Technical Assistance Report MEMP 1 Technical Solutions Workshop Miamisburg Environmental Management Project Concerning Mitigation of Fugitive Emissions During Building D&D Prepared by The Office of Science and Technology (EM-50) Technical Assistance Team August 13, 2002 U.S. Department of Energy × Office of Environmental Management
List of Acronyms
BWXTO BWXT of Ohio, Inc.
CAP88 Clean Air Act Assessment Package - 1988
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CFR Code of Federal Regulations
D&D Decontamination and Demolition
DOE U.S. Department of Energy
DOE-OH U.S. Department of Energy Ohio Field Office
EM DOE Office of Environmental Management
EM-50 DOE Office of Science and Technology
EPA U.S. Environmental Protection Agency
FAST Functional Analysis System Technique
HEPA High Efficiency Particulate Air
HT Tritium in the form of hydrogen gas
HTO Tritium water vapor
MEMP Miamisburg Environmental Management Project
NESHAPS National Emissions Standards for Hazardous Air Pollutants
NETL National Energy Technology Laboratory
OPEA Ohio Environmental Protection Agency
SAMI Systematic Analytic Methods and Innovations
SARA Superfund Amendments and Reauthorization Act
Acknowledgements The
Technical Assistance Team appreciates the excellent support provided by
the site. Project team members
were always professional, readily available to answer questions, and
unfailingly helpful. Especially
helpful to the team were Joyce Massie, Tim Heath, Jeff Stapleton, Bud
Thompson, and Bill Tonne. In addition, the team would like to recognize the
special efforts of Jim McNeil for effectively gathering and organizing the
information from the technical assistance visit and producing a high-quality
report in a short amount of time. The
team also recognizes the special effort of Steven Bossart in assembling
the members that made up this team.
Table of Contents
EXECUTIVE SUMMARY............................................................................................................ 5
1.0 INTRODUCTION.............................................................................................................. 8
1.1 .... Purpose..................................................................................................................... 8
1.2 .... Scope....................................................................................................................... 8
1.3 .... Approach.................................................................................................................. 9
1.4 .... Background
............................................................................................................ 11
1.5 .... Organization of this Report ...................................................................................... 15
2.0 EMISSION REQUIREMENTS AND DECOMMISSIONING................................... 16
2.1 Emission
Requirements............................................................................................ 16
2.2 Approaches
to Decommissioning............................................................................. 16
3.0 ANTICIPATED OUTCOME AND
CRITERIA FOR SUCCESS................................. 19
3.1 Anticipated Outcome............................................................................................... 19
3.2 Criteria
for Success................................................................................................. 19
3.3
Additional Information Provided............................................................................... 19
4.0 KEY
ISSUES..................................................................................................................... 22
4.1 What is Being Done?............................................................................................... 22
4.2 Why is this Being Done?.......................................................................................... 22
4.3 How is this Being Done?.......................................................................................... 22
4.4 Other Issues............................................................................................................ 22
5.0 IDEAS
IDENTIFIED....................................................................................................... 23
6.0 ANALYSIS
OF IDEAS.................................................................................................... 26
7.0 DEVELOPMENT
OF IDEAS......................................................................................... 28
8.0 TEAM
PROPOSALS....................................................................................................... 38
8.1 Proposal Number 1: Refining Emission Dose Projections and Near-Real-Time Monitoring of Radioactive Emissions................................................................................................................ 38
8.2 Proposal Number 2: Comprehensive Characterization.............................................. 40
8.3 Proposal Number 3: Tenting and Venting................................................................. 42
8.4 Proposal Number 4: Technologies for Size Reduction and Radioactive Waste Packaging 44
8.5 Proposal Number 5: D&D Strategies ...................................................................... 45
9.0 THE
PATH FORWARD.................................................................................................. 48
10.0 REFERENCES................................................................................................................. 49
TABLES
1 Summary of Proposals........................................................................................................... 7
5.1 Initial Ideas For Solutions................................................................................................... 23
7.1a Concept
No. 1a, Calculating Emissions, Modeling Tritium Ingestion...................................... 28
7.1b Concept No. 1b, Less Conservatism In
Emission Calculations............................................ 29
7.1c Concept No. 1c, Emissions Calculations,
Soil Activity........................................................ 30
7.1d Concept No. 1d, Emissions Calculations, Use
of CAP88-PC-T Code................................ 31
7.2 Concept No. 2, Comprehensive
Characterization .............................................................. 32
7.3 Concept No. 3, Tenting and Venting ................................................................................. 33
7.4a Concept No. 4a, Use of Innovative
Technologies, Packaging and Shipping ........................ 34
7.4b Concept No. 4b, Use of Innovative
Technologies, Fixatives ............................................... 35
7.5 Concept No. 5, D&D Strategies ....................................................................................... 36
FIGURES
1.1 Miamisburg
Environmental Management Project, Aerial View............................................... 11
1.2 Site
View Showing R-SW Complex and Stack ................................................................... 13
1.3 WD
Building ....................................................................................................................... 14
1.4 HH
Building ........................................................................................................................ 14
6.1 Graph
Used in Idea Comparison.......................................................................................... 27
7.1 FAST
Chart ....................................................................................................................... 37
APPENDIX
A Workshop
Strategy and Agenda ......................................................................................... 50
B Workshop Participants........................................................................................................ 53
C Ohio Technical Solutions Study Scope of Work................................................................... 54
D Team
Presentation Attendance List...................................................................................... 57
E Innovative
Technology List................................................................................................... 58
F Lessons
Learned List........................................................................................................... 64
EXECUTIVE SUMMARY
From July 29 until August 1, 2002, a Department of Energy (DOE) technical assistance team conducted a workshop at DOE’s Miamisburg Environmental Management Project (MEMP), formerly known as the Mound Plant. The workshop resulted from a request by MEMP management. Its purpose was to identify the best available strategies and technologies for minimizing radioactive emissions during decontamination and demolition of five buildings at the site, which is located in Miamisburg, Ohio.
The team was assembled by the Department’s Office of Science and Technology (EM-50) National Energy Technology Laboratory to assist the project under a new technical assistance initiative to help DOE sites by providing rapid and on-going access to critical experience and expertise related to closure activities. The team included seven senior, experienced professionals in the fields of nuclear facility decontamination and demolition, air dispersion modeling, and value engineering.
Background
Construction of the 306-acre Mound site began in 1947. As a DOE research, development, and production facility, Mound’s work resulted in radioactive contamination of many site buildings, including the five that were the subject of this study, with a variety of radionuclides. These five buildings – designated R, SW, WD, HH, and 38 – are of masonry construction.
Present plans call for taking the buildings down and shipping the rubble off site as low-level radioactive waste. Plans call for leaving selected equipment and building components in place until they can be removed and disposed of during the building demolition. This approach is the baseline approach for study purposes.
Approach
The workshop used a formal value methods process comprised of six basic steps. Step (1) involved team review of project information and presentations by project personnel, and a tour of the Building R-SW complex. Step (2) involved brainstorming to identify ideas for alternate solutions. In step (3), the team analyzed these ideas and identified the most promising ones for further development into concepts. Step (4) entailed developing these ideas into concepts and reasons why they would offer advantages over the current approach. The concepts were further condensed into major proposals. Each proposal was assigned to a team champion, who detailed the scope of the proposal. Step (5) involved a presentation by the team to site management on the results of the workshop and providing draft copies of this report. In step (6), if requested by the site, the team will be available for support during D&D work.
Expected
Outcome and Criteria for Success
The site identified the expected outcome of the study as
viable alternative approaches to the building D&D work that effectively
control radioactive emissions to the atmosphere and accelerate the
schedule. The criteria for success were
alternative approaches that would help accelerate the project schedule, and are
proven concepts that do not entail increased risk to the project.
Key Issues
The site is removing the buildings to make room for development of the property into an industrial park because the buildings are not considered usable in the industrial park environment. A key issue in this process is to limit radioactive air emissions in accordance with federal regulations, which is especially challenging at this site due to lack of a buffer zone and to the process of turning site property over to the community which is already underway.
Ideas
Identified
The team identified a total of 76 ideas that might have
merit in improving the site process.
Analysis
of Ideas
The team grouped these ideas into categories for further
study and analyzed them for potential benefits. This process led to the team’s proposals.
Team
Proposals
The team recommends that the site consider the following
ideas. The team considers that the site
already has a good, well-developed strategy for the D&D work, and
understands that the site has considered or is planning to implement most of
these ideas.
·
Refining calculations of projected radiation doses from
offsite emissions, and use of near-real-time emissions data to promptly
determine actual doses.
·
Comprehensive characterization of the buildings, making use
of proven, innovative characterization techniques.
·
Use of partial or full containment tents during building
demolition, with ventilation exhaust directed through the 61-meter stack.
·
Use of proven, innovative technologies for size reduction
and radioactive waste packaging.
·
Considering other strategies and lessons learned in other
D&D projects for possible application at the site.
A more-detailed summary of these proposals appears in Table
1 on the next page.
The Path
Forward
The team requests that the project consider the proposals
and determine what areas warrant further study in the interest of improving the
building decontamination and demolition plan.
The team stands ready to assist in this effort and to provide other help
with the project as requested by the site.
Note that site management reviewed a draft copy of this report for
factual accuracy, and their input was incorporated into this final version.


1.0 INTRODUCTION
1.1
Purpose
The purpose of this report is to describe the results of a technical solutions workshop held at the Department of Energy’s (DOE) Miamisburg Environmental Management Project (MEMP), formerly known as the Mound Plant or Mound Laboratory. (Word doc available
Personnel from the Battelle-Columbus Laboratories Decommissioning Project participated in the workshop, and the results produced may prove useful at that site n the decommissioning of the JN1 Hot Cell Facility. The general approaches and processes described herein may help other sites as well.
The workshop focused on controlling radioactive emissions during building decontamination and demolition (D&D). Its primary purpose was to identify the best available strategies and technologies for minimizing emissions during decontamination and demolition of five radioactively-contaminated buildings at the former Mound Laboratory in Miamisburg, Ohio. Appendix A describes the workshop strategy and agenda.
The workshop took place from July 29 to August 1, 2002. The primary participants in the workshop were members of a technical assistance team assembled by the Department’s Office of Science and Technology (EM-50) National Energy Technology Laboratory. This team included seven senior, experienced professionals in the fields of nuclear facility decontamination and demolition, air dispersion modeling, and value engineering. Participating in the workshop on a part-time basis were personnel of the MEMP contactor, BWXT of Ohio, Inc. Appendix B contains a list of workshop participants.
This technical solutions workshop was the second technical assistance visit in a series technical solution activities being undertaken by EM-50 as part of an initiative to help the Department’s sites with closure activities. Such technical assistance visits are intended to provide rapid and on-going access to critical experience and expertise in areas such as characterization, decontamination and demolition, and waste management.
1.2
Scope
The workshop’s scope was defined in a request for assistance made by project management summarized in Appendix C. This scope of work indicated that five buildings were to be considered:
· Buildings R and SW, both contaminated with tritium, plutonium, thorium, and other radioactive contaminants
· Buildings WD, HH, and 38, which are contaminated with plutonium and other radioactive contaminants
The scope of work also summarized the current approach to D&D of these buildings. This approach entails taking the buildings down and shipping the rubble off site as low-level radioactive waste. A new site D&D plan calls for leaving selected equipment and building components in place until they can be removed and disposed of during the building demolition phase. This approach is considered to be the baseline approach for the purposes of this study.
Noting the location of the MEMP in a residential area, and efforts underway for turning the site into an industrial park, project management emphasized the importance of using a D&D process that effectively stabilizes, fixes, and contains the radioactivity to ensure the safety of the public and of private industrial operations being located at the site. The project requested the team to:
· Recommend the most effective method of using commercial approaches for demolishing these buildings that could improve the current approach and allow for an effective balance between project acceleration and regulatory compliance objectives.
· Recommend how to combine risk-reducing approaches to be performed at different times during the remediation process, and
· Address the proper cleanup criteria to meet during building demolition the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAPS) developed by the U.S. Environmental Protection Agency (EPA) under the Clean Air Act, Code of Federal Regulations 40 CFR 61 Subpart H (reference 1). The project noted that it plans to use the computer software package CAP88 (reference 2) as an air dispersion model to demonstrate compliance with NESHAPS radioactivity emission requirements, and that this software may inappropriately overestimate radiation dose from tritium emissions.
The scope of work also identified five specific problem areas to be addressed by the team:
· The tritium release factor for use in CAP88 calculations,
· Regulator/ NESHAPS interpretation of cleanup criteria for nuclear facilities,
· Reducing fugitive emissions before or during demolition,
· Improved demolition techniques/technologies, and
· Methods of detection to demonstrate compliance with NESHAPS requirements during building demolition.
1.3 Approach
Prior to the workshop, the technical assistance team reviewed background information on the MEMP and the issues associated with building D&D. The workshop resulted in a value engineering study which consisted of the following six basic steps:
(1) Information Phase
This phase began approximately one month before the workshop when the technical assistance team was provided a packet of information about the MEMP and the problems to be addressed. The onsite part of the information phase took place on July 29 and July 30. It began with site presentations on the problems related to controlling radioactive emissions during building D&D work and the current plans to resolve these problems.
Following these presentations the team participants toured the subject buildings. The team then used function analysis to discuss and reach consensus on three key issues: (1) what is being done, (2) why it is being done, and (3) how it is being done. This information appears in Section 5 of this report.
(2) Creativity Phase
The team used “focused brainstorming” techniques to identify and list various ideas for possible alternative solutions. These ideas were merely listed without discussion or criticism. The list of ideas appears in Section 6.
(3) Analysis Phase
During this phase the team discussed the ideas. The team identified ideas which merited further consideration. After determining whether they met all established criteria, the team ranked the ideas with most potential using a paired comparison technique. After this was done, the team informally discussed some of them with project personnel to ensure that there were no reasons why a particular alternative should not be pursued. Section 7 describes these ideas and how they were ranked.
(4) Development Phase
The team then developed the ideas which showed promise as much as practicable within the available time, identifying reasons why they would offer advantages over the baseline plan and how they could improve the baseline lifecycle cost and schedule. This information appears in Section 8 of this report.
(5) Presentation Phase
The presentation phase involved a presentation by the team to site management on the results of the workshop and providing draft copies of this report. A list of presentation attendees appears in Appendix D.
(6) Implementation Phase
In the final phase of the process, if requested by the site, the team will provide further technical assistance during D&D, including helping improve control of radioactive emissions during building D&D work.
1.4 Background
As the MEMP moves forward toward site closure, various site nuclear buildings are being decontaminated and demolished. This activity and environmental restoration of the site property are being performed under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (reference 3), as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA) (reference 4).

Figure 1.1 Miamisburg Environmental Management Project, Aerial View
In 1990, DOE and EPA signed a Federal Facility Agreement for the Mound site. In 1993, the Ohio Environmental Protection Agency (OEPA) also became a signatory to the Federal Facility Agreement. Under the CERCLA and the agreement, both EPA and OEPA independently review and oversee the MEMP.
The CERCLA program at Mound operates in conjunction with DOE’s environmental restoration program. Under these programs, the site must comply with all applicable federal environmental laws, including the Clean Air Act.
Site History
The 306-acre Mound site is located in Miamisburg, Ohio, approximately 10 miles south-southeast of Dayton. Construction of the site began in 1947. As a DOE research, development, and production facility, Mound’s main function was to manufacture nuclear and non-nuclear components for nuclear weapons.
Mound also manufactured compact radioisotope power sources used in the nation’s space program. Plutonium-238 was used extensively for this purpose. Other radioactive materials were also used, including plutonium dioxide and polonium-210. In the mid-1950s, several programs involving tritium were instituted at the site and the site developed extensive capabilities for handling and studying tritium and tritium compounds.
One or more of these radioactive materials were used in the five buildings that were the subject of this study.
R (Research) Building
Constructed in 1948 and located on the main hill part of the site, Building R consists of a single-story structure with a penthouse, constructed of concrete block with a brick facing. The total floor area is 55,006 square feet. The roof consists of metal with a built-up coal tar membrane. The building penthouse contains a high efficiency particulate activity (HEPA) filter bank and associated ductwork connecting it to the T-West stack.
The building was divided into two areas. The hot side included areas used for tritium recovery, rooms in which plutonium work was done, and rooms used for analytical support activities. On the cold side of the building were research and development laboratories, analytical laboratories, a respirator fitting facility, offices, and a library.
Mound Technical Manual MD-22153, Mound Site Radionuclides by Location, (reference 5), lists radioactive materials used in each room of R Building. Besides plutonium, radionuclides included H-3, Po-210, U-238, and many others. Building R is physically connected to Building SW so the two structures are being treated on a single complex for D&D purposes.
SW (Semi-Works) Building
Building SW is a
two-story structure, also with a penthouse, and also constructed of concrete
block with brick facing. The roof
consists of a built-up membrane formed of carboline, asphalt, and coal
tar. Located in the main hill area, the
building has a total area of 43,066 square feet. It was constructed in 1950 and eventually included 13 additions.
Building SW was used
for tritium recovery and purification, tritium component development, component
evaluation, and analysis of materials.


Figure 1.2 Site View Showing R-SW Complex and Stack
It
was also used for research projects involving plutonium, actinium, radium,
uranium, thorium, and protactinium. The
building contains a ventilation system with HEPA filters and contains alpha and
beta hot drains.
Underneath Room SW-19
of the SW Building lies the “Old Cave.”
In this area radioactive equipment was entombed.
The Action Memorandum
for the SW Building (reference 6) describes eight safe shutdown activities for
Building SW. These entail shutdown of
systems and areas, decontamination and radioactive equipment removal.
WD (Waste Disposal) Building
Building
WD became operational in 1949 and served as the central facility for treatment
of liquid radioactive wastes at Mound.
In 1967, a beta waste treatment system began operation in the building.
In 1996, an annex to the building was constructed for treatment of alpha
waste.
Reference (5) shows that a wide range of radionuclides were used in the building, including tritium and various uranium and plutonium radionuclides.
Figure 1.3. WD Building
HH (Hydrolysis House) Building
One
of the early buildings on the site, Building HH was initially used for the
hydrolysis of highly-radioactive bismuth chloride and aluminum chloride
solutions. In 1963, building HH was
converted for use with stable gaseous isotope separation processes.
Figure 1.4. HH Building
Reference
(5) shows that a wide range of radionuclides were used in the building,
including tritium. Site personnel
reported that radioactive contamination levels in this building were lower than
in the other four buildings of interest.
Building 38
(Also known as PP or Plutonium Production Building)
Complete in 1967, Building 38 was used primarily for processing plutonium-238 dioxide. It contained two glovebox lines and various other equipment used in the processes.
The lower part of the two-story building is constructed of reinforced concrete, the upper part of concrete block. Total floor area is approximately 44,000 square feet.
Building 38 is scheduled to be the first of the five buildings of interest to be demolished. As of February 2002, reasonably complete characterization information was available. Some contaminated equipment remained in the building at that time, including F-Line gloveboxes. Two gloveboxes contained contamination levels exceeding 3.3 x 106 dpm/100cm2. A 10,000-gallon tank contained sludge with 0.23 Ci of Pu-239. Fixed alpha contamination was present on some floor areas, and five areas in the building were posted as contamination areas; removable contamination levels in other areas were well below control limits. Filter banks and ventilation exhaust ducts were known to be highly contaminated.
1.5 Organization
of this Report
The report organization generally follows the sequence of the six-step value engineering process. Section 2 first summarizes requirements related to radioactive emissions during the D&D work and briefly discusses examples of different approaches to D&D of buildings contaminated with plutonium and tritium. Section 3 explains the expected outcome and criterion for success as identified by the site. Section 4 summarizes the key issues involved. Section 5 summarizes the ideas identified by the team and Section 6 explains the results of analysis of these ideas. Section 7 shows how promising ideas were developed. Section 8 outlines the team’s proposals and the reasons for them. Section 9 discusses the path forward. References are listed in Section 10. Six appendices follow, including Appendix F on lessons learned.
Site comments on the draft report included observations about some of the team’s proposals. These observations appear in the text as SITE NOTES.
Additional supporting information developed during the study is being made available to the site separately from this report.
2.0 EMISSION
REQUIREMENTS AND DECOMMISSIONING
2.1
Emission Requirements
Federal regulations related to release of radionuclides to the environment during processes such as contaminated building D&D are promulgated by the EPA. These regulations, which appear in 40 CFR 61.90 through 40 CFR 61.103, require monitoring radionuclide releases at all release points and limiting resulting doses to any member of the public to a maximum of 10 millirem per year total effective dose equivalent
The EPA has approved the use of three radiation dose assessment computer codes to demonstrate compliance with these NESHAPS requirements. One of these is CAP88, which MEMP will use as an air dispersion model.
The original CAP88 code was developed jointly by EPA and DOE’s Oak Ridge National Laboratory for use on a mainframe computer. Later versions were developed for personal computers (CAP88-PC) and use of these was also approved by EPA.
The CAP88 code models the behavior in the atmosphere of many radionuclides, including tritium. The code assumes that all releases of tritium occur in the form of water vapor (HTO). Even though a release may occur in hydrogen gas form (HT), the regulation does not allow converting HT to an equivalent quantity of HTO. This situation results in conservatism for HT releases because metabolism differences between HT and HTO make the radiation dose associated with inhalation of HT much smaller than the dose from inhalation of an equivalent amount of HTO.
2.2 Approaches
to Decommissioning
Mound Technical Manual MD-22153 (reference 5) lists the radionuclides used in each room of each building at Mound.
Limits For Radioactive Contaminants
To decontaminate and release radioactively-contaminated buildings such as those at MEMP from radiological controls, residual radioactivity must meet certain requirements. In the DOE community, the surface radioactivity limits of DOE Order 5400.5 Radiation Protection of the Public and the Environment (reference 7) are generally used for this purpose.
In the DOE community, there are no generally approved limits expressed on a mass or volume basis for materials contaminated in depth. Such limits for soil, foundations, or structures that may be occupied after cleanup can be derived by computer modeling using residual radioactivity computer codes such as RESRAD and RESRAD-BUILD, but specific DOE approval would be necessary to utilize the derived limits (derived concentration guideline levels) on a nuclear facility decommissioning project.
The Action Memorandum for cleanup of Building, R, SW, and 58 and 68 slab removal (reference 6) provides cleanup objectives for these facilities. Among the values specified are the following radioactivity concentrations in soil: Pu-238 55 pCi/g, Pu-239/240 55 pCi/g, and H-3 235,000 pCi/g.
Examples of Decommissioning Approaches
The current approach to D&D of the MEMP buildings is, or course, one of several approaches that may be used when a contaminated facility, or the property on which it lies, is to be released from radiological controls. During the study, the team considered other approaches that could reduce radioactive emissions. The projects summarized below provide examples of other approaches.
Building 779 at the Rocky Flats Environmental Technology Site
Building 779 was a concrete block structure with reinforced steel columns, with a floor area of 68,000 square feet. Plutonium and uranium were the primary radiological contaminants. The report of the April 2002 EM-50 technical assistance team review of plans for demolition of Building 776/777 at Rocky Flats (reference 8) summarizes the Building 779 project as follows:
The Building 779 work was conducted under a state-approved decommissioning operations plan. After equipment removal, a hydro lasing system was used to decontaminate contaminated concrete surfaces. This system proved to be effective on poured concrete and concrete block. It had also been used to decontaminate areas in other site buildings, such as Building 371.
The decontamination effort allowed a significant amount of concrete in Building 779 to be released from radiological controls, although most interior walls were treated as low-level radioactive waste. The criteria used for unrestricted release was surface contamination not to exceed an average of 100 dpm/100 cm2 total alpha, with no more than three times that amount in hot spots.
Final surveys of the building followed guidelines of the Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM), NUREG-1575, (reference 9) to demonstrate that the requirements of DOE Order 5400.5, were satisfied. The final status survey plan was approved by the Department, the state of Colorado, and the EPA.
After completion of the final surveys and related independent verification surveys, Building 779 was released from radiological controls and demolished using conventional methods. Because the structure had been released from radiological controls, there were no issues with radioactive emissions during the demolition process.
The Hot and Cold Laboratory at the Barnwell Nuclear Fuel Plant
As described in reference 10, this reinforced concrete structure contains 17,000 square feet of floor space on three levels. Its 16 laboratories and 37 gloveboxes were contaminated with plutonium and natural uranium. Plutonium contamination in several gloveboxes exceeded 1010 dpm/100 cm2. Floors and walls of some laboratories contained significant levels of fixed plutonium contamination.
Because the old plant was being turned into an industrial park at minimum cost, the laboratory building was decontaminated, released from radiological controls, and left standing. The contractor used the RESRAD-Build computer code to model residual radioactivity in the facility, based on a cleanup limit of no more than 15 millirem per year from residual radioactivity. The resulting derived concentration guideline level used in the cleanup was 130 dpm/100 cm2 total alpha-emitting transuranics, which equated to 9 pCi/g plutonium in concrete.
Following removal of radioactive equipment and decontamination of the facility surfaces, the contractor performed final status surveys following the MARSSIM process (except the number of measurement was based on experience and professional judgment, rather than on MARSSIM statistical tests). Close coordination between the contractor and the regulator (the state of South Carolina) resulted in the last independent verification surveys of the building being completed about two weeks after the last contractor surveys. The plant radioactive materials license was terminated shortly afterwards, and the property turned into the South Carolina Advanced Technology Park.
Because decontamination took place under close controls which included HEPA-filtered ventilation systems, there were no issues about radioactive emissions during the D&D process. More information on this project can be obtained from Jim McNeil at 843-740-3946.
Building 232-F at the Savannah River Site.
Building 232-F, the old tritium facility at the Savannah River Site, became the first full-scale tritium facility decommissioning in the DOE complex (reference 11). This work took 30 months to complete.
During this project, the contractor encountered difficulties in characterizing materials, especially concrete, for tritium. Additional characterization of the concrete structure, including numerous surface and core samples analyzed in a laboratory, was necessary during the course of the work. More information about this project can be obtained from Bill Austin of Westinghouse Savannah River Company at 803-725-4543 or Rod Rimando of DOE-Savannah River at 803-725-4118.
3.0
ANTICIPATED OUTCOME AND CRITERIA FOR SUCCESS
The presentations made by project management and technical personnel, and subsequent discussions with site personnel, included the following information:
3.1 Anticipated
Outcome
The anticipated outcome of the study are viable alternative approaches to the building D&D work that effectively control radioactive emissions to the atmosphere and accelerate the schedule .
3.2 Criteria
For Success
The principal criteria for success are alternative approaches that reduce radioactive emissions while maintaining an appropriate balance between project acceleration and meeting regulatory objectives. That is, the alternatives must enable emission requirements to be achieved, and be faster, and if, possible, less expensive than the baseline plan. Alternatives should also be proven concepts that do not entail increased risk to the project. They should focus mainly on accelerating the closure schedule. And if, possible, they should reduce costs.
3.3 Additional
Information Provided
The study should focus primarily on the Building R-SW complex, with alternative approaches for that structure being considered as also appropriate for the other subcontracted building projects. The Old Cave entombment in the SW building should be included in the study.
The site schedule calls for completing all D&D work by September 30, 2006. Following this event, the last of the site property will be turned over to the community for use as an advanced industrial park. This turnover process is already underway and some 30 private businesses with approximately 300 employees are presently located at the site.
This situation makes the site much different from a radioactive air emissions standpoint than large DOE sites with wide buffer zones around their radioactively-contaminated facilities, and influences Mound D&D strategy. Projections for radioactive air emissions from D&D work, calculated with the CAP88-PC code using available characterization data, are used to ensure that site stays well below the annual NESHAPS limit of 10 millirems per year to the maximally exposed individual, presently defined for stack emissions as a single point 880 meters north-northeast of the HEFS stack.
Using a risk-based strategy based on projected air emissions, the site schedules and manages work so that radioactive emissions from individual D&D projects would produce no more than one to two millirems per year. Site personnel indicated that plutonium is expected to be controlling in the air emissions, rather than tritium. Radioactive does from annual total site emission projections range from 4.88 millirems in 2003 to 12.89 millirems in 2004. The site is working on ways to cut the projected 2004 emissions down to around five millirems for the year. Following NESHAPS requirements, the site obtains EPA Region V approval of processes projected to produce more than 0.1 millirem per year, such as the demolition plan for a contaminated building.
The precision of the air emission calculations is presently limited by the available characterization data. The site recognizes this situation and is presently performing additional characterization work, including analysis of concrete samples.
The site measures radioactive air emissions in several ways. These include continuous monitoring stack emissions, using perimeter and offsite monitors, and environmental sampling. The site will also measure air emissions near buildings being demolished.
Another factor that influences site D&D strategy is annual funding. The site balances workload year to year to stay within projected annual funding limitations.
The five buildings of interest in this study represent the most significant site buildings to be decommissioned. The site considers D&D of the Building R-SW complex to be longest building D&D path to closure. This conclusion in based on the size of the complex – approximately 100,000 square feet of floor area – along with the numerous contaminated areas, the relatively large amount of contaminated equipment in the buildings, and the presence of the Old Cave entombment. All building equipment, even unused gloveboxes, is being treated as potentially contaminated.
The present site strategy of taking down the buildings without first releasing them from radiological controls evolved from efforts to cut time and cost for the closure process. Before developing this strategy, the site was facing a 2009 closure date and substantially higher costs.
Relatively small low-level radioactive waste disposal costs help make this approach economical. The site plans to ship this waste to DOE’s Nevada Test Site and to Envirocare of Utah. The site considers that it has enough characterization data on the facilities to conclude that it is faster and less expensive to take the buildings down as contaminated, rather than first release them from radiological controls. (The team understands that Building HH may be released from radiological controls before demolition because contamination levels in that building are very low.)
The site plans on following a two-phase strategy. In Phase 1, the building structures are being taken to ground level. In Phase 2, the floor slabs, foundations, contaminated subsurface piping, and contaminated soil will be removed.
With the site’s strategy of taking the buildings down contaminated, the extent of radioactive equipment removal and decontamination of building surfaces is dictated primarily by reducing the source terms and projected radioactive air emissions, rather than by specific limits on surface or volumetric contamination in the structures. As noted previously, the site has established limits for radioactivity in soil that appear in reference (6).
The site plans to use several proven techniques to reduce radioactive emissions during the demolition process. These include use of fixatives, water misting to reduce dust, and promptly placing radioactive waste in containers.
Over the past few years, the site has been using site workers for D&D work. For example, in Building 38 site workers removed the A-Line gloveboxes, which were contaminated with plutonium, and other radioactive equipment. Site workers have done considerable D&D work in the R-SW complex. But projections have indicated that the present site contractor workforce is too small to accomplish all the necessary D&D work. So the site is subcontracting demolition of the Buildings 38, WD, and HH to experienced, pre-qualified D&D companies.
Building 38 is the first of the contaminated site buildings for which building demolition will be subcontracted. The subcontractor is currently making preparations for the project. Subcontractor work in Building 38 is expected to include removal of some radioactive equipment such as the F-Line gloveboxes and ventilation exhaust equipment and HEPA filters.
Site workers will continue decontamination and removal of equipment from the Building R-SW complex and eventually demolish the structures. The site will keep the exhaust ventilation fan house next to the buildings and the associated stack operational as long as practicable, to enable emissions from the decontamination process to be released through the stack. (Most gloveboxes in the Building R-SW complex are already venting through the stack.) Demolition of this building is expected to be completed in August 2005. Site personnel have considered the experience with D&D of Building 232-F at the Savannah River Site, the largest tritium facility decommissioning project yet undertaken in the DOE complex.
SITE
NOTE: While not discussed at
length with the team, soil source terms are calculated differently than other
solid material (i.e. 1E-3) dispersion.
Soil source terms incorporate surface areas, moisture content, wind
speed, time of exposure and other parameters.
This term is not as conservative as 10-3 term. Also it should be noted that the alternate
soil source term calculations were incorporated into the Federal Facility Agreement
terms with EPA Region V.
4.0 KEY
ISSUES
The team discussed information provided by the site, looked at the Building R-SW complex, and agreed that the key issue in the project is limiting radioactive air emissions during the building demolition. As a result of the initial site meetings, the team identified key issues, such as:
4.1 What
is Being Done?
The site is removing the five buildings.
3.2 Why
is this Being Done?
The site is removing the buildings to make room for development of the property into an industrial park because the buildings are not considered usable in the industrial park environment and because they take up space needed for the park development, and to eliminate future risk to people and the environment..
3.3 How
is this being done?
The site is removing radioactive materials and equipment from the buildings, performing limited decontamination of the building structures, demolishing the structures, and disposing of the building rubble as low-level radioactive waste.
3.4 Other
Issues
Other issues identified by the team during the course of the workshop included:
· Asbestos issues, such as floor tiles to be removed,
· Whether a projected dose on 0.29 millirem for air emissions was mitigated or unmitigated,
· The tight project schedule,
· The D&D of the R-SW complex is on the critical path for the overall project schedule,
· That the site lacks as-built drawings of the buildings,
· Whether the presence of lead paint is an issue, and
· The contribution to projected emission dose from tritium.
5.0 IDEAS IDENTIFIED
The team identified 76 ideas for alternative solutions as listed in Table 4.1. These ideas were initially grouped by the team as indicated.
Table 5.1 Initial Ideas for
Solutions
|
No. |
Idea |
|
Limiting Emissions
(Containment) |
|
|
1 |
Tent and recirculate and
filter |
|
2 |
Fix/encapsulate
contamination using foam, poly, and grout |
|
3 |
Build enclosure for
staging area |
|
4 |
Spray/misting/fogging
technologies for ducts, etc. |
|
5 |
Vacuum strippable coatings |
|
6 |
AEA Portable Tent with
strippable coating or liner |
|
7 |
Inject foam into piping |
|
8 |
RL encapsulation
technology (linseed oil) (a durable fixative) |
|
9 |
Containment walls,
sleeving, trenches, sheeting, chemical grout |
|
10 |
Drop dust retardant just
before wall or ceiling collapses |
|
11 |
Air sampling (using vacuum)
after a few hours to verify effectiveness |
|
Limiting Emissions
(Characterization) |
|
|
12 |
Perform more detailed
characterization (lower emission projections) |
|
13 |
Deploy portable lab |
|
14 |
Use truck x-ray or x-ray
fluorescence to look inside walls |
|
15 |
Use ICAM imaging
system (West Valley Demonstration
Project) |
|
16 |
Develop real-time
emissions monitor for asbestos |
|
17 |
Provide near real-time
emissions monitoring |
|
18 |
Pick up air
monitoring data monthly/increase frequency at fence line |
|
19 |
Maximize use of non-intrusive
characterization tools |
|
20 |
Use of on-line alpha
spectroscopy air monitoring instruments |
|
21 |
Use DDROPS technology from
INEEL for “what-if” analysis |
|
22 |
Develop real-time dose
banking system |
|
23 |
Obtain more
data on asbestos, PCBs, and lead |
|
24 |
Deploy PCB
analyzer and lead paint analyzer |
|
No. |
Idea |
|
25 |
GammaCam application |
|
26 |
ISOCS room analyzer |
|
27 |
Long range alpha detectors
(LRAD) |
|
28 |
Rad-elect
(hockey pucks) stick-on walls |
|
29 |
On-line alpha spectroscopy
instruments (duplicate) |
|
30 |
Supplement characterization
– look for hidden contamination |
|
31 |
Mid-year under building
characterization (Hanford 105-C project) |
|
32 |
Use Pipe
Explorer (SEA) for ducts and piping |
|
Limiting Emissions (Other
Options) |
|
|
33 |
Omitted |
|
34 |
Consider free releasing
and leave standing buildings (38, WD, HH) |
|
35 |
Put past experience in
report, e.g., Building 232F at the Savannah River Site |
|
36 |
Prepare final status
survey report area by area for regulators to review ASAP |
|
37 |
Don’t move fence line
until ready |
|
38 |
Reassess
assumptions in emissions model/be less conservative |
|
Limiting Emissions
(Process Improvements) |
|
|
39 |
Work from the end point
back |
|
40 |
Do nothing. Demolish and monitor only change if
necessary |
|
41 |
Portable tritiated water
removal unit |
|
42 |
Fix contamination and drop
structure |
|
43 |
Use elephant
trunk vent to stack |
|
44 |
Place concrete and soil in
soft-sided containers |
|
45 |
Develop
overall plan of attack for demolition to minimize emissions |
|
46 |
Reduce time of waste in
staging area; ship as generated |
|
47 |
Containerize waste at
D&D site, not at staging area |
|
48 |
Remove slab and mine out
the soil while R-SW building still standing |
|
49 |
Leave ventilation system
in-place during D&D to minimize emissions |
|
50 |
Limit work on windy days;
set wind limits during D&D |
|
51 |
Use portable tritium water
removal system (duplicate) |
|
52 |
Shut off power and use
portable electrical energy sensor |
|
No. |
Idea |
|
53 |
Use CAP88 PCT (Berkeley)
before and after comparison |
|
54 |
Use vacuum
collection systems during cutting and demolition |
|
55 |
Establish guidelines for
equipment sources that can remain in building |
|
Limiting Emissions (Risk) |
|
|
56 |
Relocate
staging area for D&D operations |
|
Demolition of Building
(Cutting, Size Reduction, and Demolition) |
|
|
57 |
Use diamond wire saw with
water |
|
58 |
Strategic
use of explosives |
|
59 |
Hammer drill (characterization
included) |
|
60 |
Hammer head
attachment |
|
61 |
Use shear mounted water
misting |
|
62 |
Use explosives
inside/outside tent (considering 0.29 millirem annual dose) |
|
63 |
Deploy real-time monitor
for presence of electrical power (duplicate) |
|
64 |
DDROPS cutting plan
(INEEL) |
|
65 |
Obtain copy of Cutting & Size Reduction white
paper |
|
66 |
Deploy the Universal
Demolition Processor |
|
67 |
Pipe crimping and drain
plugging |
|
68 |
Integrated Technology
Suite and use of ISOCS |
|
69 |
“Son of”
WARTHOG |
|
70 |
Deploy soft-sided containers |
|
71 |
Take out
slab while building is still in place |
|
72 |
Use Instacoat for oversize
loads of debris |
|
73 |
In-situ soil
verification, volatile organic compound stripping |
|
74 |
Trench or sheet piles to
contain secondary water |
|
75 |
Inject
chemical grout to retard soil absorption of contaminants |
|
76 |
FIU cutting saws &
dust suppression systems |
6.0 ANALYSIS
OF IDEAS
The team discussed each of the ideas listed in Table 5.1. The team determined that the ideas shown on Figure 6.1 on the next page would likely meet the criterion for success described in Section 4. Note that this conclusion was not based on the implementation cost necessarily being lower, because time did not allow for development of detailed cost estimates for ideas which showed promise at this point in the process.
The team ranked the ideas based on value of expected potential reductions in risk (primarily radioactive emissions), cost and schedule time. The team also ranked them in terms of perceived relative ease of implementation. These rankings determined the position of each idea on the Figure 6.1 graph. Ideas showing the most promise, i.e., those which appear in the upper left portion of the figure, were selected for further development.
The team later informally discussed these ideas with MEMP project team members to determine whether there were any reasons why they were not viable. The project team’s input was taken into account in selecting the ideas which led to the proposals presented in Section 8 of this report.
|
Implementation Value (Relative potential value in
reducing emissions, costs, and/or schedule time) High Medium Low |
|||||||
|
|
Easy
Hard |
G2 N P C, B |
J L1 M H |
|
|||
|
Q |
F1, F2 |
|
|||||
|
S1 S2 |
G1 |
A,
L2 |
|||||
Key to Graph:
|
A. Soil Treatment Technologies |
L1. Fixatives |
|
B. Cutting and Size Reduction during
demolition |
L2. Destructive Demolition |
|
C. Applicable Characterization Tools |
M. Using Real-time Monitoring Data |
|
F1. Application of Model Analysis |
P. Packaging and shipping options |
|
F2. Performing Model Planning |
N. Tent and Vent |
|
G1. Soil Protection (Active) |
Q. Alternative Strategic Approaches |
|
G2. Soil Protection (Passive) |
S1. Performing Asbestos abatement with
D&D |
|
H. Experience Review |
S2. Leave fence line out to buy time |
|
J.
Electrical Safety Sensor |
Scoring -Blue:
High, Black: Med., Red: Low |
Figure
6.1. Graph Used in Idea Comparison
7.0 DEVELOPMENT OF IDEAS
The team developed the ideas shown in Figure 6.1 considering potential benefits, potential advantages, and possible risks to the project. Tables 7.1 through 7.5 provide examples of this process.
The team also developed information on potential net savings which could come from implementation of the ideas. These potential savings are discussed in Section 8 of this report. The details of the costs savings estimates are being provided to the site separately from this report.
Table 7.1. Concept No. 1a, Calculating Emissions, Modeling Tritium Ingestion
|
Component: Modeling |
Function: Controlling emissions |
|
Alternative
Description |
|
|
Be less conservative in CAP88 dose assessments: model tritium
ingestion more realistically. The present
CAP88-PC dose is based on a maximum distance of 1490 meters, which means that
the model assumes that all food is grown at that distance or closer, and does
not consider food grown at greater distances with much less
contamination. It would be more
realistic to extend the food growing area out to 80 kilometers (50
miles). Doing so will probably lessen
the dose from tritium by a factor of three, as the ingestion dose now
comprises two-thirds of the dose from tritium. This should drop the total dose to about 2/3 of 0.29, or 0.20
millirem. The actual
values in the CAP88-PC assessment for tritium were as follows: ingestion 7.12 e-4, inhalation 3.32e-4. The tritium
contribution to total dose of 0.29 mrem for RSW is about 50 percent. After the transfer of the parking lot, the
dose will become 0.9 millirem. |
|
|
Benefits |
Disadvantages |
|
· The total dose from
tritium may drop by a factor of 3, as ingestion will no longer be the
dominant pathway. |
· This will only affect the
tritium component of the dose, which may not predominate (currently the
tritium component is about half or 50 percent). If the tritium component drops in significance, tweaking the
ingestion dose may not be worthwhile. |
|
Identified
Risks |
|
|
Obtaining EPA approval for
revised modeling. Note that EPA used
the suggested methodology in their own CAP88 dose estimates for the NESHAPS
rulemaking (per Barry Parks, author of CAP88-PC). |
|
Table 7.1b. Concept No. 1b, Less Conservation in Emission Calculations
|
Component: Dose assessments |
Function: Controlling emissions |
|
Alternative
Description |
|
|
Be less conservative in CAP88 dose assessments:
get a more realistic estimate of the activity in soil, and also get a better
estimate of the release fraction. While the understands that
the planned characterization is far from complete, it appears that the dose
estimates from releases of contaminated soil are based on upper bound
estimates rather than actual measured values. Better characterization is needed, as actual values are
probably less, which should lower the dose to the maximally exposed
individual. Also, the current dose
estimates are based on a release fraction of 1E-3. The actual release may be less by orders of magnitude. A suggested basis would be to look at
operating experience at Mound documenting difference between predicted and
measured values. |
|
|
Benefits |
Disadvantages |
|
· Better characterization of
soil activity would lessen the maximally exposed individual dose, but it is
not clear by how much. · Release fractions based on
operating experience may lower the dose by orders of magnitude. |
· Costs of characterizing
soils. · Costs of analyzing release
fractions from previous operations. · The data may not be
available to estimate actual release fractions. |
|
Identified
Risks |
|
|
The data may be available
for any comparison on release fractions.
EPA may not approve altered release fractions. |
|
Table 7.1c. Concept No. 1c, Emission Calculations, Soil Activity
|
Component: Modeling |
Function: Controlling emissions |
|
Alternative
Description |
|
|
Be less conservative in
CAP88 dose assessments: use a non-zero stack height. The present CAP88-PC dose estimates for
SW/R are based on a zero stack height release, which is very conservative. If
it is feasible to ventilate the emissions from D&D of the R-SW building
through the 61-meter stack, then the off-site dose to the maximally exposed
individual will drop by a factor of about 100 or greater (per CAP88-PC
estimates made by Barry Parks) from the increased dispersion alone. There will
be an additional benefit in dose reduction from the HEPA filtration of
particulates in the stack. This will
lower the dose from plutonium, which is a particulate, but will not affect
the dose from tritium, which is not a particulate. |
|
|
Benefits |
Disadvantages |
|
· Dose from all
radionuclides (particulate and non-particulate) will drop by a factor of 100. · Dose from plutonium will
drop even further from HEPA filtration. ·
The location of the MEI may move farther away. The dose to the current MEI may drop
because the plume will touch down at a farther distance |
· It may not be feasible to
do tent/vent of D&D operations. · The engineering costs of
ventilating through the 61 meter stack.
· EPA will not give credit
for HEPA filtration. |
|
Identified
Risks |
|
|
This proposal assumes that
it is feasible to ventilate through the 61 meter stack. This would require tenting and possibly
other ventilation modifications. Time
and money requirements to tent and vent may be prohibitive. |
|
SITE
NOTE: While the discussion regarding
dose reduction due to stack emissions is fairly accurate, it is something of a
misnomer to say that that the site is being overly conservative in its dose
calculations. What the team seems to be
advocating is physically changing the release point, i.e., capture and vent the
emissions up one of the stacks. Once
the release point has been changed, the model can be changed accordingly. The model currently used a ground level
release because indications were that most of the emitted inventory would be
released at that height. Also, under
disadvantages-as discussed - EPA will
allow some credit for HEPA filters.
Table 7.1d. Concept No. 1d, Emission Calculations, Use of CAP88-PC-T Code
|
Component: Modeling |
Function: Controlling emissions |
|
Alternative
Description |
|
|
Use CAP88-PC-T, developed
at LBNL for more accurately modeling tritium gas. CAP88-PC models tritium as tritiated water, instead of as a
gas, which gives about 20,000 times more dose. About 80
percent of tritium releases at Mound are in water form, so there would not be
much advantage for this option. |
|
|
Benefits |
Disadvantages |
|
· The dose from tritium gas
in CAP88-PC would drop by about 20,000 times. |
· CAP88-PC-T is not yet
approved by EPA and obtaining EPA approval will probably take too much time. · Lowering the tritium dose
may be easier to do by using less conservative agricultural production
assumptions in CAP88-PC. · This would only benefit
the 20 percent of tritium emissions that are not as tritiated water. |
|
Identified
Risks |
|
|
EPA
approval will likely be time-prohibitive. |
|
Table 7.2. Concept No. 2, Comprehensive Characterization
|
Component: Each building |
Function: Characterization |
|
|
Alternative
Description |
||
|
A host of characterization
technologies were evaluated both for their potential beneficial impact on
site emissions and on the D&D of R-SW Building complex. More complete characterization might
reduce overly conservative source term assumptions. If, however, parameters used in the emission model are found to
be too conservative and are adjusted appropriately, further, extensive
characterization may be unnecessary.
The site’s current use or consideration of these technologies in the
R-SW Building complex were not known by the team. A list of websites describing these technologies have been
provided to the site. The proposed characterization would entail three steps: 1.
Perform more detailed, focused characterization to produce more
accurate source terms, which would lead to lower emissions estimates (Room
assessment using ISOCS, evacuate air from empty piping systems to determine
contents, Hammer Drill [hollow core drill for sampling concrete]). 2.
Conduct near real-time or increase sampling frequency for
radiological air monitoring that would support a real-time dose banking system
for emissions (constant air monitor employing alpha spectroscopy). 3.
Consider the use of innovative characterization technologies (modern
portable laboratory, gamma camera, electret ion chambers, Dig Face
Characterization Robotic Retrieval System, Pipe Explorer, PCB/Lead Paint
analyzer, ICAM imaging technology, X-ray or X-ray fluorescence imaging of
inaccessible locations). 4. The team also suggests that DEF62021-EW
55094 FIU Dust Suppression Study, the
characterization technologies tested by EM-50 (in Appendix E), and the Integrated Technology Suite
(characterization suite used at INEEL, Fernald) be reviewed. |
||
|
Benefits |
Disadvantages |
|
|
·
These technologies may be more effective than baseline technologies. ·
Could review emissions on a real-time or near real-time basis which
would assure that goals and or limits are not exceeded. · The Dig Face
Characterization system could be applied to the Old Cave area for the
purposes of remote characterization and retrieval. This system has already been tested and proven at INEEL and
should be easily obtained for use at Mound.
The technologies noted may be an improvement over selected baseline
technologies. |
·
Disadvantages depend on geometry or physical nature of contaminants,
which may or may not be known. ·
Increased monitoring costs and complexity with near-real-time
emissions monitoring. ·
Some of the technologies may add cost and complexity. ·
No characterization is presently planned for the Old Cave. |
|
|
Identified
Risks |
||
|
· None. |
||
Table 7.3. Concept No. 3, Tenting and Venting
|
Component: R-SW Building |
Function: Controlling emissions |
|
Alternative
Description |
|
|
As a part of the dismantlement process provide portable or one
of a kind, single application tents with appropriate filters to capture or
contain emissions resulting from dismantlement activities. Use of existing stacks, ventilation
systems, liners, strippable coatings, portable vacuum/filter systems, and
elephant trunks are included. Three basic options are
presented with this proposal: (1) use of tent and filter system for the total
S, WR building, (2) partial tenting of a portion of the building (i.e., the
Cave), and (3) tenting of the Astaging area@, in close proximity to
the D&D operation. |
|
|
Benefits |
Disadvantages |
|
· Portable containment
systems and filters are commercially available (although lead time could be
significant). · Proposed
technologies/equipment are commonly used throughout the DOE and private
sector. · Relatively inexpensive to
procure and use. · Little or no training or
experience required to set up and use. · Adds very little secondary
waste to D&D operations. · Strong stakeholder support
because of its visible barrier/containment. · Highly effective in
reducing emissions. · Contributes to reduction
in annual site emissions dose. · Keeps rain/weather out of
project. · Allows a more-aggressive
schedule to remove building and equipment. |
· Some additional cost over
baseline open-air dismantlement.
(Need estimate of current containment, emissions mitigation costs
before comparative analysis can be determined). · Modification to the
baseline approach is required. · Additional cost associated
with re-design of staging area. · The cost of design and
construction of the tents. SITE NOTE: Considering the progress that has already been made on the present
plan for the Old Cave, there is no advantage to using a tent over this area. |
|
Identified
Risks |
|
|
Proven technology, no
standard basis risks. Small risk
associated with weather events (high winds) which would require rebuilding
the tent. The smaller the tent, the
lower the risk. |
|
Table 7.4a. Concept No. 4a, Use of Innovative Technologies, Packaging and Shipping
|
Component: R-SW Building |
Function: Controlling emissions |
|
Alternative
Description |
|
|
The evaluation team
learned that the waste staging area will theoretically be the largest source
for offsite emissions. The team
suggested ways to reduce emissions associated with waste handling and
packaging. 1.
Package waste at buildings (in intermodal containers or soil sacks) 2.
Wastes that are large and have an irregular shape should be packaged
using the Instacote process, which is sprayed on but qualifies as a
Department of Transportation strong, tight container 3.
Reduce emissions at staging area by: (1) locating staging area to
maximize distance to offsite receptor, (2) reducing the amount of time that
the waste is in the storage area (move waste offsite as quickly as possible),
(3) build an enclosure for staging area. 4.
If feasible, the transfer of the Phase I property should be delayed
to maintain the distance to the nearest receptor until the major buildings
with radioactive contamination, as well as contaminated soils, are shipped
offsite. Alternatively, the staging
area could be enclosed and emissions filtered prior to release. |
|
|
Benefits |
Disadvantages |
|
· Packaging the waste at the
demolition site in soil sacks or intermodal containers would reduce overall
emissions due to less handling, with associated reductions n handling
costs. Instacote coating of large
debris items meets Department of Transportation requirements for strong,
tight containers, and would decrease release of radionuclides. ·
Delay of the transfer of the Phase I property would decrease the
predicted effective dose to the maximally exposed individual from the staging
area. ·
A tent structure over the
staging area would reduce overall emissions. |
· Space may not be available
to package waste at the demolition site. · Moving the staging areaq
may not be practicable · Enclosing the entire
staging area would be costly |
|
Identified
Risks |
|
|
Any enclosure would be
subject to damage from debris or high winds; the smaller the enclosure, the
less risk. |
|
Table 7.4b. Concept No. 4b, Use of Innovative
Technologies, Fixatives
|
Component: R-SW Building |
Function: Controlling emissions |
|
Alternative
Description |
|
|
As a part of the
dismantlement process adopt the general use of sprays, coatings, fixatives,
fogs, and foams as a means of capturing and fixing small particles generated
during dismantlement activities. |
|
|
Benefits |
Disadvantages |
|
· Fixatives materials are
commercially available. · They are used throughout
the DOE and private sector. · Relatively inexpensive to
procure and use. · Little or no training or
experience required to use. · Adds very little secondary
waste to D&D operations. · Relatively effective in
reducing airborne contaminant concentration. · Contributes to reduction
in annual site emission dose.
|
· Not 100 percent effectve. · Many varieties are
available; must identify and select the most efficient, which may involve
some testing. · Would add some complexity
and cost to the operation. · Performance would depend
on conditions and parameters, and could vary from place to place. |
|
Identified
Risks |
|
|
Very little risk to
implement. Some fogs (glucose)
attract insects which may spread contamination if not controlled. Small risk of using ineffective material
or process and allowing contamination spread. Care must taken to ensure that the appropriate fixative be
matched to the surface being coated. |
|
SITE NOTE: It is unclear whether emissions reduction credit can be taken
for Instacote process. It would still
qualify for shipping and would be a best management practice.
Table 7.5. Concept No. 5, D&D Strategies
|
Component: Each site area |
Function: D&D strategy |
|
Alternative
Description |
|
|
The proposed strategy contains two basic elements: 1. Building work sequence Develop an overall plan that sequences building demolition work in a
way that effectively takes into account the different contamination levels
and contamination potential in the different areas, and thereby minimizes
radioactive emissions. 2. Final Status Survey Report process Prepare the Final Status Survey Report by area of the site, with
different survey units and report chapters for each area. Quickly provide draft report chapters to
the regulators, to facilitate speedy completion of independent verification
surveys on an area by area basis. |
|
|
Benefits |
Disadvantages |
|
· Effective sequencing could
reduce radioactive emissions during building demolishment · The final status survey
report process would facilitate turning the site over to the community faster
than would otherwise be possible · It would speed up the
final phase of project completion. · It would reduce costs by
saving time and site overhead costs. |
· None |
|
Identified
Risks |
|
|
· None. |
|
The team developed a Functional Analysis System Technique (FAST) chart to help organize the concepts and how they relate to the project objectives. A copy of this chart appears in Figure 7.1 on the next page.
Figure 7.1 FAST Chart
8.0 TEAM PROPOSALS
Based on the results of the study, the team offers the following recommendations for consideration by the site. Please note that the team acknowledges that the site has already considered most of these ideas and is planning on implementing others. The team also considers the present site D&D strategy to be well-thought-out.
Some of these proposals refer to innovative but proven technologies which might be used to advantage on the project. A detail list of these technologies, along with points of contact for more information, appears in Appendix E.
8.1 Proposal Number 1: Refining Emission Dose
Projections and Near-Real-Time Monitoring of Radioactive Emissions
Background
As indicated in the title, this is a two-part proposal.
The current CAP88-PC dose estimates for D&D of the Building R-SW complex show about 0.9 millirem (after the transfer of the parking lot) to the maximally exposed individual. Evaluation of the dose estimates by subject matter experts indicate that the estimate is conservative with a high degree of confidence, given the source term provided to the team, and that the actual off-site doses will most likely be substantially less. However, the subject matter expert did not do an independent evaluation of the source term.
About half of the dose from the R-SW complex is from tritium and the other half is from particulates (plutonium, thorium and actinium). The dose from tritium is conservative in the following respects:
· The dose from ingestion of tritium assumes that all food consumed by the MEI is presumed to be produced within 1500 meters of the site. Most food would realistically be produced at further distances. A more realistic ingestion model would probably lower the tritium dose by a.factor of 3.
· All tritium is presumed to be in the form of tritiated water, but about 20 percent is gas, which has 20,000 times less dose.
Alternative models such as CAP88-PC-T which models tritium gas could be used, but getting EPA approval for new models would be time-prohibitive, and it would only lower the dose by 20 percent at the most.
The dose from particulates (plutonium, thorium, actinium) may be conservative in the following respects:
· Soil activities are based on upper-bound estimates, and soil characterization is now underway. It is likely that the actual measured values for radionuclides in soil will be less than the estimates.
· The release fractions for particulates to air are set at 1E-3 by EPA, but the actual releases are likely to be orders of magnitude less.
It might be feasible
to justify more realistic release fractions based on actual operating
experience, but the team is not aware of any applicable data.
One issue that came out of the evaluation is the impact of ground-level releases. If the radionuclides were released from the 61-meter R-SW stack, instead of from ground-level as is presently assumed, the dose would drop by a factor of at least 100.
Regarding near-real-time monitoring of emissions, regulatory limits require that total off-site doses from all Mound operations be limited to less than10 mllirem per year. The present schedule for D&D has been established considering resource loading as well as cost and schedule minimization. Unmitigated off-site doses associated with this work have been estimated using CAP88-PC. In a number of cases individual project element dose estimates exceed the 0.1 millirem per year project threshold, requiring that regulatory concurrence be obtained prior to proceeding with the project. In total, the yearly unmitigated doses estimates for all Mound operations are somewhat below in some years and somewhat above the regulatory limit in 2004. However, as explained in the Proposal number 1, it is expected that these estimates are considerably high. If this is correct, there is plenty of room to perform unmitigated (i.e. “open air”) D&D as Mound is presently considering. However, the consequences of exceeding projected estimates can be substantial. These two factors emphasize the need for the Mound project to collect and track actual site doses with considerable frequency.
Proposal
The CAP88-PC dose estimates can be made lower by using more realistic assumptions. The first priority would be to characterize soils to produce a more realistic source term for the particulates released from soils, and the team understands that this characterization is underway now. A second priority would be to refine the tritium ingestion scenario, which should lower the dose by one-third.
The team also recommends that an evaluation of the source term be considered. The source term for tritium appeared low to one team member.
Management should be aware that the dose would be 100 times less if the D&D emissions were vented from the 61-meter R-SW stack.
In regard to near real time monitoring of emissions, the team considers that D&D work could proceed as scheduled initially, without implementing more than minimal fugitive emission controls. Offsite dose monitoring information should be collected and tracked on a weekly to monthly basis. If actual dose monitoring shows that levels are acceptable, the site could continue work as scheduled and consider the possibility of moving future year work forward. On the other hand, if actual emissions are leading to unacceptably high levels, the site would implement controls such as those contained in other proposals, and/or move D&D work to later years.
Reduced Emissions
This proposal would not reduce emissions but could lead to increased flexibility in performing D&D work. The second element, real-time-monitoring of emissions, would produce more current information for planning purposes.
Schedule Acceleration
Increased flexibility in performing work could lead to accelerating the schedule
Reduced Costs
If this proposal resulted in accelerating the schedule, costs would fall accordingly from reduced overhead.
Implementation
Implementation would involve additional characterization of soil with the attendant costs, and work by site health physicists to refine the calculations. The changes would need to be discussed with the regulators.
To implement near-real-time emissions monitoring, the site would need to changes procedures and increase efforts associated with the monitoring program to increase frequency of measurements and reporting. A system for tracking offsite doses would need to be implemented.
SITE NOTE:
This proposal would entail some risk of moving D&D work to later
years. This may not be an acceptable
risk.
8.2 Proposal Number 2: Comprehensive
Characterization
Background
The
team understands that somewhat more than 50 percent of the R-SW
characterization remains to be done.
The current radioactive material holdup prevents open-air demolition of
the facility due to emissions restrictions.
Site critical path is limited by removing more of the radioactive
material within the R-SW facility. The
team further understands that concrete slab and soil contamination and
contamination in the Old Cave are not included in the current 0.29 millirem
offsite dose projection from emissions, which is the dose estimate associated
with demolition of the R-SW facility after removal of most of the hold-up
radioactive material. Additional
radioactive material removal and characterization is expected, and actual
characterization data is expected to result in a reduction of the emissions
estimate.
The evaluation team understands that lead-based paint is known to exist in the R-SW complex, and that further characterization is necessary.
Proposal
Further
characterization efforts should be weighed against the needs of emissions
assessments. If the emissions estimate
is found to be too conservative and adjustments to the estimate are made,
additional characterization effort related to demolishing the R-SW facility may
be substantially reduced. The team
recommends that several sources of demonstrated or evaluated technologies be
reviewed to assure that the most effective and efficient technologies are being
used. These sources include the Office
of Science and Technology, D&D Focus Area’s web site (listing provided
separately), the Integrated Technology Suite (characterization suite of
technologies used at the Idaho National Engineering and Environmental
Laboratory and Fernald), and links to information provided during the April
2002 technical assistance visit to Rocky Flats Closure Project provided in
Appendix E.
Some specific technologies that may be helpful include:
· The use of ISOCS to estimate broad area hold up levels,
· Evacuate and analyze air from empty piping systems to determine content (Dick Meservey has experience with this method),
· Hammer drill to extract concrete samples, and
· PCB/lead paint analyzer.
Reduced Emissions
The proposal would reduce emissions, per se. Comprehensive characterization would facilitate more accurate predictions of emissions that could be released during building demolishment.
Schedule Acceleration
Both elements of the proposal could lead to accelerating the schedule depending on the characterization and air monitoring results.
Reduced Costs
If these proposals resulted in accelerating the schedule, costs would fall accordingly from reduced overhead.
Implementation
To implement the first element of this proposal, a characterization plan would be needed and the special equipment obtained. The characterization itself could take several months depending on the scope of additional effort involved.
8.3 Proposal Number 3: Tenting and Venting
Background
Conventional decommissioning would include large amounts of decontamination and removal of contaminated portions of the building before it is dismantled. However, because of the nature of the previous contamination, and the difficulty of proving clean or releasable status, the building materials would still be considered contaminated and disposed of as radioactive waste.
The team recognizes that MEMP previously used this approach and is now planning an “open air D&D” approach.
Proposal
The proposed approach would be to remove only the highly contaminated items from the building prior to starting its dismantlement. As an alternative or back-up to the completely “open air” approach, it is recommended that large tents and directed venting be used to contain emissions as dismantling of the contaminated building progressed. Because many areas of the building are already clean as a result of previous D&D activities, tenting would not be required during dismantling of much of the building. Thus, only selected areas would be tented to reduce emissions. All demolition materials would be classified as radioactive waste and disposed accordingly.
It should be recognized that tents can be supplied to cover the entire structure, or just portions of the facility being D&D=d. Rocky Flats has evaluated deploying a large tent to cover an entire structure much larger than the MEMP buildings and the related technical and economic aspects of this large scale application. In general, these large tents are considered permanent structures and thus must be built and maintained to a different set of standards than do the team’s recommended smaller, temporary tent structures.
It is recommended that open air demolition be done without use of tents, unless it can be shown that significant schedule reduction can be achieved through the use of tenting. However, if emissions from D&D operations are expected to exceed the annual dose limit at the site, then strong consideration should be given to full or partial tenting options.
In addition, specialized use of tents is recommended when dismantling the Old Cave (Option 2), and/or during waste handling and disposal operations at the waste staging area (Option 3). Use of tents might allow removal of the Old Cave to be delayed until after the building is removed. The Old Cave could then be excised under tenting using larger equipment, thus saving time.
Reduced Emissions
Use of tents with exhaust ventilation through the R-SW stack could obviously reduce emissions of particulate radioactivity and release tritium at the stack height rather than at ground level.
Schedule Acceleration
Use of tents would be unlikely to accelerate the schedule and could result in schedule delays due to lead time and installation time.
Reduced Costs
Use of tents could increase project costs.
Implementation
To implement this proposal, tents would need to be designed and procured. Tents are available from several manufacturers, including AEA Technologies. Crafts personnel would have to install the tents. Health physics personnel would need to approve their readiness and use.
SITE
NOTE 1: The tent approach makes
sense not only from an air emissions point of view, but also for alleviating
stormwater runoff/groundwater infiltration from the contamination area.
If rainfall can be kept off the excavation site while D&D is taking place,
that would minimize unnecessary movement of contamination into the
ground/groundwater and to the surface water from runoff. Controls to
prevent the spread of contamination are also required in Mound's Stormwater
Pollution Prevention Plan.
SITE NOTE 2: It is not a good
strategy to continue to perform open-air demolition until it runs out the
NESHAPS quota. This would be taking a
risk of stopping the project in the middle of the year. The impact for not continuing working on the
project could be significant, since the project end date becomes unpredictable,
not mentioning the ramp down and ramp up the resources. Also, regarding the recommendation for
tenting the "Old Cave,” the procurement and installation for the current
design have progressed half way to the current plan of remote operation within
an enclosure. The Old Cave project
should proceed with current plan instead of changing this plan.
8.4 Proposal Number 4: Technologies for Size
Reduction and Radioactive Waste Packaging
Background
In the MEMP D&D work, a large amount radioactive equipment is being sized reduced. Likewise, radioactive waste volumes will be relatively large owing to the project strategy. Making use of the most advanced proven technologies in both areas would be beneficial to the project. This would be especially important in the waste staging areas to help reduce the relatively high projected radioactive emissions from that area.
Proposal
Regarding size reduction technologies, the team recommends that that the site consider using some of those listed in Appendix E. The team has provided to the site a “white paper” on advanced size reduction methods that could prove helpful is selecting the most cost-effective technologies.
Regarding waste packaging, the team recommends packaging radioactive waste inside buildings to the extent practicable. Using intermodal containers and soil sacks would promote efficiency.
Wastes that are large and have an irregular shape could be packaged using the Instacote process, which is sprayed on but qualifies as a Department of Transportation strong, tight container
The value study team recommends for consideration three methods for reducing emissions at the staging area: (1) locating the staging area as far as practicable from the nearest offsite receptor, (2) reducing the amount of time that the waste is in the storage area, moving un-containerized waste offsite as quickly as possible, and (3) building an enclosure for staging area.
Reduced Emissions
Adopting the waste packaging practices outlined in this proposal could significantly reduce emissions.
Schedule Acceleration
The use of advanced size reduction equipment could help accelerate the schedule.
Reduced Costs
If this proposal resulted in accelerating the schedule, costs would fall accordingly from reduced overhead.
Implementation
To implement the use of more advanced size reduction methods would require purchasing, renting, or arranging to borrow equipment from other DOE sites. Special training would be necessary for some technologies.
Implementing the waste packaging recommendations would involve obtaining soil sacks and Instacoat and revising site waste management procedures to recognize these packaging methods. Relocating the staging area or enclosing it would involve some effort and expense, assuming that a suitable staging area nearer the center of the site is available.
8.5 Proposal Number 5: D&D Strategies
Background
Efficiency of the building demolition process would benefit from careful planning and sequencing, and effective sequencing could reduce radioactive emissions.
The last stage of the project will involve final status surveys to release the property from radiological controls. These surveys would be defined in a final status survey plan. The property, after building slab and contaminated soil removal, would typically be divided into different survey units, following MARSSIM protocol. A prescribed number of measurements would be taken in each survey unit to determine whether the cleanup criteria are satisfied. The team assumes that these criteria would be similar to the objectives for residual radioactivity in soil expressed in the Action Memorandum for Buildings R, SW, and 58 and the 58 slab (reference 6).
Following measurements by the site contractor, independent verification surveys would be performed by the regulators, or by another entity on the regulators’ behalf. Experience has shown that such independent verification surveys can take months to complete. This time would delay project completion and turnover of the remaining site property to the community.
Also, other sites have used different approaches in D&D of radioactively-contaminated buildings. Some examples of these different approaches appear in Section 2 of this report.
Proposal
The team recommends that the site consider implementing a two-element strategy related to building demolition and the final status surveys and the final status survey report.
The first element would be a carefully-thought-out sequence for building demolition. This sequence would entail taking down parts of the structure with the least radioactive contamination first. The rubble from this part of the demolition work would be immediately removed from the work area. Then controls to reduce emissions would be focused on the more contaminated parts of the structure as it is taken down.
The second element involves sequential completion of the final status surveys and the related report.
As one survey unit is completed, the site would quickly complete the report chapter for that survey unit and isolate the area involved. The site would complete its reviews of this chapter expeditiously, and provide the chapter in draft form to the regulators. This process will give the regulators all the site survey results in an organized form for each survey unit soon after site surveys and measurements of that unit are completed. It would also give the regulators an opportunity to complete independent verification surveys faster than would otherwise be possible.
This process has been proven effective on two large survey projects, those for Charleston Naval Shipyard and the Barnwell Nuclear Fuel Plant. In both cases, the last of the independent verification surveys was completed within two weeks of the last of the site’s surveys, even though the total final survey effort spanned 18 months or more. Reference (11) describes the how the process was used on the Barnwell Nuclear Fuel Plant project.
The team also recommends that the site consider lessons learned in the other D&D projects summarized in Section 2 of this report, if this has not already been done.
Reduced Emissions
As noted previously, the first element of the strategy would reduce emissions during building demolishment. The second element related to final status survey would not affect emissions.
Schedule Acceleration
The final status survey report strategy could cut several weeks or more off the last stage of the project.
Reduced Costs
By cutting time from the last stage of the project schedule, the final status survey strategy would reduce overhead costs during this time and thereby reduce project costs. Costs of implementation of the three-pronged strategy would be relatively small. Such costs would consist of project time spent on laying out the building sequence and final status survey report strategies, and time spent discussing the latter with the regulators.
Implementation
Implementation of the first element of this strategy would be straightforward. The Mound project team would lay out the best sequence for building demolition, something that the project team is planning on doing.
To implement the second element in the strategy, the site would need to lay out the strategy for the final surveys and compiling the report chapter by chapter. The regulators would need to be briefed on this strategy, along with plans for the final status surveys, and would need to agree to support the strategy. The community would be expected to support this strategy because it would speed up turnover of the property.
SITE
NOTE: Site verification surveys
follow the Mound 2000 process and are negotiated with the regulators. MARSSIM protocols may or may not be
used. Verification surveys are
processed by an offsite lab. EPA splits
a small percentage of samples at the same time that the site verification
survey is being taken. Also, each PRS
or building (“unit”) is issued a separate report so that effectively what is
described is what happens, although the process at Mound is streamlined in some
areas, somewhat more cumbersome in others.
There are no “chapters” as described; each unit has an on-scene
coordinator report. Pre-verification
sampling and final verification happen at least as quickly as the described
process.
9.0 The Path Forward
On August 1, 2002, the team presented its proposals to representatives from the MEMP, including DOE and BWXTO personnel and others. Appendix D lists those in attendance. The team also provided draft copies of this report, which documents the results of the workshop.
The team stands ready to provide follow-up support to the MEMP. Site requests for follow-up technical assistance on this project should be coordinated through the DOE Headquarters technical assistance lead, Skip Chamberlain, at telephone 301-903-7248 or e-mail Grover.Chamberlain@em.doe.gov.
10.0 REFERENCES
1. Clean Air Act (CAA) of 1954, as amended, Federal Code of Federal Regulations 40 CFR 61 Subpart H.
2. CAP88, Clean Air Act Assessment Package – 1998 (available at www.epa.gov/radiation/assessmment/ CAP88/).
3. Comprehensive Environmental Response, Compensation and Liability Act of 1980, as amended (CERCLA).
4. Superfund Amendments and Reauthorization Act of 1986 (SARA).
5. Mound Technical Manual MD-22153, Mound Site Radionuclides by Location.
Mound Plant, February, 11, 1998.
6. Action Memorandum: Buildings R, SW & 58 and 68 Slab Removal Action. Mound Plant: Miamisburg, Ohio, November 2000.
7. DOE Order 5440.5, Radiation Protection of the Public and the Environment. DOE: Washington, DC, Change 2, January 7, 1993.
8 The Rocky Flats Closure Project: Demolition of Building 776/777, Visit of April 16-18, 2002. DOE EM-50 technical assistance team, April 18, 2002.
9. Multi-Agency Radiation Survey and Site Investigation Manual (MARSSIM). NUREG-1575. U.S. Nuclear Regulatory Commission: Washington, DC, 2001.
10. McNeil, Jim. “Plan Ahead, Establish Support Lines, and Be Prepared for Surprises: Lessons Learned from the BNFP Decommissioning Project.” Radwaste Solutions, January/February 2001.
11. Minutes of National DOE Decommissioning HQ & Field Liaison Group Meeting, Amarillo, Texas, April 28-30, 1998. (available at www.em.doe.gov)
APPENDIX A
DRAFT
STRATEGY AND AGENDA
Miamisburg
Environmental Management Project
Mitigation
of Fugitive Emissions During Building D & D
Technical
Solutions Workshop
July
29-August 1, 2002
A
four-dayTechnical Solutions Workshop using the formal Value Methods Process
will be conducted at the Miamisburg Environmental Management Project
(MEMP). The six- step job plan be
followed in this Value Study. An
implementation plan detailing potential continued involvement of the Office of
Science and Technology (EM-50) in providing technical assistance and funding
will be developed as the final step. An
explanation of the activities in each step along with the approximate time and
date they will take place is as follows:
STEP 1 Information
Phase (off-site) – July 15-29
Approximately
two weeks before the study begins, the selected technical experts will be given
a packet containing extensive background information about MEMP and the
problems to be addressed. They will be
expected to arrive on site with a general understanding of the task to be
studied.
Information Phase (on site) - July
29, 1:00 to 5:00 PM
The study will begin at 1:00 PM with the normal
introductions and welcomes. This will
be followed by a brief management presentation detailing the expected scope of
the study, the anticipated outcome, and the criterion for judging success. Next, a detailed presentation of the
problems and the current plans to resolve them would be presented by the
project managers who would also answer clarifying questions from the Team. The remainder of the day would be spent touring
the subject buildings.
Information Phase (cont'd) - July
30, 8:00 AM to end of Step 1
Having been exposed to the problems and the proposed
technical solutions, the team will next use function analysis techniques to
reach group consensus on:1) what is actually being done; 2)
why is it being done; and 3) how is it being
done. The next step begins only
after the Team achieves this common understanding which is a critical component
of the Value Process.
STEP 2 Creativity
Phase - July 30, to completion
After achieving consensus, the Team used "Focused Brainstorming" techniques
to list as many ideas for possible alternative solutions as the group is
capable of producing. Both conventional
and unconventional ideas are encouraged.
The ideas are discussed only to clarify understanding with criticism or
development of the idea not allowed.
The step ends when the ideas stop coming.
STEP 3 Analysis
Phase - Begin July 31 - to completion
All ideas are next grouped and then discussed in sufficient detail for
group understanding. The ideas passing
the initial “ho-ho” test are then grouped, ranked, and then compared to
determine if they are viable alternatives to the baseline technical
approach. After verifying the potential
alternative meets all established criterion, the best ideas are then ranked
using a paired comparison technique. At
this point, an informal discussion is normally held with the project personnel
to insure there are no reasons why a particular alternative should not be
pursued.
STEP 4 Development
Phase - July 31 to 10:00 AM on August 1
The alternatives selected by the team are developed to
the full extent allowed by the time available and are described in a written
report. The report will describe the
proposal in detail and will attempt to show why it could be an improvement over
the present baseline. When possible,
the Life Cycle Cost and schedule of the alternative versus the baseline will be
determined.
STEP 5 Presentation
Phase –August 1 at 11:00 AM (tentative)
The results of the study are presented to management in
a close-out meeting. Team members
present any alternative proposals developed for management consideration and
answer any questions about the proposals, or lack of same (indicating baseline
cannot be improved).
The Draft Final Report is handed out at the end
of the presentation. It contains the
listing of all ideas, the details of the selection process used to select
alternatives, and the detailed write-up of each proposed alternative. It is expected the draft report will be
nearly complete and will be issued with few modifications.
(NOTE: Previous
Value Studies in OH have not contained an Implementation Plan because the
outside experts were not available for continued service. However, with the new EM-50 Closure Site Support
Program, continued technical assistance and technology deployment
funding may be made available to the site for the duration of the project.)
STEP 6 Implementation
Phase
If requested by the site, the team will develop a plan for continued
involvement in implementing the proposed alternatives. The plan would detail how MEMP may make use
of the team technical experts or make provision for expertise from other areas
or individuals. The technical support
could range from interactions with individual consultants on a continuing basis,
to a detail of a particular needed individual to work with the project for some
period of time. Assistance in technical
evaluation of proposals from others could also be provided by EM-50.
APPENDIX B
Workshop Participants
The following people participated in the MEMP workshop from July 29, 2002 until August 1, 2002.
|
Name |
Role, Discipline and Affiliation |
Telephone and E-mail Address |
|
Cliff Carpenter |
Team Leader Project Engineer NETL-DOE |
304-285-4041 Cliff.Carpenter@netl.doe.gov |
|
Sam Martin, PE, CVS |
Facilitator Engineer and Certified
Value Specialist SAMI |
303-918-4170 smartin@value-engineering.com |
|
Dave Eaton |
Participant INEEL |
208-526-7002 dle@inel.gov |
|
Ken Kasper, CHP |
Participant Technical Director Scientech, Inc. |
864-235-3694 kkasper@scientech.com |
|
Dick Merservy |
Participant D&D Technology Program INEEL |
208-526-1834 rhm@inel.gov |
|
Barry Parks |
Participant Health Physicist DOE Office of Science
(SC-83) |
301-903-9649 barry.parks@science.doe.gov |
|
Scott Willms |
Participant Tritium Facility D&D LANL |
505-667-5802 willms@lanl.gov |
|
Jim McNeil |
Participant Nuclear Facility D&D Consultant |
843-740-1947 jimmcneil@aol.com |
|
Ken Koller |
Recorder Koller Associates/CTC Consultant/Innovative
Technologies |
208-524-4726 kenkoller@earthlink.net |
|
Doug Maynor, CVS |
Co-Facilitator Certified Value Specialist DOE-OH Field Office
Coordinator |
937-865-3986 |
|
Jitendra Desai (part time) |
Observer Ohio Program Manager DOE-EM31 |
301-903-1434 jitendra.desai@em.doe.gov |
Background and Problem Description:
This technical solutions request
is focused on effective and efficient demolition of two tritium-contaminated
buildings (R, SW) plus three other buildings (WD, HH, and 38) with plutonium
and other contaminates of concern. All
five buildings are part of the Miamisburg Environmental Management Project
(MEMP). The current MEMP technical
approach centers on taking the buildings down and shipping them off-site as low
level waste. A new D & D plan calls
for leaving selected contaminated equipment and building components in place until
they can be removed and disposed of during the building demolition stage. This new approach is expected to yield
millions of dollars in savings in decommissioning and decontamination costs.
MEMP is located in the middle of a
residential area and is currently being developed as an industrial park
concurrently with the cleanup activities. Thus it is critical to MEMP that a
process to stabilize, fixate, and contain the contamination be implemented in
order to assure the safety of the public and the private industrial operations
being located on site. All work must
also conform to ALARA principles. The proposed technical solutions team study
is requested to recommend the most effective method of using commercial approaches
for demolishing these buildings. A
recommendation for a combination of risk reducing approaches, performed at
different times in the remediation process, will also be requested of the
Team.
The MEMP has several additional challenges while planning for the demolition of nuclear facilities contaminated with tritium and other radionuclides (mostly alpha). Characterization of the R and SW plus the other three buildings to determine the source term of contaminants has not been fully conducted. It is not clear whether the extent of contamination residing with the buildings would require decontamination prior to demolition.
Perhaps the most pressing concern the team will need to
address concerns the proper cleanup criteria needed to meet the NESHAPS
requirements during demolition. MEMP intends
to use CAP88 as an air dispersion model to demonstrate compliance with the
NESHAPS requirements. In CAP88 it
assumes that all tritium regardless of form (gas, tritium oxide or tritiated
compounds such as oil film, dust, rust) will contribute 100% to the air
emission. In reality, tritiated
compounds will not emit 100% (i.e., more likely 10%) to the air as fugitive
emission during demolition. This would
cause the model to overestimate the dose caused by tritium emission.
Scope:
The objective of this Technical Solutions Team is to recommend improvements to the proposed baseline technologies in demolishing the tritium and plutonium contaminated buildings. The Team will also be expected to identify opportunities for cost and schedule savings. Technical Solutions Team members with the expertise and experience needed to support the request for assistance from MEMP will be provided by the Office of Science and Technology.
The Team will be provided with extensive background information concerning the problems being addressed and the presently proposed technical solutions prior to arrival at the site. Upon arrival, the Team will receive a detailed briefing on the current baseline technology for the decommissioning and takedown of the contaminated buildings. The Team will then tour the buildings with the contractor and have any questions fully answered before the development of possible alternatives begins.
After the baseline briefing and tour, the team shall determine if more effective alternatives are available to achieve the closure objectives with improved cost and schedule. While MEMP’s current contractor has a plan for demolishing all of the selected buildings, the team should independently develop and recommend any technologies or different technical approaches currently available which can improve the proposed approach. The Team will be expected to concentrate on methods to reduce fugitive emission either before or during demolition. In addition to the obvious reduction in risk, the alternatives proposed should offer improvements over the cost and schedule resulting from the baseline methodology.
Objectives:
The primary objective of the Technical Solutions Team is to improve the MEMP Exit Plan by identifying better technologies and processes for demolition of selected building on the critical path of the MEMP Closure. Specific problem areas to be addressed by the Technical Solutions Team are:<