1 innovative use of an n-hasp at a doe closure site presentation at ism best practices workshop...
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Innovative Use of an N-HASPInnovative Use of an N-HASPat a DOE Closure Siteat a DOE Closure Site
Presentation atPresentation at
ISM Best Practices WorkshopISM Best Practices WorkshopAurora, ColoradoAurora, Colorado
September 13, 2005 (Session 5-Location 4)September 13, 2005 (Session 5-Location 4)byby
Brinley Varchol, Fluor Fernald QA DirectorBrinley Varchol, Fluor Fernald QA DirectorDr. Donald Paine, S&H DirectorDr. Donald Paine, S&H Director
Energy Facility Contractors Group
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BACKGROUNDBACKGROUND
Energy Facility Contractors Group
• N-HASP Concept used for Silos 1-2 & Silos 3
• Focus of this presentation will be on Silos 3• Silo 3 contained 5,100 cubic yards of cold
metal oxides from the processing of uranium ores
• Primary concern was Thorium 230 and Radium 226.
• Structure classified in a PHAR as a Hazard Category 3 nuclear facility
• One TSR associated with the silo dome load limits
ISM Best Practices Workshop
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Energy Facility Contractors Group ISM Best Practices Workshop
Silos 1, 2, and 3 Area
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Categorization of the Silos 3 Categorization of the Silos 3 Treatment FacilityTreatment Facility
Energy Facility Contractors Group
• DOE approved method (DOE-Standard 1027) allows partitioning a facility for purposes of hazard classification
• Segmentation is approved for use when hazardous materials within two facilities are separated and cannot be readily brought together
• Silos 3 Treatment Facility is separate from the Silos 3 Structure (Hazard Category 3 Facility)
• Design of the treatment facility limits the amount of Silos material that can be transferred into the remediation equipment
ISM Best Practices Workshop
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Energy Facility Contractors Group ISM Best Practices Workshop
Silos 3 Area, including Packaging Facility
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Energy Facility Contractors Group ISM Best Practices Workshop
Silos 3 – Vacuuming Process
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Safe Harbor ApproachSafe Harbor Approach
Energy Facility Contractors Group
• Documented safety analysis process accepted in DOE Rule 10 CFR 830 Subpart B
• Specifies different forms of safety analyses for different types of projects (i.e. Reactor, D&D, Environmental Restoration
• Table 2, Item 6 describes the Safe Harbor method for development of DSA for Environmental Restoration Activities
• Project Specific Health and Safety Plan (N-HASP) was used for the Silos Project
ISM Best Practices Workshop
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Benefits of Safe Harbor ApproachBenefits of Safe Harbor Approach
Energy Facility Contractors Group
• Combines safety requirements into one document
• Improves worker access and simplifies the application of safety requirements
• Improves overall safety by ensuring cooperation between Operations, Safety, and Project Management in creating safety controls and process requirements.
ISM Best Practices Workshop
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Energy Facility Contractors Group ISM Best Practices Workshop
Silos 3 – Vacuuming Process
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N-HASP ContentsN-HASP Contents
Energy Facility Contractors Group
• Volume 1 includes:• Standard 29 CFR 1910.120 Project Specific
Health and Safety Plan with additional sections for ISM, Conduct of Operations, Nuclear Safety Requirements, Maintenance Management, Quality Assurance, and Occurrence Reporting
• Also includes Task Level Hazard Analysis with Controls and Mitigators
ISM Best Practices Workshop
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N-HASP ContentsN-HASP Contents
Energy Facility Contractors Group
• Volume 2 includes:• Supporting Analyses consistent with other
DSA’s developed• Integrated Hazard Analyses, Hazard
Category Calculations, Human Factors Evaluations, ALARA Analysis, Environmental ALARA Report, Fire Hazards Analysis, Accident Analysis, and a Health Physics Plan
ISM Best Practices Workshop
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Silos 3 Project ResultsSilos 3 Project Results
Energy Facility Contractors Group ISM Best Practices
Workshop
• Operated for 13 Months• Approximately 2300 packages loaded and shipped• Material retrieve through vacuuming and direct
load-out with no OSHA Recordable injuries and no transportation issues
• Safe Shutdown accomplished with only one recordable injury sustained on the last day of work
• Vacuuming, packaging, and handling of material accomplished with only 60% of the project’s ALARA Goals.
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Silos 3 Project ResultsSilos 3 Project Results
Energy Facility Contractors Group ISM Best Practices
Workshop
8148D-118
WORK SCOPE• Remove 5,100 cubic yards of low-level waste from one
concrete silo• Ship waste off site for disposal
CLEANUP REMEDY• Record of Dec ision signed in December 1994
• Explanation of Significant Differences for Operable Unit 4Silo 3 Remedial Action approved in March 1998
• Record of Dec ision Amendment to allow for treatment onlyas required to meet permitted disposal fac ility’s waste acceptance criteria
• Pneumatic retrieval system as well as remotely controlled and manned mechanical excavators used to remove thesilo waste
• Condition material to reduce dispersability, package and ship off s ite for disposal
STATUS• Fac ility design/build – COMPLETE• Packaging operations – COMPLETE
- P roduced nearly 2,300 soft-side packages of waste
- 13 month extraction and packaging operation
- 12 month, 1 million mile shipping campaignto Envirocare
• Safe shutdown and demolition – COMPLETE
PROJ ECT COMPLETION - 2006
WORK SCOPE• Remove 5,100 cubic yards of low-level waste from one
concrete silo• Ship waste off site for disposal
CLEANUP REMEDY• Record of Dec ision signed in December 1994
• Explanation of Significant Differences for Operable Unit 4Silo 3 Remedial Action approved in March 1998
• Record of Dec ision Amendment to allow for treatment onlyas required to meet permitted disposal fac ility’s waste acceptance criteria
• Pneumatic retrieval system as well as remotely controlled and manned mechanical excavators used to remove thesilo waste
• Condition material to reduce dispersability, package and ship off s ite for disposal
STATUS• Fac ility design/build – COMPLETE• Packaging operations – COMPLETE
- P roduced nearly 2,300 soft-side packages of waste
- 13 month extraction and packaging operation
- 12 month, 1 million mile shipping campaignto Envirocare
• Safe shutdown and demolition – COMPLETE
PROJ ECT COMPLETION - 2006
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Video clip of Silos 3 Vacuuming and Video clip of Silos 3 Vacuuming and Packaging OperationsPackaging Operations
Energy Facility Contractors Group ISM Best Practices Workshop