The Hanford Site has a waste receipt quality assurance program (or customer Performance Evaluation System) to ensure that radioactive waste shipped to the Hanford Site is properly characterized and meets the Hanford Site Solid Waste Acceptance Criteria. The Performance Evaluation System is based on waste analysis plans and DOE requirements.
The Performance Evaluation System is performance-based. In other words, verification of a representative portion of a customer’s waste containers is used, rather than audits, to ensure the quality of waste received. The program establishes an initial verification frequency, monitors a customer’s performance, and adjusts the verification frequency based on that performance. In general, the minimum verification frequency is 5% for low-level and TRU waste and 10% for mixed and TRU-mixed waste. When consistent problems are found, the Performance Evaluation System is used to identify and implement corrective actions.
Compliance With Radioactive Waste Acceptance Requirements
New Waste Stream Initial Verification Frequency
When a customer submits a Waste Profile Sheet for a new waste stream, the form is reviewed to determine the initial verification frequency. This decision uses the following information to determine the relative potential for problems in the waste stream:
- Documentation of the customer’s waste management program
- Waste stream characterization information
- The potential for inappropriate segregation in the waste stream
The Hanford acceptance organization establishes the initial physical screening frequency using the following guidelines.
- Initial Physical Screening Frequency Between 20-50%: no concerns identified. Example: Clean up of contaminated soil where the soil has been well characterized and no other waste generation processes are occurring at that location.
- Initial Physical Screening Frequency Between 50-100%: Concern(s) identified in one of the criteria. Example: A waste stream generated in a facility that has many different processes that generate waste streams having differing management paths.
- Initial Physical Screening Frequency of 100%: concerns identified in two or more criteria. Example: A waste stream generated in a facility that has many different processes and has questionable segregation controls.
Determinations for Non-VerifiableWaste
Certain waste streams may not be verifiable because of waste form or As Low As Reasonably Achievable (ALARA) constraints. Non-verifiable waste streams will be evaluated on a case-by-case basis, relying on more extensive documentation and certification program review. On completion of this review, a determination will be made if special types of verification must be used to ensure that the waste meets the acceptance criteria. This could include verification of the waste at the point of generation or observation of the generating process.
Monthly Customer Evaluations
The Hanford acceptance organization performs monthly evaluations to identify trends in performance and to correct waste certification problems before these become severe. Each month, records of any significant deficiencies found during shipment review and receipt verification are evaluated and graded by severity. If a customer scores greater than 10 (based on set ranking criteria) for the month, the verification frequency is adjusted as follows:
- Score of 10 to 15 based on severity: frequency increased to a minimum of 15%.
- Score of 16 to 20 based on severity: frequency is increased to a minimum of 50%.
- Score greater than 20 based on severity: frequency is increased to 100%.
Resolution of Conformance Issues
Occasionally, container verification and receipt inspections identify conformance issues. These can range from relatively minor issues (e.g., a mistake in container labeling), to major problems that require processing the waste or rejection of the shipment. When a potential conformance issue is identified, the Waste Management Representative works with you to resolve the problem, as follows.
- The customer’s Waste Management Representative compiles all information about the potential conformance issue.
- The Waste Management Representative notifies the customer and might request additional information or clarification to resolve the potential conformance issue. If the customer supplies the Waste Management Representative with information that shows that there is no actual deficiency, the WMR documents this and the waste is accepted.
- If it is determined that there is an actual conformance issue, the Waste Management Representative and the customer work together to identify the best way to resolve the problem. This could include choosing additional containers for verification, returning the container or shipment, sending the shipment to a waste management unit to correct the problem, or having the customer resolve the problem at the waste management unit. If the conformance issue was sufficiently severe to result in the rejection of a shipment, the physical screening frequency for all of the customer’s waste streams is adjusted to 100% until the cause of the problems can be assessed.
- When the conformance issue has been resolved, the Waste Management Representative requests the customer to provide a Corrective Action Plan that identifies the reason(s) for the problem and describes the actions to be completed to prevent the problem from happening again. At this time, the customer may request a reduction in verification frequency for waste streams that did not have conformance issues. This request must be accompanied by an explanation of why these streams will not exhibit the same conformance issue.
- The Hanford acceptance organization will review the Corrective Action Plan and stream justification. If a Corrective Action Plan is determined to be inadequate, the customer remains at a physical screening frequency of 100%. If the stream justification is adequate, the physical screening frequency could be adjusted.
- A determination will be made whether the failure is due to a programmatic problem or is specific to the individual waste stream. The customer’s minimum physical screening frequency will be based on the following criteria and performance within the last 12 months:
- 15% to 50% - Conformance issues that are not a safety problems, regulatory violations, or result in mismanagement of the waste.
- 50% to 100% - Conformance issues that result in regulatory violations, but do not cause a safety problem or mismanagement of the waste.
- 100% - Conformance issues that result in regulatory violations and mismanagement of the waste or a safety problem.
Reducing the Physical Screening Frequency
Methods are established to reduce the physical screening of a new waste stream and for waste streams for which the physical screening frequency has increased as a result of conformance issues. In the case of waste streams having higher physical screening frequencies due to conformance issues, progression through the following steps is based on the customer’s ability to quickly implement their Corrective Action Plan.
- Step 1 reduction: reduce frequency by a maximum of 66%.
- Step 2 reduction: reduce frequency by a maximum of 50%.
- Step 3 reduction: reduce frequency to the minimum allowable screening frequency.
The amount of reduction will be determined during the monthly evaluation process. The following minimum criteria must be met before reduction of the frequency.
- Five containers from the stream in question must pass verification.
- If the frequency was increased based on conformance, the Corrective Action Plan must be fully implemented before the customer returns to the minimum physical screening frequency. Additionally, Hanford may choose to perform a site visit to obtain documentation that the Corrective Action Plan has been fully implemented.