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At least 307 records · Page 17

LESSONS LEARNED IN AEROSOL MONITORING WITH THE RASA

The Radionuclide Aerosol Sampler/Analyzer (RASA) is an automated aerosol collection and analysis system designed by Pacific Northwest National Laboratory (PNNL) in the 1990's and is deployed in several locations around the world as part of the International Monitoring System (IMS) required under the Comprehensive Nuclear-Test-Ban Treaty (CTBT). The RASA operates unattended, save for regularly scheduled maintenance, iterating samples through a three-step process on a 24-hour interval. In its 15-year history, much has been learned from the operation and maintenance of the RASA that can benefit engineering updates or future aerosol systems. On 11 March 2011, a 9.0 magnitude earthquake and tsunami rocked the eastern coast of Japan, resulting in power loss and cooling failures at the Daiichi nuclear power plants in Fukushima Prefecture. Aerosol collections were conducted with the RASA in Richland, WA. We present a summary of the lessons learned over the history of the RASA, including lessons taken from the Fukushima incident, regarding the RASA IMS stations operated by the United States.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Multi-unit Operations in Non-Nuclear Systems: Lessons Learned for Small Modular Reactors

The nuclear-power community has reached the stage of proposing advanced reactor designs to support power generation for decades to come. Small modular reactors (SMRs) are one approach to meet these energy needs. While the power output of individual reactor modules is relatively small, they can be grouped to produce reactor sites with different outputs. Also, they can be designed to generate hydrogen, or to process heat. Many characteristics of SMRs are quite different from those of current plants and may be operated quite differently. One difference is that multiple units may be operated by a single crew (or a single operator) from one control room. The U.S. Nuclear Regulatory Commission (NRC) is examining the human factors engineering (HFE) aspects of SMRs to support licensing reviews. While we reviewed information on SMR designs to obtain information, the designs are not completed and all of the design and operational information is not yet available. Nor is there information on multi-unit operations as envisioned for SMRs available in operating experience. Thus, to gain a better understanding of multi-unit operations we sought the lesson learned from non-nuclear systems that have experience in multi-unit operations, specifically refineries, unmanned aerial vehicles and tele-intensive care units. In this paper we report the lessons learned from these systems and the implications for SMRs.

22 GENERAL STUDIES OF NUCLEAR REACTORS↗

Archiving Data from New Survey Technologies: Lessons Learned on Enabling Research with High-Precision Data While Preserving Participant Privacy: Preprint

During the past 15 years, increasing numbers of organizations and planning agencies have begun collecting high-resolution Global Positioning System (GPS) travel data. Despite the significant effort and expense to collect it, privacy concerns often lead to underutilization of the data. To address this dilemma of providing data access while preserving privacy, the National Renewable Energy Laboratory, with support from the U.S. Department of Transportation and U.S. Department of Energy, established the Transportation Secure Data Center (TSDC). Lessons drawn from best-practice examples from other data centers have helped shape the structure and operating procedures for the TSDC, which functions under the philosophy of first and foremost preserving privacy, but doing so in a way that balances security with accessibility and usability of the data for legitimate research. This paper provides details about the TSDC approach toward achieving these goals, which has included creating a secure enclave with no external access for backing up and processing raw data, a publicly accessible website for downloading cleansed data, and a secure portal environment through which approved users can work with detailed spatial data using a variety of tools and reference information. This paper also describes lessons learned from operating the TSDC with respect to improvements in GPS data handling, processing, and user support, along with plans for continual enhancements to better support the needs of both data providers and users and to thus advance the research value derived from such valuable data.

33 ADVANCED PROPULSION SYSTEMS↗

25 Years Of Environmental Remediation In The General Separations Area Of The Savannah River Site: Lessons Learned About What Worked And What Did Not Work In Soil And Groundwater Cleanup

The Savannah River Site (SRS) is owned and administered by the US Department of Energy (DOE). SRS covers an area of approximately 900 square kilometers. The General Separation Area (GSA) is located roughly in the center of the SRS and includes: radioactive material chemical separations facilities, radioactive waste tank farms, a variety of radioactive seepage basins, and the radioactive waste burial grounds. Radioactive wastes were disposed in the GSA from the mid-1950s through the mid-1990s. Radioactive operations at the F Canyon began in 1954; radioactive operations at H Canyon began in 1955. Waste water disposition to the F and H Seepage Basins began soon after operations started in the canyons. The Old Radioactive Waste Burial Ground (ORWBG) began operations in 1952 to manage solid waste that could be radioactive from all the site operations, and ceased receiving waste in 1972. The Mixed Waste Management Facility (MWMF) and Low Level Radioactive Waste Disposal Facility (LLRWDF) received radioactive solid waste from 1969 until 1995. Environmental legislation enacted in the 1970s, 1980s, and 1990s led to changes in waste management and environmental cleanup practices at SRS. The US Congress passed the Clean Air Act in 1970, and the Clean Water Act in 1972; the Resource Conservation and Recovery Act (RCRA) was enacted in 1976; the Comprehensive Environmental Response Compensation, and Liability Act (CERCLA) was enacted by Congress in 1980; the Federal Facilities Compliance Act (FFCA) was signed into law in 1992. Environmental remediation at the SRS essentially began with a 1987 Settlement Agreement between the SRS and the State of South Carolina (under the South Carolina Department of Health and Environmental Control - SCDHEC), which recognized linkage between many SRS waste management facilities and RCRA. The SRS manages several of the larger groundwater remedial activities under RCRA for facilities recognized early on as environmental problems. All subsequent environmental remediation projects tend to be managed under tri-party agreement (DOE, Environmental Protection Agency, and SCDHEC) through the Federal Facilities Agreement. During 25 years of environmental remediation SRS has stabilized and capped seepage basins, and consolidated and capped waste units and burial grounds in the GSA. Groundwater activities include: pump and treat systems in the groundwater, installation of deep subsurface barrier systems to manage groundwater flow, in situ chemical treatments in the groundwater, and captured contaminated groundwater discharges at the surface for management in a forest irrigation system. Over the last 25 years concentrations of contaminants in the aquifers beneath the GSA and in surface water streams in the GSA have dropped significantly. Closure of 65 waste sites and 4 RCRA facilities has been successfully accomplished. Wastes have been successfully isolated in place beneath a variety of caps and cover systems. Environmental clean-up has progressed to the stage where most of the work involves monitoring, optimization, and maintenance of existing remedial systems. Many lessons have been learned in the process. Geotextile covers outperform low permeability clay caps, especially with respect to the amount of repairs required to upkeep the drainage layers as the caps age. Passive, enhanced natural processes to address groundwater contamination are much more cost effective than pump and treat systems. SRS operated two very large pump and treat systems at the F and H Seepage Basins to attempt to limit the release of tritium to Fourmile Branch, a tributary of the Savannah River. The systems were designed to extract contaminated acidic groundwater, remove all contamination except tritium (not possible to remove the tritium from the water), and inject the tritiated groundwater up-gradient of the source area and the plume. The concept was to increase the travel time of the injected water for radioactive decay of the tritium. The two systems were found to be non-effective and potentially mobilizing more contamination. SRS invested approximately $50 million in construction and approximately $100 million in 6 years of operation. The H Seepage Basin pump and treat system was replaced by a series of subsurface barriers that alters the groundwater velocity; the F Seepage Basin pump and treat system was replaced by subsurface barriers forming a funnel and gate augmented by chemical treatment within the gates. These replacement systems are mostly passive and cost approximately $13 million to construct, and have reduced the tritium flux to Fourmile Branch, in these plumes, by over 70%. SRS manages non-acidic tritiated groundwater releases to Fourmile Branch from the southwest plume of the MWMF with a forest irrigation system. Tritiated water is captured with a sheetpile dam below the springs that caused releases to Fourmile Branch. Water from the irrigation pond is pumped to a filter plant prior to irrigation of approximately 26 hectares of mixed forest and developing pine plantation. SRS has almost achieved a 70% reduction in tritium flux to the Branch from this plume. The system cost approximately $5 million to construct with operation cost of approximately $500K per year. In conclusion, many lessons have been learned in 25 years of relatively aggressive remedial activities in the GSA. Geotextile covers outperform low permeability clay caps, especially with respect to the amount of repairs required to upkeep the drainage layers as the caps age. Passive, enhanced natural processes to address groundwater contamination are much more cost effective than pump and treat systems. In water management situations with non-accumulative contaminants (tritium, VOCs, etc.) irrigation in a forest setting can be very effective.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Lessons Learned from FUSRAP

The US DOE Office of Legacy Management (LM) is the long-term steward for 90 sites remediated under numerous regulatory regimes including the Formerly Utilized Sites Remedial Action Program (FUSRAP) sites. In addition, LM holds considerable historical information, gathered in the 1970s, to determine site eligibility for remediation under FUSRAP. To date, 29 FUSRAP sites are in LM’s inventory of sites for long-term surveillance and maintenance (LTS&M), and 25 are with the US Army Corps of Engineers (USACE) for remediation or in the process of being transitioned to LM. It is forecasted that 13 FUSRAP sites will transfer from the USACE to LM over the next 10 years; however, the timing of the transfers is strongly dependent upon federal funding of the ongoing remedial actions. Historically, FUSRAP sites were generally cleaned up for “unrestricted” industrial use or remediated to the “cleanup standards” at that time, and their use remained unchanged. Today, these sites as well as the adjacent properties are now changing or envisioned to have changes in land use, typically from industrial to commercial or residential uses. The implication of land-use change affects DOE’s LTS&M responsibility for the sites under LM stewardship as well as the planning for the additional sites scheduled to transition in time. Coinciding with land-use changes at or near FUSRAP sites is an increased community awareness of these sites. As property development increases near FUSRAP sites, the general public and interested stakeholders regularly inquire about the sufficiency of cleanups that impact their neighborhoods and communities. LM has used this experience to address a series of lessons learned to improve our program management in light of the changing conditions of our sites. We describe these lessons learned as (1) improved stakeholder relations, (2) enhanced LTS&M requirements for the sites, and (3) greater involvement in the transition process.

54 ENVIRONMENTAL SCIENCES↗

Measured Zero Net Energy Performance: Results, Lessons, and Surprises

As more and more zero net energy (ZNE) buildings are built and monitored, we can learn from both careful case studies of individual projects as well as a broader perspective of trends over time. In a forum sponsored by Pacific Gas and Electric Company (PG&E), eight expert speakers discussed: results and lessons from monitoring occupied ZNE buildings; best practices for setting performance targets and getting actionable performance information, and; things that have surprised them about monitored ZNE buildings. This paper distills the content of the forum by laying out the most common hurdles that are encountered in setting up monitoring projects, frequent performance issues that the monitoring uncovers, and lessons learned that can be applied to future projects.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Lessons Learned about Liquid Metal Reactors from FFTF Experience

The Fast Flux Test Facility (FFTF) is the most recent liquid-metal reactor (LMR) to operate in the United States, from 1982 to 1992. FFTF is located on the DOE Hanford Site near Richland, Washington. The 400-MWt sodium-cooled, low-pressure, high-temperature, fast-neutron flux, nuclear fission test reactor was designed specifically to irradiate Liquid Metal Fast Breeder Reactor (LMFBR) fuel and components in prototypical temperature and flux conditions. FFTF played a key role in LMFBR development and testing activities. The reactor provided extensive capability for in-core irradiation testing, including eight core positions that could be used with independent instrumentation for the test specimens. In addition to irradiation testing capabilities, FFTF provided long-term testing and evaluation of plant components and systems for LMFBRs. The FFTF was highly successful and demonstrated outstanding performance during its nearly 10 years of operation. The technology employed in designing and constructing this reactor, as well as information obtained from tests conducted during its operation, can significantly influence the development of new advanced reactor designs in the areas of plant system and component design, component fabrication, fuel design and performance, prototype testing, site construction, and reactor operations. The FFTF complex included the reactor, as well as equipment and structures for heat removal, containment, core component handling and examination, instrumentation and control, and for supplying utilities and other essential services. The FFTF Plant was designed using a “system” concept. All drawings, specifications and other engineering documentation were organized by these systems. Efforts have been made to preserve important lessons learned during the nearly 10 years of reactor operation. A brief summary of Lessons Learned in the following areas will be discussed: Acceptance and Startup Testing of FFTF FFTF Cycle Reports

Wootan, David W.↗

Solid-State Lighting: Early Lessons Learned on the Way to the Market Report Summary

Summary of lessons learned from 2014 analysis of the early stages of solid-state lighting market introduction in the U.S., which also summarizes early actions taken to avoid potential problems anticipated based on lessons learned from the market introduction of compact fluorescent lamps.

ssl, lighting, LED, energy, performance, testing, ↗

Establishing Building-Level Energy Goals in Procurement Documents: Lessons Learned from Pilot Utility and Portfolio Projects: Preprint

Encouraging commercial building owners to set measurable energy goals before design begins can drive design and contractor teams to develop innovative energy efficiency solutions within conventional building budgets. A federal building owner piloted this technique and created a large-scale zero energy office building on a budget comparable to local market construction rates. The successes and lessons learned from this performance-based procurement project formed the basis of an expanded program using utilities as the outreach channel to replicate the approach. The utilities delivered incentive-based offerings to focus building owners on the whole building rather than on individual building components and systems. In addition, a ripple effect was evident, with individual building owners as well as owners of multiple-building portfolios adopting the techniques, sometimes with variations, but always maintaining the same core principles. The original performance-based procurement process and its successful implementation in a federal building project informed all these efforts. Those successes and lessons learned demonstrate that the approach can be adapted to utility programs with some variation and is a powerful tool for engaging building owners as they make critical design decisions that impact energy performance over the life of the building.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Establishing Building-Level Energy Goals in Procurement Documents: Lessons Learned from Pilot Utility and Portfolio Projects

Encouraging commercial building owners to set measurable energy goals before design begins can drive design and contractor teams to develop innovative energy efficiency solutions within conventional building budgets. A federal building owner piloted this technique and created a large-scale zero energy office building on a budget comparable to local market construction rates. The successes and lessons learned from this performance-based procurement project formed the basis of an expanded program using utilities as the outreach channel to replicate the approach. The utilities delivered incentive-based offerings to focus building owners on the whole building rather than on individual building components and systems. In addition, a ripple effect was evident, with individual building owners as well as owners of multiple-building portfolios adopting the techniques, sometimes with variations, but always maintaining the same core principles. The original performance-based procurement process and its successful implementation in a federal building project informed all these efforts. Those successes and lessons learned demonstrate that the approach can be adapted to utility programs with some variation and is a powerful tool for engaging building owners as they make critical design decisions that impact energy performance over the life of the building.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

From Theory to Practice: Lessons Learned from an Advanced M&V Commercial Pilot

Advanced measurement & verification (M&V), or M&V 2.0, is an energy data analysis method using advanced metering infrastructure (AMI) data in combination with analytics to quantify energy efficiency project savings. Advanced M&V is viewed as an enabler for underutilized behavioral, retrocommissioning, and holistic multi-measure efficiency efforts, as quantifying savings for these programs with existing methods has typically been very challenging. Despite its promise, there are still several unanswered questions about the use of advanced M&V such as: How accurately can these tools quantify energy savings? How can advanced M&V satisfy regulatory requirements for rigorous savings estimates? Where and how does advanced M&V intersect with traditional impact evaluation and the principles of ‘embedded’ evaluation, measurement & verification (EM&V)? Pilots are being pursued in various regions and program contexts to address these research questions. However, results from these pilots are rarely made public, meaning that lessons may not be widely shared and the scope of analyses varies widely. The paper presents encouraging results from a recent advanced M&V pilot and discusses key process-related aspects such as managing AMI data and refining analysis methodologies. An approach to reviewing and classifying projects based on savings characteristics and magnitude is demonstrated, as a potential risk management tool. The authors also demonstrate how advanced M&V can identify underperforming projects and non-routine events in a timely manner. The paper also outlines lessons learned from this and other recent pilot activity and barriers to be overcome in moving toward the goal of widespread adoption of holistic meter-based programs.

Crowe, Eliot↗

Federal Automotive Statistical Tool: Asset-Level Data - Lessons Learned and Looking Forward

This presentation provides an overview of collecting federal motor vehicle fleet data at the individual vehicle level for the first time during the fall of 2017, lessons learned related how that data was validated, and changes being made based on those lessons. This presentation is one of three comprising a panel discussion with representatives from other Federal agencies. FAST is a Web-based information system managed by the US Department of Energy, the US General Services Administration, and the Energy Information Administration. FAST is used to collect information about the fleet of motor vehicles used and managed by the Federal government.

99 GENERAL AND MISCELLANEOUS↗

Target Control and Protection Systems Lessons from SNS Operations

The Spallation Neutron Source (SNS) at Oak Ridge National Laboratory has been in operations since 2006 and proposes a project to build a Second Target Station (STS) to effectively double potential scientific output. The SNS target controls operate in a harsh environment which includes high radiation, exposure to gaseous radionuclides, and activated liquid mercury and mercury vapor. These conditions necessitate protective interlocks and credited controls for protection functions to ensure proper response to off-normal conditions. In order to inform the design of target controls for the STS, we have examined lessons learned during SNS operations regarding the design and implementation of the control and protection systems for the first target station (FTS). This paper will examine various aspects of the performance of the target control and protection systems including reliability, maintainability and sustainability given the challenging environment created by 1.4 MW operations. Specific topics include distributed control of various target subsystems, response to loss of power, selection of nuclear grade instrumentation, and applying these lessons to the design for the STS project.

Humphreys, Dana↗

Challenges and Lessons Learned from fabrication, testing and analysis of eight MQXFA Low Beta Quadrupole magnets for HL-LHC

By the end of October 2022, the US HL-LHC Accelerator Upgrade Project (AUP) had completed fabrication of ten MQXFA magnets and tested eight of them. The MQXFA magnets are the low beta quadrupole magnets to be used in the Q1 and Q3 Inner Triplet elements of the High Luminosity LHC. This AUP effort is shared by BNL, Fermilab, and LBNL, with strand verification tests at NHMFL. An important step of the AUP QA plan is the testing of MQXFA magnets in a vertical cryostat at BNL. The acceptance criteria that could be tested at BNL were all met by the first four production magnets (MQXFA03-MQXFA06). Subsequently, two magnets (MQXFA07 and MQXFA08) did not meet some criteria and were disassembled. Lessons learned during the disassembly of MQXFA07 caused a revision to the assembly specifications that were used for MQXFA10 and subsequent magnets. In this paper, we present a summary of: 1) the fabrication and test data of all the MQXFA magnets; 2) the analysis of MQXFA07/A08 test results with characterization of the limiting mechanism; 3) the outcome of the investigation, including the lessons learned during MQXFA07 disassembly; and 4) the finite element analysis correlating observations with test performance.

43 PARTICLE ACCELERATORS↗

Lessons Learned From Ventilation and Glovebox Flooding Via Overfilling of the Wet Vacuum System in a Plutonium Facility

In the summer of 2021, operations personnel requested maintenance personnel to fill a wet vacuum (Wetvac) seal water tank in a plutonium facility at Los Alamos National Laboratory (LANL). After the filling was finished, the fill valve of the Wetvac seal water tank was left open and a ‘dead-man’ valve on an isolation line failed to close properly. After a series of other failures, the water exited the glovebox and contaminated three rooms of the first floor of the facility and an underlying area in the basement. A retrospective analysis of this event determined that there was no risk of a criticality due to the inherent design features of the ventilation system. This paper will explain the driving factors behind how this event was able to happen, as well as some of the major lessons learned that can be universally applied to other nuclear facilities. One of the main causes of the event was the delegation of work to maintenance personnel that were not qualified for the work being asked of them. Additionally, there was a lack of coordination between criticality safety engineers and facility operations equipment owners regarding equipment and connections present on the seal water tanks for the Wetvac, specifically the presence of overflow drain lines. The respective criticality safety evaluation credited an overflow drain line being present on the seal water tanks that was later found to have not been present. Lastly, there are lessons to be learned regarding equipment configuration and designing systems with safety in mind.

46 INSTRUMENTATION RELATED TO NUCLEAR SCIENCE AND ↗

U.S. Department of Energy Office of Legacy Management Legacy Uranium Mine Site Reclamation - Lessons Learned - 12384

The U.S. Department of Energy (DOE) Office of Legacy Management is responsible for administering the DOE Uranium Leasing Program (ULP) and its 31 uranium lease tracts located in the Uravan Mineral Belt of southwestern Colorado (see Figure 1). In addition to administering the ULP for the last six decades, DOE has also undertaken the significant task of reclaiming a large number of abandoned uranium (legacy) mine sites and associated features located throughout the Uravan Mineral Belt. In 1995, DOE initiated a 3-year reconnaissance program to locate and delineate (through extensive on-the-ground mapping) the legacy mine sites and associated features contained within the historically defined boundaries of its uranium lease tracts. During that same time frame, DOE recognized the lack of regulations pertaining to the reclamation of legacy mine sites and contacted the U.S. Bureau of Land Management (BLM) concerning the reclamation of legacy mine sites. In November 1995, The BLM Colorado State Office formally issued the United States Department of the Interior, Colorado Bureau of Land Management, Closure/Reclamation Guidelines, Abandoned Uranium Mine Sites as a supplement to its Solid Minerals Reclamation Handbook (H-3042-1). Over the next five-and-one-half years, DOE reclaimed the 161 legacy mine sites that had been identified on DOE withdrawn lands. By the late 1990's, the various BLM field offices in southwestern Colorado began to recognize DOE's experience and expertise in reclaiming legacy mine sites. During the ensuing 8 years, BLM funded DOE (through a series of task orders) to perform reclamation activities at 182 BLM mine sites. To date, DOE has reclaimed 372 separate and distinct legacy mine sites. During this process, DOE has learned many lessons and is willing to share those lessons with others in the reclamation industry because there are still many legacy mine sites not yet reclaimed. DOE currently administers 31 lease tracts (11,017 ha) that collectively contain over 220 legacy (abandoned) uranium mine sites. This contrasts to the millions of hectares administered by the BLM, the U.S. Forest Service, and other federal, tribal, and state agencies that contain thousands of such sites. DOE believes that the processes it has used provide a practical and cost-effective approach to abandoned uranium mine-site reclamation. Although the Federal Acquisition Regulations preclude DOE from competing with private industry, DOE is available to assist other governmental and tribal agencies in their reclamation efforts. (authors)

11 NUCLEAR FUEL CYCLE AND FUEL MATERIALS↗

Savannah River Site, Liquid Waste Program, Savannah River Remediation American Recovery and Reinvestment Act Benefits and Lessons Learned - 12559

Utilizing funding provided by the American Recovery and Reinvestment Act (ARRA), the Liquid Waste Program at Savannah River site successfully executed forty-one design, procurement, construction, and operating activities in the period from September 2009 through December 2011. Project Management of the program included noteworthy practices involving safety, integrated project teams, communication, and cost, schedule and risk management. Significant upgrades to plant capacity, progress toward waste tank closure and procurement of needed infrastructure were accomplished. Over 1.5 million hours were worked without a single lost work day case. Lessons Learned were continually identified and applied to enhance the program. Investment of Recovery Act monies into the Liquid Waste Program has ensured continued success in the disposition of radioactive wastes and the closure of high level waste tanks at SRS. The funding of a portion of the Liquid Waste Program at SRS by ARRA was a major success. Significant upgrades to plant capacity, progress toward waste tank closure and procurement of needed infrastructure was accomplished. Integrated Project Teams ensured quality products and services were provided to the Operations customers. Over 1.5 million hours were worked without a single lost work day case. Lessons Learned were continually reviewed and reapplied to enhance the program. Investment of Recovery Act monies into the Liquid Waste Program has ensured continued success in the disposition of radioactive wastes and the closure of high level waste tanks at SRS. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Implementation of Lessons Learned - 17406

Following a negative occurrence or event, putting corrective actions into place to address an organisation's systemic and administrative weaknesses is paramount to that organisation's future success. At Los Alamos National Laboratory (LANL, or the Laboratory), recent experiences emphasize this critical point. On February 14, 2014, transuranic (TRU) waste management at DOE facilities changed significantly when a drum of mixed hazardous and TRU (MTRU) waste from LANL breached after its disposal at the Waste Isolation Pilot Plant (WIPP) near Carlsbad, New Mexico. Shortly following the LANL-WIPP event, several internal and external investigations and analyses were conducted by LANL, the U.S. Department of Energy (DOE) and others, including the DOE Inspector General and an Office of Environmental Management Accident Investigation Board (AIB), to determine the cause of the LANL drum breach at WIPP. Internal investigations led LANL to self-disclose non-compliancies including treatment without a permit and improper waste characterization to the New Mexico Environment Department (NMED), leading to a Settlement Agreement in January 2016. The Settlement Agreement, together with the other investigations, led LANL to identify and implement many corrective actions related to its waste management practices. The Laboratory recognized the need to revisit implementation of some fundamental concepts, and noted the following 'Lessons Learned': - Communicating requirements more clearly, - Using technical expertise more effectively, and - Improving implementation of policies and procedures. This paper presents the actions LANL has taken to prevent recurrence and demonstrate the Laboratory's commitment to compliant waste management requirements. They have focused on promoting a better understanding of the regulatory requirements in order to address the key root causes and the resulting Lessons Learned, as follows: - Ensure that all levels of a Project Team understand the regulatory requirements related to performing the work;- Engage RCRA subject matter experts in planning (for both initial project plans and subsequent modifications to plans); - Validate that Project Teams' plans and procedures will be effective in meeting regulatory requirements; and - Verify implementation. We believe the corrective actions taken since the drum event at WIPP will fundamentally improve our way of doing business throughout the Laboratory. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗