MH-1A_STURGIS_Lessons_Learned_.pdf

.59

“The views, opinions and findings contained in this report are those of the authors(s) and should not be construed as an official Department of the Army position, policy or decision, unless so designated by other official documentation.”

Brenda Barber, P.E. and Hans Honerlah Baltimore District, CENAB-ENE For NAVY Enterprise (CVN-65) Team 11 Jan 2018

DEACTIVATED NUCLEAR POWER

PLANT PROGRAM (DNPPP)

LESSONS LEARNED FROM MH-1A

STURGIS

• 1952 DOD Study on the Feasibility of Developing Military Power Plants

• Defense Utilization Facilities Authorized by Section 91.b. of the Atomic Energy Act of 1954

• Section 110.b. of the AEA Excludes DOD Utilization Facilities from AEC/NRC Licensing

• ANPP a Joint Program Between DOD and the Atomic Energy Commission

• Each Service Participated in the Army Managed Program

• USACE was Designated the Supervisory Agency by Army

• Planned, Designed, Operated, and Shut Down the Plants

• US Army Engineer Reactors Group

• Nuclear Power Division – OCE

• Nuclear Power Field Office - Ft Belvoir

• Six DOD Power Reactors Fielded

• Four Army

• One Air Force

• One Navy

• Three Prototypes Built at National Reactor Testing Station (Now Idaho National Lab)

US Army Nuclear Power Program

• For the Three Army Deactivated Plants (SM-1, SM-1A, MH-1A) Remaining:

• Ensure the Security of the Residual Radioactive Materials Present in the Reactors

• Ensure Structural Integrity of Facilities

• Perform Environmental Monitoring to Ensure any Exposure to the Public is Below Limits and As Low As Is

Reasonably Achievable (ALARA)

• Perform Required Environmental Cleanup

• Plan for and implement Final Decommissioning

DNPPP Mission

• Historical (1972 to 1996)

• Nuclear Reactor Systems Health and Safety (AR 385-80)

• USACE Approved Environmental Assessments and Decommissioning Plans

• Current (1996 to Present)

• Army Reactor Program (AR 50-7)

• Army Radiation Safety Program (Pam 385-24)

• Permits - Radiation Protection Programs

• We must comply with all federal health, safety, and environmental regulations

• DOT 49 CFR

• OSHA 29 CFR

• RCRA/TCSA 40 CFR

Regulatory Framework and Oversight

AR 50-7 published in 1996

• Assigns Proponency to Deputy Chief of Staff for Operations (now DCS G-3/5/7)

• Created the Army Reactor Council (ARC)

• USACE Representative on ARC

• Assigns Roles and Responsibilities

• Outlines Reactor Permitting Process

Current Regulatory Framework

• 1998 USANCA Study of Potential Decommissioning Costs

• Cost Escalate Much Greater than Inflation

• Environmental Regulations continue to become more stringent and impact cost

• Uncertainty associated with availability of waste disposal facilities

• Army Reactor Office Requested that USACE

Perform All Hazards Assessments to Better Define Disposal Costs

• VCSA Concurred with Concept of Early Decommissioning and Directed USACE to Begin AHA of MH-1A

Decommissioning Planning Activities

As of 2000

X10 CFR 50.82(a)(3) requires that decommissioning be completed within 60 years post-shutdown

STURGIS MH-1A

First Barge Mounted Nuclear Power

The former World War II Liberty Ship, SS Charles H. Cugle, was converted into a floating nuclear power plant in 1966

STURGIS was the first barge mounted nuclear plant to regularly supply power to a shore station

The STURGIS’ nuclear reactor, MH-1A, was used to generate electricity for military and civilian use in the Panama Canal Zone from 1968-1976

Fuel Removal and Long-term Storage

In 1977 after completing it’s mission, the STURGIS returned to Fort Belvoir where the nuclear fuel was removed, and the vessel was prepared for safe long-term storage

The STURGIS was maintained in James River Reserve Fleet at Joint Base Langley-Eustis, VA since 1978

The Corps of Engineers has performed quarterly monitoring in the James River until 2015 when the STURGIS was moved to Galveston, TX for Decommissioning

THE STURGIS IS A

HISTORIC

PROPERTY

During decommissioning, the Corps will preserve items of historic interest, including an electronic repository of documents

USACE entered into Memorandum of Agreement with the Virginia State Historic Preservation Office to mitigate the adverse effects of the decommissioning

Design schematic from 1959

STURGIS DECOMMISSIONING PLANNING

• Issued a Task Order against an existing MATOC base contract to IEM for $1.9M to complete the

Decommissioning Planning, which included:

• A review of all prior studies and documentation

• Preparation of a Environmental Assessment (EA)

• Preparation of NEPA Section 106 Documentation

• Preparation of a Decommissioning Plan

• A cost estimate to implement the decommissioning and dismantlement

• A Waste Management Plan, including transportation

Planning Contract issues in 2012; Planning was substantially complete by 2014; Decommissioning permit issued in 2014

Lesson learned on planning was with respect to the EA – we had selected four (4) potential locations for the project. The EA was publicly advertised in all locations in two major papers for each location. NO public comments were received during this process. We should have been more proactive with ensuring local and state government were aware their locations were being considered for this project.

File Name

STURGIS – DECOMMISSIONING AND DISMANTLEMENT

CONTRACT ACQUISITION

• Solicitation strategy was to issue a Task Order against an existing MATOC base contract

• Prepared an Independent Gov’t Estimate (IGE) for approx. $37M

• Contract type – Cost Plus Fixed Fee

• Award was based on a Best Value to the Gov’t approach

• Received 7 bids

• Utilized the same review board for technical and cost

• Team reviewed all technical proposals first and prepared a formal memo on the technical proposal

• Team then performed a cost analysis and realism review

• Upon review of the technical merits and the cost merits, the successful bidder was selected

• Chicago Bridge and Iron (now APTIM) won the contract for $34.6M

• Brief protest for 45 days stopped the project; protest was resolved and work quickly resumed

Lesson learned on contract: Allow adequate time to issue the contract and to allow for sufficient review by the bidders;

consider options for incentives; ensure all subcontractor’s or teaming partner’s contracts agreement are thorough vetted;

require subcontracts to be firm fixed price and/or have ample justification for other contract types (T&M, cost, etc);

schedule should include adequate time to address protest.

BIG QUESTIONS – Will indemnification be offered under the Price Anderson Act?

ROLES AND RESPONSIBILITIES

USACE Management and Oversight Team

– Overall Project Management and Technical – CENAB

– Construction oversight – CESWG

– Naval Architect – CENAP

– Oak Ridge Associated University – Independent Verification for the Army Reactor Office

CB&I Project Management

– Includes Site Manager, Safety, RSO, Quality

– Engineering of Work Packages

Waste Management and Radiological Controls – Atkins

– Radiological Control Technicians and Waste Characterization and Packaging

Waste Transportation and Disposal – WCS (Andrews, TX) [this was a USACE directed change after cost avoidance was identified by USACE] Shipyard Support – Malin

– Site Security

– Dockside Support (Crane and Equipment Operators, Electrician, Welders, Naval Architect)

MH-1A STURGIS ACCOMPLISHMENTS

• All major reactor components have been successfully removed with the exception of the Primary Shield Tank which is almost completely removed

• Ongoing waste shipments;

• Debris – 57 radiological shipments to WCS, ~1,137,000 lbs.

• Water – 33 shipments to US Ecology TX ~1,150,000 lbs.

• Lead recycled to date ~600,000 lbs.

• MARSAME Survey Unit Package/Plans finalized to date – 36

• Surveys implemented – 30

• ORISE completed IV and/or side by side measurements in 16 survey units

• Reports finalized – 22

• ORISE reports reviewed – 5

• Radiation dose to date – 4,450 mrem total which is ~30% of projected dose budget; highest individuals (2) 600-700 mrem

• Risk mitigation is on-going and providing positive results

COST BREAKDOWN

Contract Costs

– Planning Contract $1.9M award; actual $1.4M

– Decommissioning Contract

• Initial award - $34.6M

• First modification - $17.6M

• Second modification - $14.5M

– USACE oversight costs (FY12 – FY19)

• Actual expenditures (FY12 – FY17) - $5.7M

• Future forecasted need (FY18-FY19) - $2.3M

RADIOLOGICAL CONDITIONS

Radiological Characterization *

– Contamination is low (Corrosion products and activated metals)

– Decontaminated during defueling and SAFESTOR

– Estimated 6,000 Curies

• 5,200 based on Ni activation

• Over 95% in Pressure Vessel

– Highest dose rate measured to date is 7mr/hr in RCV

– Two components with significant dose rates expected

• RPV (up to 5 R/hr on contact)

• PST inner wall (up to 2 R/hr on contact)

– RPV is only waste item designated as Class B/C

• Most other material is less than Class A

– Will be disposed in RCRA Cell at WCS

* Information based on USACE data

MOBILIZATION AT GALVESTON

Site Mobilization and Training Initial activities that established the shipyard infrastructure

– Site security

– Environmental Monitoring established

– Staging areas for the planned work including ship access, industrial hygiene preparation, and decontamination areas,

– Materials storage areas and project offices/crew facilities.

– Work crews hired and trained

– Rad Worker

– Rigging

– HAZWOPER/Hazmat

– Containment

Secure Work Area

RELOCATION OF STURGIS FROM JRRF TO MALIN

Towing delayed 6 months due to concerns raised by Galveston City Council The STURGIS tow was initiated on April 16 and it arrived at the Malin Shipyard (Pier 40/41 at the Port of Galveston) on April 29

– 6 days ahead of schedule.

Hull was scamped in the JRRF prior to tow Towing was by a licensed towing contractor in accordance with the requirements of the U.S. Navy Towing Manual.

Towing Plan approved by USACE and USCG Licensed pilots were used in port areas Ballast remains on-board and will be processed in Galveston

Lesson Learned: 80% of the ballast water was RCRA hazardous waste (D008) from lead paint and required stabilization prior to disposal

Preparation of STURGIS for Decommissioning Established the shipboard infrastructure on the STURGIS

– Boarding ramps

– Safety upgrades

– Hurricane Plan

– Controlled areas/zones established within the existing superstructure

– Radiological support area/laboratory

– Power infrastructure including emergency power installed

– HVAC systems installed

– On-board crane refurbished

Lesson Learned: Shipboard infrastructure took significantly longer than planned due to complexity of installation and development of knowledge of shipboard systems

PREPARATION FOR DECOMMISSIONING

Access the RAC and RCV Access and inspect Reactor Access Compartment (RAC) and the Reactor Containment Vessel (RCV) – repeat of USACE activity of 1999.

– Determined the overall condition, material present, and to confirm radiological conditions/dose rates

– Determined dose rate from Reactor Pressure Vessel (RPV)

– Used Laser Scanners to develop Point Cloud of RAC and RCV

DECOMMISSIONING ACTIVITIES

Establish Roof Access to Refueling Room Design and install roof penetrations to remain in-place (providing containment) and be removed only for lifting operations.

The covers are weather tight and designed for severe weather conditions that can occur in the Galveston area

Remove Materials from Refueling Room All items are assumed to be impacted, and will be disposed of as radioactive waste.

Remove Spent Fuel Storage Tank The SFST was sealed in 1977 and contains an assortment of materials and equipment 27 feet tall X 8 feet diameter, ~ 55k pounds SFST was prepared, characterized, void space filled, bagged, and removed for disposal

Remove Spent Fuel Storage Tank

Remove Materials from Refueling Room Following removal of SFST Removal of remaining items in Refueling Room including Mezzanine Deck Allowed placement of IMCs

Prepare overhead Access to Reactor Containment Vessel including removal of Canopy and Torques Box

Historical photo of the canopy

Current photo of the reactor containment vessel with the canopy removed

Revised cut plan for Canopy

Securing items for lift

Lifts using the V-Bar

Prepare overhead Access to Reactor Containment Vessel Overhead Access to RCV

– Remove interferences in RCV

– Remove top of RCV to access components

Remove Large Components from RCV Large components that are in the RCV were removed to make room for RPV removal Items will include Steam Generator, Pressurizer, Coolant Pumps, Refueling Shield Tank, Ductwork, and reactor head dolly.

Items w be removed and placed directly into shipping containers

• RPV was activated and expected to have significant dose rate

• A shielded transport container was built to comply with transportation requirements. It was staged inside the RCV as shown below to allow the RPV to be placed inside the container within containment.

• Shielded shipping container and RPV were removed from STURGIS for transport on 20 May (see video)

REMOVAL OF THE REACTOR PRESSURE VESSEL (TWD 6) - COMPLETED

Title to the RPV was transferred to the Department of Energy for disposal purposes at WCS – DOE and USACE signed agreement on 5 May 2017

Removal of the RPV

RPV TRAVELING TO

WCS AND BEING

PLACED INTO FINAL

LOCATION IN

DISPOSAL CELL

• Smaller components including surge tanks, instrumentation, cabling, ventilation systems, as well as floor gratings, ladders, etc.

• Material disposed of as Low Level Waste

• Only remaining item is the Primary Shield Tank

Remove Remaining items from RCV (TWD 10) - COMPLETED

36Current Major Milestone - Removal of the Primary Shield Tank

• PST Inner wall was activated and had significant dose rate (~4 R/hr)

• Shielded transport container was fabricated and is being used for shipments

• Inner wall and ion detectors were removed first to reduce dose

• Balance of unit is being sectioned for disposal

Phase 1

Phase 2

Phase 3

Phase 1 and 2 are completed; team is on target to complete Phase 3 ahead of schedule

Upcoming Major Milestone – Remove or Decon Hull Bottom Tanks 37

Status on remaining tanks

• All ballast water removed

• 8P still drying to allow for survey

• 10 CL - First round of decontamination complete, need to resurvey to determine if additional decontamination required or if its ready for MARSAME release survey

• 12 CL - Just starting the first round of decontamination.

Initial efforts will focus on 100% decontamination of areas below water line in the tanks (~6 feet)

SIGNIFICANT LESSONS LEARNED

• Shipyard Infrastructure

• Dock load bearing pressure

• Health and Safety Requirements

• Engineering Design

• Qualified Staff – training; ramp up; ramp down

• Subcontractors/Teaming Partners

• Site Specific DCGLs

• Disposal/Disposition Method

• Cost Overruns

• Contract Administration and team oversight by Gov’t

• Contractor Team for implementation

• Collaboration between Gov’t and Contractor is a must

• Proactive and transparent communications

• Local government officials and stakeholders

SHIPYARD INFRASTRUCTURE

• Estimated one (1) month to set up the project site

• Took four months – considerable effort required to provide water, electricity, air conditioning, compressed air, HEPA systems, etc.

• Major issue with shipyard

• Dock Loading bearing capacity

• Project required a 440 ton crane for the major lifts

• Dock was not able to sustain the crane weight

• Project had to be shutdown for 6 months while the team engineered a solution to provide adequate load bearing pressure

• Ensure security and access issues are fully defined and understood by all parties

MAJOR ISSUE – Ensure the relationship with the shipyard is fully defined with the prime and/or Navy.

HEALTH AND SAFETY REQUIREMENTS

• Unique safety issues to work on a vessel including challenges from;

• Lead,

• Asbestos,

• Hexavalent Chromium,

• Ergonomic stress and injuries,

• Heat stress,

• Fatigue,

• Slips trips and falls,

• Confined space/hull bottom tank entry and

• Stress associated with personnel protective equipment

• Respiratory protection programs

• Significant training requirements

Staff of 3-4 safety personnel was a must (started with one); team coordination is critical – must be working closely with operations and engineering, plus involve subcontractor’s experts and the crew

Consistently auditing the system and ensuring adequate monitoring of all established safety programs is a must

ENGINEERING DESIGN

• Engineering costs were triple what the contractor originally anticipated

• Engineering assumption were not checked until implementation which caused significant rework and project delays

• Need to ensure all engineering drawings are accurate and/or that the assumptions made about planning an activity are validated prior to starting the work

• All engineering should not be done up front as each phase may impact the next phase and could change the engineering approach

• An field engineer should be on site in the field to provide adequate support

QUALIFIED STAFF

• Contractor’s Team

• Grossly under estimated the needed staff to support the work

• Need team members in all key disciplines

• Original management team grew from 7-10 people to almost 25

• Government Oversight

• Administrative burden for cost contract oversight is tremendous

• Need a fully resourced team to include a PM, Engineer, Safety Staff, and contracting assets

• Support Staff (Subcontractors)

• Need to fully understand the type of work

• Be prepared for staff turnover

TEAMWORK IS A MUST. DAILY INTERACTION AND COOPERATIVE TEAM APPROACHES TO ALL

WORK IS A NECESSITY.

DISPOSAL/DISPOSITION METHOD AND SITE SPECIFIC DCGLS

• Disposal/Disposition Methods

• Consider multiple tiers for disposal

• Free release for recycle

• Alternative disposal for low activity radioactive materials disposition at a RCRA facility

• LLRW

• Site Specific DCGL’s

• Ensure all media have surface and volumetric DCGL’s for each potential disposal path

• The decommissioning process could generate unexpected wastes/media

• Cutting of surface contaminated pipes could generate materials that can only be analyzed volumetrically

• Scrapping of surfaces to allow surface measurements will generate materials that can only be analyzed volumetrically

LOCAL OFFICIALS AND STAKEHOLDERS

• Early interaction with the local officials and stakeholders is key

• Provide frequent, fully transparent updates to all parties

• Except to have officials and stakeholder who express concerns about radioactive work being done

• Develop key messages early in the project

• Understand that there is a high potential that everyone will not support the decisions made

• Compliance with the local permitting was a project based decision. The team made this decision to foster relations with the local community. The Navy would need to determine how to handle issues of this sort dependent upon approach.

• All Federal and State regulations were followed.

45MH1-A STURGIS – Decommissioning Completion

• Upon completion of decommissioning activities in Galveston, the STURGIS will be radiologically released for future dismantlement

• After release, the STURGIS will be towed to Brownsville for shipbreaking at a commercial facility

• Port of Galveston, Pier 41 will be surveyed and released allowing for the ARO permit to be terminated

• Departure ceremony, media event to thank community for their support of the project

Questions?