This Guide was prepared as part of the Department's response to the Defense Nuclear Facilities Safety Board's (DNFSB) Recommendation 94-2, 'Conformance with Safety Standards at DOE Low-Level Nuclear Waste and Disposal Sites,'. As part of responding to Recommendation 94-2, the Department identified a number of deficiencies related to the projection of LLW generation within the DOE complex:
- disposal facilities do not receive the same quality of projections from on- and off-site generators;
- only current generators submit projections, therefore, future generation of LLW (especially environmental restoration waste) is not captured;
- the projections of LLW received by disposal facilities are not uniformly developed by the generators;
- the quality and detail (e.g., radiological characteristics and physical/chemical forms) of data received by disposal facilities are insufficient;
- projections are dramatically impacted by unstable budgets, out-year projections are rapidly outdated as budgets, and thus priorities, change;
- and projections, particularly from decontamination and decommissioning, and environmental restoration activities, will be dramatically impacted by cleanup level and land-use decisions.
Subsequent to the issuance of the DNFSB Recommendation 94-2, the DOE has implemented or is in the process of implementing several initiatives that have begun to address these concerns and the core issue of the adequacy of DOE LLW disposal capacity. These initiatives include a LLW minimization strategy and recent forecasts which contain improved estimates of future waste volumes including: the Baseline Environmental Management Report (BEMR), the Office of Environmental Restoration (EM-40) Core Database, the Current and Planned Low-Level Waste Disposal Capacity Report, the EM Ten Year Plan (TYP), and the National Low-Level Waste Program Center for Excellence. These initiatives are summarized below.
Baseline Environmental Management Report
The BEMR was prepared in response to a mandate from Congress and provided a life-cycle cost estimate for all environmental management activities including waste management, environmental restoration, and decommissioning. As part of the BEMR effort, life-cycle estimates for management of contaminated media and LLW were developed. These estimates included projected LLW generation from environmental restoration and decommissioning activities, as well as waste generated from on-going operations.
For environmental restoration and decommissioning activities, data was collected on proposed remediation strategies, contaminated media and waste type (including LLW), projected annual waste volumes requiring treatment, storage, and disposal; and the planned site of disposal.
The BEMR also contains an estimate of contaminated surplus facilities that may be transferred to EM in the future and the amount of LLW that would be generated from decommissioning those facilities. In addition, the BEMR collected data on the amount of LLW expected to be generated from on-going 'routine' mission support activities and secondary waste streams arising from waste management activities.
EM-40 Core Database
The Office of Environmental Restoration developed the EM-40 Core Database to provide a consolidated data set to support its planning and integration activities. The Core Database combines data elements from the 1993 Environmental Restoration contaminated media/waste data call, site project baselines, and the requirements of the 1996 BEMR. It may be noted that the Office of Waste Management (EM-30) is developing a similar database using data elements and requirements from the BEMR, site baselines, the Integrated Database Report (IDB Report), the Mixed Waste Inventory Report, and previous LLW data calls.
Current and Planned Low-Level Waste Disposal Capacity Report
In accordance with the DOE Implementation Plan developed in response to DNFSB Recommendation 94-2, the Current and Planned Low-Level Waste Disposal Capacity Report, Revision 0, was prepared using existing data from the BEMR, EM-40 Core Database, and the IDB Report. The report provides volumetric projections of LLW generation through the year 2070 and compares those projections to the disposal capacity of DOE's current and planned LLW disposal facilities. Another revision of the report incorporating radiological information (e.g., radiological capacity based on specific nuclides) is scheduled for completion in September 1997.
Office of Environmental Management Ten Year Plan (TYP)
Environmental Management is currently developing the TYP. The purpose of the TYP is to provide a vision and framework for accelerating EM's environmental cleanup efforts with the goal of completion, to the extent possible, by FY 2006. LLW generation and disposal estimates are included in the TYP. EM is working toward integrating the project work structure of the TYP into the budget and planning process.
National LLW Center for Excellence
A National Low-level Waste Center for Excellence is being established at the Idaho Operations Office in concert with the Albuquerque and Nevada Operations Offices. The Center for Excellence will become operational in 1997. The Center for Excellence responsibilities related to LLW projections will be described in the Low-Level Waste Program Management Plan to be issued in March 1997.
1.2 Low-Level Waste Projection Program
As described above, DOE has been active in improving LLW forecasting capabilities since DNFSB issued Recommendation 94-2. However, DOE has not issued formal guidance nor established a program to ensure the consistency of LLW projection data and the integration of LLW forecasts into Departmental life-cycle planning. Although the BEMR and the LLW Capacity Report provide life-cycle estimates of LLW, including LLW generated from environmental restoration and decommissioning activities, national life-cycle projections are essentially summations of projections prepared independently by individual sites rather than data developed and collected in a standardized manner.
In response to this need, EM is implementing a LLW Projection Program as recommended by DNFSB. The LLW Projection Program will facilitate consistency and uniformity in the development of LLW projections, improve the quality of LLW projections, and ensure that accurate LLW projections are integrated info life-cycle planning activities.
The LLW Projection Program addresses LLW generated from all sources including stabilization, deactivation, and decommissioning activities, environmental restoration activities, LLW generated by the treatment of other wastes (such as mixed LLW and TRU waste), nuclear materials disposition, as well as LLW generated by operational facilities. The objectives of the LLW Projection Program, the major elements of the program, and the key implementation steps are described below.
1.2.1 Objectives of the Low-Level Waste Projection Program
The objectives of the DOE LLW Projection Program are as follows:
Provide the Department with accurate and consistent projections of LLW, including: current and future LLW volume; LLW characteristics; treatment; storage; and disposal facility capacity information; and where applicable, identify LLW that has no management plan.
Ensure that LLW projections are developed in a standardized, systematic manner using a consistent methodology and common assumptions. and,
Provide LLW projection data that can be integrated into Departmental life-cycle program planning and execution activities to ensure that adequate, cost effective treatment, storage, and disposal facility capacity will be available.
1.2.2 Major Elements of the LLW Projection Program
Efforts by the Department to establish and implement a LLW Projection Program will proceed in 1997 and beyond. The major elements of the Program are the Low-Level Waste Projection Program Guide, the Low-Level Waste Program Management Plan, the revised DOE Radioactive Waste Management Order 435.1, and technical directive manual associated with DOE Order 435.1. These are described in more detail below.
Low-Level Waste Projection Program Guide
This Guide describes the overall approach, major elements, and key implementation steps of the LLW Projection Program. The Guide provides a standardized approach and methodology for developing LLW projections including the establishment of data quality objectives and periodic assessment of the quality and accuracy of the projections. To the extent practical, this Guide has been developed in a manner to be consistent with LLW forecasting and data collection practices already in place at DOE sites.
Low-level Waste Program Management Plan
As part of the DOE Implementation Plan developed in response to DNFSB Recommendation 94-2, DOE is preparing a Low-Level Waste Program Management Plan which will accomplish the following objectives:
- establish the programmatic strategies, policy initiatives, and assumptions for achieving a complex-wide integrated LLW program;
- describe the near-term and long-term actions, milestones, and responsibilities necessary to achieve the desired future status of the LLW program;
- identify the key management interfaces, organizational structure, and the appropriate division of roles and responsibilities between DOE/HQ and field elements; and
- define the process for assessing LLW program effectiveness.
The Program Management Plan will identify elements of the LLW Projection Program for direct implementation by field elements, with particular focus on waste management units. In addition, the Program Management Plan will identify DOE's strategy and mechanism for collecting and maintaining LLW projection information and how LLW projections will be integrated into national level life-cycle planning and analysis activities. A key requirement of the Program Management Plan will be to ensure that DOE develops and maintains a consistent LLW projections data set that is used for all reporting, planning, and analysis activities.
Department of Energy Order 435.1, Radioactive Waste Management
DOE Order 435.1 (the revised Radioactive Waste Management Order) will contain a requirement for Field Offices to development and maintain LLW projections.
Department of Energy Order 435.1 Technical Directives Manual
The Technical Directives Manual to be developed in concert with DOE Order 435.1 implementation will include LLW Projection Program requirements based upon key elements in this Guide. Specifically, the elements listed below are expected to be included in the Technical Directives Manual:
Each waste management unit (or other appropriate Department of Energy field element responsible for low-level waste) shall implement a Low-Level Waste Projection Program. Projections will provide annual totals for years 1 through 10 and a total sum for years 11 through 30. The Low-Level Waste Projection Program shall, at a minimum, address the following elements:
- generator information;
- projected volume;
- waste form;
- radionuclide data including key isotopic and curie content;
- container types; and
- treatment, storage, and disposal facility capacity.
Each waste management unit shall implement data quality objectives to improve the quality of low-level waste forecasts. A period of three projection cycles may be allowed to fully meet data quality objectives.
Low-level waste projections shall be updated annually.
Low-level waste projections shall be integrated into program life-cycle planning efforts.
1.2.3 Low Level Waste Projection Program Implementation
During 1997 waste management units (or other appropriate DOE field elements responsible for low-level waste) should implement the provisions contained in this Guide. Key elements of the Guide include data requirements, a consistent projection methodology, establishment of data quality objectives, and periodic review and assessment of data quality. In addition, the development and collection of LLW projection data should be integrated into overall information management, data collection, and life-cycle planning activities. It is expected that in 1997, LLW projections developed by waste management units will be consistent with the data requirements and approach contained in this Guide.
In accordance with the DOE Implementation Plan developed in response to DNFSB Recommendation 94-2, the Department is revising the Current and Planned Low-Level Waste Disposal Capacity Report. The revised report will be prepared in accordance with this guidance and will incorporate radiological information. It is due to be completed by September 1997. A data request to collect the national low-level waste projection and capacity information needed for this report will be issued in the second quarter of fiscal year 1997. A summary of the projections information will also be published in the 1997 DOE Integrated Database Report.
In subsequent years, the Department's Office of Environmental Management will continue to collect and maintain a national low-level waste projections data set. The national low-level waste data set will be published annually in the IDB Report and will be used to periodically update the Current and Planned Low-Level Waste Disposal Capacity Report. The Office of Environmental Management will also periodically assess the quality of low-level waste projections as compared to actual generation. Further, the national low-level waste data set will be integrated into national level planning and analysis activities.
1.2.4 Integration with Life-Cycle Planning
LLW projections should be integrated into site program planning, execution activities, and information collection activities. It is essential that this information be available and used in program planning and execution activities to support the following objectives:
- safe, efficient, and timely disposal of LLW generated by DOE activities;
- timely planning for additional treatment, storage, and disposal facilities;
- determination of the DOE complex-wide configuration for future LLW disposal facilities based on specific waste characteristics; and
- achievement of DOE complex-wide strategic planning to determine the most efficient use of LLW disposal capacity.
The use of LLW projection information should be expanded at the site level to ensure adequate budget and planning for waste management. Data regarding disposal volumes, shipping schedules, treatment plans, and waste management plans (or lack there of) should be collected during the LLW projection process and is important to budget and life-cycle planning efforts. The site-specific LLW Projection Program should be designed to ensure that these data are in a form that can be easily transferred to budget and life-cycle planning processes. In any case, the data collected should be consistent with budget requests and long range life-cycle planning.
At the national level, implementation of the LLW Projection Program will result in collection of data from each site in a consistent manner, facilitating its use in complex-wide planning. Data collected under this program will be integrated with Departmental life-cycle planning, where appropriate, and will support assessment of disposal capacity against the results of Radiological Performance Assessments and Composite Analyses to ensure that DOE has adequate disposal capacity.