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Recap of the EFCOG Working Group meeting covering changes, new activities, and tasks on waste management and disposal strategies for DOE facilities.
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Waste Management Working Group FY2019 EFCOG Working Group Chair Meeting Renee EcholsFirewater Associates, LLC WMW Group Chair June 4, 2019
Summary • WMWG leadership positions have changed and subgroups and task teams have been realigned. • WMWG has new activities that require modification to the 2019 Work Plan. • New activities at the request of EM include: • Onsite versus Offsite methodology tool collaboration between DOE, prime contractors, and commercial providers • Challenging Waste Subgroup to provide a forum for waste disposition information sharing and development of disposition pathways • Support on Greater than Class C disposal rulemaking • Work plan modification will update ongoing tasks and finalize other tasks.
WMWG Mission and Scope • The WMWG’s purpose is to seek, promote, and communicate: • Complex wide waste management and transportation best practices; • Cost effective cradle to grave generation, treatment, and disposal; • Regulatory and disposal strategies; • Evaluate and share information on new technologies and capabilities for waste disposition.
2019 Annual Work Plan • Work Plan is being modified to include new activities, update ongoing tasks, and add new tasks that have developed since the beginning of the year; • Working to more closely align with DOE objectives; • Tasks that have been completed are being removed and tracked separately; • Resubmittal to BOD and DOE by end of June.
New Consolidated Subgroup • Challenging Waste Subgroup established: • EM’s top to bottom review - report to DOE EM 4.2 “Low-Level Waste/Mixed Low-Level Waste Initiative Report”. • Recommended sites expand collaboration for disposition of challenging wastes. • Continue identification and resolution of challenging wastes. • Incorporates Subgroups with similar missions - High Level Waste and National Lab Subgroups.
New Tasks • Onsite vs Offsite Disposition Analysis: • Model/methodology to assist with onsite vs offsite disposition decisions (validate cost comparisons). • SMEs from DOE, site contractors, commercial packaging/ transportation/ disposal companies, and NNSS. • Model will be used to run various waste streams anticipated from future D&D at Paducah Site. • Task completion goal Dec. 2019.
New Tasks Continued • Support for Greater than Class C disposal rulemaking: • Submitted draft white paper entitled “Greater than Class C Low-Level Waste Strategy White Paper” April 2019. • Suggested strategy supports development of a disposition pathway for GTCC LLW, GTCC-like LLW, and waste with certain TRU radionuclides exceeding 100 nCi/g. • Recommends DOE petition NRC to remove TRU exclusion language for LLW definition in upcoming revision to 10 CFR 61 (consistent with DOE’s final EIS - 02/16). • SMEs will provide support of disposition of non-defense TRU (West Valley) as needed.
Ongoing Tasks • Technical support for waste classification issues including WIR support. • Technical support to EM’s radioactive waste program including the Low-Level Waste Federal Review Group (LFRG), and LLW, TRU, and Tank Waste Corporate Boards. • Provide technical support and training for implementation of DOE Order 435.1 and its future revisions. • Technical support to EM’s packaging and transportation organization and NNSS.
Ongoing TasksContinued • Support technical standard for consistent methodologies for surface contaminated dry active waste characterization. • Technical, regulatory and program support for D&D activities to ensure efficient generation and disposition of wastes from these activities. • Support update to the Tank Integrity Program (DOE Order 435.1A) for current technology. • Technical PA/CA support for Portsmouth Onsite Disposal Cell through LFRG.
Accomplished Tasks • P&T subgroup issued lessons learned on waste transportation incidents and issues. • D&D subgroup issued Cold and Dark Best Practice for deactivation of facilities using state of the art practices. • Completed LFRG PA/CA review of the Portsmouth Disposal Cell with recommendations on Technical Basis documents. • Gained approval of a Project Justification facilitating Technical Standard for characterization of LLW.
Accomplished Tasks Continued • Provided support to West Valley on WIR determination of spent fuel cuttings and vit cell wastes. • Issued recommendations report to EM as part of their radioactive waste program top to bottom review. • Provided challenging waste and technology gap information to National Academy of Science review. • Provided letter of support and technical rationale for EM’s clarification of the HLW definition. • P&T subgroup issued report on Return to Service radiological contamination limits for commercial equipment.
Accomplished Tasks Continued • National Lab subgroup issued a Best Practice for “Stakeholder Engaged Structured Decision Making” for early and timely collaboration on waste generation. • Provided Order 435.1 training at HQ, LANL, and Hanford. • Provided recommendations to NNSS RWAP on waste acceptance process improvements.
Meetings • Minimum of 3 working meetings per year: • WM19 – Phoenix, AZ – March 2019 successful meeting included attendance and participation of EM-1, DOE sponsors, and BOD sponsor; • DOE Cleanup Workshop - Alexandria, VA - Sept. 2019; • Perma-Fix Generator Conference – Nashville, TN – Dec. 2019 • Subgroup working meetings: • Packaging & Transportation – WM19, and CTMA. • Disposal Model Task Team – NNSS Workshop, Radwaste Summit • Challenging Waste subgroup – Cleanup Workshop, TBD • Monthly conference calls.