BNFL INC. SOLUTIONS THROUGH PRIVATIZATION IDAHO NATIONAL ENGINEERING AND ENVIRONMENTAL LABORATORY ADVANCED MIXED WASTE TREATMENT PROJECT
Calvin Ozaki
BNFL Inc.
1970 E. 17th Street, Suite 207
Idaho Falls, ID 83404
(208) 524-8484 (telephone)
524-4442 (facsimile)
ABSTRACT
In December 1996, the U.S. Department of Energy, Idaho Operations Office awarded the Advanced Mixed Waste Treatment Project (AMWTP) privatization contract to the BNFL Inc. Team. The AMWTP is the second largest privatization project in the DOE complex with a total life cycle cost of $1.18 Billion. The primary goal of this project is to meet milestones identified in the Settlement Agreement between the state of Idaho, DOE, and the U.S. Navy; an agreement which requires Idaho National Engineering and Environmental Laboratory (INEEL) transuranic (TRU) waste to be shipped out of Idaho by 2018. The BNFL Inc. Team includes BNFL plc, BNFL Engineering Ltd., Morrison Knudsen Corporation, GTS Duratek, Science Applications International Corporation, Rocky Mountain Remediation Services, Pajarito Scientific Corporation, and Manufacturing Sciences Corporation.
The AMWTP schedule is long-term, beginning in 1997 and completing in 2015. The schedule is divided into three distinct phases; Phase I - Permitting, Phase II - Construction, and Phase III - Operations. Phase III will include the retrieval of approximately 65,000 m3 of TRU and alpha low-level wastes currently stored above ground at the INEEL, waste treatment, and preparing the waste for shipment out of Idaho. Because the AMWTP is a fixed-price privatized project, BNFL Inc. will own the facility and finance the design, construction, and operations. DOE will pay only for performance (i.e., when deliverables are completed, and when waste is processed to contract specifications). BNFL Inc.’s process design includes supercompaction, macro-encapsulation, incineration, and vitrification. The overall treatment process will reduce the waste volume by at least 65% and will result in waste forms that can be accepted either by the Waste Isolation Pilot Plant or a low-level waste storage/disposal facility.
INTRODUCTION
In December 1996, the U.S. Department of Energy, Idaho Operations Office (DOE-ID) awarded the Idaho National Engineering and Environmental Laboratory’s (INEEL) Advanced Mixed Waste Treatment Project (AMWTP) privatization contract to the BNFL Inc. Team. The AMWTP is the second largest privatization project in the DOE complex, with a total lifecycle contract value of $1.18 B. The primary goal of this Project is to "treat and get the waste out of Idaho" and thereby meet the milestones agreed to in the 1995 Settlement Agreement between the State of Idaho, DOE and the U.S. Navy.
The overall vision for the AMWTP is to safely treat Transuranic waste (TRU) and mixed Alpha Low Level Waste (ALLW) for final disposal by a process that provides efficiency and value to the Government. This will be accomplished through a private sector treatment facility that will be designed, permitted, financed, built, operated, and owned by BNFL Inc. The facility will have the capability to treat the specified INEEL waste streams, with the flexibility to also treat other similar INEEL and DOE regional and national waste streams.
BACKGROUND
In the early 1970’s, DOE began retrievably storing defense-related TRU waste at the INEEL. This waste was primarily generated at the Rocky Flats Site, near Denver Colorado, and other DOE sites across the nation. In the mid 1980’s DOE stopped shipping TRU waste to INEEL, leaving behind a legacy of approximately 65,000 m3 of TRU waste retrievably stored above ground at the INEEL. The waste is currently stored at the Radioactive Waste Management Complex (RWMC) in the southwest corner of the INEEL in an enclosed aboveground earthen covered berm (Transuranic Storage Area Retrieval Enclosure, TSA-RE), and Type II storage modules (see Figure 1). The waste is mainly packaged in 55 gallon steel drums, fiberglass reinforced plywood boxes, and metal boxes, (see Figure 2) and contains heterogeneous mixtures of solid materials such as paper, plastics, rags, rubber, glass, graphite, concrete, metals, solidified process sludges, and absorbed liquids.
Fig. 1. Aerial view of Radioactive Waste Management Complex
Fig. 2. Aerial view of aboveground earthen covered berm prior to enclosure.
Most of the waste is presumed to be mixed waste, which contains both Resource Conservation and Recovery (RCRA) regulated hazardous waste constituents and radioactivity. Some waste streams also contain Toxic Substance Control Act (TSCA) regulated materials such as polychlorinated biphenyls (PCBs) and asbestos. Based on the TRU concentration, the waste is subdivided into two categories. The first category is AMLLW, which contain alpha-emitting radionuclides with an atomic number greater than 92, half-lives greater than 20 years, and concentrations between 10 and 100 nCi/g. The second category is TRU waste, which contains the same radioisotopes as AMLLW, but have concentrations greater than 100 nCi/g. Of the 65,000 m3 of waste to be treated at the AMWTP, it is estimated that approximately 25,000 m3 is AMLLW and 40,000 m3 is TRU.
In addition to the above mentioned 65,000 m3 of waste, DOE can exercise an option in the BNFL Inc. contract, and direct BNFL Inc. to treat up to 120,000 m3 of additional waste. This additional waste may include other INEEL waste, such as environmental restoration and decontamination and decommissioning (D&D) wastes or waste from other DOE sites.
REGULATORY DRIVERS
The primary regulatory drivers for the AMWTP are the 1995 Settlement Agreement and the INEEL RCRA Site Treatment Plan (STP). The 1995 Settlement Agreement between the State of Idaho, DOE, and the U.S. Navy contains specific legally enforceable (fines and penalties) milestones that DOE must meet for shipping the TRU waste out of the State of Idaho. The applicable AMWTP milestones are as follows;
The STP also requires that the AMLLW be treated to Land Disposal Restriction (LDR) requirements. Therefore, the AMWTP must treat the waste so that it meets the applicable requirements in the Waste Isolation Pilot Plant (WIPP) Waste Acceptance Criteria (WAC), RCRA LDR, TSCA, and achieve a volume reduction of at least 65%.
SCHEDULE
The AMWTP is divided into three Project Phases, which are primarily defined by the Settlement Agreement milestones;
Phase I - Permitting; This Phase consists of preparing and receiving approval for the required preliminary environmental permits and safety authorization documents. These include; (1) RCRA Part B Permit and Air Permit to Construct, (2) TSCA authorization, (3) data to support DOE’s NEPA analysis, (4) Preliminary Safety Analysis Report (PSAR), (5) Environmental, Safety, and Health Program Operating Plan (ESHPOP), (6) Preliminary Decommissioning Plan, and (7) regulatory-required public involvement activities. During Phase I, BNFL Inc. will also assist DOE in identifying other INEEL and non-INEEL DOE waste for potential treatment at the AMWTP. This will include obtaining treatment concurrence with the generator sites and regulatory authorities, and developing a treatment schedule for these wastes. The completion of Phase I is defined as providing DOE with all contract deliverables, and receiving all regulatory agency approvals that allow facility construction to proceed. Phase I began in January 1997 and will be completed by April 1, 1999.
Phase II - Construction; Phase II will commence once DOE gives BNFL Inc. the authorization to proceed with this part of the contract. This Phase includes; (1) completing the detailed design, (2) equipment development, and (3) equipment manufacture and construction of the Advanced Mixed Waste Treatment Facility (AMWTF) at the RWMC. This phase also entails completing operational testing, and testing required by the ESHPOP to fulfill any regulatory obligations. Phase II also includes successfully completing all final environmental permits, licenses, requirements and other obligations established during the ESHPOP authorization process. The anticipated Phase II start date is May 1, 1999, with completion by December 31, 2002.
Phase III - Operations; This phase includes; (1) retrieval of the waste from the RWMC above ground storage facilities, (2) pretreatment characterization of waste for storage and/or treatment, (3) storage, treatment, and post-treatment characterization for certifying the final waste form, (4) preparing and loading waste for shipment in TRUPACT II, and (5) RCRA closure of the AMWTF. DOE is responsible for transporting the TRU waste to WIPP or another TRU storage/disposal facility. BNFL Inc. is responsible for transporting and disposing of any mixed LLW or LLW. Waste treatment operations will begin by March 31, 2003, and the 65,000 m3 will be completely treated by the target date of December 31, 2015.
PRIVATIZATION CONTRACT
The AMWTP contract is a firm fixed price contract that spans the entire Project lifecycle, from conceptual design to RCRA closure. BNFL Inc. is responsible for securing and providing the necessary Project financing, and DOE only pays BNFL Inc. upon successful completion and acceptance of specified deliverables, and upon successful treatment of waste. Phase I deliverable include the preliminary environmental permits, safety authorizations, and project plans, for a total price of approximately $16M. BNFL Inc. fully finances the Phase II construction (approximately $270M) and Phase III operations, and does not receive any payments from DOE until the waste is successfully treated to the agreed upon final waste form specifications. DOE pays a fixed unit price for successfully treated waste, and BNFL Inc. amortizes the capital investment over the first 25,000 m3 of treated waste.
BNFL TEAM
The BNFL Team includes BNFL Inc., BNFL plc, BNFL Engineering Ltd. (BEL), Morrison Knudsen Corporation (MK), GTS Duratek, Science Applications International Corporation (SAIC), Rocky Mountain Remediation Services (RMRS), Pajarito Scientific Corporation (PSC), and Manufacturing Sciences Corporation (MSC).
BNFL Inc. is the prime contractor for the AMWTP and has overall contract responsibility to the DOE. BNFL Inc. is responsible for overall Project funding, and Project integration. This includes project management, public involvement/community relations, business management, hot startup, operations, and quality assurance.
BNFL Inc. is the American subsidiary of British Nuclear Fuels plc and was established in 1990. Over the past six years, BNFL Inc. has successfully bid and won numerous DOE contracts, including Management and Operating contracts at the Rocky Flats Environmental Technology Site (RFETS) and Savannah River Site (SRS), privatization contracts at the Hanford Site (Tank Waste Remediation System), Oak Ridge East Tennessee Technology Park (ETTP) and the INEEL, and Engineering Support contracts at the Hanford Site, RFETS, and Los Alamos National Laboratory (LANL). BNFL plc, the parent, is an international nuclear fuel-cycle services company with over 40 years of nuclear operations experience. BNFL plc brings over 25 years experience in designing, licensing, constructing, and operating private nuclear facilities. Over the past ten years BNFL plc has successfully completed over $12 billion in fixed-price privatized capital construction projects, some of which are similar to the AMWTP.
BNFL Engineering Ltd. is a British subsidiary of BNFL plc and brings many years of hands-on experience in designing similar waste management facilities at other BNFL plc United Kingdoms (UK) facilities, such as the Thermal Oxide Reprocessing Plant (THORP) at the Sellafield Site in England. BEL will provide the overall technology lead for flow sheet and process technology selection. BEL has specific design, development, and engineering responsibilities for materials handling, container opening, sorting, size reduction, supercompaction and encapsulation, materials transfer, containment philosophy, and specifying overall control systems. BEL will also provide the shielding and criticality consultancy for all systems within the Facility.
Morrison Knudsen Corporation has over 40 years of experience at the INEEL and a long history in the nuclear industry. MK will be the overall design integrator and will manage facility and utility design interfaces between the Team members. MK’s specific areas of responsibility include overall architect/engineering services, cost estimating, design for the site, buildings, and utilities, project controls and scheduling, and construction management and management of cold startup.
GTS Duratek is a national leader in vitrification of low-level radioactive and mixed waste. They are responsible for the design, development, procurement, and fabrication supervision of the thermal treatment systems which include the vitrification melter system, incinerator units, feed systems, discharge systems, offgas systems, and process control systems.
Science Applications International Corporation has extensive knowledge and first-hand experience in environmental permitting and safety documentation at the INEEL, and with the State of Idaho and EPA Region X. SAIC is responsible for all regulatory, permitting, and safety assessment activities, and will prepare all the necessary permitting and safety documentation for the AMWTP.
Rocky Mountain Remediation Services is a joint venture between BNFL Inc. and MK at the Rocky Flats Environmental Technology Site, where they are the subcontractor for all waste management and environmental restoration activities. RMRS will lead the preparation of the ESHPOP, PSAR, and decommissioning plan. They will also have primary responsibility for the process design, planning, and execution of waste retrieval and final waste form certification activities.
Pajarito Scientific Corporation, a wholly owned subsidiary of BNFL Instruments Ltd. specializes in radiometric assay systems. PSC is responsible for providing design support, fabrication, and startup and control of all nondestructive characterization instrumentation systems.
Manufacturing Sciences Corporation is an industry leader in recycling radioactively contaminated metals. MSC will provide design support, supply, and startup and control of all contaminated metals recycling systems that may be required for the AMWTP.
In synthesizing this Team, BNFL used their traditional integrated team concept for successfully managing large complex Projects. This concept includes the customer, the BNFL Team (BNFL and subcontractors), and the regulators as team members. At Project initiation, the BNFL Inc. Team developed the following Project Mission Statement that is meant to address the combined interests and needs of the BNFL AMWTP Team, DOE-ID AMWTP Team, and the State of Idaho and U.S. EPA Region X Regulators:
As a responsible member of the community, the BNFL Team is committed to the safe, timely, profitable, and efficient management of the Advanced Mixed Waste Treatment Project, which will prepare waste for shipment from the INEEL.
Additionally, the DOE-ID AMWTP Team participated in developing and concurring with this final version of the mission statement.
PROCESS FLOW DESCRIPTION
Waste operations are planned to commence by March 31, 2003, and continue on an around-the-clock (24 hours per day, 365 days per year) operating schedule through December 31, 2015. This schedule equates to an equivalent of one drum treated every 30 minutes, for 13 years. The Process Flow Sheet is depicted in Figure 3. and is divided into three main functional areas; (1) retrieval, (2) pretreatment, and (3) treatment.
Fig. 3. Advanced Mixed Waste Treatment Project Process Flow Sheet
Approximately 11,700 m3 of waste is presently stored in the Type II storage modules. The Type II storage modules are metal buildings which set on concrete pads, and contain free-standing stacks of waste drums and boxes. The remaining 53,300 m3 of waste is stored in the TSA-RE, which is a metal building which covers the above-grade earthen-covered berm. The berm was constructed by stacking drums and boxes on asphalt pads, and then covering the stacks with layers of plywood, tarps, and soil on the top and sides.
Waste will be retrieved from the TSA-RE by removing the soil overburden, tarps, and plywood. The retrieval operation will be automated and hands-off as much as practicable. The waste will travel from the TSA-RE to the characterization facility where it will undergo nondestructive examination and assay. Based on the waste’s physical, chemical, and radiological properties it will be sent to segregated storage in the Type II storage modules for preparation of waste campaigns. The waste will be segregated into the following 14 waste categories, based on treatment requirements; (1) inorganic homogeneous sludges, (2) organic homogeneous sludges, (3) soils, (4) metal debris, (5) inorganic debris, (6) graphite, (7) ceramic/brick debris, (8) organic debris, (9) paper/rags/plastic/rubber, (10) heterogeneous debris, (11) special case waste, (12) prohibited material, (13) remote handled, and (14) secondary waste.
Based on planned waste campaign schedules, the waste is transferred from the Type II storage modules and enters the Pretreatment Building, where it is fed into either a box line or drum line. There are currently one drum line and one box line planned, which will remotely open, sort, and size reduce waste containers and contents. The waste will be sorted and packaged to facilitate downstream treatment.
There will be four primary waste treatment processes within the AMWTF; (1) supercompaction, (2) macroencapsulation, (3) incineration, and (4) vitrification. The supercompactor is a remotely operated high force press that will compact waste packaged in 55 gallon drums. The resulting "pucks" will be loaded into "puck" drums or Standard Waste Boxes (SWB) and filled with a cementaceous grout (macroencapsulated). The incinerator will be a two stage horizontal excess air incinerator with offgas systems. The vitrifier will be a joule heated melter with offgas systems.
Metal debris, inorganic debris, graphite, ceramic/brick debris, organic debris, heterogeneous debris, and paper/rags/plastic/rubber will be supercompacted and macroencapsulated. Some large metal debris will bypass the supercompactor and go directly to macroencapsulation. Organic and inorganic homogeneous sludges will go to the incinerator, with the inorganic ash then going to the vitrifier. The molten glass will be discharged into 40 gallon drums, which will be overpacked into 55 gallon drums. The AMWTF will produce two final waste forms, vitrified waste and macroencapsulated waste, which will then be certified for shipment and disposal at WIPP. The waste will be campaigned and managed such that waste that is less than 100 nCi/g is minimized.
The certified waste packages will be either sent to the Type II storage modules to await shipment or sent directly to the TRUPACT II loading facility for shipment. BNFL Inc. is responsible for loading the waste into the TRUPACT II shipping containers, and DOE is responsible for transporting the waste out of the State of Idaho in the TRUPACT II shipping containers.
WHY TREAT
The BNFL AMWTP is contractually required to treat 65,000 m3 of TRU and AMLLW to meet EPA LDR, TSCA, WIPP WAC, and TRUPACT II requirements, and achieve a minimum volume reduction of 65%. The rationale for treating specific types of waste is as follows;
Approximately 1,500 m3 (2%) of drummed waste has been identified as potentially containing greater than 50 parts per million (ppm) of polychlorinated byphenyls (PCBs). Waste with greater than 50 ppm PCB does not meet the WIPP WAC, and TSCA requires treatment (incineration) of this waste prior to disposal. An additional 12,662 m3 (20%) of drummed waste is listed as "unknown for PCB contamination" and may also require treatment. Without some regulatory relief from WIPP WAC or TSCA requirements, this waste must be incinerated.
Approximately 35,000 m3 (54%) of waste is presently packaged in boxes that don’t fit into the TRUPACT II shipping containers. The TRUPACT II shipping container is the only shipping container for transporting the waste to WIPP. Therefore, these boxes will require treatment, and at a minimum will need to be opened, size reduced, and repackaged, and require extensive characterization prior to shipment to WIPP in TRUPACT II.
Approximately 15,000 m3 (23%) of TRU waste is packaged in drums and can be shipped to WIPP in TRUPACT II untreated if it meets the WIPP WAC and TRUPACT II shipping requirements. However, it is anticipated that a significant portion of this waste (~25-50%) will require some level of treatment and/or open-container characterization to meet the TRUPACT II and WIPP WAC requirements.
And lastly, approximately 25,000 m3 (39%) of drums and boxes of AMLLW do not meet WIPP WAC requirements, and are co-located and co-mingled with the TRU waste. This waste must be treated and/or concentrated to meet WIPP WAC requirements for disposal at WIPP, or treated to meet the Waste Acceptance Criteria at a RCRA-permitted mixed LLW disposal site.
Because of the above-stated regulatory and configuration requirements, approximately 60,000 m3 (92%) will require some sort of treatment before it can be shipped out of the State of Idaho for final disposal.
PROJECT STATUS
As of January 1998, the AMWTP Team has met all key project milestones on or ahead of schedule. These include:
The remaining key Phase I milestones and deliverables include the following;
CONCLUSION
This paper provides a snapshot of the early stages of the BNFL AMWTP, with much work remaining to be done before the first drum of waste is successfully treated. A key contributor to the overall success of this Project will be the continued cooperation that’s been provided between the DOE, State of Idaho, and BNFL Team.
The schedules for obtaining the required environmental permits and safety authorizations are extremely challenging, especially with regards to the chosen treatment processes (e.g. incineration). However, the BNFL Team believes this is an achievable schedule, because in this Project all of the key stakeholders share a common end goal. The State of Idaho and EPA wants to get the waste treated and out of Idaho. The DOE wants to get the waste off the INEEL and permanently disposed. The State of Idaho general public wants to get the waste off the Snake River Plain aquifer and out of Idaho. And BNFL, as a part of its core business, wants to treat the waste for DOE and get it out of Idaho.
The Settlement Agreement embodies the commitment of the federal parties and the State of Idaho to "act in good faith to effectuate its fulfillment" and "affirmatively support this Agreement." To date the AMWTP has enjoyed strong public and political support, and the commitment and cooperation of both the DOE-ID, and the State of Idaho. As such, the BNFL Team is confident that the AMWTP will continue to move forward in meeting the goal of treating and getting the waste out of Idaho.