Richland Operations Office (DOE-RL) Implementation Plan for DOE Order 435.1
The U.S. Department of Energy issued U.S. Department of Energy Order 435.1, Radioactive Waste Management, and U.S. Department of Energy Manual 435.1-1, Radioactive Waste Management Manual, on July 9, 1999, to replace U.S. Department of Energy Order 5820.2A. Compliance is required by July 9, 2000, where compliance is defined as ''implementing the requirements, or an approved implementation, or corrective action plan'' (refer to Manual, Introduction, paragraph four). This implementation plan identifies the status of each requirement for U.S. Department of Energy, Richland Operations Office Site contractors, and provides the plan, cost, and length of time required for achieving full implementation. The U.S. Department of Energy, Richland Operations Office contractors (Fluor Hanford, Incorporated, DynCorp Tri-Cities Services, Bechtel Hanford, Inc., and Pacific Northwest National Laboratory) conducted a line-by-line review of DOE Order 435.1 and associated manuals to determine which requirements were new, and which requirements already are used for compliance with the previous DOE Order 5820.2A or other requirements. The Gap Analysis for DOE Order 435.1 (HNF-5465) identified compliance gaps, along with other issues that would impact efforts for achieving compliance. The gap analysis also contained a series of assumptions made by the various projects in determining compliance status. The details and section-by-section analysis are contained in Appendix A. Some of the DOE Order 435.1 requirements invoke sections of other DOE Orders not incorporated in various U.S. Department of Energy, Richland Operations Office contracts (refer to Section 2.0, Table 2-1). Those additional DOE Orders are identified by contractor and will be left for evaluation in accordance with each contractor's requirements. No attempt was made to evaluate all of those orders at this time, although in many cases, contractors follow a similar older DOE Order, which is cited in the Appendix. In some areas, the interpretation of the requirement is not clear, so clarifying assumptions have been made to assist the U.S. Department of Energy, Richland Operations Office in understanding the path forward planning basis. The assumptions and interpretations form the basis for the compliance gap analysis, as well as for the implementation plan itself as noted in Section 2.2. In some cases, the interpretation is essentially an exemption from a requirement, with the basis stated and justified. Some of the critical items in this area relate to the following: (1) Pre-existing waste; (2) Staging and storage; (3) Exemption of Comprehensive Environmental Response. Compensation. and Liability Act of 1980 remediation areas; (4) Contingency and confinement requirements for old facilities; (5) Siting and design requirement exemption for limited-lifetime facilities; (6) Waste with no identified path to disposal; and (7) Characterization, packaging, storage, certification, and monitoring requirements that might not satisfy the letter of DOE Order 435.1 but are justified fully in related safety, environmental, or monitoring documents.
- Research Organization:
- Fluor Hanford, Richland, WA (United States)
- Sponsoring Organization:
- USDOE Office of Environmental Management (EM) (US)
- DOE Contract Number:
- AC06-96RL13200
- OSTI ID:
- 803915
- Report Number(s):
- DOE/RL-2000-25, Rev.1; TRN: US0300767
- Resource Relation:
- Other Information: PBD: 1 Jun 2000
- Country of Publication:
- United States
- Language:
- English
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