A Review of Decontamination and Decommissioning Technology Development Programs at the Department of Energy (1998)

Trip Report by Trish Baisden and Frank Crimi for the NRC Subcommittee on Decontamination and Decommissioning (D&D) Submitted December 3, 1996

For over 40 years, the Hanford Site manufactured nuclear materials for the nation's defense programs. To assist in this nuclear materials production, nine water-cooled graphite-moderated plutonium reactors were constructed along the Columbia River by the U.S. government between the years 1943 and 1971. Eight of these reactors (B, C, D, DR, F, H, KE, and KW), operated between 1944 and

1971, have been retired from service and declared surplus. In 1989, the more general need to remediate radioactive and chemical waste at the Hanford Site was identified by the DOE, the EPA, and the Washington State Department of Ecology in the Hanford Federal Facilities Agreement and Consent Order, commonly know as the Tri-Party Agreement. In 1992, the need to remediate (D&D) eight of the surplus production reactors to protect the environment was identified in the Hanford Environmental Impact Statement (EIS). The following year, the DOE issued a Record of Decision (ROD) under the signature of Thomas Grumbly, then Assistant Secretary for Environmental Restoration and Waste Management, concerning the decommissioning of the eight reactors. The ninth reactor, N-Reactor, was in transition to deactivation and was therefore not considered within the scope of the EIS or the ROD.

In the ROD five decommissioning options were evaluated. These options were:

1. Safe storage followed by deferred one-piece removal that would include a safe storage period during which surveillance, monitoring, and maintenance would be continued until each reactor block could be moved intact, via a tractortransporter, from its present location in the 100 Area to the 200 West Area for disposal (a distance of about 5–14 miles depending on the reactor location relative to the disposal site). A hypothetical safe storage period of 75 years was used to estimate the radiological inventory for this option.
2. No action; continue the present routine surveillance, monitoring, and maintenance of reactor structures for an indefinite period.
3. Immediate one-piece removal of the reactor block from its present location in the 100 Area to the 200 West Area for disposal.
4. Safe storage followed by deferred dismantlement and disposal at the 200 West Area.
5. In-situ decommissioning involving removal of roofs, superstructures, and concrete shield walls down to the level of the top of the reactor block and covering the remaining structures to a depth of least 5 meters with earth and gravel. The resulting mound would be topped with an engineered barrier designed to limit water infiltration to 0.1 centimeter per year.

principal test facility for exploring effects such as power level increases, graphite burn-out, and new fuel designs. Given the nature of testing, this reactor experienced higher-than-average fuel and process tube failures. In addition to the condition of the reactor core, a driver for selecting C-Reactor was high costs associated with maintenance and surveillance (M&S). With the exception of the D&D of some ancillary structures, stabilization of the fuel storage basins, and removal of the fuel, the reactor has been kept in an M&S mode since it was shut down in the spring of 1969. Age and resulting deterioration has made M&S an increasing expensive operation (about $1 million per year). Therefore, by demolishing as much of the building as possible and leaving only the structure and reactor core within the 3-to 5-foot thick concrete shielding wall, M&S and the potential for the spread of contamination can be reduced significantly. The other reason for choosing C-Reactor as the first of eight reactors to be decommissioned, was its proximity (900 feet south) to B-Reactor. Because B-Reactor has significant historical value, it has been nominated for inclusion in the National Register of Historic Places and currently is listed in the National Register by the National Park Service. Further, B-Reactor has been proposed as a publicly accessible museum, which carries with it certain implications as to the overall desired conditions at the combined 100 B/C Area. The last reasons for selecting C-Reactor were that the EIS ROD for the proposed D&D approach had been finalized, and the conceptual design and detailed radiological and hazardous materials characterization had been completed to implement the plan.

Note: Although Fluor-Daniel is the Site Management and Integration Contractor (I/C), all of the surplus reactors were turned over to Bechtel Hanford, Inc. (BHI), the Hanford Environmental Restoration Contractor.

"Cocooning" (i.e., safe storage) would involve the removal of 105 C-Reactor Building equipment and structure, except for the 3-to 5-foot concrete shielding walls adjacent to all sides of the reactor. These remaining shielding walls will be extended with concrete to the level of the highest shielding wall, and a roof system will be installed. An entry opening for access to the reactor area will remain, but it will be modified to accept a security door. C-Reactor ancillary buildings and structures would also be removed, leaving only the reduced reactor block enclosure.

September 29, 1995, BHI awarded a contract to Delphinus Engineering to develop a conceptual design for the interim safe storage of C-Reactor. The working definition of the safe storage condition given to Delphinus was:

• Interim inspection can be limited to once every five years.
• Containment to ensure that releases to the environment are not credible under normal design basis conditions.
• Shield wall penetration closures will maintain air/water leak tightness; in addition, below-grade penetration seals will withstand soil pressure and surcharge pressure.
• New roofing to be adequate to eliminate the need to replace the roof during the intended facility safe-store lifetime of 50 years.
• The final safe storage configuration of the facility not to preclude or significantly increase the cost of any decommissioning alternative for the reactor assembly itself.

The major activities addressed by Delphinus Engineering in its Conceptual Design Report (CDR) included:

• Site preparation, including security;
• Procurement strategy for long-lead-time equipment, materials, and services;
• Decontamination activities, including hazardous materials and equipment removal, building and structure demolition, and disposition of the Fuel Storage Basin and Transfer Bay;
• Waste management, including volume reduction, packaging, transportation, and disposal;
• Safe storage enclosure system design, including roof, penetration seals, electrical and remote monitoring, and ventilation; and
• Site restoration.

In April 1996 Delphinus Engineering delivered to BHI the CDR, which included the following deliverables:

• Conceptual design;
• Engineering studies;
• Long-lead-time procurement items;
• Preliminary hazards analysis;
• Work breakdown structure and WBS dictionary; and
• Conceptual cost estimate and project schedule.

Of particular note are the engineering studies. Five separate studies were performed to address the following areas:

• Safe storage enclosure;
• Decontamination versus contaminant removal;
• Demolition techniques selection;
• Salvage versus scrap value; and
• Disposition of the Fuel Storage Basin and Transfer Bay.

The purpose of the engineering studies was to conduct an in-depth search, determine potential alternatives, evaluate and compare alternatives, and develop prudent and cost-effective directions for the major design aspects of the projects.

The CDR developed by Delphinus Engineering became the basis for the 12-volume D&D plan from April through September 1996. The D&D plan was entitled "Definitive Design Report for the Reactor 105-C Interim Safe Storage Project."

The visit included a tour of the 105 C-Reactor Site on November 7, 1996, and discussions at the EESB Building in the 300 Area of the Hanford Site on November 8, 1996. In preparation for the site visit, a memorandum was sent to Jef Walker, DOE, Washington, and Shannon Saget, DOE, Hanford, by K. T. Thomas (dated October 18, 1996) on behalf of the NRC Subcommittee on D&D. The memo contained four questions to be addressed during the Hanford Site visit. These four questions (numbered), questions that arose during the visit, and our understanding of the BHI and DOE answers resulting from the discussions are given below.

Question 1: What led DOE-Richland (DOE-RL) to propose C-Reactor for a D&D large-scale technology demonstration (LSDP)? For example, was there one particular problem DOE needed help on, or did DOE-RL include the LSDP so as to stretch the D&D budget?

C-Reactor is one of eight reactors slated for safe storage followed by deferred one-piece removal. Developing new, practical technologies in the areas of characterization, decontamination, demolition, waste disposal, facility stabilization and worker health and safety during the C-Reactor project hopefully will reduce D&D costs, reduce health and safety risks, and expedite the safe storage of the other surplus reactors. The D&D of C-Reactor is being funded by EM-40 and EM-50 on a 50-50 cost-shared basis (projected total cost, $18 million.)

Question 2: What baseline technologies were being considered prior to the insertion of LSDP? What technologies would be used if there were no mature innovative technologies?

Baseline technologies are provided in the D&D plan for various work activities and in the CDR by Delphinus Engineering. As the design contractor, Delphinus Engineering was responsible for making a catalog of available technologies. In the CDR engineering studies, potential technologies were evaluated for the various activities identified (e.g., decontamination versus contaminant removal, demolition techniques, etc.). A description of each technique considered was included along with its potential application, applicability, cost, and availability. Technical references and source documents were included in each study. In determining baseline technologies, use was made of the DOE D&D Handbook (DOE/EM-0142P), and it is referenced repeatedly in the engineering studies.

Question 3: What is the comfort level with the baseline technologies? What is the comfort level with the proposed technologies?

The overall process used to select, review, and implement a LSDP associated with C-Reactor D&D is given in flowchart form in Figure 1. In the flow chart the roles of the IC Team and the Administrating Contractor are defined and the process used to determine, recommend, and implement the demonstration of innovative technologies is described. At this stage, care is taken to ensure that innovative technology has a direct comparison to the baseline technology.

Question 4: What are the contingency plans should the LSDP be unsuccessful? How long is DOE-RL willing to wait in terms of delays to accommodate problems associated with technology demonstrations for the LSDPs?

Environmental technology demonstrations are scheduled in parallel with the critical path activities and are not allowed to impact the schedule. The C-Reactor Safe Storage project is slated to be completed in about 18 months. Only mature technologies will be accepted for the C-Reactor LSDP. If a technology demonstration does not perform within the allotted time, then the original baseline technology will be used.

Is DOE-RL using an I/C for Its LSDP? Was the I/C concept a METC requirement for proposals? What basis was used to choose the I/C partners (i.e., did they have to be members of the Strategic Alliance?)?

The use of an I/C was a requirement of METC for all LSDPs. According to the original proposal, DOE-RL is committed to managing the project coopera-

tively with METC. The Assistant Manager for Environmental Restoration (AME) will be the senior DOE-RL manager with direct responsibility for the C-Reactor demonstration project. BHI is the Environmental Restoration Contractor and will function as the I/C. BHI reports directly to the AME for all work performed under the Site ER contract. The C-Reactor LSDP is using an I/C Team approach which couples a Technology Alliance Team (TAT) with BHI Project Management, which serves as the Administrative Contractor. The TAT consists of representation from CH₂MHiLL, International Technology, Thermo Electron, Savannah River Site, Bechtel National, Inc., AEA Technologies, D&D subgroups, Montgomery-Watson, and Morrison Knudson. These organizations are responsible for providing supporting cost estimates as well as collecting actual cost data. BHI executes the D&D activities using Hanford Plant Force union workers, except for construction work, which falls under the requirements of the Davis-Bacon Act. Davis-Bacon construction-type activities are bid competitively and awarded to firms in accordance with established DOE FAR. BHI provides project management, engineering, compliance, regulating health and safety, quality assurance, and field support for the project.

In developing a list of potential partners for the Strategic Alliance, did DOE issue a CBD announcement for an expression of interest concerning the cocooning of C-Reactor?

The selection of the members of TAT was made on the basis of previous D&D experience and a desire to become a part of the C-Reactor LSDP. A CBD solicitation was used. CH₂MHiLL, International Technology, and Thermo Electron are part of the Environmental Restoration Contractor and they represent the corporate offices. AEA Technologies is a European firm and provides the TAT connections to D&D activities internationally. The D&D subgroups also include representation from local Indian tribes, stakeholders (primarily DOE via the Hanford Site Technology Coordination Group [STCG]), and regulators (Washington State Department of Ecology and the EPA). METC required that the U.S. Army Corps of Engineers be represented on the TAT, and Montgomery-Watson and Morrison Knudson are the Corps representatives.

How does DOE-RL make cost estimates for the D&D activities? How are the cost-sharing technology demonstrations done?

Delphinus Engineering provided a detailed cost estimate and man-rem exposure estimates during development of the CDR and later the 12-volume detailed D&D plan. Baseline technologies were used for this cost estimate. After technology demonstrations are awarded, the technology providers are required to submit actual cost data to the I/C in sufficient detail for comparison with the

baseline costs. Cost data is collected and made a part of the Innovative Technology Summary Report (ITSR).

The C-Reactor project is not being carried out on a cost-sharing basis with the technology providers because it is felt that small business will not receive a "fair shake" if it is required to share the cost. EM-50 is funding the technology demonstrations. Thirty percent of the EM-50 funding (30 percent of the approximately $9 million EM-50 is providing over the life of the project) is targeted for allocation to private industry for technology demonstrations.

In developing the plans for the D&D of the C-Reactor, did DOE-RL rely on documentation associated with the D&D of the Shippingport Reactor?

Delphinus Engineering prepared the C-Reactor D&D plan. Personnel who had some involvement in the Shippingport Atomic Power Station D&D now work for Delphinus and were used during the preparation of the C-Reactor D&D plan. Bechtel personnel who were involved in the Three Mile Island Plant 2 cleanup and recovery effort also participated in the plan development and review.

How will DOE-RL prevent getting involved with an immature technology, that is, a technology which is not sufficiently developed to be tested as an LSDP?

The Technology Provider must then submit detailed procedures for review and approval. Immature technologies should be identified at this step.

Under which set of Environmental Safety and Health (ES&H) regulations (such as 10CFR835) do the activities at C-Reactor fall?

The C-Reactor Interim Safe Storage Project is being conducted by BHI under CERCLA requirements and DOE orders. The Hanford Environmental Remediation Disposal Facility (ERDF) is also permitted as a CERCLA facility, although it was designed to RCRA criteria. ERDF can accept up to 1.2 million cubic yards of waste. At present approximately 6,000 cubic yards per week are being sent to the ERDF. DOE EM-30 is not involved in the C-Reactor D&D, since any waste generated will be sent to ERDF.

Necessary and sufficient ES&H standards are not being used for the C-Reactor LSDP. All work is done in accordance with radiological regulations (i.e., 10CFR835), applicable DOE orders, and federal/state regulations.

Technology selection and evaluation:

• What is the baseline technology of the D&D project?
• What are the criteria for selection of LSDP over the baseline technology?

• What are the measurement criteria used to evaluate the LSDP in relation to the baseline technology?

The process for technology selection is shown in Figure 2. Hanford has identified six focus areas for which innovative technologies will be selected, used, and evaluated. The Hanford focus areas are characterization, decontamination, demolition, waste disposition, facility stabilization, and worker health and safety. It is important to note that BHI plans to evaluate the innovative technology (LSDP) in a direct side-by-side comparison with the baseline technology. For example, if the activity is decontaminating the surface of a wall, both the innovative technology and the baseline technology will be used to clean comparable size areas of the same wall.

Technologies that already have undergone demonstration at another DOE site will not be retested at C-Reactor unless there is a compelling reason to do so. For example, although the self-contained air-cooled respirator suits have been evaluated at CP-5, the demonstration did not utilize the suits in an actual reactor D&D situation. Since there is a need at C-Reactor for this protective equipment, it will be reevaluated. Four characterization technologies demonstrations are scheduled to start into the procurement cycle in mid-November 1996.

Is there a standardized format for documentation and reports?

Cost and performance data are collected and made a part of the ITSR. The ITSR guidelines help ensure that a uniform, standardized format is used for all LSDPs in the EM-50 program.

How are the I/C Teams selected? Are there established criteria?

The selection of I/C Teams members was not based on a competitive process. Members of the I/C Team are prohibited from bidding on large-scale demonstration projects.

How does DOE ensure that industry knows what technologies DOE needs for future D&D projects that can be demonstrated in an LSDP?

The Hanford LSDP program also uses the CBD, the Internet, the STCG, and Environmental Technology Partnerships to seek companies that might have innovative technologies to demonstrate. In seeking companies, the problem to be addressed is defined and one or more vendors are sought. Demonstration Packages are prepared with no specific Technology Provider in mind; only the problem to be addressed by the innovative technology is specified.

How were liability issues resolved?

BHI indicated that to date, they have not encountered any liability issues with the implementation of the C-Reactor LSDP. BHI is following the contractual requirements of its contract with DOE-RL by including appropriate contract clauses and requirements to the members of the TAT and other subcontractors. Product liability and intellectual property rights have not been barriers in setting up the C-Reactor LSDP.

How were intellectual property rights handled?

Intellectual property rights are retained by the Technology Provider.