Assessing the Impacts of Waste Management Issues by Program Element - 23521

The Nevada National Security Site (NNSS) accepts waste that has a demonstrated U.S. Department of Energy (DOE) nexus for disposal from more than 20 generators. Generator categories consist of national laboratories, defense production and research sites, environmental restoration sites, and commercial treatment facilities. Each waste generating program must have a robust written waste certification program that is designed to ensure compliance with the current NNSS Waste Acceptance Criteria. The site must also demonstrate that they rigidly adhere to their waste certification program. The waste certification programs address key program elements: characterization (radioactive and chemical); traceability; transportation, inclusive of packaging; and quality assurance. The NNSS Radioactive Waste Acceptance Program (RWAP) is responsible for assessing the content and execution of the generators' NNSS waste certification programs on behalf of the DOE Environmental Management Nevada Program. Due to the complex nature of waste management, occasionally issues arise impacting compliance with the receiving site's acceptance criteria. Issues can be identified through a variety of mechanisms, including RWAP facility audits and surveillances, real-time radiography verifications, visual verifications, receipt inspections, generator self-identification, and regulatory authority reviews. The NNSS requires generators to manage identified issues in accordance with DOE Order 414.1D or equivalent programs such as 10 Code of Federal Regulations 830 for licensed facilities through their own issues management systems. RWAP monitors generator waste issues from discovery to closure and thus is in a unique position to identify potential trends and provide guidance to waste generators. To assess potential trends, RWAP assigned each issue identified since fiscal year 2016 into one of three impact categories: high impact, resulting in suspension by the NNSS RWAP of either a profile or program requiring a causal analysis and corrective action plan; medium impact, resulting in a finding issued by NNSS RWAP requiring a causal analysis and corrective action plan but no suspension; and low-impact observations and discrepancies in the generators NNSS certification program addressed directly by the generator without a causal analysis. Due to the maturity of the generator programs shipping to the NNSS, the rate of high-impact issues per number of packages received is very low, allowing for detailed analysis of the information. The information has been parsed by generator type and by key program elements. There were no discernable differences between the three types of waste generators (i.e., national labs, defense, or environmental restoration), regarding high-impact issues. At least one facility from each of the generator categories was impacted by a high-impact incident. There was more differentiation of data when sorted by key program elements. While the fewest number of issues overall (high-, medium-, and low-impact issues) were related to characterization, the largest number of high-impact issues were categorized as characterization, primarily chemical characterization. Other categories with high-impact issues were traceability and transportation, inclusive of packaging. The most impactful information noted was the disparity in the time required to restart after a suspension based on key program element. The time for restart after a waste characterization issue universally exceeded one year and the average exceeded two years.Anecdotally, these issues were not found during routine reviews and, when discovered, required extensive extent-of-condition reviews that in some cases resulted in regulatory action. By contrast, traceability and packaging issues did not routinely result in regulatory action and restarts under a month were recorded. In summary, NNSS has collected and analyzed information from over six years to assess impacts by generator types and key program elements. This information indicates that any site is susceptible to an incident resulting in a suspension, impacting cost and schedule. Furthermore, this information has clearly identified that while low in total numbers, issues regarding characterization almost always resulted in significant and costly program impacts. The NNSS believes generators should consider this information to inform management decisions regarding risks and potentially mitigating actions. (authors)