Susan B. Miller and Douglas G. Hamrick
Safe Sites of Colorado, L.L.C.

The end of the Cold War moved the Department of Energy’s focus from nuclear weapons production to the stabilization and cleanup of previously operating facilities. Many production facilities that once operated with a high priority, are now considered surplus or excess. Rocky Flats Environmental Technology Site (RFETS), which was significantly impacted by this transition of DOE missions, is engaged in the process of planning the closure of a major nuclear facility. Building 771 was used for processing plutonium and other actinides with a wide variety of processes between 1951 and 1989. This included many modifications, a substantial variation in operations, and several upsets resulting in contamination of the facility. The 1994 Plutonium Working Group Report on Environmental Safety and Health Vulnerabilities associated with the Department’s Plutonium Storage determined Building 771 to be the "most dangerous building in America". Since that time, a significant quantity of Special Nuclear Material (SNM) has been removed, lowering the risks involved. Now, RFETS is undertaking the ambitious task of planning a monumental closure project, which will safely and cost-effectively deactivate, decontaminate and decommission the facility. A phased approach towards closure is being implemented, along with a parallel planning process. These activities are expected to accelerate closure of this complex significantly. This acceleration of closure eliminates the costs associated with the surveillance and maintenance of this facility allowing these costs to be reallocated towards other risk-reduction activities at RFETS. Furthermore, the closure of Building 771 will result in a significant reduction of hazards at RFETS.

The end of the Cold War moved the Department of Energy’s focus from nuclear weapons production to the stabilization and cleanup of previously operating facilities. Many production facilities that once operated with a high priority, are now considered surplus or excess. Rocky Flats Environmental Technology Site (RFETS), which was significantly impacted by this transition of DOE missions, has embarked on the process of planning the closure of a major nuclear facility. This document describes the closure process employed on the Building 771 complex.

Building 771 was used for processing plutonium and other actinides with a wide variety of processes between 1951 and 1989. This included many modifications, a substantial variation in operations, and several upsets resulting in contamination of the facility. The 1994 Plutonium Working Group Report on Environmental Safety and Health Vulnerabilities associated with the Department’s Plutonium Storage (Reference 1) determined Building 771 to be the "most dangerous building in America". Since that time, a significant quantity of Special Nuclear Material (SNM) has been removed, lowering the risks involved. Now, RFETS is undertaking the ambitious task of planning a monumental closure project, which will safely and cost-effectively deactivate, decontaminate and decommission the facility.

The 771 Closure Project scope includes the deactivation, decontamination, decommissioning, and demolition of Building 771/774, ancillary support structures, trailers, plant systems and utilities, underground tank systems, and waste sites associated with the 771 complex. A number of systems are interconnected between Building 771 and other facilities on site. Consideration for the interfaces has been given for each portion, and actions have been taken to prevent unexpected disruption of services.

A number of hazards are already known to exist in the Building 771 complex. The primary hazard is radiological contamination. Building 771 and 774 were used for the recovery of plutonium since 1953. During that period, a number of leaks, spills, and a fire in 1957 have contaminated virtually the entire facility at one time or another. It has always been standard operating practice to decontaminate an area after spills, leaks or fire, although the precise level of decontamination is often not known. Areas hard to decontaminate were often painted over.

In addition to the radiological concerns, a number of chemicals have been used in the 771 complex, both for processing and in the analytical labs. Most of these chemicals are well documented and are in relatively small quantities. One notable example is hydrofluoric acid (HF). The system that used HF is operationally empty, but has not been flushed. Additionally, beryllium is known to be left from past operations, although in a limited number of gloveboxes. Machine, hydraulic, and lubricating oils and greases exist in various machines, gearboxes, and equipment. PCB is also likely to be encountered in equipment and electrical devices, as well as residual from a known spill on the second floor. Due to the age of the facilities, considerable amounts of asbestos are present in the insulation and building materials. Finally, lead is present in the glovebox shielding, as well as some building materials. Aside from the radiological and chemical hazards, the 771 complex has the normal industrial hazards expected of any chemical processing/lab area.

In developing the 771 Closure Plan, a number of strategies were used in the development of scope, work logic, and cost and schedule estimating. These strategies embody the seven guiding principles contained in the Department of Energy’s Assistant Secretary Alm’s December 1996 Guidance on the Ten Year Plan and the Rocky Flats Cleanup Agreement. The major strategies employed in the Rocky Flats’ 771 Closure Project are the same as those employed by the Site’s Ten Year Plan:

• Maintain the Site’s safety envelope ensuring the continued safety of Site workers, the public, and the environment during cleanup activities.
• Eliminate highest priority risks first. High priority risk activities primarily involve stabilization, consolidation, interim storage, and offsite shipment of SNM.
• Reduce the Site’s high nuclear facility baseline costs by accelerating closure of these facilities through expedited stabilization and removal of SNM.
• Demolish Site facilities and infrastructure to eliminate future funding and safety liabilities, ongoing maintenance and surveillance, and residual radioactive material management.
• Clean up environmentally contaminated areas to the extent that sources of contamination which pose a significant risk are mitigated and controlled.
• Reduce infrastructure and management costs at a steady pace throughout the life of the cleanup project.
• Comply with all applicable laws, regulations, and agreements.

Unlike previous efforts towards closure of nuclear facilities, the closure of the Building 771 complex utilizes a phased approach. This approach moves away from the typical "deactivation, decontamination, and decommissioning" in series and moves towards a well-integrated parallel approach where all three of these activities may occur at any time within the facility. This approach is shown below in Figure 1.

This phased approach enables Building 771 to begin closure in a number of areas, allowing for the most efficient utilization of resources. It also accelerates closure schedules for the complex. This will eliminate the costs associated with the surveillance and maintenance of this facility allowing these costs to be reallocated towards other risk-reduction activities at RFETS. Furthermore, the closure of Building 771 will result in a significant reduction of hazards at RFETS.

The planning process which has been employed to facilitate this strategy allows for activities to occur in parallel, with an end result of a finalized Project Management Plan. This planning approach, shown below in Figure 2, can be narrowed down to five main activities: Project Management, Facility Characterization, Trade Studies, Development of Resource-Loaded Schedule, and End Point Development, all of which occur in parallel, and finish in the culmination of the Project Management Plan. Each of these activities are discussed below.

Project management is a significant factor in dealing with closure activities. This includes managing work activities regulatory issues, as well as stakeholder issues. The 771 complex receives oversight from two separate outside organizations: the Defense Nuclear Facility Safety Board, for oversight of all nuclear activities on site; and the Colorado Department of Public Health & Environment, for oversight of all environmental activities on site. This leaves the facility with dual oversight for portions of closure, and the challenge of ensuring that the needs of all stakeholders are heard and addressed.

The 771 Project Management Team has made a commitment to open communication throughout closure. As with all projects of this magnitude, communications must be living and dynamic, responding to accomplishments and emerging issues or activities. Specific actions have been taken to disseminate information regarding project objectives, strategies, problems, issues, and status, and to develop strategies for soliciting input/involvement throughout the closure project.

The key communications objectives are:

• Initiate dialogue to achieve understanding of the project, obtain input from and acceptance by all interested parties (employees, customers, regulators, stakeholders, media, and the public) in decisions regarding closure.
• Publicize successful activities and share project problems/concerns with all interested parties.

Efforts to assemble and distribute informational documents that allow non-technical people to understand the history, operations and condition of large, complex facilities have begun. The provision of such documents can save enormous time for plant personnel that might otherwise have to be spent answering repetitive questions. It also can prevent a domino-effect of misunderstandings about the closure, based on basic misunderstandings of plant functions, layout, history, chemical and radiological inventory, and many other topics. Plant tours also are important to helping stakeholders understand the scope of the physical plant itself, the closure project, and the work being performed. Finally, numerous meetings are held on a regular basis with employees, stakeholders, and regulators to ensure that their input is received early on in the planning process.

Another major part of project management is to develop work practices and an organization structure to execute the project activities in a safe and efficient manner. To accomplish this, Building 771 has completed a formal reengineering effort. Prior to this effort, the organizational structure was a traditional operations/production arrangement. The reengineered organization structure is based on a multi-disciplined, team approach. This structure is displayed in Figure 3. The revised work practices and new organization structure will compliment the planning processes described later in this paper. When the planning process is complete each work team will be assigned a specific scope of work (set of "end points"), a resource loaded schedule and a budget allotment to perform. This clear assignment of roles and responsibilities will allow the required closure work to proceed in a safe and efficient manner.

Characterization of a facility is the process of identifying what physical, chemical, biological and radiological hazards are associated with a facility. The hazard may be contained (e.g., acid in a tank) or loose (e.g., radioactive material on a floor). The hazard may be potential (e.g., broken ladder) or immediate (e.g., a leaking pipe which contains radioactive material). The closure of 771 requires that the physical, chemical and radiological condition of the facility be assessed. Characterization is achieved through a combination of facility walkdowns, review of historical records, information from similar buildings, interviews of personnel familiar with building operations, direct measurement, non destructive assay, and sample collection for laboratory analysis. The characterization data will be utilized for assessing potential hazards, waste management, basis for the development of the technical approach to work activities, and support for the proper disposal of property/waste.

There are five phases of facility characterization which are being completed in the 771 complex as defined below. The first two of these, Scoping and Reconnaissance, are completed as part of the planning process. The remainder are performed during closure activities.

• Scoping Characterization
  The Scoping Characterization phase is the process of gathering information about the facility’s hazards from existing sources. The main sources of this information are historical records, routine survey records, facility walk downs, and interviews with facility personnel and former facility personnel. The compilation of this information is used as the basis for preliminary evaluations of proposed closure activities. The Scoping Characterization phase feed information into the Reconnaissance Characterization phase.
• Reconnaissance Characterization
  The Reconnaissance Characterization phase establishes a definitive baseline of information about the facility’s hazards. During this phase of characterization the Scoping Characterization is used in conjunction with a review of the proposed closure activities to determine if the proposed activities are feasible and to identify the need for additional sampling and/or surveys. If additional characterization information is needed to adequately define the quantity and distribution of contaminants, the additional samples would be completed during the Reconnaissance Characterization phase.
• In-Process Characterization
  In addition to the Reconnaissance Characterization, additional radiological, chemical, and safety surveys will be completed, as necessary, to prepare appropriate work authorization documents. These surveys are typically completed shortly before the work is initiated to ensure conditions have not changed since the work planning stage. As the work continues and hazards are removed, further characterization is completed to verify the effectiveness of the decommissioning work efforts. This continued sampling and surveys are called In-Process Characterization.
• Final Decommissioning Survey
  The Final Decommissioning Survey is conducted to demonstrate that the radiological and industrial contaminants within the facility have been reduced to levels that comply with the established release criteria. The Final Decommissioning Survey report will be included as part of the project’s administrative record and turned over to the Contractor’s Environmental Remediation Department for final site remediation.
• Confirmatory/Verification Survey
  This survey is conducted to verify that the facility and/or material removed meets established release criteria. The confirmatory/verification survey is performed by a third party, which provides an independent review of the Final Decommissioning Survey methodology and survey data. Although the scope may vary, typically a confirmatory survey of one to 10 percent of the area is performed. Comparisons are made between confirmatory and final surveys. Anomalies are identified and addressed.

Characterization information gathered has been entered into a facility database to enable easy access and retrieval of this effort. Parallel to the characterization activities, the facility was broken down into sets of equipment which will be removed. These sets encompassed a variety of items such as process equipment, utility equipment, or whole portions of the facility. Sets were developed in a manner to create logical work groups. This effort resulted in approximately 80 sets being identified in the 771 complex. These sets were then prioritized using the criteria in Table I.

Each of the above criteria for prioritizing the sets was given a weighting factor. Then each set was then evaluated against these criteria and assigned a factor for how well it met the individual criteria. The criteria factor was multiplied by the set factor and the summed to give an overall set criteria value. Using the final criteria value, the sets were prioritized. The criteria, which combined with solid engineering judgment, enabled the project team to make informed decisions concerning the order in which equipment is removed from the facility.

It is important to understand, however, that this prioritization is not set in stone, but rather is used as a guide for activity order. The order in which sets are removed may be impacted based on several issues. Activities may be either delayed or brought forward based on budget, available resources, and approval status. For example, priorities 1, 2, and 3 may be ready to work. Priority 4, 5 and 6 may be awaiting regulatory approvals; however, priorities 7 and 8 are approved, and can be safely performed ahead of priorities 4, 5 and 6. Priority 9 may be on hold due to a lack of resources, while priority 10 may have exactly the resources required. In no case would a lower priority activity be performed when it is not safe or economical.

As the sets were being selected, a "Trade Study" was conducted to create a spreadsheet tool which would result in quantitative assessments of options for equipment disposal. The primary function of this tool was to determine the cost effectiveness of equipment decontamination. A second spreadsheet tool has recently been developed to create a "waste flow sheet" for each set of equipment. This tool, developed through a joint effort of Rocky Flats contractors, the Department of Energy, and external (to RFETS) experts, was utilized to characterize equipment sets and perform a cost-benefit analysis to determine the safest and most economical disposition of the set.

Additional Trade Studies are planned and being conducted to answer further questions towards closure on site. For example, Rocky Flats is evaluating the needs and availability of characterization capabilities.

Concurrent to all of the above activities, "end points" were developed for all equipment sets within the complex. The "end points" method utilized at RFETS built upon the successful process developed and tested at PUREX (Plutonium-Uranium Extraction), a Hanford facility. These methods of defining end points for facility stabilization and closure have proven to be extremely effective in planning work and interacting with the regulators and stakeholders.

Every end point is driven by an objective which formed the basic criteria for the end points. At RFETS, the overall objectives are:

• Protecting the public and the environment.
• Complying with regulations and requirements
• Protecting the workers
• Optimizing the costs

Since carrying out of the end point specifications results in work plans to achieve those conditions, the method supports the development of work plans by providing a task focus. The end point methods utilized are not intended to be prescriptive in nature, but rather are to be adapted to suit the specific needs of the facility under transition. More details on end point development can be found in DOE/EM-0318 (Reference 2).

All work performed at RFETS is scheduled and integrated by inclusion in a controlled master schedule, referred to as the Closure Project Baseline Schedule. The schedule includes all work scope required to initiate, plan, execute, and closeout the project using activities tied to the approved Site Work Breakdown Structure (WBS) and is tiered in accordance with the WBS. The total life cycle of a project is scheduled; however, near-term work is scheduled in greater detail than outyear work.

For the 771 Closure project, the schedule was developed by mapping the project end points into a WBS which matched to activities planned. A schedule was then completed for a typical equipment set. This "baseline" schedule is now being expanded for each of the sets created, tailoring the schedule to fit the particulars of each circumstance.

Individual activity planning package budgets are also prepared based on a project specific scope, schedule, cost estimate, and WBS. The budgets are based on estimates of labor, equipment, materials, subcontracts, and all other direct and indirect costs to the WBS level and include the level of detail required for effective project planning and control. Developed at the activity package level, these budgets use control points/milestones to define the accomplishments and deliverables of a work package.

In closing the Rocky Flats site, a Federal Facility Agreement and Consent Order named the Rocky Flats Cleanup Agreement (Reference 3) has been created that establishes the regulatory guidelines and framework for achieving cleanup of Rocky Flats in an accelerated and cost effective manner. Through this document, Rocky Flats nuclear facilities are required to document their plans for closure through a Decommissioning Operations Plan (DOP). This document presents an activity-based program to decontaminate the locations identified in that building’s preliminary characterization study as contaminated or presenting a physical hazard.

For the Building 771 Closure Project, this DOP has been incorporated into an overall draft Project Management Plan (PMP). The PMP covers not only those topics required by a DOP, but also the overall project strategy, the Health & Safety Plan, the Waste Management Plan, the Reconnaissance Level Characterization Report, the End-Point Document, and project specifics for budget and schedules. This allows both the Project Team, as well as the oversight agencies to "see the big picture" for the overall project, rather than reviewing it in a piecemeal fashion. This also allows a separation of those portions which are enforceable, from those portions which are non-enforceable by the regulatory agencies. This configuration is shown in Figure 4. This draft PMP is now being reviewed by the Department of Energy, regulators and stakeholders. Comments from this review will be incorporated into the final, approved PMP/DOP.

In making this change to a phased closure project, safety is our number one priority. Worker involvement is a key consideration and significant Lessons Learned from PUREX. Enhanced Work Planning (EWP) is the natural implementing vehicle to involve workers, and to incorporate the five key elements of the Defense Nuclear Facility Safety Board recommendation 95-2. These key elements -- work scope reviewed and prioritized; work scope analyzed for hazards and categorized based on risk; controls established based on hazards, risk, and experience of workers; work performed safely, efficiently, with appropriate degree of supervision; and continuous improvement and lessons learned -- encompass the essence of an effective, efficient, and safety conscious work process.

Enhanced Work Planning considers the entire work process and continually asks the questions necessary to implement a safer, more efficient work control process. In the traditional approach to the work control process, technical specialists, management, and workers are given work packages for review during various phases of the work planning process. When changes are made by one or more of the reviewers, the package must be reviewed again by all parties. This sequential review process is inefficient and tends to create conflict between planners, reviewers, and workers. Enhanced Work Planning is designed to improve the traditional work control process, primarily through extensive communication and feedback from the appropriate mix of personnel responsible for the work.

The closure of the Building 771 complex utilizes a phased approach, which moves away from the typical "deactivation, decontamination, and decommissioning" in series and moves towards a well-integrated parallel approach where all three of these activities may occur at any time within the facility. By using this new phased approach towards closure, as well as conducting the planning segments in parallel, closure activities are dramatically accelerated. Closure of the 771 complex will eliminate the costs associated with the surveillance and maintenance of this facility allowing these costs to be reallocated towards other risk-reduction activities at RFETS. Furthermore, the closure of this complex will result in a significant reduction of hazards at Rocky Flats.

1. DOE/EH-0415 Plutonium Working Group Report on Environmental, Safety and Health Vulnerabilities associated with the Department’s Plutonium Storage, U.S. Department of Energy, November 1994
2. DOE/EM-0318 Facility Deactivation Guide: Methods and Practices Handbook, U.S. Department of Energy, Rev. 0, December 1996
3. Rocky Flats Cleanup Agreement, July 19, 1996

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