Radioactive Waste Management Program

Draft 3/16/2006

FUNCTIONAL AREA GOAL: The Department of Energy and its contractors are establishing and maintaining an integrated complex-wide radioactive waste management program for high-level waste (HLW), transuranic (TRU) waste, low-level waste (LLW), or mixed low-level waste (MLLW) to protect the workers, public, and the environment. These programs shall use a systematic approach of planning, documenting, execution, and evaluation to ensure that waste generation, storage, treatment, and disposal needs are met and coordinated across the DOE complex.

The Department of Energy is providing effective Federal oversight to ensure it fulfills its radioactive waste management program roles and responsibilities within its programs and its operations.

REQUIREMENTS:

DOE P 226.1, Department of Energy Oversight Policy
Public Law 102-579, WIPP Land Withdrawal Act of 1992, as amended
Atomic Energy Act of 1954, as amended
DOE Order 435.1, Radioactive Waste Management
DOE M 435.1-1, Radioactive Waste Management Manual
Office of Civilian Radioactive Waste Management Quality Assurance Requirements Description (QARD), DOE/RW-0333P
Office of Civilian Radioactive Waste Management Waste Acceptance System Requirements Document (WASRD), DOE/RW-0351
Office of Civilian Radioactive Waste Management Integrated Interface Control Document (IICD) Volume 1, DOE/RW-0511
Office of Civilian Radioactive Waste Management Civilian Radioactive Waste Management System Requirements Document (CRD), DOE/RW-0406
Waste Acceptance Product Specifications for Vitrified High-Level Waste Forms (WAPS), Revision 2, DOE/EM-0093, December 1996
Nuclear Waste Policy Act 1982, as amended.
Disposal of High-Level Radioactive Wastes In a Geologic Repository at Yucca Mountain Nevada 10 CFR 63
Nuclear Waste Policy Act of 1982, as amended
Licensing Requirements For Land Disposal of Radioactive Wastes, 10 CFR 61
Section 3116 of the National Defense Authorization Act for Fiscal Year 2005
DOE/WIPP-02-3122 Rev 4.0 Contact-Handled Transuranic Waste Acceptance Criteria for the Waste Isolation Pilot Plant - Rev 4.0, December 29, 2005
DOE/CBFO-94-1012, Rev 7, Quality Assurance Program Document, July 2005
Reference Chapter 1 of DOE M 435.1,1.E. for additional requirements

GUIDANCE:

DOE Low-Level Waste Disposal Facility Federal Review Group Manual, Rev 1, November 1999
DOE G 435.1-1, Implementation Guide for use with DOE M 435.1-1

Performance Objective 1: Contractor Program Documentation

DOE line management have established and implemented effective oversight processes that evaluate the adequacy and effectiveness of contractor work control processes.

1.1 Site-Wide Radioactive Waste Management Programs: Developing, documenting, implementing, and maintaining a Site-Wide Radioactive Waste Management Program using a systematic approach for planning, executing, and evaluating the site-wide management of radioactive waste in a manner that supports an integrated Complex-Wide Radioactive Waste Management Program.

Criteria:

Sites have developed and documented Site-Wide Radioactive Waste Management Programs that are clearly defined and describe and document the rationale to accomplish the site-wide program goals, objectives, and milestones.
A systematic approach for planning, executing, and evaluating the site-wide management of radioactive waste facilities is applied and the significant constraints and assumptions are documented.
Program addresses all of the site's radioactive waste, including any off-site radioactive waste managed by the site, and all phases of the life-cycle of the waste.
Waste projections are implemented by the site-wide programs and the methodology used in developing the data is documented.
The Field Managers are responsible for the management of radioactive waste in a safe, effective, and efficient manner.
Activities are integrated, coordinated, and support integrated site-wide and complex-wide goals and objectives and progress is measured and evaluated.
The site-wide program provides personnel with an understanding of the site's radioactive waste management needs and strategy and the organizational responsibilities and the facilities and methods that will be used by the site to meet those needs.
Feedback is provided for continued improvement of the management of radioactive waste.

1.2 Radioactive Waste Management Basis: Ensure a radioactive waste management basis is developed and maintained for each DOE radioactive waste management facility, operation, and activity and ensure that review and approval of the basis before any operations begin. The basis shall reference or define the conditions under which a facility may operate based on radioactive waste management documentation; include the applicable elements identified in the specific waste-type chapters of DOE M 435.1.1; and be developed using the graded approach process.

Criteria:

The hazards associated with radioactive waste management facilities, operations, and activities have been identified, their potential impacts systematically analyzed, and appropriate controls documented, implemented, and maintained for the protection of workers, the public, and the environment by development and approval of an authorization basis for a Category 1, 2, and 3 radioactive waste management facility (currently there are no Category 1 facilities).
Other facilities that are not Category 2 or 3 have an Auditable Safety Analysis or a DOE or contractor established interim safety basis for facility operation such as a Basis for Interim Operations. Review of the existing programs and documentation is conducted for their adequacy in providing the controls needed to meet DOE M 435.1-1 or determine if additional documentation is need to meet the requirements of the DOE 435.1 order and manual.
DOE staff reviews and approves the radioactive waste management basis for each radioactive waste management facility under the Field Manager's responsibility so that there are adequate controls to manage radioactive waste in accordance with the requirements of DOE Order 435.1 and DOE M 435.1 and that the facility is authorized to manage radioactive waste. Review and approval must occur before operations begin.
The basis is documented for all radioactive waste management facilities, activities, and operations; i.e., that it includes the specific programs, processes, and documents that represent implementation of critical radioactive waste management controls which are primarily based on DOE M 435.1-1 requirements.
The radioactive waste management basis is reviewed periodically and whenever there is a change to the subject facility, operation, or activity, or the requirements of DOE O 435.1 or DOE M 435.1-1.

1.3 Site Closure Plans: Ensure that closure activities for deactivated high-level waste facilities/sites do not proceed prior to the review/approval of the site closure plans.

Criteria:

Closure plans define and bound the parameters of a closure action.
A credible independent bounding review is conducted by DOE to include a HQ technical review of a Tier 1 Closure Plan to include the determination of the adequacy of the analyses (assessment of projected performance and composite performance of each unit to be closed and composite performance of all the units; e.g., individual tanks to ultimately be closed as part of the site.)
Closure plans are updated periodically, as determined by the Field Office Manager, to reflect revised analysis and the status of individual facility closure actions that are part of a site closure.
An EM Authorization to Proceed with Closure is provided to the responsible Field Office Manager which constitutes EM-HQ approval of the site closure plan and other closure documents as adequately representing and assessing the closure action plan.
A Site-Manager approved Tier 2 Closure Plan is issued after Authorization to Proceed with Closure is obtained, to ensure closure of a specific unit is within the bounds of the Tier 1 Plan.
Closure plans are implemented properly at the sites, during operations and through final closure, and in accordance with the applicable requirements in the waste-type chapters of DOE M 435.1-l.

Performance Objective 2: Contractor Program Implementation

2.1 Qualifications and Training: Ensure that a training and qualifications program is implemented for designated radioactive waste management program personnel, and the training is commensurate with job duties and responsibilities. Only those personnel who have been trained and qualified shall design or operate safety (safety class and safety significant) structures, systems, and components.

Criteria:

There is a formal system for tracking and documenting personnel training and/or qualifications to ensure all workers possess the knowledge, skills, and technical abilities required to perform the assigned work and training records are current.
Adhere to the requirements specified in DOE 5480.20A, Personnel Selection, Qualification, and Training Requirements for DOE Nuclear Facilities and DOE O 360.1, Training.
There is documentation that Federal technical employees who provide management direction or oversight are in compliance with the Technical Qualification Program in DOE O 360.1.
Workers (including subcontractors) are trained to understand the hazards associated with their work, the safety significance of the controls provided to protect them from the hazards of radioactive waste, and the importance of working within/adhering to the controls.
Personnel are trained on activity level work radioactive waste management planning and control processes and understand how their function contributes to and integrates with the processes.
Personnel possess the knowledge, skills, and technical abilities required for performing assigned work.

2.2 Implementation of Radioactive Waste Management Program: An integrated and documented complex-wide radioactive waste management program is in existence for HLW, TRU, LLW, or MLLW to protect the workers, public, and the environment.

Criteria:

The top-level functions for planning or formulation, execution, and evaluation, are defined and the split of functions between HQ and the Field is clearly delineated.
The site radioactive waste management program addresses each appropriate waste type and is defined in the terms of scope, mission, goals and objectives, priorities, and interfaces consistent with guidance provided by Headquarters.
For strategic planning purposes, systems are in place to collect and maintain data on inventories of waste and estimate of future waste receipts is collected to compare with current and projected facility capacities and to determine the strategy for meeting current and future waste management needs.
Ensure that National Environmental Policy Act (NEPA) analyses are performed to support waste management activities.
Maintain cognizance of the activities and funding for waste management being requested by other Program Offices to ensure waste management activities are integrated.
Perform the studies and analysis that form the basis for resolving issues and conducting future planning.
Evaluate the work accomplished during the execution phase of the radioactive waste management program, measuring progress against established programmatic goals/metrics.

2.3 Approval of Exemptions for Use of Non-DOE Facilities: DOE radioactive waste shall be treated, stored, and in the case of low-level waste, disposed of at the site where the waste is generated, if practical, or at another DOE facility. If DOE capabilities are not practical or cost-effective, exemptions may be approved to allow use of non-DOE facilities for the storage, treatment, or disposal of DOE radioactive waste; however, only when it is in the best interest of the DOE and protective of the public, workers, and the environment.

Criteria:

There is a formal process for approval of exemptions for use of non-DOE facilities that: 1) complies with applicable Federal, State, and local requirements; 2) has the necessary permit(s), license(s), and approval(s) for the specific waste(s); and 3) is determined by the Field Manager to be acceptable based on review conducted annually by DOE.
Documentation exists for determinations for use of non-DOE facilities. The documents show how us of non-DOE facilities are cost-effective and in the best interest of DOE, including consideration of alternatives for on-site disposal, an alternative DOE site, and available non-DOE facilities; consideration of life-cycle cost and potential liability; and protection of public health and the environment.
DOE waste was sufficiently characterized and certified to meet the facility's waste acceptance criteria.
Appropriate NEPA review is completed. For actions taken under CERCLA, make sure NEPA values are incorporated into the CERCLA documentation.
DOE HQ is notified of any exemption allowing use of non-DOE facility for disposal (program office and EH).
Host states and state compacts where the non-DOE facilities are located were consulted prior to approval of the exemption to use the facilities.

2.4 Environmental Restoration, Decommissioning, and Other Cleanup Waste: Ensure the management and disposal of radioactive waste resulting from environmental restoration activities, including decommissioning, meet the substantive requirements of DOE 0 435.1 and its manual. Environmental restoration activities using the CERCLA process (in accordance with E. O. 12580) may demonstrate compliance with the substantive requirements of DOE O 435.1 and its manual through the CERCLA process. Environmental restoration activities that result in off-site management and disposal of radioactive waste must meet the applicable requirements of DOE O 435.1 and manual.

Criteria:

Certification is submitted to EM-1 that compliance with the substantive requirements of DOE O 435.1 have been met through application of the CERCLA process.
A crosswalk between CERCLA and the DOE M 435.1-1 requirements was prepared and reviewed when the cleanup action involved development and management of a radioactive waste disposal facility. (A sample crosswalk is included in DOE M 435.1-1.)
When the CERCLA process was used to plan for onsite disposal of CERLCA waste, that compliance with the objectives of DOE M 435.1 was documented.
A decision document was submitted that serves as an authorization to dispose; i.e., Record of Decision.

2.5 High-Level Radioactive Waste Special Requirements: The DOE Office of Civilian Radioactive Waste Management (OCRWM) Waste Acceptance System Requirements Document (WASRD) specifies and documents technical requirements for the acceptance and disposal of HLW by the U.S. Department of Energy's (DOE) Civilian Radioactive Waste Management System (CRWMS). These WASRD requirements consist of international, national, and internal CRWMS requirements that are derived from the Civilian Radioactive Waste Management System Requirements Document (CRD), DOE/RW-0406, and acceptance criteria imposed by the CRWMS on HLW delivered into the CRWMS. The WASRD govern all aspects and acceptance criteria for the filled and sealed canistered waste form, including the borosilicate or lanthanum waste glass, stainless steel canister, and the sealed produced canistered waste form. The EM Waste Acceptance Product Specifications (WAPS) is subordinate to the WASRD, contains HLW acceptance requirements, and is complied with at selected HLW sites where RW has previously approved its use as the baseline treatment document.

HLW Producers/Custodians are responsible for characterizing, treating, and packaging the waste form for shipment and disposal to the CRWMS and preparing documentation needed to verify compliance with OCRWM waste acceptance criteria. HLW accepted into the CRWMS for disposal shall be HLW as defined in the Nuclear Waste Policy Act of 1982, as amended (NWPA) .

In addition, HLW canisters that DOE produces must conform to the interfaces identified in the Integrated Interface Control Document (IICD), Volume 1, DOE/RW-0511, which has been developed cooperatively with OCRWM. All appropriate HLW storage, treatment and packaging activities must be conducted in accordance with quality assurance requirements established in the OCRWM Quality Assurance Requirements Document (QARD), DOE/RW-0333P.

Criteria:

HLW treated and packaged by DOE will meet the requirements of the WASRD, DOE/RW-0351, Revision 4, January 2002. The HLW shall be treated and packaged to meet the EM WAPS requirements at specific sites where applicable.
HLW treated and packaged by DOE will conform to the interfaces identified in the IICD, Volume 1, DOE/RW-0511, Revision 1, March 2002, unless OCRWM has issued a further revision.
HLW storage, treatment, and packaging will be performed under a quality assurance program that complies with the QARD, DOE/RW-0333P. The particular revision of the QARD that each site must satisfy may vary from site to site depending on when HLW treatment operations are conducted.

2.6 Radioactive Waste Acceptance Requirements (reference section 2.5 for HLW acceptance requirements): Ensure development, review, approval, and implementation of the radioactive waste acceptance requirements for facilities that receive waste for storage, treatment, or disposal. Radioactive waste acceptance requirements shall establish the facility's requirements for the receipt, evaluation, treatment, if necessary, and acceptance of waste.

Criteria:

Waste acceptance requirements and waste acceptance criteria are developed, reviewed, and approved.
Waste acceptance requirements for radioactive waste management facilities follow the graded approach process that is consistent with the hazards associated with the management of the waste in the facility and the complexity of the activities conducted in the facility and on the waste.

2.7 Radioactive Waste Generator Requirements: Ensuring development, review, approval, and implementation of a program for waste generation planning, characterization, certification, and transfer. The program should also address characterization of waste, preparation of waste for transfer, certification that the waste meets the receiving facility's radioactive waste acceptance requirements, and transfer of waste.

Criteria:

Effective programs exist for managing the front end of radioactive waste management cycles are promoted; i.e., activities performed by waste generators in preparation for turning over waste for management in systems that eventually lead to disposal.
Requirements exist to ensure a waste generator program provides for development and implementation of systematic, integrated capabilities considering the following key elements: 1) consider waste management needs prior to and during generation of waste streams (planning); 2) obtain and maintain knowledge about the waste that supports effective decision-making about the waste (characterization); 3) document that waste generated by one facility meets the receiving facility's waste acceptance requirements (certification); and 4) ensure that waste to be shipped satisfies certain documentation, authorization, and manifest requirements (transfer).
Waste generator programs are developed, reviewed, and approved.
Subordinate organizations and personnel establish and carry out the generator programs.
Ensure there is adequacy of the programs for achieving the more detailed requirements identified for waste types and for approving the programs.
Programs are implemented as designed and approved.
Obtain Resource Conservation and Recovery Act (RCRA) permits for generation of mixed wastes.

2.8 Defense-in-Depth: Ensure that defense-in-depth principles are incorporated where potential uncertainties or vulnerabilities warrant their use when reviewing and approving radioactive waste management activities and documents. These principles advocate the use of multiple levels of engineered and administrative controls to provide protection to the public, workers, and the environment.

Criteria:

Defense-in-depth principles are appropriately evaluated and applied to the management of radioactive waste where uncertainties or vulnerabilities warrant multiple levels of controls to provide protection to the public, workers, and the environment.
Multiple levels of protection are in place to compensate for potential human and mechanical failures which could result in release of radioactive material.
Defense-in-depth includes both administrative and design controls.

2.9 Incorporation of As Low as Reasonably Achievable (ALARA) Principles: Ensure ALARA principles for radiation protection are incorporated when reviewing and approving radioactive waste management activities.

Criteria:

The ALARA process is implemented in the management of radioactive waste (ref CFR Part 835, Occupational Radiation Protection and DOE 5400.5, Radiation Protection of the Public and the Environment.)
Administrative and design controls are used in work processes to minimize exposures to radiation.
Waste management operations are conducted so that radiation exposures to workers and members of the public are maintained as far below regulatory limit as possible, and releases to the environment are minimized, commensurate with sound economics and operating principles.

2.10 Storage of Radioactive Waste: Ensure that all radioactive waste is stored in a manner that protects the public, workers, and the environment in accordance with a radioactive waste management basis, and that the integrity of waste storage is maintained for the expected time of storage and does not compromise meeting the disposal performance objectives for protection of the public and the environment when the waste is disposed.

Criteria:

Waste is properly stored by providing for containment, protecting the ability of packages to maintain containment, and ensuring waste is handled in a way that in that facilitates proper disposal and contributes to the long-term performance of the disposal facility.
Storage must protect the public, workers, and the environment.
Ensure waste packages are maintained during the storage period so that nothing occurs to the waste or waste packages that is detrimental to the final disposal of the waste.
Perform radiation and contamination surveys of storage areas and waste packages to provide an indication of the package integrity and ensure worker protection.
Considerations are given to the design and operation of storage facilities to meet the eventual requirements of the disposal facility.
Obtain RCRA compliance instruments for storage of mixed wastes.

2.11 Treatment of Radioactive Waste: Ensure all radioactive waste requiring treatment is treated in a manner that protects the public, workers, and the environment and in accordance with a radioactive waste management basis and all required RW QARD, International, Federal, or State, rules and regulations.

Criteria:

Ensure that when radioactive waste treatment technologies are utilized, they provide the necessary protection to the public, workers, and the environment from treatment operations and are in compliance with the radioactive waste management basis for the treatment facility.
Comply with all required treatment and waste form requirements specified in:
- Low Level Waste (LLW) - waste-type chapters in DOE M 435;
- High Level Waste (HLW) - EM Waste Acceptance Product Specifications (WAPS), DOE/EM-0093, RW Waste Acceptance System Requirements Document (WASRD), DOE/RW-0351, RW Quality Assurance Requirements Document (QARD) DOE/RW-0333P, and the RW Integrated Interface Control Document (IICD) Volume 1, DOE/RW-0511.
- Transuranic Waste - waste-type chapters in DOE M 435, current WIPP Waste Acceptance Criteria (WAC), and current Carlsbad Field Office Quality Assurance Program Document (QAPD). (The current versions of the WAC and QAPD can be found on the WIPP Home Page at http://www.wipp.energy.gov.)
- Mixed Waste - RCRA permits and Federal Facilities Compliance Act Site Treatment Plans.

2.12 Disposal of Radioactive Waste: Ensure that radioactive waste is disposed in a manner that protects the public, workers, and the environment and in accordance with a radioactive waste management basis. Review specific transuranic or low-level waste documentation including the performance assessment and composite analysis or appropriate CERCLA documentation, prior to approval, and obtaining and ensuring the facility is operated in accordance with the disposal authorization statement. Also conduct performance assessment and composite analysis maintenance.

Criteria:

Ensure that the specific waste type is disposed of and complies with all pertinent DOE orders and directives, rules and regulations in 40 CFR 191, 10 CFR 63, 10 CFR 61, the Nuclear Waste Policy Act, and the National Environmental Policy Act, and the IAEA as appropriate.
Ensure that low-level waste is disposed so that there is a reasonable expectation that the performance objectives of Chapter IV of DOE M 435.1-1 will be met.
Ensure that the PA for the TRU waste disposal facility and the PA and CA for a low-level waste disposal facility (or appropriate CERCLA documentation) are technically adequate, logical, complete, and defensible for establishing controls on disposal of waste for protection of the public and the environment into the future and that they are reviewed and approved.
Ensure data is collected and studies conducted to verify the CA and PA are updated as necessary and the CA and PA are maintained.
Ensure safe and environmentally sound disposal of TRU, MLLW, and LLW and future final disposal of HLW in a Federal Repository.
Obtain RCRA permits for any onsite disposal of mixed wastes, as appropriate.

2.13 Monitoring of Radioactive Waste Management Facilities: Ensure monitoring is conducted for all radioactive waste management facilities as required. All disposal facilities should be monitored, as appropriate, for compliance with conditions of the disposal authorization statement.

Criteria:

Monitoring is conducted as required, including monitoring of storage, treatment, and disposal facilities with respect to key parameters and conditions of their authorization statements.
Monitoring programs and plans are in compliance with DOE 5400.1 General Environmental Protection Program and DOE 5400.5, Radiation Protection of the Public and Environment, and Section IV.R, Section IV.R. (1), (2), and (3) of DOE M 435.1-1 for LLW disposal facility and storage of liquid LLW.
PA's and CA's are in place to establish the monitoring plan to collect data to develop an understanding of the actual performance of the disposal facility (see DOE M 435.1-1, Sections IV.P. (2) and (3)).
For long-term performance of the LLW disposal facility to ensure performance objectives are met, monitoring data are reviewed periodically against the action levels contained in the monitoring plan (ref DOE M 435.1-1, Section IV.R.(3) (c)).

2.14 Material and Waste Declassification for Waste Management: Ensure, to the extent practical, radioactive material and waste generated under a program that is classified for national security reasons is declassified or rendered suitable for unclassified radioactive waste management.

Criteria:

Reduce unnecessary management costs and maintain national security by ensuring that radioactive material and waste is, as practical, declassified and managed as unclassified material and waste.
Material that is classified and can be declassified or sanitized is handled in accordance with current classification guidance.
Determinations that waste has been declassified or sanitized are documented to support maintaining the classification for either national security or economic reasons.

2.15 Waste Incidental to Reprocessing: Ensure that waste incidental to reprocessing determinations are made by either the provisions of Section 3116 of the National Defense Authorization Act for Fiscal Year 2005, for specific wastes at the Savannah River Site and Idaho National Laboratory, or the "citation" or "evaluation" process as described in Chapter II of DOE M 435.1-1. Ensure consultation and coordination with EM for waste determined to be incidental to reprocessing through the Section 3116 or "evaluation" process of DOE M 435.1-1. Ensure that the provisions of the NRC Final Policy Statement for Decommissioning of the West Valley Demonstration Project (WVDP) are followed for certain wastes from reprocessing that will remain at WVDP.

Criteria:

Ensure that the processes and responsibilities for making waste incidental to reprocessing determinations are understood and implemented.
Determinations are made that the following wastes are not high-level waste using the processes identified below:
- Low-level and transuranic waste is identified through application of the "Citation" process at Section II.B.1 of DOE M 435.1.
- Low-level waste identified by the Secretary, in consultation with the Nuclear Regulatory Commission, using the process contained in section 3116 (a) of the National Defense Authorization Act for Fiscal Year 2005 (NDAA);
- Low-level waste identified by DOE through the application of the waste incidental to reprocessing provisions in II.B.2 "Evaluation" process of DOE Manual 435.1, Radioactive Waste Management;
- Low-level waste identified by other regulatory mechanisms such as the West Valley Demonstration Project Act and the Nuclear Regulatory Commission Policy Statement on Decontamination and Decommissioning Criteria for WVDP; and
- Transuranic waste identified by DOE through the application of the waste incidental to reprocessing provisions in II.B.2 "Evaluation" process of DOE Manual 435.1, Radioactive Waste Management, or by another determined process and which is identified in a Class 3 permit modification request to WIPP's Hazardous Waste Permit approved by the New Mexico Environment Department, for wastes that were ever managed as HLW.
Establish a process or method that documents waste incidental to reprocessing decisions as specified in Section II.B. of DOE M 435.1.
Include the following elements in the evaluation process and citation process: 1) organization and responsibilities; 2) procedures; 3) quality assurance; 4) document/record control; and 5) training.

2.16 Waste with No Identified Path to Disposal: Ensure a process is developed and implemented for identifying the generation of radioactive with no identified path forward to disposal and reviewing and approving conditions under which radioactive waste with no identified path to disposal may be generated. Notify HQ of these decisions.

Criteria:

Issues associated with generating waste with no identified path to disposal are brought to the attention of the appropriate DOE managers before the waste is generated to resolve the problems that will prevent it from being disposed, to ensure that the waste has appropriate long-term safe storage until it can be disposed, and to minimize the generation of waste with no path to disposal.
A periodic evaluation of whether no path to disposal waste should continue to be generated is included in the management plans for this waste.
Process exists for the generation of no path forward waste prior to generation.
Conditions are documented and approved under which no path forward waste may be generated.
Process exists for notifying appropriate Headquarters management decisions to generate no path forward waste.

2.17 Corrective Actions: Ensure a process exists for proposing, reviewing, approving, and implementing corrective actions when necessary to ensure that the requirements of DOE O 435.1 and its manual are met and to address conditions that are not protective of the public, workers, or the environment.

Criteria:

There are processes to identify, manage, and resolve radioactive waste management deficiencies in complying with DOE O 435.1 and address conditions that are not protective of the public, workers, or the environment are established and implemented.
The responsibility and right of all personnel is clearly communicated to identify and report unsafe conditions so actions can be taken to ensure protection of the workers, public, and the environment.
The operation of radioactive waste management facilities or the performance of radioactive waste management activities is discontinued or controls are put in place if it is poses an imminent danger or serious hazard to the public, workers, or the environment.
A process is established that includes problem identification and tracking through resolution; proposal, review, and implementation of solutions, and a method of approval and assigning accountability.
The corrective action process interfaces with the lessons learned program to achieve benefit from an action taken.

Performance Objective 3: DOE Line Management Oversight

DOE line management have established and implemented effective oversight processes that evaluate the adequacy and effectiveness of contractor work control processes

3.1 Complex-wide Radioactive Waste Management Program Plans: Complex-wide Radioactive Waste Management Plans are developed, implemented, and maintained for HLW, TRU, LLW, and MLLW.

Program plans provide an overarching strategy for making and implementing waste management decisions and also will provide site personnel a framework within which they can formulate and execute plans for managing wastes at the individual sites. The plans address mission, goals/objectives, milestones, priorities; boundaries and interfaces, constraints, organization and responsibilities, integrated program strategy; technical and programmatic issues, and waste minimization and pollution prevention.
Functional elements, organizations, responsibilities, and activities that comprise the system needed to store, treat, and dispose of radioactive waste are adequately described.
A waste management strategy is present that integrates waste projections and life-cycle waste management planning informing complex-wide facility configuration decisions.
A documented approach for research and development is being pursued to improve safety and/or efficiency in managing radioactive waste.
Development of the program plans is a cooperative and iterative effort with site representatives and other affected programs.
Site program scope, schedule, and cost are consistent with the approved EM baseline.

3.2 Waste Management Data System: A system is established and maintained to compile appropriate waste inventory and generation projection data and other information concerning radioactive waste management facilities, operations, and activities across the complex.

Criteria:

Information and data concerning the management of radioactive waste is collected and compiled at the DOE complex level. Under a graded approach , the following information and data is collected: quantities of past, current, and projected waste, by waste type and year; waste characteristics; waste management life-cycle plans, including final disposition and no path to disposal information; facility and operational information including capacities; barriers to disposition; and technology needs.
The data is consistently collected and reported in a manner that makes it useful to the complex-wide waste-type programs and plans required by DOE M 435.1-1, sections 1.2.B and 1.2.D.
Development and documentation of data requirements are complete for all information collected to assure accurate reporting.
Data is updated on a routine basis to support capacity and facility planning, resource and budget planning, integration and efficiency efforts, and lessons learned.

3.3 Review and Approval of Performance Assessments and Disposal Documents: Reviewing and approve, along with EH-1, waste disposal facility performance assessments and other disposal documents as required in waste specific chapters of DOE Order 435.1 for which DOE is responsible for making compliance decisions.

Criteria:

Evaluations conducted in the performance assessment of a TRU waste disposal facility and in the performance assessment (or appropriate CERCLA documentation) and composite analysis (or appropriate CERCLA documentation) for a LLW or MLLW disposal facility, are found by DOE to be technically adequate, logical, complete, and defensible for establishing the controls on disposal of waste for protection of the public and the environment into the future.
A Federal panel reviews LLW disposal facility Performance Assessments (PA's), Composite Analyses (CA's), and appropriate CERCLA documentation, recommends LLW disposal facility compliance determinations to senior management and develops disposal authorization statements. Review and approval of CA's and PA's are made in a manner to ensure that waste disposal is being conducted safely and effectively.

3.4 Oversight of Radioactive Waste Management Facilities: Ensure oversight of radioactive waste management facilities, operations, and activities are conducted. Oversight shall ensure radioactive waste management program activities are conducted in accordance with a radioactive waste management basis and meet the requirements of DOE O 435.1 and its manual.

Criteria:

Oversight of radioactive waste, management facilities, operations, and activities occurs by Federal staff. This ensures that storage, treatment, and disposal occur in a manner that protects the public, workers, and the environment.
Overall goals and objectives of the DOE Integrated Safety Management System are met.
The requirements of DOE O 435.1 and its manual are incorporated within the functions, responsibilities, authorities, and requirements explained in the set of Safety Management System directives.
HQ ensures that changes to regulations and DOE directives are reviewed and, when necessary, incorporates them into revisions of DOE O 435.1 and its manual and guide to ensure the basis for safe radioactive waste management facilities, operations, and activities are maintained.

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