DOE Order 435.1 Radioactive Waste Management Revision Project Update

1. DOE Order 435.1 Radioactive Waste ManagementRevision Project Update DennisKnapp General Requirements Core Team Member Savannah River Nuclear Solutions, LLC ASP 2011 Workshop, Pleasanton, California September 19 – 22, 2011

2. DOE O 435.1 Update Status • 435.1 update through four Core Teams • General Requirements – Linda Suttora • Low-Level Waste – Frank DiSanza • High-Level Waste – Joel Case • Transuranic Waste – J.R. Stroble/Alton Harris • Core Team membership comprised of DOE • Hdqtrs, DOE Field Reps and Contractor SMEs

3. Where We are Now DNFSB 94-2 Update DOE O 435.1 2010 CWR 1996 CWR >10 years of experience Issue DOE O435.1 1999

4. DOE O 435.1 Update Status • Project initiated in January 2009 by EM • Phase 1 - A complex-wide review (CWR) was initiated to capture best practices and areas of improvement from HQ and the Site federal and contractor organizations • Phase 2 – Update the Order using inputs from: • CWR • Federal and contractor (EFCOG) experts from HQ and Field • NRC, EPA, & IAEA regulations • Current national and international treatment, storage and disposal practices • Corporate Boards • Senior technical advisors from industry • stakeholders • Phase 3 – provide the updated Order in the new DOE O 251.1C format for review and comment

5. Chapter I - General Requirements • Roles and Responsibilities (overall) • Changes • FEM responsible for commercial exemptions • Comprehensive RWMB prepared by facility contractor and approved by FEM • Host state and state compacts notification regarding use of off-site and non-DOE facilities to be ensured by FEM • Additions • Field Element level Radioactive Waste Management Strategies to be prepared by facility contractors and approved by FEM • Institutional Control implementation and Control Plan to be prepared by facility contractor and approved by FEM

6. Chapter I - General Requirements • Roles and Responsibilities (overall) • Changes • FEM responsible for commercial exemptions • Comprehensive RWMB prepared by facility contractor and approved by FEM • Host state and state compacts notification regarding use of off-site and non-DOE facilities to be ensured by FEM • Additions • Field Element level Radioactive Waste Management Strategies to be prepared by facility contractors and approved by FEM • Institutional Control implementation and Control Plan to be prepared by facility contractor and approved by FEM

7. Chapter I - General Requirements • Requirements • Changes • Comprehensive Radioactive Waste Management Basis • Formal approved document reviewed biennially • Consolidated applicable requirements from all waste types • Contains treatment, storage & disposal requirements • Consolidation of waste (blending) • Graded approach • Unreviewed Waste Management Question Evaluation • Notification of and consultation with host state and state compacts regarding use of off-site and non-DOE facilities

8. Chapter I - General Requirements • Additions • Radioactive Waste Management Strategies • Prepared at DOE-wide and Field Element Level • Scope, mission, priorities, life-cycle, organizational roles & responsibilities, interfaces, etc • Institutional Controls • Passive controls – no more than several hundred years • IC implementation & control plan (public reviewed) • Cost estimate, transfer documentation, permanent markers • Reviewed on 5-year cycle

9. Chapter II - HLW • Roles and Responsibilities (specific to HLW) • Additions • NDAA 3116 responsibilities • Requirements • Changes • The definition of HLW was made consistent with the Nuclear Waste Policy Act of 1982. Sub-definitions for key terminology in the HLW definition such as: “Highly radioactive”, “Sufficient Concentrations”, “Reprocessing”, “Permanent Isolation” • Clarified waste incidental to reprocessing (WIR) citation process to enable sites to safely disposition equipment that previously came into contact with HLW.

10. Chapter II - HLW • Additions • Incorporate the process for tank closure under the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 Section 3116 (NDAA 3116).

11. Chapter III - TRU • Roles and Responsibilities (specific to TRU) • No significant changes • Requirements • Changes • Updated Management of Specific Wastes requirement to address classified TRU waste • Additions • RH/CH TRU waste packaging instructions • New Notice on TRU packaging instructions will be converted into a Technical Standard within the Order

12. Chapter IV - LLW • Roles and Responsibilities (specific to LLW) • No significant changes • Requirements • Changes • 90 day LLW staging requirement changed to “RWMB approved time limit” • PA water resources & intruder performance measures changed to performance objectives

13. Chapter IV - LLW • Additions • Probabilistically analyze compliance performance objectives (e.g. the peak of the mean or median of the results distribution, whichever is higher) • PA sensitivity/uncertainty analysis includes an assessment of peak impact within a period of 10,000 years. If the peak impact is not realized within 10,000 years, a qualitative assessment shall be performed from 10,000 years to the peak impact. • PA shall include an ecological risk assessment and systems evaluation (new facilities only) section

14. Chapter IV - LLW • Additions • DAS will require sites with PAs to have an unreviewed disposal question evaluation (UDQE). • CA performance objective of 100 mrem and an administrative limit of 30 mrem (previously in the Guide only) • PA critical assumptions must be protected in operational procedures • New section on “Waste Resulting from Environmental Restoration Activities” (Interface of CERCLA/ RCRA and DOE Order 435.1 requirements) • Requirements for insitu closure of radioactive facilities (e.g. reactors)

15. DOE O 435.1 – Technical Standards Addition • Update to include 2 new Technical Standards: • Disposal Authorization • Transuranic Waste Packaging • Compliance with these standards will be mandatory.

16. DOE O 435.1 – DAS Technical Standard • Applies to LLW, TRU disposed at individual sites, and CERCLA • waste disposal facilities • - Identifies the documents required for DAS issuance • - Required format and content for each document • - Independent review requirements • - Approval and issue process • - The maintenance and reporting requirements for a radioactive waste disposal facility • Consolidates “Rogue” Guidance and certain Low Level Waste Facility Federal Review Group guidance into one place • Organized in eleven chapters (Chapters 0 – 10)

17. DOE O 435.1 – DAS Technical Standard Chapter 0 - Introduction, Applicability, Scope and Table of Contents for the technical standard. Chapter 1 - Outlines the process for attaining a Disposal Authorization including reviewing, revising, maintaining and approving DAS and the associated technical basis documentation. Chapters 2 – 10 includes annotated outlines for format/ content and 435.1 compliance review criteria for the preparation of PAs, CAs, Closure Plans, Maintenance Plans, Monitoring Plans, UDQEs/UCAQEs, Annual Summary, Quality Assurance and Waste Acceptance Criteria.

18. DOE O 435.1 – TRU Packaging Tech Standard • Will be based on new DOE Notice 435.1 • Provides specific instructions for packaging and/or repackaging TRU waste. • Consolidates Remote Handled and Contact Handled packaging instructions. • Consistent with transportation requirements and WIPP programmatic requirements.

19. DOE O 435.1 – TRU Packaging Tech Standard • Highlighted Changes/Additions • Video and audio recording during packaging • Applicability of certification/characterization programs • Certain definitions • Exemption process • Grouping waste for packaging and/or repackaging

20. DOE O 435.1 Update Schedule • Fall/Winter 2011 • Complete technical updates and first draft of new Technical Standard • DOE General Counsel review • Informal cross-PSO and Field review • Spring 2012 • Continue discussions with stakeholders • Release updated DOE O 435.1 for public review • Summer 2012 • Formal DOE review through RevCom • Fall 2012 • Release final DOE 435.1 for use across the complex • Begin outreach and training to DOE and contractor staff