The United States Department of Energy (DOE) and its contractor were remediating a large hot cell complex to mitigate the radiological hazard. A Resource Conservation and Recovery Act (RCRA) closure unit was determined to he located within the complex. The regulator established a challenge to develop an acceptable closure plan on a short schedule (four months). The scope of the plan was to remove all excess equipment and mixed waste from the closure unit, establish the requirements of the legally binding Closure Plan and develop an acceptable schedule. The complex has several highly radioactive tanks, tank vaults, piping. and large hot cells containing complex chemical processing equipment. Driven by a strong need to develop an effective strategy to meet cleanup commitments, three principles were followed to develop an acceptable plan: (1) Use a team approach, (2) Establish a buffer zone to support closure, and (3) Use good practice when planning the work sequence. The team was composed of DOE, contractor, and Washington State Department of Ecology (Regulator) staff. The team approach utilized member expertise and fostered member involvement and communication. The buffer zone established an area between the unregulated parts of the building and the areas that were allegedly not in compliance with environmental standards. Introduction of the buffer zone provided simplicity, clarity, and flexibility into the process. Using good practice means using the DOE Integrated Safety Management Core Functions for planning and implementing work safely. Paying adcquate attention to detail when the situation required contributed to the process credibility and a successful plan.
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