Amber Clay
Simulation Dynamics
Maryville, TN

John F. Suermann
Argonne National Laboratory
Argonne, IL

Donald Galbraith
U.S. Department of Energy
Carlsbad Area Office
Carlsbad, NM

L. Ronald Levis
Roy F. Weston, Inc.
Rockville, MD

The U.S. Department of Energy (DOE) Carlsbad Area Office (CAO) developed a strategy to obtain private sector mobile systems vendors to perform contact-handled transuranic (TRU) waste characterization and packaging operations to prepare the waste for transportation to and disposal at the Waste Isolation Pilot Plant (WIPP). The larger DOE TRU-waste sites plan to perform most of the required TRU-waste characterization and packaging operations in-house. However, these larger sites need outside vendor support for specific services to meet waste shipping schedules. Smaller sites, including several private sector sites where TRU materials were processed, have either very limited or no capability to characterize or package waste to meet the WIPP Waste Acceptance Criteria. These smaller sites must use outside vendor support to complete waste characterization and packaging cost effectively and on schedule.

The CAO surveyed companies that provide mobile waste management services to verify the availability of the needed services. They solicited these private sector vendors to participate in Cooperative Agreements under which the vendors share in the cost of becoming approved by the CAO to provide services to the TRU-waste sites. The CAO selected two vendor teams to develop the required plans and procedures needed to perform the necessary operations and to participate in the WIPP Performance Demonstration Programs (PDPs) for nondestructive assay, RCRA constituent analysis, and analysis of simulated waste container headspace gas. Final CAO approval for the vendor teams to be deployed to the TRU-waste sites is scheduled for March 1998.

The CAO has determined that using mobile systems, particularly at the smaller sites, has the potential to yield significant cost savings and shorten the schedule for readying TRU waste for shipment. By using mobile systems at five sites scheduled early in the program, the DOE expects to save more than $40 million and hasten waste preparation by more than two years on average.

Several years ago the CAO evaluated the options for disposing of TRU waste located at 13 small-quantity sites (SQSs) across the U. S. About half of these sites are owned by private sector companies or universities that had provided services under contract to the DOE, while the rest are small DOE-owned sites. Two options appeared to be reasonable: ship SQS waste to one of the large DOE TRU-waste sites, or characterize and package the waste at the SQSs for shipment directly to the WIPP. In a few cases, the waste was sufficiently characterized that it could be shipped to a DOE site for final characterization and certification before being sent to the WIPP. (Two SQSs recently did so.) However, most of the sites have neither sufficient data nor adequate facilities to perform the minimum characterization needed to ship the waste off-site. CAO concluded that using mobile characterization equipment and personnel at the SQSs was the preferred approach.

In 1996 the Westinghouse Waste Isolation Division issued the Mobile Waste Characterization Systems Analysis Report (1) which found that "...mobile waste characterization systems have immediate application in regard to assisting the large quantity sites in filling the pipeline to the WIPP." This report encouraged developing mobile waste characterization capability for both the SQSs and the large DOE sites.

In December 1997 the CAO issued the first revision to the National Transuranic Waste Management Plan (2) which establishes a summary schedule for shipping waste to the WIPP from the various TRU-waste sites. The schedule optimizes the receipt of waste at the WIPP to achieve efficient operation of the facility and to maximize the quantity of waste disposed of during the facility's operating life of 35 years. This Plan confirmed that several of the large DOE sites needed mobile characterization and packaging support to supplement their capabilities and increase their throughput to meet the Management Plan schedule. In addition, CAO believed that using mobile characterization and packaging systems at several of the smaller DOE sites would avoid more costly permanent additions to their limited waste management facilities.

Having defined the need for considerable mobile characterization services, the CAO then determined the best approach to deploying the needed services at the TRU waste sites. They evaluated contracting alternatives and implications resulting from potential use of private sector vendors. The primary concerns were:

• Availability of capable vendors for the specific services needed at the sites at the required time
• The complexity of integrating mobile service vendors into each site's certification process
• The cost of many small procurements by each of the sites compared to the cost of a single procurement for the Program
• Options for funding the capital expenditures for the mobile systems and equipment
• Potential competition among the sites for the services of capable vendors.

They developed an approach that offered favorable solutions to these concerns. That is, to have the CAO contract with one or more "full service vendors," have them prequalified to perform the required services, and deploy them through a competitive bidding process to the TRU-waste sites on a schedule that best meets the needs of the Program and the sites.

The CAO next developed a detailed plan to implement the full service vendor approach. The Mobile Systems Capability Plan (3) was issued in September 1996 after an extensive study to identify and resolve the more detailed issues and questions remaining from the earlier CAO evaluations.

The planning process began with identifying the potential private sector vendors who had the demonstrated capability to perform waste characterization and packaging operations. There were a number of vendors providing specialty mobile services - such as nondestructive assay or sampling and analyses for RCRA hazardous materials - to the DOE complex. In addition, potential vendors were working with the DOE in technology development programs under the Office of Science and Technology (EM-50). It was believed that there were sufficient private sector companies that had demonstrated the same or similar operations in the private and utility sectors and in the DOE complex to support the CAO's needs. This was confirmed by responses received to a survey sent to individual companies, both domestic and foreign, and from feedback from two workshops held by the CAO as part of the development of the Mobile Systems Capability Plan.

It was clear that the private sector had considerable mobile service capabilities, either already available or well into the development stage. It was also clear that most of the companies were highly specialized and that no one company could provide all of the diverse services needed. Therefore, CAO expected that teams of companies would be formed to propose on the work.

The CAO also surveyed the TRU-waste sites to determine the type and extent of mobile system services and the schedule for such services that each site would need to meet both the overall Program schedule for receipt of waste at the WIPP and, equally important, to meet individual site regulatory and local agreement milestone dates.

The requirements for characterization of TRU waste destined for disposal at the WIPP are based on a combination of regulatory drivers with which the WIPP Program must comply. The Program's implementation of these drivers is defined in the applications submitted to the regulatory authorities to obtain the required permits and certificates needed to package the TRU waste, transport it to the WIPP site near Carlsbad, New Mexico, and dispose of it underground in the WIPP facility. Specifically, the TRU waste must be characterized to confirm that it complies with requirements in the Certificate of Compliance (C of C) issued by the Nuclear Regulatory Commission (NRC) for the TRUPACT-II Type B transport container, the Compliance Certification Application (CCA) submitted to the Environmental Protection Agency (EPA), and the Waste Analysis Plan (WAP) of the RCRA Part B Permit Application submitted to the New Mexico Environment Department. The characterization requirements from the applicable Program documents have been consolidated in the Transuranic (TRU) Waste Characterization Quality Assurance Program Plan (QAPP) (4).

The waste characterization activities to be performed by the mobile system vendors include:

• Waste container headspace gas sampling and analysis for 28 target volatile organic compounds (VOCs) and for hydrogen and methane
• Sampling of a statistically significant number of randomly selected waste containers of homogeneous solidified waste and soil/gravel and analysis of the samples for RCRA listed and hazardous constituents, including total VOCs, total semi-VOCs, and total metals
• Nondestructive examination (NDE) of waste containers using real-time radiography (RTR) to verify the waste form and estimate the amount of rubber, plastics, and cellulosics in the containers, and visual examination of a statistically significant number of randomly selected containers to verify the RTR results
• Radioassay, including both nondestructive assay (NDA) and radiochemistry, to determine the curie content and isotopic distribution for isotopes of plutonium, uranium, americium, cesium, and strontium

In addition to the testing, sampling, and analysis activities summarized above, the mobile system vendors will provide packaging services including:

• Repackaging of waste stored in unacceptable containers (e.g., large wooden boxes), including any sorting and size reduction needed, and documenting the container contents
• Weighing waste containers to support unit weight calculations and to verify compliance with container and TRUPACT-II weight limits
• Waste container venting and filter installation
• Selection, assembly, and packaging of waste containers into acceptable configurations for the TRUPACT-II
• Loading, closing , and leak testing the TRUPACT-II
• Preparing data reports, data packages, other QA records, and shipping documentation.

The Mobile Systems Capability Plan also provides the results of cost studies for a range of options for procuring and deploying mobile systems. The study results indicated that the most

cost effective and expedient approach is for CAO to contract for the needed services from full service vendors who would use their own equipment and systems operated by their own staff.

In January 1997, the CAO issued a draft request for proposal (RFP) to prospective vendors who had expressed interest in providing the needed services. The draft RFP called for up to three vendor teams and was divided into two phases: (1) preparation of plans and procedures and demonstration of analytical capabilities to become prequalified and (2) providing fixed unit rate characterization and packaging services. The vendor comments on the draft RFP helped clarify its requirements.

The potential for large-dollar value, long-term contracts suggested that vendor teams should consider cost sharing for the prequalifying phase of the process. Accordingly, the draft RFP was converted to a Solicitation for Cooperative Agreements covering only the prequalifying phase. Contracting for the characterization and packaging work was deferred until after selection and prequalification of the vendor teams. The cooperative agreement solicitation was issued in April 1997 and bids from two vendor teams were received in mid-June. The selection process and negotiations were completed by the end of September and resulted in cooperative agreements with both vendor teams. The participating companies and areas of expertise are summarized in Table I.

The WIPP Program employs a rigorous program for authorizing the TRU-waste sites to certify waste and transportation readiness. The site certification authorization process, defined in the Generator Site Certification Guide (5), is used to verify that site operations will ensure that waste to be shipped to the WIPP will fully comply with the Waste Acceptance Criteria for the Waste Isolation Pilot Plant (6). This is accomplished by CAO approval of major site prepared plans, such as the Waste Characterization Quality Assurance Project Plan (QAPjP) and Waste Certification and Certification QA Plans, combined with on-site audits of the implementation of requirements detailed in each site's detailed Standard Operating Procedures (SOPs). Those sites that plan to use mobile services are preparing their plans and procedures around the anticipated vendor plans and procedures and will be audited by the CAO for certification up to the point where the site plans and procedures will interface with the vendor's plans and procedures. The site may be granted limited certification authority to perform those operations outside the anticipated vendor scope of work. The preparation of vendor plans and procedures and the interface integration with the site are described in the subsections below.

In addition, each site must participate in the three Performance Demonstration Programs (PDPs) for NDA, simulated headspace gas, and RCRA constituent. For each PDP each participating site receives blind samples to test or analyze using the site's procedures and equipment. The results are sent to the appropriate PDP Coordinator for evaluation against the certified composition of the samples and the site is notified of their pass/fail status. When mobile systems vendors are used, the vendors, instead of the sites, participate in the PDPs, as described below.

The mobile vendor prequalification process conducted under the cooperative agreements consists of preparation and approval of essentially the same plans and procedures required of the TRU-waste sites and consist of:

• Waste Certification Plan
• Certification QA Plan
• Quality Assurance Project Plan (QAPjP)
• Sampling Plan
• TRUPACT-II Authorized Methods for Payload Control
• Packaging QA Program Plan
• Radiological Safety and Hazards Analysis Plan
• QAPD Matrix and QA Grading Procedure
• Standard Operating Procedures

These plans and procedures cover the complete range of the services that each vendor team will provide and are specific to the methods, mobile facilities, and equipment that each of the teams will use.

The mobile system vendor teams are also required to successfully participate in each of the three PDPs. The vendor teams performed both RCRA constituent and simulated headspace gas analyses at their company facilities. Mobile vendor participation in the NDA PDP was accomplished by transporting the vendor equipment to DOE facilities at LANL, INEEL, RFETS, and LLNL, where the vendors were provided with the NDA test drums for counting and isotope identification and quantification.

The WIPP Program must provide traceability from the highest-tier waste characterization and packaging requirements documents (e.g., the WAP, WAC, CCA, and C of C) to implementation of these requirements at the lowest level (e.g., site SOPs). The mobile system vendors' documents were not necessarily prepared to be applicable to any specific waste site. Even though the mobile vendors' documentation and PDP performance have been approved by the CAO, this "documentation must be integrated into documentation for each specific site where they will provide services to provide the appropriate traceability from the site documentation to the vendor plans and procedures. Therefore, when a mobile system vendor is assigned to a specific site, the CAO will perform an audit of the necessary document integration before granting final certification authority to the site.

The CAO has worked closely with the TRU-waste sites to develop an integrated schedule for deployment of the two approved mobile systems vendors. The mobile systems deployment schedule for five near-term sites is shown in Figure 1. The schedule is generally based on the Management Plan baseline but has been adjusted as necessary to support site-specific needs. The first two deployments will be to the Nevada Test Site (NTS) and to the Mound Plant in Miamisburg, OH. Figure 1 also provides the original baseline schedule for TRU waste processing at the same five sites. A comparison of the baseline and mobile systems schedules shows the significant schedule improvement offered by mobile systems.

Not all sites will need full service support. For example, LLNL is planning to use only repackaging and TRUPACT-II loading services. The mobile systems vendors will therefore split the teams for deployment at more than one site simultaneously. In addition, the CAO anticipates that the vendor teams will be able to duplicate some services at multiple sites simultaneously.

Mound cleanup project is scheduled to be completed prior to 2005. The Mound Plant does not have facilities, equipment, or trained staff to perform waste characterization and packaging. Evaluation of the cost of developing on-site capability and the resulting delay in removing TRU waste from the site indicates that to do so is neither cost nor schedule effective compared to the use of mobile systems. Also, it is likely that this approach would delay project completion beyond the schedule committed to Miamisburg because of the need to reallocate cleanup funds to construction of a TRU waste facility. The mobile vendor selected will provide the full suite of services to the Mound Plant.

The situation at the NTS is somewhat different in that they have recently completed a waste handling building but have not fitted out the building for TRU waste processing. An evaluation of the cost to complete the facility for TRU waste processing and the schedule for doing so compared to using mobile systems indicated that using mobile systems offered significant cost and schedule benefits. In particular, using mobile systems at the NTS allows the site to meet a milestone agreed to with the State of Nevada to be prepared to begin TRU waste characterization by June 1, 1998. This schedule could not have been achieved if the site's waste processing facility were completed to provide for TRU waste characterization and packaging. However, the new waste facility will be used for staging and storing waste processed by the mobile systems and, in the future, will be used for continuing waste operations.

The CAO developed cost estimates for five sites scheduled early in the program to use mobile systems and compared these estimates with the baseline costs developed by the sites for performing waste characterization and packaging without using the CAO-approved mobile vendors. The results are summarized in Table II.

The basic cost estimating methodology developed for the Mobile Systems Capability Plan was used but assumptions were revised and other changes were made to reflect the latest site approaches to completing characterization and packaging operations. To ensure consistency, the cost for each site to provide support to the mobile vendor (e.g., utility costs, management oversight, health and safety oversight, health physics support, and site labor to stage and remove waste containers) was added to the base cost for the work performed by the mobile systems vendor. In addition, the cost to CAO for the Cooperative Agreements with the vendors is included in the table to complete the comparison. The savings at Mound and NTS are particularly striking. At Mound either a new facility or a major renovation to an existing facility would have been required to perform the required operations. Similarly, at NTS a major savings is realized from avoiding costly outfitting of their waste handing building. The savings at the other three sites are not nearly as large, but are significant on a percentage basis. Common to all the sites are the savings attributed to significantly shortening the overall schedule and reducing the mortgage chargeable to the TRU waste on site.

In the out years, mobile systems will be deployed to the SQSs to fulfill their originally intended purpose. Using the mobile systems at the larger DOE sites first will not, however, adversely affect the schedules for completing the SQS cleanup projects. In addition, the CAO anticipates that mobile systems will be reused at a number of the larger DOE sites to support continuing campaigns to characterize and package newly generated waste.

Using mobile TRU waste characterization and packaging systems developed, deployed, and operated by private sector vendors has been shown to be significantly effective for reducing costs and shortening schedules. The CAO approach of prequalifying full service vendor teams for this work and administering task order type contracts for individual site deployments offers a significant cost savings to the Program by avoiding duplication of a large portion of the planning and documentation cost at each site. In addition, using prequalified vendors enhances the consistency and comparability of waste characterization results, which supports a Program commitment to the regulators. Overall, using mobile system vendors reduces waste preparation schedules by about two years on average at five sites planning to use the service early in the program and is estimated to reduce the total costs for these five sites by more than $40 million. These benefits will continue to grow in the out years.

1. U.S. DEPARTMENT OF ENERGY, "Mobile Waste Characterization Systems Analysis Report," NTP-WID-96-2163, Carlsbad Area Office (1996).
2. U. S. DEPARTMENT OF ENERGY, "The National Transuranic Waste Management Plan," DOE/NTP-97-1204, Revision 1, Carlsbad Area Office (December 1997).
3. U. S. DEPARTMENT OF ENERGY, "Mobile Systems Capabilities Plan," DOE/NTP-96-1202, Revision 0, Carlsbad Area Office (September 1996).
4. U. S. DEPARTMENT OF ENERGY, "Transuranic (TRU) Waste Characterization Quality Assurance Program Plan (QAPP)," CAO-94-1010, Revision 1, Carlsbad Area Office (in press).
5. U. S. DEPARTMENT OF ENERGY, "Generator Site Certification Guide," DOE/CAO-95-2119, Revision 1, Carlsbad Area Office (August 1997).
6. U. S. DEPARTMENT OF ENERGY, "Waste Acceptance Criteria for the Waste Isolation Pilot Plant (WAC)," DOE/WIPP-069, Revision 5, Carlsbad Area Office (April 1996).

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