Display Related Directives to this directive.

CROSSWALK TABLES
DOE 5820.2A vs. DOE O 435.1/M 435.1-1

These crosswalk tables have been prepared to assist in understanding how the requirements that
are currently in 5820.2A are addressed in the DOE O 435.1 and DOE M 435.1-1. The tables are
prepared by waste type, and are indexed sequentially on the citations within DOE 5820.2A. The
proposed disposition of any requirement that is in the current Order can be ascertained by
entering the appropriate crosswalk table and finding the DOE 5820.2A citation in the left hand
column, and the requirement in the second column. The corresponding 435.1-1 directive citation
appears in the third column and the requirement appears in the far right hand column. In those
instances where the 5820.2A requirement was not retained in its original or modified form, or
was not covered by other cited DOE O 435.1/M 435.1-1 requirements, the "435.1-1
CITATION(s)" column will indicate "Not Retained" or "None"and the "435.1-1
"REQUIREMENT(s)" column will explain the technical basis for deleting the requirement. (This page intentionally left blank.)
5820.2A
Citation
5820.2A REQUIREMENT
435.1-1
Citation
435.1-1 REQUIREMENT

O.1
PURPOSE. To establish policies, guidelines, and minimum
requirements by which the Department of Energy (DOE)
manages its radioactive and mixed waste and contaminated
facilities.
O.1

M.1
OBJECTIVE. The objective of this Order is to ensure that all
Department of Energy (DOE) radioactive waste is managed in a manner
that is protective of worker and public health and safety, and the
environment.

PURPOSE. This Manual further describes the requirements and
establishes specific responsibilities for implementing DOE O 435.1,
Radioactive Waste Management, for the management of DOE high-level
waste, transuranic waste, low-level waste, and the radioactive
component of mixed waste. The purpose of the Manual is to catalog
those procedural requirements and existing practices that ensure that all
DOE elements and contractors continue to manage DOE's radioactive
waste in a manner that is protective of worker and public health and
safety, and the environment.

O.2
CANCELLATION. DOE 5820.2, RADIOACTIVE WASTE
MANAGEMENT OF 2-6-84.
O.2
CANCELLATION. The following is canceled: DOE 5820.2A,
Radioactive Waste Management, of 9-26-88. Cancellation of that Order
does not, by itself, modify or otherwise affect any contractual obligation
to comply with the Order. The provisions of this canceled Order which
have been incorporated by reference in a contract shall remain in effect
until the contract is modified.

O.3
SCOPE. The provisions of this Order apply to all DOE elements
and, as required by law and/or contract and as implemented by
the appropriate contracting officer, all DOE contractors and
subcontractors performing work that involves management of
waste containing radioactivity and/or radioactively contaminated
facilities for DOE under the Atomic Energy Act of 1954, as
amended (Public Law 83 -703) .

O.3

M.2

M.3
APPLICABILITY.

a. DOE Elements. This Order applies to all DOE elements
except as stated in item "d."

b. Radioactive Waste. Except as stated in item "d," this Order
applies to the management of:

(1) All high-level waste, transuranic waste, and low-level waste, including the radioactive component of
mixed waste, for which DOE is responsible;

(2) DOE accelerator-produced radioactive waste; and

(3) If managed at DOE low-level waste facilities,
byproduct materials as defined by section 11e.(2) of
the Atomic Energy Act of 1954, as amended, or
naturally occurring radioactive materials.

c. Contractors. The Contractor Requirements Document,
Attachment 1, sets forth requirements to be applied to
contractors performing work that involves management of
DOE radioactive waste at DOE-owned or leased facilities.
Contractor compliance with the Contractor Requirements
Document will be required to the extent set forth in a contract.

APPLICABILITY. The requirements set forth in this Manual apply to
DOE elements and contractors as set forth in DOE O 435.1, Radioactive
Waste Management.

SUMMARY. This Manual is organized into four (4) chapters. Chapter
I, General Requirements and Responsibilities, contains requirements and
responsibilities which are applicable to all radioactive waste types and
delineates responsibilities for radioactive waste management decision-making at the complex-wide and Field Element levels. Chapters II
through IV contain those requirements that are applicable to high-level
waste, transuranic waste, and low-level waste including the radioactive
component of mixed low-level waste, respectively.

O.4
EXCLUSION. This Order does not apply to the management by
the Department of commercially generated spent nuclear fuel or
high-level radioactive waste, nor to the geologic disposal of
high-level waste produced by the Department' s activities and
operations. Such materials are managed by the Office of Civilian
Radioactive Waste Management under the requirements of the
Nuclear Waste Policy Act of 1982, as amended (Public Law
97-425).
O.3.d
Exemptions. This Order does not apply to certain DOE programs,
facilities, or activities as described below.

(1) This Order does not apply to activities conducted under the
authority of the Director, Naval Nuclear Propulsion Program,
as described in Department of Energy National Security and
Military Applications of Nuclear Energy Authorization Act of
1985, Public Law 98-525.

(2) Requirements in this Order that overlap or duplicate
requirements of the Nuclear Regulatory Commission (NRC)
related to radiation protection, nuclear safety (including
quality assurance), and safeguards and security of nuclear
material, do not apply to the design, construction, operation,
and decommissioning of Office of Civilian Radioactive Waste
Management facilities as defined in DOE O 250.1, Civilian
Radioactive Waste Management Facilities Exemptions from
Departmental Orders.

(3) Requirements in this Order that overlap or duplicate
requirements of NRC or an Agreement State do not apply to
facilities and activities licensed by the NRC or an Agreement
State.

(4) Requirements in this Order that overlap or conflict with the
Waste Isolation Pilot Plant Land Withdrawal Act of 1992, as
amended, Public Law 102-579, do not apply to the operation
of the Waste Isolation Pilot Plant or the disposal of waste
therein.

(5) Unless managed in a low-level waste facility, requirements in
this Order do not apply to byproduct material as defined in
section 11e.(2) of the Atomic Energy Act of 1954, as amended,
or naturally occurring radioactive material.

(6) This Order does not apply to either spent nuclear fuel or non-waste materials.

(7) Upon request or on its own initiative, DOE may grant
exemptions from the requirements of this Order in accordance
with the process provided by DOE O 251.A, Directives
System.

O.5
POLICY. Radioactive and mixed wastes shall be managed in a
manner that assures protection of the health and safety of the
public, DOE, and contractor employees, and the environment.
The generation, treatment, storage, transportation, and/or
disposal of radioactive wastes, and the other pollutants or
hazardous substances they contain, shall be accomplished in a
manner that minimizes the generation of such wastes across
program office functions and complies with all applicable
Federal, State, and local environmental, safety, and health laws
and regulations and DOE requirements.
O.4

M.I.1.C.

REQUIREMENTS.

a. DOE radioactive waste management activities shall be
systematically planned, documented, executed, and evaluated.

b. Radioactive waste shall be managed to:

(1) Protect the public from exposure to radiation from
radioactive materials. Requirements for public
radiation protection are in DOE 5400.5, Radiation
Protection of the Public and the Environment.
(2) Protect the environment. Requirements for
environmental protection are in DOE 5400.1,
General Environmental Protection Program, and
DOE 5400.5, Radiation Protection of the Public and
the Environment.
(3) Protect workers. Requirements for radiation
protection of workers are in 10 CFR Part 835,
Occupational Radiation Protection; requirements
for industrial safety are in DOE O 440.1A, Worker
Protection Management for DOE Federal and
Contractor Employees.
(4) Comply with applicable Federal, State, and local
laws and regulations. These activities shall also
comply with applicable Executive Orders and other
DOE directives.

c. All radioactive waste shall be managed in accordance with the
requirements in DOE M 435.1-1, Radioactive Waste
Management Manual.

d. DOE, within its authority, may impose such requirements, in
addition to those established in this Order, as it deems
appropriate and necessary to protect the public, workers, and
the environment, or to minimize threats to property.

Radioactive Waste Management. All radioactive waste subject to DOE
O 435.1, Radioactive Waste Management, and the requirements of this
Manual shall be managed as high-level waste, transuranic waste, low-level waste, or mixed low-level waste.

O.6
REFERENCES.
O.6

M.I.1.E

REFERENCES. DOE M 435.1-1, Radioactive Waste Management
Manual of XX-XX-XX and DOE G 435.1-1, Implementation Guide for
DOE M 435.1-1.

Requirements of Other Regulations and DOE Directives. The following
requirements and DOE directives are required for all DOE radioactive
waste management facilities, operations, and activities as applicable.
Any of the requirements for the following Departmental directives may
be waived or modified through application of a DOE-approved
requirements tailoring process, such as the "Necessary and Sufficient
Closure Process" in DOE P 450.3 and DOE M 450.3-1 and DOE P
450.4, Safety Management System Policy, or by an exemption processed
in accordance with the requirements of that directive or DOE M 251.1-1A, Directives System Manual.

1. DOE 1332.A, UNIFORM REPORTING SYSTEM, of
10-15-85, establishes the content and format of plans
and reports to be obtained from the Department' s
contractors and stipulated as a contract requirement.
None
Essential requirements to address radioactive waste management are no
longer found in this Directive or its successor(s).

2. DOE 1430.1A, MANAGEMENT OF THE
DEPARTMENT' S SCIENTIFlC AND TECHNICAL
INFORMATION, of 9-10-86, which establishes the
policy that scientific and technical information
developed during work supported by DOE shall be
promptly and fully reported to the Technical
Information Center (MA-28), located in Oak Ridge
Tennessee, for inclusion in the Department' s
information data base.
None
Essential requirements to address radioactive waste management are no
longer found in this Directive or its successor(s).

3. DOE 1540.1, MATERIALS TRANSPORTATION
AND TRAFFIC MANAGEMENT of 5-3-82, estab-
lishes the Department' s policies for management of
materials transportation activities.
M.I.1.E.(11)
Packaging and Transportation. Radioactive waste shall be packaged
and transported in accordance with DOE O 460.1A, Packaging and
Transportation Safety, and DOE O 460.2, Departmental Materials
Transportation and Packaging Management.

4. DOE 1540.2, HAZARDOUS MATERIAL
PACKAGING FOR TRANSPORTATION
ADMINISTRATIVE PROCEDURES of 9-30-86,
establishes administrative procedures for the certifi-
cation and use of radioactive and other hazardous
materials packaging by the Department of Energy.
M.I.1.E.(11)
Packaging and Transportation. Radioactive waste shall be packaged
and transported in accordance with DOE O 460.1A, Packaging and
Transportation Safety, and DOE O 460.2, Departmental Materials
Transportation and Packaging Management.

O.6
5. DOE 2110.1, PRIClNG OF DEPARTMENTAL
MATERIALS AND SERVICES of 2-16-84, which
establishes the Department' s policy for establishing
prices and charges for materials and services provided
to outside persons and organizations.
None
Essential requirements to address radioactive waste management are no
longer found in this Directive or its successor(s).

6. DOE 4300.1B, REAL PROPERTY AND SITE
DEVELOPMENT PLANNING of 7-1-87, establishes
Department policies and procedures for planning the
development and utilization of sites and their facilities
and for the acquisition, use, inventory, and disposal of
real property or interests therein.
M.I.1.E.(9)
Life-Cycle Asset Management. Planning, acquisition, operation,
maintenance, and disposition of radioactive waste management facilities
shall be in accordance with DOE O 430.1A, Life-Cycle Asset
Management, and DOE 4330.4B, Maintenance Management Program,
including a configuration management process to ensure the integrity of
physical assets and systems. Corporate physical asset databases shall be
maintained as complete, current inventories of physical assets and
systems to allow reliable analysis of existing and potential hazards to the
public and workers.

7. DOE 4700.1, PROJECT MANAGEMENT SYSTEM,
of 3-6-87, establishes the DOE Project Management
System (PMS), provides implementing instructions,
formats and procedures and sets forth requirements
which govern the development, approval and execution
of DOE' s outlay program acquisition as embodied in
the PMS.

M.I.1.E.(9)
Life-Cycle Asset Management. Planning, acquisition, operation,
maintenance, and disposition of radioactive waste management facilities
shall be in accordance with DOE O 430.1A, Life-Cycle Asset
Management, and DOE 4330.4B, Maintenance Management Program,
including a configuration management process to ensure the integrity of
physical assets and systems. Corporate physical asset databases shall be
maintained as complete, current inventories of physical assets and
systems to allow reliable analysis of existing and potential hazards to the
public and workers.

8. DOE 5000.3, UNUSUAL OCCURRENCE
REPORTING SYSTEM of 11-7-84, establishes the
Department's policy and provides instructions for
reporting, analyzing, and disseminating information on
programmatically significant events.
M.I.1.E.(6)
Environmental and Occurrence Reporting. Radioactive waste
management facilities, operations, and activities shall meet the reporting
requirements of DOE O 231.1, Environment, Safety and Health
Reporting, and DOE O 232.1A, Occurrence Reporting and Processing
of Operations Information.

9. DOE 5400.2, ENVIRONMENTAL COMPLIANCE
ISSUE COORDINATION, of 8 -13 -87, establishes
DOE requirements for coordination of significant
environmental compliance issues.
None
Essential requirements to address radioactive waste management are no
longer found in this Directive or its successor(s).

10. DOE 5440.1C, NATIONAL ENVIRONMENTAL
POLICY ACT of 4-9-85, establishes the Department' s
policy for implementation of the National
Environmental Policy Act of 1969 (Public Law
91-190).
M.I.1.D.
Analysis of Environmental Impacts. Existing and proposed
radioactive waste management facilities, operations, and activities shall
meet the requirements of 10 CFR Part 1021, National Environmental
Policy Act Implementing Procedures; and DOE O 451.1A, National
Environmental Policy Act Compliance Program. All reasonable
alternatives shall be considered, as appropriate. Nothing in this Order is
meant to restrict consideration of alternatives to proposed actions.

O.6
11. DOE 5480.1B, ENVIRONMENTAL SAFETY, AND
HEALTH PROGRAM FOR DEPARTMENT OF
ENERGY OPERATIONS of 9-23-86, establishes an
overall framework of program requirements for safety,
environmental, and health protection, including criteria
for radiation exposure and radioactive effluent releases
for operating facilities and sites.
M.I.1.E.(13)
Radiation Protection. Radioactive waste management facilities,
operations, and activities shall meet the requirements of 10 CFR Part
835, Occupational Radiation Protection, and DOE 5400.5, Radiation
Protection of the Public and Environment.

12. DOE 5480.3, SAFETY REQUIREMENTS FOR THE
PACKAGING AND TRANSPORTATION OF
HAZARDOUS MATERIALS, HAZARDOUS
SUBSTANCES AND HAZARDOUS WASTES, of
7-9-85, establishes requirements for the packaging and
transportation of hazardous materials, hazardous
substances, and hazardous wastes.
M.I.1.E.(11)
Packaging and Transportation. Radioactive waste shall be packaged
and transported in accordance with DOE O 460.1A, Packaging and
Transportation Safety, and DOE O 460.2, Departmental Materials
Transportation and Packaging Management.

13. DOE 5481.1B, SAFETY ANALYSIS AND REVIEW
SYSTEM of 9-23-86, establishes uniform requirements
for the preparation and review of safety analyses of
DOE operations.
M.I.1.E.(8)
Hazard Analysis Documentation and Authorization Basis.
Radioactive waste management facilities, operations, and activities shall
implement DOE Standards, DOE-STD-1027-92, Hazard Categorization
and Accident Analysis Techniques for Compliance with DOE 5480.23,
Nuclear Safety Analysis Reports, and/or DOE-EM-STD-5502-94, DOE
Limited Standard: Hazard Baseline Documentation, and shall, as
applicable, prepare and maintain hazard analysis documentation and an
authorization basis as required by DOE O 425.1A, Startup and Restart
of Nuclear Facilities, DOE O 5480.21, Unreviewed Safety Questions,
DOE 5480.22, Technical Safety Requirements, and DOE 5480.23,
Nuclear Safety Analysis Reports.

14. DOE 5482.1B, ENVIRONMENT, SAFETY AND
HEALTH APPRAISAL PROGRAM of 9-23-86
establishes an environment safety and health appraisal
program for DOE.
M.I.1.E.(13)
Radiation Protection. Radioactive waste management facilities,
operations, and activities shall meet the requirements of 10 CFR Part
835, Occupational Radiation Protection, and DOE 5400.5, Radiation
Protection of the Public and Environment.

15. DOE 5484.1, ENVIRONMENTAL, SAFETY, AND
HEALTH PROTECTION INFORMATION
REPORTING REQUIREMENTS of 2-24-81,
establishes requirements and practices for reporting
environmental, health, and safety information for DOE
operations.
M.I.1.E.(6)
Environmental and Occurrence Reporting. Radioactive waste
management facilities, operations, and activities shall meet the reporting
requirements of DOE O 231.1, Environment, Safety and Health
Reporting, and DOE O 232.1A, Occurrence Reporting and Processing
of Operations Information.

16. DOE 5700.6B, QUALITY ASSURANCE of 9-23-86,
sets forth principles and assigns responsibilities for
establishing, implementing, and maintaining programs
of plans and actions to assure quality achievement in
the Department' s programs.
M.I.1.E.(12)
Quality Assurance Program. Radioactive waste management
facilities, operations, and activities shall develop and maintain a quality
assurance program that meets the requirements of 10 CFR 830.120,
Quality Assurance Requirements, and DOE O 414.1, Quality Assurance,
as applicable.

O.6
17. DOE 6430.1, GENERAL DESIGN CRITERIA of
12-12-83, establishes general design criteria for use in
acquisition of the Department' s facilities and to
establish responsibilities and authorities for the
development and maintenance of those criteria.
M.I.1.E.(18)
Site-Evaluation and Facility Design. New radioactive waste
management facilities, operations, and activities shall be sited and
designed in accordance with DOE O 420.1, Facility Safety, and DOE O
430.1A, Life-Cycle Asset Management.

18. WIPP-DOE-069, rev. 2, of 9-85, "Transuranic Waste
Acceptance Criteria for the Waste Isolation Pilot Plant"
of 9-81, as updated, specifies basic requirements for
disposal of contact-handled and remote-handled
transuranic waste at the Waste Isolation Pilot Plant.
Copies of this and other DOE Waste Isolation Pilot
Plant reports may be obtained from the Albuquerque
Operations Office.
None
Lower Tier Document that implements essential transuranic waste
acceptance requirements.

19. WlPP-DOE-120, rev. 1, of 1-83, "Quality Assurance"
establishes the Quality Assurance requirements to
ensure that each site' s transuranic waste certification
program will perform satisfactorily.
None
Lower Tier Document that implements essential transuranic waste
quality assurance and waste certification requirements.

20. WlPP-IIOE-157 rev. 1, of 9-85, "Data Package Format
for Certified Transuranic Waste for the Waste Isolation
Pilot Plant" specifies the arrangement of data which are
required to be reported to the Waste Isolation Pilot
Plant for transuranic waste to be received.
None
Lower Tier Document that implements essential transuranic waste
certification and packaging and transportation requirements.

21. DOE/LLW-63T of 9-87, "Guidance for Conduct of
Waste Management Systems Performance Assessment"
provides information on meeting the systems
performance requirement of Chapter III3b(2) of DOE
5820. 2A.
None
Guidance for 5820.2A. Does not contain essential requirements.

22. DOE-J10-025 of 9-87, "Comprehensive
Implementation Plan for the DOE Defense Buried
Transuranic-Contaminated Waste Program, describes
long term management alternatives for all DOE sites
with buried transuranic waste.
None
Planning Document. Does not contain essential requirements.

O.6
23. DOE/RW-0006, rev. 3, "Integrated Data Base for
1987: Spent Fuel and Radioactive Waste Inventories,
Projections, and Characteristics" of 9-87, with annual
updates, summarizes data in the Integrated Data Base
program on all domestic spent fuel and radioactive
waste. Copies may be obtained from the Office of
Nuclear Energy, Germantown, or the Technical
Information Center, Oak Ridge.
None
Reference Document. Does not contain essential requirements.

24. DOE/DP/0020/1 "An Evaluation of Commercial
Repository Capacity for the Disposal of Defense High
Level Waste,"of 6-85, evaluates the use of civilian
repository capacity for the disposal of high level waste
resulting from Defense activities, and provided to the
President as one analytical input for his evaluation as
required under the Nuclear Waste Policy Act.
None
Planning Document. Does not contain essential requirements.

25. Nuclear Waste Policy Act of 1982. as amended. (Public
Law 97-425) provides for the development of
depositories for the disposal of high-level waste and
spent nuclear fuel.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

26. Uranium Mill Tailings Radiation Control Act of 1978
(Pubic Law 95-604) establishes national policy for
control of uranium mill tailings.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

27. Energy Reorganization Act of 1974 (Public Law
93-438), in Section 202, assigns licensing and related
regulatory authority to the Nuclear Regulatory
Commission for facilities authorized for the
express-purpose of long-term storage of defense
high-level waste.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

28. Department of Energy National Security and Military
Applications of Nuclear Energy Authorization Act of
1980 (Public Law 96-164), Section 213(a) authorizes
the Waste Isolation Pilot Plant.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

O.6
29. Low-Level Radioactive Waste Policy Amendments Act
of 1985 (Public Law 99-240) makes the Federal
Government responsible for disposal of commercially
generated greater than class C waste as defined in
Section 3(b) (1) (D) of the Act.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

30. Resource Conservation and Recovery Act of 1976, as
amended, (Public Law 94-580) establishes safe and
environmentally acceptable management practices for
solid wastes.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

31. Comprehensive Environment Response, Compensation,
and Liability Act of 1980, as amended, (Public Law
96-510) to provide for liability, compensation,
cleanup, and emergency response for hazardous
substances released into the environment, and the
cleanup of inactive hazardous waste disposal sites.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

32. The Superfund Amendments and Reauthorization Act
of 1986 (Public Law 99-270) provides for a fund
(Superfund) which may be utilized by the
Environmental Protection Agency, State, and local
governments to clean up hazardous waste sites listed
on the National Priorities List.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

33. National Environmental Policy Act of 1969 (Public
Law 91-190) requires the preparation of a statement
which considers environmental impacts, alternatives,
and resource commitments for any major Federal
action that significantly affects the quality of the
human environment.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

I.1.D. Analysis of Environmental Impacts. Existing and proposed
radioactive waste management facilities, operations, and
activities shall meet the requirements of 10 CFR Part 1021,
National Environmental Policy Act Implementing Procedures;
and DOE O 451.1A, National Environmental Policy Act
Compliance Program. All reasonable alternatives shall be
considered, as appropriate. Nothing in this Order is meant to
restrict consideration of alternatives to proposed actions.

34. Title 5 CFR 1320, Controlling Paperwork Burdens on
the Public serves as the implementing regulation for
Public Law 96-511, Paperwork Reduction Act of 1980
and directs the identification and clearance of
information collections levied on the public including
contractors, State and local government units, and
persons who perform services for the Department on
an individual basis.
None
See Clearance under the Paperwork Reduction Act of 1980 issued for
DOE Order 5820.2A, Item 11, which is presented later in this crosswalk
table.

O.6
35. Title 10 CFR Part 60, of 2-25-81, Disposal of
High-Level Wastes in Geologic Repositories,
prescribes rules governing the licensing of the
Department of Energy to receive and possess source,
special nuclear, and byproduct material at a geologic
repository operations area.
None
Not applicable to radioactive waste management activities conducted at
DOE facilities under Order 435.1. Evaluated in Requirements Analysis
to derive essential requirements.

36. Title 10 CFR Part 61, of 12-27-82, Licensing
Requirements for Land Disposal of Radioactive Waste,
establishes technical requirements for the land disposal
of commercial low-level waste including site selection,
site design, and facility operation and closure.
None
Not applicable to radioactive waste management activities conducted at
DOE facilities under Order 435.1. Evaluated in Requirements Analysis
to derive essential requirements.

37. Title 10 CFR Part 71, of 8-5-83, Packaging and
Transportation of Radioactive Material, establishes (1)
requirements for packaging, preparation for shipment,
and transportation of licensed material and (2)
procedures and standards for NRC approval of
packaging and shipping procedures for fissile material
and for a quantity of other licensed material in excess
of a Type A quantity.
None
Not applicable to radioactive waste management activities conducted at
DOE facilities under Order 435.1. Evaluated in Requirements Analysis
to derive essential requirements.

38. Title 10 CFR Part 962, of 5-1-87, Radioactive Waste;
Byproduct Material establishes the policy that all DOE
radioactive waste which is hazardous under the
Resource Conservation and Recovery Act will be
subject to regulation under both the Resource
Conservation and Recovery Act and Atomic Energy
Act.
O.4.b

M.I.1.E.(10)
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

Mixed Waste. Radioactive waste that contains both source, special
nuclear, or by-product material subject to the Atomic Energy Act of
1954, as amended, and a hazardous component is also subject to the
Resource Conservation and Recovery Act (RCRA), as amended.

39. Title 40 CFR Part 61, of 7-1-87 National Emission
Standards for Hazardous Air Pollutants, establishes
standards for atmospheric emissions of hazardous air
pollutants and radionuclides.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

O.6
40. Title 40 CFR Part 191, of 9-19-85, Environmental
Radioactive Protection Standards for Management and
Disposal of Spent Nuclear Fuel, High-Level and
Transuranic Radioactive Waste, establishes radiation
protection standards governing the management and
storage of spent nuclear fuel or high-level or
transuranic wastes at any disposal facility operated by
DOE.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

41. Title 40 CFR Part 192, of 1-5-83, Health and
Environmental Protection Standards for Uranium and
Thorium Mill Tailings, concerns the control of residual
radioactive material at designated processing or
disposal sites.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

42. Title 40 CFR part 261, of 5-19-80, Identification and
Listing of Hazardous Waste identifies those solid
wastes that are subject to regulation as hazardous
waste.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

43. Title 40 CFR 262, of 5-19-80, Standards Applicable to
Generators of Hazardous Waste, establishes
manufacturing, packaging, labeling, record keeping,
and reporting requirements for generators of hazardous
waste.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

44. Title 40 CFR Part 263, of 5-19-80, Standards
Applicable to Transporters of Hazardous Waste,
establishes manufacturing, record keeping, spill
reporting and cleanup requirements for transporters of
hazardous waste.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

45. Title 40 CFR Part 264, of 5-19-80, Standards for
Owners and Operators of Hazardous Waste Treatment,
Storage and Disposal Facilities, establishes minimum
national standards defining the acceptable management
of hazardous waste.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

O.6
46. Title 40 CFR Part 265, of 5-19-80, Interim Status
Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities,
establishes minimum national standards that define the
acceptable management of hazardous waste during the
period of interim status and until certification of final
closure.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

47. Title 49 CFR parts 100-178, of 10-1-86, Other
Regulations Relating to Transportation: Chapter
I-Research and Special Programs Administration,
Department of Transportation, prescribes the
requirements of the DOT governing the transportation
of hazardous material and the manufacture and testing
of packaging and containers.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

48. ANSI/ASME NQA-1 "American National Standards
Institute/American Society of Mechanical Engineers
Nuclear Quality Assurance-1, " sets forth requirements
for the establishment and execution of quality
assurance programs for the design, construction,
operation, and decommissioning of nuclear facilities.
None
Standards Document. Incorporated if appropriate by reference in the
Manual or in Guidance.

49. Atomic Energy Act of 1954, as amended 42 U. S. C.
2011-2292 (1982) which authorizes and directs the
Atomic Energy Commission to produce special nuclear
material in its own facilities to produce atomic
weapons or atomic weapons parts and to research and
develop military applications of atomic energy.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

50. Nuclear Waste Policy Amendments Act of 1987 (part of
the Budget Reconciliation Act for FY 1988 Public Law
100-203), of December 22, 1987, streamlines and
focuses the high level waste management program
established by the Nuclear Waste Policy Act.
O.4.b
Radioactive waste shall be managed to:

(4) Comply with applicable Federal, State, and local laws and
regulations. These activities shall also comply with applicable
Executive Orders and other DOE directives.

O.7

DEFINITION. (See Attachment 2.)
M.6
DEFINITIONS. Definitions for DOE M 435.1-1, Radioactive Waste
Management Manual, are provided in Attachment 2. (Definitions
crosswalk table is presented following this crosswalk table)

O.8
RESPONSIBILITIES.

a. Assistant Secretary for Defense Programs (DP-1) has
authority for establishing policy for the management of
DOE waste and assuring that DOE waste generated by
operations and activities under DP- 1 cognizance, or
any other waste within the purview of DP-1, is
managed according to the requirements of this Order.
DP-1 also has general responsibility for assuring that
DP-1 programmatic decisions include waste
management considerations when appropriate.
O.5

M.I.2

RESPONSIBILITIES

All DOE elements as specified in 3.a are responsible for implementing
the requirements of this Order. See DOE M 435.1-1, Radioactive Waste
Management Manual, for specific responsibilities.

RESPONSIBILITIES

A. Program Secretarial Officers. Program Secretarial Officers with
radioactive waste management facilities, operations, or activities are
responsible within their respective programs for ensuring that the Field
Element Managers meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual.

b. Director of Defense Waste and Transportation
Management (DP-12) is charged with carrying out
DP-1 waste management responsibilities for oversight
of the waste management complex, for interpreting
waste management policy, and for implementing the
requirements of this Order for waste management
facilities and operations funded by DP-12.
M.I.2.B

M.I.2.D

M.I.2.E

Assistant Secretary for Environmental Management. The Assistant
Secretary for Environmental Management is responsible for:

(1) Complex-Wide Radioactive Waste Management
Programs. (Full text not included)

(2) Changes to Regulations and DOE Directives.
(Full text not included)

Deputy Assistant Secretary for Waste Management. The Deputy
Assistant Secretary for Waste Management is responsible for:

(1) Complex-Wide Radioactive Waste Management
Program Plans. (Full text not included)

(2) Waste Management Data System. (Full text not
included)

Deputy Assistant Secretaries for Waste Management and Environmental
Restoration. The Deputy Assistant Secretary for Waste Management
and the Deputy Assistant Secretary for Environmental Restoration are
responsible, within their respective programs, for:

(1) Disposal. (Full text not included)

(2) Site Closure Plans. (Full text not included)

O.8
c. Director of Civilian Radioactive Waste Management
(RW-1) is responsible for selected research and
development, siting, construction, operation, and
management activities assigned to the Secretary of
Energy by the Nuclear Waste Policy Act of 1982
(Public Law 97-425) for the interim storage and
disposal of high-level waste and spent nuclear fuel.
M.I.2.A
Program Secretarial Officers. Program Secretarial Officers with
radioactive waste management facilities, operations, or activities are
responsible within their respective programs for ensuring that the Field
Element Managers meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual.

d. Assistant Secretary for Nuclear Energy (NE-1) is
responsible for assuring that waste generated by
operations funded by NE-1 is managed according to
the requirements of this Order and that NE-1 program
decisions include waste management considerations, as
appropriate.
M.I.2.A
Program Secretarial Officers. Program Secretarial Officers with
radioactive waste management facilities, operations, or activities are
responsible within their respective programs for ensuring that the Field
Element Managers meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual.

e. Assistant Secretary for Environment, Safety and Health
(EH-1) is responsible for providing an independent
overview of DOE radioactive waste management and
decommissioning programs to determine compliance
with DOE environment, safety, and health
requirements and applicable Environmental protection
Agency (EPA) and state regulations.

I.2.C.
Assistant Secretary for Environment, Safety, and Health. The Assistant
Secretary for Environment, Safety and Health is responsible for
providing an independent overview of DOE radioactive waste
management and decommissioning programs to determine compliance
with DOE environment, safety, and health requirements and applicable
Environmental Protection Agency (EPA) and state regulations,
including:

(1) Advising the Secretary of the status of Departmental
compliance with the requirements of DOE O 435.1, this
Manual, and applicable provisions of other DOE Orders.

(2) Conducting independent appraisals and audits of DOE waste
management programs.

(3) Reviewing site Waste Management Plans with regard to
compliance with DOE environment, safety, and health
requirements.

f. Director, Naval Nuclear Propulsion Program:
Executive Order 12344, statutorily prescribed by
PL98-525 (42 USC 7158 note), establishes the
responsibilities and authority of the Director, Naval
nuclear Propulsion Program (who is also the Deputy
Assistant Secretary for Naval Reactors within the
Department) over all facilities and activities which
comprise the Program, a joint Navy-DOE organization.
The policy principle promoted by these executive and
legislative actions is cited in the Executive Order as "...
preserving the basic structure, policies and practices
developed for this Program in the past...". Accordingly,
The Naval Propulsion Program is exempt from the
provisions of this Order. The Director shall maintain
an environmental protection program to assure
compliance with applicable environmental statutes and
regulations The Director and EH-1 shall exchange
information and cooperate as appropriate to facilitate
exercise of their respective responsibility.
O.3.d
Exemptions. This Order does not apply to certain DOE programs,
facilities, or activities as described below.

O.8
g. Directors of other Headquarters Program Organizations
are responsible for implementing the requirements of
this Order for all DOE waste generated by their
programs utility is transferred to a DOE or licensed
storage/disposal site. For all contaminated facilities
under their jurisdiction, they are responsible for
assuring that their programmatic decisions include
waste management considerations, as appropriate, and
for implementing the requirements of other applicable
DOE Orders for their waste management programs.
M.I.2.A
Program Secretarial Officers. Program Secretarial Officers with
radioactive waste management facilities, operations, or activities are
responsible within their respective programs for ensuring that the Field
Element Managers meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual.

h. Office of General Counsel(GC-1) provides legal advice
to program organizations regarding DOE waste
management and decommissioning activities involving
DOE-owned and privately owned sites; renders legal
opinion on DOE authority to undertake remedial action
and other waste management activities; and renders
legal opinions on, and concurs in, program actions to
comply with the National Environmental Policy Act,
the Resource Conservation and Recovery Act, the
Comprehensive Environmental Response, Compen-
sation, and Liability Act, the Superfund Amendments
and Reauthorization Act, and other legal authorities in
conjunction with proposed waste management and
decommissioning activities.
None
Maintains these programmatic responsibilities, and they do not need to
be included in DOE O 435.1.

i. Assistant Secretary, Management and Administration
(MA-1) is responsible providing contractual and
business advice to program organizations regarding
DOE waste management activities including use of
DOE management and operating contractors in such
activities.
M.I.2.A
Program Secretarial Officers. Program Secretarial Officers with
radioactive waste management facilities, operations, or activities are
responsible within their respective programs for ensuring that the Field
Element Managers meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual.
O.8
j. Heads of Field Organizations are responsible for all
activities that affect storage, or disposal of waste in
facilities under their jurisdiction regardless of where
the waste is generated. Heads of field organizations
with treatment, storage or disposal facilities respon-
sibility have the authority for establishing waste
management requirements at that facility (e.g., setting
waste acceptance criteria, waste certification,
verification of contents of waste shipped or to be
shipped, concurring in waste reduction plans). In
addition, they are responsible for assuring that the
day-to-day waste management and surplus facility
operations at their sites are conducted in compliance
with the requirements of this Order and comply with
all applicable Federal, State, and local statutes.
Specific responsibilities include the following:

[ Items (1) through (10) of this section ]

M.I.2.F
F. Field Element Managers. Field Element Managers are
responsible for:

[Full text not included]
(1) Site-Wide Radioactive Waste Management
Programs
(2) Radioactive Waste Management Basis
(3) Waste Minimization and Pollution Prevention
(4) Approval of Exemptions for Use of Non-DOE
Facilities
(5) Environmental Restoration, Decommissioning, and
Other Cleanup Waste
(6) Radioactive Waste Acceptance Requirements
(7) Radioactive Waste Generator Requirements
(8) Closure Plans
(9) Defense-In-Depth
(10) Oversight
(11) Training and Qualification
(12) As Low As Reasonably Achievable (ALARA)
(13) Storage
(14) Treatment
(15) Disposal
(16) Monitoring
(17) Material and Waste Declassification for Waste
Management
(18) Waste Incidental to Reprocessing
(19) Waste With No Identified Path to Disposal
(20) Corrective Actions

O.8
k. Manager of Albuquerque Operations Office is
responsible, in addition to the responsibilities
identified in paragraph 8j, for use of certified
packaging, standard containers, transportation, waste
acceptance Criteria, and all other aspects related to
transuranic waste emplacement at the Waste Isolation
Pilot Plant. Within the Albuquerque Operations Office,
a standing committee, the Waste Isolation Pilot
Plant-Waste Acceptance Criteria Certification
Committee, is responsible for review, audit, and
approval of generator transuranic waste certification
programs and activities. The Manager of the
Albuquerque Operations Office, as Head of the Waste
Isolation Pilot Plant project office, also has
responsibility for the design, construction, technology
development, and operational activities leading to
permanent isolation of transuranic waste from the
biosphere.
None
The duties of the Albuquerque Operations Office Manager included in
this 5820.2A requirement will be assigned as necessary in the Complex-Wide Transuranic Waste Management Program required in M.III.C.

O.9
EXEMPTIONS. Exemptions from the requirements of this Order
may be granted only with the approval of DP-12 in consultation
with EH-1. New or alternate waste management practices that are
based on appropriate documented safety, health protection, and
economic analyses may be proposed by field organizations and
adopted with the approval of DP-12 and EH-1.
M.4
IMPLEMENTATION. The requirements of this Manual apply to all
new and existing DOE radioactive waste management facilities,
operations, and activities. Implementation of the requirements shall
begin at the earliest possible date, and all DOE entities shall be in
compliance with this directive within one year of its issuance.
Compliance with this directive includes implementing the requirements
or an approved implementation or corrective action plan. If compliance
with this Order cannot be achieved within one year of its issuance, the
Field Element Manager must request approval to extend the compliance
date to no later than October 1, 2001, from the cognizant Program
Secretarial Officer (PSO). Failure to implement the requirements of this
directive shall, through the appropriate lines of management, result in
corrective actions including, if necessary, shutdown of radioactive waste
management facilities, operations, or activities until the appropriate
requirements are implemented. Any of the requirements in this Manual
may be waived or modified through application of a DOE-approved
requirements tailoring process, such as the "Necessary and Sufficient
Closure Process" in DOE P 450.3 and DOE M 450.3-1 and DOE P
450.4, Safety Management System Policy, the applicable or relevant and
appropriate requirements identification process for actions taken
pursuant to the Department's CERCLA authorities, or by an exemption
processed in accordance with the requirements of DOE O 251.1-1A,
Directives System Manual.

O.10
IMPLEMENTING PROCEDURES AND REQUIREMENTS.
Within 6 months of the date of issuance of this Order, Heads of
Field Elements shall prepare and submit to appropriate
Headquarters program organizations an implementation plan
describing schedules, costs, and quality assurance activities for
compliance with the requirements of this Order with copies to
EH-1 for review and comment. Specific guidance for the plan
will be issued by DP-12 under separate cover. Thereafter, the
status of compliance with the requirements of this Order shall be
reported to the appropriate Headquarters program organization in
the annual update of the Waste Management Plans.
M.4
IMPLEMENTATION. The requirements of this Manual apply to all new
and existing DOE radioactive waste management facilities, operations,
and activities. Implementation of the requirements shall begin at the
earliest possible date, and all DOE entities shall be in compliance with
this directive within one year of its issuance. Compliance with this
directive includes implementing the requirements or an approved
implementation or corrective action plan. If compliance with this Order
cannot be achieved within one year of its issuance, the Field Element
Manager must request approval to extend the compliance date to no later
than October 1, 2001, from the cognizant Program Secretarial Officer
(PSO). Failure to implement the requirements of this directive shall,
through the appropriate lines of management, result in corrective actions
including, if necessary, shutdown of radioactive waste management
facilities, operations, or activities until the appropriate requirements are
implemented. Any of the requirements in this Manual may be waived or
modified through application of a DOE-approved requirements tailoring
process, such as the "Necessary and Sufficient Closure Process" in DOE
P 450.3 and DOE M 450.3-1 and DOE P 450.4, Safety Management
System Policy, the applicable or relevant and appropriate requirements
identification process for actions taken pursuant to the Department's
CERCLA authorities, or by an exemption processed in accordance with
the requirements of DOE O 251.1-1A, Directives System Manual.

O.11
CLEARANCE UNDER THE PAPERWORK REDUCTION
ACT OF 1980. This directive has been determined to contain
information collections under the provisions of 5 CFR 1320,
"Controlling Paperwork Burdens on the Public." The Office of
Management and Budget (OMB) has issued a clearance to the
Department (OMB No. 1910-0900) for these information
collections. Waste acceptance criteria shall be established for
each low-level waste treatment, storage, and disposal facility,
and submitted to the cognizant field organization.
None
Office of Management and Budget clearance under 5 CFR Part 1320 not
required for information collections internal to Department activities and
operations.

Chapter VI
WASTE MANAGEMENT PLAN OUTLINE
M.I.2.D.

D. Deputy Assistant Secretary for Waste Management. The
Deputy Assistant Secretary for Waste Management is
responsible for:

(1) Complex-Wide Radioactive Waste Management Program Plans.
Developing, implementing, and maintaining integrated Complex-Wide
Radioactive Waste Management Program Plans for high-level,
transuranic, low-level, and mixed low-level waste. Each plan shall, at
the DOE complex-wide level, describe the functional elements,
organizations, responsibilities, and activities that comprise the system
needed to store, treat and dispose of radioactive waste in a manner that is
protective of the public, workers, and the environment. In addition, the
plans shall:

(a) Present a waste management strategy that integrates waste
projections and life-cycle waste management planning into
complex-wide facility configuration decisions; and

(b) Describe the approach to research and technology
development being pursued to improve safety and/or
efficiency in managing radioactive waste.

F. Field Element Managers. Field Element Managers are
responsible for:

(1) Site-Wide Radioactive Waste Management Programs.
Developing, documenting, implementing, and maintaining a Site-Wide
Radioactive Waste Management Program. The Program shall use a
systematic approach for planning, executing, and evaluating the site-wide management of radioactive waste in a manner that supports the
Complex-Wide Radioactive Waste Management Programs and ensures
that the requirements of DOE O 435.1, Radioactive Waste Management,
and this Manual are met.

The remaining DOE O and M 435.1-1 requirements have no
predecessor requirements in DOE 5820.2A.
M.5
REVISIONS. Systematic planning, execution, and evaluation of
radioactive waste management facilities, operations, and activities will
provide the basis for evaluating the adequacy of and, if necessary,
revising the requirements of DOE O 435.1, Radioactive Waste
Management, and this Manual. The revision process will be based on
DOE P 450.4, Safety Management System Policy, and will implement
continuous improvement for management of radioactive waste. The
process includes: identifying the functions necessary to execute
radioactive waste management responsibilities; conducting an analysis
of the hazards associated with performing those functions; developing
and implementing the proper controls to mitigate any associated
hazards; developing and implementing a periodic assessment of work
performance; and providing feedback to revise the work processes and
incorporate lessons learned, as appropriate. Administrative requirements
of the Order and Manual will be revised as needed to support safe and
efficient waste management.

M.I.1.A.
Delegation of Authority. Managers charged with responsibilities within
this Manual may delegate authority for these tasks to another manager.
All delegations of authority shall be documented.

M.I.1.B.
Use of Guidance. Additional information supporting the requirements
in this Manual is contained in the Implementation Guide for use with
DOE M 435.1-1, Radioactive Waste Management Manual. This Guide,
DOE G 435.1-1, Implementation Guide for DOE M 435.1-1, shall be
reviewed when implementing the requirements of this Manual. The
Guide provides additional information and acceptable methods for
meeting the requirements. Other methods may be used but must ensure
an adequate level of safety commensurate with the hazards associated
with the work and be consistent with the radioactive waste management
basis.

M.I.1.E
E. Requirements of Other Regulations and DOE Directives.

(1) Analysis of Operations Information. Data that measure the
environment, safety, and health performance of radioactive
waste management facilities, operations, and activities shall be
identified, collected, and analyzed as required by DOE O
210.1, Performance Indicators and Analysis of Operations
Information.
(2) Classified Waste. Radioactive waste to which access has
been limited for national security reasons and cannot be
declassified shall be managed in accordance with the
requirements of DOE 5632.1C, Protection and Control of
Safeguards and Security Interests, and DOE 5633.3B, Control
and Accountability of Nuclear Materials.
(4) Criticality Safety. Radioactive waste management facilities,
operations, and activities shall be covered by a criticality
safety program in accordance with DOE O 420.1, Facility
Safety.
(16) Safeguards and Security. Appropriate features shall be
incorporated into the design and operation of radioactive
waste management facilities, operations, and activities to
prevent unauthorized access and operations, and for purposes
of nuclear materials control and accountability, where
applicable; and shall be consistent with DOE O 470.1,
Safeguards and Security Program.
(17) Safety Management System. Radioactive waste management
facilities, operations, and activities shall incorporate the
principles of integrated safety management as described in
DOE P 450.4, Safety Management System Policy, and DOE P
450.5, Line Environment, Safety and Health Oversight, and
meet the requirements of the safety management systems
sections of 48 CFR Chapter 9, Department of Energy
Acquisition Regulations and DOE M 411.1-1, Manual of
Safety Management Functions, Responsibilities, and
Authorities.
(21) Worker Protection. Radioactive waste management
facilities, operations, and activities shall meet the requirements
of DOE O 440.1A, Worker Protection Management for DOE
Federal and Contractor Employees.

M.I.2.G.
All Personnel. All personnel are responsible for:

(1) Problem Identification. Identifying and reporting radioactive
waste management facilities, operations, or activities that do
not meet the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual, or that pose a threat to
the safety of the public, workers, or the environment.

(2) Shutdown or Curtailment of Activities. Stopping or
curtailing work, through the appropriate level of management,
to prohibit continuation of conditions or activities which pose
an imminent danger or other serious hazard to workers or the
public, or are not protective of the environment.

Chapter V
DECOMMISSIONING OF RADIOACTIVELY
CONTAMINATED FACILITIES
None
Decommissioning of facilities is not within the scope of DOE O 435.1.
Decontamination and decommissioning of facilities is covered by
DOE O 430.1A, Life Cycle Asset Management.

5820.2A
CITATION
5820.2A REQUIREMENT
435.1-1
CITATION(s)
435.1-1 REQUIREMENT(s)

I.1.
Purpose. To establish policies and guidance for managing the Department of
Energy's (DOE) high-level waste and any other materials which, because of
their highly radioactive nature (level of health risk, longevity of health risk and
thermal activity), require similar handling. (Unless demonstrated to the
contrary, all high-level waste shall be considered to be radioactive mixed waste
and subject to the requirements of the Atomic Energy Act, as amended, and the
Resource Conservation and Recovery Act.)
1.

II.C.(1)

I.1.E.(10)
Purpose: This Manual further describes the requirements and establishes
specific responsibilities for implementing DOE O 435.1, Radioactive Waste
Management, for the management of DOE high-level waste, transuranic
waste, low-level waste, and the radioactive component of mixed waste. The
purpose of the Manual is to catalog those procedural requirements and
existing practices that ensure that all DOE elements and contractors continue
to manage DOE's radioactive waste in a manner that is protective of worker
and public health and safety, and the environment.

Management of Specific Wastes. The following provide for management of
specific wastes as high-level waste in accordance with the requirements in
this Chapter:

(1) Mixed High-Level Waste. Unless demonstrated otherwise, all high-level
waste shall be considered mixed waste and is subject to the requirements of
both the Atomic Energy Act of 1954, as amended, the Resource Conservation
and Recovery Act, as amended, DOE O 435.1, Radioactive Waste
Management, and this Manual.

Mixed Waste. Radioactive waste that contains both source, special nuclear,
or by-product material subject to the Atomic Energy Act of 1954, as amended,
and a hazardous component is also subject to the Resource Conservation and
Recovery Act (RCRA), as amended.

I.2.

Policy. All high-level waste generated by DOE operations shall be safely
stored, treated, and disposed of according to requirements set forth in this
Order. Storage operations shall comply with applicable EPA standards and
EPA/State regulations. Geologic disposal shall comply with both Nuclear
Regulatory Commission regulations and EPA Standards.

Order 4.b.

Order 4.c.

I.1.E.(10)

II.S.

Radioactive waste shall be managed to:

3. Protect the public from exposure to radiation from radioactive materials.
Requirements for public radiation protection are in DOE 5400.5,
Radiation Protection of the Public and the Environment.

4. Protect the environment. Requirements for environmental protection
are in DOE 55400.1, General Environmental Protection Program, and
DOE 5400.5, Radiation Protection of the Public and the Environment.

5. Protect workers. Requirements for radiation protection of workers are
in 10 CFR Part 835, Occupational Radiation Protection; requirements
for industrial safety are in DOE O 440.1A, Worker Protection
Management for DOE Federal and Contractor Employees.

6. Comply with applicable Federal, State, and local laws and regulations.
These activities shall also comply with applicable Executive Orders and
other DOE directives.

All radioactive waste shall be managed in accordance with the requirements
in DOE M 435.1-1, Radioactive Waste Management Manual.

Mixed Waste. Radioactive waste that contains both source, special nuclear,
or by-product material subject to the Atomic Energy Act of 1954, as amended,
and a hazardous component is also subject to the Resource Conservation and
Recovery Act (RCRA), as amended.

Disposal. Disposal of high-level waste must be in accordance with the
provisions of the Atomic Energy Act of 1954, as amended, the Nuclear Waste
Policy Act of 1982, as amended, or any other applicable statutes.

I.3.a(1)(a)

Requirements for New Facilities.

(a) Design objectives for new facilities will assure protection of the public
and operating personnel from hazards associated with normal high-Level
Waste operations, accident conditions, and the effects of natural
phenomena. Other objectives are compliance with DOE policies
regarding nuclear safety, quality assurance, fire protection, pollution
control, and safeguards and security protection for high-level waste and
protection of essential operations from the effects of potential accidents.

II.P.(2)(a)

I.1.E.(18)

I.1.E.(12)

I.1.E.(16)

Safety (Safety Class and Safety-Significant) Structures, Systems, and
Components. Safety Structures, systems and components for high-level
waste storage, pretreatment, and treatment facilities shall be designated and
designed consistent with the provisions of DOE O 420.1, Facility Safety;
DOE 5480.22, Technical Safety Requirements; and DOE 5480.23, Nuclear
Safety Reports.

Site Evaluation and Facility Design. New radioactive waste management
facilities , operations, and activities shall be sited and designed in accordance
with DOE O 420.1, Facility Safety, and DOE O 430.1A, Life-Cycle Asset
Management.

Quality Assurance Program. Radioactive waste management facilities,
operations, and activities shall develop and maintain a quality assurance
program that meets the requirements of 10 CFR 830.120, Quality Assurance
Requirements, and DOE O 414.1, Quality Assurance, as applicable.

Safeguards and Security. Appropriate features shall be incorporated into
the design and operation of radioactive waste management facilities,
operations, and activities to prevent unauthorized access and operations, and
for purposes of nuclear materials control and accountability, where
applicable; and shall be consistent with DOE O 470.1, Safeguards and
Security Program.

I.1.E.(20)

II.G

Waste Minimization and Pollution Prevention. Waste minimization and
pollution prevention shall be implemented for radioactive waste management
facilities, operations, and activities to meet the requirements of Executive
Order 12856, Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements, and Executive Order 13101, Greening the
Government through Waste Prevention Recycling, and Federal Acquisition,
and DOE 5400.1, General Environmental Protection Program.

Quality Assurance Program. The following requirements are in addition to
those in Chapter I of this Manual.

(1) Product Quality. The requirements of RW-0333P, Quality Assurance
Requirements and Description, shall apply to those high-level waste
items and activities important to waste acceptance/product quality.

(2) Audits and Assessments. The evaluation and assessment requirements
of RW 0333P, Quality Assurance Requirements Document and
Description, and associated implementing procedures shall be met for
high-level waste acceptance and product quality activities, in addition to
the assessment requirements of other DOE directives and requirements
identified in Chapter I of this Manual.

I.3.a.(1)(b)

Designs for new storage and treatment facilities shall meet the requirements of
DOE 6430.1, applicable EH Orders and 40 CFR 264.

I.1.E.(10)

I.1.E.(18)

II. P.(2) (a) through
(j)

Mixed Waste. Radioactive waste that contains both source, special nuclear,
or by-product material subject to the Atomic Energy Act of 1954, as amended,
and a hazardous component is also subject to the Resource Conservation and
Recovery Act (RCRA), as amended.

Facility Design. Note: The design requirements at Section II.P.(2) (a)
through (j) are in addition to those required in the General Requirements
Chapter of DOE M 435.1-1 and apply to new and existing high-level waste
management facilities, unless the requirement specifies otherwise.

I.3.a.(1)(c)

Designs for new storage facilities shall incorporate features to facilitate
retrieval capability.

II. P.(2)(g)

Facilities for Receipt and Retrieval of High-Level Waste.

1. Designs for storage facilities shall incorporate features to facilitate
retrieval capability.

2. High-level waste receipt and retrieval systems shall be designed to
complement the existing storage facilities for safe storage and transfer of
high-level waste.

I.3.a.(2)

Design Review for Existing Facilities. Uniform requirements for the
preparation of safety analysis reports for high-level waste operations, detailed
in DOE 5481.1B, include the review of existing operational facilities based on
current technical criteria. When hazards are identified that should be
eliminated, controlled, or mitigated, appropriate upgrading, actions in
accordance with paragraph 3a(1) above, shall be identified and implemented
according to the requirements of DOE 5481.1B.
I.1.E.(8)

I.1.E.(9)

I.1.E.(18)

II.P.(2)(a)
Hazard Analysis Documentation and Authorization Basis. Radioactive
waste management facilities, operations, and activities shall implement DOE
Standards, DOE-STD-1027-92, Hazard Categorization and Accident
Analysis Techniques for Compliance with DOE 5480.23, Nuclear Safety
Analysis Reports, and/or DOE-EM-STD-5502-94, DOE Limited Standard:
Hazard Baseline Documentation, and shall, as applicable, prepare and
maintain hazard analysis documentation and an authorization basis as
required by DOE O 425.1A, Startup and Restart of Nuclear Facilities,
DOE O 5480.21, Unreviewed Safety Questions, DOE 5480.22, Technical
Safety Requirements, and DOE 5480.23, Nuclear Safety Analysis Reports.

Life-Cycle Asset Management. Planning, acquisition, operation,
maintenance, and disposition of radioactive waste management facilities shall
be in accordance with DOE O 430.1A, Life-Cycle Asset Management, and
DOE 4330.4B, Maintenance Management Program including a configuration
management process to ensure the integrity of physical assets and systems.
Corporate physical asset databases shall be maintained as complete, current
inventories of physical assets and systems to allow reliable analysis of
existing and potential hazards to the public and workers.

I.3.b.(1)(a)

Liquid and solidified high-level waste shall be characterized consistent with
radiation protection requirements to determine its hazardous components, per
40 CFR 261 and 40 CFR 264. Characterization shall satisfy requirements of
paragraph 3b(1) (b) and may reflect knowledge of waste generating processes,
laboratory testing results, and/or the results of periodic sampling and analysis.
Examples of required information are chemical composition, physical
properties, radionuclide concentrations, and PH.

II. L.

Waste Characterization. High-level waste shall be characterized using direct
or indirect methods, and the characterization documented in sufficient detail
to ensure safe management and compliance with the waste acceptance
requirements of the facility receiving the waste.

(1) Data Quality Objectives. The data quality objectives process, or a
comparable process, shall be used for identifying characterization
parameters and acceptable uncertainty in characterization data.

(2) Minimum Waste Characterization. Characterization data shall, at a
minimum, include the following information relevant to the
management of the waste:

(a) Physical and chemical characteristics;

(b) Volume, including the waste and any solidification media;

(d) Any other information which may be needed to demonstrate
compliance with the requirements of the DOE/EM-0093, Waste
Acceptance Product Specifications for Vitrified High-Level Waste
Forms, or DOE/RW-0351P, Waste Acceptance System Requirements
Document, for non-vitrified, immobilized high-level waste.

(3) Hazardous Characteristics. Waste characterization processes shall
yield sufficient chemical and physical data to clearly identify any
hazardous characteristics that may degrade the ability of structures,
systems, and components to perform their radioactive waste
management function.

I.3.b.(1)(b)

Waste characteristics and compatibility information shall be documented in a
safety analysis report (see DOE 5481.1B) and be used as a basis for designing
new facilities.

I. 1.E.(8)

I.1.E.(10)

Hazard Analysis Documentation and Authorization Basis. Radioactive
waste management facilities, operations, and activities shall implement DOE
Standards, DOE-STD-1027-92, Hazard Categorization and Accident
Analysis Techniques for Compliance with DOE 5480.23, Nuclear Safety
Analysis Reports, and/or DOE-EM-STD-5502-94, DOE Limited Standard:
Hazard Baseline Documentation, and shall, as applicable, prepare and
maintain hazard analysis documentation and an authorization basis as
required by DOE O 425.1A, Startup and Restart of Nuclear Facilities,
DOE O 5480.21, Unreviewed Safety Questions, DOE 5480.22, Technical
Safety Requirements, and DOE 5480.23, Nuclear Safety Analysis Reports.

Mixed Waste. Radioactive waste that contains both source, special nuclear,
or by-product material subject to the Atomic Energy Act of 1954, as amended,
and a hazardous component is also subject to the Resource Conservation and
Recovery Act (RCRA), as amended.

I.3.b.(2)(a)

All new high-level waste handling, transfer, and storage facilities (e. g., tanks,
bins, pipelines, and capsules) shall be doubly contained.

II. P.(2)(b)

Facility Design. The following facility design requirements, at a minimum,
apply:

Confinement. High-level waste systems and components shall be designed
to maintain waste confinement. The following requirements apply to new or
modifications to existing high-level waste systems, ancillary systems, and
components:

1. Secondary confinement systems shall be designed to prevent any
migration of wastes or accumulated liquid out of the waste system; shall
be capable of detecting, collecting, and retrieving releases into the
secondary confinement; and shall be constructed of, or lined with,
materials that are compatible with the waste(s) to be placed in the waste
system.

2. Tank and piping systems used for high-level waste collection,
pretreatment, treatment, and storage shall be welded construction,
except where remote configurations or periodic rerouting of high-level
waste streams require non-welded construction.

I.3.b.(2)(b)

Singly contained pipelines may be used routinely for liquid waste that has a
total radioactivity concentration of less than 0.05Ci/gal(4. 9 x 1011 Bq/m3).
They may be used on a temporary basis for higher activity waste, if appropriate
design and administrative controls are in place to mitigate adverse effects from
a pipeline failure.

None

This is a very prescriptive requirement for which there is no documented
technical basis for the value (0.05 Ci/gal.) contained in the DOE 5820.2A
requirement. DOE M 435.1-1, Section II.Q.(2)(c) addresses the concern of
structural integrity of single-walled pipelines, and all pipelines, by requiring
that their structural integrity be verified to assure leak tightness and structural
strength, no matter the activity level.

I.3.b.(2)(c)

Leaking waste storage systems shall not be used to receive waste unless
secondary containment is maintained. (e. g., liquid Level maintained below
leak point) and it can be shown with the support of formal documentation (e.
g., Safety Analysis Reports, Operational Safety Requirements, Operating
Standards) that temporary operation can be performed without releasing
radioactive Liquid to the environment.

None

The conditions for continued use of single wall and leaking tanks have been
provided in the Manual. These conditions are established in two new
requirements under Section II.Q., Storage. Section II.Q.1. addresses
operation of confinement systems, and Section II.Q.(2)(a) addresses structural
integrity requirements for tanks in-service that are leak tight, both single and
double confinement. These tanks must demonstrate leak-tightness and
structural strength. Furthermore, a projection of the remaining service life
(leak-tightness and structural strength) must be made. Section II. Q.
(2)(b)addresses the conditions for the continued use of leaking tanks both
single and double confinement. For tanks that are known, or suspected, to
leak, the structural integrity program must identify a safe operational
envelope for each such tank to remain in service. This operational envelope
may be specified in terms of capacity, waste properties, or both; and the time
period for which the leak-tightness and structural strength can be assured for
the safe operational envelope must be established. The requirement also
specifies that the additional controls necessary to maintain the safe
operational envelope be identified. Such controls may include periodic
pumping to remove all pumpable liquid, keep the freeboard at specified
levels, and/or periodicity for future structural integrity assessments.

I.3.b.(2)(d)
Secondary containment systems shall be capable of containing liquids that leak
into them from the primary system and shall be equipped with transfer
capability to retrieve the leaked liquid. Secondary containment systems for
solidified high-level waste shall provide for physical isolation of the waste
from the environment.
II. P.(2)(b)

II.Q.(1)

II.Q.(2)(c)

Storage. The following requirements are in addition to those in Chapter I of
this Manual and also apply to facilities intended for management of high-level waste awaiting pretreatment, treatment, or disposal, unless stated
otherwise.

(1) Operation of Confinement Systems.

(a) Confinement systems shall be operated and maintained so as to preserve
the design basis.

(b) Secondary confinement systems, where provided, shall be operated to
prevent any migration of wastes or accumulated liquid out of the waste
confinement systems.

Other Storage Components. The structural integrity of other storage
components shall be verified to assure leak tightness and structural strength.

II.Q.(3)

Canistered Waste Form Storage. Canisters of immobilized high-level
waste awaiting shipment to a repository shall be:

(a) Stored in a suitable facility;

(b) Segregated and clearly identified to avoid commingling with low-level,
mixed low-level, or transuranic wastes; and

(c) Monitored to ensure that storage conditions are consistent with
DOE/EM 0093, Waste Acceptance Product Specifications for Vitrified
High-level Waste Forms, or DOE/RW-0351P, Waste Acceptance System
Requirements Document, for non-vitrified immobilized high-level
waste. Facilities and operating procedures for storage of vitrified high-level waste shall maintain the integrity of the canistered waste form.

I.3.b.(2)(e)

To the extent practical, waste shall be segregated by type (sludge, salt, high
activity, and low activity) to make accessibility for future processing easier.

II. P.(2)(g)

II.V.(2)

Facilities for Receipt and Retrieval of High-Level Waste.

1. Designs for storage facilities shall incorporate features to facilitate
retrieval capability.

2. High-level waste receipt and retrieval systems shall be designed to
complement the existing storage facilities for safe storage and transfer of
high-level waste.

Operation of Facilities for Receipt and Retrieval of High-Level Waste.
High-level waste receipt and retrieval systems shall be operated and
maintained consistent with high-level waste system features incorporated in
the facilities. Strategies for retrieval of waste shall be analyzed to ensure that
structural and radiological impacts are consistent with the facility design
basis.

I.3.b.(2)(f)

Where required, ventilation and filtration systems shall be provided to
maintain radionuclide releases within the guidelines specified in DOE 5481.1B
and applicable EH Orders. Ventilation systems shall be provided where the
possibility exists for generating flammable and explosive mixtures of gases (e.
g., hydrogen/air or organic/air).

II. P.(2)(d)

Ventilation.

1. Design of high-level waste pretreatment, treatment, and storage facilities
shall include ventilation through an appropriate filtration system to
maintain the release of radioactive material in airborne effluents within
the applicable requirements.

2. When conditions exist for generating gases in flammable and explosive
concentrations, ventilation systems or other measures shall be provided
to keep the gases in a non-flammable and non-explosive condition.
Where concentrations of explosive or flammable gases are expected to
approach the lower flammability limit, measures shall be taken to
prevent deflagration or detonation.

I.3.b.(2)(g)

Facilities using cathodic corrosion protection systems shall include engineered
features that protect against abnormal conditions such as stray currents or
system failure. The cathodic protection systems shall be calibrated annually,
and all sources of impressed current shall be inspected and/or tested at least
every other month.

II. Q.(2)(a)3.

II.Q.(2)(b)(3)

Structural Integrity Program.

Leak-Tight Tanks In-Service. A structural integrity program shall be
developed for each high-level waste storage tank site to verify the structural
integrity and service life of each tank to meet operational requirements for
storage capacity. The program shall be capable of:

3. Adjusting the chemistry of tank waste, calibrating cathodic protection
systems, wherever employed, and implementing other necessary
corrosion protection measures;

In-Service Tanks that Have Leaked or Are Suspect. For each high-level
waste storage tank in-service that is known to have leaked, or is suspect, a
modified structural integrity program shall be developed and implemented to
identify the safe operational envelope. The modified program shall be
capable of:

3. Adjusting the chemistry of tank waste, calibrating cathodic protection
systems, wherever employed, and implementing other necessary
corrosion protection measures;

I.3.b.(2)(h)

Engineering controls shall be incorporated to provide liquid volume inventory
data and to prevent spills, leaks, and overflows from tanks or containment
systems. Examples are level-sensing devices, liquid level alarms, and
maintenance of sufficient freeboard. The high-level waste shall be stored at
pressures lower than those of ancillary systems (e.g., cooling water).

II. P.(2)(i)

II. P.(2)(j)

II.T.

Instrumentation and Control Systems. Engineering controls shall be
incorporated in the design and engineering of high-level waste treatment
storage, pretreatment, and treatment facilities to provide volume inventory
data and to prevent spills, leaks and overflows from tanks or confinement
systems.

Volume Monitoring Systems. Monitoring and/or leak detection capabilities
shall be incorporated in the design and engineering of high-level waste
storage, pretreatment, and treatment facilities to provide rapid detection of
failed confinement and/or other abnormal conditions.

Monitoring. High-level waste pretreatment, treatment, storage, and
transportation facilities shall be monitored for chemical, physical,
radiological, structural, and other changes that could indicate failure of
system confinement, integrity, or safety, and which could lead to abnormal
events or accidents. Parameters that shall be sampled or monitored, at a
minimum, include: temperature, pressure (for closed systems), radioactivity
in ventilation exhaust and liquid effluent streams, flammable or explosive
mixtures of gases, level and/or waste volume, and significant waste chemistry
parameters for non-immobilized high-level waste. Facility monitoring
programs shall also include physical inspections to verify that control systems
have not failed.

I.3.b.(2)(i)

Nuclear criticality safety considerations and controls shall be evaluated for
normal operations and, before any significant operational changes are made, to
protect against an uncontrolled nuclear criticality incident (e. g., dissolution of
sludges for removal from tank).

I. 1.E.(4)

Criticality Safety. Radioactive waste management facilities, operations, and
activities shall be covered by a criticality safety program in accordance with
DOE O 420.1, Facility Safety.

I.3.b.(2)(j)

Each facility shall utilize remote maintenance features and other appropriate
techniques to minimize personnel radiation exposure in accordance with DOE
5481.1B.

II. P.(2)(f)

Maintenance Exposure Reduction. Remote maintenance features and other
appropriate techniques to maintain as low as reasonably achievable (ALARA)
personnel exposures shall be incorporated into each high-level waste facility.

I.3.b.(2)(k)

Upon loss and subsequent recovery of normal electrical power, high-level
waste transfer equipment shall not have the capability to restart without active
operator action.

None

II.P.(2)(b)

II.N.

This prescriptive requirement is unnecessary. The DOE M 435.1-1
performance-based requirements in Section II.P. (2)(a), Safety Structures,
Systems, and Components, addresses safety and safety class systems,
structures, and components, and encompass this as well as other prescriptive
requirements regarding system safety. Additionally, the following DOE M
435.1-1 sections address the DOE 5820.2A concern:

Waste Transfer. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Authorization. High-level waste shall not be transferred to a storage,
treatment, or disposal facility until personnel responsible for the facility
receiving the waste authorize the transfer.

I.3.b.(2)(k) (cont.)

(2) Data. Waste characterization data and generation, storage,
pretreatment, treatment, and transportation information for high-level
waste shall be transferred with or be traceable to the waste.

(3) Records and Transfer Reporting. The records and transfer
requirements for canistered high-level waste forms shall comply with
DOE/EM-0093, Waste Acceptance Product Specification for Vitrified
High-Level Waste Forms, or DOE/RW-0351P, Waste Acceptance
System Requirements Document, for non-vitrified, immobilized high-level waste.

I.3.b.(3)(a)

Monitoring and Leak detection capability shall be incorporated in the
engineering systems (e. g., Liquid Level sensing devices and alarms for high-level waste liquid systems) to provide rapid identification of failed
containment, and measurement of abnormal temperatures. The following, at a
minimum, shall be monitored: temperature; pressure; radioactivity in
ventilation exhaust; and Liquid effluent streams associated with high-Level
Waste facilities. Where the possibility exists for the generation of flammable
and explosive mixtures of gases, monitoring shall be conducted. For facilities
storing liquid high-level waste, the following should also be monitored: liquid
levels; sludge volume; tank chemistry; condensate and cooling water.

II. P.(2) (i)

II. P.(2) (j)

II. T.

I.3.b.(3)(b)

Leak detection systems (e. g., conductivity probes) shall be designed and
operated so that they will detect the failure of the primary containment
boundary, the occurrence of waste release, or accumulated liquid in the
secondary containment system.

II. P.(2) (i)

II. P.(2)(j)

II. P.(2)(b)

II.Q.(1)

II.T.

Operation of Confinement Systems.

(a) Confinement systems shall be operated and maintained so as to preserve
the design basis.

(b) Secondary confinement systems, where provided, shall be operated to
prevent any migration of wastes or accumulated liquid out of the waste
confinement systems.

I.3.b.(3)(c)

A method for periodically assessing waste storage system integrity (e. g.,
coupons for corrosion testing, photographic and periscope inspections, leak
detectors, liquid level devices) shall be established, documented, and reported
as required in the Waste Management Plan.

II. Q.(2)

Structural Integrity Program.

(a) Leak-Tight Tanks In-Service. A structural integrity program shall be
developed for each high-level waste storage tank site to verify the
structural integrity and service life of each tank to meet operational
requirements for storage capacity. The program shall be capable of:

1. Verifying the current leak-tightness and structural strength of each
tank in service;

2. Identifying corrosion, fatigue, and other critical degradation modes;

3. Adjusting the chemistry of tank waste, calibrating cathodic protection
systems, wherever employed, and implementing other necessary
corrosion protection measures;

4. Providing credible projections as to when structural integrity of each
tank can no longer be assured; and

5. Identifying the additional controls necessary to maintain an
acceptable operating envelope.

(b) In-Service Tanks that Have Leaked or Are Suspect. For each high-level waste storage tank in-service that is known to have leaked, or is
suspect, a modified structural integrity program shall be developed and
implemented to identify the safe operational envelope. The modified
program shall be capable of:

I.3.b.(3)(c) (cont.)

1. Verifying the structural strength of each tank in-service which has
leaked or is suspect;

2. Identifying corrosion, fatigue and other critical degradation modes;

3. Adjusting the chemistry of tank waste, calibrating cathodic protection
systems, wherever employed, and implementing other necessary
corrosion protection measures;

4. Determining which of the tanks that have leaked or are suspect may
remain in service by identifying an acceptable safe operating envelope;

5. Providing credible projections as to when the acceptable safe
operational envelope can no longer be assured; and

6. Identifying the additional controls necessary to maintain the
acceptable safe operational envelope.

When physical activities, as part of a structural integrity program, pose
additional vulnerabilities, alternative measures shall be implemented to
provide an acceptable storage operational envelope.

(c) Other Storage Components. The structural integrity of other storage
components shall be verified to assure leak tightness and structural
strength.

I.3.b.(3)(d)

Electrical monitoring and Leak detection devices essential to safe operations
shall be provided with backup power, as appropriate, to ensure operability
under emergency conditions.

None.

I.1.E.(8)

I.1.E.(18)

This prescriptive requirement is unnecessary. The DOE M 435.1-1
performance-based requirement at paragraph II P (2) (a), which addresses
safety and safety class systems, structures, and components, encompass this O
5820.2A requirement. Additionally the following DOE Orders cited in DOE
M 435.1-1 provide defense-in-depth:

Site Evaluation and Facility Design. New radioactive waste management
facilities, operations, and activities shall be sited and designed in accordance
with DOE O 420.1, Facility Safety, and DOE O 430.1A, Life-Cycle Asset
Management.

I.3.b.(3)(e)

Surface water systems associated with the high-Level Waste storage area shall
be monitored according to applicable National Pollution Discharge
Elimination System permits and EH Order requirements.

None

This prescriptive requirement is unnecessary. Permitting requirements are not
within the established scope of this Order. DOE M 435.1-1 provides a list of
other appropriate regulations and directives in Chapter I, paragraph 1.E., for
example, Section I.1.E.(7), Environmental Monitoring.

I.3.b.(3)(f)

A system of ground water or vadose zone monitoring wells meeting the
Resource Conservation and Recovery Act requirements per 40 CFR 264 shall
be installed, as a minimum, around clusters of liquid waste storage tanks.

None

I.3.b.(4)(a)

A tank or secondary containment system from which there has been a leak or a
spill to the surrounding soil, or which is otherwise unfit for use, shall be
removed from service until conditions can be evaluated fully.

None

I.2.F.(20)

This prescriptive requirement is unnecessary. The related safety concerns are
addressed in DOE M 435.1-1, Section II.Q.(2). This performance based
requirement. addresses structural integrity for tanks in-service and for other
components of the storage system. Single shell tanks must demonstrate leak-tightness and structural strength. Furthermore, a projected service life (leak-tightness and structural strength) must be made. For tanks that are known, or
suspected, to leak, the structural integrity program must identify the safe
operational envelope for each such tank. This operational envelope may be
specified in terms of capacity, waste properties, or both; and, the time period
for which the safe operational envelope can be assured must be established.
The requirement also specifies that the additional controls necessary to
maintain the safe operational envelope be identified. Such controls may
include periodic pumping to remove all pumpable liquid, keep the freeboard
at specified levels, and/or periodicity for future structural integrity
assessments.

Corrective Actions. Ensuring a process exists for proposing, reviewing,
approving, and implementing corrective actions when necessary to ensure
that the requirements of DOE O 435.1, Radioactive Waste Management, and
this Manual are met, and to address conditions that are not protective of the
public, workers, or the environment. The process shall allow workers,
through the appropriate level of management, to stop or curtail work when
they discover conditions that pose an imminent danger or other serious hazard
to workers or the public, or are not protective of the environment.

II.I

Corrective Actions. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Order Compliance. Corrective actions shall be implemented whenever
necessary to ensure the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual are met.

(2) Operations Curtailment. Operations shall be curtailed or facilities
shut down for failure to establish, maintain, or operate consistent with
an approved radioactive waste management basis.

I.3.b.(4)(b)
Upon detection of released radioactive materials, steps shall be taken to
prevent further migration of the release to soil or surface water. Major
contamination in the soil shall be removed or stabilized unless compliance
with this requirement would cause greater harm to human health or the
environment.
None.

I.2.F.(20)
DOE O 151.1, Comprehensive Emergency Management System, cites the
discovery of releases of radioactive waste as an "Operational Emergency
Events and Condition" , Chapter V, paragraph 2.(a)(1), that is covered by that
Order. DOE M 435.1-1, Section I.1.E.(5) requires that radioactive waste
management facilities, operations, and activities shall maintain an emergency
management program in accordance with DOE O 151.1, Comprehensive
Emergency Management System.. Released material is not considered
radioactive waste to be managed as defined in DOE M 435.1-1, Chapter I,
Attachment 1, Glossary, and as such, are not within the scope of DOE O
435.1. DOE O 435.1 and DOE M 435.1-1 set forth the requirements that
DOE and its contractors must follow in managing radioactive waste to protect
workers, the public, and the environment from radiological exposures. In the
context of "managing" radioactive waste, these directives apply to waste in
storage, treatment, and disposal (except the disposal of high-level waste in the
NRC-regulated geologic repository and disposal of transuranic waste at the
WIPP, both of which are covered by other regulations). These directives all
have as their objective promoting practices that preclude the uncontrolled
release of radioactive material, such as from leaking tanks. However,
remediation of past or future uncontrolled releases are not within the scope of
DOE O 435.1 and DOE M 435.1-1 and are generally conducted under the
CERCLA process. Thus the DOE 5820.2A requirement at I.3.b.(4)(b)
regarding the remediation of released material has not be retained in DOE M
435.1-1.

II.I.

public, workers, or the environment. The process shall allow workers,
through the appropriate level of management, to stop or curtail work when
they discover conditions that pose an imminent danger or other serious hazard
to workers or the public, or are not protective of the environment.

Corrective Actions. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Order Compliance. Corrective actions shall be implemented whenever
necessary to ensure the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual are met.

(2) Operations Curtailment. Operations shall be curtailed or facilities
shut down for failure to establish, maintain, or operate consistent with
an approved radioactive waste management basis.

I.3.b.(4)(c)

If a release results from a spill and the integrity of the system is not damaged,
the system may be returned to service as soon as action to correct the condition
is completed

I.2.F.(20)

II.I.

Corrective Actions. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Order Compliance. Corrective actions shall be implemented whenever
necessary to ensure the requirements of DOE O 435.1, Radioactive
Waste Management, and this Manual are met.

(2) Operations Curtailment. Operations shall be curtailed or facilities
shut down for failure to establish, maintain, or operate consistent with
an approved radioactive waste management basis.

I.3.b.(4)(d)

For emergency situations involving liquid high-level waste, spare capacity
with adequate heat dissipation capability shall be maintained to receive the
largest volume of liquid contained in any one tank. Adequate transfer pipelines
also shall be maintained in operational condition. Interconnected tank farms
with adequate transfer capabilities and spare capacity may be considered as a
single tank farm for purposes of this requirement.

II. H.

Contingency Actions. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Contingency Storage. For off-normal or emergency situations
involving high-level waste storage or treatment, spare capacity with
adequate capabilities shall be maintained to receive the largest volume
of waste contained in any one storage vessel, pretreatment facility, or
treatment facility. Tanks or other facilities that are designated for high-level waste contingency storage shall be maintained in an operational
condition when waste is present and shall meet all the requirements of
DOE O 435.1, Radioactive Waste Management, and this Manual.

(2) Transfer Equipment. Pipelines and auxiliary facilities necessary for
the transfer of waste to contingency storage shall be maintained in an
operational condition when waste is present and shall meet the
requirements of DOE O 435.1, Radioactive Waste Management, and
this Manual.

I.3.b.(4)(e)

A schedule and procedure shall be developed for monitoring, Surveillance, and
calibration checks. The frequency of these activities shall be based on the
potential rate of equipment deterioration and the possibility of an
environmental or human health incident, assuming that a malfunction from
equipment failure or human error is not detected between checks. Schedules,
procedures, and performance requirements shall be documented in the
operating and maintenance documentation.

II.T.

I. 1.E.(3)

Conduct of Operations. Radioactive waste management facilities,
operations, and activities shall be conducted in manner based on
consideration of the associated hazards. Waste management facilities,
operations, and activities shall meet the requirements of DOE 5481.19,
Conduct of Operations Requirement for DOE Facilities.

I.3.b.(4)(f)

Each high-level waste facility shall have response procedures for credible
emergencies, as identified in the Safety Analysis Reports.

I. 1.E.(5)

Emergency Management Program. Radioactive waste management
facilities, operations, and activities shall maintain an emergency management
program in accordance with DOE O 151.1, Comprehensive Emergency
Management System.

I.3.b.(5)(a)

Operator training and qualification standards shall be developed and an up-to-date record of training status shall be maintained.

I. 1.E.(19)

I. 2. F.(11)

Training and Qualification. A training and qualification program shall be
implemented for radioactive waste management program personnel, and shall
meet the requirements of DOE O 360.1, Training, and DOE 5480.20A,
Personnel Selection, Qualification, and Training Requirements for DOE
Nuclear Facilities.

Training and Qualification. Ensuring a training and qualification program
is implemented for designated radioactive waste management program
personnel, and the training is commensurate with job duties and
responsibilities. Only those personnel who have been trained and qualified
shall design or operate safety class and safety significant structures, systems,
and components.

I.3.b.(5)(b)

Worker safety training must comply with the requirements of DOE 5480.1B
and applicable EH Orders.

I. 1.E.(19)

I. 2. F.(11)

I.3.b.(6)(a)

Quality Assurance. Consistent with DOE 5700.6B, high-level waste operations
shall be conducted in accordance with applicable requirements of the American
National Standards Institute/American Society of Mechanical Engineers
Nuclear Quality Assurance-1 and other appropriate national consensus
standards. (See Attachment 1, page 5, paragraph 48).

II. G.

I.1.E.(12)

Quality Assurance Program. The following requirements are in addition to
those in Chapter I of this Manual.

I.3.b.(7)(a)

For the purpose of economy and enhancing the safety of high-Level Waste
storage, processing programs shall be developed and implemented at the
generating site to reduce the quantity of waste being sent to storage, and
techniques (e. g., evaporation) shall be implemented to reduce further the
waste volume in storage.

None

II.J.(1)(a), (d)

This requirement primarily addresses efficiency of operations and is not
retained in DOE M 435.1-1. The following requirements at II.J. and II.K.
provide the safety performance sought by the O 5820.2A requirement.

Waste Acceptance. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Technical and Administrative. Waste acceptance requirements for all
high-level waste storage, pretreatment, or treatment facilities,
operations, and activities shall specify, at a minimum, the following:

(a) Allowable activities and/or concentrations of specific radionuclides;

II.J.(2)

II.K.(1)

I.1.E.(20)

(d) Pretreatment, treatment, storage, packaging, and other operations
shall be designed and implemented in a manner that will ultimately
comply with DOE/EM-0093, Waste Acceptance Product Specifications
for Vitrified High-Level Waste Forms, or DOE/RW-0351P, Waste
Acceptance System Requirements Document, for non-vitrified,
immobilized high-level waste.

(2) Evaluation and Acceptance. The receiving facility shall evaluate
waste for acceptance, including confirmation that the technical and
administrative requirements have been met. A process for the
disposition of non-conforming wastes shall be established.

Waste Generation Planning. The following requirements are in addition to
those in Chapter I of this Manual.

(1) Life-Cycle Planning. Prior to waste generation, planning shall be
performed to address the entire life cycle for all high-level waste
streams.

Waste Minimization and Pollution Prevention. Waste minimization and
pollution prevention shall be implemented for radioactive waste management
facilities, operations, and activities to meet the requirements of Executive
Order 12856, Federal Compliance with Right-to-Know Laws and Pollution
Prevention Requirements, and Executive Order 13101, Greening the
Government through Waste Prevention, Recycling, and Federal Acquisition,
and DOE 5400.1, General Environmental Protection Program.

I.3.b.(7)(b)

Programs should be developed and implemented to treat high-level waste in
storage to prepare it for eventual conversion to suitable disposal forms, as such
forms are developed. This may include separation of high-level waste into
other waste categories, such as transuranic waste or low-level waste.

II. R.

II.B.

Treatment. Treatment shall be designed and implemented in a manner that
will ultimately comply with DOE/EM-0093, Waste Acceptance Product
Specifications for Vitrified High-Level Waste Forms, or DOE/RW-0351P,
Waste Acceptance System Requirements Document, for non-vitrified,
immobilized high-level waste.

Waste Incidental to Reprocessing. Waste resulting from reprocessing spent
nuclear fuel that is determined to be incidental to reprocessing is not high-level waste, and shall be managed under DOE's regulatory authority in
accordance with the requirements for transuranic waste or low-level waste, as
appropriate. When determining whether spent nuclear fuel reprocessing plant
wastes shall be managed as another waste type or as high-level waste, either
the citation or evaluation process described below shall be used:

(1) Citation. Waste incidental to reprocessing by citation includes spent
nuclear fuel reprocessing plant wastes that meet the description included
in the Notice of Proposed Rulemaking (34 FR 8712) for proposed
Appendix D, 10 CFR Part 50, Paragraphs 6 and 7. These radioactive
wastes are the result of reprocessing plant operations, such as, but not
limited to: contaminated job wastes including laboratory items such as
clothing, tools, and equipment.

(2) Evaluation. Determinations that any waste is incidental to reprocessing
by the evaluation process shall be developed under good record-keeping
practices, with an adequate quality assurance process, and shall be
documented to support the determinations. Such wastes may include,
but are not limited to, spent nuclear fuel reprocessing plant wastes that:

(a) Will be managed as low-level waste and meet the following criteria:

1. Have been processed, or will be processed, to remove key
radionuclides to the maximum extent that is technically and
economically practical; and
2. Will be managed to meet safety requirements comparable to
the performance objectives set out in 10 CFR Part 61, Subpart
C, Performance Objectives; and
3. Are to be managed, pursuant to DOE's authority under the
Atomic Energy Act of 1954, as amended, and in accordance
with the provisions of Chapter IV of this Manual, provided the
waste will be incorporated in a solid physical form at a
concentration that does not exceed the applicable
concentration limits for Class C low-level waste as set out in
10 CFR 61.55, Waste Classification.; or will meet alternative
requirements for waste classification and characterization as
DOE may authorize.

(b) Will be managed as transuranic waste and meet the following
criteria:

1. Have been processed, or will be processed, to remove key
radionuclides to the maximum extent that is technically
and economically practical; and
2. Will be incorporated in a solid physical form and meet
alternative requirements for waste classification and
characteristics, as DOE may authorize; and
3. Are managed pursuant to DOE's authority under the
Atomic Energy Act of 1954, as amended, in accordance
with the provisions of Chapter III of this Manual, as
appropriate.

I.3.b.(7)(c)

The chemistry of liquid high-level waste shall be adjusted to control corrosion
within design limits for the storage system.

None.

The adjustment of waste chemistry is encompassed by the requirement for a
structural integrity program in DOE M 435.1-1, Section II.Q.(2). However,
the limits for the adjustment are predicated on the length of time for which
storage capacity needs to be retained. Consequently, these limits will
probably be more restrictive than the original design limits.

I.3.b.(7)(d)

Treatment reagents shall not be placed in a tank system without proven
effective mitigative action if they could cause the tank, its ancillary equipment,
or the containment system to rupture, Leak, or otherwise fail.

II. L.

Waste Characterization. High-level waste shall be characterized using
direct or indirect methods, and the characterization documented in sufficient
detail to ensure safe management and compliance with the waste acceptance
requirements of the facility receiving the waste.

(2) Minimum Waste Characterization. Characterization data shall, at a
minimum, include the following information relevant to the
management of the waste:

(a) Physical and chemical characteristics;

(b) Volume, including the waste and any solidification media;

II. N.
Waste Transfer. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Authorization. High-level waste shall not be transferred to a storage,
treatment, or disposal facility until personnel responsible for the facility
receiving the waste authorize the transfer.

I.3.b.(7)(e)

Waste generation and waste management systems that significantly change the
chemical and physical forms of the waste shall be technically assessed to
assure compatibility and retrievability.

II. L.

Waste Characterization. High-level waste shall be characterized using
direct or indirect methods, and the characterization documented in sufficient
detail to ensure safe management and compliance with the waste acceptance
requirements of the facility receiving the waste.

(2) Minimum Waste Characterization. Characterization data shall, at a
minimum, include the following information relevant to the
management of the waste:

(a) Physical and chemical characteristics;

(b) Volume, including the waste and any solidification media;

(d) Any other information which may be needed to demonstrate
compliance with the requirements of the DOE/EM-0093,
Waste Acceptance Product Specifications for Vitrified High-Level Waste Forms, or DOE/RW-0351P, Waste Acceptance
System Requirements Document, for non-vitrified,
immobilized high-level waste.

II. N.

Waste Transfer. The following requirements are in addition to those in
Chapter I of this Manual.

(1) Authorization. High-level waste shall not be transferred to a storage,
treatment, or disposal facility until personnel responsible for the facility
receiving the waste authorize the transfer.

(2) Data. Waste characterization data and generation, storage,
pretreatment, treatment, and transportation information for high-level
waste shall be transferred with or be traceable to the waste.

I.3.c.(1)

Waste Characterization. The contents of singly contained tank systems shall be
characterized consistent with radiation protection requirements and the needs
associated with safe storage to determine its hazardous components consistent
with 40 CFR 261, 40 CFR 264, and State requirements. Characterization may
reflect knowledge of waste generating processes, laboratory testing results,
and/or the results of periodic sampling and analysis.

II. L.

Waste Characterization. High-level waste shall be characterized using
direct or indirect methods, and the characterization documented in sufficient
detail to ensure safe management and compliance with the waste acceptance
requirements of the facility receiving the waste.

(2) Minimum Waste Characterization. Characterization data shall, at a
minimum, include the following information relevant to the
management of the waste:

(a) Physical and chemical characteristics;

(b) Volume, including the waste and any solidification media;

I.1.E.(10)

Mixed Waste. Radioactive waste that contains both source, special nuclear,
or by-product material subject to the Atomic Energy Act of 1954, as amended,
and a hazardous component is also subject to the Resource Conservation and
Recovery Act (RCRA), as amended.

NOTE: Chemical hazards and safety are not within the scope of DOE M
435.1-1. Therefore, the requirement to characterize high-level waste to
identify RCRA hazardous components was not retained, however, such
requirements are invoked by the RCRA regulations.

I.3.c.(2)(a)

Singly contained tank systems shall not be used to store fresh high-level waste
from fuel reprocessing operations except under emergency conditions as
determined by the Operations Office Manager.

None.

This requirement is not retained, however, the requirements in DOE M 435.1-1, Section II Q.(2)(a), Structural Integrity Program, do allow the continued
use of existing single confinement tank systems provided a determination is
made that the tank system is fit.

II.Q.(2) Structural Integrity Program.

(a) Leak-Tight Tanks In-Service. A structural integrity
program shall be developed for each high-level waste storage
tank site to verify the structural integrity and service life of
each tank to meet operational requirements for storage
capacity. The program shall be capable of:

1. Verifying the current leak-tightness and structural strength
of each tank in service;

2. Identifying corrosion, fatigue, and other critical
degradation modes;

3. Adjusting the chemistry of tank waste, calibrating cathodic
protection systems, wherever employed, and implementing
other necessary corrosion protection