Streamlining and Transparently Automating Complex Waste Determinations at Los Alamos National Laboratory - 17286
Environmental programs at Los Alamos National Laboratory (LANL) generate a large amount of sampling activities that can result in waste that needs to be characterized and properly disposed. Since 2011, sampling results are managed in the cloud-based Environmental Information Management (EIM) database, which contains over 16 million current and historical data records. In many cases, the database's analytical records are used to characterize and dispose waste from environmental operations. Three factors contribute to streamlining of the waste disposition operations: (1) if possible, use of the existing analytical data for waste characterization to avoid additional laboratory analysis; (2) reduction in time spent on data evaluation for various waste acceptance criteria; and (3) choice of the proper and least expensive disposal alternative. Use of the existing analytical data, when allowed by law, creates some paradoxical problems: when chemical analysis is requested with the purpose of characterizing waste, it creates only 100 to 400 analytical records. However, use of exiting analytical data at LANL may lead to evaluation of tens of thousands of analytical records, with many records for each single analyte. This occurs because data were collected for environmental characterization and not waste characterization. To streamline data analysis for waste disposition using existing data, LANL has created a Waste Data Summary (WDS) module in the site's EIM database. Recognizing that waste determination is performed by groups outside the environmental program at LANL, the WDS allows for logically guided data selection for a specific waste determination (solids, liquids, radiological, etc.) and reduces potentially thousands of rows of data into simple formatted data reports that are easy to comprehend and process. This allows the waste evaluators to review data using multiple approaches to make their own determination on the most appropriate disposal method. There are four basic principles of WDS operation: (1) The highest detected analytical result is evaluated for the selected samples (or the lowest undetected result if there are no detected results); (2) All approved disposal pathways are evaluated; (3) Any failures of the Waste Acceptance Criteria are visibly highlighted to focus the attention of the evaluator; and (4) The decision of the disposal path is left to the trained waste evaluator (WDS does not choose or suggest any disposal paths). The summary results are presented as the set of short data reports. These reports can be divided into two groups: general comparison reports and disposal pathway specific forms. The general comparison forms show all Resource Conservation and Recovery Act (RCRA) analytes with pass/fail evaluation and with preference for toxicity characteristic leaching procedure (TCLP) results (or 20x rule) for solid samples, the potential RCRA hazard codes assignment for detected analytes, and all rad results. The detected chemical and radioactivity results are compared to the background values and to Soil Screening and Soil Action limits (SSL/SAL limits). Disposal pathway specific forms follow Waste Acceptance Criteria requirements for all disposal pathways available at LANL. The programming of the WDS tries to maximize existing data by analyte substitutions (like using gross alpha for necessary alpha emitting isotopes) or by making calculations when analytical results do not agree with legal requirements (like total chlordane in the RCRA regulations, which is most often analyzed and reported as individual isomers). All forms may be annotated by the waste evaluator to provide additional information to support decision making. Upon final decision of a disposal path, the complete dataset used in the evaluation and the WDS forms with annotations is 'frozen' as an un-editable PDF export to document the data used in the waste disposal determination. The streamlined process results in less work for waste evaluators and reduces overall labor and analytical costs. By comparison, a full review of a 10,000 record parent dataset may take a waste evaluator over a week to review, whereas with the WDS module, the task can be accomplished in less than one hour with clear, reproducible results. These results can be reviewed and checked at any time by quality assurance personnel, thus ensuring transparency in the decision making process. LANL believes this approach has broad applicability to other sites where waste determination is based on review of existing data collected for more generalized environmental purposes. (authors)