Report of Survey of Oak Ridge Building 3597 Hot Storage Garden
1. Introduction
1.1 Purpose
The purpose of this document is to report the results of a survey conducted at
the Hot Storage Garden facility (identified as "Building" 3597) on the Y-12
Plant property at the Oak Ridge Site. The survey was conducted during the week
of 11/15/99.
The primary purpose of the survey is to identify facility conditions and to
define the characterization, stabilization, and material/waste/equipment
removal (if any) requirements that need to be met to transfer responsibility
for the facility from the Office of Science (SC) to the Office of Environmental
Management (EM). Additionally, estimated post stabilization surveillance and
maintenance (S&M) activities and costs are identified for transfer along
with the facility. The second purpose is to provide EM with insight regarding
the facility’s risks and liabilities, which may influence the management of
eventual downstream life-cycle activities.
The survey and this report are part of a process for implementing the
requirements related to the disposition of excess facilities addressed in DOE
Order 430.1A, LIFE CYCLE ASSET MANAGEMENT, using the associated guidance for
facility transition, deactivation, surveillance & maintenance, and
decommissioning.
1.2 Facility Description
The Hot Storage Garden is a fenced-in, open air facility. It is a 12 m by 5 m
concrete pad with two rows of pre-cast, reinforced concrete, cylindrical pipes
that form 14 vertical storage wells with caps. A 5 m by 2.7 m by 3.7 m deep
reinforced concrete canal of approximately 41,600 liters adjoins the pad. An
enclosed sand filter and pump house with non-operating equipment used
previously for water cleanup is still in place. Structural steel is in place
with hoisting equipment.
The area was previously utilized to store radioactive components (including
spent fuel rods) in below-grade wells and in the partially above-grade (about
half), water filled canal. It is exposed to the weather. The stored materials
were stated to have been removed in 1980 (This could not be verified).
The storage canal can be emptied via drains to Y-12 central water processing.
The boundaries of transfer are expected to include the 3597 facility (facility
footprint plus six feet in each direction). Boundaries for utilities associated
with the facility are expected to be the first source connection, exterior to
the facility.
1.3 Organization Representatives
Contacts in transferring and receiving organizations are:
| Oak Ridge SC |
Stan Frey |
| Oak Ridge EM |
John Michael Japp |
| Headquarters SC |
Barry J. Sullivan |
| Headquarters EM |
Andrew Szilagyi |
1.4 Survey Participants
2. Summary, Conclusions & Recommendations
2.1 Transfer Considerations
The conditions of the Hot Storage Garden area (3597) are such that very few
stabilization actions are required to transfer ownership from SC to EM. The
near term integrity of the facility does not pose a significant risk.
Surveillance and maintenance resource requirements are low.
The sand filter, which is substantially radioactive (emitting dose readings up
to approximately 2.5 feet beyond the facility boundary), is in a housing of
questionable integrity. As it is outdoors, a breach would have radiological
cleanup and disposal consequences. As a result, it should be removed and
disposed of relatively soon. This can be done either before or after transfer
to EM (see below), but should not be deferred indefinitely.
Although it is believed that there are no materials remaining in the storage
wells, this either needs to be verified, or contingency for costs incurred by
EM should be provided for discovery of such after transfer. The memorandum for
transfer should include language which would assign budgetary responsibility to
the Office of Science for an unexpected discovery of nuclear material (fuel)
within the wells.
Experience at DOE sites has confirmed a continuously increasing S&M
requirement and cost over time as facilities degrade; as such, the current
S&M estimate is anticipated to increase over time.
2.2 EM Path Forward & Management Risk
In general, the Hot Storage Garden can be readily decontaminated and
demolished. The effort and resources required for demotion is judged to be low.
The cost for maintaining the facility as-is is very low.
The water contained within the canal presents a potential for contamination
mobilization and therefore, should be drained. Additionally, any sludge
remaining in the canal after the water has been drained will require
dispositioning. Should circumstances prevent sludge removal, some water should
be left to prevent drying out and release as potential airborne contamination.
Although removable radioactive contamination is likely present throughout the
facility, it is limited. The effort to mobilize for sand filter removal may,
however, provide a synergistic value for proceeding with decontamination and/or
demolition of the rest of the facility. Therefore, planning for sand filter
removal should also consider the incremental effort to proceed with removal of
all the canal pump system components and decontamination of the facility. Once
decontamination has taken place, demolition can take place as an industrial
facility.
It is recognized that this recommendation needs to be incorporated into the
overall site priority list. The need to remove the sand filter, coupled with
the relatively low cost of decontaminating and demolishing this facility, the
fact that it is an non-enclosed area, and realization that eventually it will
have to be removed, all provide a rationale for doing so in the near term.
3. Survey Results
Table 1 - Survey results
|
Subject of Survey
|
Summary – These are observations except as otherwise
indicated to be statements or presumptions. |
| 1. Facility Structure |
The reinforced concrete appears to be
in reasonable shape. However, the concrete block wall surrounding the sand
filter and pump station is cracked, the steel cover on the canal is rusting as
is the structure used for rigging equipment. The fence surrounding the facility
is old, but functional for limiting unintentional access. The sooner these
relatively straightforward structures and systems are removed or repaired the
lower the susceptibility to degradation consequences.
There are vines growing on the structure. Periodic surveillance should address
vegetation intrusion. |
| 2. Process Systems |
The pumping system and sand filter
for the canal are out of commission and degraded from exposure to the weather.
The condition of the housing for the sand filter is questionable. The water
contained within the canal presents a potential for contamination mobilization.
Center sump – there is a sump in the center of the facility which is
uncharacterized. It is presumed to be contaminated since it drained the slab
which is roped off. This may become significant, but only during
decommissioning. |
| 3. Infrastructure and Support Systems |
It must be presumed that the hoists
are no longer certified and cannot be used - no issue.
Could not determine if electricity is still connected. |
| 4. Nuclear Safety & Materials |
Well internals – Material was
anecdotally stated to have been removed from the wells, but this has not been
verified. |
| 5. Hazardous Material |
Virtually none. There are lead
blankets on the sand filter for shielding. |
| 6. Radioactive Contamination and
Waste |
Water – the canal is substantially
filled with water, although below the overflow pipe. Presumably this water is
from rain and snow. The water is contaminated, albeit stated to be at very low
levels. The water was last sampled in 1990 when the canal was emptied. As
stated above, the water contained within the canal presents a potential for
contamination mobilization.
The sand filter is contaminated to the point of radiation levels 50-60 mR/hr,
indicating a substantial level of internal contamination. At these levels,
radiation worker training will be required for workers performing S&M
activities in proximity to the sand filter. Special shielding etc. is not
required. |
| 7. Environmental |
Soil contamination under facility –
the design of the wells is open bottomed. The drawings indicate the pool
overflow to the process water system is vitrified clay pipe. There is local
contamination within the facility and roped off areas at one end of the
facility. It can be presumed that removal of the facility will require
characterization and removal of some soil.
Animals are nesting beneath the sand filter and pump slab. |
| 8. Characterization Information |
Last radiation/contamination survey
is available. Highest smearable in 1999 annual survey was 2,000 dpm/100 cm2
beta/gamma. Direct radiation in the vicinity of the sand filter is 50-60 mR/hr.
At these levels, radiation worker training will be required for workers
performing S&M activities in proximity to the sand filter. Special
shielding etc. is not required.
A full understanding of the degree of contamination requires a more systematic
and thorough survey, including water sampling. |
| 9. Surveillance and Maintenance |
The only current activity is an
annual radiation survey for direct dose rate and contamination. There has been
no maintenance of the facility since the water was last drained from the canal
in 1990. |
4. Stabilization and Other Actions Required for Transfer
Characterization
-
An up-to-date report of an appropriately graded Pre-Transfer Review is required
to ensure that the facility's condition, contents, regulatory status and
hazards have been identified and documented. This documented review establishes
a baseline at the time of transfer, to provide EM with an adequate
understanding of the facility, and includes an assessment and graded
characterization of the facility. With agreement between SC and EM, this survey
report may serve as documentation of an appropriately graded Pre-Transfer
Review.
-
Storage Well internals – Material (spent fuel) was anecdotally stated to have
been removed from the wells, but this has not been verified. Documentation
(including photographs) should be provided, or a joint, SC-EM field inspection
of the open wells should be conducted prior to the transfer.1
-
A full understanding of the degree of radioactive contamination requires a more
systematic and thorough survey. Water sampling in addition to smear and
penetrating radiation surveys should be performed.
Stabilization
-
Canal Water – The water in the canal represents mobility for contamination and
should be removed along with any sludge. Install a better integrity cover to
aid in verifying that source and rate of accumulation is precipitation.
-
Ensure sand filter container is not rusted through and better protect from
weather until it can be removed.
-
Ensure electrical isolation – This is to verify what is already believed to be
the case.
5. Surveillance & Maintenance After Transfer
The following are the key surveillance and maintenance activities that should
be undertaken to properly manage the facility. Part of the surveillance and
maintenance program must include assessments for worker hazards and the
appropriate actions taken to assure worker safety. An estimate of near-term
annual cost is shown in Table 2
.
Surveillance
Annually
-
Radiation Surveys – annual and upon entry
-
Water sample and analysis
Monthly
-
Monthly Walkdown
| -
| Measure water level changes |
| -
| Vegetation control |
| -
| Animal control to prevent nesting beneath the
contaminated equipment |
| -
| Visual inspection to determine if physical degradation
has significantly increased |
Maintenance
-
Periodic draining of canal if necessary – if water continues to accumulate, it
should be periodically pumped to the process drains.
-
Sand filter – The condition of the sand container is suspect. It is exposed to
weather and if it should rust through, contamination will be spread. The sand
filter should be removed as soon as EM assumes responsibility, if not before.
-
Structure degradation – The metal structure, fence, concrete canal, unused
monitoring station and well covers will continue to degrade over time.
Eventually they will require some refurbishment to maintain isolation of
contamination.
Table 2 - S&M Cost Estimate Worksheet for Activities After Transfer1
|
Surveillance & Maintenance Costs |
Basis for Estimate |
Annual Estimated Hours & Capital |
Annual Estimated Cost |
| By NFDI |
| Nuclear Safety |
|
|
|
|
|
| Occupational Safety Health
|
|
|
|
|
|
| Fire Protection
|
|
|
|
|
2 |
| Radiation Protection |
Annual radiological survey: multiple
smears, dose rates near sand filter, etc. |
16 hours |
|
$1,600 |
|
| Emergency Management |
|
|
|
|
|
| Control, Accountability, Security for
SNM |
|
|
|
|
|
| Training and Qualification
|
|
|
|
|
|
| Quality Assurance
|
|
|
|
|
|
| Engineering, Configuration Control |
|
|
|
|
|
| Environmental & Waste Management
|
Occasional weed control requires LLW
disposal of cut weeds, debris. |
40 hours |
|
$4,000 |
|
| Administration |
Annual management of S&M,
reporting, and disposition planning.
|
80 hours |
|
$8,000 |
|
| Facility Structural S&M |
Periodic structural inspection of
canal. |
20 hours |
|
$2,000 |
$10,520 |
Facility Systems & Components
Surveillance
|
|
|
|
|
|
| Subtotal |
$15,600 |
|
| Other Direct Costs associated with
S&M. |
Allow 20% of the S&M labor cost
for consumables (HEPA filters, equipment repair parts, paint, absorbent, etc.). |
|
|
$ 3,000 |
|
| Site Overheads |
|
|
|
|
<>$4,261 |
| Site Assessment Costs |
|
|
|
|
|
| -
Utilities |
|
|
|
|
|
| -
Security |
|
|
|
|
|
| -
Site Services |
|
|
|
|
|
| Subtotal |
|
|
| Overall
Total |
|
$15,000 |
1 Budget estimate based on $100/hr
labor rate - fully loaded
2 Cost of Fire Protection and Security are
included in ORNL overhead
6. Other Transfer Details
Table 3 is a generic list of other considerations for transfer to EM.
Table 3 - Staff Considerations and Information Required for Transfer
| Subject |
Pre-Transfer Requirement/\Survey Report
Statement |
| Staffing |
Staffing considerations are not applicable to Building
3597. |
| Authorization Basis/Safety Regime |
Provide a list of facility-specific Authorization Basis
or other Safety Documents, if any, that govern the operation of the facility. |
| Nuclear & Fissionable Materials Inventory |
Not applicable assuming the storage wells do not
contain fuel. |
| Prior Commitments |
Provide a list and description, or supporting
documents, of facility specific commitments, if any, for which EM
will be responsible after transfer. |
| Agreements - Permits, Licenses, Purchase Orders,
Contracts, etc. |
Provide a list and description, or supporting
documents, of facility specific permits, licenses, purchase orders,
contracts, and other agreements, if any, for which EM will be
responsible after transfer. |
| Assets and Property Management |
Provide a list of government owned capital assets, if
any, (as defined in 41 CFR 109, Department of Energy Property
Management Regulations) for which custody will be transferred to EM along with
the facility. |
7. Attachments and References
-
Layout sketches and drawings
-
Photographs
-
Annual Radiological Survey Results
-
Response to Questionnaire
1 Discussion with Barry Sullivan
indicates and Office of Science preference for the establishment of a
contingency (specified in the MOA) for the unanticipated presence of spent fuel
in the cells.
|