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--> Appendix C Summary of the Meeting held on April 18, 1996, at the Argonne National Laboratory on the Subject of the DOE Large-Scale Technology Demonstration Program Associated with the D&D of the Chicago Pile 5 (CP-5) Reactor Trip Report by Trish Baisden and Frank Crimi for the NRC Subcommittee on Decontamination and Decommissioning Submitted June 3, 1996 Attendees Dick Baker DOE Chicago Operations Office Rob Rose Project Manager, Technology Development Division, Decontamination and Decommissioning Projects, D&D Project Engineer for CP-5, ANL David Black Waste Management Engineering, Technology Development Division, ANL Tom Yule Manager, Waste Management Program, Technology Development Division, D&D Program Leader for CP-5, ANL Jerry Hyde DOE HQ, EM-50 Steve Bossart METC, Morgantown, WV Frank Crimi Lockheed Environmental Systems, NRC Subcommittee on D&D Trish Baisden Lawrence Livermore National Laboratory, NRC Subcommittee on D&D The meeting summary and response to questions represent our understanding gained during this visit with DOE and Argonne National Laboratory (ANL)
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--> personnel. Numbered questions in the following text (e.g., Question 1), were sent to METC prior to the ANL visit. Questions that arose during the visit are not numbered. Meeting Summary Some history regarding the ANL proposal submission for funding associated with DOE's LSDP was provided. The METC representative explained that in July 1995, DOE-EM put out a Request for Proposals through the METC organization for the LSDP. Eight proposals were received; two were submitted by the Savannah River Laboratory, one from Oak Ridge National Laboratory, one from Rocky Flats, one from Battelle, one from Hanford for the C-Reactor, one from Fernald for its Plant I Facility, and one from ANL for the Chicago Pile-5 (CP-5) Reactor decommissioning. It was further explained that EM-40 (the Office of Environmental Restoration) and EM-60 (the Office of Facility Transition and Management) within DOE would be the organizations doing the testing, but EM-50 was the holder of technologies. The schedule for an LSDP was set by DOE to be 18 months and three technology projects were to be selected for the first year of the program. The second year, two more projects would be selected and in the third, three more projects. By the year 2000, DOE, through the DDFA, expects 90 percent of the technologies to have undergone a large-scale technology demonstration. ANL commented that the DOE METC solicitation required that the proposal incorporate the Integrating Contractor Project Management concept (i.e., integrating industry, university, national laboratory, and international expertise to accelerate technology progress) and that the proposals be endorsed by and submitted through a DOE field operations1 office. The latter requirement was to ensure commitment to the LSDP from the respective field operations offices. In October 1995 METC awarded LSDP contracts to ANL for CP-5, to Hanford for the C-Reactor, and to Fernald for Plant 1. DOE briefly described the use of cooperative agreements between the DOE Chicago Field Office (DOE-CH) and the Strategic Alliance as well as differences between commercial business practices and the Federal Acquisition Regulations (FAR). DOE also discussed three barriers or issues that had to be overcome or resolved before the CP-5 contract could be awarded: 1) Intellectual Property—At the present time, DOE appears to be giving up rights to the property and patents as an incentive to companies to test their technologies; 1 Proposal for a Large Scale Decontamination and Decommissioning (D&D) Demonstration at the CP-5 Facility, August 18, 1995, Chicago Operations Office, Department of Energy.
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--> 2) Product Liability—The liability limit is $25 million with the Strategic Alliance liable for the first $15 million; DOE pays all claims above this amount; and, 3) Issues related to negligence. QUESTION 1: What led DOE-CH to propose its site for a D&D LSDP? For example, was there one particular problem you needed help on or did you include the LSDP so you could stretch your D&D budget? ANL responded that ANL is the best place to develop technology for D&D because of ANL's commercial, naval, and research reactor experience. ANL has the right people with the corporate memory. ANL has experience in the D&D arena already. It is not one particular problem we are looking for help on but rather ANL is committed to developing and testing new technologies. D&D of nuclear facilities is one of ANL's strategic thrusts and members of the staff have been working for over two years developing an overall D&D initiative. When the METC call for proposals was made, we were prepared to respond. The proposal submitted through DOE-CH requested a total of $5.25 million from DOE-HQ EM-50 for the period of October 1995 through March 1997 to accommodate and demonstrate approximately 40 technologies. This request included anticipated costs for technology evaluations, interface engineering, safety assessments, and demonstration costs. It was proposed that after finalizing the selection of technologies the budget allocations for the specific LSDPs be prepared jointly by DOE-CH and METC staff.2 ANL also commented that organizational changes were made to facilitate its D&D initiative. At ANL, the D&D effort was moved from the Operations Division to the Technology Development Division. Within the ANL management structure, all project managers are members of the Technology Development Division.3 ANL is attempting to marry users of technology with developers of technology. ANL managers are required to identify and develop new technologies and be willing to take a risk. ANL has personnel with extensive D&D experience. For example, the ANL CP-5 D&D Project Engineer who was present at the meeting was the Project Manager for the recently completed D&D efforts on both the B-200 M-Wing hot cells and the B-212 D-Wing Plutonium Gloveboxes at ANL. Another example given was an individual who was the Project Manager for the recently completed D&D of the Experimental Boiling Water Reactor (EBWR) and is now the Project Manager for the D&D of the JANUS reactor. ANL also mentioned that some of the funds originally earmarked for its Integral Fast Reactor (IFR) Program are being redirected into a couple of decon- 2 Ibid., Section II.B 3 Organizational chart for the Technology Development Division, the organization unit within ANL involved in the CP-5 D&D LSDP.
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--> tamination projects at ANL, one based on a laser and the other on chemical decontamination technologies. Since use of the Integrating Contractor concept was a METC requirement for proposals, ANL was asked on what basis they chose their partners (i.e., members of the Strategic Alliance). DOE-CH established the Strategic Alliance with ANL and the others in response to the condition in the Request for Proposals that the integrating contractor management concept be used for the proposed LSDP of D&D technology. DOE-CH is committed to co-manage the LSDP and the D&D integrating contractor with METC. Members of the Strategic Alliance for the LSDP at CP-5 include: Partner Reasons Selected Duke Engineering & Services Commercial nuclear experience and demonstrated cost effective management practices ICF-Kaiser Experience with commercializing technologies, particularly in the international marketplace Florida International University (FIU) 17 universities were evaluated; chose FIU because of its expertise in decontaminating concrete 3M 3M has several technologies that may be cost-effective alternates to baseline technologies of the CP-5 reactor demonstration Commonwealth Edison (ComEd) Interface with commercial utilities Argonne National Laboratory Site of facility to undergo D&D In developing a list of potential partners for the Strategic Alliance, did DOE issue a Commerce Business Daily (CBD) announcement for an expression of interest concerning the decommissioning of CP-5? The reply from DOE-Chicago was that no CBD notice was issued for CP-5. How are the D&D efforts being managed by the Strategic Alliance? ANL responded by saying they are using performance-based management rather than compliance-based management. ANL explained that all of the tech-
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--> nology providers (TP) share in the risk. Their cost share is 30 percent of the total cost (i.e., a fixed-price contract) for the development and demonstration of a LSDP project. Members of the Strategic Alliance who also want to participate as technology providers were required to declare their intentions at the time the alliance was being formed. 3M and FIU made this declaration. Under the conditions of the Strategic Alliance, ANL does not have to declare and can be both a member of the Strategic Alliance and a technology provider. Articles of Collaboration, an agreement among the members of the Strategic Alliance that defines how the members will interact and resolve disagreements, were also developed. The Articles of Collaboration provide for the election of a Board of Directors. ANL is a signatory to the Articles of Collaboration. DOE sits on the Board of Directors as a non-voting member. The Board of Directors works on a 90-day window for reviewing and approving projects. Once the Board of Directors makes it decision, then it goes to DOE-CH, METC, and EM-40 for approval. Technology providers often have good candidate technologies, but they do not have experience working in a radiation environment. ANL expects the D&D of CP-5 to be a good place to learn how to work in a radiation area because of the relatively low radiation levels associated with CP-5. However, the increased cost associated with training workers and working in a radioactively contaminated area will be representative of future applications of D&D technology. Members of the companies that serve on the Board of Directors cannot participate in the demonstration of one of their technologies and simultaneously serve on the Board. If they want to demonstrate one of their technologies, they become a non-voting member while their technology goes through the selection process and, if selected, during the time the technology is evaluated for overall effectiveness and performance. If, for example, 3M, which is on the Board of Directors, wants also to act as a TP, it cannot vote on the performance of its technology. 3M must step out of the Strategic Alliance when it is demonstrating its technology. The representative from DOE-CH stated that the Board of Directors was expected to be a self-policing group. It is to establish performance criteria and metrics by which to judge performance (i.e., 90-day performance milestones). It was also commented that while the first million dollars was being expended, DOE-CH would stand back and let the Strategic Alliance do its job. The report card at the end will tell the story of how efficiently and cost effectively the Strategic Alliance has both managed the D&D efforts to decommission CP-5 and integrated the testing of new D&D technologies. The functions and the organizational structure of the DOE-CH D&D LSDP are shown in Figure 1. How are the D&D funds managed? A Cooperative Agreement was drawn up between members of the Strategic Alliance (with the exception of ANL). The Cooperative Agreement was devel-
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--> Figure 1 Functions and Organization Structure of the DOE-CH D&D LSDP. oped to cover the cost share commitment associated with the Technology Providers, as well as issues related to liability and intellectual property. A Cooperative Agreement is being used that incorporates commercial business practices rather than the FAR requirements. ANL is not a signatory to the Cooperative Agreement because liability and intellectual property rights are covered for them under the contract between DOE and the University of Chicago. It was reiterated that the biggest issue related to developing documents such as a Cooperative Agreement was the question of liability. Intellectual property was also a stumbling block, but DOE gave up property rights and patents as an incentive. After the LSDP contract was awarded to ANL by METC in October 1995, ANL entered into a Basic Ordering Agreement (BOA) with Duke Engineering & Services so that the planning process could begin. The BOA offered ANL the greatest flexibility in that the agreement could be amended quite easily to increase the scope of work. As new, well-defined tasks are added, Duke Engineer-
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--> ing & Services provides ANL with a revised cost estimate to cover the increased scope of work. The revised cost is based on a previously agreed upon rate structure for services. Duke Engineering & Services is handling all of the administrative details for the Strategic Alliance and will be tasked with writing all the contractual agreements with technology providers for the LSDPs. In early 1996 METC asked for a separate proposal to be submitted for the LSDP for CP-5, but this time the proposal was to be from the Strategic Alliance on behalf of ANL and not from DOE-CH. METC also asked for the proposed work to be submitted by the Strategic Alliance using the Technical Task Proposal (TTP) format required by DOE-EM. The Strategic Alliance responded to both of these requests. The new proposal and the associated TTP is the mechanism that allows the DOE to fund members of the Strategic Alliance directly. How are LSDP technologies selected and if selected, how are they evaluated? Technologies are selected by a Technology Selection Team (TST). Members of the TST for the LSDP for CP-5 include: Organization Representative ANL David Black ComEd Rock Akers Duke Engineering & Services Brian Cruse FIU Joe Boudreaux ICF-Kaiser Holmer Duggar (Chair) 3M Jack Everett METC (ex-officio) Steve Bossart Functions of the TST were described as: Identifying needs and developing problem sets; Developing selection criteria; Looking for innovative demonstration technologies; Evaluating technologies; Recommending technologies for demonstration; Specifying performance indicators for demonstration; and Assessing and reporting on technologies demonstrated. The Screening/Selection Criteria developed by the TST include: State of maturity; Improvement over baseline; Application across complex/cost benefit; Transportability to CP-5;
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--> Cost of CP-5 demonstration; TP interest; Compatibility with CP-5 schedules; and Value of information gained by demonstration. After initial selection, other facility specific issues of the proposed technology demonstration are established. These include: Does the LSDP fall within the established safety and environmental envelope? Are there any issues related to characterization and waste disposal? Can the utility/support system requirements reasonably be met? Table I lists the applicability of EM-50/METC funded technologies to the CP-5 LSDP. The members of TST evaluated primarily METC/EM-50 supported technologies. Individual members of the TST are charged with evaluating technologies in their own areas of expertise. Table 2 lists the potential technology demonstration opportunities in CP-5 by activity. Factors considered in technology evaluation: Improvements over baseline; Reduction of secondary waste volume; Cost; Personnel exposure; Time; Training, viability; and Job specific issues. Technology demonstration will be done in two phases: Test plan development and safety analysis (may stop here because of facility specific issues); and Demonstration performance (following approval of the initial plan with a "90-day window" to allow for changes in the plan). At the end of the demonstration, a technical report will be generated by the Test Engineer. The report will contain "just the facts" and no conclusions. The TST will use the technical report and other information to make a final evaluation and provide conclusions and recommendations. This information will be documented in a final report issued by the TST.
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--> How does ANL make cost estimates for D&D activities? ANL has worked closely with Nuclear Engineering Services (NES), a private company specializing in decommissioning consulting and field support with experience in D&D planning, cost estimating, remediation, field services, and radiological health and safety, to develop the cost estimates. In essence, NES is validating ANL's cost estimates. ANL commented that good characterization data is needed before going out to bid. Otherwise, the scope of the job can change drastically. Issuing change orders causes the costs to escalate. ANL stated that it wants to develop the capability to do good cost estimates internally. For benchmarking cost estimates, DOE-CH Operations Office used TLG Services, Inc., a company similar to NES, to validate cost estimates independently. ANL also believes that it gained some valuable experience in this area with the D&D of the EBWR. ANL plans to use an internally bid contract (i.e., use ANL personnel) for health physics support of D&D efforts at ANL and for characterization of the JANUS reactor. In developing the plans for the D&D of the CP-5 Reactor, did ANL rely on documentation associated with the D&D of the Shippingport Reactor? DOE-CH answered that it did use the Shippingport documentation in planning CP-5. QUESTION 2: What baseline technologies were being considered prior to the insertion of the LSDP? What would you use if there were no mature innovative technologies? The Strategic Alliance selected baseline technologies on the basis of comfort, known technologies that will work, and their collective experience. A baseline technology or short list of needs (if no baseline technology is available) was selected for each D&D operation associated with the decommissioning of CP-5. All baseline technologies are documented in the overall CP-5 Decontamination and Decommissioning Plan. (Because this information is contained in several large reports, copies were not requested.) How do you prevent getting involved with an immature technology, that is, a technology which is not sufficiently developed to be tested as an LSDP? The reply was that immature technologies should be weeded out by the provision requiring the technology provider to cost share at the 30 percent level. DOE does not want to pay for technology development if it is not ready for a
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--> Table 1 Applicability of RM-50/METC funded technologies to CP-5 LSDP
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Complete chart is found on the previous page.
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Complete chart is found on the previous page.
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--> TABLE 2 Potential Technology Demonstration Opportunities in CP-5 Activity Demonstration Location Possible Technologies 1. Characterization Rod storage holes Internal piping surfaces Exhaust system ductwork Automated surveys (floors, wall) Characterization of Radioactive Contamination Inside Pipes with the Pipe ExploreTM System Internal Duct Characterization System Three-Dimensional Integrated Characterization and Archiving System (3D-ICAS) Mapping, Characterization, and Inspection System (MACS-Mobile Automated Characterization System) 2. Concrete Decontamination Concrete floors, walls Wall storage area Hot cell Decontamination Using Liquid Nitrogen Carrier with Solid CO2 Particles Remote Operated Vehicle Dry Ice Pellet Decontamination System Laser Ablation of Contaminants from Concrete and Metal Surfaces Concrete Decontamination Using Microwaves Electrokinetic Decontamination of Concrete 3. Remote Dismantlement Reactor vessel Graphite reflector Thermal shield Lower shield Biological shield Dual-Arm Work Module Mobile Work System for Decontamination and Decommissioning (ROSIE) Swing-Free Crane Control 4. Worker Protection In-cell work Advanced Worker Projection System Protective Clothing Based on Permselective Membrane and Carbon Adsorption 5. Work Area Containment Reactor block Innovative Containment Design Capture Ventilation Systems Contained Waste Transfer Equipment LSDP. Contracts will be negotiated for a fixed price. The cost share requirement applies only if the contractor is testing a technology. QUESTION 3: What was your comfort level with the baseline technologies? What is Your comfort level with the proposed LSDP technologies? ANL feels comfortable with the technologies that already have undergone the selection process. The technologies that are ready to go include:
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--> Mobile Automated Characterization System (MACS)—ORNL-developed technology for automated floor surveys for radiation contamination (expected early May 1996); Membrane Filtration—3M-developed technology for the removal of Cs-137, Co-60 from pool water (Gary Goken, 3M, is the contact); Pipe ExplorerTM—Science and Engineering Associates-developed technology for characterization of contamination in underground drain and ventilation piping (expected late April 1996); Rotopeen—3M-developed technology for the removal of fixed contamination from rod storage hole liners. This is a scabbling technique using tungsten-carbide blades, but there is an issue involving use of the Rotopeen in a radiation environment. The baseline technology for this operation is cutting the pipes out of concrete. Future demonstration technologies that have been selected include: Contaminated paint removal from concrete: ° Flashlamp—high intensity light for heating painted surfaces ° ROVCO2-Remote Operation Vehicle with solid CO2 blasting ° Rotopeen (ANL has already tried some chemical decontamination and grit blasting) Advanced Worker Protection System Robotics ° Dual Arm Work Module ° ROSIE-II Why are you using robotics when a job can be done by hand? Previously the DOE EM-40 Program Manager stated that using robotics will drive up the costs especially if you use robotics where you can do the work by hand. Work can usually be done quicker by hand. Using robotics will take longer and increase costs. However, if using robotics can make a significant difference in areas where hands-on work is unsafe due to radiation levels, DOE is interested in developing it. For robotics to be a successful development effort, it must be tested in areas where hands-on work also can be done. If problems arise with the robotics during testing, workers need to be able to make repairs and adjustments without encountering unacceptable exposures to radiation. What is the status of LSDP activities that are now on the CP-5 D&D schedule? None of LSDP technologies so far selected are on a critical path of the CP-5 D&D schedule. ANL says it has some flexibility with EM-40. For example, the
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--> D&D of the fuel pool is scheduled for 1998. However, time may permit the insertion of the Membrane Filtration LSDP ahead of schedule. ANL may ask for an increment of funding from EM-40 to do the membrane filtration test this year rather than waiting until 1998. QUESTION 4: Are there contingency plans if the LSDP is unsuccessful? How long are they (i.e., ANL in Concert with DOE EM-40) willing to wait in terms of delays to accommodate problems associated with the LSDP technology demonstrations? ANL provided a copy of its project schedule which shows technology insertion points. The schedule has an outlook at of at least 180 days. Duke Engineering will write contracts that will have a termination clause if technologies are not working out. Technology providers will not be paid until the negotiated milestones are met. Contracts are written for service costs plus a fixed price for meeting the milestones. Work-arounds are laid out for contingency planning purposes. The schedule4 contains parallel paths for LSDPs and are laid out so they are not all on the critical path. Under which set of Environmental Safety and Health (ES&H) regulations do the D&D activities of CP-5 Fall? D&D activities funded by EM-40 have been going on at CP-5 for about two years and they have been operating under the usual ES&H regulations, primarily those in 10CFR835. In 1994, as part of the planning for the D&D of the CP-5 reactor, the associated hazards were identified, defined, assessed, and documented in a Safety Analysis Review (SAR). More recently, another SAR was prepared that included the LSDPs associated with CP-5. During the past year, ANL also participated in a pilot study for the DOE ES&H Necessary and Sufficient Standards (N&SS) Program. The objective of the N&SS pilot study with ANL was to review the hazards associated with a real D&D situation and based on the assessment of the hazards, make judgments as to which DOE orders and regulations should apply; that is which ones are necessary and sufficient. The N&SS deemed appropriate for the D&D of CP-5 were documented in the pilot study. This document is in the final approval phase at DOE headquarters. Organizations in the approval chain for the N&SS for CP-5 include the University of Chicago (representing ANL) and DOE-EH-1. Once the N&SS are approved, it is intended that it is this set of ES&H regulations that will be followed. Thus, the Strategic Alliance would be bound to abide by the N&SS document, if approved. (A copy of this document was not yet available.) 4 EM-40/EM-50-METC CP-5 D&D LSDP Integrated Projects Baseline Schedule.
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--> A comment from one of the ANL staff was that many of the DOE orders can be traced back to a federal mandate. DOE-CH pointed out that the D&D of CP-5 is not regulated under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act, ''Superfund," enacted in 1980 and amended in 1986 as the Superfund Amendments and Reauthorization Act [SARA]). The State of Illinois supported a request for exemption from CERCLA. CERCLA/SARA pertains only to hazardous waste that is regulated by the Environmental Protection Agency and was intended to address the restoration of major U.S. uncontrolled hazardous waste sites, including landfills (Superfund sites). Since the D&D of CP-5 no doubt will involve the generation of radiological-only and mixed (radiological and hazardous) waste, ANL argued that its work falls more naturally solely under the Resource Conservation and Recovery Act (RCRA) (RCRA legislation was designed to regulate the production, handling, disposal, and reporting of hazardous wastes).
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