Closure, activities

Finding 9. Cost containment efforts in the closure of JACADS are fragmented and have been inhibited by the absence of a total project cost baseline estimate for the Army and all contractors supporting closure activities. A multiyear program cost estimate and schedule that encompasses all closure costs is essential for the cost-effective completion of the JACADS closure campaign. Costs will probably change as the closure project evolves. 

More specifically, current plans call for the Army to place the site under the jurisdiction of the Air Force upon completion of JACADS closure activities. Although it is likely that FWS will ultimately assume stewardship responsibility for Johnston Island, the Army presently plans to provide part-time monitoring staff for a period of 5 years after closure operations have been completed. 

The JACADS closure activities will involve the dismantling and destruction of that portion of the facility that cannot be decontaminated to meet the 5R cleanliness standard. An area decommissioning matrix delineates the areas that will be decontaminated and dismantled, decontaminated and abandoned in place, or solely abandoned in place (U.S. Army, 2000c). The remaining systems, structures, and components (SSCs) that are left in place must meet the Resource Conservation and Recovery Act (RCRA) criteria for decontamination as well as the Army standard of 5R. Areas that were kept free of any agent or hazardous materials will be sampled to demonstrate their cleanliness in accordance with the final closure sampling and analysis plan. 

Such a risk management framework should be in place prior to the initiation of closure activities and should be a dynamic process. The constituent risk models should be updated as new information becomes available and should be responsive to changing and emerging hazards. 

In conducting sampling for preclosure activities (such as the RCRA facility investigation (RFI)) and for closure activities, the Army must either follow accepted published... 

The Decontamination Report provides an overall strategy for removing hazardous materials from the MDB, SWMUs, and AOls. A contamination investigation (RFI), yet to be completed, will provide the detailed characterization data to support closure activities. The characterizations will be based in part on analysis of concrete core borings taken from selected locations. 

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. It might, for example, allow eliminating cross-contamination and reducing disposal costs. 

Closure demolition operations will generate significant quantities of particnlates, which may contain hazardons chemicals, inclnding agent. It is important to evalnate both the need for monitoring (at the location of closure activity and/or at the site boundary) and the potential health and/or ecological risks associated with particulate transport. 

Closure activities will necessarily span several typhoon seasons. A direct strike could leave a tangled mass of material that would be difficult and dangerous to handle. Careful... 

Disposal operations and closure activities are proceeding safely, within regulatory guidelines, according to a published, transparent plan, and without the prospect of bad surprises. 

The closure activities at J AC ADS consist of decontamination and removal of process equipment and building structures and some soil removal and disposal. Although no requirement for groundwater treatment is anticipated at Johnston Island, other CSDP disposal sites might require groundwater treatment, which would affect the closure process and the ultimate postclosure monitoring at those sites. 

Careful and thorough records documenting closure activities should be kept. These records might include ... 

Much effort has been (and continues to be) expended to plan the closure of JACADS in advance and in great detail, and much will certainly be learned in the course of closure operations and facility closeout. With eight continental U.S. sites for disposal of the remaining U.S. chemical stockpile now operating, under construction, or planned, significant economies in time and cost associated with their eventual closure may be obtained through careful and timely dissemination of the lessons learned from closure activities at JACADS. 

The following lessons learned became apparent to the committee during its review of JACADS closure activities to date ... 

Obtain samples and analyses Decontamination plan Program closure activities Facility released ... 

The Stockpile Committee is preparing a report for release in 2001 on the ongoing closure activities for JACADS. This report could provide useful guidance to the Army for making timely closure decisions regardless of the technology selected for implementation at Pueblo. 

Recommendation 3b. The Army should identify toxic agent reaction products likely to be present at potentially harmful levels in liquid-phase process streams, liquid wastes, and solid wastes, including waste streams generated during closure activities. 

There are no commercial TSDFs in Indiana to support NECDF s closure activities. To date, NECDF has been permitted to ship limited quantities of its secondary wastes to out-of-state permitted disposal facilities. However, additional quantities need to be shipped while bulk VX disposal operations are still ongoing so that the wastes from agent destruction operations do... 

Closure Activity ceases and the area is abandoned or returned to another use. 

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