Richard C. Carmichael
NCPP Manager Environmental Safety &
Health, BNFL Inc.
Rocky Flats Environmental Technology Site
PO Box
4085, Building 883, Golden, Colorado 80402-4085
ABSTRACT
The National Conversion Pilot Project, (NCPP) is DOE's first facilities reuse initiative. The NCPP was launched by Secretary O'Leary in 1993 at the Rocky Flats Environmental Technology Site, Golden, CO. Planning began in April 1993 with hands-on D&D and refurbishment work starting in April 1994. The NCPP is currently on schedule and budget in its mission to decontaminate, decommission and refurbish two of four former weapons production facilities. These two facilities, buildings 883 and 865 representing 90330 square feet and 70 pieces of equipment will be available for commercial, non-weapons production activities in early 1997. An RFP requesting expressions of interest from private industry for use of these buildings was published in the Commerce Business Daily the fourth quarter of 1996. Responses were received early in January 1997. A contract for Stage III operations was awarded to Manufacturing Sciences Corporation at the end of January 97. Operational capabilities of the above facilities include metal rolling (up to 42 inches wide), forging, extruding, pressing, heat treating, welding, machining, and carbon dioxide cleaning. The NCPP has accomplished its mission with only one lost work day accident since the start of work. The one lost work day accident occurred outside of the contamination area while moving a piece of equipment.
Since historically the NCPP buildings were used for rolling, forming, crushing, and machining of materials containing beryllium and depleted uranium, an aggressive monitoring program consisting of equipment, area, and personal sampling was instituted. The NCPP program has collected over 3600 surface smears of equipment and building surfaces along with over 6000 personal breathing air samples.
This project, unique within the DOE, is currently converting two major buildings on the plant site in preparation for commercial metal forming/processing activities. Preparation for commercial operations involves the radiological and toxicological decontamination of the buildings, the removal of redundant facilities and the refurbishment of tooling and equipment required for operations. Project planning began in April 1994 with cleanup activities commencing in building 883 in April 1995 and in March 1996 in building 865. Completion of cleanup work will be completed in the second quarter of FY 1997.
Overall project management is the responsibility of Manufacturing Sciences Corporation (MSC) through a cooperative agreement with the DOE. BNFL Inc. is the principal subcontractor to MSC.
The NCPP can be viewed as a three way recycling project:
By recycling facilities, materials and labor, the project plans to show that the conversion of contaminated ex-weapons facilities into commercial uses can reduce the burden of underutilized facilities upon the DOE as well as being an economically viable commercial operation.
This paper describes the progress made to date in the decontamination and refurbishment of these facilities as part of the NCPP.
INTRODUCTION
The National Conversion Pilot Project (NCPP) is a recycling project currently underway at the Department of Energy (DOE) Rocky Flats Environmental Technology Site (RFETS) in Colorado. This paper describes the decontamination/dismantling and refurbishment experience of the NCPP from inception to now.
HISTORY OF THE SITE
RFETS has an area of 6,500 acres and is located 16 miles NW of Denver, Colorado. The plant site began operating in 1951, manufacturing weapons components and conducting plutonium processing operations. RFETS currently comprises numerous buildings within the plant site boundaries with radiological and/or toxic contamination. In 1993, the production oriented plant site mission changed to read "manage waste and materials, cleanup and convert RFETS to beneficial use in a manner that is safe, environmentally and socially responsible, physically secure and cost effective". This change of mission led to the cessation of production facilities with the plant site entering a surveillance and maintenance state while cleanup plans and options were considered.
THE NATIONAL CONVERSION PILOT PROJECT
In 1993 the Department of Energy (DOE) selected Manufacturing Sciences Corporation (MSC) to cleanup the radioactive and toxic contamination in four major plant site buildings in preparation for the possibility of using these refurbished buildings for commercial metal recycling and manufacturing operations.
The NCPP task involved four radiologically and toxicologically contaminated buildings on the RFETS plant site (883, 865 and 444/7) with a combined floor area in excess of 200,000 ft2. Equipment within these buildings includes ovens, furnaces, presses, metal rolling equipment, shears, forges, lathes and other metallurgical processing equipment. Equipment of note includes nine vacuum induction melting furnaces, one new vacuum arc remelting furnace, two large rolling mills, a new 2000 ton extrusion press and six hydraulic forming presses including two 2000 ton presses and two 300 ton presses with 64" strokes This equipment would be valued at $92M if installed new today. Following the end of the Cold War and the change of mission at RFETS, these buildings and contents became surplus to requirements.
The buildings were selected principally because they contained machinery and tooling suitable for metal recycling operations. In addition, the buildings were located such that they could be accessed by contract personnel without affecting the security of other parts of the plant site.
In April 1994, the DOE entered into a Cooperative Agreement with MSC to perform this work. MSC selected BNFL Inc. as its principal subcontractor to utilize experience gained by BNFL Inc.'s parent, British Nuclear Fuels plc, conducting similar cleanup at its UK sites.
The NCPP was authorized in December 1993 by Secretary of Energy Hazel O'Leary to proceed in three distinct stages with the first stage commencing in April 1994. The NCPP is being conducted through a Cooperative Agreement which was signed April 1, 1996 between the US DOE Rocky Flats Field Office and Manufacturing Sciences Corporation (MSC).
STAGES OF THE NCPP
The Project has three stages. Stage I was the feasibility and planning phase of the project and was completed in September 1994. Stage II, the current project stage, involves cleanup and refurbishment and the removal of unnecessary equipment from the facilities. Equipment retained for Stage III in buildings 883 and 865 has been decontaminated and restored to operational use. Building contamination has likewise been reduced to a level suitable for recycling operations. Stage III is the recycling and manufacturing phase of the Project. A Request For Proposal seeking expressions of interest from private industry for use of these buildings was published in the Commerce Business Daily the fourth quarter of 1996 and a award made to Manufacturing Sciences Corporation the first quarter of 1997.
Stage I
Stage I set the ground work for the successful implementation of decontamination, dismantling, and refurbishment of NCPP facilities. What makes the NCPP unique is a flexible work approach achieved with the help and support of DOE Headquarters and RFETS. The NCPP also enjoys the strong backing and support of its DOE Project Manager.
Some aspects that give the NCPP flexibility are:
A multi-skilled team approach means that each team worker performs multiple tasks. The NCPP hired employees with base competence in multiple areas - welding, sheet metal, electrical, pipe fitting, radiation control, machinist, etc. The base competence of workers was verified and certified. Workers were then given additional skilling to round out or enhance competence in areas needed to perform D&D and refurbishment. The NCPP assembled these workers into teams and matched work to a team's predominate skill sets. If a work package contains a large amount of welding/cutting, then the team with the highest competence level is selected. Competence is an on-going process to maintain or broaden a worker's skill set. This program not only benefits the project, but the workers as well by giving them additional marketable skills.
The NCPP manages D&D work by means of work packages written for each new job or process. The work control process takes advantage of the experience and knowledge of team workers. Work packages are written as a team effort between workers, operations, and ES&H. This process takes advantage of worker knowledge and achieves better buy-in by those actually performing the work. In order to assure that the hazard analysis includes the most current situation specific information for the work to be performed, a job safety analysis (JSA) is performed for each work package. The JSA hazard analysis includes identification of the operation or job, a break down of the individual steps required to perform the job, an identification of the potential health and safety hazard hazards associated with each step, and a determination of the necessary controls and personal protection equipment to be used to eliminate or mitigate each hazard along with any required permits. Once the work begins, the NCPP ES&H performs its own radiological, industrial hygiene and safe workplace audits to ensure that health and safety of employees is not impacted by operations.
A DOE Headquarters approved health and safety program compliant with OSHA regulations that also allows flexibility in the approach to work was implemented. The NCPP is conducted as an interim measure/interim remedial response action (IM/IRA) under CERCLA. As such the requirements of 29 CFR 1910 apply. 29 CFR 1910.120, "Hazardous Waste Operations and Emergency Response," specifies the requirements of the Health and Safety Plan (HASP) for such actions. The NCPP Stage II Occupational Health and Safety Plan meets those requirements. What makes the NCPP HASP flexible is the dynamic approach to task and operational specific safety and health risks or hazard analysis. Work is controlled by means of work packages written for each new job or process. These work packages become part of the HASP when written and approved. This ensures a current HASP and hazards analysis for all work. The NCPP ES&H audits each job from start to finish. ES&H, in concert with the work teams, can make pen and ink revisions to work packages on the work floor in response to changes in work conditions and hazards or in response to discovery during work. Jobs requiring immediate response can be performed without a JSA as long as the work is under the direct oversight of ES&H.
A DOE approved Radiation Protection Program compliant with 10 CFR 835 was also implemented. The NCPP Radiation Protection Plan (RPP) was written to meet the requirements of 10 CFR 835 as it applied to the planned work and building contamination and conditions. Procedures address the radiological hazards associated with the NCPP buildings. Specified personal protective equipment is adequate to protect workers in a uranium environment. The NCPP elected not to cite the RFETS Radiological Control Manual in its RPP because the Manual went well beyond minimum NCPP needs as well as related statutory or regulatory requirements. This approach gave the NCPP greater flexibility in how work must be performed and controlled. The value added included more efficient and effective work activities and cost savings.
Stage II
Stage II began in October 1994 and received regulatory sanction in April 1995 with the approval of the Interim Measures/Interim Remedial Action Decision Document which has been used to direct activities to take place in Stage II and to solicit public involvement in the project.
The Project is considered to be a recycling operation and, as such, recycling is along three lines:
FACILITY RECYCLING
Each of the four buildings eventually will be converted from weapons production operations to a part of a commercial metal recycling operation. Each building contains unique metal working equipment, much of it valuable, some of it unused but all still operable with, in some cases, minor maintenance. Unwanted equipment is being removed (as described above) for reuse elsewhere or, if not economically feasible to recover, being retained as recycle scrap for Stage III if suitable, or disposed as waste. Equipment within the buildings is being reorganized as necessary to facilitate process flows. Equipment to be retained is being refurbished after cleaning. With full funding all buildings will be returned to operational status prior to the end of Stage II.
MATERIALS RECYCLING
Each building contains materials which are suitable for recycling into commercially viable products. These materials fall into one of three categories: depleted uranium, beryllium and radioactive scrap metal. As each building undergoes cleanup, stocks of depleted uranium and beryllium, not required by the DOE, are being recovered and stored pending Stage III recycling. Radioactive scrap metal arising from the cleanup process as unwanted equipment is dismantled and removed. Scrap suitable for use in future recycling operations is being retained in the building following size reduction. Not all metal scrap is suitable for recycling. Stainless steel is the preferred Stage III feedstock. However, substantial sections of other steels are being retained as additional feedstock materials. Within the three buildings, it is expected that 200,000 lb. of depleted uranium, 80,000 lb. of beryllium and 160,000 lb. of recyclable steel exist.
LABOR RECYCLING
With the change of mission, production operations ceased on plant site resulting in reductions in force. The final aspect of NCPP recycling concerns the reuse of labor made available due to the RFETS mission change. Approximately 88 percent of the Stage II work force are displaced RFETS workers. Many of the displaced workers have a working knowledge of the NCPP buildings, both operationally and through maintenance. Workers seeking to join the project undergo a selection procedure which considers their existing skills and experience which are relevant to the project. Workers, when hired, go through a cultural retraining and receive training in essential areas where they do not have relevant experience. There is no 'blanket' training for all employees. Flexible working methods and a team approach to working practices are encouraged.
STAGE II CLEANUP METHODS
Prior to the beginning of work, smears of all accessible areas of equipment along with floors, and walls are taken and analyzed for radiological and beryllium contamination. Direct readings for radiological contamination are also taken to determine fixed contamination. Removable radiological contamination is measured using a Tennelec purchased by the NCPP. Direct radiological contamination is measured using hand-held instruments. Removable beryllium contamination is sent to a commercial analytical laboratory under contract to the NCPP. In addition, sampling for other contaminants of concern (asbestos, PCBs, chlorinated solvents, etc.) is performed based on historical documents or equipment labeling. Clearance of samples for release to the laboratory is performed by the RFETS Integrating Management Contractor. The commercial laboratory provided rapid analysis times on an extremely cost competitive basis. NCPP contract laboratories are required to maintain a license to receive, handle and store radiological material. Despite this, and the radiological characterization performed on each sample by the NCPP, the major delay in obtaining results was in releasing samples from RFETS.
Characterization of equipment and surrounding area is used to determine the decontamination procedures and PPE required for each work package. Characterization is used to determine if equipment requires decontamination, can be hand wiped, needs chemical and/or mechanical decontamination, requires an enclosure for decontamination, is best cleaned in-place or moved to a centralized decontamination facility, and so on. Characterization is also used to determine PPE and engineering controls to mitigate exposure to workers. Examples of PPE are respiratory protection and layers and types of protective clothing and gloves. Examples of engineering controls are ventilation, enclosures, and screens.
In addition to the above considerations, the type of decontamination processes used is restricted by requirement the NCPP imposed on itself. These included a requirement that no free liquid effluent be produced, and that solvents used for decontamination be non toxic and contain no RCRA controlled constituents. Many of the effective decontamination solutions available on the market were incompatible with this requirement.
The cleanup systems chosen were wiping with acceptable decontamination reagents, vacuum cleaning, grinding, grit blasting and CO2 blasting. The CO2 system existed on plant site although it had rarely been used. The system was recovered, assembled, tested, and the existing HEPA filtered booth re-configured. It now operates successfully as a non-destructive decontamination system which produces little secondary waste.
Dismantling methods are largely manual for many of the same reasons described above. Refurbished equipment is dismantled, cleaned, refurbished, and reassembled, using powered and non-powered hand tools (wrenches, sockets, etc.). Equipment to be disposed is disassembled much the same way but with less care and with the addition of size reduction methods such as plasma arc and oxyacetylene cutting, and cold cutting methods (saws, grinders, nibbler).
Wherever possible, decontamination is carried out centrally in the CO2 chamber with dismantling and reassembling operations performed locally.
CLEANUP PROGRESS SO FAR
Cleanup activities began in April 1995 with the following accomplished to date:
The work is being accomplished by seven work teams - five decontamination teams, one waste management team, and one survey team. Decontamination, dismantling and refurbishment operations in building 883 are complete as is the final survey of all building equipment, ceilings, walls, and floors.
All items to be disposed in building 883 have now been size reduced and either stored as recycle material or disposed as waste. Twenty five items have been dismantled and removed including a laser inspection table, two nitric acid baths, a sheet scrubber, a small rolling mill, three salt baths, numerous small ovens, three large ovens, two large furnaces, one pit furnace, two shears, two small mills, one large lathe, three fork lifts, and miscellaneous small equipment. The remaining twenty eight pieces of equipment have been cleaned, dismantled, refurbished, reassembled and operated. These items include two large rolling mills (used for uranium sheet rolling), five hydraulic presses (two 2000 ton / one 300 ton / and two 300 ton clearing), a salt bath, a bench lathe, two large vertical lathes, four shears, four ovens, two grit blasters, a roller grinder, a powered hack saw, fork trucks and man lifts, and all the building cranes. Final work in the building included floor repairs (minor and major), final decontamination and building surveying. Over 88,00 ft2 of floor, wall and ceiling surfaces have been cleaned with 35,000 lb. of recyclable material retained for Stage III operations. To date over 7,000 ft3 of low level waste we repackaged and about 5000 ft3 transferred out of the building. During the same period, the amount of low level mixed waste created was 3000 ft3 with about 300 ft3 shipped.
Work in building 865 has begun with the refurbishment of 11 items including the Sutton extrusion press, hydrospin, numerous lathes and drill presses, cranes, man lifts, and an automatic welder. Thirteen items have been dismantled including five ovens, a large swager, lathes, a 36 inch cut off saw, and bench grinders. Due to the beryllium contamination in building 865, a major decontamination effort has been under taken.
Decontamination methods used so far have proved effective as much of the contamination encountered has been removable. Considerable success has been achieved using the CO2 system for removable material decontamination. Fixed contamination has been effectively removed using grit blasting and mechanical grinding methods where feasible.
Plasma arc cutting has proven effective and quick, particularly, in sectioning stainless steel. The use of containments with HEPA filtration has contained airborne contamination well though the smoke encountered using plasma cutters has shown a tendency to block filters prematurely. Additionally, it has been difficult to mitigate worker exposure to metal fumes when cutting in containment. To control fume generation and protect workers, a special HEPA filtration system using a diatomaceous earth pre filter has been installed. Additionally, mechanical cutting size reduction methods have been effective although more arduous than plasma cutting.
Due to concerns over removable contamination, primarily beryllium, in the NCPP buildings an aggressive breathing zone air monitoring program was initiated. Personal breathing zone air samples are used to provide air particulate sampling in the breathing zone of all individuals entering the contamination area to perform work. Sampling is performed using NIOSH Analytical Method 7102.
WASTES
Waste arising from all Stage II operations has been estimated at 53,500 ft3 of solid low level waste with another 20,000 ft3 of solid low level mixed waste. By comparison, the project is expected to generate over 335,000 ft3 of materials suitable for recycling in Stage III which would have otherwise been disposed of as waste.
STAGE III OF THE NCPP
Stage III is initially planned as having a five year duration with an option for extension if viable. Products to be manufactured in Stage III will utilize the facilities, materials and workers used during Stage II. Intended customers for these commercially viable products will be the DOE and other government and private interests.
It is intended that prototypes developed and fabricated during process verification activities in Stage II will become suitable products during Stage III. Typical products being investigated include coffee-tin sized stainless steel containers suitable for plutonium storage and 100 ft3 steel containers for LLW shipment and storage.
FUTURE COMMERCIALIZATION OF DOE FACILITIES
The mission of the NCPP is to provide a model of how weapons facilities can be converted into commercially viable operations. The success of the Project with the associated transition from DOE Order regulatory control to a Nuclear Regulatory Commission agreement state license will determine whether this type of operation can be attempted at other DOE facilities.
ACHIEVEMENTS OF THE NCPP SO FAR
Though only about half-way through the four Stage II buildings, the NCPP has achieved the following:
CONCLUSIONS
The NCPP is the first project of its kind to try and convert contaminated ex-weapons facilities into commercially viable operations. The cleanup and refurbishment operations in Stage II are a fundamental part of this project. The Project uses the experience of decontamination and dismantling operations from other facilities in the planning and execution of cleanup methods at Rocky Flats.