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At least 451 records · Page 25

Post-closure Nuclear Criticality Safety Evaluations for Disposition of Criticality Control Overpacks at the Waste Isolation Pilot Plant

The Waste Isolation Pilot Plant (WIPP) is a geological repository in southern New Mexico that provides for disposal of transuranic (TRU) wastes from atomic energy defense activities. The Sandia National Laboratories (Sandia) Report, Consideration of Nuclear Criticality When Disposing of Transuranic Waste at the Waste Isolation Pilot Plant, addresses nuclear criticality safety based on the projected inventory characteristics for the initial compliance certification application of WIPP in 1996. As the inventory, waste forms, and disposal package designs change, revised or new analyses are necessary to demonstrate acceptability for these configurations within the WIPP safety basis and compliance with 10,000-year post-closure standards of the US Environmental Protection Agency (EPA). Saylor and Scaglione evaluated criticality control overpacks (CCOs) in 2017 based on conservative assumptions for post-closure repository structural conditions with resulting effects on containers and container spacing, The Saylor and Scaglione evaluation of CCOs addressed a single waste configuration that represents the Surplus Plutonium Disposition Program’s dilute and dispose waste form and composition. This initial CCO study demonstrated that 50 grams of boron carbide (B 4 C) per CCO is sufficient to ensure post-closure criticality safety based on a well-mixed waste composition, and Oak Ridge National Laboratory (ORNL) subsequently determined that this amount of B 4 C does not require constraints on moisture or plastic present as moderator. The Saylor and Scaglione analysis conservatively assumes repository room closure that eliminates all space between fissile gram equivalent (FGE) 239 Pu masses. The close-packed array was selected based on limited availability of repository salt creep modeling results at that time. In 2019, Brickner provided additional evaluations for pipe overpack containers (POCs), building on the conservative basis provided by Saylor and Scaglione. Brickner’s 2019 analysis made use of new geomechanical data for post-closure spacing that rely on advances in repository modeling as documented in the work by Reedlunn and Bean. This current CCO evaluation for generic waste materials expands on earlier work performed at ORNL and includes evaluation of CCOs across a much broader range of possible waste compositions and geometries. This evaluation is intended to provide input for the required feature, event and process (FEP) screening to determine if post-closure criticality must be included as an event in the 10,000-year regulatory evaluation. As such, the approach to modeling post-closure criticality presented in this report has been coordinated with the Sandia team responsible for FEP screening. The resulting analysis supports disposition of fissile materials in the CCO containing up to 380 FGE 239 Pu and expands conditions acceptable for disposal of fissile material in CCOs. This evaluation builds on the methodology of Saylor and Scaglione and Brickner, using the most recently available geomechanical data for CCO spacing under salt creep compaction scenarios provided by Reedlunn and Bean. The broad range of fissile material configurations analyzed in this report are intended to account for configurations that may occur during the post-closure disposal time period, and it also includes waste configurations that are not physically possible to support analysis of conditions that influence neutron fluence.

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Hanford Site Composite Analysis: Recharge and Inventory Sensitivity Analyses for the A Trenches, BC Cribs and Trenches, and PUREX Area Vadose Zone Models

The main objectives of the composite analysis (CA) compliance case vadose zone (VZ) facet are to simulate transport of radionuclide releases from the surface to the water table, and to provide radionuclide transfer rates to groundwater for inclusion into the Plateau-to-River (P2R) saturated zone (SZ) model (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). The CA compliance case approach to address the scale and distribution of contaminant sources in the VZ facet is to subdivide the Hanford Site Central Plateau into 26 models that contain contaminant sources and liquid discharges likely to commingle during migration through the VZ to the water table

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Analysis in Support of Disposition of Tank 48 Legacy Material

This report contains the characterization of six 200-mL Tank 48H samples: HTF-48-21-74, HTF-48-21-75, HTF-48-21-76, HTF-48-21-81, HTF-48-21-82, and HTF-48-21-83. The effort supports a Systems Engineering Evaluation (SEE) recommendation involving a Tank 48H decantation strategy that would remove liquid volume and grout the solids. The first three Tank 48H samples were surface samples taken after a quiescent period in the tank. The quiescent period allowed settling of the solids, these being mostly potassium tetraphenylborate. These three surface samples had no measurable solids, though a settling haze could be seen. The latter three samples were taken at 48, 25, and 10 inches from the bottom of Tank 48H immediately after tank mixing pumps had been run. Those samples contained measurable insoluble solids that were readily visible. All six samples were analyzed to provide chemical and radionuclide concentrations as defined as the "Limit" and "Target" in the Saltstone Production Facility (SPF) Waste Acceptance Criteria (WAC) and per the compliance strategy in the Tank Farm Waste Compliance Plan (WCP). Samples were analyzed by many methods to determine pH, density/specific gravity, radioactive isotopes, soluble and insoluble elements, total solids, total insoluble solids, organic and inorganic mercury, volatile and semi-volatile chemicals, and anions. Photographs of the settling of small samples were taken over time and are displayed in this report. The extent of settling was very significant, showing that surface sample liquids are similar to filtrates. However, Cs-137 measurements exceeded WAC limits in all surface samples (1.1E+07 vs. 1.3E+06). The solids were found to contain very high cesium activity, measured as high as 1.1E+10 dpm/gram. Sodium was in the range of 4.24 to 4.74 M for all samples, so the solids would tend to settle with time and would not be at risk of floating without air entrainment. No organic mercury was detected in this work.

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Composite Analysis Vadose Zone Transport of Selected Radionuclides Released from DOE O 435.1 Sources.

The main objectives of the composite analysis (CA) compliance case vadose zone (VZ) facet are to simulate transport of radionuclide releases from the surface to the water table, and to provide radionuclide transfer rates to groundwater for inclusion into the Plateau-to-River (P2R) saturated zone (SZ) model (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). The parallel exascale version of the Subsurface Transport Over Multiple Phases (eSTOMP1) simulator is used to simulate flow and transport for the CA VZ models. The CA compliance case approach to address the scale and distribution of contaminant sources in the VZ facet is to subdivide the Hanford Site Central Plateau into 26 models that contain contaminant sources and liquid discharges likely to commingle during migration through the VZ to the water table.

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Oklahoma State University – Industrial Assessment Center (Final Report)

Our first primary objective is to provide industrial assessments to clients in Oklahoma, Arkansas, Kansas, and north and northwest Texas, including the Texas Panhandle (about 10% of the state of Texas). This geographical region extends about 400 miles north and south and about 600 miles east and west. In addition, the partnership links two universities, Oklahoma State University (OSU) and Wichita State University (WSU) within our region together in a significant collaboration focused on improving our region’s industrial competitiveness. Our second primary objective is to produce competent, motivated energy engineers. Student training will be a combination of classroom work, individual mentoring, and on-the-job training. The focus will be on energy conservation technologies, in conjunction with increased productivity, the economics of the same, and client relationships including client recruiting, on-site assessment, reporting, and client-related communications. Finally, we will work to provide resources and expertise to complement the first two primary objectives. The effectiveness and efficiency of our IAC will be measured, internally, by four broad criteria: (1) client benefits, (2) student development and acceptance after graduation, (3) regional/national contribution to lowering energy use and reducing pollutants, and (4) compliance with DOE/FM requirements. Client-related benefits include client contacts, timeliness of assessments and reports, the value of recommendations provided, and the value of recommendations implemented. Student development includes many students trained and the level of training provided in energy, waste, and productivity-related technologies as well as teamwork and communication skills. The contribution to lower national energy use and waste production is a natural outcome of the program. Compliance with DOE/FM requirements includes timeliness of reports, participation in Best Practices activities, contributions to EERE goals and objectives, and other requirements as communicated to the IAC.

32 ENERGY CONSERVATION, CONSUMPTION, AND UTILIZATI↗

Distributed Energy Resource Cybersecurity Framework and Cyber Range Integration

Distributed energy resource (DER) systems feature complex, data-driven communications networks that require careful system coordination and constant vigilance to ensure that grid assets are secure. Because DERs are an important component of the decarbonization strategy, agencies need to secure energy data that could implicate issues of national security if compromised. To help federal energy managers assess, monitor, and manage cybersecurity while achieving decarbonization, the National Renewable Energy Laboratory's (NREL's) Distributed Energy Resource Cybersecurity Framework (DER-CF) offers a comprehensive, web-based assessment tool focusing on cyber governance or policies, technical management, and physical security. The DER-CF currently presents users with a series of pertinent cybersecurity questions that are used to generate a site-specific report and recommendations. This paper outlines a plan to integrate the DER-CF with another key asset-NREL's cyber range-to visualize cybersecurity resilience and compliance and to enhance the usability and accessibility of the DER-CF for federal facility energy managers and planners. This integration will result in a visualization environment to interpret and interact with compliance data. Its development will include regular conversations with stakeholders to assess the effectiveness of these efforts, refine the visualization capability, and ensure its value to our partners.

24 POWER TRANSMISSION AND DISTRIBUTION↗

Hanford Waste Treatment Plant LAB Facility Stack Effluent Monitoring: Sampling Probe Location Qualification Evaluation

The Waste Treatment Plant laboratory (LAB) facility stack monitor locations were qualified using scale model stacks to mitigate the risk of identifying that sampling locations do not meet the qualification criteria on the full-scale stack. As required by the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1-1999 standard, the scale model and its sampling location were geometrically similar to the actual stack and the Reynolds numbers for both the actual and model stacks were >10,000. An additional criterion is that the product of the hydraulic diameter and mean velocity (DV) of the full-scale stack must be between 1/6 DV and 6 DV of the scale model stack tests. Verification tests of the LAB stacks were performed at normal operating conditions. The minimum 1/6 DV value, along with the maximum 6 DV value from the scale model testing determines the range of conditions for which the full-scale stack may be operated and remain in compliance with the stack verification criterion. Based on these DV values, the corresponding stack flow rates for each of the LAB stacks are 625 to 47,237 scfm for LB-C2, 1,704 to 103,131 scfm for LB-S1, and 467 to 18,088 scfm for LB-S2. The remaining criteria for the stack verification to be considered valid involve the flow angle and velocity uniformity results. First, the flow angle at the full-scale stack must be =20°. Second, the velocity uniformity at the full-scale stack must be =20% coefficient of variance (COV). Finally, the velocity uniformity results for the actual and scale model stack tests must agree within 5% COV. These criteria were met through the full-scale stack tests at the LAB facility. Flow angle results were primarily less than 10 degrees, except for the LB-C2 Fan A results, which were an average of 17.6 degrees; all flow angle results were within the =20° criterion. The velocity uniformity results for each test condition averaged between 1.5 and 3.5% COV, which were all within the range of the target %COV values from the scale model tests. Based on these stack verification test results, the three LAB filtered exhaust stack sampling locations meet the qualification criteria provided in the ANSI/HPS N13.1-1999 standard for all fan operating configurations. This includes single-fan as well as dual-fan operations for LB-C2, each of the dual-fan operating conditions for LB-S1, and each single-fan operating condition for LB-S2. Further changes to the system configuration or operating conditions that are outside the bounds described in this report may require additional tests or analyses to determine compliance with the standard.

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Hanford Waste Treatment Plant Low Activity Waste Facility Stack Effluent Monitoring - Sampling Probe Location Qualification Evaluation

The Hanford Tank Waste Treatment and Immobilization Plant low activity waste (LAW) facility stack monitor locations were qualified using scale model stacks to mitigate the risk of identifying that sampling locations do not meet the qualification criteria on the full-scale stack. As required by the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1-1999 standard, the scale model and its sampling location were geometrically similar to the actual stack and the Reynolds numbers for both the actual and model stacks were >10,000. An additional criterion is that the product of the hydraulic diameter and mean velocity (DV) of the full-scale stack must be between 1/6 DV and 6 DV of the scale model stack tests. Verification tests of the LAW stacks were performed at normal operating conditions. The minimum 1/6 DV value, along with the maximum 6 DV value from the scale model testing determines the range of conditions for which the full-scale stack may be operated and remain in compliance with the stack verification criterion. Based on these DV values, the corresponding stack flow rates for each of the LAW stacks are 815–55,758 scfm for LV-S1, 980–112,078 scfm for LV-S2, 264–22,901 scfm for LV-S3, and 981–79,832 scfm for LV-C2. The remaining criteria for the stack verification to be considered valid involve the flow angle and velocity uniformity results. First, the flow angle at the full-scale stack must be =20°. Second, the velocity uniformity at the full-scale stack must be =20% coefficient of variance (COV). Finally, the velocity uniformity results for the actual and scale model stack tests must agree within 5% COV. These criteria were met through the full-scale stack tests at the LAW facility. Flow angle results were primarily less than 10°, except for one LV-S2 Fan A result, which was 13.2°; all flow angle results were within the =20° criterion. The velocity uniformity results for each test condition ranged between 1.5 COV and 9.2% COV, which were all within the range of the target % COV values from the scale model tests. Based on these stack verification test results, the four LAW filtered exhaust stack sampling locations meet the qualification criteria provided in the ANSI/HPS N13.1-1999 standard for all fan operating configurations. This includes single-fan operating conditions for LV-S1 and LV-S2, dual-fan operations for LV-S3 at both the continuous air monitor and record sampler locations, and both the single-fan as well as the dual-fan operations for LV-C2. Further changes to the system configuration or operating conditions that are outside the bounds described in this report may require additional tests or analyses to determine compliance with the standard.

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Using Information Automation and Human Technology Integration to Implement Integrated Operations for Nuclear

The purpose of the research effort described in this report is to develop and demonstrate an approach to the design and implementation of advanced, automated systems intended to increase operational efficiencies at nuclear power plants. In particular, we describe methods for considering human-technology integration (HTI) issues throughout the various phases of system design, test, and implementation and how these considerations help promote effective design. This research project will develop planning tools and comprehensive guidance on how HTI principles and methods, in combination with information automation technologies, can enable effective data integration and coordination for full nuclear plant modernization. Specifically, this research project will develop an approach to automate the mapping of data from plant systems and processes to application needs, thereby significantly reducing the amount of human workload currently required for the execution of these tasks. In addition to developing an automated solution as a replacement for these tasks, this research will also analyze digitalization’s effectiveness in reducing operational costs of compliance related activities. Compliance activities are estimated to account for as much as 50% of operations and maintenance (i.e., non-fuel and non-capital) costs of plant operation.

97 MATHEMATICS AND COMPUTING↗

Hanford Waste Treatment Plant Effluent Management Facility Stack Effluent Monitoring: Sampling Probe Location Qualification Evaluation

The Hanford Tank Waste Treatment and Immobilization Plant Effluent Management facility (EMF) stack monitor location was qualified using the LV-S1 scale model stack as a baseline, augmented by the LB-S1 and LV-S2 scale model stacks to address the Direct Feed Low Activity Waste Effluent Management Facility Vessel Vent Process (DVP) injection into the main Active Confinement Ventilation (ACV) system duct. As required by the American National Standards Institute/Health Physics Society (ANSI/HPS) N13.1-1999 standard, the scale models and its sampling locations were geometrically similar to the actual stack and the Reynolds numbers for both the actual and model stacks were >10,000. An additional criterion is that the product of the hydraulic diameter and mean velocity (DV) of the full-scale stack must be between 1/6 DV and 6 DV of the scale model stack tests. Verification tests of the EMF stack was performed at normal operating conditions. The minimum 1/6 DV value, along with the maximum 6 DV value from the scale model testing determines the range of stack flow rates for which the full-scale stack may be operated and remain in compliance with the stack verification criterion. Based on the LV-S1 scale model test DV values, the corresponding stack flow rates for the EMF stack are as listed in Table S1. Table S1. Effluent Management Facility Stack Qualified Flow Range. Stack Parameter EM-1 Minimum Qualified Stack Flow (scfm) 781 Maximum Qualified Stack Flow (scfm) 53,432 The remaining criteria for the stack verification to be considered valid involve the flow angle and velocity uniformity results. First, the flow angle at the full-scale stack must be =20°. Second, the velocity uniformity at the full-scale stack must be =20% coefficient of variance (COV). Finally, the velocity uniformity results for the actual and scale model stack tests must agree within 5% COV. These criteria were met through the full-scale stack test at the EMF. Flow angle results were less than 5°; all flow angle results were within the =20° criterion. The velocity uniformity results for each test condition ranged between 2.2% COV and 4.3% COV, which were all within the range of the target % COV values from the scale model tests on the LV-S1, LB-S1, and LV S2 scale models. Based on these stack verification test results, the EMF filtered exhaust stack sampling location meets the qualification criteria provided in the ANSI/HPS N13.1-1999 standard for all fan operating configurations. This includes each combination of ACV fan with the DVP exhausters. Further changes to the system configuration or operating conditions that are outside the qualified flow rates described in this report may require additional tests or analyses to determine compliance with the standard.

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Engineering evaluations of nuclear material storage containers against the packaging requirements at TA-55 (FY22 Rules of Use Report)

A set of obligations in the yearly storage container surveillance program, ensures that a retrospective approach is applied with loaded containers in inventory to confirm compliance with all “users” to ensure nuclear material storage container requirements are being followed. Validation that packaged containers are properly used, within a specific set of container types prescribed “bounding conditions of use,” is based on meeting requirements as identified in operating procedures associated with TA55-DOP-091, TA-55 Nuclear Material Packaging, and PA-RD-01022, Nuclear Material Packaging Requirements. The surveillance plan obligation requires the application of local area nuclear material accountability software or (LANMAS) to produce queries. The data queries are used to assess attributes of containers in storage these investigations are conducted on a bi-annual basis. This rules of use (ROU) compliance process ensures proper usage of storage containers as containment systems and therefore provides effective worker protection. It is structured as a supporting effort by implementing aspects of PA-AP-01207, Nuclear Material Container Safety Management at TA-55.

36 MATERIALS SCIENCE↗

Using Systems Theoretic Process Analysis and Causal Analysis to Map and Manage Organizational Information to Enable Digitalization and Information Automation

The overarching goal of this Light Water Reactor Sustainability Program–supported research and development project is to provide planning tools and comprehensive guidance to utilities considering or undertaking full nuclear plant modernization. The results of this research will provide the nuclear industry with a comprehensive and usable solution, including guidance, lessons learned, methods, and planning tools. This research is currently working to provide guidance on digitalization and information automation to enable the evolution of data to information, insight, and action—thereby allowing utilities to operate safely and cost-competitively with all other electrical generation sources. Light Water Reactor Sustainability Program researchers have also recently started investigating how human and technology integration principles, information automation, and digitalization enable data evolution. These researchers are currently in the process of validating the use of System-Theoretic Process Analysis to define high-level safety constraints in the United States Nuclear Regulatory Commission’s problem identification and resolution process (i.e., a plant compliance information gathering activity). The next step in this research, which is described in the following sections of this report, is to map out data evolution in a use case to identify inefficiencies in another aspect of plant compliance information gathering and communication activities—event investigations and root cause analyses.

21 SPECIFIC NUCLEAR REACTORS AND ASSOCIATED PLANTS↗

Composite Analysis Vadose Zone Transport of Selected Hanford Site Composite Analysis: Vadose Zone Transport of Selected Radionuclides Released from DOE O 435.1 Waste Sites

The main objectives of the composite analysis (CA) compliance case vadose zone (VZ) facet are to simulate transport of radionuclide releases from the surface to the water table, and to provide radionuclide transfer rates to groundwater for inclusion into the Plateau-to-River (P2R) saturated zone (SZ) model (CP-57037, Model Package Report: Plateau to River Groundwater Model, Version 8.3). The parallel exascale version of the Subsurface Transport Over Multiple Phases (eSTOMP) simulator is used to simulate flow and transport for the CA VZ models. The CA compliance case approach to address the scale and distribution of contaminant sources in the VZ facet is to subdivide the Hanford Site Central Plateau into 26 models that contain contaminant sources and liquid discharges likely to commingle during migration through the VZ to the water table.

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LLNS Request for Variance from 10 CFR 851 for Construction of LLNL Digital Infrastructure Capabilities Expansion Project

Lawrence Livermore National Security, LLC (LLNS) requests variance to 10 CFR 851 (the Rule) for the construction of the Digital Infrastructure Capabilities Expansion (DICE) project. The request isin continued support of the National Nuclear Security Administration (NNSA) “pilot” to streamline the delivery of commercial-like line-item construction projects under $50 million. This pilot is aligned with the approved NA-50 safety approach. Experience gained in the construction of the new Lawrence Livermore National Laboratory (LLNL) Emergency Operations Facility (EOC) under the variance granted in June 2020 is very encouraging. While detailed analysis will be forthcoming after that project is completed, there are strong indicators that a benefit has been realized by the subcontractors executing the work. The variance has permitted local/regional construction businesses contracted to Management & Operation contractor operated facilities and lower tier subcontractors to bid, operate, execute, and comply with safety and health standards they utilize in their business outside of the Department of Energy (DOE) Complex. While compliance to standards that are as safe and healthful as those in 10 CFR 851: confusion, additional cost, and inefficiencies associated with the burden of compliance to an unfamiliar regulatory spectrum has been avoided. Safety and health performance on the EOC construction project including the number of inspection and surveillance issues is comparable to other subcontractors and projects at LLNL executed under 10 CFR 851.

99 GENERAL AND MISCELLANEOUS↗

LLNS Request for Variance From 10 CFR 851 for Construction of LLNL Emergency Operations Center

Lawrence Livermore National Security, LLC (LLNS) is submitting the following variance application requesting the use of the State of California’s Occupational Safety and Health Administration (Cal/OSHA) Regulations in lieu of Title 10 Code of Federal Regulations Part 851 (10 CFR 851, the Rule), Worker Safety and Health Program, Subpart B (Program Requirements), Subpart C (Specific Program Requirements), and Appendix A (Worker Safety and Health Functional Areas), solely with respect to the construction of the new Lawrence Livermore National Laboratory (LLNL) Emergency Operations Center (EOC) facility. The request is in support of the National Nuclear Security Administration (NNSA) “pilot” to streamline the delivery of commercial-like line item construction projects under $50 million. This pilot is aligned with the approved NA-50 safety approach for the projects in the pilot. This pilot is to test and demonstrate innovation leading to a reduced cost of construction for building commercial type structures at Department of Energy (DOE)/NNSA facilities. The variance proposes to permit local/regional construction businesses contracted to Management & Operation contractor operated facilities to bid, operate, execute, and comply with safety and health standards they utilize in their business outside of the DOE Complex. This will permit compliance to standards that are as safe and healthful as those in 10 CFR 851 without confusion, additional cost, and inefficiencies associated with the burden of compliance to an unfamiliar regulatory spectrum.

99 GENERAL AND MISCELLANEOUS↗

Performance Assessment for the Disposal of Low-Level Waste in the 200 East Area Burial Grounds (Annual Status Report FY 2022)

This annual review provides the projected dose estimates of radionuclide inventories disposed in the 200 East Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-SD-WM-TI-730). The estimates are compared with the performance objectives defined in U.S. Department of Energy requirements (DOE O 435.1 and its companion documents DOE M 435.1-1 and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063) and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 is expected.

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Performance Assessment for the Disposal of Low-Level Waste in the 200 West Area Burial Grounds (Annual Status Report FY 2021)

This annual review provides the projected dose estimates of radionuclide inventories disposed in the active 200 West Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-EP-0645). The estimates are compared with the performance objectives defined in U.S. Department of Energy requirements (DOE O 435.1 and its companion documents DOE M 435.1-1 and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063). and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 is expected.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

LLNS Request for Permanent Variance from 10 CFR 851 for Construction

Lawrence Livermore National Security, LLC (LLNS) requests variance from 10 CFR 851 (the Rule) for construction work at Lawrence Livermore National Laboratory (LLNL). The request is based upon successful application of similar variances granted to LLNS in continued support of the National Nuclear Security Administration (NNSA) initiative to streamline the delivery of line-item construction projects under $50 million. This request is aligned with the approved NA 50 safety approach. Experience gained in the construction of the new LLNL Emergency Operations Center (EOC) under the variance granted in June 2020 and construction preparations to date on the Digital Infrastructure Capabilities Expansion (DICE) under the variance granted April 2022 is very encouraging. There are strong indicators that a benefit has been realized by both the subcontractors executing the work and the Laboratory. The variance has permitted local/regional construction businesses contracted to Management & Operation Contractor operated facilities and lower tier subcontractors to bid, operate, execute, and comply with safety and health standards they utilize in their business outside of the Department of Energy (DOE) Complex. While compliance to standards that are as safe and healthful as those in 10 CFR 851: confusion, additional cost, and inefficiencies associated with the burden of compliance to an unfamiliar regulatory spectrum has been avoided. Safety and health performance on the construction project including the number of inspection and surveillance issues is comparable to other subcontractors and projects at LLNL executed under 10 CFR 851. This variance application was prepared according to the requirements in 10 CFR 851, Subpart D – Variances, § 851.31 Variance Process. This request is limited to subcontractor executed construction at LLNL.

42 ENGINEERING↗