1. 1 Innovative Use of an N-HASP at 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, S&H Director

2. 2 BACKGROUND 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

3. 3 Silos 1, 2, and 3 Area

4. 4 Categorization of the Silos 3 Treatment Facility 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

5. 5 Silos 3 Area, including Packaging Facility

6. 6 ISM Best Practices Workshop Silos 3 – Vacuuming Process

7. 7 Safe Harbor Approach 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

8. 8 Benefits of Safe Harbor Approach 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

9. 9 Silos 3 – Vacuuming Process

10. 10 N-HASP Contents 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

11. 11 N-HASP Contents 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

12. 12 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 project’s ALARA Goals.

13. 13 Silos 3 Project Results ISM Best Practices Workshop 8148D-118

14. 14 Video clip of Silos 3 Vacuuming and Packaging Operations ISM Best Practices Workshop