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DOE Order 435.1A Radioactive Waste Management Revision Project Update

DOE Order 435.1A Radioactive Waste Management Revision Project Update. Dennis Knapp. General Requirements Core Team Member Savannah River Nuclear Solutions, LLC ASP 2012 Workshop, Idaho Falls ID September 17 – 21, 2012. 435.1A Revision Overview.

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DOE Order 435.1A Radioactive Waste Management Revision Project Update

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  1. DOE Order 435.1A Radioactive Waste ManagementRevision Project Update DennisKnapp General Requirements Core Team Member Savannah River Nuclear Solutions, LLC ASP 2012 Workshop, Idaho Falls ID September 17 – 21, 2012

  2. 435.1A Revision Overview Revision provides format and content changes that bring 435.1A into compliance with DOE O 251.1C requirements - • improves consistency, provides clarification, specific outline defined Substantive format changes • Section 4 – Requirements (General, HLW, TRU, LLW) • Section 5 – Responsibilities (Secretary of Energy, PSOs, Asst. Secretary for EM, CTA, FEMs including NNSA) • Attachment 1 - Contractor Requirements Document • Attachment 2 - Definitions • Updated Radioactive Waste Management Requirement Guides (DOE G 435.1A-1, 2, 3, 4)

  3. Chapter I - General Requirements • New or Modified Requirements • Comprehensive Radioactive Waste Management Basis (RWMB) • Consolidated common requirements from all waste types • Contains treatment, storage & disposal requirements • Consolidation of waste (blending) • Unreviewed Waste Management Question Evaluation(UWMQE) • Off-site disposal exemption eliminated • Characterize waste for treatment and storage purposes and classify when prepping for disposal ( to preclude reclassification issues)

  4. Chapter II - HLW • New or Modified Responsibilities/Requirements • HLW definition made consistent with the Nuclear Waste Policy Act of 1982. • Includes National Defense Authorization Act for 2005, Section 3116 process • Clarified Waste Incidental to Reprocessing citation process • Assigns responsibility for those documents formerly under the Civilian Radioactive Waste Office

  5. Chapter III - TRU • New or Modified Requirements • Updated management of specific wastes requirement to address classified TRU waste • Incorporates current remote and contact-handled TRU waste packaging instructions (currently a DOE Notice approved August 2011) into a required Technical Standard • New notice on TRU packaging instructions is converted into a Technical Standard within the Order • Acceptance of Non-Defense TRU waste

  6. Chapter IV - LLW • New or Modified Requirements • 90 day LLW staging requirement changed to “RWMB approved time limit” • PA water resources & intruder performance measures changed to performance objectives • Merges current guidance and "rogue” guidance, e.g., LFRG Manual, Format and content guide into required Technical Standard for Disposal Authorization Statement Documents (DAS Technical Standard) • DAS will require sites with PAs to have an Unreviewed Disposal Question Evaluation (UDQE).

  7. Chapter IV - LLW New or Modified Requirements (cont.) • 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)

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

  9. DOE O 435.1A – 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 • Organized in eleven chapters (Chapters 0 – 10) • Chapter 0 - Introduction, Applicability, Scope and Table of Contents for the technical standard.

  10. DOE O 435.1A – DAS 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.

  11. DOE O 435.1A – 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.

  12. DOE O 435.1A – 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

  13. DOE O 435.1A Update Schedule • Summer 2012 - DOE General Counsel review - EFCOG WMWG review • Fall 2012 • Informal cross-PSO and Field review • Stakeholder/public review • Winter 2012 • Formal DOE REVCOM review • Winter 2012/Spring 2013 • Release final DOE 435.1A for use across the complex • Begin outreach and training to DOE and contractor staff

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