Innovative Use of an N-HASP at a DOE Closure Site

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Innovative Use of an N-HASPat a DOE Closure Site

• Presentation at
• ISM Best Practices Workshop
• Aurora, Colorado
• September 13, 2005 (Session 5-Location 4)
• by
• Brinley Varchol, Fluor Fernald QA Director
• Dr. Donald Paine, SH Director

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BACKGROUND
ISM Best Practices Workshop

• 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

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ISM Best Practices Workshop
Silos 1, 2, and 3 Area
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Categorization of the Silos 3 Treatment Facility
ISM Best Practices Workshop

• 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

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ISM Best Practices Workshop
Silos 3 Area, including Packaging Facility
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ISM Best Practices Workshop
Silos 3 Vacuuming Process
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Safe Harbor Approach
ISM Best Practices Workshop

• 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, DD,
  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

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Benefits of Safe Harbor Approach
ISM Best Practices Workshop

• 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.

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ISM Best Practices Workshop
Silos 3 Vacuuming Process
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N-HASP Contents
ISM Best Practices Workshop

• 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

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N-HASP Contents
ISM Best Practices Workshop

• Volume 2 includes
• Supporting Analyses consistent with other DSAs
  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

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Silos 3 Project Results
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 projects ALARA
  Goals.

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Silos 3 Project Results
ISM Best Practices Workshop
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Video clip of Silos 3 Vacuuming and Packaging
Operations
ISM Best Practices Workshop