resources, reduce waste inventories in storage and reduce costs for waste disposition. 9.0 9.1 Develop update to the Tank Integrity Program requirements and guidance to update DOE Order 435.1A in concert with the Tank Waste Corporate Board. Additional work to develop a technical basis for the current program is being explored as well. This is expected to require additional funding. The Tank Integrity Program requirements in the current DOE Order 435.1 are out of date and inconsistent with the current state of the technology. Further, the Hanford Site HLW tank program must inform the State of WA regulators that they will not follow DOE Order requirements because of this inconsistency. This could be of considerable concern for the State and other stakeholders. The WMWG is assisting DOE in updating the requirements and guidance to make them consistent with current technology. Incorporating consistent, state of the art technology in the DOE Order 435.1 Requirements and Guidance for HLW Tank integrity programs will advance the safety of tank systems and strengthen the technical integrity of the DOE required program for the entire complex. 9.1.1 Expect to provide specific recommendations and draft wording for requirements, definitions, and guidance to DOE-EM in FY18. 10.0 10.1 Provide technical support and consultation to the Portsmouth Onsite Disposal Cell PA/CA LFRG Review for Disposal Authorization and future DOE LLW disposal activities at DOE sites in the future (e.g. Paducah, Oak Ridge, Hanford IDF). The LFRG is made up of Federal officials that are responsible to review technical documents, required by DOE 435.1, that provide DOE authorization of LLW disposal in DOE owned LLW disposal facilities. By the WMWG providing technical and regulatory consultation to the LFRG review , DOE is able to utilize additional resources that have years of Performance Assessment, Composite Analysis, key technical basis document preparation, and Operational experience to 10.1.1 Expect to provide specific recommendations and wording for Disposal Authorization Technical Basis Documents, definitions, and guidance to DOE Portsmouth and Oak Ridge in FY18. Carry that expertise into the reviews of Paducah, Oak Ridge, Idaho and Hanford .
authorize and operate LLW Disposal Facilities. 11.0 11.1 Provide Technical assistance to West Valley’s Waste Classification of spent fuel cuttings and vitrification cell/off-gas materials to enable disposition as TRU or LLW. Also Assist in modification of WIR Citation Procedure as needed. The cost savings will be considerable since the alternative approach will be to classify these waste streams as Spent Fuel and HLW. If this waste is not examined to determine its actual classification and defaults to Spent Fuel or HLW, there is currently no disposition path for this waste. This waste consists of 79 30-gal drums of vitrification facility materials (about 320 cubic feet or 9 cubic meters, not considering overpacks) and over 300 30-gal drums of HEC floor debris (about 35 cubic meters). 11.1.1 Expect to provide specific recommendations and draft wording changes to the Classification Documentation as a result of WIPP and General Council Reviews for DOE-EM and West Valley in FY18. Expect to provide assistance in WIR Citation modification as needed. 12.0 12.1 Provide continued support to the Office of River Protection (Hanford) and DOE HQ for the Waste Incidental to Reprocessing (WIR) Evaluations and Integrated Disposal Facility (IDF) Performance Assessment (PA), other technical basis documents, and Idaho Waste Determination Documents as a result of the High-Level Waste (HLW) WIR Lessons Learned Workshop conducted at WM13. The cost savings due to implementation of the lessons learned in interaction between NRC, DOE and the States are difficult to quantify as the end product of this work is methods, guides, and lessons learned. The goal is to reduce the review time of each organization and significantly reduce the rework of regulatory documents resulting in HLW Tank closures. A conservative estimate of the accomplishments and activities exceeds $5-10 million across the complex. 12.1.1 Expect to provide specific recommendations and draft wording for the WIR Evaluation, Radioactive Waste Management Basis (RWMB), the IDF PA, Technical Basis Documents, and the Idaho Waste Determination in FY18. 13.0
program. Further having independent reviews of waste profiles and assessments for waste generator compliance to the NNSS WAC is intended to increase confidence. and consultation on the verification program. 16.0 16.1 Safety Basis Analysis and process for D&D and remediation (particularly for soil) difficult and not standardized. The use of fixatives, agents, etc. and how they interface with existing Safety Basis requirements. The WMWG D&D Subgroup formed a Team and partnered with the Safety Working Group to participate with DOE to revise and review DOE STANDARD 1120-2005 INTEGRATION OF ENVIRONMENT, SAFETY, AND HEALTH INTO FACILITY DISPOSITION ACTIVITIES. DOE STANDARD 1120-2016, PREPARATION OF DOCUMENTED SAFETY ANALYSIS FOR DECOMMISSIONING AND ENVIRONMENTAL RESTORATION ACTIVITIES, was issued in March 2016 as a significant revision to DOE STANDARD 1120-2005. As a follow-on activity, the WMWG D&D subgroup will again partner with the Safety Working Group to evaluate the effectiveness of the revision particularly with the implementation of various D&D techniques across the complex, the application of graded approach principles, and facility hazard categorization and downgrading. The intent is to continue partnering with the Safety Working Group to ensure that the revised DOE requirements are protective of the workers and the public, but at the same time are implementable in a manner that will allow efficient, effective Decommissioning and Environmental Restoration. 16.1.1 Expect to continue to support implementation of DOE STANDARD 1120-2016 that will allow D&D Projects to proceed safely and successfully. Share lessons learned, D&D methods, processes and procedures and how they were implemented within the guidelines of DOE STANDARD 1120-2016 including implementation of graded approach principles and hazard categorization step-out criteria as hazards were eliminated. 17.0
17.1 Process for taking a facility Cold and Dark and requirements for maintaining Life Safety Codes until just prior to Demo ready. A Graded Approach needs to be taken allowing a less stringent set of code compliance. Example is maintaining the fire protection system active right up until Demo ready. A consistent approach to achieving Cold and Dark status in preparation for Demolition will benefit the DOE through the application of common processes and techniques. The expected result is anticipated to yield cost reductions to D&D projects and more flexibility in deactivating facilities (reducing S&M costs while the facility awaits demolition). The WMWG D&D Subgroup will conduct research across the DOE sites to determine standards and methodologies in use for conducting Cold and Dark Activities. A draft DOE Technical Standard will be prepared during FY2018 for complex-wide review and comment. 18.0 18.1 The WMWG National Laboratory Subgroup will continue to develop consistent methodologies for characterization of dry active LLW (debris, LSA, SCO). methodologies could be implemented through issuance of a DOE Technical Guide for characterization of surface contaminated LLW. DOE has requested that the WMWG coordinate this important activity. The expected result is to introduce consistency for characterization of LLW among National Lab sites (and possibly other EM sites). Implementing consistent guidance on methodologies, techniques, procedures and documentation can result in cost savings and improve accuracy of or validate waste characterization activities. 18.1.1 Expect to conduct research DOE sites to determine standards and methodologies in use. A draft DOE Technical Standard will be prepared during FY2018 for Complex-wide review and comment. 19.0
19.1 The WMWG Packaging & Transportation Subgroup will collect and compile relevant waste transportation incidents and issues r to produce a summary of lessons learned. Inputs will be collected by P&T members as well as through soliciting inputs from CTMA, the TMC, HQ Occurrence Reports, and from NNSS waste generators. Emphasis will be placed upon highlighting recent transportation activities that have resulted in corrective actions by waste generators – resulting in development of a lessons learned summary that is applicable to multiple sites and generators. The expected benefit will be to generate a summary of recent lessons learned that can be used in planning waste transportation activities while ensuring that those activities meet all applicable DOT and DOE requirements. Implementing consistent and compliant methodologies, techniques, procedures, and documentation should result in reduction in delays from and cost savings due to their avoidance. 19.1.1 Expect to initiate collection of relevant transportation incident/issues data - with data compilation and Lessons Learned Summary to be posted by December 2017. 20.0 20.1 In accordance with DOE O 435.1, assist the DOE Office of Waste Disposal (EM 4.22) with their macro assessment of DOE’s LLW/MLLW management activities. Identify potential issues and opportunities for integration. The initial activity requested is to survey all major sites and submit survey results to HQ. To ensure that DOE HQ is of potential programmatic issues with disposition of wastes (e.g., onsite disposal site development, D&D waste generation); ability to disposition problematic waste streams; understand if new technologies are needed to address disposition; and, ensure there is information sharing for disposition of consistent waste streams across the complex. The initial effort involved generating a survey that be distributed to major sites and a few minor sites. Surveys were sent to prime contractors – UCOR, CHPRC, Fluor Paducah, Fluor Portsmouth, SRNS, LANS, CHBWV, and Fluor Idaho. 100% of surveyed sites provided responses by June 2017, which were submitted to DOE HQ. The WMWG provided an analysis of the survey responses at the National Cleanup Workshop in Sept. 2017. As a result, the EFCOG Director Sponsor recommended and DOE agreed that one or more workshops should be conducted with the sites selecting the 1 or 2 most problematic waste streams or issues for review and analysis. The subject matter experts on theses wastes or issues should be present to discuss and design a path forward for each one.