G.J. Bracken
Rocky Mountain Remediation Services

B.P. Colby
GTS Duratek

R.G. Lahoud
Kaiser-Hill

G.L. Potter
Savant Enterprises

Rocky Flats Environmental Technology Site has a significant inventory of backlog (i.e. legacy) waste containers that were characterized and packaged prior to the onset of the more stringent and disciplined operations currently in place. Until recently, most of these containers were stored in former production buildings with their attendant high costs due to health, safety and security controls related to managing co-located special nuclear material. A major initiative was undertaken by Kaiser-Hill and Rocky Mountain Remediation Services (RMRS) to relocate the waste containers out of the former production buildings into single purpose waste storage facilities to facilitate mission-critical site closure activities (e.g., special nuclear material consolidation, residue stabilization, tank draining, building deactivation and demolition). These wastes were characterized and packaged to the prevailing procedures at the time (i.e. pre-1990), and did not satisfy today’s more rigorous authorization basis directives, quality assurance/quality control requirements nor offsite disposal acceptance criteria. Historically, the method for managing these wastes was to issue nonconformance reports (NCRs), grandfather them into the existing authorization basis of the building in which they were stored and leave them in place. The presumption was that when the containers left the building, they would be repackaged for offsite disposal. As a result, procedures, inspection checklists and quality control criteria for moving waste containers out of buildings had built-in requirements indexed to ultimate disposal. In addition, newly constructed or recently upgraded waste storage buildings rely upon recently prepared authorization basis rationale that take credit for the controls and procedural requirements used today. These conditions, in effect, rendered legacy waste ineligible for being moved out of former production buildings and into new waste storage buildings without reconciling the differences between wastes that were characterized and packaged to old, outdated standards with the site’s current standards governing intra-site container transfers and building waste receipt criteria. This paper discusses the challenges faced by the RMRS waste relocation project team and the innovative approaches used to successfully move wastes from the former production buildings to the waste storage facilities without compromising safety and security requirements. In addition to relocating waste to allow the site’s accelerated cleanup activities to proceed, a number of streamlining initiatives were instituted which resulted in substantial cost savings, improved regulatory compliance and better utilization of labor resources.

Rocky Mountain Remediation Services, LLC (RMRS) completed an ambitious initiative to move wastes out of many former production and support buildings in the Protected Area (PA) to more suitable waste storage locations outside the PA or to designated waste storage facilities within the PA (e.g., Building 964, 750 Pad, Building 991). This initiative, referred to as the PA Evacuation Project, was designed to improve overall waste storage efficiency by consolidating wastes into large, dedicated waste storage facilities, mainly outside the PA, where the wastes could be managed more economically and to relieve the constraints created by storage of large amounts of waste in former production buildings. Over 86 percent of the pre-September 30, 1996 radioactive waste inventory stored in plutonium facilities inside the PA was relocated. This involved relocating over 1,052 cubic meters of waste. Progress over time in removing waste volume is shown in Figure 1.

The PA Evacuation Project was conducted in accordance with RMRS which provides a strategy to coordinate waste handling activities with other mission critical activities occurring at the Rocky Flats Environmental Technology Site (Site).

The goal of the PA Evacuation Project was to remove a minimum of 85 percent of the pre-September 30, 1996 containerized waste inventory from the plutonium facilities inside the PA. Waste was relocated to lower cost storage areas both within and outside the PA. The Project was established by Kaiser-Hill Company, LLC, as an incentivized performance, with a completion date of September 30, 1997. Based upon the criteria of the performance measure rating plan, a detailed list of 4,538 containers, equal to 1,220 cubic meters, was developed early in the Project. This list of containers was used for the performance measure and became the baseline for the Project. Successful completion of the performance measure was determined by a decrease in the volume of containerized waste inventory within the PA buildings as tracked in the Waste and Environmental Management System (WEMS). This performance required 1,037 cubic meters of baseline waste be removed from PA buildings by September 30, 1997. WEMS data was used to document container transfers and track project progress.

Evacuation and consolidation of waste inventories allowed waste types to be grouped together and "targeted" toward appropriate storage areas. These areas were selected based on regulatory permits and capacity, safety authorization bases, and operational constraints. The plan identified the evacuating and receiving facilities and the projected container movements.

Multiple benefits in productivity, efficiency, reduced worker dose, and facility operations are expected to be realized with completion of the PA Evacuation Project. Consolidation of the waste inventories into lower cost, exclusive-use storage areas is expected to result in the following: (1) reduced competition with residues for storage spaces associated with safety upgrades to the Building 771 Annex; (2) reduction in radiation dose to workers by relieving crowded conditions in former production facilities; (3) removal of waste containers from areas scheduled for deactivation and decommissioning activities so as to not impede progress of these other initiatives; (4) consolidation of non-conforming waste containers to facilitate disposal in fiscal year 1998 and beyond; and (5) reduction in inspection and other waste costs through consolidation of waste storage operations. The Project also confirmed and updated WEMS for a large population of waste containers. Numerous process improvements affecting storage facilities and waste transfer procedures were also realized.

A summary of waste inventory changes resulting from the PA Evacuation Project is presented in Figure 1. The Project is credited with removing 1052 cubic meters of waste from the PA. The figure shows weekly container movement in cubic meters based on the original plan, target containers moved and cumulative containers moved. The original plan was revised in mid-January.

During the course of the PA Evacuation Project, a number of changes to the overall waste container movement process were implemented that benefited waste operations at the site. These changes frequently resulted from overcoming obstacles to the efficient movement of containers from former production buildings to dedicated waste storage facilities. The key process improvements included: identification of container preparation and documentation requirements prior to movement, container counting, tracking, and transport. Several streamlining initiatives were completed to assist waste receiving buildings accept and manage waste associated with the PA Evacuation Project, such as:

• Additional Item Description Codes (IDCs are categories of waste materials) to B906 Final Safety and Analysis Report
• Development of Authorization Basis checklists to integrate nuclear safety, criticality safety and RCRA permit requirements.
• Increasing B440 Nuclear Material Safety Limits for metal boxes.
• FSAR changes in B664 to replace 10 kilogram building limit for plutonium with a container limit.
• Policy and procedure changes to allow storage of containers with incidental liquids in B664.

Not all containerized waste was removed from the affected PA buildings because many of the containers require special handling and/or resolution of nuclear safety, criticality safety, and safeguards issues before they can be transferred to other buildings. Where possible, these remaining wastes have been grouped into families of containers with common issues affecting their disposition. This information will facilitate development of action plans for families of containers that can be dispositioned as individual campaigns. In this manner, issues impacting the movement of containers to dedicated waste storage buildings can be resolved expeditiously and cost effectively through a focused campaign effort. It will also assist in identifying problems that may preclude offsite shipment. To solve these problems, plans can be developed and executed which will allow for future disposal. The project completion report included a summary of the containers remaining in the PA, the issues affecting relocation, and actions necessary for movement of the containers out of the PA or into an appropriate PA waste storage building.

The PA Evacuation Project was conducted without a single accident (Figure 2). There were no first-aid cases, no recordable accidents, no restricted workday cases and no lost workdays. This accomplishment is significant because it involves approximately 400 waste shipments and over 6,000 waste container movements. These numbers take into account the occasional multiple container moves to accommodate logistical constraints associated with non-destructive assay and space limitations.

The initial estimated budget to perform the PA Evacuation Project was $4.8M. This estimate assumed waste container movements would be conducted according to traditional methods and protocols. Early in the Project, it became apparent that continuing to follow historical site practices would jeopardize successful completion of the Project milestone as well as possibly overrun the budget. The Project schedule was significantly impacted when all movement of waste containers on site was stopped for almost seven weeks due to a non-project related criticality safety infraction.

The Project instituted a weekly planning session for all waste container moves on plant. Through this weekly plan, care was exercised in the sequencing and scheduling of container movements to avoid duplication of effort and minimize repetitive moves for individual containers. In addition, it became apparent early in the Project that technical issues and procedural requirements affecting nearly every container in the Project baseline were on the critical path. To effectively work these issues and develop a realistic schedule, the Project hired dedicated technical staff and assigned them to each of the major facilities involved with the evacuation effort. The result was a significant savings in costs needed to complete the Project. Total cost to perform the PA Evacuation Project was approximately $3.5M, $1.3M less than initially estimated.

As a consequence of the PA Evacuation Project, a number of future efforts were identified which have a strong potential for saving and/or avoiding substantial costs associated with ongoing waste operations. The most significant future action is to consolidate the Authorization Basis for waste storage buildings.

The existing authorization bases for the principal waste receiving facilities (e.g., Buildings 440, 664, 906, and 991) have limitations which preclude the transfer of various waste forms. These limitations may not be warranted for personnel safety, public protection, and/or security reasons. More in depth technical evaluations should be performed to determine which limitations are necessary and sufficient. If some of these limitations could be removed, more waste containers could be consolidated into waste receiving buildings. Example evaluations are discussed below.

• Corrosives in Building 440: Building 440 currently restricts corrosive waste (i.e., D002) from storage in the facility. The Basis for Operation Physical Operational Control (BFO POC3) suggests that limiting corrosives limits fire initiation and propagation mechanisms. Corrosives do not contribute to fire initiation or propagation. The RCRA permit allows D002 wastes in Building 440. An evaluation should be done to determine if a change to the Building 440 BFO to allow D002 wastes would be prudent.
• Non-Department of Transportation (DOT) Containers: Building 440 cannot accept non-DOT, site-approved containers. The basis for this requirement is that DOT containers are believed to provide "containment of radioactive wastes during fire, seismic-initiated container falls, and handling accidents" [Engineered Operational Control (EOC)1]. Many of the approved on-site packages are considered acceptable for this purpose. An evaluation would confirm the acceptability of non-DOT, site-approved containers for waste storage supporting a change to the Building 440 BFO.
• Multiple IDCs per Waste Container: Many of the waste packages stored on-site contain more than one IDC and currently cannot be accepted in Building 440 or 664. A criticality evaluation should be performed that considers multiple IDCs per package (i.e., containers with less than 90 percent of one IDC).
• Classified Wastes: At present Building 991 is not authorized to store some forms of drummed classified wastes. The current work to prepare a new authorization basis needs to review the necessity for these restrictions.
• Mechanically Compacted Wastes: Containers filled with mechanically compacted wastes are not allowed in Buildings 440 or 664. The rational for this exclusion is that the compacted waste may increase moderation. An evaluation needs to be performed to determine if this total prohibition is necessary. If not, then the Nuclear Material Safety Limit (NMSL) should be changed so that mechanically compacted waste can be accepted into waste storage buildings.

There currently is no single unified authorization basis for waste receiving and storage buildings outside the PA even though these buildings perform the same function in similarly constructed structures. The inconsistencies and different procedures and requirements add to the cost of managing waste because of increased training requirements for personnel sending waste, repetitive authorization basis change requests needed to accommodate the various waste forms to be stored, and delays resulting from determining appropriate receiving facility for the waste form to be shipped. Significant cost savings could be realized if waste receiving and storage buildings located outside the PA had a common standardized authorization basis document governing operations.

The Project was completed on time, for $1.3M less than initially estimated and with a flawless safety record. Completion of this project not only provided a gateway for site deactivation and decommissioning, but clearly identified the actions necessary to streamline on-site logistics for movement and storage of waste containers.

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