WASTE MINIMIZATION VIA RADIOLOGICAL
HAZARD REDUCTION

Keith A. Stone
British Nuclear Fuels Limited
Savannah River Corporation
P. O. Box 616
Aiken, South Carolina 29802

Karen L. Hooker, Ph.D.
U. S. Department of Energy
Savannah River Operations Office
P. O. Box A
Aiken, South Carolina 29802

Tim Coffield
Westinghouse Savannah River Co.
P.O. Box 616
Aiken, South Carolina 29802

ABSTRACT

The Savannah River Site (SRS), a 803 km2 U. S. Department of Energy (DOE) facility in south-western South Carolina, incorporates pollution prevention as a fundamental component of its Environmental Management System. A comprehensive pollution prevention program was implemented as part of an overall business strategy to reduce waste generation and pollution releases, minimize environmental impacts, and to reduce future waste management and pollution control costs. In fiscal years 1995 through 1997, the Site focused on implementing specific waste reduction initiatives identified while benchmarking industry best practices. These efforts resulted in greater than $25 million in documented cost avoidance. While these results have been dramatic to date, the Site is further challenged to maximize resource utilization and deploy new technologies and practices to achieve further waste reductions.

The Site has elected to target a site-wide reduction of contaminated work spaces in fiscal year 1998 as the primary source reduction initiative. Over 120,900 m2 of radiologically contaminated work areas (~600 separate inside areas) exist at SRS. Reduction of these areas reduces future waste generation, minimizes worker exposure, and reduces surveillance and maintenance costs. This is a major focus of the Site's As Low As Reasonably Achievable (ALARA) program by reducing sources of worker exposure. The basis for this approach was demonstrated during 1997 as part of a successful Enhanced Work Planning pilot conducted at several specific contamination areas at SRS. An economic-based prioritization process was utilized to develop a model for prioritizing areas to reclaim. In the H-Canyon Separation facility, over 3,900 m2 of potentially contaminated area was rolled back to a Radiation Buffer Area. The facility estimated nearly 420 m3 of low level radioactive waste will be avoided each year, and overall cost savings and productivity gains will reach approximately $1 million annually as a result of this effort.

During fiscal year 1998, SRS will intensify the reclamation of contaminated work areas through implementation of the Site Rollback Plan. The economic based model was utilized to prioritize areas for reclamation based on achieving a return on investment of over 2:1. Generators have been challenged to exceed planned rollbacks through a DOE imposed Performance Based Incentive with the Site Operator. In the first quarter, over 1,580 m2 of contaminated areas have been reclaimed with approximately 7,720 m2 remaining to be done before the end of the fiscal year.

INTRODUCTION

The Savannah River Site (SRS) is a 803-km2 U. S. Department of Energy (DOE) site managed by the Westinghouse Savannah River Company. The SRS is located in the Southern Coastal Plain and Sandhills Land Resource Area of west-central South Carolina (Figure 1). Originally constructed in the 1950s for the production of nuclear-defense related materials, all five of the original production reactors are permanently shut down. Current missions include the safe management of radioactive and hazardous wastes and spent nuclear fuel generated from past operations, as well as ongoing environmental restoration and waste management activities.

Fig. 1. The Location of the Savannah River Site

Reducing waste generation is one of the seven guiding principles to accomplish the DOE Office of Environmental Management (EM) vision. At the SRS, our Environmental Management System, which has been recognized with ISO 14001 certification, embraces pollution prevention as a fundamental component of our systems approach to integrating business goals and environmental stewardship. Vigilance of SRS resources, products, waste, and contamination is fundamental to overall risk reduction, and worker and environmental protection.

BACKGROUND

The Waste Management program at the SRS focuses on the safe management of newly generated and legacy transuranic (TRU), mixed low-level radioactive, hazardous and low-level wastes (LLW) from over 50 separate generators. Waste generation rates have declined through time coincident with the shutdown of the nuclear production facilities and implementation of a comprehensive pollution prevention program. Recent increases in forecasted waste reflect the acceleration of in-field remediation work and decontamination and decommissioning activities. A substantial portion of the annual Site budget is dedicated to the surveillance and maintenance of active, as well as inactive facilities, which currently number in the hundreds.

Over the past three years, the SRS Pollution Prevention program has made great strides in establishing pollution prevention as a business strategy for the Site. As part of the Site's Environmental Management strategy and touting senior management support, SRS has a proven track record of success in implementing waste reduction initiatives. In fiscal years 1996 and 1997, source reduction initiatives and improvements in storage utilization extended the life of existing disposal facilities by an order of magnitude. Active generator involvement and high return on investment source reduction initiatives contributed to a waste generation avoidance of over 6,720 m3 of low level waste in fiscal years 1996 through 1997 with cost avoidance estimated to exceed $25 million. While these results have been dramatic to date, the Site is further challenged to meet its future efficiency and productivity challenges. The major focus for fiscal year 1998 is the reclamation of radiologically contaminated work spaces which enhances both the pollution prevention and radiological control programs to meet and exceed regulatory and contractual requirements while maintaining radiation exposure as low as reasonably achievable. To be successful in this objective, the Site will be required to maximize resource utilization and deploy new technologies and practices.

To emphasize the importance of this initiative, DOE developed a Performance Based Incentive for the Contractor to reclaim more radiologically contaminated work spaces than provided for in their annual operating budget. The Contractor can earn an incentive fee for accomplishing 200% more rollbacks than planned for in the fiscal year 1998 work scope, with the maximum fee available paid when at least 9,300 m2 of contaminated work areas that have been identified in the Site Rollback Plan have been reclaimed.

Currently, there are over 120,900 m2 of contaminated work areas at the SRS, comprising hundreds of separate inside and outside areas ranging in size from a few square feet to several acres. Reclaiming these areas to the maximum extent feasible will have several benefits. These include: 1) reducing the source of current and future radioactive, hazardous, and mixed waste requiring treatment, storage or disposal; 2) decreasing the donning and doffing time for protective equipment (>100,000 hours annually); and 3) decreasing radiological exposures of SRS workers consistent with As Low As Reasonably Achievable (ALARA) principles. In addition, a large portion of the Site's annual operating budget is dedicated to surveillance and maintenance of hundreds of facilities. Reducing entry and survey requirements for as many areas as practicable is a cost efficient approach to reducing surveillance requirements for these areas, as well as life cycle costs.

ROLLBACK PROCESS

The process of "roll back" converts radiologically impacted areas to areas with lower levels of contamination or clean areas. Posted areas are surveyed to determine the feasibility of remediating and reclassifying them to lower levels of contamination. When feasible, they are decontaminated to new lower limits. High contamination areas are downgraded to contamination areas, which are downgraded to radiological buffer areas (RBAs). The purpose of rollbacks is to significantly reduce the life cycle costs of working in and maintaining an area classified as a contamination area. Substantial savings are obtained through generating less waste for disposal and decreased laundering of personal protective equipment. Additional benefits are obtained through increased productivity and reducing the risk of personal exposure to radiological contamination.

ECONOMIC-BASED PRIORITIZATION TOOL

In fiscal year 1996, an Enhanced Work Planning (EWP) pilot was conducted on contamination area rollbacks. As part of this effort, an economic-based prioritization tool was developed using data from a small subset of Site contamination areas, which was ranked in order of return on investment. The computer tool that was developed identified the combination of rollback projects that will provide the greatest benefit given a specified funding level. This tool served to bridge the gap from idea to implementation by organizing and optimizing the benefits and costs of conducting the contaminated area rollbacks. The model was validated on a few select areas that had the potential for large return on investments. In the H-Canyon Separation Facility, over 3,900 m2 of posted contamination area was rolled back to an RBA. Additionally, 300 items were salvaged and released for reuse or sale. SRS published an "Enhanced Work Planning Rollback Handbook" after completing these activities within the H-Canyon facility.

To facilitate the accomplishment of reclaiming (or rolling back) 9,300 m2 of contamination areas in fiscal year 1998, a Sitewide Rollback Plan was issued at the start of the fiscal year. Using the economic-based prioritization tool, facility-specific input for 485 individual areas was analyzed and prioritized to target those areas that were financially feasible to roll back, had a high return on investment, and to identify any difficult configurations. Life-cycle costs associated with working and maintenance of these areas will be greatly reduced by targeting high return on investment areas for reclamation first. Facility-specific savings were also calculated and inputted into the model. These savings result from environmental corrections, improved operator safety and health, emergency response efficiencies, decreased monitoring and surveillance, capital outlay avoidance, area deactivation projects and operational efficiencies.

The optimization component provides the "brains" of the decision support tool. It consists of a linear optimization program, which interfaces with the cost and benefit data that were calculated using a standard spreadsheet package. The optimization model maximizes the savings of the recovery portfolio with the boundary condition that the sum of the costs are less than or equal to the maximum allowable funding availability and that a selected project must be completed in the funding cycle period. This second constraint was added to minimize project rollover and to ensure that a portfolio of "partial projects" was not selected. The optimization algorithm then generates the project portfolio that will provide the greatest return on investment. The decision maker then has a very powerful tool, that can select which projects to focus resources on that will generate the maximum benefit for the organization.

A chart of the model output optimization provides a quick visualization of the "best case"solution which maximizes return on investment. Overlays of other possible solutions can be added such as minimizing the impact on operational facilities and effective resource allocation (Figure 2).

Fig. 2. Life Cycle Cumulative Cost to Remediate vs. Life Cycle Cumulative Savings

IMPLEMENTATION STRATEGIES

Communications, effective program management, and resource leveraging have been essential in establishing a coordinated and integrated site-wide approach to meeting the aggressive goals defined in the Site Rollback Plan. The Plan encompasses nine major SRS operating divisions and 20 industrial facilities with diverse missions, priorities, and radiological challenges. Further, the impacts of this work, and the necessary integration, cut across multi-functional disciplines such as radcon; engineering, maintenance, operations, procurement, and miscellaneous additional support service functions. Some of the organizational bodies that play a key role in the overall coordination and execution of the Plan are the Solid Waste Management Council, the Waste Minimization Subcommittee, the DOE Waste Council, the Site ALARA Committee, and the Facility Manager Council. Frequent communication and issue resolution through these information exchange forums, which include representation from all SRS operating and support organizations and functional areas, has been integral to maintaining a cohesive focus and disciplined approach.

Specialized decontamination teams were formed to support facility efforts. The SRS Decontamination Facility has deployed a full-time team to provide rollback services across the SRS. The team consists of a supervisor, two decontamination operators, two laborers, and a subcontracted radiological control technician. Two of the largest operating divisions have fielded their own dedicated rollback teams utilizing existing facility support augmented by radiological control technicians subcontractors and construction labor forces. Another key strategy is identification and deployment of technologies that would accelerate the decontamination efforts. The existing Decontamination Facility augmented generator rollback efforts by supplying specially-designed equipment utilizing best industry technologies and personnel trained and experienced in facility and materials decontamination. Decontamination equipment included: carbon dioxide blasting, steam vacuuming, plastic blasting, surface profiling, grit blasting, and general and specialty chemical decontamination techniques. The facility also maintains and deploys a surface coating service, which sprays a polymer (InstaCoteÒ ) lining guaranteed against chipping, peeling, or deterioration for ten years. This coating service has accelerated site rollback initiatives and will simplify future cleanup activities. All Site organizations teamed together to supply labor, radiological control technicians, and operators to deploy these technologies. An additional resource that has paid dividends is the service of a commercial industry expert in the areas of radiological waste management and facility decontamination. This subcontracted expertise augments a SRS rollback team that has experience primarily at the SRS.

To fund these activities, Site operating budgets will support recovery efforts for only 1/3 of the contaminated workspaces defined in the Rollback Plan. To help bridge this resource gap, several alternative funding sources have been tapped. The first and perhaps largest opportunity is the SRS Generator Set-aside Fee (GSAF). The GSAF was introduced at the SRS through a DOE pilot program in 1996 and is designed to provide a funding source for waste minimization projects and at the same time provide some incentive to generators to reduce waste. The GSAF is a tax applied to all SRS waste generation based on the waste volume. The tax proceeds are pooled and applied to waste minimization projects offering the best value to the Site. Through the first quarter of fiscal year 1998, over $250K of GSAF moneys has been allocated to support rollbacks; over the course of the fiscal year the GSAF could provide up to $900K of funding. DOE also periodically provides limited supplemental funding for waste minimization projects that offer good payback. The SRS received $130K of this funding for equipment to support the achievement of Rollback Plan objectives.

RESULTS TO DATE

Utilizing these tools, strategies, and resources, 1,582 m2 of contaminated areas (comprised of fourteen separate areas) have been rolled back, exceeding the first quarter fiscal year 1998 goal of 1,453 m2. Following are some examples of the challenges and benefits associated with these early results.

SUMMARY

The SRS has identified and is capitalizing on a significant improvement opportunity that will yield multiple benefits including, but not limited to: reduction of future waste generation; minimization of worker radiological hazard exposure, and reduced long-term surveillance and maintenance costs. The comprehensive approach that the SRS is taking towards contaminated area rollbacks is innovative and unique to the DOE complex. The incentives, tools, strategies, organizational arrangements, and technical capabilities that have been developed and deployed will ensure success and the long-term sustainability of the rollback effort. Early results from actual recovery of contaminated areas are demonstrating savings as predicted and provide additional optimism for a successful campaign.

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