2013 ASP Workshop & DOECAP Meeting

1. 2013 ASP Workshop & DOECAP Meeting Facility Closure Audits Joe Pardue, DOECAP Operations Team Laboratory Lead, Pro2Serve, Inc. September 26, 2013

2. Facility Closure Audits All subcontract facilities receiving radiological materials from DOE sites assume a liability for the safe handling, storage, and disposal of all radiological materials and derived wastes.

3. Facility Closures Due to a variety of reasons, a certain number of commercial facilities cease operations. To protect the interests of the DOE contract holders and to minimize any liability to DOE, DOECAP conducts a closure audit of all facilities that are receiving or have received radiological material from a DOE site.

4. AD-1 Closure Audit AD-1 requires: A closure audit must be performed to verify the satisfaction of contractual requirements, including satisfactory disposition of DOE material, at a facility not intended for future use.

5. AD-1 Closure Audit The criteria for successful completion of a closure audit are: • Determination that contractual requirements have been satisfied; • Verification of satisfactory disposition of DOE material/waste; and • Verification of archival or other appropriate disposition (e.g., transfer to DOE) of quality documents and records (e.g., standard operating procedures, logbooks, electronic data, certificates of disposal) associated with work performed for the DOE.

6. Facility Closure Plan • Detailed plans for waste management. • Record archival (hard copy and electronic). • Database archival. • Organizational responsibilities for closure.

7. Documents and Records • Written policy for disposition of records. • All documents must be retained for a minimum of 5 years. • All revision of procedures will be archived. • The facility must have plan for the archival of all accountable documents (logbooks, chain-of-custody records, and all other documents related to sample receipt, analysis, and disposal.

8. Documents and Records (cont.) • The facility must develop a plan to submit all final reports to their DOE clients.

9. Waste Management • All containerized waste must be itemized. • All liquid waste must be itemized. • A waste disposal plan and schedule must be developed. • All sample must be itemized and a disposal path identified. • The closure audit will include an inspection of all RCRA units.

10. Waste Management (cont.) • Waste manifests must be retained for all the disposal of all DOE samples and for all waste disposition activities.

11. Facility Security Facility security must be maintained until all records are archived and all waste disposed.

12. Software Documentation • All versions of software programs, with the dates that the software was placed into service or removed from service must be maintained by the facility. • All software records will be retained in accordance with Good Automated Laboratory Practices.

13. Documentation • Completed checklists and a formal audit report will be developed for all closure audits. • The audit report will be distributed to all points of contact. • The audit report for the closure will be maintained in the DOECAP Electronic Data System.

14. Lack of Financial Resources • There have a few cases where the facility does not have the resources to complete the required closure activities. • At that point, the liability for the closure falls back to DOE and the sites that have sent radiological material to the facility.

15. Path Forward • In addition to closure audits of laboratory facilities, closure audits of TSDFs that cease operation will be conducted in the future.

16. Questions