PMCD "spin" on CWWG's Schedule Summary, based on the internal Army document, "Operations Schedule Task Force 2000: Final Report"

The following quotes by Greg Mahall, PMCD spokesperson, appeared in the May 1, 2001 issue of the Hermiston Herald.

"Mahall, however, told the Hermiston Herald that Williams used 'worst-case input' to draw incorrect conclusions, then presented them as fact to members of the Senate."

"'Williams took the worst-case scenarious possible, put them in his machine, and drew conclusions. Then he presented them as fact when indeed they are not fact,' Mahal said"

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Response to the PMCD Claim that the Schedule Report Presented to the Senate During Testimony was a "Worst-Case Scenario" Document.

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The following sections contained in the 2000 Operations Schedule Task Force Report reflect clearly that the "Report" was NOT "worst-case scenario" in the authors intent nor in the data presented. Rather, the information contained in the Report was a candid assessment of the Task Force's projected operational capability of the follow-on baseline incineration sites based on the 10 years of JACADS experience and the 5 years of TOCDF experience.

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32 Sections Which Disprove PMCD's Characterization of the 2000 Schedule Task Force Report as "Worst-case Scenario":

2. Background:

d. "The basis for the CSDP operations schedule has evolved since operations began at JACADS in July 1990. In the fall of 1993, a task force was assembled to update the basis of calculations of the CONUS operations schedules based upon result of the recently completed OVT. Results of this assessment were documented in reference 1a. In 1996, to support an update to the Acquisition Program Baseline (APB) and to the programmatic Life-Cycle Cost Estimate (LCCE), the operations schedules were further revised to incorporate lessons learned from JACADS." (p. 4)

e. "In 1994, Science Applications International Corporation (SAIC) developed an operations model. The model includes consideration for : ramp-up rates, shift scheduling, maintenance down time, environmental restrictions, changeover, plant availability, and projected contingencies. The operation model outputs campaign durations which in turn are provided for generation of operational Life Cycle costs." (p. 4)

3. "In September 2000, a new task force was formed to reassess and update the assumptions used in the development of the operations schedules. The charter of this task force was to evaluate the actual performance data and operational experience to date from JACADS and Tooele Chemical Agent Disposal Facility (TOCDF) and to determine recommended changes or adjustments to the assumptions. The task force went further to identify key areas of schedule risk that could not be readily quantified. Finally the task force identified a series of initiatives to either increase the likelihood of meeting the revised schedule or, in some cases, to improve the schedule. (p.4)

4. The purpose of this memorandum is to document the latest recommended revisions of the assumptions, calculations, or direction that should be used for the development of operations schedules. (p. 4 )

COMMENT: Nowhere in the above narrative (or anywhere in the "Report") do the words "worst-case scenario" appear nor is there any implication that the data contained in the Report is in any way a "worst-case scenario." In fact, with the exception of the phrase, "....or, in some cases, to improve the schedule" the Report clearly states the data is based on operational experience as were the 1990 and 1996 reports. And, the phrase, "Finally the task force identified a series of initiatives to...increase the likelihood of meeting the revised schedule" indicates that without these "initiatives" being implemented successfully, the schedule reflected within the Report may not even be attainable! All references made in "Attachment 1" that identify schedule component areas that might be improved are categorized as "possible schedule improvements" and none claim a known capability to achieve any improvement. This is not a worst-case scenario. Worst-case scenario intent would have to indicate that included in the Report are identified areas of known schedule improvement that, although capable of being achievable, have not been factored in the data. No such references exist within the document.
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Section:

5. Basis of Calculations:

a. Processing Rates : Operations Schedule Task Force 2000

"...Based on this analysis, the task force recommends that the previously used full processing rates be revised as follows to better reflect actual operational steady state rates demonstrated at JACADS. To better reflect steady state conditions, ramp-up periods and major maintenance outages were removed from consideration. The actual steady state production data for the JACADS campaigns demonstrate that the 1996 full rates remain overly optimistic for use in estimating the duration of operational campaigns." (p. 7; )

Comment: In a worst-case scenario you don't reflect actual rates, you assume worse than actual rates and you don't ignore activities like "ramp-up rates" and problems like "maintenance outages." In a worst-case scenario you would attribute longer "ramp-up" periods and assume more (or at least as many) "maintenance outages" than were experienced in the operational history at JACADS/TOCDF.
"Actual production data" does not imply worst-case scenario, but shows the data is based on what it says, "Actual production data."
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"...The differences in factors in projectile rates reflect the actual differences seen in JACADS operational data. For example, full use of the gimbaled cam socket for unfuzed projectiles was assumed, which resulted in improved steady-state rates. Processing information from the projectile campaigns using the old nose closure removal station was discounted and not used. In addition, mustard processing experience was reviewed in some detail. (p. 7)

Comment: In a worst-case scenario, you don't ignore the actual data and assume a new technique will work all the time, you do just the opposite!
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...JACADS approached resolution of these problems by securing RCRA approval and successfully testing the processing of undrained projectiles in the metal parts furnace. This approach greatly increased processing rates from M60 105mm projectiles to M2A1 4.2 inch mortars but increased the Metal Parts Furnace (MPF) cycle time by nearly a factor of three. It is therefore, anticipated that HD projectile-processing rates will be reduced to approximately a third of 1996 scheduled rates. The bulk mustard stockpile lacks quantification/characterization to fully define the amount of HD which has turned to sludge in ton containers. It is anticipated that if over 10% heels remain after ton container drain efforts, HD TC processing rates could be impacted. However, the mustard bulk processing rates were not decremented to account for this possibility. (p. 8) (Major Potential Schedule Impact - Not factored in)

Comment: In a worst-case scenario, you don't ignore a known factor that is "anticipated," you include it!
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b. Ramp-up Rates : 2000 Operations Schedule Task Force:

The 2000 Operations Schedule Task Force could find no data to support changing the current ramp-methodology. It was noted by the task force that there may be a need to conduct additional trial burns (gelled rockets, etc.) The current duration of two weeks per furnace does not include these types of additional requirements. (p. 14)

Comment: In a worst-case scenario, you don't ignore a known factor that "might be needed," you include it!
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c. Shift Scheduling : 2000 Operations Schedule Task Force:

The 2000 Operations Schedule Task Force could identify no basis for changing the assumption used in the 1996 model and therefore recommended no changes to the current shift scheduling assumptions. The use of the JACADS Steady state rates is based upon a 7-day work week. Therefore, the task force recommended elimination of the 14.3% contingency built into the 1996 model." (p. 14 )

Comment: In a worst-case scenario you don't eliminate a "contingency factor" from an earlier model, you include it!
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f. Reject Munitions : 2000 Operations Schedule Task Force:

...From JACADS experience, the amount of reject munitions has been significantly reduced as the result of implementation of the Gimbaled Cam Socket (GCS)...the task force recommended that two weeks would be retained for each agent type to process all rejected projectiles. (p. 16)

Comment: Actual experience at JACADS improved from needing more than two weeks to treat rejected munitions to needing about two weeks for this activity. Therefore, maintaining the time actually needed, based on actual operations, is not a worst-case scenario, but a reasonable assumption.
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g. Leaking Munitions : 2000 Operations Schedule Task Force:

The Operations Schedule Task Force did not have an updated count of leaker items. Therefore, the original assumptions for leaker items were retained...A recommendation to assess leaker processing assumptions is provided at Attachment 1. (p. 17 )

Comment: It is a known fact that there have been a certain number of leakers at the assembled CW munitions sites since 1996. It is a simple number to obtain through SBCCOM. To ignore this factor, based on not having the accurate number, is not a worst-case scenario, but equates to assuming no additional leakers since the 1996 report, which is not only false but could be considered a "best-case scenario."
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I. Secondary Waste: (Major Potential Schedule Impact - Not factored In)

(1) 1996 Model:

It was assumed that the generation and process of secondary waste would not have any impact on the operations. (p. 17)

(2) 2000 Operations Schedule Task Force:

The 2000 Schedule Task Force did not change this assumption. This decision was predicated on the assumption that DPE suits would be disposed of in the MPF in a manner which did not impact on plant productivity. The task Force also assumed that charcoal would be disposed of during closure and that no schedule impact from its treatment during operations was justified. (p. 17-18 )

Comment: Secondary waste is a huge problem in Oregon and to a lesser degree in Alabama and Arkansas. The abandonment of the DUN and the problems with the BRA create a significant potential schedule impact. To "assume" no impact on schedule arising from this aspect of de-mil activities is not a worst-case scenario.

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j. Changeover:

(1) 1996 Model:

The agent and munition changeover guidelines in the following summary table reflect the recommendations made by the changeover task force assembled in 1994. These recommendations were based upon best available engineering judgment at the time of the 1994 assessment. (p. 18)

(2) 2000 Operations Schedule Task Force:

The following table also provides the results of the 2000 task force based upon the changeover data available from JACADS and the assumptions below: (p. 18 )

Comment: Using operational data available does not equate to a worst-case scenario. To create a worst-case scenario, the data available would have to be multiplied by a certain factor.
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k. Slag Removal.

(1) 1996 Model:

The baseline schedule for all sites except JACADS did not include time for manual removal of slag. This assumption was predicated on the conclusion that the new slag removal system would work at TOCDF and future sites as designed, eliminating the need for manual slag removals. (p. 20)

(2) 2000 Operations Schedule Task Force:

...The length of an agent campaign and the amount of agent processed through the LIC at the CONUS plants before a required slag clean out will be evaluated by a separate study to determine the effect of slag removals on agent campaign schedules. Although the TOCDF data is currently only for the agent GB, JACADS experience indicates that slag removal for VX and HD agents will be required less often. Thus the current approach is considered a reasonable estimate based upon the current data. (p. 20)

Comment: Obviously there is a lack of data available on the adequacy and performance of the slag removal system for VX and HD, as neither has been processed at TOCDF. Incorporating the assumption contained within the 1996 model into the 2000 model without significant data to back it up, is certainly not a worst-case scenario.
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o. Impact of Stockpile Characteristics: (Major Potential Schedule Impact - Not factored in)

(1) 1996 Model:

The 1996 model did not specifically address stockpile characteristics and its potential impact on throughput rate performance. (p. 22 )

(2) 2000 Operations Schedule Task Force:

Stockpile chemical weapons disposal operations has identified stockpile deterioration issues with chemical agents, explosive components, and metal parts that have been throughput limiters at both TOCDF and JACADS. Three problems have been discovered with GB: gelled rocket fill, crystalline accumulation in GB projectiles, and pressurized/strongly acidic ton containers.

Polymerized mustard issues have been encountered in all projectiles processed at JACADS; mustard difficulties in general were discussed earlier in this report. In addition, two generic difficulties have been encountered with processing explosives from projectiles: tetryl energetics
from HD munitions and mines have a predictable history of detonation; and Comp B bursters from nerve agent projectiles have deteriorated with age and have produced larger than anticipated loose explosive accumulations to clean in processing areas. Process pressure excursions from explosive
component issues are generally within the design limits of the Explosive Containment Room (ECR) and DFS rooms and equipment but are a permitting challenge for RCRA pressure control requirements. Heavy metal difficulties are not generally related to explosives, but have been traced back to metal parts assembly or metals contamination from fill techniques or past ton container usage. HD munitions have been assembled with silver solder that has produced high metal limits in brine. Mercury has been found in HD projectile fills. TOCDF has found significant levels of metal residues in a small number of ton containers, apparently residues form past ton container usage without complete clean out prior to refilling with newer agents. The 2000 task force did not decrement production rates based upon these factors--however, recommendations are provided at attachment 1 to address several of these issues. (p. 22-23)

Comment: This is a major omission in their 2000 schedule projection. It identifies significant known problems with a wide range of agent and munition types and states that none of these factors were incorporated into the 2000 schedule review. Clearly, dismissing these factors shows the 2000 Report is not a worst-case scenario.
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p. Operations Schedule Task Force--Assessment of Initial Workforce Learning Curve.

(1) 1996 Model:

The 1966 model provided an initial workforce learning curve containing a ramp-up of staff as well as a ramp-up of processing rates. (p. 23)

(2) 2000 Operations Schedule Task Force:

One of the key lessons-learned from both the JACADS and the TOCDF start-ups is that there will be a degree of initial inefficiency as a wholly new workforce begins to truly integrate and learn to operate a chemical demilitarization facility. There are many factors that contribute to this, including:

* ...Diagnostics/trouble shooting and repair will initially take longer.
* The workforce...has to learn how to truly work together...
* ...over-reacting to unusual circumstances.
* ...it is difficult to attract experienced operations and maintenance personnel...thus, the general experience level may be lower than that encountered in other industries.
* ...a demanding integration...not commonly experienced at commercial industry. (p. 23-24)

...further compounded by the addition of new process equipment...(p. 24)

...earlier versions of operational schedules in chemical demilitarization did not adequately accommodate the inefficiency that should have been anticipated given these circumstances. That said, the Task Force could not develop a supportable and defensible inefficiency factor to apply on top of the other scheduling assumptions, nor could they develop a duration to apply this factor across. (p. 24)

Additionally, the task force did not consider normal attrition as having an effect on costs or schedules. (p. 24)

Comment: Ignoring these factors shows the 2000 Report is not a worst-case scenario.
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. Areas for Potential Operations Schedule Improvements or Risk Mitigation:

...During the task force meetings there were many areas of uncertainty identified where current operational data is not available to quantify the potential impacts to operations schedules...(p. 24)

 

Comment: "Worst-case scenario" would require attributing some best-guess quantification to the areas of uncertainty--that's what worst-case scenario implies--that what you don't know will have an impact of "X amount of time" based on what you do know. The 2000 Report allows these uncertainties to have no impact on the schedule projections.
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2000 Operational Task Force Report - Attachment 1

Areas of Future Work to Mitigate Risks or to Assess Potential Process Improvements

2. Heel Determination in HD bulk munitions at TOCDF, UMCDF and PBCDF :
(Major Potential Schedule Impact - Not factored In)

...the task force assumed that ton containers would be able to be drained sufficiently to support current feed limits to the MPF......this assumption may be optimistic. (p. 25 )

The potential throughput rate ramifications of partially or totally solidified ton containers would be significant. Either an alternative process would have to be designed, permitted, and installed in the facility, or throughput rates in the MPF would have to be greatly decremented. (p. 26 )

Comment: On page 8 of the Report as noted above it states, "This phenomenon (agent deterioration into a highly viscous sludge) was also experienced to a lesser degree in HD ton containers The bulk mustard stockpile lacks quantification/characterization to fully define the amount of HD which has turned to sludge in ton containers. It is anticipated that if over 10% heels remain after ton container drain efforts, HD TC processing rates could be impacted. However, the mustard bulk processing rates were not decremented to account for this possibility."
To make the assumption that, in spite of this experience, it won't be the case at other sites while admitting that if it is at 10% or better, it would have schedule impact, does not reflect a worst-case scenario.
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4. Maximum Achievable Control Technology (MACT) - Mercury (Hg) Ramifications.

PMCD chartered Science Applications International Corporation (SAIC) to examine trial burn and agent/munition characteristics data against the new MACT standards...The draft study...indicates that there are only two areas of potential concern from a compliance perspective--Semi-Volatile Metals (SVMS)--(lead and cadmium) and mercury. (p. 27 )

...several data points exist which indicate that higher mercury feeds should be anticipated... (p. 27 )

...several options ...can be taken to ensure MACT compliance for mercury. These recommendations range from decreasing feed rates to changing the type of carbon used in the PFS to one that is specifically selected for its ability to capture mercury. (p. 27 )

...Task Force concluded that it was premature to project a schedule impact due to compliance with MACT requirements...given the potential ramifications, this issue needs to be more intensively managed... (p. 27 )

...The PFS expert groups should also be chartered with assessing potential mitigating actions where appropriate, to include the potential disposal problems associated with using carbon in the PFS that is mercury selective. (p. 27 )

Comment: Ignoring "potential disposal problems" does not reflect a worst-case scenario.
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5. Complete Nitrogen Oxide (Nox) Assessment for Potential Impacts.

The Nox limits contained in the current Pine Bluff Chemical Disposal Facility (PBCDF) Air Permit could severely curtail production. This issue could be moot if the production is actually slowed to the rates specified in the revised operational schedule. Work is underway to develop a major air permit modification to address this issue. (p. 28 )

Comment: Problem exists with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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6. PFS--Potential Availability Impacts.

The...Task Force did not have sufficient information to assess the possible availability impact of the addition of the PFS...However, the Task Force recognizes that the PFS is a prototypic unit--and, prototypes historically have significant performance issues associated with them. It is expected that the PFS will contribute initially to below-projected performance. Given the prototypic nature of the PFS and the lack of industrial experience with units of this type in this application, world-class expertise should be assembled to assist in the development of test plans, operational conditions reviews, and initial operations. (p. 28 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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7. Operational Issues with Gelled Rockets.

...However, TOCDF experience with processing gelled rockets at a rate of one per hour identified a series of operational issues which must also be addressed to achieve higher feed rates. (p. 29 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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8. Furnace Pressure Control Requirements--Analysis of Permits.

Munitions with tetry-containing energetics have demonstrated a propensity for detonating in the DFS...a facility's RCRA permit must give one sufficient leeway to operate with these rapid short term pressure excursions. The...Task Force did not assume any throughput rate impact or limitation based upon low-grade detonations within the DFS. (p. 29 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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9. Resolve Potential UMCDF and PBCDF Trial Burn Limitation Issue (Agent Tank Issue).

The...Task Force discussed how best to time and execute agent trial burns given the configuration of the demilitarization facilities' ducts and stacks. If sampling cannot be conducted in each furnace duct (which, based upon anecdotal information provided to the Task Force, appears to be the case for Anniston, Umatilla and Pine Bluff), then the buffering approach used at JACADS will have to be employed at these sites This will be problematic given the reduced size of the agent storage tanks at those sites...Anniston had already coordinated approval for the use of the major spill tank (1,300 gallons) in lieu of the normal agent tank (500 gallons)...However, similar measures may not be underway at UMCDF or PBCDF--and, it is uncertain if regulatory acceptance of the change at those sites can be obtained. The...Task Force assumed that trial burns can be conducted without additional restrictions from the smaller agent tank. (p. 30 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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10. Reassess # of Trial Burns Given Stockpile Characteristics (For Instance, Additional Trial Burns for Gelled Rockets)?

The presence of gelled rockets within the stockpile suggest that the original trial burn strategy for the DFS must be revised to provide maximum flexibility. (p. 30 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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13. Mustard Conditioning.

The...Task Force recognized that draining of mustard projectiles will in all probability, not be executed given the polymerization of mustard observed at JACADS. However, it is essential that mustard ton containers be drained--if they are not, the residence time in the MPF would have to be increased substantially, with a resultant impact on the plant schedule. (p. 32 )

As discussed in attachment 1, item 2 (above), a characterization program has been recommended to determine if the mustard is drainable. Assuming that it is, it is also important that the mustard conditioning system work to ensure that the mustard is in liquid form when the bulk item is punched and drained. Significant effort has been expended on design and testing to date. However, the mustard conditioning units (to include the procedures for operations and maintenance) must be considered prototypical, with performance issues anticipated as the units are first deployed and used at the Deseret Chemical Depot. No scheduled downtime or reduced availability has been assumed in the operations schedules for Tooele or for any other site. (p. 32 )

...This represents an additional risk to mustard projectile processing that requires assessment. (p. 32 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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14. Understand Aluminum Phenomena (Kiln).

During the processing of both GB and VX rockets at JACADS, significant amounts of solidified aluminum built up on the Heated Discharge Conveyor (HDC) and the discharge gates from the HDC system...Truly understanding the aluminum phenomena is essential in projecting future rocket destruction operations. (p. 32 )

Comment: Significant issues exist with no fix in place, yet no schedule impact is attributed. Therefore, this is not a worst-case scenario.
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15. Spent Decontamination Solution (SDS) Offsite Assessment, Rebricking Improvement. Pre-emptive Replacement/SDS Management (Isotainers?)

The...Task Force assessed the experiences with refractory life and the impact this can have on operational schedules. Currently, furnaces are rebricked upon failure and not upon a prescribed frequency. It was agreed that, in the future, the stockpile program should consider pre-emptive refractory replacement. (p. 33 )

...explore other disposal options for SDS. The...Task Force agreed not to schedule additional downtimes for rebricking except when an agent campaign reached 2 million pounds of agent processed between agent changeovers. (p. 33 )

Comment: "Consideration" of significant issues with no schedule impact attributed does not qualify as worst-case scenario. Assuming that after consideration the approach would fail, would be worst-case scenario.
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16. Assessment of MPF Refractory (Based Upon TOCDF and JACADS Failures).

Both JACADS and TOCDF have experienced unscheduled maintenance downtime because of refractory failure associated with the MPF. The CONUS design includes more anchors for the refractory walls based upon JACADS experience but the door is still a problem (especially the exit door seal)...The...Task Force did not include additional time in the schedule for rebricking the MPF. (p. 33 )

...An assessment should be made of the MPF refractory anchors....the assessment should include the recent TOCDF exit door seal and refractory shifting failures in addition to the JACADS wall failure. (p. 34)

Comment: Experiencing specific problems, directing an assessment be done, but discounting continuation of the problem before the assessment is completed is not worst-case scenario modeling.
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19. Agent Changeover Duration Integrated Product Team (IPT).

The...Task Force members discussed at some length the issue of agent conversions and changeovers. While all members agreed that the length of time needed to convert represented significant growth over previous estimates, no member was able to identify defensible changes in the process or the requirements that could be used to justify using a duration shorter than that experienced at the JACADS--17 weeks. The Task Force concluded that any meaningful reduction in the duration will require a change in the requirements for changeover and will not be achieved simply through process optimization. (p. 35 )

Comment: Using identified data to project specific time requirements (ie: changeover) is not worst-case scenario modeling, it is modeling based on empirical data.

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20. Staffing/Personnel for Carbon Changeout.

The...Task Force did not include time specifically targeted for carbon changeout...The...Task Force recognized that, if such a concept is not pursued, it is conceivable that additional time will be required in the schedule for carbon changeout. (p. 35 )

Comment: Recognizing the need to factor in additional time for this activity and not allotting such time in the Report is the opposite of worst-case scenario modeling.
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21. Reassess Leakers Based on Actual Numbers of Leakers in Storage: Assess Leaker Processing Experience.

The number of known containerized leakers in storage has changed since the last operational schedule was created. Therefore, the operational schedule needs to be adjusted to reflect the current configuration and condition of the stockpile. (p. 36 )

Comment: On page 17 of the Report it states, "The Operations Schedule Task Force did not have an updated count of leaker items. Therefore, the original assumptions for leaker items were retained...A recommendation to assess leaker processing assumptions is provided at Attachment 1". (p. 17 )
The number of leakers could only have risen since the 1996 report. Not attributing any additional time to the schedule for this known factor is not worst-case scenario modeling.
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23. Continue to Press the Chemical Personnel Reliability Program (CPRP) / National Agency Check (NAC) Issue.

The...Task Force did not address any schedule ramifications due to potential personnel issues with obtaining and retaining sufficient numbers of personnel who successfully complete the NAC process and obtain entry in the CPRP program. This issue remains one of potential impact to the demilitarization schedule and must continue to be tracked and worked by PMCD Management to ensure that the current assumption in the operations schedule...remains valid. (p. 36-37 )

In addition, there has been discussion at some sites that the local Commander may want to keep the duress code classified CONFIDENTIAL. This will require even more onerous review and investigation of personnel, potentially exacerbating the NAC issue... (p. 37 )

Comment: These are highly anticipated factors that will impact schedule. Not attributing any additional time to the schedule for these factors is not worst-case scenario modeling.
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25. Metal Content in Brines.

JACADS has observed higher-than-anticipated metal content in Pollution Abatement System (PAS) brines. This, combined with feed limitations to the Brine Reduction Area (BRA), has resulted in the need to store and blend brines to ensure permit compliance. If brine storage capacity and permit conditions do not allow a similar process, then plant processing may have to be restricted as the BRA becomes a rate-limiting operation. The...Task Force did not decrement plant productivity due to BRA limitations. (p. 38 )

Comment: This is a highly anticipated factor that will impact schedule. Not attributing any additional time to the schedule for this factor is not worst-case scenario modeling.
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26. Changes in Agent Standards.

The Army is currently working on an update to agent standards. These changes in standards are anticipated to result in a lowering of the Time Weighted Average (TWA) and Immediately Dangerous to Life and Health (IDLH) standards, and the addition of a Short-Term Exposure Limit (STEL). For nerve agents, if the demil program continues to maintain a requirement to monitor and react at 20% of the action level, then a lowering of the TWA standard is projected to pose technical difficulties, with possible schedule and cost ramifications. If, however, the Limit of Quantification (LOQ) is maintained at the same absolute value, then the change can probably be accommodated without impact.

While no values have been published on mustard, conversations with Army Team members indicate that a more severe reduction is being considered. If this anecdotal information turns out to be accurate, then the ability of the monitoring system to meet these new standards is not clear.
The...Task Force has not included any schedule impact due to monitoring issues or changes. (p. 38 )

Comment: This is a highly anticipated factor that will significantly impact schedule. Anecdotal information indicates the factor will come into play. Not attributing any additional time to the schedule for this factor is not worst-case scenario modeling.

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The following 7 sections reflect possible schedule improvements from what is cited in the "Report" but, none have been identified as being able to be implemented with any degree of certainty. Had any been identified as certain to be achievable, and to improve schedule, but not factored in the "Report" data, the specific factor would be considered "worst-case scenario".

5. Basis of Calculations.

d. Co-Processing/Complimentary Processing

(2) 2000 Operations Schedule Task Force:

...Several members expressed strong concern that complimentary processing created severe dilution of focus and effort without a demonstrable benefit. Therefore, the task force did not include complimentary processing in its LCCE update. PMCSD may want to revisit this task force decision upon completion of the GB campaign at TOCDF. (p. 15 )

Comment: Complimentary processing was only ever contemplated at TOCDF and Oregon. Should it be reinstated as a procedure it would only impact those two sites. From the language presented it would be of no "demonstrable benefit" even if reinstated. Experience however shows that PMCD uses "Co-Processing" as a rationale for projecting better throughput rates when asked to identify such potential improvements.
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e. Post Trial Burn Rate

(2) 2000 Operations Schedule Task Force:

The 2000 Operations Schedule Task Force recommended the post trial burn rate be changed to 1/2 Full Rate with the duration remaining at one year. This change was predicated on moving from the design-based "average rate" used in the 1996 model to using one-half of the steady-state rate demonstrated at the JACADS. (p. 15)

It must be recognized that the duration of the post-trial burn period has significant impact on the operational schedule duration. An initiative has been included at Attachment 1 to explore if improvements in the trial burn conduct--report generation--report approval cycle can be credibly anticipated. (p. 15)

Comment: This factor would require a Class I permit modification allowing feed rates to increase 25% for the first year after trial burns (from 50% to 75% of the trial burn rate). Although it is unlikely that all follow-on sites would grant such a modification, it is possible that some might. However it must be pointed out that the 50% rate is a long standing restriction that could be viewed by the States as "untouchable." Either way, no elimination of this restriction has been achieved and by leaving the current permit restriction in place in the Report does not equate to worst-case scenario modeling.
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Attachment 1

Areas of Future Work to Mitigate Risks or to Assess Potential Process Improvements

1) Can/Should the Modified Baseline Concept be Used at Anniston for Mustard Projectiles?

" If it can be implemented at Anniston, it may be possible to reduce the projected duration of the mustard projectile campaigns.....may have schedule benefits." (page 25 )

Comment: By not factoring in the "possible" benefits that fall well outside the realm of any degree of certainty does not equate to worst-case scenario modeling.
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3. Should Two Mind Machines be Installed at ANCDF?

...the possibility of going to a two mine-machine configuration will help in increasing the plant capacity to destroy land mines. (p. 26 )

...JACADS replaced the original mine glove box operation with a manual unpacking operation in the Unpack Area (UPA). This concept was adopted after initial efforts to have the mines reconfigured off-line into a monitor-abled container failed. If the unpacking operation could be enhanced, production rates for mine processing could be improved. (p. 26)

Comment: "The possibility," "if" and "could" are all optimistic qualifiers that do not mitigate the current status of information available. Not assuming that these modifications will be deployed does not equate to a worst-case scenario. Rather it affirms that the Report is based on actual operational data.
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11. Assess Changes to Eliminate Post-Trial Burn Restrictions at all Sites.

The current RCRA permits contain a restriction for operations conducted after completion of the agent trial burns but before receipt of approval from the state regulatory agency...Assuming no significant data outliers, throughput could be increased to 75% for the time period between submittal of the initial data and approval of the final trial burn report... (p. 30-31)

Based upon the current permit restrictions, the...Task Force recommended holding the half-rate restriction for one year after completion of the trial burns and for using the steady-state rate instead of the peak rate for the calculation. However, the Task Force endorses rigorous pursuit of elimination, or at least scaling back, of this restriction. (p. 31)

Comment: See section (5) (e) above in this section.
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12. Assess Staffing/Ramp-up Times.

Current contract statements of work specify when the Systems Contracts are to assume expanding the operational hours from one shift to two and eventually to three. The Operations Schedule Task Force did not feel they had sufficient information to recommend a change to these requirements. However...alternate ramp-up and staffing profile may provide schedule or cost advantage. (p. 31 )

Comment: Leaving this factor out as improving schedule, when there is insufficient information to include it, is not a worst-case scenario.
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18. Continue to Press Forward to Reduce Agent Conversions.

The...Task Force conceptually endorses moving forward to try to minimize the number of agent conversions at every multi-agent site. (p. 34)

The potential cost and schedule ramifications of eliminating agent conversions should not be underestimated...Therefore, each changeover eliminated results in a 17-week reduction to the life-cycle schedule... (p. 34)

Comment: The order of agent/munitions campaigns does impact schedule. However there is still a changeover period of 5 weeks anticipated for switching munitions of the same agent which seems to be ignored in this section. Should this change be implemented, a 12-week, rather than a 17-week, reduction would be optimum under best case. Other factors could further alter the reduction to the life cycle schedule.
Either way, leaving this yet to be determined factor out of the Report schedule does not reflect a worst-case scenario model.
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Conclusion : The above excerpts, which cover almost every aspect of the Report, demonstrate the methodology used to generate the data contained in the "revised schedule" charts and accompanying footnotes of the Report. They are the basis of the summary presented to the Senate Defense Subcommittee on April 25, 2001 by the CWWG.
There is absolutely no doubt that the position now being taken by PMCD that this Report is a "worst case scenario" of what schedules can be expected at the follow-on incineration sites is a complete and utter misrepresentation of the document.