J. Greg Field and Dennis L. McCall, Waste Management Federal Services, Inc., Northwest Operations, Hanford; Brent A. Daugherty and Tom Dyer, Savannah River Site; Stanley T. Kosiewicz, Los Alamos National Laboratory; Ronald B. Pope and Randy Walker, Oak Ridge National Laboratory; Anthony J. Trennel, Sandia National Laboratory; John R. Patterson, Nuclear Assurance Corporation; Kenneth Lenarcic, Rocky Flats Environmental Technology Site; Brent W. Dixon, Idaho National Engineering Laboratory; Lloyd Donovan, West Valley Nuclear Services; Paul T. Dickman, U.S. Department of Energy-Albuquerque

A team of DOE and contractor transportation experts was challenged by the EM Complex-Wide Integration Working Group to develop strategies for resolving transportation issues perceived as barriers to successful inter-site waste management initiatives. This paper describes the team’s activities and recommendations.

The EM Integration Transportation team reviewed the waste stream transportation links between DOE sites and formulated seven specific solutions to resolve the most significant barriers. In a follow-on effort, the team focused on transportation opportunities that might lead to additional cost savings or program accelerations. These opportunities were grouped into three major issue categories: regulatory; stakeholder, and packaging. A formal process was followed to select a preferred set of recommendations for each area.

Through this effort, the team identified solutions that can significantly influence the outcome of the EM Integration initiatives. Key opportunities involve complex-wide integration of transportation activities and elimination of overly restrictive regulations that add cost without enhancing safety. Cost savings result primarily from the elimination of treatment facilities needed to process waste to meet current requirements for transportation or disposal. Most of the significant opportunities identified require strong leadership and an investment in development funds, but the potential payback in waste stream cost savings exceeds $1B and cleanup schedules are reduced by up to 10 years.

During fiscal year (FY) 1997, site operating contractors of the U.S. Department of Energy (DOE) continued working to develop integrated solutions to complex-wide waste management problems.. In the process, the waste type subject matter experts (SME) identified several transportation issues as barriers or inhibitors to many of their preferred recommendations.¹ As a result, in April 1997, transportation SMEs from site contractors and the DOE were tasked to develop strategies for resolving these barriers.

The EM Integration Transportation effort involves three phases, each of which addresses a different waste type. Phase I, discussed in this paper, focuses on Environmental Restoration and Waste Management (ER &WM) inter-site waste shipments of transuranic (TRU) waste, mixed low-level waste (MLLW), and low-level waste (LLW), including special case waste (SCW). Phase II, scheduled for FY 1998, will address high-level waste (HLW) and spent nuclear fuel (SNF) inter-site shipments, and Phase III will address the remaining waste types, such as isotopes, non-EM SNF, and other defense wastes.

The Phase I effort was achieved in two multi-day workout sessions involving a multi-disciplinary team of transportation, packaging and waste stream experts from across the complex, representing DOE and contractor organizations. The initial effort focused on evaluating the adequacies or gaps in the transportation links identified in the overall EM Integration preferred or alternative solutions. Solutions were proposed to resolve the transportation gaps. Next, the team identified and recommended integration opportunities specific to transportation which would significantly reduce program costs, risks, volumes transported, and total number of planned shipments to accomplish the EM Integration objectives.

Resolution of the transportation gaps entailed examination of the several hundred potential transportation links between DOE sites. The focus of this evaluation was to determine which transportation links were "OK" or "viable" and which were considered "broken" or just "bent." Links were considered "broken" if the transportation could not proceed without additional facilities, packagings, or activities that were not planned or budgeted. An example would be the lack of an existing or planned characterization capability at the originating site. Links were considered "bent" if there was an established path forward, but the problem resulted in an inefficient solution. An example would be high density waste that would meet the weight limits of the packaging by only partially filling the available volume, resulting in an increased number of shipments. About 45 percent of the transportation links were found to be problematic.

The transportation links were identified by waste type (TRU, LLW, MLLW, etc.), point of origin and final destination. Based on the existing waste characterization information available, potential transportation systems were identified for the shipment of these materials and wastes under the baseline and alternative scenarios developed by the waste type SMEs. The types and quantities of packaging currently available or planned, as well as their authorized payloads and capacities, were used to determine packaging adequacy. Facility handling interfaces and regulatory restrictions were also considered.

The broken and bent links were found to have a common set of causes:

• Waste contents exceed available packaging operating envelopes for heat load, flammable gas generation, and weight.
• Waste contents characterization information is not sufficient to classify for transportation or meet waste acceptance criteria.
• The volume capacity of the available packagings is small compared to the total volume of waste that will be transported.
• Stored waste will require resizing prior to transportation.
• Certain waste forms are too large or unique to be transported by available transportation systems.
• Many available packagings are no longer authorized to be built or significantly modified.

Several gap problem causes were common to all three waste types. These include insufficient waste characterization to support transportation categorization, and the insufficient capacity and flexibility of Type B shipping packages. Other problems were particular to TRU waste TRUPACT-II limitations. Given the available information, the team developed the following proposed solutions to resolve the causes of the "broken" and "bent" transportation links:

• Maximize the allowable contents in the TRUPACT- II (requires continuing ongoing engineering studies and actual testing to demonstrate the required level of safety and obtaining regulator approval)
• Engage the Nuclear Regulatory Commission (NRC) research division to participate in development of technical solutions for the high H₂ generation problem
• Extend the life of the current fleet of Type B packages (Casks), and developing new Type B packages for inter-site shipments
• Use the existing Atomic Munitions Transporter (ATMX) rail cars with the current U.S. Department of Transportation (DOT) Exemption for the movement of materials authorized under this approval
• Develop a new Type B rail-based packaging and transport system based on authorized performance standards and certified by the NRC
• Use a special team of packaging, transportation, and waste management experts to address on a case-by-case basis the shipment and disposal of large, high-activity orphan items
• Implement a comprehensive waste characterization and classification program to address legacy wastes.

As a group, these recommendations might eliminate the need for significant new and unplanned infrastructure improvements at many DOE sites such as facilities needed for waste treatment, sizing, and/or repackaging prior to transportation or disposal. They also contribute to substantial life-cycle cost savings, even with the necessary up-front investment that is required.

The Transportation team was also tasked with identifying integration opportunities specific to transportation that could significantly reduce program costs, risks, volumes transported, and total number of shipments needed to accomplish the baseline and alternative recommendations of the EMI integration effort and the DOE’s accelerated cleanup plan³ (2006 Plan objectives). Brainstorming techniques were used to obtain an extensive list of potential opportunities.

The opportunities list was iteratively screened by the full team. During each iteration the surviving opportunities were more fully developed and benefits and barriers identified. The final opportunities list was then grouped into four compatible sets, or "alternatives," based on the levels of system change they involved. The first alternative set included only the packaging and technology solutions developed to address programmatic gaps. The other three alternative sets involved successively more aggressive approaches to tackling regulatory and institutional issues. The alternative sets follow:

The baseline represents the presently planned and funded situation, with no additional action.

It should be noted that, within the current baseline there are efforts to improve the payload of TRUPACT-II, develop the HALFPACK, and to utilize "out-of-commerce" transport in emergency situations or to meet local needs. Out-of-commerce transport involves the use of government (noncommercial) drivers and vehicles resulting in movements which are outside the jurisdiction of commerce-based regulations.

Moderate Confidence in Achieving Success, with Moderate Savings - This alternative incorporates actions necessary to close gaps and achieve the transportation requirements of the baseline and EM Integration program, and primarily focuses on the development of adequately flexible packaging to support required transport. Features include expanded applicability of existing shipping packages and developing new packages where necessary, as well as use of existing exemptions and other near term actions while new packaging is under development, certification, and fabrication.

The out-of-commerce control is selectively applied to handle oversized, high-activity orphaned waste. Research is supported to reduce or eliminate gas generation problems. Existing rail-based systems are used under exemption on an interim basis, and new Type B rail-based packaging is developed.

High Confidence in Achieving Success, with Low Savings - This incorporates actions necessary to support most of the transportation requirements of the 2006 Plan and makes some improvements in efficiency and/or cost by extension of regulatory limits. These actions are largely technical in nature and are performed using established regulatory procedures.

For instance, the actions required to delete the requirements for double containment of nondispersible plutonium include the generation of safety analysis data that can be taken to the NRC using existing procedures for regulatory amendment. Existing DOE mechanisms can charge a coordinating council to provide advice concerning the transportation or to address the unique requirements of high-activity orphans. Existing standards organizations could be used to develop a consensus standard for waste containers.

Moderate Confidence in Achieving Success, with High Savings (selected as the preferred alternative and highlighted on Table I) - Difficult but could be accomplished. This alternative encompasses those changes in the DOE approach to business that involve substantial changes to current operations, changes to regulatory requirements, and refocusing on external drivers that led to DOE self-imposed requirements beyond those specified in the transportation regulations, such as unique stakeholder agreements..

Low Confidence in Achieving Success, with High Savings - Alternative 4 requires aggressive actions by DOE, but it offers the potential for significant payoffs in terms of large cost savings and significant schedule accelerations. This alternative challenges DOE’s traditional method of doing business in the transportation arena since it requires integration and coordination between sites, programs and DOE-HQ; and elimination of the ad hoc approach to working with stakeholders. It would also include regulator and external stakeholder involvement possibly reversing some precedents and agreements established with these entities in the past. Success would occur only if it can be demonstrated to the stakeholders (through well conducted and documented assessments) that taxpayer costs will be significantly reduced while safety is not compromised.

Table I identifies the opportunities evaluated and their relationships to the alternatives.

a. Intersite shipments in emergency situations only.
b. Intersite emergency shipments and selected oversized/high-activity orphans.
c. General use where economical.
d. NRC certification would be based on the safety performance of the total system (package and vehicle).

Using a systems engineering approach, the EM Integration Transportation team analyzed the four sets of alternatives to determine the best approach to achieve complex-wide integration.

All alternatives were felt to be technically defensible and provide appropriate levels of environmental protection and safety. The team selected Alternative 3 as the preferred alternative. This alternative removes transportation roadblocks to achieving the 2006 Plan while taking a reasonable, safety-based approach to regulatory and institutional barriers.

Alternative 3 challenges several specific areas in the baseline, which, if examined individually, could be received negatively. In particular, there is considerable institutional and stakeholder inertia associated with the exclusive use of a truck-based system for TRU waste transport. However, increased TRU waste transport flexibility is desirable given the large volumes of waste, highway weight limits, and the technical restrictions of the TRUPACT-II package.

Most Alternative 3 opportunities are highly interdependent. Significant accomplishment in one area reduces the effort needed in other areas to achieve overall goals. For example, since excessive gas generation is the reason several waste streams fail to meet TRUPACT-II requirements, a complete technical breakthrough related to gas mitigation would reduce the need for a new truck-based Type B system. As another example, expanded use of the out-of-commerce option for oversized items would reduce the need for a large volume rail-based package.

The 21 opportunities identified in the shaded boxes of Table I (Alternative 3) are recommended to improve the current baseline. The opportunities are sorted into three primary categories: regulatory, stakeholder, or packaging.

The categories were reviewed to develop proposed actions to implement the opportunities. In particular, the opportunities in a category were further grouped, as practicable, to develop common strategies for implementation. Following is a summary of key opportunities for each category:

DOE Actively Interact with DOT and NRC to Influence Future Regulatory Changes

• Problem Statement - Several existing regulatory requirements add complexity, cost, and personnel exposure without improving safety, and others may be proposed in the future.
• General Opportunity - DOE should develop a coordinated program, using experts from its staff and contractors to work cooperatively with the regulators to develop future changes in transport regulations. These future changes can be driven by a number of factors including: implementation of international regulations nationally, modifying current requirements in the regulations, and developing meaningful guidance for interpreting and applying the regulations.
• Specific Opportunities - a) interpretation and application of double containment criteria, b) clarification on the shipment of solid low specific activity (LSA)-II in bulk packagings, c) guidance on the shipment of large contaminated self-contained objects, d) adoption of new definitions for radioactive material promoted by the international community, and e) the need to grandfather certain packaging during a transitional period.

Eliminate Unnecessary, Inefficient, and Excessively Restrictive Self-Imposed Requirements

• Problem Statement - DOE has imposed on itself and its contractors a number of restrictions and operational requirements that are not driven by transportation regulatory requirement or safety concerns which add costs and complexity to DOE’s packaging and transportation operations.
• General Opportunity - DOE should consider removing extra-regulatory requirements, establish common policies and procedures complex-wide for the transport of radioactive and hazardous materials and wastes, and establish a senior management council to advise the National Transportation Program on policy, budget and procurement of services.
• Areas needing attention - a)dilution and homogenization of wastes, b) extra-regulatory requirements driven by conflicting regulations and stakeholder postures, c) poor coordination of complex-wide transportation initiatives, and d) extended shipment delays, which result in higher overall costs and higher site mortgages.

Develop an Inventory of Type B Packages Suitable to Meet Shipment Needs

• Problem Statement - The projected inventory of Type B packages (cask type containers) is inadequate to meet the needs of the EM program.
• General Opportunity - Initiate a program to enhance existing Type B packaging capabilities and to develop needed new packaging designs.
• Specific Opportunities - a) expand the TRUPACT-II operating envelope in terms of curie loading, heat generation, etc., b) develop new Type B packages for certain classes of waste (e.g., high-activity LLW, CH and RH-TRU, high heat source waste, etc.), and c) develop large capacity truck and rail based systems for large components and minimize the number of required shipments.

Develop Performance-Based Flammable Gas Policy

• Problem statement - Packages currently authorized for transporting TRU wastes are very limited in capacity due to material type and quantity limitations based on the potential of hydrogen gas generations during transportation.
• General Opportunity - Partner with the NRC research division to develop an approach to solving the hydrogen generation issue associated with the transport of TRU waste
• Areas needing attention - there are a number of mechanical and chemical approaches to mitigate hydrogen generation from waste inside the transport package. Some of these that should be explored include: hydrogen getters, venting, purging, and inerting the cavity with inert gas. Solving this problem would allow much higher curie loadings, loosen restrictions on hydrogenous material, and reduce the numbers of packages and shipments significantly.

Establish a Team of Experts to Develop a Path Forward for Large, High-Activity Orphans

• Problem statement - Many sites have unique waste components that may be oversized, or have very high activity that pose significant transportation challenges (e.g., large contaminated vessels, glove boxes trains, uniquely shaped articles).
• General Opportunity - Set up a team of SMEs representing packaging, transportation and waste management expertise to identify creative solutions for each of these unique wastes.
• Specific Opportunities - These wastes should be campaigned on a priority basis. The team should explore technical, regulatory, and stakeholder issues and develop and execute a plan that fully meets environmental protection and safety issues.

The Phase I EM Integration Transportation effort included the evaluation of transportation issues associated with the waste type baseline and alternative cases. It was found that 45 percent of the required transportation links between sites were problematic. A set of specific causes was identified and solutions were proposed to resolve them. Subsequent evaluation of the transportation links revealed integration opportunities which might significantly reduce cost, risks and schedule, and 21 actions were identified as opportunities for improvements over the current baseline.

These opportunities fall into three general areas: regulatory, stakeholder, and packaging. Regulatory issues might be resolved by appropriate interaction with the regulators on specific DOE waste forms, recognizing that DOE has unique transportation needs that are not all well represented in the current regulations. Stakeholder agreements and interactions, while necessary, may impose requirements on transportation that increase cost and schedule, but do not enhance safety and are not required by the transportation regulations. Those agreements should be examined to determine overall value. The packaging issues result from the variety and complexity of the DOE waste forms and an aging packaging fleet that is being superseded by regulation changes and various technical issues. The transportation SMEs strongly suggest that compliance with the transportation regulations provides an appropriate level of safety to workers, the public, and the environment during transportation.

The proposed opportunities represent a step forward, but considerable follow-on effort is needed to validate the identified issues and potential effectiveness of implementing the opportunities. Since the issues are not simply technical or regulatory, all affected parties need to be involved in the validation process. While these opportunities offer significant cost savings to the DOE complex, it will take effective and dedicated leadership to turn these opportunities into reality.

1. Complex-wide EM Integration, 1997, Contractor Report to the Department of Energy on Opportunities for Integration of Environmental Management Activities Across the Complex (Pre-decisional Draft), Idaho National Engineering and Environmental Laboratory Report INEEL/EXT-97-00065, Idaho Falls, Idaho, March 1997.
2. Complex-wide EM Integration, 1997, Transportation Needs, Issues, and Opportunities, Phase I - Environmental Management’s Transuranic Waste, Mixed-Low Level Waste, and Low-Level Waste (Pre-decisional Draft), Idaho National Engineering and Environmental Laboratory Report INEEL/EXT-97-01048, Idaho Falls, Idaho, September 1997.
3. DOE-EM, 1997, Accelerated Cleanup: Focus on 2006, Discussion Draft, DOE/EM-0327, June 1997.

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