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Complex-wide Review (CWR) and DOE O 435.1 Revision Project Update

Complex-wide Review (CWR) and DOE O 435.1 Revision Project Update. Dennis Knapp. General Requirements Core Team Member Savannah River Nuclear Solutions, LLC ASP 2010 Workshop, Seattle, Washington September 20 – 25, 2010. Introduction. Background 2010 Complex-Wide Review (CWR)

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Complex-wide Review (CWR) and DOE O 435.1 Revision Project Update

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  1. Complex-wide Review (CWR)and DOE O 435.1 RevisionProject Update DennisKnapp General Requirements Core Team Member Savannah River Nuclear Solutions, LLC ASP 2010 Workshop, Seattle, Washington September 20 – 25, 2010

  2. Introduction Background 2010 Complex-Wide Review (CWR) Responses & Findings DOE O 435.1 revision update

  3. Where We’ve Been and Where We’re Going DNFSB 94-2 Update DOE O 435.1 2010 CWR 1996 CWR >10 years of experience Issue DOE O435.1 1999

  4. 2010 CWR Survey Results Over 14,000 Individual Responses 100% Site and Program response CWR Data Capture and Evaluation Successes – Achievement of complex-wide mission, goals or milestones Best Practices – Activities and approaches that demonstrated effective implementation of DOE O 435.1 Lessons Learned – Work practices or approaches shared to promote repeat application or avoid recurrence Areas of Improvement – Specific areas of the Order that may not be fully implemented or suggested revisions, additions, or clarifications to DOE O 435.1

  5. HQ Responses & Findings Best Practices (6) Management, planning and integration of the TRU program Low-Level Waste Disposal Facility Federal Review Group (LFRG) process for review of PA/CA Areas of improvement (21) Execution of oversight responsibilities by HQ Program Offices/Site Managers Commercial treatment, storage, and disposal exemption process Ensuring the performance assessment requirements are included in legacy management process for sites being closed Ensuring integration of DOE O 435.1 and CERCLA closure requirements.

  6. HLW Responses and Findings Best Practices (10) WIR Citation process has allowed for safe disposition of equipment that had previously come in contact with HLW Areas of Improvement (25) Clarifying the requirements for alternative waste forms (other than glass) Integration of NDAA 3116 and DOE O 435.1 requirements

  7. TRU Responses and Findings Best Practices (12) Deployment of the central characterization project (CCP) has increased the efficiency and accuracy of TRU waste characterization Establishment and implementation of the TRU Corporate Board was used as the standard for establishing other waste-type Corporate Boards Areas of Improvement (20) Improvements in integration in waste handling could be experienced if there were a single contractor for TRU management at each site. Identification of annual disposal goals should be included in site waste management planning documents in order to improve consistency and reduce rework. Improvements in the disposal process for classified TRU need to be made.

  8. LLW Responses and Findings Best practices (40) Establishment of the LFRG and its manual and guidance has improved consistency with requirements of DOE O 435.1. Adoption of a "one touch" philosophy which stipulates that at the point of generation, waste will be packaged, classified, and characterized in full compliance with its disposition pathway to minimize overall worker risk and to promote consistency. Implementation of the Unreviewed Disposal Question Evaluation (UDQE) procedure at Savannah River Site is the standard for determining the impact to the PA and CA when proposed actions or new information is discovered. LLW Corporate Board (LLWCB) effective in providing forum for sharing information across DOE sites

  9. LLW Responses and Findings (cont.) Areas of improvement (73) Clearly establishing DOE’s authority to take ownership of radioactive material that is in the national interest There is a need for consistent implementation of radioactive waste management requirements for those sites that have multiple contractors, Field Offices and Program Offices responsibilities. Clarifying the appropriate use of concentration averaging Integrating requirements from DOE O 435.1 and those of other regulations such as RCRA, CERCLA, 40 CFR 191, 10 CFR 61 and, NDAA 3116.

  10. Key Findings/Issues – Executive Summary Significant progress has been made in radioactive waste management over the last 10 years Establishing LFRG has improved consistency in PA/CA reviews New requirements (e.g. NDAA 3116 for tank closures) should be included in the DOE O 435.1 update Identification of disposal paths for certain waste with no path for disposal (e.g. non-defense TRU) Clarifying definitions for: fission products in sufficient concentrations; classified matter and spent nuclear fuel reprocessing in DOE O 435.1

  11. Key Findings/Issues – Executive Summary(cont.) Improving Program Office and Site Managers oversight responsibilities and consistent implementation of requirements involving multiply site contractors and/or program offices Improved implementation of other DOE Orders (e.g. classified matter) and outside regulatory agencies (e.g. RCRA, CERCLA) requirements that have overlapping requirements with DOE O 435.1 Modify the current commercial disposal exemption process requirements for LLW

  12. DOE O 435.1 Update Status Developed methodologies for updating 435.1 Using same approach as 1999 order revision Established chapter-specific Core Teams (Team Lead) – General Requirements (Linda Suttora) – LLW (Frank DiSanza) – HLW (Joel Case) – TRU (J.R. Stroble/Alton Harris) Developed algorithm for processing input information Established website for establishing baseline information and changes to Order, Manual, Guide & Technical Basis

  13. DOE O 435.1 Update Status Four Core Team Workshops Workshop #1 (April 2010, Portland OR) Established core teams, developed plans and schedules, made team assignments, established expectations Workshop #2 (October 2010, Salt Lake City UT) Core team status, identify/work crosscutting issues, address technical standards (rogue guides), ensure team consistency/approach Workshops #3 & 4 - TBD

  14. DOE O 435.1 Update Status Key Changes Being Considered General Requirements - Restructured to include items common to all waste types - Unreviewed Waste Management Question Evaluation - Contingency storage requirements for Liquid LLW - Complex-wide/Site-wide Waste Management Plans - Radioactive Waste Management Basis - Closure requirements (CERCLA/RCRA) - Classified waste versus “matter” - Use of Off-Site DOE and Non-DOE Facilities

  15. DOE O 435.1 Update Status Key Changes Being Considered (cont.) HLW - Revise definition of HLW - Add definitions: HLW facility, highly radioactive, highly radioactive radionuclides, liquid waste produced directly in reprocessing, permanent isolation, reprocessing, reprocessing facility, sealed source, sufficient concentrations - Clarify/update WIR requirements - Include NDAA 3116 requirements

  16. DOE O 435.1 Update Status Key Changes Being Considered (cont.) TRU - Added packaging requirements from Technical Standard/ ”Rogue Guidance” - Staging requirements - Blending/dilution - Non-defense TRU

  17. DOE O 435.1 Update Status Key Changes Being Considered (cont.) LLW - Commercial exemptions - DAS/”Federal Permit” equivalency language - PA/CA –Technical Standards/Rogue Guides - Blending/dilution

  18. DOE O 435.1 Update Status Cross Cutting Issues FFAs entered into with state/EPA including closure and post-closure requirements should qualify for the same exemption as CERCLA closures. 435.1 process for closure allows equivalency under CERCLA but not RCRA leading to inconsistent interpretation/implementation. Differences between the 435.1 WIR process and NDAA 3116 result in inconsistent determinations across the complex. Management and disposal requirements for problematic waste streams including: TRU and HLW with no path for disposal, classified matter, waste generated during work for others and waste form (e.g., bulk liquid).

  19. DOE O 435.1 Update Status Cross Cutting Issues (cont.) Develop clear expectations for Site LFRG representatives. Improve guidance on completing a cost-analysis for the exemption process so requests take all factors into consideration. Develop a formal, consistent process that considers the technical basis, regulatory issues/authority, and approval process for transferring ownership and accepting non-DOE waste for disposal in DOE facilities (interests of national security).

  20. DOE O 435.1 Update Status Cross Cutting Issues (cont.) Coordination with NRC to ensure that DOE requirements related to probabilities of exposure scenarios, critical groups, time frames and other similar standards are consistent and technically justifiable.

  21. DOE O 435.1 Projected Schedule

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