Kurt Colborn, Ward Best, Kurt Colborn, Richard Terlecki, Dennis Wade
RMI Environmental Services
P.O. Box 579
Ashtabula, OH 44004
(440) 993-2805

A major step in the decommissioning of the RMI Titanium Company's (RMI) extrusion plant in Ashtabula, Ohio was the removal of the Loewy 3850-ton extrusion press used by the DOE for uranium fuel and target fabrication. The project involved removal of the press itself, seven (7) furnaces, and miscellaneous support equipment totalling approximately 1.1 million pounds of uranium-contaminated metal.

A summary of the completed project is presented which emphasizes the unique aspects of planning and performing large equipment removal and decontamination. The summary includes a description of the physical performance of the project, and management practices which contributed to the project's success, including:

• The integration of RMI Environmental Services' (RMIES') in-house waste processing capabilities (including large capacity debris shredding, compacting, and intermodal transportation facilities) with selected service subcontracting of larger dismantling and decontamination tasks.
• Project approaches to waste minimization and overall cost control, including specification development which permitted bidders to propose the most effective strategy for completion of the project based on their own experience, expertise, and equipment availability.
• Lessons learned during cutting, rigging, and transportation of large components for decontamination off site; and techniques employed to assure that disposal site waste acceptance criteria were met.

The Major Equipment Remediation Project was completed during the period from August 1997 to February 1998 by RMI Environmental Services, Inc. (RMIES) with subcontracted assistance from GTS Duratek's SEG Division. The completed project demonstrates the successful application of the resources of a site prime contractor to support limited scope, service-oriented subcontracts as a means for improving the efficiency of a decommissioning project, and provides valuable lessons learned for those sites and project managers actively engaged in facility decontamination.

The RMI facility is contaminated with both radiological and hazardous materials resulting from almost thirty year's operation for the US Department of Energy (DOE) to shape nuclear materials. DOE's Office of Environmental Restoration and Waste Management (EM) has contracted RMI Titanium Company to conduct the RMI Decommissioning Project (RMIDP) to satisfy DOE's financial responsiblity to RMI for the removal of radiological and hazardous contaminants to levels which will allow the facility and adjacent areas to be released for unrestricted use. The project will allow RMI to terminate its license with the Nuclear Regulatory Commission (NRC) and to achieve closure of a Resource Conservation and Recovery Act (RCRA) Corrective Action Management Unit (CAMU) located on RMI's property.

The original RMI owned buildings were constructed in the 1950's, to enclose a titanium/zirconium sponge compaction facility. However, these buildings were never used for that purpose. In 1961, the facility was modified to house an Atomic Energy Commission (AEC) owned, 3850 ton extrusion press. The press and associated process equipment was moved to the site from Adrian, Michigan.

The primary function of the Extrusion Plant, since 1962, has been the extrusion and/or closed-die forging of metallic depleted, natural, and slightly enriched uranium (U) as a step in the production of reactor fuel elements for use in DOE defense reactors at the Hanford Reservation near Richland, Washington, and the Savannah River Site near Aiken, South Carolina. Uranium metal and a small amount of thorium metal extrusion work was performed under an exclusion section in the Atomic Energy Act and/or Nuclear Regulatory Commission (NRC) license during the production life of the site. RMI currently holds an NRC license for the site, amended to possession only for the purpose of decommissioning the site in accordance with the approved decommissioning plan.

At peak production in 1986, there were 138 people employed. The 35 acre site includes the primary plant's 7 acres, with approximately 100,000 square feet of plant area.

The removal of the Loewy 3850-ton extrusion press is a major milestone in the decommissioning of the RMI Extrusion Plant. The removal of the press was undertaken as a project which included removal of the press itself, seven (7) process furnaces, and miscellaneous support equipment totalling approximately 1.1 million pounds of uranium-contaminated metal. The approach to the project called for disassembly, sizing, and disposal of approximately 300,000 pounds of equipment, and decontamination of the remaining 800,000 pounds for disposal as radiologically clean scrap metal.

The prime contractor on the RMI site, RMIES, undertook the major equipment remediation project with an approach designed to make the greatest possible use of RMIES capabilities, combined with the selective application of subcontracted services. Careful development of this approach maximized the use of DOE resources already committed to decommissioning project support. The incorporation of this approach into the development of the technical specification produced a clearly defined scope of work, and a precise division of contractor/subcontractor responsibilities resulting in project completion with only one change order amounting to less than 2% of the firm fixed price subcontracted work effort. A summary of the utilization of RMIES capabilities in the approach to the project follows:

RMIES has the capability to perform much of the basic disassembly required to prepare for removal of the extrusion press and associated equipment. RMIES disassembly work included the removal of subsystems attached to the press such as cutoff saws, pumps, ventilation ducting, shears, and die-cleaning brushes. This preparatory work minimized the scope of the subcontracted work effort. In addition, completing this preparatory work before the pre-bid walkthroughs were conducted helped assure a clear understanding of the large-scale disassembly and rigging work required, with the goal of reducing the contingency bidders would consider necessary in their estimates of the work involved.

Perhaps the most significant of the preparatory efforts conducted was the complete safing of energy sources to the extrusion press, furnaces, and other systems slated for removal during the project. RMIES personnel first performed a lockout/tagout of all utilities, mechanical, and electrical energy sources. The subcontracted work scope was further reduced by RMIES' physical removal of utility and energy supplies from the extrusion press and other equipment. Conduits were cut, and lines were visibly severed or removed, greatly simplifying the subcontractor's pre-work inspection of the work area, and providing clear assurance that work could proceed safely. This engineered safety precaution completely isolated the equipment to be removed, eliminated the need for the subcontractor to interface with the utility needs of an operating plant, and allowed work to proceed without reliance on administrative controls such as lockout/tagout procedures.

RMIES capabilities include an installed large capacity shredder used to volume reduce light gauge metals, conduits, and non-metallic shreddable materials. The shredder is equipped with a permitted filtration system, and typically reduces initial waste volume by a factor of two. The use of this shredder capability was assured in the major equipment remediation subcontract specification through a requirement that the subcontractor segregate shreddable and non-shreddable materials to a set of requirements provided with the specification. Shredder utilization produced a waste volume reduction and disposal cost avoidance of approximately $35,000.

RMIES has established an intermodal container waste loading facility to provide for the efficient packaging and shipment of wastes for disposal. Subcontractor waste handling and disposal costs were avoided through RMIES' use of this facility, and the use of RMIES personnel to load containers and prepare them for shipment. The subcontract technical specification established waste segregation and sizing requirements to assure adequate interface with this capability, and with disposal site waste acceptance criteria. The major equipment project generated wastes sufficient to fill approximately 16 intermodal containers.

RMIES' decontamination capabilities include a sandblast booth with ventilation capabilities permitted for removal of both radiological contamination and lead paint. This capability was used on several large metal components too small to efficiently ship for off site decontamination. Application of this resource reduced waste volume generation, resulting in a disposal cost avoidance of approximately $35,000.

The technical specification for the subcontracted work effort made RMIES ventilation systems available for the subcontractor's use. The ventilation systems are equipped with fire suppression, and are permitted for use in work which generates airborne radiological and lead contamination. The subcontractor's ability to tie into these systems was clearly defined and limited by the technical specification, yet was sufficient to greatly reduce the subcontractor effort required to provide control of airborne contamination generated by the equipment removal effort.

RMIES is NRC licensed, and has its own Health Physics Department. and Health Physics Technicians (HPTs) which were provided to the subcontractor in support of equipment remediation activities. The HPTs performed radiological surveys, provided intermittent and continuous coverage (as required) of radiation work areas, and addressed general radiological issues and concerns associated with equipment remediation activities. HPTs also posted radiation work permits (RWPs) and established radiation work areas.

RMIES's decision to provide HPT support was based on the need for RMIES to maintain control over work performance in compliance with the terms of its NRC license for operation of the site. RMIES HPTs had the authority to stop work if approved policies and procedures concerning radiological protection were not followed, if the radiological protection measures specified in the RWP(s) governing work activities were not followed, or if general radiation safety or industrial safety practices were violated.

Selective subcontracting of a significant portion of the major equipment project was necessary due to the size of the equipment involved. The lifting capacity of site cranes was insufficient to handle many of the extrusion press components. Available cutting tools and personnel training were not applicable to sectioning the up to 22-inch thick castings for transportation and disposal, and the site's decontamination facility was not large enough to accommodate most of the equipment items involved. In addition, site personnel were not qualified to handle asbestos containing materials found in some furnace insulation and extrusion press gaskets. Therefore, RMIES pursued a service subcontractor with these capabilities. A firm fixed price contract was placed with GTS Duratek to compliment RMIES capabilities with the following:

Individual extrusion press components weighed as much as 110,000 pounds. The selected subcontractor brought the capability to rig and transport these components for further size reduction and subsequent disposal or decontamination.

Several large equipment items required sizing either to meet disposal site waste acceptance criteria (size envelope of 8 feet by 8 feet by 10 inches), or to permit transportation to off site decontamination facilities on standard-weight trucks. Cutting the up to 22-inch thick castings in some extrusion press components was required, with concordant control of airborne radioactive contamination and lead-based paint hazards. Subcontracted services included provision of trained personnel who used standard burning bars to perform this work. A track-hoe mounted hydraulic shear was also used to size piping and lighter-gauge components of the extrusion press and furnaces.

The scope of work for the major equipment removal project identified several items for decontamination. These items were selected based on a qualitative assessment of ease of decontamination based on factors such as simplicity of geometry, and surface to volume ratio. Selected items typically consisted of large cast pieces of the extrusion press. The technical specification provided the subcontractor the option either to decontaminate this equipment at the RMIES site, or to take the items off site for decontamination. Off site decontamination required that the subcontractor be responsible for secondary waste disposal, and that the subcontractor take title to the material under its license when it left the site.

Careful project planning and technical specification development paved the way for efficient, on time, and on budget completion of the major equipment remediation project. Further supporting this effort was the decision to structure the subcontract as a service subcontract offering the bidders maximum flexibility to select an approach to the work. The goal of RMIES was to remove the equipment in a specified time frame. The subcontract for the equipment removal provided a rudimentary sequence for the work, but did not define any aspect of the approach in detail. Key elements of the subcontract and technical specification leading to the success of the project include:

The technical specification provided a clear description of the condition the equipment would be in at the time the subcontractor arrived on site. RMIES equipment safing activities were performed prior to the subcontractor's start of work to eliminate potential interferences. A work area turnover procedure was implemented to confirm that contract-defined initial conditions were present. Walkdowns performed by RMIES and the subcontractor produced a written checklist confirming these conditions prior to the start of work. RMIES-provided services (material handling, waste disposal, health physics support) were not only described in the technical specification, but the methods the subcontractor would use to coordinate activities with RMIES were also described. In some cases, such as HPT support, the subcontractor was required to submit and update a schedule detailing the support RMIES needed to provide. Work plans were submitted by the subcontractor for each major element of the work. These described the approach to the work, defined the work area, and identified support requirements for completion. Daily reviews of the progress of the work between the RMIES Construction Manager and the subcontract project manager promoted the smooth flow of work. No changes were required due to RMIES delay or failure to perform.

Perhaps the single most important characteristic of the technical specification providing for efficient and effective completion of the project was the flexibility it provided the subcontractor to define the technical approach to equipment removal and decontamination. Providing this flexibility complicated the proposal review process, but it allowed subcontractors the flexibility to propose methods with which they were familiar and experienced. Within certain limits defined by the specification, subcontractors could even define the extent of the scope of work. For example:

• The specification provided bidders the option to perform the required equipment decontamination on site, or at an off site facility. If performed on site, RMIES would provide ventilation and secondary waste disposal, but compliance with Davis Bacon wage rates and lower-than-NRC free release standards was required. Off site decontamination freed bidders from project wage considerations, but required them to cover transportation costs and to take responsibility for secondary waste disposal. A prescriptive specification would have either eliminated bidders without off site decontamination capability, or would have resulted in higher bids from those whose off site facilities are more efficient than temporary, on site decontamination facilities.
• Bidders were provided the option to take responsibility for decontaminated scrap disposition, and even had the opportunity to purchase decontaminated equipment for resale. Flexibility in scrap disposition was necessary if off site decontamination was to be a feasible option. The latter option was of particular interest to two of the eleven bidders, one of whom ultimately proposed purchase of some of the equipment.
• The technical specification allowed the subcontractor to define the approach to achieving decontamination goals. Specific pieces of equipment were identified by RMIES for decontamination based on a qualitative analysis of their decontaminability, considering geometry and surface to weight ratios. Decontamination of these items was required, but the subcontractor had the option to dispose of heavily contaminated sections, or to select other items as necessary to decontaminate metal equivalent to 80% of the total weight of the specified items. A more prescriptive specification might have resulted in claims for repeated decontamination attempts, and in subsequent contract revisions to relax the specification requirements.

Considering the degree of flexibility given the subcontractor to define the technical approach to the project, a technically-focussed evaluation was necessary. Bid evaluations were performed using a 70% technical, 30% cost criteria. The technical evaluation awarded points for each of 15 submittals defining the subcontractor's approach required with the bid, specifically evaluated the technical approach, experience and references, innovativeness of the technical approach, and techniques for safety or quality assurance. Extensive and detailed evaluation of the bids was performed to determine the bidder's familiarity with the specification, ability to perform the work, and preparedness to interface with existing RMIES systems, procedures, and personnel.

Planning and coordination of subcontractor activities with RMIES operations demanded close attention to the interfaces between the two organizations. The technical specification required various submittals from the successful bidder which were developed prior to the start of work and also as the work proceeded. Key examples included:

• Submittal of a detailed project schedule for resource planning, in which the subcontractor identified needed RMIES support for waste handling, waste container delivery, Health Physics Technician support, and utility modification/availability.
• Detailed work plans for each major subtask were submitted by the subcontractor for RMIES review and approval. These work plans described the subcontractor approach to the safe performance of the work, and provided detailed requests for specific RMIES support or interface.
• Safe work procedures were submitted by the subcontractor which established a permitting system for specific high-risk activities. The procedures called for RMIES development of radiological work permits, and review and approval of welding and cutting permits, confined space permits, pre-lift checklists for hoisting and rigging, and necessary utility lockouts. Specific procedures were also submitted and approved for waste handling, hazardous waste handling and lead protection.

The submittal of the various work plans and procedures provided RMIES the opportunity to review the subcontractor's proposed operations in advance, to coordinate activities, to veto some activities, and to direct task performance in accordance with the procedures submitted for the project. This provided excellent control over safe work performance, and minimized prime/subcontractor conflict.

The technical specification for the major equipment removal called for the work to progress generally from east to west in the main plant. This cleared equipment from areas of the plant needed for waste material processing (shredding) and handling.

The seven furnaces in the specification were removed first. RMIES completed the utility disconnection of the furnaces prior to the subcontractor's arrival on site. Dismantling of these stand-alone pieces of equipment was therefore straightforward. The items were disassembled and sized using a hydraulic shear. Debris was deposited in bins by the subcontractor, after which RMIES performed an environmental evaluation and waste acceptance criteria review prior to depositing debris into intermodals for disposal. The single change order required on the project evolved because some of the furnaces contained more asbestos that RMIES environmental evaluations identified, and the additional asbestos remediation effort constituted a change in scope.

These tables were post processing staging and cooling areas for extrusions ejected from the press. Their construction included ducting to the RMIES permitted ventilation stacks, hoists for lifting the heavy uranium extrusions, and air-powered transfer systems integral to the tables. Ducting was removed first, compacted using the shear, and delivered to RMIES for disposal in intermodals. The tables were prepared for shearing by removing most of the bolts holding the structure together. The structure of the hoods over the tables was temporarily connected to still-active ventilation, and provided dust containment as disassembly proceeded. The hoods were brought down with the hydraulic shear, and size reduced along with the tables themselves. Some cast components of the tables were set aside for thermal cutting.

The Loewy extrusion press was powered using a bank of high pressure nitrogen bottles which provided the activating force for the hydraulic system which actually drove the press. Two tanks held reservoirs of water used to move the press cylinders. The bottles and one of the tanks were the first items to be removed for off site decontamination. The 5,000-pound bottles were lowered using a 35-ton crane, rinsed, shrink wrapped, and loaded eight to a truck for shipment to the subcontractor's off site decontamination facility. One of the tanks was similarly shipped, while another smaller tank was sheared for disposal by RMIES.

Finally, the extrusion press was removed. The main cylinder of the press posed the most significant challenge. A single cast piece, weighing over 110,000 pounds, it was designated for decontamination by the technical specification. The cylinder therefore had to be sectioned into pieces for shipment to the off site decontamination facility on standard weight trucks. The subcontractor rigged the individual sections to support them during cutting with the mobile 35-ton crane brought to the site. The cylinder was sectioned using standard carbon burning bars. Individual sections were shrink wrapped, and shipped on standard-weight flatbed trucks.

Thousands of linear feet of high-pressure piping were sheared or thermally cut depending on their thickness, and delivered to RMIES for disposal as radioactive waste. The press hydraulic control system was drained by RMIES prior to the subcontractor's arrival, and was subsequently removed and sized for RMIES packaging and disposal.

Decommissioning is not construction. Standards applied to a decommissioning project, identified in the specification for the work, and enforced as the work proceeds, should focus on the safe performance of the work. The end product is an empty building or an empty lot, so exhaustive application of conventional construction quality standards and configuration control practices is unnecessary. However, a clear definition of the end product (just how empty is the building to be) is still required. The development of a clear definition of the scope of work is key to the project's success.

Further, the nature of decommissioning makes it possible, even desirable, to perform the work on a service contract basis. The end product is so easily defined that this greatly simplifies the customer's role in getting the work done. Initial conditions can be described by the specification, and left to the bidder to determine by inspection. The approach to demolition is unlikely to be affected by minor changes in field conditions which would have significant impact on a construction project.

Finally, there may be any number of valid approaches to successfully complete a decommissioning project. Different service vendors offer different skills, and have varying combinations of strengths and weaknesses which may direct the strategy they develop. The technical specification will attract the greatest variety of bidders, and benefit from the most innovative ideas, if the specification is not restrictive in defining the approach to the project. Certainly, boundary conditions such as utilities which must remain in service, or adjacent buildings which must not be damaged will drive the specification development. However, details such as the cutting or decontamination technique to be used need not be specified.

Decommissioning projects can be successfully performed through the use of selective service subcontracts. Interfaces with the existing organization's capabilities must be clearly defined, and the scope of work clearly established. These basic elements will ensure the project's completion with minimum conflict, change orders, and deviation from schedule.

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