled to recover actual costs that are reasonable and allowable, including overhead, incurred in performance of the contract. Target reimbursable costs are established on a monthly basis and these serve as a basis for the contractor’s fee pools. The contracts also include a fixed base fee of 3 percent of the target cost. This covers contractors’ essential costs (such as cost of money), which the contractor gets re- FIGURE 5-1 General organization structure for the chemical stockpile disposal program management pre-2002.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment FIGURE 5-2 General organizational structure for the chemical stockpile disposal program management post-2003. gardless of its performance. The base fee is paid out monthly over the estimated period of performance. The award fee percentage ranges from 3 percent to 7 percent of target costs, based on the terms in the contract. Award fee is earned based on actual performance against the criteria established in the Award Fee Plan. Award fee evaluations are conducted semiannually (CMA, 2005).2,3 Site personnel believe that the tone and substance of award and incentive fees motivate contractor cooperation with other site managers, excellence in operational performance, concern for safety, and general alignment with program purposes as intended by the CMA. They acknowledge, however, that CMA and contractor corporate purposes are not totally congruent. The CMA director’s programmatic performance-based incentive (DPPBI) was implemented, at least in part, because of a “lack of Government and Systems Contractors’ ability to readily and effectively translate successful solutions from one site to another” (CMA, 2006, p. 1). This translation is of key importance for developing systemwide obsolescence management programs, but it is not clear that the DPPBI has yet been successful in meeting this goal. The effectiveness of the site-focused organizational model depends importantly on the confidence that the contracting parties have in the quality and fairness of the contractual incentives used to drive contractor performance. Contractor site personnel have indicated that the quality of a contractor’s performance in those technical areas subject to objective measurement is easily agreed in conference between contractor site managers and CMA on-site representatives. Contractor performance measured subjectively, which also affects incentive awards, is more likely to be conten- 2 Tooele Chemical Agent Disposal Facility personnel interview with Gary McCloskey, briefing to the committee, March 2, 2006. 3 Personal communication between Raj Maholtra, deputy, Technical Support Directorate, CMA, and Robert J. Love, NRC staff, via e-mail, June 26, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment tious (CMA, 2006). Directly involved government personnel report mixed opinions regarding the success of the new operating model. Some believe it is working reasonably well; others report that it is proceeding satisfactorily but that significant changes in the government’s role have been challenging to accept and understand. Still others are overtly critical, feeling that responsibility and authority are not properly balanced, and that contractors are not well enough motivated to minimize program costs (CMA, 2006). For example, in the Award Fee Plan for Fiscal Year 2006 at TOCDF, cost performance is weighted only 10 percent in determining the contractor’s qualifying score for incentive payment (CMA, 2005). Army CMA/Field Office/System Contractor Interactions CMA representatives intend no significant differences in contractor responsibility at the four incineration sites. Implementation of this policy is challenging indeed in spite of the best efforts of senior leaders at CMA headquarters. The degree to which responsibility and authority have been delegated by contract to the private sector site operators makes oversight of site differences in program execution a major undertaking for the current level of CMA staffing. This is especially true since two different contractors are involved, EG&G at TOCDF and Washington Group International (WGI) at the other three sites. There also are site-specific differences in configuration and procedures, as well as in workforce culture among the WGI sites.4 Contract relationships have led CMA oversight to depend mostly on coordination and influence rather than directive authority.5 The PMCSE functions from CMA headquarters with a total staff of 20. Increasingly, responsibility for technical issues is being transferred to the CMA technical support director, who reports to the CMA director, and not to the PMCSE.6 Management of the stockpile disposal program in general is site-focused, thus diluting single-point responsibility and authority for program execution. The government field staff reports to the CMA director of operations rather than the PMCSE. The separation of technical and operational leadership conflicts with the need for close intersite cooperation and coordination that can be essential in promoting the sharing of critical system component spares and dependable communication of lessons learned. The PMCSD reported that absence of intersite cooperation is difficult to detect, and that cooperation has improved since all site contracts have been awarded and competition between contractors for additional work has subsided.7 The PMCSD indicated a belief that in spite of this improvement, and in spite of increasingly attractive incentive programs, some differences in configuration and practices remain.8,9 The site contractor holds responsibility, directly or through subcontractors, for overall operations, including: production control; costs and schedules tracking; document and records control; protocol, property administration, maintenance, logistics, safety, security; quality assurance and quality control programs, environmental compliance, site engineering, laboratory training and operation; emergency medical support; planning for closure; and personnel surety program. The site contractor responsibility also includes the administrative support of contractor staff, training, and such programs as lessons learned that involve interaction with other sites and with the CMA. The site contractor is responsible for constructive interaction with other sites in support of critical repair parts provision when required. Site security is generally handled by the host military unit responsible for the military installation upon which the chemical agent stockpile disposal facility is located. The site contractor holds responsibility for emergency response and notification, waste disposal, and supply procurement, stocking, and issuing. The concept, as described by the PMCSD, is for the site contractor to hold most of the responsibility, to have commensurate authority, and to be responsible to the CMA for safe, effective operations within limits prescribed by the contractual arrangement. The PMCSE continues to be charged by the CMA with ensuring effective implementation of program directives; however, the committee does not believe that at present the PMCSE has commensurate authority to discharge this obligation effectively and with reasonable assurance of success. 4 NRC Committee on Continuing Operability of Chemical Agent Disposal Facilities, presentation by Robert C. Love, ANCDF project general manager, CMA, to the committee, April 6, 2006. 5 Chemical Stockpile Disposal (CSD) Facilities and Equipment Obsolescence Assessment, presentation by Joseph Pecoraro, project manager for chemical stockpile disposal, CMA, to the committee, January 25, 2006. 6 Bruce Pringle, chief, Life Cycle Management Office, PMCSD-CMA, program management question-and-answer session with the committee, April 6, 2006. 7 Chemical Stockpile Disposal (CSD) Facilities and Equipment Obsolescence Assessment, presentation by Joseph Pecoraro, project manager for chemical stockpile disposal, CMA, to the committee, January 25, 2006. 8 Bruce Pringle, chief, Life Cycle Management Office, PMCSD-CMA, program management question-and-answer session with the committee, April 6, 2006. 9 Chemical Stockpile Disposal (CSD) Facilities and Equipment Obsolescence Assessment, presentation by Joseph Pecoraro, project manager for chemical stockpile disposal, CMA, to the committee, January 25, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment Finding 18. The program manager for chemical stockpile elimination (PMCSE, formerly PMCSD) has a small central staff, which limits the technical expertise that is available within the Chemical Materials Agency (CMA). The PMCSE is responsible to the CMA director for the functioning of the chemical agent stockpile incineration facility sites but has no contracting or other authority to ensure a desired result. The PMCSE must depend on personal persuasion and the responsibility of site contractors, operating under CMA-generated financial incentives, to keep the chemical agent stockpile disposal program functioning safely and effectively. Recommendation 18. The Chemical Materials Agency (CMA) and Army management of the chemical stockpile elimination program should adjust PMCSE resources and authority, commensurate with CMA responsibility, to manage the program in the interest of the Army and the U.S. citizenry. Adjustments should ensure that an appropriate balance between assigned responsibility, resource adequacy, and granted authority is attained. (Tier 1) The CMA administers the chemical stockpile demilitarization contract on behalf of the government and is responsible for quality assurance. It evaluates contractor performance as required to implement the basic and incentive provisions of the contract and accomplishes other governmental functions as may be required. The contractor’s scope of work is provided through the contract with the CMA, with the CMA approving any changes to the scope, and providing resources to further the work. A CMA site representative leads a small team of government employees to accomplish these tasks, and is authorized to approve contract changes costing a maximum of $200,000 without reference to CMA headquarters. In a briefing to the committee at ANCDF, it was reported that this figure has not been changed over a period of several years while costs have escalated substantially, resulting in an increasing number of contract change requests that required CMA headquarters approval and associated delays while the requests are processed. Effects of Shifting Site Responsibility Largely to Contractor While recognizing that site-focused management has some distinct advantages since both management and responsibility are focused locally, the committee noted some disadvantages that it believes should be balanced carefully with the advantages. Among these disadvantages is the necessity to comply with the rather rigid federal acquisition regulations with on-site contractors, which in turn limits decision flexibility. Although efforts are being made to centralize some logistical support activities, as noted in Chapter 2, each site maintains its own stock of spares and to some degree its own channels of procurement. The likelihood of duplication of effort therefore clearly exists. With encouragement by the CMA through contract monetary incentives and the passage of time, there may be improvement in the communications, coordination, and cooperation among sites. This is happening, but it may not necessarily eliminate the negative effects of duplication of effort or divergence in configuration among sites. At the very time that uniform standards would serve the program well, site-focused management utilizing two contractors has led to some divergence in hardware and software standards between sites. This problem is exacerbated by further separation of technical supervision at CMA headquarters from project management oversight. As equipment ages and some sites are decommissioned, the interoperability of sites and interchangeability of components will become increasingly important to continuing operations. The committee views the growth of intersite equipment and systems divergence as a weakness of incentive-driven, site-focused management. Finding 19. Adoption of the site-focused management system, while promoting some improvements in the workforce culture and performance at chemical agent stockpile incineration facility sites, risks allowing a degree of independence in contractor decision making and action that could result in a loss of a critical capability for interchangeability crucial to continuing operability. Recommendation 19. The Chemical Materials Agency should exercise sufficient centralized management control to ensure that there is appropriate programwide interchangeability of resources important to the continuing operability of chemical agent disposal incineration facilities. (Tier 1) Obsolescence Management The interchangeability and exchanging of parts and knowledge among sites can facilitate continuing operability as time passes, equipment wears and ages, and employee expertise dissipates. While site-focused obsolescence management systems deal with issues at a tactical level, programmatic performance still requires centralized direction and oversight from the CMA using both contractual incentives and some command and control directives. However, in spite of a strong incentives program, management system complexity, process diversity, and site independence can impede optimum realization of the total program potential for success. The Assembled Chemical Weapons Alternatives (ACWA) program sites (in Pueblo, Colorado, and Lexington [Blue Grass], Kentucky) are unlikely to benefit from interaction with incineration sites as far as spare parts interchangeability, although there is potential for interdependence on selected equipment items between the two sites. However, other experiential learning during the incineration programs
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment may apply, for example, in training, maintaining a safety culture, safe practices in working in contaminated areas, configuration management, and documentation. Effort by the CMA will be needed to detect and overcome some natural, negative tendencies inherent in the site-focused management approach. It may even be necessary to limit site manager independence in selecting replacement equipment and software to ensure maximum interoperability. It is important that ECPs be shared between sites so that problems that could well affect more than one site need be solved only once and in a coordinated manner. Evidence shows that this objective has been recognized and appropriate action taken to maximize sharing under the mandatory lessons learned program.10 As noted in previous chapters, the site-developed strategies for obsolescence management have significant differences among the sites. The CMA is encouraging interchanges in this regard among the sites, and hopes that plans may be improved by understanding approaches at the other sites. The CMA is in the process of building a programmatic strategy to deal with the management of obsolescence but this is still evolving. Finding 20. The Chemical Materials Agency has initiated an obsolescence management program that is based on using contractual means to incentivize chemical agent stockpile incineration facility site contractors to develop site-specific programs and then to share approaches and specific strategies across sites. Although the program is still evolving, the sites have begun to approach some obsolescence issues collectively. Recommendation 20. The Chemical Materials Agency should strengthen its obsolescence management strategies programmatically and at each chemical agent stockpile incineration facility site to incorporate measures for intersite coordination and cooperation to facilitate continuing operability through to the completion of the chemical stockpile disposal program. (Tier 1) ORGANIZATIONAL MANAGEMENT AND SPECIALIZED EXPERTISE RESOURCES Continuing operability is as much a function of personnel management challenges and issues as it is of equipment and supporting hardware concerns. The committee noted that the chemical stockpile disposal program, having evolved over time from JACADS operations to the present circumstances, has seen the migration of experienced people from site to site, and from employer to employer. In many cases this has worked to the program’s advantage, since the required training efforts were minimized for the experienced managers and craftsmen moving from JACADS to other sites. But this situation has also raised questions regarding the efficacy of the contractor-operated, site-focused management system as practiced. The chemical stockpile disposal program is small enough that many, if not most, of the senior people involved know and have worked with and/or for each other. It becomes especially important that the CMA monitor site activities with sensitivity to the possibility of there being too close a working relationship between the contractor and the government representative. Further, much of the specialized knowledge and capability have moved from the old PMCD organization to the distributed site structure. Specialties and expertise are not equally duplicated at each site, so there is a need to share experts and knowledge across all the sites in response to operational or other problems. Performance Indicators, Incentives, and Their Effectiveness Reported worker safety performance has continued to improve significantly under site-focused management. For example, in 2001 the OSHA recordable injury rate (RIR) was around 2.5 per 200,000 hours worked for TOCDF—the only facility operating at that time.11 As of July 31, 2006, the programmatic RIR for all sites was 1.25, with TOCDF at 1.54. The ANCDF site safety record is commendable, with a present RIR of 0.73 while working over 9 million consecutive hours without a lost work day incident. The program is highly incentivized, with 75 percent of the money allocated to safety and surety going to safety. The total safety and surety component carries the highest weight of any incentive categories under award fee rules, 30 percent (CMA, 2005). It is not possible to know in an absolute sense how much improvement has been achieved in accident prevention because of the effect of incentives, but the committee believes that qualitatively substantial progress has been made. Both EG&G and WGI managements have, at their own initiative, adopted a “flow down” process whereby corporate incentive fee earnings are shared with all employees on site. Annual employee payments under this plan at TOCDF were estimated to be approximately $500.12 Awards were about $500 to $600 per year per employee at ANCDF. 10 Raj Malholtra, CMA, presentation to the committee, April 7, 2006. 11 Kevin Flamm, briefing, September 13, 2006. Note that the current RIR for the overall chemical manufacturing industry is 3.5 and the current programmatic RIR metric is 1.75 for the stockpile disposal facilities. 12 Site briefings by Terry Thomas, engineering manager, EG&G, and Edward Banks, site contractor, lessons learned specialist, EG&G, and discussion with the committee, March 3, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment Command, Control, and Communications Channels Site-focused management tends to complicate command, control, and communications problems. Although site contractors have a complex and large group of personnel, organizations, and agencies with which communication must be maintained, there is no real “communications central” serving to receive and relay messages. The TOCDF site contractor listed the following organizations and agencies with which communications are routinely exchanged, and other site operating contractors have similarly demanding situations:13 EG&G corporate office; CMA representatives on site and at Edgewood Area of Aberdeen Proving Ground; federal and state regulators; OSHA; Deseret Chemical Depot representatives; community and political leaders; other sites and contractors; and numerous suppliers and subcontractors. Under existing organizational circumstances, effective communications are highly dependent on voluntary cooperation that is usually forthcoming. The committee considers that in spite of its complexity and general lack of structure, the communication channels are working reasonably well at all the sites visited. Lessons Learned The lessons-learned program has been reinvented. The original program, although it remains available, is used only rarely. No new entries to this program have been recorded since January 2002. For roughly two years from 2002 until 2004, there was no lessons learned program in regular use. The original program was useful in that it was common across sites, but not well used for a number of reasons. First, it was perceived as bureaucratic and not site-specific. Second, the program was expected to function largely as a standalone software system with very little human intervention. Third, the user interface was not particularly suited to the ultimate users (i.e., those who were looking for new ideas to implement). Finally, active implementation of lessons learned was not incentivized by management. All of these factors have been shown to be characteristics of low utilization (Voit and Drury, 2006). A new program that addresses most of these issues has been launched similar to the successful Department of Transportation (DOT) and Department of Energy (DOE) systems. The new system appears to be well designed, and the responsible site managers report both regular additions to the database and increased usage by staff. Frequent communication between sites and with the WGI central library of lessons learned have ensured prompt notice of new entries and quick availability of filed data. To date, the full process has not been formalized, and there has been no regular analysis of input data.14 Continuing operability is not yet represented in the new system’s limited database. Lessons-learned programs are not the only way of capturing deviant conditions and potential solutions. Accident and incident reports are useful in themselves even though many form the basis for lessons learned. They alert people to potential safety issues so that the same adverse event is not repeated inadvertently. Near-miss reporting systems can be even more proactive as they allow personnel to avoid potential events as well as actual events. Finding 21. The current lessons-learned system is much better organized and user-friendly than the original system, and is actively used to retain past and current programmatic knowledge of operational and hardware improvements. Recommendation 21. The current lessons-learned program should be continually evaluated and improved as appropriate to ensure the safety and continuing operability of the chemical agent stockpile incineration facilities as obsolescence challenges increase. Wider topical aspects should be incorporated, including near-miss information and root cause accident analyses. Provision should also be made for incorporation of lessons learned into all training programs, as well as for incentives at the individual employee level when appropriate contributions to the lessons-learned program are made. (Tier 2) Configuration Management Effective continuing operability planning requires careful attention to configuration management across sites if the benefits of interchangeability of parts and expertise are to be maintained. Although, as noted above, configuration management remains within the purview of the PMCSE, the committee observed that some divergence of hardware and software standards between sites has occurred. FUNDING Department of Defense and congressional officials have expressed concern regarding the escalating cost of the chemi- 13 Terry Thomas, engineering manager, EG&G, question-and-answer session with the committee, March 2, 2006. 14 Site briefing by Edward Banks, site contractor, lessons-learned specialist, EG&G, and discussion with the committee, March 3, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment cal stockpile disposal program. Chemical stockpile demilitarization is safety and schedule driven. While cost can never be ignored, it has been subordinated to higher-priority project purposes. Site contractor contracts and incentive plans are drafted consistent with this principle. The nature of the chemical stockpile disposal program suggests a level-of-effort approach to resource management, since plants are highly automated and individual disposal campaigns for specific munitions with a particular agent fill can proceed for several months. It is difficult and inefficient to accomplish these “higher purposes” in a climate of limited funding and funding uncertainty beyond the current budget year. With pay rates known and most other cost factors reasonably estimated based upon experience and known circumstances, a relatively steady cash flow projection is possible. The expenditure rate is insensitive to the rate of production. For Fiscal Year 2006 the four incineration sites were required to lend $150 million to other DOD programs. Program officials doubt that this money will be returned. Even more onerous is a proposed $300 million cut in the Fiscal Year 2007 budget. Continued adequate funding for the operating facilities to ensure safe and environmentally compliant operations is essential. Suspending operations at any one of the operating facility sites would exacerbate obsolescence issues, unduly prolong the destruction schedule, and substantially increase program life-cycle costs. Risk analyses, the results of which have been shared repeatedly with the public, show that continued storage of munitions and bulk agent entails more risk than do demilitarization operations (NRC, 1997). Suspension of operations at any chemical agent disposal facility could be expected to generate public and political concern. Finding 22. Factors impacting the chemical stockpile disposal program include: scheduling pressure driven by compliance with the Chemical Weapons Convention; safety demands of dealing with highly toxic materials; requirements of detailed and demanding environmental permits; high public and political visibility; and a mandate to minimize risk to the public, to workers, and to the environment. To ensure the continuity of operations in view of these circumstances, a stable workforce and a stable, continuous source of funds are required. Failure to provide for funding continuity will undoubtedly lead to program interruption and adversely affect the completion date for demilitarization operations as well as program costs. Adequate, stable, and dependable funding of the chemical stockpile disposal program is an essential element of program success. Recommendation 22. The Department of the Army, Department of Defense, Office of Management and Budget, and Congress should recognize the critical need for adequate, continuous, and predictable funding of the Chemical Materials Agency as a basis for operational planning essential to accomplishing the mission of chemical agent stockpile disposal. (Tier 1) IMPACTS ON CLOSURE Closure of the four incineration facilities will begin at least four to six years from the date of this report. Planning for closure is just getting underway at TOCDF and is still in preliminary stages at the other facilities.15 The lessons learned at JACADS and provided in the NRC report on closure will serve as a basis for closure planning (NRC, 2002). If the closure operations are the same or similar to those carried out at JACADS, certain key pieces of equipment will have to be fully operational for a period of one to three years after completion of the agent disposal mission. The operational time required for each system will depend in part on how the secondary waste is managed during stockpile processing operations. Closure will be expedited if obsolete, no longer needed equipment can be disposed of while disposal operations are still in progress. Industry practice is to retain only necessary equipment depending on the end use of a facility. In general, the practice in commercial industry is to close a facility to an industrial standard unless the intended end use dictates otherwise. Thus, early decisions on the end-use standard for each disposal facility to be closed would be helpful. The equipment that may be required during closure of the incineration sites will include, but not be limited to, monitoring equipment, the metals parts furnace and its ancillary process equipment, the DFS and its ancillary process equipment, and the pollution abatement systems (PAS). The two ACWA sites, Pueblo and Blue Grass, are still in the design phase. In those cases it is possible to consider closure during design, which will facilitate the closure process. Obsolescence at these sites, as well as at Newport, should not become a major consideration; however, continuing operability will remain a challenge. Finding 23. Plans for mitigating the obsolescence of key equipment that will be required for closure of chemical agent stockpile incineration facilities, such as the LIC and MPF furnaces with their PAS/PFS systems, have not yet been developed. Recommendation 23. Key equipment required for closure of chemical agent stockpile incineration facilities should be 15 Communication between Bob Karlik, TOCDF, and Peter Lederman, committee member, March 2, 2006.
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Assessment of the Continuing Operability of Chemical Agent Disposal Facilities and Equipment identified now and steps to mitigate and manage obsolescence should be extended to include that equipment’s operational life. (Tier 3) COMMUNITY AND REGULATORY ISSUES Good to excellent relations with the adjacent community and regulators were indicated at all of the incineration sites. Active public outreach programs are satisfactory for current operations. For example, at the ANCDF site, the site management considers the workers as the first and often best line of communication with the community. Site officials also visit regularly with community leaders, regulators, and state and local policy makers on an informal basis. The management at ANCDF believes that this multipronged program is most successful in gaining, if not support, certainly community acceptance.16 It was not possible for the committee to verify this, but the committee believes this to be the current state of affairs. All the sites are located in different states. While the regulators communicate with one another frequently, each state, and thus each site, operates in a somewhat different regulatory environment. The sites and the PMCSE manage these differences as appropriate. Challenges could arise if obsolete equipment must be replaced with new, different equipment. If this is ruled a major change, it will require cooperation of both the regulators and the community. Depending on the particular situation, this could become a problem. This could occur if changes in the regulations that apply, such as the imposition of the maximum achievable control technology (MACT) regulations, make current equipment obsolete. This could also occur because of changes in operations, such as adoption of new procedures required to handle mercury contaminated material. REFERENCES CMA (Chemical Materials Agency). 1995. The TOCDF Statement of Work Section C-Mod 291. Edgewood, Md.: CMA. CMA. 2005. Award Fee Plan for the Fiscal Year 2006 for the Tooele Chemical Agent Disposal Facility. Edgewood, Md.: CMA. CMA. 2006. Director’s Programmatic Performance Based Incentive (DPPBI) 1 October 2005-30 September 2006. Edgewood, Md.: CMA. NRC (National Research Council). 1997. Risk Assessment and Management at Deseret Chemical Depot and the Tooele Chemical Agent Disposal Facility. Washington, D.C.: National Academy Press. NRC. 2002. Closure and Johnston Atoll Chemical Agent Disposal System. Washington, D.C.: The National Academies Press. Voit, J.R., and C.G. Drury. 2006. Sociotechnical aspects of lessons learned programs. Proceedings of the 16th World Congress on Ergonomics. Maastricht, The Netherlands: Elsevier. 16 Communication between Timothy Garrett, site project manager, ANCDF, and Peter Lederman, committee member, May 30, 2006.
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Representative terms from entire chapter: