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Letter Dated March 23, 2017 from the U.S. Department of Energy West Valley Demonstration Project (DOE-WVDP) Wvdp Main Processing Plan Decommissioning & Demolition Plan, WVDP-586, and Incoming Email
	ML17090A299
Person / Time
Site:	West Valley Demonstration Project
Issue date:	03/23/2017
From:	Bower B C; US Dept of Energy, West Valley Demonstration Project
To:	Meyer M R; NRC/NMSS/DDUWP/MDB
	A. Snyder NMSS/DUWP/MDB 415-6822 T-8E45
References
	Download: ML17090A299 (97)
	v • d • e

West Valley Demonstration Project Doc. ID Number WVDP-586 Revision Number 1 Revision Date 02/27/17 Cognizant Author: Robert Steiner Cognizant Manager: Tom Dogal CH2M HILL BWXT West Valley, LLC 10282 Rock Springs Road West Valley, New York USA 14171-9799 WV-1816, Rev. 8 WVDP-586 Rev. 1 Page 2 of 94 TABLE OF CONTENTS Acronyms ......................................................................................................................................................... 5

1.0INTRODUCTION

............................................................................................................................................. 71.1Background ......................................................................................................................................... 71.2Purpose ............................................................................................................................................... 91.3Scope .................................................................................................................................................. 9 2.0FACILITY DESCRIPTION ............................................................................................................................. 102.1Facility Design................................................................................................................................... 102.2Facility Use ....................................................................................................................................... 11 3.0CHARACTERIZATION SUMMARY ............................................................................................................... 143.1Radiological Characterization ........................................................................................................... 143.2Hazardous and Other Materials ........................................................................................................ 17 4.0MANAGEMENT APPROACH ........................................................................................................................ 184.1WVDP Work Planning and Implementation ...................................................................................... 18 5.0PRE-DEMOLITION ACTIVITIES ................................................................................................................... 195.1Deactivation Activities Completed .................................................................................................... 195.2Deactivation Activities Remaining..................................................................................................... 215.3Dispositioning "Stand-Alone" Items .................................................................................................. 235.4Structural Analysis ............................................................................................................................ 245.5Demolition Readiness Checklist ....................................................................................................... 245.6Preparation of Work Documents....................................................................................................... 25 6.0MAIN PLANT PROCESS BUILDING DEMOLITION ..................................................................................... 266.1General Decommissioning Approach and Technologies ................................................................. 276.2Equipment to be Utilized and Available ............................................................................................ 296.3Demolition Approach and Sequence ................................................................................................ 306.4Radiation Protection and Radiological Controls ............................................................................... 556.5Access Control and Security ............................................................................................................. 61 7.0WASTE MANAGEMENT ............................................................................................................................... 627.1Waste Identification and Characterization ........................................................................................ 637.2Waste Minimization and Mitigation Strategies .................................................................................. 637.3Disposal Pathways ........................................................................................................................... 637.4Packaging, Transportation and Disposal .......................................................................................... 647.5Summary of Estimated Waste Quantities ......................................................................................... 657.6Record Keeping and Disposal Records ............................................................................................ 65 8.0SCHEDULE ................................................................................................................................................... 65 9.0REFERENCES .............................................................................................................................................. 66 WVDP-586 Rev. 1 Page 3 of 94 TABLE OF CONTENTS (continued) Tables Table 1 Historical Measured Maximum Gamma Radiation Levels in Process Building Areas ..................... 14 Table 2 Radioactivity Levels Based on Survey Results for Several Areas of the Main Plant Process Building ............................................................................................................. 15 Table 3 Residual Radioactivity Levels Prior to Demolition Process Sample Cell - 2 and Extraction Cell-2 . 16 Table 4 Estimated Low-Level Waste Quantities from MPPB Demolition ...................................................... 65 Figures Figure 1 Photograph of Main Plant Process Building ..................................................................................... 12 Figure 2 Main Plant Process Building Isometric View..................................................................................... 13 Figure 3 Main Plant Process Building Prior to Demolition .............................................................................. 31 Figure 4 Head End Ventilation Overview ........................................................................................................ 32 Figure 4A Head End Ventilation Zoomed In ...................................................................................................... 32 Figure 5 Main Stack Overview ........................................................................................................................ 33 Figure 5A Upper Portion of Main Stack ............................................................................................................. 33 Figure 6 Extraction Chemical Room Overview ............................................................................................... 35 Figure 6A Extraction Chemical Room Zoomed In ............................................................................................. 35 Figure 7 Process Chemical Room Overview .................................................................................................. 36 Figure 7A Process Chemical Room Zoomed In ................................................................................................ 36 Figure 8 Upper and Lower Warm Aisles ......................................................................................................... 37 Figure 8A Upper and Lower Warm Aisles Zoomed In ....................................................................................... 37 Figure 9 Uranium Load Out & Product Packaging & Handling Area Overview .............................................. 38 Figure 9A Uranium Load Out & Product Packaging & Handling Area Zoomed In ............................................ 38 Figure 10 Process Mechanical Cell Crane Room Extension & Door Hoist Enclosure Overview ..................... 39 Figure 10A Process Mechanical Cell Crane Room Extension & Door Hoist Enclosure Zoomed In ................... 39 Figure 11 Upper and Lower Extraction Aisle Overview .................................................................................... 40 Figure 11A Upper and Lower Extraction Aisle Zoomed In .................................................................................. 40 Figure 12 Equipment Decontamination Room & Chemical Crane Room Overview ......................................... 41 Figure 12A Equipment Decontamination Room & Chemical Crane Room Zoomed In ....................................... 41 Figure 13 Process Mechanical Cell Crane Room & Scrap Removal Room Overview ..................................... 42 Figure 13A Process Mechanical Cell Crane Room & Scrap Removal Room Zoomed In ................................... 42 Figure 14 Ventilation Exhaust Cell, Ventilation Wash Room, and Ventilation Supply Room Overview ........... 43 Figure 14A Ventilation Exhaust Cell, Ventilation Wash Room, and Ventilation Supply Room Zoomed In ......... 43 Figure 15 Uranium Product Cell Overview ........................................................................................................ 44 Figure 15A Uranium Product Cell Zoomed In ..................................................................................................... 44 WVDP-586 Rev. 1 Page 4 of 94 TABLE OF CONTENTS (concluded)

Figure 16 Hot Cells Overview ........................................................................................................................... 45 Figure 16A Hot Cells Zoomed In ......................................................................................................................... 45 Figure 17 Liquid Waste Cell Overview .............................................................................................................. 46 Figure 17A Liquid Waste Cell Zoomed In ............................................................................................................ 46 Figure 18 Off-Gas Operating Aisle and Acid Recovery Cell West Wall (including South Stairs) Overview ..... 47 Figure 18A Off-Gas Operating Aisle and Acid Recovery Cell West Wall (including South Stairs) Zoomed In ... 47 Figure 19 Acid Recovery Cell Floor and Cell Overview .................................................................................... 48 Figure 19A Acid Recovery Cell Floor and Cell Zoomed In .................................................................................. 48 Figure 20 Off Gas Blower Room & Acid Recovery Pump Room Overview ...................................................... 49 Figure 20A Off Gas Blower Room & Acid Recovery Pump Room Zoomed In .................................................... 49 Figure 21 Off Gas Cell Overview ...................................................................................................................... 50 Figure 21A Off Gas Cell Zoomed In .................................................................................................................... 50 Figure 22 Process Mechanical Cell Overview .................................................................................................. 51 Figure 22A Process Mechanical Cell Zoomed In ................................................................................................ 51 Figure 23 Chemical Process Cell Overview ...................................................................................................... 52 Figure 23A Chemical Process Cell Zoomed In ................................................................................................... 52 Figure 24 Extraction Cells and Product Purification Cell Overview .................................................................. 53 Figure 24A Extraction Cells and Product Purification Cell Zoomed In ................................................................ 53 Figure 25 End of Demolition Cross Section View Looking East ....................................................................... 54 Figure 26 Ambient Air Monitoring Locations ..................................................................................................... 59 Figure 27 Boundaries During MPPB Demolition ............................................................................................... 62 Attachments Attachment A Main Plant Process Building/Vitrification Facility View North to South Through Chemical Process Cell, Looking Southeast ....................................................................... 70 Attachment B WVDP Demolition Readiness Checklist Form .................................................................................. 71 Attachment C Activity Hazards Analysis .................................................................................................................. 78 Attachment D Typical Types of Demolition Equipment ........................................................................................... 87 Attachment E Main Plant Process Building Demolition Schedule ........................................................................... 93 WVDP-586 Rev. 1 Page 5 of 94 Acronyms ACM Asbestos-Containing Materials AERMOD American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee's Dispersion Model ALARA As Low As Reasonably Achievable ANSI American National Standards Institute A&PC Analytical & Process Chemistry ARC Acid Recovery Cell ARPR Acid Recovery Pump Room BSFR Bulk Survey for Release CAM Continuous Air Monitor CAP88 Clean Air Act Assessment Package - 1988 CCR Chemical Crane Room CFR Code of Federal Regulations CHBWV CH2M HILL BWXT West Valley, LLC CPC Chemical Process Cell CSBD Cut, Shear, Break, Drop D&D Decommissioning & Demolition DAC Derived Air Concentration DOD U.S. Department of Defense DOE U.S. Department of Energy DOT U.S. Department of Transportation DP Decommissioning Plan DR Damage Ratio DSA Documented Safety Analysis EDR Equipment Decontamination Room EIS Environmental Impact Statement EPA U.S. Environmental Protection Agency FRS Fuel Receiving and Storage GCR General Purpose Cell Crane Room GCRE General Purpose Cell Crane Room Enclosure GCRX General Purpose Cell Crane Room Extension GOA General Purpose Cell Operating Aisle GPC General Purpose Cell HAC Hot Acid Cell HEV Head End Ventilation HEPA High-Efficiency Particulate Air HWMU Hazardous Waste Management Unit HVAC Heating Ventilation and Air Conditioning IM Intermodal ISMS Integrated Safety Management System IWCP Integrated Work Control Program IWP Industrial Work Permit IWTS Integrated Waste Tracking System LLW Low-Level Waste LWA Lower Warm Aisle LWC Liquid Waste Cell LXA Lower Extraction Aisle LWTS Liquid Waste Treatment System MAR Material at Risk MEOSI Maximally Exposed Off-Site Individual MLLW Mixed Low-Level Waste MOA Mechanical Operating Aisle MPPB Main Plant Process Building NESHAP National Emission Standards for Hazardous Air Pollutants NNSS Nevada National Security Site WVDP-586 Rev. 1 Page 6 of 94 NRC U.S. Nuclear Regulatory Commission NYCRR New York State Official Compilation of Codes, Rules, and Regulations NYSDEC New York State Department of Environmental Conservation NYSDOL New York State Department of Labor OGA Off-Gas Aisle OGBR Off-Gas Blower Room OGC Off-Gas Cell OSHA Occupational Safety and Health Administration PAR Power Manipulator PCR Process Chemical Room PCB Polychlorinated Biphenyl PMC Process Mechanical Cell PMCR Process Mechanical Cell Crane Room PMCRE Process Mechanical Cell Crane Room Extension PPC Product Purification Cell PPH Product Packaging and Handling rad-NESHAP National Emission Standards for Hazardous Air Pollutants (for Radionuclides) RCRA Resource Conservation and Recovery Act RER Ram Equipment Room RM Responsible Manager RPP Radiation Protection Program RWP Radiological Work Permit SOP Standard Operating Procedure SPDES State Pollutant Discharge Elimination System SPRU Separations Process Research Unit SRR Scrap Removal Room SST Solvent Storage Terrace STR Subcontractor Technical Representative TRU Transuranic ULO Uranium Load Out UPC Uranium Product Cell UWA Upper Warm Aisle UXA Upper Extraction Aisle VEC Ventilation Exhaust Cell VF Vitrification Facility VSR Ventilation Supply Room VWR Ventilation Wash Room WAC Waste Acceptance Criteria WCS Waste Control Specialists WIP Work Instruction Package WNYNSC Western New York Nuclear Service Center WRPA Waste Reduction and Packaging Area WVDP West Valley Demonstration Project XC Extraction Cell XCR Extraction Chemical Room WVDP-586 Rev. 1 Page 7 of 94

1.0 INTRODUCTION

1.1 Background In December 2009 the U.S. Department of Energy (DOE) submitted Revision 2 of the Phase 1 Decommissioning Plan (DP) for the West Valley Demonstration Project (WVDP) to the U.S. Nuclear Regulatory Commission (NRC). The DOE prepared the DP pursuant to its statutory obligations under the WVDP Act of 1980, Public Law 96-368, and to satisfy a commitment in the 1981 Memorandum of Understanding between DOE and NRC. The proposed action in the Phase 1 DP is based on the preferred alternative (Phased Decisionmaking) in the Final Environmental Impact Statement for Decommissioning and/or Long-Term Stewardship at the West Valley Demonstration Project and Western New York Nuclear Service Center (EIS). Under the preferred alternative, decommissioning will be accomplished in two phases. Phase 1 decommissioning actions include removal of certain WVDP facilities including the Main Plant Process Building (MPPB) and the Vitrification Facility (VF). The Phase 2 decision involves decommissioning or long-term management decisions for those facilities remaining at the WVDP and Western New York Nuclear Service Center (WNYNSC) following Phase 1 decommissioning.

Under the WVDP Act, the NRC's responsibilities include prescribing requirements for decontamination and decommissioning of project facilities, providing informal review and consultation to DOE on activities related to the project, and monitoring project activities for the purpose of assuring public health and safety.

The organization and content of the Phase 1 DP prepared by DOE were based on NRC guidance in Volume 1 of NUREG-1757, Consolidated Decommissioning Guidance, Decommissioning Process for Materials Licensees and agreements made between NRC and DOE on the applicability of this guidance to the DP during a May 2008 meeting. Prior to DOE developing the Phase 1 DP, NRC agreed that certain DOE regulations, orders, and technical standards are adequate to define, control, and establish safe work activities at the site, and that DOE did not need to provide these details in the Phase 1 DP. In this respect, NRC considered areas such as project management and organization, the health and safety program, the environmental monitoring and control program, and the radioactive waste management program adequate under DOE's responsibility and authority.

The DP contains a general overview of Phase 1 decommissioning activities including a summary of remediation and demolition technologies. In the Phase 1 DP, DOE generally avoided being prescriptive in methods to be used to give the decommissioning contractor(s) flexibility. The DP stated that it would be supplemented by more detailed work plans for demolition of major facilities such as the MPPB and VF.

In June 2011, DOE awarded the Phase 1 Decommissioning and Facility Disposition Contract to CH2M HILL BWXT West Valley, LLC (CHBWV). Under this current contract, CHBWV, and its subcontractors, will deactivate and prepare the VF and MPPB for demolition, demolish the buildings to grade level (i.e., nominal 100 +/-3 ft, plant reference elevation), and stabilize the remaining at-grade and below grade structures.

In 2012 the WVDP established an ambient air monitoring network and sampling program providing continuous environmental air sampling during all site activities for surveillance and regulatory compliance. Sixteen air monitoring stations encircling the WVDP are located near the closest off-WVDP-586 Rev. 1 Page 8 of 94 site receptor in each compass sector and one background location located about 18 miles from the site. In 2015, the U.S. Environmental Protection Agency (EPA) approved the use of "ambient environmental measurements" pursuant to 40 Code of Federal Regulations (CFR) 61.93(b)(5) for estimating off-site dose from airborne emissions and to demonstrate compliance with 40 CFR 61, Subpart H. As the predominant source of WVDP air emissions transitions from point sources (e.g., MPPB stack) to diffuse sources (i.e., releases from building demolition), the use of ambient air monitoring samplers becomes a more appropriate method of demonstrating compliance with radiological National Emission Standards for Hazardous Air Pollutants for radionuclides (rad-NESHAP) requirements.

In January 2016, the WVDP submitted to EPA a request for approval for alternative methodology, pursuant to 40 CFR Part 61.96(b), for radionuclide source-term calculations for air emissions from WVDP demolition activities. The WVDP believes the proposed alternative calculation is more appropriate for the estimation of radionuclide emissions from demolition activities, as demolition activities were not considered when the regulations (Appendix D to 40 CFR Part 61) were originally promulgated. The EPA approved the use of the alternative methodology to support VF demolition on May 3, 2016, with conditions to be implemented during demolition activities. The WVDP will continue to coordinate with EPA and perform calculations to support WVDP facility demolitions in accordance with rad-NESHAP requirements.

Within the MPPB are several areas/systems that are identified as Resource Conservation and Recovery Act (RCRA) Interim Status Hazardous Waste Management Units (HWMUs) with closure of these units to be performed in accordance with RCRA closure plans. The following are the RCRA Interim Status Units within the MPPB and the associated RCRA Closure Plans:

Analytical and Process Chemistry (A&PC) Hot Cells - WVDP-447, Resource Conservation and Recovery Act Hazardous Waste Closure Plan Analytical and Process Chemistry Hot Cells; submitted to the New York State Department of Environmental Conservation (NYSDEC) in December 2014;

High-Level Waste Interim Storage Facility (HLWISF) - WVDP-448, Resource Conservation and Recovery Act Hazardous Waste Closure Plan for the High-Level Waste Interim Storage Facility; submitted to the NYSDEC in February 2016; and

Liquid Waste Treatment System (LWTS) - WVDP-154, Resource Conservation and Recovery Act Hazardous Waste Closure Plan for the Liquid Waste Treatment System; submitted to the NYSDEC in April 2016.

The RCRA closure plans were prepared to meet the requirements of the State and Federal hazardous waste regulations, specifically Title 6 of the New York State Official Compilation of Codes, Rules, and Regulations (6 NYCRR) §373-3 and 40 CFR 265, Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities. Closure certification and required documentation will be prepared at completion of closure activities for each HWMU and submitted to NYSDEC.

The Main Plant Process Building (MPPB) was evaluated in 1993 as part of the RCRA 3008(h) Administrative Order on Consent (Order). Under the Order, several cells referred to as "Sealed Rooms" were evaluated for releases or potential releases of hazardous constituents. Based on historical knowledge, limited testing, and MPPB operations, the Sealed Rooms were specifically identified as either inaccessible or their access was restricted due to very high radiation levels; therefore, they could not be initially characterized pursuant to RCRA. Due to high radiation levels WVDP-586 Rev. 1 Page 9 of 94 and As Low As Reasonably Achievable (ALARA) concerns, the RCRA Facility Investigation (RFI) work plan directed that a paper investigation be conducted of the Sealed Rooms. This paper characterization was a historical review of existing documentation to assess potential pathways and determine whether hazardous waste or hazardous waste constituents were contained in the rooms. The Sealed Rooms Paper Characterization report, issued in June 1994, concluded that there were no known RCRA-listed wastes present inside the rooms; that some rooms and vessels may contain RCRA characteristic wastes; and that the evaluation did not identify a release of hazardous waste or hazardous constituents to the environment. In subsequent correspondence from NYSDEC to DOE, NYSDEC indicated that "the only further action necessary at this time for the Sealed Rooms is continued groundwater monitoring required pursuant to the West Valley Demonstration Project Groundwater Monitoring Plan." In addition to ongoing groundwater monitoring, the WVDP agreed to provide NYSDEC with updates on RCRA mixed waste generation from decontamination activities in the MPPB which are included in the Quarterly Progress Reports prepared in accordance with the Order. The WVDP also agreed that observations regarding conditions in the Sealed Rooms would be collected during facility deactivation. 1.2 Purpose The purpose of this Decommissioning and Demolition (D&D) plan is to provide information on the tasks and approaches for deactivating (i.e., prepare for demolition), decommissioning, and demolishing the MPPB. The WVDP Phase 1 DP presented a general summary of remediation and demolition technologies with more detailed information to be included in decommissioning work plans such as this. The types of information to be provided were summarized in the Phase 1 DP checklist, based on NUREG-1757, Volume 1, Appendix D. 1.3 Scope This D&D Plan provides a summary of tasks and techniques to decommission and demolish the MPPB structure, systems, and components and stabilize the grade-level and below grade-level portions of the structure. These activities will be performed by CHWBV and its subcontractor(s), according to the terms and scope of the Phase 1 Decommissioning and Facility Disposition Contract between CHBWV and DOE.

As noted above, the WVDP Phase 1 DP indicated that it would be supplemented with more detailed plans for demolition of major facilities such as the MPPB and VF. Consistent with NUREG-1757, the Phase 1 DP checklist summarizes the types of additional information to be provided which include: (plan sections providing the information are shown in parentheses)

a summary of the deactivation and demolition tasks and the order in which they occur and a description of remediation techniques for contaminated structures, systems, and equipment (Sections 5.0 and 6.0);

a summary of equipment being removed or decontaminated and decontamination approach(es) (Sections 5.0 and 6.0);

commitment to conduct decommissioning activities in accordance with written, approved procedures (Sections 4.1 and 5.6); and

a summary of unique safety or remediation issues associated with the facility and systems (Sections 5.2-5.4 and 6.0).

WVDP-586 Rev. 1 Page 10 of 94 In addition to these primary topics, this D&D Plan presents a description of the MPPB, summary of characterization information and an overview of the management approach. Also included is information regarding work planning and work controls, radiological control measures, and waste management activities that are integrated by CHBWV to safely and compliantly demolish the MPPB.

This document is not intended as a comprehensive procedure for implementing MPPB D&D. This D&D Plan will be supplemented by specific Work Instruction Packages (WIP's) and CHBWV work procedures, Industrial Work Permits (IWPs), Radiological Work Permits (RWPs), and waste management and environmental monitoring procedures, as applicable. The WVDP work control process is described in more detail in Sections 4.1 and 5.6.

The specific D&D approaches, techniques, work sequencing and schedule are based on currently available information and planning and lessons learned from demolition of the 01-14 Building. Demolition of the 01-14 Building was conducted first as a proof of concept for safe and compliant open air demolition of a radiological building. Demolition of the Vitrification Facility will follow, and lessons learned from those activities will be incorporated into the planning for MPPB demolition.

As the final steps are taken and equipment is removed to prepare the MPPB for demolition and facility demolition begins, it may become necessary to make adjustments to the approaches or sequencing outlined in this plan. Such potential adjustments will be documented through the work control process and associated documents. 2.0 FACILITY DESCRIPTION The MPPB was built between 1963 and 1966. This multi-storied structure is approximately 130 feet wide, 270 feet long, and extends approximately 79 feet above the ground surface at its highest point. The stack structure is about 160 feet tall, varying four to ten feet in diameter, and composed of Type 304L stainless steel and Gunite. Figures 1 and 2 illustrate the general layout of the building. The figures also show some adjacent structures that are not part of the MPPB demolition described in this plan.

2.1 Facility Design The major MPPB structure is supported by approximately 480 driven steel H-piles which extend to depths ranging from approximately 60 to 70 feet below the ground surface. The building is composed of a series of cells, aisles, and rooms that are constructed of reinforced concrete and concrete block. The reinforced concrete walls, floors and ceilings range from one to six feet thick. The reinforced concrete walls are typically surrounded by walls of lighter concrete and masonry construction and metal deck flooring.

Most of the facility was constructed above grade. However, a few of the cells extend below the ground surface (i.e., nominal 100 +/-3 ft, plant reference elevation). The deepest one, the General Purpose Cell, extends approximately 27 feet below the ground surface. The Cask Unloading Pool and the Fuel Storage Pool, located in the Fuel Receiving and Storage Area on the east side of the building, were used to receive and store spent fuel sent for reprocessing, and extend approximately 49 and 34 feet below the ground surface, respectively. These structures will not be removed during MPPB demolition.

WVDP-586 Rev. 1 Page 11 of 94 Cells such as the Process Mechanical Cell, the Chemical Process Cell, and the extraction cells were constructed of reinforced, high-density concrete three to five feet thick and frequently lined with stainless steel. Such thicknesses were needed to provide radiation shielding.

The operations performed in the cells were remotely controlled by individuals working in the various aisles of the MPPB, which were formed by adjacent walls of the cells. The aisles contained the manipulators and valves needed to support operations in the cells. Rooms not expected to contain radioactivity during operations - such as the Control Room, Ventilation Supply Room, and Extraction Chemical Room - were typically constructed with concrete block and structural-steel framing.

2.2 Facility Use The MPPB was used from 1966 to 1972 to recover uranium, plutonium, and thorium from irradiated nuclear fuel. Reprocessing involved a "chop-leach" method. The spent nuclear fuel assemblies were mechanically sheared and the sheared fuel was dissolved in concentrated nitric acid. The dissolved fuel was an aqueous stream containing uranium nitrate, plutonium nitrate, and fission products. A five-stage solvent extraction process using a tributyl phosphate/n-dodecane solution separated the fission products from the uranium and plutonium and then separated the uranium from the plutonium. Aqueous uranium nitrate and plutonium nitrate were the final products of the reprocessing cycle. Nuclear fuel was reprocessed until early 1972, when the process building was shut down for modification and expansion purposes, but fuel reprocessing was never resumed.

The mechanical process cells contained the equipment for trimming, chopping, and general handling of the spent fuel assemblies before and after chemical dissolution of the fuel material. The area was divided into several cells: the process mechanical cell (PMC), the general purpose cell (GPC), and the scrap removal room (SRR). Maintenance, repair, and decontamination of the cranes and manipulators were in a mechanical crane room (MCR), a manipulator repair room (MRR), and a GPC crane room (GCR).

WVDP-586 Rev. 1 Page 12 of 94 Figure 1, Photograph of Main Plant Process Building Equipment for dissolution of the spent fuel, separation and purification of the uranium and plutonium, cleanup of used solvent, and concentration of the liquid wastes was housed in several process cells: the chemical process cell (CPC), three solvent extraction cells (XC-1, XC-2, and XC-3), the product purification cell (PPC), and the Acid Recovery Cell (ARC).

The WVDP modified portions of the MPPB to support its primary mission of solidifying High-Level Waste (HLW). Fuel reprocessing equipment was removed from the CPC to allow it to be used for storage of canisters of vitrified HLW. Original equipment in XC-3 and the PPC was removed and was replaced with equipment used to support the Liquid Waste Treatment System (LWTS). The LWTS was used to manage supernatant and sludge wash solutions from Tank 8D-2 that were treated in the Supernatant Treatment System, and to treat waste water generated during the vitrification process. General area of MPPB demolition WVDP-586 Rev. 1 Page 13 of 94

Figure 2, Main Plant Process Building Isometric View

Not part of MPPB demolition Separate demolition under Facilities Disposition contract Not part of MPPB demolition General Area of MPPB Demolition WVDP-586 Rev. 1 Page 14 of 94 3.0 CHARACTERIZATION SUMMARY Characterization is an ongoing process with the obtained information used to guide the deactivation activities in preparation for demolition, including work planning and worker protection, and to support waste management and disposition. Characterization data will be utilized to help determine the engineering controls, work sequencing, personal protective equipment, demolition techniques and equipment needed to execute deactivation and demolition activities. Ultimately, characterization data will be used to ensure that the appropriate decontamination levels are achieved for safe and compliant open air demolition, taking into account demolition approaches and engineering controls and site specific environmental conditions. 3.1 Radiological Characterization The December 2009 revision of the DP presented the amount of residual radioactivity estimated to be present in the MPPB at the beginning of WVDP Phase 1 decommissioning activities in 2011.

The estimated total was approximately 6,100 curies (Ci) with the largest contributions from cesium-137 (Cs-137), strontium-90 (Sr-90), and plutonium-241 (Pu-241). The total estimate included 260 Ci of americium-241 (Am-241) and 310 Ci of alpha plutonium (Pu-238, 239, 240). This estimate does not include the HLW canisters stored in the CPC. Areas estimated to have the largest contributions to this total were the GPC, PMC, and LWC. The information on radiation levels presented in Table 1 was originally included in the DP, and is included here to provide perspective on the challenges faced with preparing the MPPB for demolition. Table 1 Historical Measured Maximum Gamma Radiation Levels in Process Building Areas Area mR/h Remarks Chemical Process Cell 15,000 At south sump in 1994 Equipment Decontamination Room 50 On floor in 1997General Purpose Cell 200,000 3 feet above floor32,000 9 feet above floorHead-End Ventilation Cell 50,000 On pre-filters in 2002 Liquid Waste Cell 1,800 In 2002 Miniature Cell 80 In 1998 Off-Gas Blower Room 700 In 2003 Process Mechanical Cell 40,000 In 2004, 3 feet above floorProduct Purification Cell 53 Hot spot on wall in 2003 Sample Storage Cell 1,950 On floor in 2001 Ventilation Wash Room 1,500 On ventilation duct WVDP-586 Rev. 1 Page 15 of 94 The guiding WVDP document for hazard characterization for demolitions is WVDP-446, Facility Demolition Hazard Characterization Planning. Samples to assess surface contamination levels and radiation dose surveys are performed in accordance with WVDP-477, CHBWV Documented Radiation Protection Program and Implementation for Title 10, Code of Federal Regulations, Part 835, as Amended May 2011. Characterization efforts will quantify residual contamination and radiological activity that is present, focusing on Cs-137, Sr-90, Pu-239/240, and Am-241, although not excluding other isotopes that may be present in measurable quantities. Table 2 shows an example of radioactivity levels for several areas based on the characterization data. Data collected are utilized for dose modeling to support demolition sequencing and limits (i.e., maximum number of square feet in a given area that can be removed or demolished in a given time period). Characterization data will also be used to model potential dose to onsite workers (i.e., using AERMOD, air dispersion modeling system) and the public (i.e. the maximally exposed off-site individual [MEOSI] using CAP88 dose modeling software). Table 2 Radioactivity Levels Based on Survey Results for Several Areas of the Main Plant Process Building Extraction Cell - 2 (dpm/100cm2) Off-Gas Aisle (dpm/100cm2) Extraction Chemical Room (dpm/100cm2) Liquid Waste Cell (dpm/100cm2) Total Alpha 1.48E+05 6.75E+03 9.14E+03 1.15E+06 Total Beta 3.18E+05 1.00E+05 1.22E+05 1.57E+07 Total 4.66E+05 1.07E+05 1.31E+05 1.69E+07 Equipment removal and decontamination activities have removed and will continue to remove a significant quantity of radioactivity from the MPPB. Also, grout will be placed in below-grade portions of the MPPB and on the 100 foot plant elevation floor (i.e., ground level) prior to demolition, as necessary to reduce the radiological dose to workers and provide a protective barrier during demolition. Additional material such as gravel may also be used to protect the underlying surfaces. Information on residual radioactivity levels of these surfaces will be collected prior to grouting, but this radioactivity is not included in the dose modeling to support open air demolition since the surfaces will not be disturbed during this demolition.

Radioactivity levels will continue to be reduced as decontamination and deactivation activities continue to be performed in the various areas of the MPPB ahead of the planned start of demolition activities in 2019. Radiological surveys and samples continue to be collected to characterize and make a determination that each area is ready for demolition. Table 3 shows the radioactivity levels in two of the areas of the MPPB (Process Sample Cell-2 and Extraction Cell-2) where data have been collected and the determination made that the areas are ready for demolition. This is an example of the data that will be collected for the various areas of the MPPB and used to determine that the overall building is ready for demolition with the implementation of appropriate radiological controls. Calculations using AERMOD and the radioactivity levels for a given area are performed to show that the remaining activity levels are below the maximum that can be left behind to comply with worker dose limits.

The total Material at Risk (MAR), based on the area of each cell, will be used in the alternative calculation method approved by EPA for estimating emissions from the demolition activities as it relates to estimating dose to the public and compliance with 40 CFR 61 Subpart H. Public dose estimates are performed using the computer dispersion code CAP88 WVDP-586 Rev. 1 Page 16 of 94 Table 3 Residual Radioactivity Levels Prior to Demolition Process Sample Cell-2 and Extraction Cell-2 Process Sample Cell-2 (PSC-2) Isotope Scaling Factor by Activity (2017) Radioactivity (dpm/100cm2) Area of Cell (ft2)* Total Material at Risk (Curies) Cs-137 1 6.37E+03 752 2.23E-04 Cm-243 4.94E-05 3.15E-01 752 1.10E-08 Cm-244 1.24E-03 7.90E+00 752 2.77E-07 Np-237 2.94E-05 1.87E-01 752 6.56E-09 Sr/Y-90 3.67E-01 2.34E+03 752 8.18E-05 Am-241 5.25E-02 3.34E+02 752 1.17E-05 Pu-238 1.60E-02 1.02E+02 752 3.57E-06 Pu-239 1.20E-02 7.64E+01 752 2.68E-06 Pu-240 9.05E-03 5.76E+01 752 2.02E-06 Pu-241 1.58E-01 1.01E+03 752 3.52E-05 U-232 1.05E-02 6.69E+01 752 2.34E-06 U-233 8.24E-04 5.25E+00 752 1.84E-07 U-234 3.84E-04 2.45E+00 752 8.56E-08 U-235 1.79E-05 1.14E-01 752 3.99E-09 U-238 2.58E-04 1.64E+00 752 5.75E-08 TOTAL 1.04E+04 TOTAL 3.63E-04 Total 8.71E+03** Total 3.40E-04 Total 6.55E+02 Total 2.29E-05 Extraction Cell-2 (XC-2) Isotope Scaling Factor by Activity (2017) Radioactivity (dpm/100cm2) Area of Cell (ft2)* Total Material at Risk (Curies) Cs-137 1 2.36E+04 5,195.25 5.13E-04 Cm-243 6.10E-05 1.44E+00 5,195.25 3.13E-08 Cm-244 1.31E-03 3.09E+01 5,195.25 6.72E-07 Np-237 1.42E-05 3.35E-01 5,195.25 7.28E-09 Sr/Y-90 1.66E+00 3.92E+04 5,195.25 8.51E-04 Am-241 3.61E+00 8.52E+04 5,195.25 1.85E-03 Pu-238 1.23E+00 2.90E+04 5,195.25 6.31E-04 Pu-239 8.04E-01 1.90E+04 5,195.25 4.12E-04 Pu-240 6.13E-01 1.45E+04 5,195.25 3.14E-04 Pu-241 1.08E+01 2.55E+05 5,195.25 5.54E-03 U-232 5.74E-04 1.35E+01 5,195.25 2.94E-07 U-233 6.30E-03 1.49E+02 5,195.25 3.23E-06 U-234 3.05E-03 7.20E+01 5,195.25 1.56E-06 U-235 4.61E-03 1.09E+02 5,195.25 2.36E-06 U-238 1.20E-03 2.83E+01 5,195.25 6.16E-07 TOTAL 4.66E+05 TOTAL 1.01E-02 Total 6.28E+04** Total 6.90E-03 Total 1.48E+05 Total 3.22E-03 * - Area of cell for PSC-2 includes the floor. Area of cell for XC-2 does not include the floor since it will be protected and not removed. ** - Not including Pu-241 which is not detected with field instrumentation WVDP-586 Rev. 1 Page 17 of 94 Radiological surveys will continue to be performed and documented in support of pre-demolition and demolition activities. Radiation and radiological contamination surveys are performed in accordance with WVDP radiological control procedure RC-RPO-104, Performing Radiation and Contamination Surveys. This procedure contains general guidelines for performing pre-demolition radiological surveys where the collected data is used for demolition calculations using air dispersion modeling. The source term calculations based on the collected data will be part of the final calculation package(s) that will be prepared to document that it is safe for demolition to proceed. All of the inventory present will be assigned to the MAR and the "Damage Ratio" (DR) in the calculations will be used to account for inventory that is impacted. 3.2 Hazardous and Other Materials As mentioned in Section 1.1, The MPPB contains three RCRA HWMUs which have been used to treat and/or manage mixed waste (i.e., a solid waste that contains a hazardous waste component that is subject to RCRA and a radioactive component subject to the Atomic Energy Act). The HWMUs in the MPPB include the A&PC Hot Cells, HLWISF, and the LWTS. Wastes managed in these units were characteristically hazardous due to the presence of various metals and some were corrosive (12.5<pH<2.0). Some of the process equipment and residual materials removed from these areas during deactivation activities were also characterized as mixed wastes in accordance with the WVDP waste management program. Any spills that might have occurred in these areas during NFS or WVDP operations would have been contained by the cells' secondary containment systems (e.g., stainless-steel floor liners and sumps), then collected and transferred back into the WVDP treatment system. There have been no uncontained spills or releases to the environment resulting from waste storage operations at these HWMUs. As mentioned above, the floor surface will be covered with grout to provide a protective barrier during the upcoming phase of building demolition, with no current plan for further RCRA characterization of the floors.

As part of deactivation in preparation for demolition, potential hazardous materials are being identified and plans developed to remove the materials either prior to or during demolition. Materials being removed prior to demolition include lead counterweights and shielding not integral with the MPPB structure, electrical lamps, ballasts and switches, petroleum based oils from cranes, and zinc bromide and mineral oils from shield windows. Lighting ballasts that may contain polychlorinated biphenyls (PCBs) will be removed and paints historically applied in the MPPB are being characterized to determine if they contain PCBs. Any material packaged as mixed or hazardous wastes will be removed from the MPPB prior to demolition. Evaluation for the presence of remaining asbestos containing materials (ACM) is underway. A pre-demolition ACM survey will be performed and any additional ACM will be documented and dispositioned in accordance with New York State Department of Labor (NYSDOL) requirements.

In some instances the locations or types of hazardous materials cannot be removed before demolition. In these instances, the work documents will include steps to identify/mark, remove, and segregate the hazardous materials during the demolition operations. Examples may include leaded glass shield windows, lead materials in the shield window frames, lead in shield doors and shield plugs, and ACM on piping embedded in walls and in roof materials.

WVDP-586 Rev. 1 Page 18 of 94

4.0 MANAGEMENT APPROACH Using the guiding principles of the Integrated Safety Management System (ISMS), all work will be completed under the Integrated Work Control Program (IWCP). ISMS is built directly into the entire D&D planning and working phases through a team concept with continuous improvement including worker feedback and management self-assessments. The IWCP implements the ISMS core functions and guiding principles for planning the work at the activity level by: defining the scope of work; identifying, analyzing, and controlling associated hazards; performing the work safely within controls; and conducting a feedback and improvement process. Essential to the successful utilization of the IWCP and strongly supported by CHBWV management is worker input. Augmenting this work planning approach is a step back/stop work policy that is in effect whenever workers or support personnel are uncertain or concerned about an activity, thus ensuring workers and line management's total control of the work evolution. The Work Control process for identifying, planning, scheduling, authorizing, performance, and closeout of work activities at the WVDP is defined in WVDP-485, Work Control.

Senior management assigns work planning and control program roles and responsibilities and a Subcontractor Technical Representative (STR) is assigned to ensure requirements flow down to the subcontractor(s). Senior management also performs independent review of high hazard/complex work during the work package approval process in accordance with EMD-002, Hazard Review Board. Line management is responsible for the protection of employees, the public, and the environment. Line management includes CHBWV and subcontractor employees managing or supervising employees performing work. CHBWV's program and implementing documents define clear and unambiguous lines of authority and responsibility for ensuring environmental, safety, and health requirements are established and maintained at all organizational levels and become an integral but visible part of the WVDP's work planning and execution process.

4.1 WVDP Work Planning and Implementation The WVDP has a robust work planning and control program. Complex or high hazard work that is only performed once or a limited number of times requires the preparation of a WIP. High hazard or complex work activities involve tasks that require detailed work instructions and accompanying hazard analysis to be performed safely and correctly. WIPs are developed per EP 002, Administration of Work Instruction Packages, and hazard analysis is performed per WV-921, Hazards Identification and Analysis.

Each WIP will contain a thorough hazard analysis, all relevant design engineering documents, and tailored instructions for safely executing the scope within the safety basis of the facility. Hazard controls will be tailored for various facility conditions allowing a graded approach to address personnel and environmental safety concerns for specific activities.

More routine and repetitive operations and maintenance activities may be described in Standard Operating Procedures (SOPs). SOPs may be used for various levels of risk and complexity and the level of detailed instruction will vary based on the complexity. Hazard analysis is performed in accordance with WV-921 and hazard mitigations are included directly in the SOP or in permits required by the SOP (e.g., IWPs and RWPs). SOPs are developed, issued and maintained in accordance with DCIP-100, Controlled Document Preparation and Revision Process and DCIP-101, Controlled Document Review, Approval, and Emergent Change Process.

WVDP-586 Rev. 1 Page 19 of 94 To fully embed the ISMS processes and expectations, work will commence at a controlled, deliberate pace. Work controls will also be reinforced by Human Performance tools such as those included in DOE-HDBK-1028-2009, Human Performance Tools for Individuals, Work Teams, and Management. The strategic approach for improving performance is to reduce human error and manage controls so as to reduce unwanted events and/or mitigate their impact should they occur. MPPB deactivation and demolition work will be planned to allow personnel to gain familiarity with the facility and gain confidence in the processes being used. This approach affords line management the opportunity to mentor and monitor the personnel in a less hazardous environment where the likeliness of personnel injury or environmental upsets is minimized. 5.0 PRE-DEMOLITION ACTIVITIES As previously stated, portions of the MPPB were modified to support its primary WVDP mission of solidifying HLW. Fuel reprocessing equipment was removed from the CPC to allow it to be used for storage of canisters of vitrified HLW. Fuel reprocessing equipment in XC-3 and the PPC was removed and was replaced with equipment used to support the LWTS. This system was used to manage treated supernatant, sludge wash solutions, and vitrification waste water from Tank 8D-2. 5.1 Deactivation Activities Completed Major hazard reduction activities were performed in the MPPB prior to the start of the current contract in August of 2011 and have continued since. The current contract scope includes the demolition of the MPPB to the facility slab at grade elevation (100ft +/- 3ft). To date, the majority of the process cells (i.e. extraction cells, PPC, OGC, PMC, CPC) have all undergone a significant radiological source term reduction by removal of all process equipment, vessels, tanks, piping, and support systems. This effort has contributed to an overall radiological source term reduction which will support the demolition of the facility. There has been additional hazard reduction in the support areas (i.e. operating aisles, labs, offices, areas outside cells) that not only includes radiological source term reduction but also industrial hazards such as ACM, lead, PCB's, and hazardous waste components. This hazard reduction will continue until the MPPB is deemed demolition ready. The following is a summary of MPPB deactivation activities in major areas, performed to support historical WVDP operations and in preparation for demolition:

CPC o Prior to being established as the HLWISF, the process equipment, vessels, tanks, piping, and support systems were removed. Gross decontamination of the cell walls and floor was also performed. o On-site relocation of the vitrified HLW canisters is complete and removal of low-level waste (LLW), and transuranic (TRU) waste containers is progressing.

PMC o All process equipment and support systems were removed. In-cell debris was packaged in drums and removed. Gross decontamination of the walls was performed up to the crane rail elevation utilizing the nitrocision decontamination system.

Extraction Cells o All process equipment, vessels, tanks, piping, and support systems were removed. Targeted gross decontamination was performed on sections of walls. Embedded wall penetrations in the cell have been stabilized (i.e. expandable foam, fixative).

WVDP-586 Rev. 1 Page 20 of 94

PPC o All process equipment, vessels, tanks, piping, and support systems were removed. Some targeted gross decontamination was performed on sections of walls. Embedded wall penetrations of the cell have been stabilized (i.e. expandable foam, fixative).

LWC o Eight of nine process tanks were flushed and decontaminated to reduce radiological source term for removal during demolition. o The majority of process piping associated with each tank was removed. o Gross decontamination of the cell floor was performed. o Three tanks have been stabilized with foam and five have been grouted.

Uranium Product Cell (UPC) o Removal of the remaining process water from the tanks to waste containers for stabilization and or disposal was completed. o Samples to characterize the remaining material in the tanks have been collected.

A&PC Laboratory Area o All remaining chemicals and laboratory equipment were removed from the hoods and the hoods have been surveyed for demolition. o Extensive ACM removal was performed throughout the laboratory area. o Process equipment, piping, and working tables were removed from the hot cells. Gross decontamination was performed. o Manipulators containing lead counter weights were removed. o Shield windows have been drained. o Applied fixative to lab hoods, gloveboxes, ventilation duct, ceilings, and walls, as needed.

Head End Ventilation (HEV) o Removed the system pre-filters, roughing filters, and high-efficiency particulate air (HEPA) filters and packaged for disposal or further processing. o Removed liquid from the under floor ducting. o Fabricated tooling and began scraping floor debris into piles.

Operating Aisles and Support Areas o ACM removal was been performed extensively throughout the operating aisles and support areas. o Partial removal of process and utility piping, and ventilation duct work was performed, targeting equipment with higher levels of radioactivity. o Partial removal of electrical components, conduit, wiring, and instrumentation was performed.

NOTE Some of the piping, ventilation duct work, electrical components, conduit, wiring, instrumentation, and industrial equipment that have been determined to be non-hazardous will remain in the facility for removal during demolition.

WVDP-586 Rev. 1 Page 21 of 94 5.2 Deactivation Activities Remaining In addition to the completed activities, the following deactivation activities will be completed prior to the start of MPPB demolition. As used below, "gross decontamination" refers to the removal of radiologically contaminated debris, sediment, and loose media that is readily removable from building surfaces, equipment, and components. Removed materials will be characterized and packaged for off-site disposal. Subgrade piping beneath the MPPB that penetrates the MPPB slab will be isolated prior to demolition so there will not be a pathway for water or contaminant transport. The need and extent of decontamination for some cells will be evaluated based upon the results of ongoing characterization. Deactivation activities for some areas may be adjusted once additional information is obtained.

Decontamination activities will continue to progress until such time that the structure meets prescribed limits for open air demolition. Actions such as painting surfaces and using a water curtain are being used to keep exposure during demolition ALARA.

These activities are expected to be complete by late 2018:

CPC o Remove associated equipment from HLW canister removal activities, LLW, and TRU waste containers. o Perform debris removal, gross decontamination, embedded wall penetration stabilization, sampler stabilization, and application of fixatives to the cell walls and ceiling. o Subgrade piping that will remain after demolition will be isolated so there will not be a pathway for water. o Drain fluids from the shield windows, shield door gear boxes, and overhead cranes o Decontaminate overhead cranes and apply fixative to stabilize for removal during demolition. o Perform additional characterization of the CPC racks and determine rack disposition. o Provide structural hatch cover from CPC to GPC to allow for floor grouting and provide strength to protect GPC during MPPB demolition. o Stabilize the cell floor with grout.

PMC o Perform debris removal, gross decontamination, stabilize embedded wall penetrations, and apply fixatives, as necessary, to the cell walls, ceiling, and floor. o Remove manipulators and stabilize ports within the walls. o Drain fluids from the shield windows, shield door gear boxes, and overhead cranes. o Decontaminate overhead cranes and apply fixative to stabilize the cranes for removal during demolition. o Install structural hatch covers from PMC to GPC and PMC to Miniature Cell, to allow for floor grouting and strengthening to protect GPC during MPPB demolition. o Install structural hatch cover from PMC to Fuel Receiving and Storage Facility (FRS) tunnel to allow for PMC floor grouting and strengthening to protect FRS tunnel during demolition. o Stabilize the cell floor with grout.

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Scrap Removal Room (SRR) o Install structural hatch cover from SRR to GPC to allow for floor grouting and strengthening to protect GPC during demolition.

Extraction Cells o Apply fixative, as necessary, to the cell walls and floors. o Stabilize the cell floors with grout.

PPC o Stabilize embedded wall penetrations and perform decontamination on isolated spots on walls. o Apply fixative, as necessary, to the cell walls and floors. o Stabilize the cell floor with grout.

LWC o Complete process piping removal and decontamination of one tank. o Transfer decontamination water to waste containers and move to waste storage areas in preparation for shipment/disposal. o Complete preparing nine tanks for removal during demolition by capping openings, stabilizing interior with foam or grout, and removing anchors. o Stabilize embedded wall penetrations and perform decontamination on isolated wall locations. o Apply fixative, as necessary, to the cell walls and floors. o Stabilize the cell floor with grout.

UPC and ULO (Uranium Load Out) o Complete process piping removal and decontamination of remaining tank. o Remove remaining materials from the tanks. o Prepare the UPC tanks, including one single tank and one dual compartment tank, and one tank in the ULO for removal during demolition by capping openings, stabilizing interior (by grouting, foaming, or painting), and removing anchors. o Stabilize embedded wall penetrations and perform decontamination on isolated wall locations. o Apply fixative, as necessary, to the cell walls and floors. o Stabilize the cell floor with grout.

Analytical Lab Area o Evaluate A&PC Hot Cells process drain line and ventilation duct for removal or stabilization.

Ventilation Wash Room (VWR) o Perform initial radiological and ACM characterization for deactivation planning. o Remove partial wall sections to allow better access for deactivation. o Stabilize penetrations, as necessary. o Remove radiological source term associated with, filters, ACM, piping, and ducting based on characterization results, or stabilize (i.e. fixative, foaming, grout) components for removal during demolition. o Prepare washer for removal during demolition.

Head End Ventilation (HEV) o Decontaminate filter housing and stabilize (i.e. fixative, foaming, grout) for eventual removal during demolition. o Remove or stabilize system duct work.

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Equipment Decontamination Room (EDR) o Perform debris removal, gross decontamination, stabilize embedded wall penetration, and apply fixatives to the cell walls, ceiling, and floor. o Drain fluids from the shield window, shield door gear boxes, and overhead crane. o Decontaminate overhead crane and apply fixative to stabilize crane for removal during demolition. o Stabilize the cell floor with grout or fixative.

Operating Aisles and Support Areas o Complete limited ACM removal on piping and duct work. o Remove piping and duct work based on radiological hazard levels. o Remove electrical components that are hazardous or contain PCB's. o Apply fixative to the overhead ceilings and walls as necessary. o Stabilize floors, as necessary (e.g., paint, grout, fill, etc.).

Ventilation Exhaust Cell (VEC) o Stabilize or remove corresponding duct work. o Perform initial radiological and ACM characterization for deactivation planning. o Remove filters and package for disposal or further processing. o Remove rad source term, piping, and duct based on characterization or stabilize (i.e. fixative, foaming, grout) components for removal during demolition.

Ventilation Supply Room (VSR) o Perform initial radiological and ACM characterization for deactivation planning. o Remove hazardous materials.

Ram Equipment Room (RER) o Decontaminate area walls from spills originating in VWR. o Stabilize ram sleeves for demolition. o Stabilize the floor, as necessary.

Roof ACM Mitigation o Abate/remove ACM insulation and associated piping. 5.3 Dispositioning "Stand-Alone" Items Within the MPPB, there are several "stand-alone" items that will be processed and dispositioned as part of the open air demolition. These items include:

CPC overhead cranes, Power Manipulator (PAR) arm, canister drum storage racks, 1C Sampler, and shield doors;

PMC overhead cranes, PAR arm, and shield doors;

EDR overhead crane and shield doors;

EDR transfer Cart

LWC nine process tanks;

UPC and ULO process tanks;

XC-1 Artisan robotic arm;

Extraction Cells & PPC man-lifts/ automated scaffolds;

HEV, VEC, and VWR filter housings and blowers, and washer;

Sample transfer stations (multiple locations);

VSR supply air filter housing & blower;

Control Room cabinets;

Analytical Aisle laboratory hoods and gloveboxes; WVDP-586 Rev. 1 Page 24 of 94

Remaining piping, ductwork, small vessels, pumps, electrical wiring, conduits, light fixtures, control panels, motor control centers, and switchgear. 5.4 Structural Analysis An engineering survey will be conducted and documented by a Professional Engineer to evaluate the structural condition of the MPPB in accordance with American National Standards Institute International (ANSI), American National Standard for Construction and Demolition Operations - Safety Requirements for Demolition Operations (ANSI A10.6); and 29 CFR Part 1926.850 - Safety and Health Regulations for Construction, Subpart T - Demolition.

The engineering survey will include a visual survey of the building and a structural assessment to evaluate the possibility of a premature collapse of portions of the building during demolition and steps to be taken to prevent any such occurrence. In addition, any adjacent structure where employees may be exposed shall also be similarly checked.

In addition to the engineering survey there are areas in the MPPB that will require additional analysis prior to demolition and evaluation during demolition activities. Such areas are anticipated to include, but may not be limited to:

The east wall of the East Mechanical Operating Aisle (EMOA) and the north walls of the UPC and the ULO area. These walls are common with the FRS which is not part of the current contract;

Areas located above the Miniature Cell, General Purpose Cell (GPC), General Purpose Cell Operating Aisle (GOA), General Purpose Cell Crane Room (GCR) and extension (GCRE), CPC Vault Waste Catch Tank, and associated stairwell;

Hatches located in the CPC to the GPC, PMC to the FRS, PMC to the GPC, South Master Slave Manipulator (MSM) Shop to the GOA, SRR to the GPC;

Stainless steel chutes from the PMC to Miniature Cell and PMC shear to the GPC;

The ceiling of the LWC (which has had several hatches cut through it).

Additional analyses may be performed based on the judgement of the Professional Engineer.

As described below, a demolition readiness checklist will be prepared prior to demolition. This checklist will include an engineering section where completion of the engineering survey described above will be documented prior to initiating MPPB demolition. A New York State-licensed Professional Engineer is also part of the work planning and sequence development process. This individual will assess the demolition WIP(s) to ensure the demolition sequencing, means, and methods will not cause a premature collapse during demolition and will prevent damage to any adjacent structures.

5.5 Demolition Readiness Checklist A demolition readiness checklist will be developed to ensure pre-demolition activities are completed and accepted as complete prior to starting MPPB demolition. Attachment B is an example of a checklist used for other WVDP demolition activities. The checklist will be reviewed by personnel from various departments whose signatures will indicate that they concur that all items and required actions, for their area of expertise, needed to make the facility ready for demolition have been identified and addressed. Organizations reviewing the checklist will include: Regulatory WVDP-586 Rev. 1 Page 25 of 94 Strategy & Chief Engineer, Industrial Safety, Nuclear Safety, Radiological Controls, Quality Assurance, and Waste Operations.

Topical areas addressed by the checklist will include:

Regulatory Notifications/Requirements

Training Requirements

Engineering Evaluation

Utilities

Hazardous Materials

Other Hazards (e.g., radiological, biological, physical, etc.) Once the checklist is reviewed and approved/signed by the necessary departments, the Facility Manager will approve it, indicating that the MPPB is ready for demolition. 5.6 Preparation of Work Documents As described in Section 4.1, WVDP work planning follows a well-established and controlled process which insures that: 1) The work scope is well defined; 2) Hazards are identified and controlled; 3) Work is performed safely and within controls; and 4) Feedback is provided and lessons learned are shared. The work documents (i.e., WIPs) governing MPPB demolition activities will be prepared, reviewed, and approved according to this process as further described below.

As part of work planning and execution, the planning/work team, including workers and subject matter experts, performs walk downs using SOP 00-46, Work Instruction Walkdowns, Pre-Job and Daily Briefings, and Post-Job Feedback/ Lessons Learned to better identify and analyze specific hazards and possible human performance issues. Other items accomplished during the walk downs also include:

identify the specific tasks and associated steps necessary to accomplish the work;

verify the equipment, components, locations, etc. described in the requested work are correct and accurate;

identify the applicable and affected documents (e.g., procedures, drawings, specifications, vendor manuals, training materials, etc.), and the latest versions/revisions, and;

determine that the work activity is clearly and adequately bounded/limited (e.g., physical boundaries such as equipment/components to which work activity is limited, specific work environment to which work is confined; conditions under which work can be performed; and organizations responsible for the various tasks, etc.).

Facility Assessments are an essential prerequisite to a safe and successful D&D process. An integrated group of personnel composed of safety, industrial hygiene, radiological controls, engineering, D&D management, workers, environmental and regulatory compliance, nuclear safety, waste operations, and quality assurance are involved in the WIP development.

As part of the planning process, hazard assessments are conducted to document existing conditions in and around the facility. Hazard assessments are performed by qualified individuals to document current facility conditions from a safety, radiological, engineering, utility, and demolition standpoint. An example of the hazards analysis form that is prepared is included in Attachment C.

WVDP-586 Rev. 1 Page 26 of 94 Pre-demolition surveys are conducted as part of the hazard assessments process on all structures decommissioned in accordance with Occupational Safety and Health Administration (OSHA) guidelines (29 CFR 1926.850) following WVDP-446, Facility Demolition Hazard Characterization Planning.

Prior to issuance of a WIP, the work review group coordinator performs a Work Control management review of the WIP and ensures that: 1) the WIP was developed following the processes in EP 002; and 2) all Hazard Control Specialists identified by the hazard analysis process were required to review and approve the WIP.

The Responsible Manager (RM) and Operations Manager also approve the WIP, and a final interactive meeting for high hazard or complex work is held when deemed necessary by the RM. The final interactive WIP review meeting is a face-to-face review of the draft WIP with planning team members. This allows the reviewers to improve the final product based on the shared discussions. Work Control reviews the WIP for completeness, insuring that all necessary signatures are present. The work package is then issued for implementation along with supporting documents such as an IWP, to identify hazards and establish worker health and safety controls, and a RWP to establish radiological controls. If it is necessary to make a Field Change to a WIP, the steps identified in EP 002 are followed, including obtaining signatures from all departments and work groups affected by the change.

6.0 MAIN PLANT PROCESS BUILDING DEMOLITION This section provides an overall description of how the open air demolition approach and techniques will be executed to ensure the MPPB is safely and compliantly demolished. The overall approach is to perform characterization, decontamination, and source term reduction to a degree that supports conventional, uncontained, open air demolition. Techniques which utilize mechanical, hydraulic, or remote equipment, to the greatest extent possible, will be implemented to perform D&D activities in a manner which minimizes worker exposure to radiological, mechanical, and chemical hazards. The demolition approach may include the limited use of localized, portable ventilation controls to insure worker protection and public health and safety. Lessons learned from the 2013 demolition of the WVDP 01-14 Building, demolition of the WVDP Vitrification Facility (scheduled for 2017), the Separations Process Research Unit (SPRU) D&D activities at Knolls Atomic Power Laboratory, and other DOE facilities will be factored into the planning for the MPPB demolition. Among others, these lessons learned include:

thorough characterization of the facility;

utilization of personnel familiar with the facility and associated hazards;

application of fixatives to control spread of contamination;

identifying specific steps and sequencing in the WIP along with diagrams that identify safety and radiological considerations, precautions, and notes;

utilization of real time air monitors and reviews of daily radiological data;

careful consideration of dust suppression methods as well as the rate of application, wind speed, and direction; and

timely application of process controls, as needed, based on the information collected.

The following general performance criteria will be incorporated into the work scope for the MPPB D&D:

demolition of the MPPB will be performed in accordance with all applicable Federal, State and DOE Environmental, Safety and Health Requirements, Laws and Regulations; WVDP-586 Rev. 1 Page 27 of 94

demolition will be consistent with the WVDP DP, and the NRC Technical Evaluation Report;

during the decommissioning and demolition work, CHBWV will minimize the generation of difficult to dispose of waste streams such as transuranic (TRU) and mixed-TRU waste and mixed low-level waste (MLLW);

measures will be implemented to minimize and control the spread of contamination;

an Ambient Air Monitoring Program approved by EPA is operational to support the decommissioning and demolition work, and;

measures will be implemented to prevent the migration of water into, or out of all remaining penetrations, surfaces, and structures and the accumulation of water in below grade structures. 6.1 General Decommissioning Approach and Technologies The MPPB demolition WIP(s) will identify the final, approved, specific sequence of demolition activities, including detailed means and methods and controlled demolition techniques consistent with the final approved calculation for open air demolition. The demolition WIP will also include a radiological monitoring plan to identify methods for monitoring the perimeter of the work area and personnel working within the area, environmental controls to mitigate potential releases, waste management practices, and safety and health processes to ensure worker safety. These items are discussed further below.

Some of the techniques and approaches to be used include development of detailed demolition drawings/sketches identifying the specific sequence of events, continuous air monitoring, control and disposition of wastewater, use of suppressants on demolition debris to prevent dispersion of particulates and/or contamination, timely loading and disposition of debris to prevent accumulation, and restricting access to the area to prevent unauthorized entry during demolition activities. Suppression of airborne contamination during demolition will be through the application of fixatives to contaminated building surfaces and the use of water fogging nozzles/misting equipment (stand-alone or equipment mounted), which may include surfactant, to suppress dust during demolition. Debris piles will be sprayed with a suppressant at the end of each day or more frequently.

Run-off water will be controlled and dispositioned in accordance with WVDP procedures (e.g., treated and discharged through the site's State Pollutant Discharge Elimination System [SPDES] permitted system). A berm or berms will be set up around the demolition area(s) to provide containment for dust suppression water and precipitation. The water will be tested as directed by site procedures and transferred for treatment through the SPDES permitted low-level waste treatment facility. Efforts will be made to minimize the volume of water by using misting techniques and a surfactant. Storm drain inlets within the bermed area will be sealed. These practices will effectively control the volume of water to be controlled, as well as avoiding impacts to other systems, including groundwater, to minimize the potential for the spread of contamination both inside and outside work areas.

The MPPB floors and below-grade structures will be coated with a fixative and/or grouted, as necessary to maintain dose ALARA, protect the surfaces from damage during demolition, minimize equipment contamination, and deter water intrusion. Prior to placing grout, an engineering analysis will be performed to determine the thickness of grout needed to avoid damage to the underlying surfaces. Items such as filters, cell debris, piping, and miscellaneous equipment with high levels of radioactivity will already have been removed from the building or stabilized during deactivation. Some remaining items will be clearly marked (e.g., painted) for segregation and dispositioning during demolition. Remaining piping sections and wall penetrations containing piping that were WVDP-586 Rev. 1 Page 28 of 94 stabilized will be removed and segregated during demolition. Sufficient coat(s) of contamination fixatives will be applied to allow open air demolition; the criteria for fixing contamination and leaving contaminated materials/equipment in place for removal during demolition is an ALARA evaluation (Section 6.4.1) to determine if further decontamination efforts are justified in lieu of beginning demolition activities with fixatives applied. As described in Section 6.4, continuous monitoring will be performed near the demolition area to monitor worker safety. If necessary, additional fixatives can be applied during the demolition work process. Gravel or similar material will be placed, as necessary, over the floors of the MPPB footprint to provide "cushioning" during demolition and support equipment passage. This material will be graded to promote drainage following demolition.

Demolition will primarily be performed using heavy equipment, with two to four pieces of complimentary heavy equipment typically used as described in Section 6.2. The demolition techniques will be performed by competent persons who are familiar with the building design and construction, demolition operations, equipment functions, and potential hazards. These individuals will perform what is generally described as a "Cut, Shear, Break, Drop" (CSBD) approach starting at the top of the building and working in a downward manner. The CSBD approach can generally be described as cutting or shearing followed by breaking and lowering the building pieces to the ground within the controlled/regulated work area (drop zone). The building structure and components are then sized into small manageable pieces on the ground through the use of hydraulic excavators (or other manual equipment) and appropriately sized attachments.

One important aspect to be maintained throughout demolition is that no undermining and no cutting or shearing of lower level/floors will occur that could jeopardize the structural integrity of the building. The overall demolition approach is to remove upper structures, roofs, walls and floors in a limited or general area, then work in a downward manner as each floor or area is completed. The individuals directing operation of the equipment (e.g., Demolition Superintendents, Foreman and craft work crew) are primarily responsible for determining, from the WIP, which pieces are cut, broken or sheared as well as the general direction and sequencing of the demolition, such as either working from north to south, east to west, or any other direction as needed to address site specific concerns. The demolition activities will also be supported by a licensed Professional Engineer throughout the process.

Explanation of the following terms is provided to help describe the demolition process:

Cut - To cut apart using a combination of means and methods. Cutting typically involves the use of manually operated thermal torches, burning bars, cutoff saws, or pneumatic and hydraulically operated equipment to cut through steel, concrete, wood and other building materials.

Shear - To snip, saw, or otherwise tear apart (similar to a scissors) with the use of a hydraulically operated, mechanical device attached to a track excavator, crane, or other equipment. Shears (or similar devices) are typically capable of cutting through steel, metals, concrete, wood and typical building materials.

Break - To break apart building components with a combination of devices such as hydraulically operated hammers, pulverizers, grapples, buckets with thumbs, or other types of material processors generally attached to track mounted hydraulic excavators, cranes or other carriers. Typically, once a building component is "Cut" or "Sheared", the piece may need to be further broken apart from the structure before being lowered to the ground.

WVDP-586 Rev. 1 Page 29 of 94 Drop - Once the various types of building materials and structural components are cut, sheared, or broken apart from the building, they are then lowered to the ground under controlled conditions into the controlled/regulated work zone.

As the building demolition progresses, debris will be sized and loaded in appropriate containers for transportation to the designated waste disposal facility. Demolition debris will be packaged and transported in accordance with the waste management approach described in Section 7.0. The various sized excavators will perform the shearing and debris segregation/load out operations. The majority of debris will be loaded into intermodals (IM's) or other specified containers.

6.2 Equipment to be Utilized and Available A primary processing excavator configured with a rotating shear or hydraulic breaker attachment along with a secondary processing excavator with a concrete pulverizer and handling attachment(s) will be the typical equipment utilized. Additional methods such as a concrete crusher on an excavator may also be used to fracture the thickest reinforced concrete walls of the MPPB.

Attachment D contains pictures and additional information regarding typical D&D equipment items. The following types of equipment (or equivalents) will be utilized as necessary:

large excavator (such as CAT 374D, 160-220K class) with standard arm and combination shear for cutting/shearing steel and/or concrete crusher jaw and hydraulic hammer for breaking concrete and masonry

medium excavator (such as CAT 345D, 90 to 110K Class) with bucket and thumb, able to use 11,000 ft lb hammer, and or shear/concrete breaker High Reach Arm (30' extension = total height to +/- 60')

small excavator (such as CAT 320D, 40 to 50K Class) with standard arm and concrete pulverizing head for crushing concrete, segregating rebar, and breaking masonry, bucket and thumb, and 3-4K lb hammer,

Aerial platforms (varies) to facilitate cutting and dust control

Dust suppression equipment

Front end loader(s)

Skid steer(s)

Crane(s)

Waste Containers

Forklifts

Diamond Wire Saw (available if needed)

Concrete Saw (e.g., wall saw)

Oxy-Propane or oxy-gasoline cutting torch,

Air sampling equipment.

Heavy equipment end effectors (attachments, such as shears, grapples, buckets, thumbs, hammers, etc.) will become contaminated during the course of MPPB demolition. At the completion of the MPPB D&D work, the equipment may require decontamination and/or bagging in order to be reused or dispositioned as waste if there is no foreseeable reuse.

WVDP-586 Rev. 1 Page 30 of 94 6.3 Demolition Approach and Sequence The overarching demolition approach and planned sequencing for the MPPB is to perform the demolition in a stepwise manner from the known radiologically "cleanest" areas (the perimeter ancillary areas, interior support areas, and interior aisles) to those areas more impacted by prior processes (CPC, PMC, LWC, Extraction Cells) and from top to bottom. This will minimize the potential for cross-contamination of facility areas, minimize migration of contamination and will reduce the time and resources associated with decontaminating equipment and materials from one area to another. This conceptual sequencing approach was successfully implemented during D&D of the WVDP 01-14 Building and will be applied during VF demolition. The approach and sequence will also factor in adjacent facilities to the MPPB which may not be demolished prior to MPPB demolition. Figure 3 shows a schematic of the MPPB prior to demolition.

Figures 3 through 25, further described below, show the planned sequencing approach for the MPPB demolition using the methods and equipment described in the previous sections. There may be some overlap between areas and activities occurring in parallel as demolition progresses from area to area. As final steps are taken to prepare the MPPB for demolition and demolition gets underway, it may be necessary to make adjustments to the approaches and/or sequencing described below due to differing conditions. Such potential adjustments will be documented and authorized through the work control system and associated documents. Factors influencing the work process may include: structural integrity, activities and occupancy in adjacent nearby facilities, other surrounding site activities, radiological monitoring and controls, ventilation controls and requirements, or other project related factors.

The specific area(s) being addressed in each section are highlighted in yellow on the accompanying figures. Other colors such as green or blue have been incorporated into the model to highlight certain types of common equipment located throughout the building such as doors or hatches, which may not be associated with the yellow highlighted area being addressed. When an area is listed as "common", its removal is considered a straightforward demolition activity and it is being removed as part of a corresponding surrounding area, and additional detail is not warranted as part of the MPPB demolition discussed herein. Similarly, a "low risk" area is one where minimal radiological controls are needed during demolition based on either non-detectable, or low levels of contamination.

WVDP-586 Rev. 1 Page 31 of 94 Figure 3 - Main Plant Process Building Prior to Demolition (Facing Southwest)