Arthur G. Samiljan
Radiation Safety Officer,
Manufacturing Sciences Corporation
Rocky Flats Environmental Technology
Site
PO Box 4085, Building 883
Golden, Colorado 80402-4085
ABSTRACT
The present paper outlines the development, review, approval process, implementation, and administration of an independent Radiation Protection Program (RPP) for a decontamination and decommissioning project at Department of Energy (DOE) facilities. The radionuclides of concern for this project are uranium 235U/238U and 239Pu/241Am. The RPP meets all the requirements of 10 CFR 835 and demonstrates that a private contractor can achieve tangible radioactive cleanup results outside the authority of, but in concert with, the site's integrating management contractor.
INTRODUCTION
In 1993 the Vice President of Manufacturing Sciences Corporation (MSC), presented the Department of Energy (DOE), at the Rocky Flats Environmental Technology Site (RFETS) a proposal that would make surplus DOE equipment and facilities available to private industry. DOE accepted the proposal and the National Conversion Pilot Project (NCPP) was authorized and funded to determine if it is economically and practically feasible for DOE to lease surplus facilities and equipment to private firms for the manufacturing of products.
The National Conversion Pilot Project (NCPP) is the first of its kind to convert a former Department of Energy (DOE) weapons production facility into a private commercial enterprise. The NCPP aims to demonstrate that contaminated DOE facilities and equipment can be cleaned up and reused for commercial purposes. Significant cost savings can be realized through the refurbishment of surplus facilities and capital equipment valued at $92M. Additional benefits include re-employment of former production workers, re-cycling of scrap metal which would have otherwise been disposed of as contaminated waste, the declassification of 272,000 pounds of classified parts and tooling, and profitable commercial use of otherwise idle facilities and equipment. The success of the NCPP to transition from DOE Order regulatory control to a Nuclear Regulatory Commission (NRC) license will determine the viability of private commercialization at other DOE facilities.
THE PROJECT
The Project is organized into three distinct stages. Stage I commenced in April 1993 to establish an oversight entity comprising DOE, federal and state regulators and local Stakeholders, securing the necessary approvals to proceed with Stage II, and to begin characterization of the clean-up and refurbishment effort. Stage II commenced in October 1994 to hire and train employees, complete facility and equipment characterization, clean-up and refurbishment, conduct a baseline contamination survey and independent verification, and submit an application to the Colorado Department of Public Health and Environment for a Colorado Radioactive Material License. Stage III is projected to commence in the summer of 1997 with a private company to manufacture a commercial product or products under a Colorado Radioactive Material License in lieu of the DOE RPP.
DOE RADIATION PROTECTION PROGRAM
Part 835 to Title 10 of the Code of Federal Regulation (10 CFR 835) became effective in January 1993. It required each DOE site involved with nuclear activities to submit to DOE Headquarters a Radiation Protection Program (RPP) by January 1, 1995 and be in full compliance with 10 CFR 835 by January 1, 1996. During the interim period between DOE Order 5480.11 (occupational radiation protection standards) and full compliance under 10 CFR 835, DOE published the DOE Radiological Control Manual (Manual) to establish practices for the conduct of DOE nuclear activities. The Manual required the contractor senior site executive to issue and endorse a Site-Specific Radiological Control Manual that invoked the requirements of the Manual.
The EG&G Rocky Flats senior site executive for RFETS issued a Site-Specific Radiological Control Manual in 1994. It was cited in its entirety to fulfill the requirements for an RPP in 10 CFR 835.101. The RFETS RPP specifically excluded the NCPP activities and thereby forced the NCPP to establish an independent RPP in order to continue cleanup work activities.
NCPP RPP
The initial NCPP strategy was to use the RFETS RPP that had already been submitted for DOE approval. It was first thought that only minor name changes would be required to modify the RFETS RPP into an acceptable NCPP RPP. After reviewing the RFETS RPP and the requirements of 10 CFR 835 it was obvious that in many cases the RFETS RPP went well beyond the statutory and regulatory requirements necessary for an acceptable RPP . The provisions of the RFETS Manual developed in the pursuit of excellence and incorporated in the RPP are not found in 10 CFR 835 and are not subject to regulatory enforcement unless they are committed to in the documented RPP. The NCPP decided to develop an RPP in compliance with 10 CFR 835 and not to incorporate the RFETS Manual. This approach gave the NCPP greater flexibility because site-specific Manuals generally contain far more detail than that required for an RPP by 10 CFR 835. This resulted in more efficient and effective work procedures to be developed. In addition, endorsement of the entire site-specificManual as documentation of the RPP would make violations of those provisions not specifically required by 10 CFR 835 subject to enforcement under 10 CFR 835.101(a).
The NCPP RPP submission to DOE consists of four parts. The primary document is the RPP itself which describes the program and includes its purpose, scope, and policy, responsibilities, ALARA (as low as reasonably achievable), revision criteria, and reference to appendices A and B. Appendix A to the RPP states 10 CFR 835 requirements and NCPP's commitment to those requirements. The commitment is a verbatim restatement of applicable 10 CFR 835 requirements, as opposed to using site-specific Manual wording. Appendix B lists each requirement of 10 CFR 835 and the associated NCPP compliance status, keeping in mind that full compliance was not required until January 1, 1996. An implementation plan leading to full compliance by January 1, 1996 was addressed for each requirement where NCPP was not in compliance. The fourth part is the Crosswalk document that lists each requirement of 10 CFR 835 and the NCPP programs, plans, and implementation documents necessary to demonstrate that compliance with each rule requirement could be achieved.
DOE REVIEW TEAM
After the NCPP RPP was officially submitted to DOE, a 180 day clock begins. In accordance with 10 CFR 835.101(j), an initial RPP or an update shall be considered approved 180 days after its submission unless rejected by DOE at an earlier date. The DOE Rocky Flats Field Office (RFFO) assembled an Implementation Plan Review Team (IPRT) comprising of representatives from affected RFFO organizations, subject matter experts, and the cognizant secretarial officer. The NCPP Radiation Safety Officer (RSO) was a team advisor and provided the primary source information. The team convened at RFETS to review the RPP documents.
REVIEW CRITERIA
The "Department of Energy Review Criteria for the 10 CFR 835 Documented Radiation Protection Program (RPP)", December 12, 1994 was developed by the DOE Radiological Control Coordinating Committee to provide consistency in RPP reviews across the DOE. The review criteria of this document was utilized by team members while performing the review.
The goal of the DOE review is to assure the approval of an RPP, provide an accurate assessment of present compliance conditions, and in the case where the program is not in compliance, provide an achievable implementation plan to meet compliance by January 1, 1996. The document must adequately address the required elements as specified in Part 835.101 and accurately provide information that (relative to radiological protection) reflects the current situation, corrects all identified problems, and reflects appropriate priorities.
REVIEW
The review team reviewed four aspects of the RPP utilizing the entire implementation of Part 835. The four aspects comprised the four required elements of an RPP specified in Part 835.101. This portion of the review was intended to assure that the requirements of Part 835 have been addressed in all appropriate portions of the RPP. The aspects included scope, ALARA, address of each part, and plans, schedules, and budget. In addition, the team reviewed 10% of sample requirements selected from each subpart of the rule. Each requirement was reviewed from interpretation and assessment of current compliance status through planning, scheduling, budgeting, and verification of compliance.
Comment resolution was accomplished through a formal process, however, problems identified by the review process were often discussed and resolved on the spot since the NCPP representative attended all team meetings. Attendance at all team meetings by the NCPP representative enhanced the review process by allowing face to face discussion of each problem identified by the team. Most problems were resolved on the spot and the issues and expectations were defined and understood by all parties for problems that could not be immediately resolved. Formal comments were provided by each team member with the comment disposition developed by NCPP and provided to the comment author. If the comment disposition was determined inadequate, discussion between the appropriate individuals provided a resolution. Problems that could not be resolved by discussion were elevated to management. Final resolution was documented as an attachment to the comment form. No problems were identified that required DOE-mandated changes to the RPP.
RPP APPROVAL
Upon completion of the review, final resolution of all issues, and revision to the RPP the IRPT's review report and recommendation was sent to DOE Headquarters for review and final approval. DOE has 180 days to approve or deny an activity's RPP once it has been submitted for review. If DOE fails to approve or deny an RPP in 180 days it is approved by default. The NCPP RPP was approved in four months after submittal to DOE.
RPP IMPLEMENTATION
To the extent possible, implementation of the NCPP RPP had begun during its development since restricted work activities were authorized by the DOE RFFO Plant Manager. Standard operating procedures were approved, however, implementation at the working level could not be accomplished until the RPP was approved and the work authorized. After receiving DOE approval of the RPP in September 1995, and the lifting of work restrictions, Stage II work officially commenced. The NCPP became subject to DOE enforcement under the Price Anderson Act for all rule requirements on January 1, 1996.
CONCLUSION
The NCPP RPP is new and different for a DOE site because it meets the requirements of 10 CFR 835 and not necessarily those of the Manual. The DOE has approved a program that is more in line with private industry standards. What is ALARA for DOE is not necessarily ALARA for a private firm in business for profit. The NCPP RPP allows for more flexibility and options giving privatization a better chance. With this great opportunity, it is imperative that workers fully comply with written procedures and all other documents that make up the RPP. DOE and RFETS workers and inspectors are constantly challenging NCPP work procedures because many are different from the RFETS RPP and Manual requirements.
Worker qualifications, training, procedures, instrument calibration, dosimetry, bioassay, and ALARA are just a few areas that require constant and close vigilance. Continuous audits
and assessments of the RPP are performed by DOE, Kaiser-Hill, and NCPP management. Compliance with the NCPP RPP is paramount in the success of the NCPP.
REFERENCES