67-04

EXPERIENCE WITH INDEPENDENT REGULATION ON A FIXED-PRICE CONTRACT TO IMMOBILIZE HANFORD'S TANK WASTES

Bill Dixon
Director of Regulatory Affairs
Hanford Tank Waste Privatization Project Lockheed Martin Advanced Environmental Systems

ABSTRACT

The U.S. Department of Energy (DOE) is privatizing the immobilization of Hanford's tank wastes through vitrification. This paper presents Lockheed Martin Advanced Environmental Systems' experience to date on how fixed-price contracts can be compatible with independent regulation.

POINT OF VIEW

Fixed-price contracts can be compatible with independent regulation within the DOE complex when:

Regulatory requirements and process are completely defined and mutually understood.
Both parties are careful to remain within the defined requirements and process.
Both parties have qualified regulatory staff who have experience in a fixed-price environment.
DOE shares the risks of regulatory impacts on project scope, cost, schedule, and quality.
All parties share a cooperative team approach focused on a safe and successful project.

EXPERIENCE

Lockheed Martin Advanced Environmental Systems (LMAES) is leading one of the two teams competing to immobilize Hanford's highly radioactive tank waste in privately owned and operated vitrification plants. The U.S. Department of Energy (DOE) wants this work performed under fixed-price contracts. DOE also wants this work done under independent safety, health, and environmental regulation. LMAES has just completed a 16-month phase of the fixed-price contract to establish the technical, regulatory, and business/financial elements of the project. DOE is performing a four-month evaluation of whether to proceed with neither, one, or both teams.

The regulators for this project are:

Washington State Department of Ecology for hazardous and mixed waste management and toxic air emissions,
Washington State Department of Health for radiography, radioactive air emissions, and sanitary waste,
U.S. Occupational Health and Safety Administration for industrial health and safety, including chemical process safety, and
DOE's independent Regulatory Unit for radiological and nuclear safety, including oversight of chemical process safety.

The U.S. Nuclear Regulatory Commission (NRC) is providing advice and assistance to the DOE Regulatory Unit. NRC and DOE are planning to transition regulation to NRC for the second generation vitrification plants at Hanford.

The Defense Nuclear Facility Safety Board (DNFSB) has actively interacted with DOE and its Regulatory Unit. So far DNFSB has just observed contractor activities, but has reserved its right to interact directly with the privatization contractors.

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