Waste Management Working Group
Waste Management Working Group
FY2018 Annual Work Plan
October 2016
Final
September 18, 2017
Working Group Mission and Scope
The Waste Management Working Group (WMWG) is chartered to leverage the expertise and experience of contractors to the DOE. The purpose of the WMWG is to seek out and promote the best management and operating practices, cost effective technologies and disposal options for all waste streams generated at DOE facilities whether destined for DOE or commercial facilities. The WMWG will be focused on complex wide integration and technology transfer while supporting cost effective and efficient waste options. This will be achieved in a way that enhances complex wide communication and maintains a priority on safety, environmental stewardship and security. The scope of the working group includes cradle-to-grave waste management considerations including waste generation, especially from all DOE activities including facility deactivation & decommissioning (D&D) programs.
In addition to the overarching main Nuclear Waste Management focus of the WMWG, the WMWG incorporates the efforts of four technical Sub-groups.
National Laboratory Subgroup
Tank/High Level Waste Subgroup
Packaging & Transportation Subgroup
Decontamination & Decommissioning (D&D) Subgroup
Working Group Main Focus Areas in 2017
a. Provide continued technical support concerning Waste Classification issues across the DOE Complex. This Focus was generated from discussion at the Workshop held in conjunction with the Radwaste Summit, entitled “During WIPP Shutdown, Develop Options and Alternatives for the Transuranic Waste Inventory Across the DOE Complex.” Now that WIPP is operational again, this effort is even more significant to ensure WIPP capacity is maintained compliant with regulatory requirements (i.e., received wastes meet the WIPP Waste Acceptance Criteria and the appropriate use of DOE Order 435.1 Waste Incidental to Reprocessing [WIR] for certain wastes), and is used efficiently. Proper Classification for disposal after actions/treatment for safety and technical reasons to ensure waste is safely disposed in a cost-effective manner remains extremely important.
b. Provide continued support to the radioactive waste program (including the Low-Level Waste [LLW] Federal Review Group [LFRG], LLW Corporate Board, Transuranic [TRU] Waste and Tank Waste Corporate Boards). Included in this support is assistance with EM’s Top to Bottom Macro Assessment of the Low-Level Waste/Mixed Low-Level Waste (LLW/MLLW) Program for sites around the complex, which is a required by DOE Order 435.1. This support includes surveying sites to identify potential waste management Issues, future treatment and disposal needs and opportunities for integration to address programmatic problems. In the Tank Waste area, provide technical assistance to the Office of River Protection (Hanford) for the WIR Evaluations and Integrated Disposal Facility (IDF) Performance Assessment (PA) as a result of the High-Level Waste (HLW) WIR Lessons Learned Workshop conducted at the 2013 Waste Management Symposium.
c. Provide technical support for the completion, response to comments, implementation and training associated with DOE Order 435.1 and future Revisions (Radioactive Waste Management) with a focus on LLW disposal technical standards, consolidation, waste classification, and waste incidental to reprocessing. Provide technical support in development and the conduct of Assist and Assessment visits to DOE Complex Sites.
d. Provide continued technical support to EM’s Packaging and Transportation (P&T) organization. Focus on completion of the evaluation of “return to service” radiological contamination clearance limits for commercial equipment that has transported DOE materials to a DOE facility or commercial disposal facility. Provide technical support and impact review for the development of overall performance standards for use by DOE sites when conducting rad clearance surveys on commercial transporter equipment and vehicles. Coordination of this Focus Areas will include support to the Contractors Transportation Management Association (CTMA) and will incorporate a P&T Lessons Learned Program.
e. Provide technical inputs for mechanisms to facilitate early collaboration among National Laboratories for challenging new waste streams. Develop and publish process for sustainable structured decision analysis. In addition, investigate standards for waste characterization.
f. Provide continued technical, regulatory, and program support to Decontamination and Decommissioning (D&D) activities across the complex with emphasis on improvement of the integration of program and project management for D&D, integration of regulatory structures and authorities, safety requirements, and stakeholder concerns that may affect the efficient and effective generation, treatment, and disposal of radioactive waste from these activities.
WMWG Planned Activities for FY 2017
Activity / Benefit / Deliverable/Key Milestone(s) /1.0
1.1 Continue to assist DOE in the evaluation of realistic “return to service” radiological contamination limits for commercial equipment that has transported DOE wastes to a DOE disposal facility including the DOT HM 250 rulemaking. / Consistent Application of DOE Release Criteria vs DOT Return to Service Limits Results in Cost Savings and reduces Contamination Incidents - $160K per incident and a history of over 10 incidents per year results in cost avoidance of $1.6 Million per year. / 1.1.1 Evaluate impacts of the implementation of the DOE proposed “clearance” criteria as it relates to the release of commercial transport equipment as well as reusable containers including who and how costs for release surveys may be covered.
1.1.2 As a result of the report. “Return to Service Impacts for Non-DOE Owned Transport Conveyances” dated June 21, 2016, provide assistance to DOE as DOE works to implement the EFCOG report recommendations.
2.0
2.1 Develop overall performance standards for use by DOE sites when conducting rad clearance surveys on commercial transporter equipment and vehicles. / In conjunction with #1 above, develop a performance standard for Rad acceptance and release surveys that will reduce the number of contamination incidents holding commercial equipment at DOE sites for decontamination (in coordination with the EFCOG Safety Working Group). / 2.1.1 Issued Best Practice in FY2016 #190 dated 4/1/2016 “Non-DOE Owned Transport Equipment Return to Service Inconsistencies.” Plan is to provide assistance and react to DOE and Contractor Implementation questions and/or training. (in coordination with the EFCOG Safety Working Group Rad Protection Subgroup).
3.0
3.1The EFCOG Chair or his/her representative will provide technical support to and attend scheduled meetings of the DOE Corporate Boards (LLW, Tank Waste, TRU), the Contractors Transportation
Management Association(CTMA), and the Low-Level Waste Federal Review Group (LFRG) / In providing technical and regulatory consultation to the DOE Corporate Boards, the LFRG, and CTMA allows the EFCOG WMWG to stay abreast of the issues facing DOE and provide immediate advice and longer term assistance as DOE determines the need for continued EFCOG involvement on selected issues. / 3.1.1 Attendance at each of the four Corporate Board meetings, CTMA and LFRG, and report on EFCOG progress in addition to the expectation of requests for additional EFCOG assistance on specific issues.
4.0
4.1 Provide technical input to DOE/HQ regarding NRC’s performance-based revision to 10 CFR 61 as it affects LLW disposal performance requirements. / NRC has been tasked by the Commissioners to modify 10 CFR 61 for LLW disposal requirements to make this rule more performance based, site specific, and have waste acceptance criteria that reflects the Performance Assessment. NRC is working with DOE to understand how DOE accomplishes this through DOE Order 435.1 and, as a result, the EFCOG continues to provide technical and regulatory assistance in document preparation and presentation material as well as attending public meetings. / 4.1.1 Expect to provide specific recommendations to DOE-EM to assist in formal comments to the NRC on the 10CFR61 proposed rule. Additionally, impacts to DOE LLW disposal regulations and guidance will be identified.
5.0
5.1 Provide technical support for the completion, response to comments, implementation and training associated with revised DOE Order 435.1 (Radioactive Waste Management). Specific focus will be in the areas of LLW Disposal, Consolidation, Waste Classification, Waste Incidental to Reprocessing, and the Spent Fuel definition. Also, included in this task is the continued management of the EFCOG Waste Classification Library. / The EFCOG contractors benefit directly by providing consultation to DOE in setting requirements for radioactive waste generation, treatment, storage and disposal. For example, Consolidation and Classification (wording of requirement and guidance provided by the WMWG) requires that compatible waste types be combined to reduce cost of disposal (LLW vs. TRU) and improve safety of handling waste by no longer requiring segregation. A managed, treated, or processed waste should be dispositioned at the lowest classification technically defensible. For example, the National TRU Waste Management Plan, Rev 1, (8/2013) indicates that over 8,000 m3 of TRU waste is stored in the DOE Complex as potential TRU waste for WIPP disposal. If only 10% of that inventory were to be managed, treated, processed, or dispositioned as LLW, a savings of over $6 million would be achieved. Further savings, not included here, will be realized from avoiding the generation of TRU waste through use of Consolidation techniques. (See #12 for WIR benefits.) In addition, correct Classification of items such as spent fuel cuttings resulting from preparation for reprocessing and waste from experimental/tests of spent fuel should be properly classified as LLW or TRU for proper disposal and saving costs. / 5.1.1 Expect to provide specific recommendations and draft wording for requirements, definitions, and guidance to DOE-EM. Assist in response to reviews from other DOE offices including General Council. Training and implementation strategy will also be recommended. This will include assistance with expedited review of the latest revisions prior to issuance of the draft order for public review.
5.1.2 Expect to develop and provide LLW Disposal requirements training to the DOE LFRG.
5.1.3 Expect to assist in implementation of the Technical Standard Guidance for Disposal Authorization Statements and Tank Closure approved 5/3/2017 by Robert Seifert.
5.1.4 Expect to Develop Training and provide DOE O 435.1 Training to DOE sites. Expect to develop assists/assessments program for DOE O 435.1 to contractors and DOE staff around the complex (first sites were LANL, DOE-HQ, and Nevada). Expect to participate in Assist Visits around the complex. Expect to participate in training around the complex (Hanford per EFCOG, other sites require additional funding)
6.0
6.1 Provide technical inputs and interface with DOE regarding the implementation and deployment of the Automated Transportation Logistics Analysis System (ATLAS) software product that replaces the currently used Automated Transportation Management System (ATMS) software product. / The EFCOG team is working to develop, beta test and encourage use of the system across the DOE complex. Use DOE wide is expected to save more than $1.5 million per year in cost reductions from the use of government tenders and pre-payment audits alone. / 6.1.1 Expect to participate in beta test and implementation to provide specific recommendations and Guidance to DOE-EM. Assist in response to implementation issues.
7.0
7.1 Develop and document two additional Best Practices. / 7.1.1 A Best Practice is expected to be developed from Task #8. A second Best Practice is expected as well from other activities.
8.0
8.1 Provide approach to ensure technical inputs to facilitate early and timely collaboration among National Laboratories for managing challenging new waste streams. Develop and publish process for sustainable structured decision analysis. / The result of this effort is to develop a set of guidelines and a tool kit for waste managers at National Laboratories to have a "catalog of diverse solutions “before” generation of problematic waste streams using Decision Analysis. This is intended to provide Laboratory researchers and generators with the DOE complex’s available expertise and experience in development of disposition path guidance rather than reacting to a waste problem. These efforts could compensate for the lack of resources at small waste generator laboratory sites. Providing these tools to Laboratory waste managers will reduce the need for more resources, reduce waste inventories in storage and reduce costs for waste disposition. / 8.1.1 Expect to develop a best practice in FY2018. Assist in response to implementation issues
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 other 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 Order 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 authorize and operate LLW Disposal Facilities. / 10.1.1 Expect to provide specific recommendations and draft 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 .
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 HECfloor 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.