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Building Stakeholder Trust: Defensible Government Decisions - 13110

Administrative decisions must be grounded in reasonable expectations, founded on sound principles, and bounded by societal norms. Without these first principles, attaining and retaining public trust is a Herculean task. Decisions made by governmental administrators must be both transparent and defensible: without the former the agency will lose the public's trust and support (possibly prompting a legal challenge to the decision) and without the latter the decision may fail to withstand judicial scrutiny. This presentation and accompanying paper delves into the process by which governmental decisions can achieve both defensibility and openness through building stakeholder trust with transparency. Achieving and maintaining stakeholder trust is crucial, especially in the environs of nuclear waste management. Proving confidence, stability, and security to the surrounding citizenry as well as those throughout the country is the goal of governmental nuclear waste remediation. Guiding administrative decision-making processes and maintaining a broad bandwidth of communication are of incalculable importance to all those charged with serving the public, but are especially essential to those whose decisional impacts will be felt for millennia. A strong, clear, and concise administrative record documenting discrete decisions and overarching policy choices is the strongest defense to a decisional challenge. However, this can be accomplished using transparency as the fundamental building block. This documentation allows the decision-makers to demonstrate the synthesis of legal and technical challenges and fortifies the ground from which challenges will be defended when necessary. Further, administrative actions which capture the public's interest and captivate that interest throughout the process will result in a better-informed, more deeply-involved, and more heavily-invested group of interested parties. Management of information, involvement, and investment on the front-end of the process reaps rewards far more efficiently than attempts to assuage and mitigate the concerns of those parties after the fact and there are a number of tools Savannah River Remediation (SRR) has deployed that render transparency an ally in this context. The makers, applicators, and beneficiaries of policies and decisions will all benefit from strong administrative records which document decisional choices in an open and transparent manner and from timely, up-front management of concerns of interested parties. The strongest defense to decisional challenges is an ability to demonstrate the basis of the decision and the reason(s) that the decision was chosen over other alternatives. Providing a sound basis for defending challenges rather than avoiding or fighting over them allows the deciding entity the greatest opportunity to produce value for its customer. Often, a transparent process that invites public participation and is open for public review and comment will thwart challenge genesis. An entity that has to devote resources to defending its choices obviously cannot utilize those resources to further its mission. (authors)

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NRC Monitoring of Salt Waste Disposal at the Savannah River Site - 13147

As part of monitoring required under Section 3116 of the Ronald W. Reagan National Defense Authorization Act for Fiscal Year 2005 (NDAA), the NRC staff reviewed an updated DOE performance assessment (PA) for salt waste disposal at the Saltstone Disposal Facility (SDF). The NRC staff concluded that it has reasonable assurance that waste disposal at the SDF meets the 10 CFR 61 performance objectives for protection of individuals against intrusion (chap.61.42), protection of individuals during operations (chap.61.43), and site stability (chap.61.44). However, based on its evaluation of DOE's results and independent sensitivity analyses conducted with DOE's models, the NRC staff concluded that it did not have reasonable assurance that DOE's disposal activities at the SDF meet the performance objective for protection of the general population from releases of radioactivity (chap.61.41) evaluated at a dose limit of 0.25 mSv/yr (25 mrem/yr) total effective dose equivalent (TEDE). NRC staff also concluded that the potential dose to a member of the public is expected to be limited (i.e., is expected to be similar to or less than the public dose limit in chap.20.1301 of 1 mSv/yr [100 mrem/yr] TEDE) and is expected to occur many years after site closure. The NRC staff used risk insights gained from review of the SDF PA, its experience monitoring DOE disposal actions at the SDF over the last 5 years, as well as independent analysis and modeling to identify factors that are important to assessing whether DOE's disposal actions meet the performance objectives. Many of these factors are similar to factors identified in the NRC staff's 2005 review of salt waste disposal at the SDF. Key areas of interest continue to be waste form and disposal unit degradation, the effectiveness of infiltration and erosion controls, and estimation of the radiological inventory. Based on these factors, NRC is revising its plan for monitoring salt waste disposal at the SDF in coordination with South Carolina Department of Health and Environmental Control (SCDHEC). DOE has completed or begun additional work related to salt waste disposal to address these factors. NRC staff continues to evaluate information related to the performance of the SDF and has been working with DOE and SCDHEC to resolve NRC staff's technical concerns. (authors)

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D and D: Dismantling and Release of Large Components at the GNS Premises in Duisburg on the Example of a CASTOR S1 Container - 13536

There are a lot of metallic large components for the transport of radioactive waste in Germany. Some of these large components like for example the Castor S1 with 82 Mg are so old, that the transport via streets is not possible because the permission is not valid anymore. The application for a new permission is economically not reasonable. Out of this reason the large components need to be decontaminated and recycled to use them again in the economic cycle. Decontamination of large components by cleaning/removing the surface for example with beam technology is a very time-consuming release procedure. Manufacturing a specialized machine for decontamination and creation of a new surface was the intention of this project. The objective was to save interim storage and final repository volume and costs as well as developing a process that is nationally and internationally usable. 90% of the volume/mass of waste could be released and therefore possibly re-used. (authors)

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Sludge Settling Rate Observations and Projections at the Savannah River Site - 13238

Since 2004, sludge batches have included a high percentage of stored sludge generated from the H- modified (HM) process. The slow-settling nature of HM sludge means that the settling is often the major part of the washing tank quiescent period between required pump runs to maintain flammability control. Reasonable settling projections are needed to wash soluble salts from sludge in an efficient manner, to determine how much sludge can be washed in a batch within flammability limits, and to provide composition projections for batch qualification work done in parallel with field preparation. Challenges to providing reasonably accurate settling projections include (1) large variations in settling behavior from tank-to-tank, (2) accounting for changing initial concentrations, sludge masses, and combinations of different sludge types, (3) changing the settling behavior upon dissolving some sludge compounds, and (4) sludge preparation schedules that do not allow for much data collection for a particular sludge before washing begins. Scaling from laboratory settling tests has provided inconsistent results. Several techniques have been employed to improve settling projections and therefore the overall batch preparation efficiency. Before any observations can be made on a particular sludge mixture, projections can only be made based on historical experience with similar sludge types. However, scaling techniques can be applied to historical settling models to account for different sludge masses, concentrations, and even combinations of types of sludge. After sludge washing/settling cycles begin, the direct measurement of the sludge height, once generally limited to a single turbidity meter measurement per settle period, is now augmented by examining the temperature profile in the settling tank, to help determine the settled sludge height over time. Recently, a settling model examined at PNNL [1,2,3] has been applied to observed thermocouple and turbidity meter readings to quickly provide settling correlations to project settled heights for other conditions. These tools improve the accuracy and adaptability of short and mid-range planning for sludge batch preparation. (authors)

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The Waste Isolation Pilot Plant Deep Geological Repository: A Domestic and Global Blueprint for Safe Disposal of High-Level Radioactive Waste - 12081

At the end of 2011, the world's first used/spent nuclear fuel and other long-lived high-level radioactive waste (HLW) repository is projected to open in 2020, followed by two more in 2025. The related pre-opening periods will be at least 40 years, as it also would be if USA's candidate HLW-repository is resurrected by 2013. If abandoned, a new HLW-repository site would be needed. On 26 March 1999, USA began disposing long-lived radioactive waste in a deep geological repository in salt at the Waste Isolation Pilot Plant (WIPP) site. The related pre-opening period was less than 30 years. WIPP has since been re-certified twice. It thus stands to reason the WIPP repository is the global proof of principle for safe deep geological disposal of long-lived radioactive waste. It also stands to reason that the lessons learned since 1971 at the WIPP site provide a unique, continually-updated, blueprint for how the pre-opening period for a new HLW repository could be shortened both in the USA and abroad. (authors)

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Integrated Project Teams - An Essential Element of Project Management during Project Planning and Execution - 12155

Managing complex projects requires a capable, effective project manager to be in place, who is assisted by a team of competent assistants in various relevant disciplines. This team of assistants is known as the Integrated Project Team (IPT). he IPT is composed of a multidisciplinary group of people who are collectively responsible for delivering a defined project outcome and who plan, execute, and implement over the entire life-cycle of a project, which can be a facility being constructed or a system being acquired. An ideal IPT includes empowered representatives from all functional areas involved with a project-such as engineering design, technology, manufacturing, test and evaluation, contracts, legal, logistics, and especially, the customer. Effective IPTs are an essential element of scope, cost, and schedule control for any complex, large construction project, whether funded by DOE or another organization. By recently assessing a number of major, on-going DOE waste management projects, the characteristics of high performing IPTs have been defined as well as the reasons for potential IPT failure. Project managers should use IPTs to plan and execute projects, but the IPTs must be properly constituted and the members capable and empowered. For them to be effective, the project manager must select the right team, and provide them with the training and guidance for them to be effective. IPT members must treat their IPT assignment as a primary duty, not some ancillary function. All team members must have an understanding of the factors associated with successful IPTs, and the reasons that some IPTs fail. Integrated Project Teams should be used by both government and industry. (authors)

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F-Tank Farm Performance Assessment Updates through the Special Analysis Process at Savannah River Site - 12169

The F-Area Tank Farm (FTF) is owned by the U.S. Department of Energy and operated by Savannah River Remediation, LLC (SRR), Liquid Waste Operations contractor at DOE's Savannah River Site (SRS). The FTF is in the north-central portion of the SRS and occupies approximately 22 acres within F-Area. The FTF is an active radioactive waste storage facility consisting of 22 carbon steel waste tanks and ancillary equipment such as transfer lines, evaporators and pump tanks. An FTF Performance Assessment (PA) was prepared to support the eventual closure of the FTF underground radioactive waste tanks and ancillary equipment. The PA provides the technical basis and results to be used in subsequent documents to demonstrate compliance with the pertinent requirements identified below for final closure of FTF. The FTank Farm is subject to a state industrial waste water permit and Federal Facility Agreement. Closure documentation will include an F-Tank Farm Closure Plan and tank-specific closure modules utilizing information from the performance assessment. For this reason, the State of South Carolina and the Environmental Protection Agency must be involved in the performance assessment review process. The residual material remaining after tank cleaning is also subject to reclassification prior to closure via a waste determination pursuant to Section 3116 of the Ronald W. Reagan National Defense Authorization Act of Fiscal Year 2005. The projected waste tank inventories in the FTF PA provide reasonably bounding FTF inventory projections while taking into account uncertainties in the effectiveness of future tank cleaning technologies. As waste is removed from the FTF waste tanks, the residual contaminants will be sampled and the remaining residual inventory is characterized. In this manner, tank specific data for the tank inventories at closure will be available to supplement the waste tank inventory projections currently used in the FTF PA. For FTF, the new tank specific data will be evaluated through the Special Analysis process. The FTF Special Analyses process will be utilized to evaluate information regarding the final residual waste that will be grouted in place in the FTF Tanks and assess the potential impact the new inventory information has on the FTF PA assumptions and results. The Special Analysis can then be used to inform decisions regarding FTF tank closure documents. The purpose of this paper is to discuss the Special Analysis process and share insights gained while implementing this process. An example of an area of interest in the revision process is balancing continuous improvement versus configuration control of agreed upon methodologies. Other subjects to be covered include: 1) defining the scope of the revisions included in the Special Analysis, 2) determining which PA results should be addressed in the Special Analysis, and 3) deciding whether the Special Analysis should utilize more qualitative or quantitative assessments. For the SRS FTF, an FTF PA has been prepared to provide the technical basis and results to be used in subsequent documents to demonstrate compliance with the pertinent requirements for final closure of FTF. The FTF Special Analyses process will be utilized to evaluate the impact new information has on the FTF PA assumptions and results. The Special Analysis can then be used to inform decisions regarding FTF tank closure documents. In preparing SAs, it is crucial that the scope of the SA be well defined within the SA, since the specific scope will vary from SA to SA. Since the SAs are essentially addendums to the PA, the SA scope should utilize the PA as the baseline from which the SA scope is defined. The SA needs to focus on evaluating the change associated with the scope, and not let other changes interfere with the ability to perform that evaluation by masking the impact of the change. In preparing the SA, it is also important to let the scope determine whether the Special Analysis should utilize more qualitative or quantitative assessments and also which results from the PA should be addressed in the Special Analysis. These decisions can vary from SA and should not be predetermined. (author)

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River Corridor Closure at DOE's Hanford Site - 12503

The discussion of Hanford's River Corridor will cover work that has already been completed plus the work remaining to be done. This includes the buildings, waste sites, and groundwater plumes in the 300 Area; large-scale burial ground remediation in the 600 Area; plutonium production reactor dismantling and 'cocooning' along the river; preservation of the world's first full-scale plutonium production reactor; removal of more than 14 million tons of contaminated soil and debris along the Columbia River shoreline and throughout the River Corridor; and the excavation of buried waste sites in the river shore area. It also includes operating an EPA-permitted low-level waste disposal facility in the central portion of the site. At the completions of cleanup in 2015, Hanford's River Corridor will be the largest closure project ever completed by the Department of Energy. Cleanup of the River Corridor has been one of Hanford's top priorities since the early 1990's. This urgency has been due to the proximity of hundreds of waste sites to the Columbia River. In addition, removal of the sludge from K West Basin, near the river, remains a high priority. This 220-square-mile area of the Hanford Site sits on the edge of the last free-flowing stretch of the Columbia River. The River Corridor portion of the Hanford Site includes the 100 and 300 Areas along the south shore of the Columbia River. The 100 Areas contain nine retired plutonium production reactors. These areas are also the location of numerous support facilities and solid and liquid waste disposal sites that have contaminated groundwater and soil. The 300 Area, located just north of the city of Richland, contains fuel fabrication facilities, nuclear research and development facilities, and their associated solid and liquid waste disposal sites that have contaminated groundwater and soil. In order to ensure that cleanup actions address all threats to human health and the environment, the River Corridor includes the adjacent areas that extend from the 100 Area and 300 Area to the Central Plateau. For sites in the River Corridor, remedial actions are expected to restore groundwater to drinking water standards and ensure that aquatic life in the Columbia River is protected by achieving ambient water quality standards. It is intended that these objectives be achieved, unless technically impracticable, within a reasonable timeframe. In those instances where remedial action objectives are not achievable in a reasonable time frame, or are determined to be technically impracticable, programs are being implemented to contain the plume, prevent exposure to contaminated groundwater, and evaluate further risk reduction opportunities as new technologies become available. River Corridor cleanup work also removes potential sources of contamination, which are close to the Columbia River, and places them on the Central Plateau for final disposal. The intent is to shrink the footprint of active cleanup to within the 75-square- mile area of the Central Plateau by removing excess facilities and remediating waste sites. Cleanup actions are supporting anticipated future land uses consistent with the Hanford Reach National Monument, where applicable, and the Hanford Comprehensive Land- Use Plan (DOE 1999). The River Corridor has been divided into six geographic decision areas to achieve source and groundwater remedy decisions. These decisions will provide comprehensive coverage for all areas within the River Corridor and will incorporate ongoing interim action cleanup activities. Cleanup levels will be achieved in order to support anticipated future land uses of conservation and preservation for most of this area and industrial use for the 300 Area. At the conclusion of cleanup actions, the federal government will implement long-term stewardship activities to ensure protection of human health and the environment. (authors)

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Progress of GE development of accident tolerant fuel FeCrAl cladding

The Accident Tolerant Fuel (ATF) concept proposed by General Electric (GE) utilizes a FeCrAl alloy and current uranium dioxide (UO{sub 2}) fuel pellets, resulting in a fuel assembly that leverages the performance of existing LWR fuel assembly designs and infrastructure with improved accident tolerance. The focus of this paper is to report on the maturity of the concept and the overall feasibility on the use of ferritic FeCrAl alloys as cladding for nuclear fuel in commercial light water reactors. The following aspects are reviewed: mechanical properties, corrosion performance, stress corrosion cracking, fabrication assessments and performance evaluation. The results show that FeCrAl alloy clad fuel rods (with UO{sub 2} fuel) have reasonably demonstrated capabilities to meet or exceed current fuel design technical requirements while providing increased safety benefit during design basis events and severe accident conditions. Initial characterization of the materials, in particular APMT (the current leading FeCrAl alloy candidate whose composition is Fe + 22Cr + 5Al + 3Mo) indicates excellent operational and accident condition performance in both PWR and BWR environments. Challenges on the neutron economy and tritium release have a reasonable path to mitigation. The fabrication processes for the FeCrAl/UO{sub 2} system appears to be very similar to current LWR fuel fabrication processes (pilgering/extruding, heat treatments, welding, NDE techniques, etc.) which are mature and well understood. No issues are anticipated complying with current nuclear industry quality and performance standards.

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Development of molecular dynamics potential for uranium silicide fuels

The use of uranium-silicide (U-Si) in place of uranium dioxide (UO{sub 2}) is one of the promising concepts being proposed to increase the accident tolerance of nuclear fuels for light water reactors. First-principles based density functional theory (DFT) electronic structure calculations may provide the most reliable information. However, it is probably not possible to obtain kinetic information such as amorphization under irradiation directly from DFT simulations due to size and time limitations. Thus, a more feasible way may be to employ molecular dynamics (MD) simulation. Unfortunately, so far no MD potential is available for U-Si to discover the underlying mechanisms. Here, we present our recent progress in developing a U-Si potential. The development is based on the Tersoff type potentials for single element U and Si. The Si potential is taken from the literature and a Tersoff type U potential is developed in this project. With the primary focus on the U{sub 3}Si{sub 2} phase, some other U-Si systems such as U{sub 3}Si are also included as a test of the transferability of the potentials for binary U-Si phases. Based on the potentials for unary U and Si, two sets of parameters for the binary U-Si system are developed using the Tersoff mixing rules and the cross-term fitting, respectively. The cross-term potential is found to give better results on the enthalpy of formation, lattice constants and elastic constants than those produced by the Tersoff mixing potential, with the reference data taken from either experiments or DFT calculations. In particular, the results on the formation enthalpy and lattice constants for the U{sub 3}Si{sub 2} phase and lattice constants for the high temperature U{sub 3}Si (h-U{sub 3}Si) phase generated by the cross-term potential agree well with experimental data. Reasonable agreements are also reached on the elastic constants of U{sub 3}Si{sub 2}, on the formation enthalpy for the low temperature U{sub 3}Si (m-U{sub 3}Si) and h-U{sub 3}Si phases, and on the lattice constants of m-U{sub 3}Si phase. All these phases are predicted to be mechanically stable. The unary U potential is also tested for three metallic U phases (α, β, γ). The potential is found capable to predict the cohesive energies well against experimental data for all three phases. It matches reasonably with previous experiments on the lattice constants and elastic constants of αU. (authors)

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Software Quality Assurance for LeachXS/ORCHESTRA as a Tool for Assessment of Waste Management Systems Performance - 17486

Qualified modeling and simulation tools and experimental data are needed to provide a reasonable basis for the incorporation of realistic wasteform retention assumptions (i.e., those without orders-of-magnitude conservatism) into performance assessments and regulatory decisions. Use of highly conservative assumptions in performance assessments has historically led to the overprediction of release and near-field transport by as much as 4- to 6-orders of magnitude thereby limiting the nature and quantities of certain contaminants of concern in near surface disposal facilities. This project provides peer-reviewed models and characterization methods to provide more reasonable assumptions for use in performance assessments and regulatory decisions. Simulations tools have been developed to predict hydraulic and chemical performance of waste-forms and barriers used in nuclear applications under several important aging and degradation scenarios, including sulfate attack, carbonation, oxidation, cracking, and leaching; these tools are complaint with DOE Order 414.1D and ASME NQA-1. Wasteform characterization methods have been developed that are consistent with US EPA's Leaching Environmental Assessment Framework (LEAF) currently part of EPA's Hazardous Waste Test Methods (SW-846); the resulting experimental data are evaluated using LeachXS. ORCHESTRA models, that can be called seamlessly from LeachXS, have been developed representing both laboratory and field conditions; these models have undergone an extensive Software Quality Assurance process where they have been calibrated (where necessary), verified, and validated to be compliant with relevant guidelines. The models used for field predictions have also been incorporated into the Cementitious Barriers Partnership (CBP) Software Toolbox that allows probabilistic evaluation of field scenarios. The foci over the next year will be on providing 1) a mechanistic basis for projecting the retention of Tc-99, I-129, and other important radionuclides in near-surface disposal facilities at the Savannah River and Hanford Sites and 2) a technical basis for assessing the efficacy of macro-encapsulation of mercury-contaminated debris at the Oak Ridge Reservation. (authors)

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A paradigm shift - the key to optimal, defensible and transparent waste management, disposal and remediation decisions - 15236

Current methods for structuring nuclear waste management, disposal, and remediation decisions are subject to three major limitations. First, they are based on a series of extraordinarily conservative assumptions. The dominant way of thinking is that, for example, conservative models yield better, safer decisions. Second, they lack methods to meaningfully address and incorporate the 'human dimension'. The dominant way of thinking is that the current approach is sufficient to bring together the values and interests of both internal and external stakeholders in making a decision. And third, they lack a formal method through which both internal and external stakeholders are encouraged collectively to 'think through' complex problems that contain multiple competing objectives so that wise, socially acceptable, and scientifically-defensible decisions are made. To overcome these limitations, a paradigm shift is needed towards a holistic, integrated approach to structure nuclear waste management, disposal and remediation decisions. The first requirement of this paradigm shift is the realization and recognition that the problems faced are decision problems, and that there is a formal theory of decision analysis that can, and should, be used to support finding the best solutions. Decision analysis, very simply, is formalized common sense. The reason it is needed for complex problems is that there are too many moving parts (variables) for humans to manage with out the formalism. Decision analysis leads to addressing problem solving using a combination of a science-based model and a costs/values model. Expectation ('realism') and uncertainty are addressed in the science-based models, whereas stakeholder values, preferences, and desires are addressed when modeling costs and value judgments. Science-based modeling tools have been developed, improved, and used since the current regulatory setting was introduced about 30 years ago. However, modeling of costs and value judgments has not often been addressed using any formal approach, despite the openings that exist in regulations (e.g., CERCLA's modifying criteria and the concept of 'as low as reasonably achievable' referenced in DOE Orders). A discussion of the need and rationale for this paradigm shift is presented, followed by a description of the technical basics of this approach to decision modeling, and ending with an explanation of the steps that are taken in this approach to structured decision-making. A software framework program called Guided Interactive Statistical Decision Tools (GiSdT - pronounced 'gist') is introduced that supports this paradigm shift. (authors)

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Challenges of mine remediation programmes in developing countries - a life cycle perspective - 15371

This paper analyses some challenges of environmental rehabilitation (ER) projects in developing countries that the authors have encountered over the past two decades in many parts of the world, discusses the reasons and proposes ways to mitigate them. In the life cycle of an ER project, some stages that are particularly decisive for the lasting rehabilitation success are considered here: (1) site characterisation/baseline studies, (2) justification and development of remediation objectives, site end states and a remediation strategy, and (3) the after-care phase. This paper argues that the time available in many ER projects in developing countries using international funding is very often insufficient, and discusses the reasons for some of the most important bottlenecks: (1) time realistically required to produce thorough baseline data and obtain historic site information that are indispensable to develop a robust remediation design, (2) lack of an adequate legal and regulatory framework, overlapping and/or conflicting provisions of national standards and discrepancies with international best practice, (3) unmanaged stakeholder expectations regarding the actual health and environmental risks, justification and prioritisation of remedial actions, and the achievable remediation end state. Insufficient resources for after-care, monitoring and, if required, corrective action is another major issue that, in the experience of the authors, jeopardises the sustainability of remediation success. Consequently by applying the lessons learnt from previous ER projects in developing (and developed) countries and taking them on board during the programming phase of new ER projects, international funding agencies could greatly help to avoid these obstacles. (authors)

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The root causes of siting failures in nuclear waste management - 15652

For many decades, the global nuclear industry and associated governments have attempted to establish new facilities for the storage and disposal of nuclear wastes. Success has been rare (France, Sweden and Finland being the examples) and remains elusive for many programs despite attempts to change the selection process in some cases. Success has been aided by local and national consent in the few cases that are proceeding. A small study of several countries lack of success is examined to determine the dominant reasons for such failures. The goal of the study is to inform the planning process for efforts to site new facilities by feeding back some lessons learned from past failed efforts. This limited review of international experience indicates that there is no simple approach available for siting deep geologic disposal or even centralized storage facilities. A number of countries have tried multiple times to find an acceptable site. Two studies [1, 2] clearly indicate that there must be adequate assurance of social as well as technical acceptability for successfully siting such facilities. It is evident that even though the technology and science may be proven, it is the politics and public engagement in siting processes that dominate the failures. However, the detailed reasons within each effort present a richer set of lessons. This paper will summarize the findings and present them such that they can be used to inform future siting efforts by a nation. (authors)

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Revision of the Branch Technical Position on Concentration Averaging and Encapsulation - 16315

On February 25, 2015, the U.S. Nuclear Regulatory Commission (NRC) issued Revision 1 of the Branch Technical Position on Concentration Averaging and Encapsulation (CA BTP), culminating a six-year process. This revision provides updated guidance on the interpretation of paragraph 61.55(a)(8) of Title 10 of the Code of Federal Regulations, 'Determination of concentrations in wastes', as it applies to the classification of a variety of different types and forms of low-level radioactive waste (LLW) as Class A, B, or C waste. The waste class determines the minimum safety measures to be applied in order to provide reasonable assurance of safe disposal of the waste. The CA BTP is used by thousands of LLW generators, by the waste processing industry, by all operating LLW disposal sites in the U.S. and by Agreement States. The previous version of the CA BTP, published in 1995, was issued before the NRC adopted its risk-informed and performance-based regulatory policy. The revised CA BTP has been informed by that policy. The revised CA BTP also contains new guidance on acceptable methods that can be used to perform concentration averaging of LLW for the purpose of determining its waste class for disposal. This paper provides background information on why the CA BTP was issued and subsequently updated. This paper summarizes the new guidance found in the revised CA BTP. This paper also explains some of the key issues that required NRC's resolution, and the reasoning that underpins the major decisions reflected in Revision 1 of the CA BTP. (authors)

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Natural Attenuation Progress, Plume Movement, and Source Reduction for the SRS CMP Pits VOC Plume - 18384

Monitoring the effectiveness of natural attenuation for remediating the Savannah River Site (SRS) Chemical, Metals, and Pesticides (CMP) Pits plume fringe has focused intensive sampling of shallow groundwater for different reaches of Pen Branch from 2005 to 2017. Volatile organic compounds (VOCs) were analyzed for the critical hyporheic zone beneath Pen Branch and adjacent floodplain. These sampling efforts assisted larger-scale compliance monitoring in accordance with US Environmental Protection Agency (EPA) guidelines. When applicable, EPA has found natural attenuation to be an acceptable mode of achieving regulatory compliance. While natural attenuation can include any ecosystem function that reduces contaminant loads, it is focused on microbial biochemical pathways. The study plume originated from CMP Pits, a waste disposal area in operation from 1971 to 1979, when the pits were closed and backfilled. In 1984, excavations of source material and contaminated soils were removed up to a depth of 7.6 m below the trenches. However, monitoring well data indicated that perchloroethylene (PCE) and trichloroethylene (TCE) had seeped beneath the vadose zone and formed groundwater plumes reaching the Pen Branch valley below. Although 'hot spots' of TCE were found within the Pen Branch floodplain, it was unknown just how the flow pattern was entering Pen Branch and to what degree natural attenuation was reducing the contaminant load. For this reason, our stations were located along the Pen Branch reach bordering the modelled plume fringe. In general, VOCs were highest at station piezometer holes in the middle study zone. Moderate VOC levels were detected at upstream stations and lowest VOC levels were found at downstream stations. Electrical resistance heating (ERH) with soil vapor extraction (SVE) conducted by Savannah River Nuclear Solutions (SRNS) from 2008 to 2009 at the filled CMP Pits helped to remove contaminants trapped in clay horizons beneath the CMP Pits and to reduce overall new plume concentrations. Collectively PCE, TCE, and their degradation products displayed a favorable yearly trend of contaminant natural attenuation. Additionally, phytoremediation actions by native bamboo, Arundinaria gigantea, added to VOC removal from wetlands soils. Total VOC concentrations at some stations declined by >25% and concentrations of vinyl chloride (VC), a nearly-final stage degradation product increased from 0.0 ppb to >20 ppb. Temporal patterns displayed a continued reduction of VOCs, while spatial patterns indicated a possible slow progression of the plume downstream along Pen Branch. Conclusions about plume export into surface waters must address the seasonal and geological complexities of this system. Hydrological patterns are complex and plumes do not directly outcrop into Pen Branch surface waters, but emerge into the stream through pathways in the porous hyporheic zone. For this reason, continued sampling must identify critical depths and downstream locations where plume flows may be more intense. During drought periods with no surface flow in Pen Branch, subsurface plume flows may be flowing downslope in the hyporheic zone. (authors)

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A Novel Mobile Examination and Remediation Facility for On-Site Remediation of Dry Storage Systems - 18389

Most of the spent nuclear fuel (SNF) in dry storage in the United States is safely and securely stored in dual-purpose (i.e., storage and transportation) canisters [1]. However, some of the SNF is stored in storage-only (i.e., non-transportable) packages, or packages that may become nonconforming for continued storage or transportation for a variety of reasons. Currently, the capability to remediate dry storage systems (DSSs) for SNF that are not transportable or that need to be repaired to maintain confinement boundary integrity during storage service does not exist without on-site access to a spent fuel pool. Hence, there is a potential future need for a mobile facility with remediation capabilities that can be used at multiple storage installations. These capabilities would permit needed repairs to an existing DSS to support continued storage or for the dry transfer of fuel to a new conveyance suitable for transport, if necessary. This is a technical paper that does not take into account the contractual limitations under the Standard Contract for Disposal of Spent Nuclear Fuel and/or High-Level Radioactive Waste (Standard Contract) (10 CFR Part 961). Under the provisions of the Standard Contract, DOE does not consider spent nuclear fuel in canisters to be an acceptable waste form, absent a mutually agreed to contract amendment. To the extent discussions or recommendations in this paper conflict with the provisions of the Standard Contract, the Standard Contract provisions prevail. A novel design concept for a Mobile Examination and Remediation Facility (MERF) is proposed with functions and capabilities to remediate a DSS. The proposed MERF would be a multi-purpose facility, remotely operated and computer-controlled with semi-automated equipment to allow trained operators to safely perform remediation activities while keeping worker radiation dose as low as reasonably achievable. It would include a shielded rotating platform with support towers and would use commercial off- the-shelf examination and repair equipment. A slip ring arrangement underneath the rotating platform would allow for the power supply without impeding the continuous rotation and would simplify cable management. The support towers would be mounted on the rotating platform, and each tower would have vertical and horizontal positioning capability for axial and radial tool location. The rotating platform would be attached to the main MERF structure. Capabilities would include visual, surface, and volumetric examinations to fully characterize physical conditions on canister surface before and after a repair; repair techniques, e.g., laser beam welding, friction stir welding, or cold spray, to perform needed remediation activities; and associated equipment for surface preparation such as cutting and grinding equipment. The proposed design would be simple, modular, robust, economically viable, and easily transportable and would have a small footprint. The modular design would present several advantages including compatibility with a variety of different DSSs, on-site assembly, and transportability; it also would be built in interchangeable sections to facilitate decontamination. Further, shielding would be supplemented through interface with the existing transfer cask and storage overpack. Robustness and canister stability would be achieved using pneumatic holders and steel support structures designed with vibration absorbers to reduce impacts and/or a 'pendulum' effect during a seismic event. Thus, the proposed MERF would be designed to: (i) minimize handling of an affected DSS to the extent practicable, (ii) provide radiation shielding and minimize dose to operators and the public during remediation activities, and (iii) enable examination, repair, and repackaging. This paper describes the proposed MERF design concept and capabilities, main components, equipment, different modes of operation, and operating procedures. Structural and safety assessments would need to be performed before final design, licensing, and deployment. The MERF is evaluated with respect to regulatory impact (first of a kind, prior experience), operational impact (safety, security, staffing, ongoing operations, constraints), worker dose (low, medium, high), cost (low, medium, high), schedule (duration, time sequence), and technology readiness level. (authors)

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Peculiarities of Transition from Operation to Decommissioning for the Chernobyl NPP - 18486

Usually the transition period is supposed to last around 5 years and to cover the eventual defueling of the reactor and the reactor cooling pool, completion of the characterization survey and preparation of all necessary documents to start the decommissioning activities in accordance with the decommissioning strategy chosen and the decommissioning plan approved. It was not the case for the Chernobyl NPP due to a number of reasons and obstacles, including delayed defueling due to unavailability of the storage capacities, lack of preparatory work due to prescheduled decommissioning, luck of experience of RBMK-type reactors decommissioning, influence of the destroyed Chernobyl-4 Unit and related works on site. All these factors not only delayed the completion of the characterization survey, but added complications to development of the decommissioning strategy and the decommissioning plan. De facto the issue of end state is still open as the end state for the destroyed Chernobyl-4 as well as the prospects of the exclusion zone transformation need further clarifications and justifications. As a result, the need to reconsider the standard concept of transition period was recognized already by the end of 2000, when Chernobyl-1 and Chernobyl-2 were out of operation for a few years. It was clear that the personnel had generally a bad perception of the prescheduled permanent shutdown decision and a low motivation to change and to learn. The first signs of organizational degradation were visible and the framework of the operational license did not fit well to prevent it. So it was decided to start the legal and organizational transformation into the decommissioning mode without waiting for polishing of the decommissioning strategy and decommissioning plan as in this case both documents seemed to need further adjustments anyway. The transition period (or the termination of operation as it called in the national nuclear safety regulations) was considered as the first phase of decommissioning to be covered by the decommissioning license. The detailed plan of activities for the transition period with proper safety justification documents was the main part of the relevant license application. Human resource management plan and adoption of the management system were important constituents as well. It was also considered reasonable to start some dismantling works already at this phase to avoid further delays and degradation, the works being carefully justified. Eventually such approach added to streamlining the decommissioning process and to avoid further organizational and technical degradation. Flexibility in transition from operation to decommissioning seems necessary in cases of prescheduled or post-accidental decommissioning but may be also beneficial for a scheduled decommissioning case. (authors)

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