EFCOG Best Practice #55
03/21/08
PDF version
Facility:
Hanford Site, Richland, Washington
Best Practice Title:
Achieving the First Record of Decision on a Canyon in the
Complex
Points of Contact:
Brief Description of Best Practice:
One of the most challenging precursors to performing
environmental cleanup is
reaching a decision on a cleanup alternative that is
agreeable to the U.S. Department of Energy (DOE), regulatory
agencies, and stakeholders, who represent a multiplicity of
interests. Furthermore, the difficulty in achieving a
decision is directly related to the complexity of the
cleanup effort itself. Challenges include physical aspects
such as obtaining the quantity and quality of
characterization data required to provide a basis for
decision-making. They also include, however, organizational
aspects such as maintaining commitment and consistency in
thought over the length of time needed to perform
evaluations and reach a decision, while budgets fluctuate,
leadership changes, and priorities evolve. Activities
leading to the issuance of a cleanup decision for Hanford’s
U Plant exemplify the complexity of reaching cleanup
decisions for the many substantial structures still to be
addressed across the DOE complex. The difficulties
associated with reaching a decision for U Plant were
significantly reduced as a result of implementing this Best
Practice.
The U Plant “Canyon” is an 800-plus-foot long concrete
structure constructed, as were four other canyon facilities
at Hanford, to chemically separate plutonium from fuel rods
irradiated in Hanford’s production reactors. An examination
of the way the Record of Decision (ROD)a
on the U Plant Canyon was achieved provides a Best Practice
methodology for achieving decisions on other substantial
structures:
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Create, sustain, and empower an interagency project team
committed to resolving challenges.
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Establish an Agreement-in-Principle (AIP) among DOE and
applicable environmental regulatory agencies to define the
cleanup problem and the framework under which it will be
solved.
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Divide major initiatives into meaningful but achievable
subtasks and focus on completing one of the easier
subtasks first to create success to build upon.
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Provide regular opportunities for DOE and regulatory
agencies to interact jointly with stakeholders.
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Plan and coordinate with regulatory agencies and
stakeholders to identify and resolve potential issues at
the outset.
-
Conduct independent validation of project scope, schedule,
budget, risks, and associated road blocks early in the
project.
In 1995, a Canyon Disposition Initiative (CDI) team was
formed comprising members from DOE, the U.S. Environmental
Protection Agency (EPA), and the State of Washington
Department of Ecology (i.e., the “Tri-Parties”) as well as
from major site contractors. The CDI team developed a plan,
including a range of alternatives for dispositioning the
five canyons at Hanford, reviewed it with stakeholders, and
cemented it in an AIP signed by the Tri-Parties the
following year. The AIP established that the
Comprehensive Environmental Response, Compensation, and
Liability Act of 1980
(CERCLA) Remedial Investigation/ Feasibility Study process
would be followed, on a case-by-case basis, to evaluate
potential cleanup remedies and identify a preferred
alternative for the final end state for the five canyons.
The U Plant Canyon was chosen as the pilot for the proof of
concept, due to its relatively low radiological loading and
more limited number of regulatory issues that needed to be
addressed.
In conjunction with the public interactions required under
the CERCLA process, from 1996 through 2005, the CDI team
implementing the AIP primarily gained stakeholder
perspective through frequent presentations and updates to
the Hanford Advisory Board (HAB). The HAB is an independent,
non-partisan, and broadly representative body advising the
Tri-Parties on selected major policy issues related to the
cleanup of the Hanford Site. In 1997 a draft Phase I
feasibility study was prepared for the U Plant, and based on
that study, the HAB provided a letter to the Tri-Parties
framing its concerns regarding the CDI. This issues letter
provided an important guidepost to the Tri-Parties through
the years as players changed.
Additionally, the DOE interacted directly with affected
Indian nations as designee of the Federal government.
Lastly, in 2001 and 2005, the Tri-Parties supported the
Hanford communities in providing informational local
television broadcasts covering the CDI and the overall
vision for closure of the U Plant area. Team input,
stakeholder reviews, and independent validation early in the
project allowed identification of the most difficult issues
and prompt initiation of issue resolution actions (such as
specific characterization and studies) to be accomplished on
a schedule to support the decision-making process.
The U Plant final ROD was issued in the fall of 2005 as the
first final ROD for the remediation of a DOE canyon facility
and the first ROD calling for leaving waste in place on the
Hanford Central Plateau under an engineered
evapotranspiration barrier. The ROD was recognized by the
EPA as one of three RODs of the Year for Fiscal Year 2005.
Numerous complex regulatory and technical issues were
resolved to reach a final remedial decision that will
protect the environment and minimize risk to the workers
during cleanup. The selected “close-in-place” remedy for U
Plant involves the removal of some long-lived radionuclides
from the facility and disposal to an out-of-state geologic
repository, consolidation of contaminated equipment into
below-grade cells, filling the equipment and cells with
grout, collapsing the structure above the canyon deck,
installing an engineered soil barrier, and conducting long
term monitoring. The remedy is sufficiently robust that the
ROD documents the regulatory agencies’ approval of waivers
and variances from various environmental requirements for
the disposal of the variety of hazardous wastes that are
currently within the canyon.
Why the Best Practice was used:
The U Plant is one of five canyons at Hanford that were
similarly constructed as concrete monoliths to chemically
process irradiated fuel, and consequently contain
significant amounts of residual radioactive material. As of
the early 1990s, planning for their cleanup consisted
basically of deactivating the facilities, followed by many
years of surveillance and maintenance before they would be
decontaminated, demolished, and disposed of in a traditional
manner. This approach was characterized by significant
projected cost and carried with it a fair amount of
industrial and radiological safety risk. This Best Practice
was used to reach a better decision for the U Plant as a
pilot project for the remaining four canyons through the CDI.
What are the benefits of the Best Practice:
Benefits of implementing this Best Practice are improved
safety, reduced cost, and increased confidence among
regulatory agencies and stakeholders that innovative
solutions can be achieved together. The Best Practice also
establishes a team that can effectively promote obtaining
waivers and exemptions from governing regulations where the
intent of those regulations is otherwise met with an
innovative approach. Precedent has been set for the
close-in-place disposal of canyons and other substantial
structures across the DOE complex.
What problems/issues were associated with the Best Practice:
Over the nine years between establishing the AIP and issuing
the ROD, nearly all the major players changed. With those
changes in personnel, there were at times pushes to change
the scope outlined in the AIP. While reassessment of a
project can be good, it many times serves as an unwarranted
distraction that can prolong the decision-making process,
increase the cost, and even put the outcome in jeopardy.
Future deployment of this Best Practice would benefit from
including in the AIP provisions for 1) existing players to
indoctrinate new players with the content of the AIP and
history of the project as it has progressed and 2) formally
evaluating proposed changes in scope, which is an essential
practice for good project management.
Additional lessons learned and best practices regarding the
U Plant Canyon (i.e., 221-U Facility) ROD are provided in
the following noteworthy sources:
The CDI concept held that significant cost avoidances might
be realized by using the canyon buildings for permanent
disposal of low-level waste instead of demolishing the
buildings and disposing of the resulting waste in another
location. Thus, early CDI concepts involved disposal of
Hanford Site wastes both inside and outside of the canyon
structure, followed by the installation of a surface barrier
to provide long-term containment for the concrete structure
and waste fill. To ensure that the use of canyons are
maximized in the future, management committed to identify
waste disposal possibilities in current and near-term
feasibility studies and modify the approved U Plant Canyon
ROD if an appropriate waste stream is identified.
-
D&D-35827c,
“Project Experience Report, Canyon Disposition Initiative
(221-U Facility),” January 2008.
This report provides a summary of Lessons Learned associated
with the CDI for the U Plant Canyon. The report provides
recommendations for the U Plant Canyon and future projects,
as well as opportunities for improvement for future projects
throughout the DOE Complex.
How the success of the Best Practice was measured:
The success of this Best Practice was measured in achieving
the first ROD on a canyon structure in the complex.
Projected net present worth costs of the full removal
alternative and the chosen close-in-place alternative are
$84 million and $67 million, respectively. The
close-in-place alternative also realizes an improvement in
worker safety in that a lesser degree of heavy demolition
activities involving radiological hazards is required.
Additionally, the close-in-place alternative provides
greater long-term protection of the environment than the
full removal alternative.
Description of process experience using the Best Practice:
Use of this Best Practice buoyed the effort to achieve a ROD
on the U Plant Canyon through changes in budgets,
leadership, and priorities. At times funding constraints
slowed progress, and the momentum generated by CDI was
essential to bridging those gaps to achieve the goal of a
ROD over the long run.
This Best Practice embodies Integrated Safety Management
System Core Function 1: “Define Scope of Work.” Clear
definition of the task to be performed and the goal to be
achieved is essential to safely and successfully completing
a specific work task in the field, and even more so for
completing long-term projects in the regulatory arena. For
complex situations, independent validation of task
definition, including early identification of major
challenges to achieving the goal, further improves the
probability of success.
a
U Plant ROD
http://www.efcog.org/bp/p/doc/cdiROD.pdf
b
DOE/IG-0672
http://www.efcog.org/bp/p/doc/ig-0672.pdf
c
D&D-35827
http://www.efcog.org/bp/p/doc/cdiPER.pdf
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