DOE G 435.1-1, Crosswalk Tables: DOE O 5820.2A vs. DOE O 435.1/M 435.1-1

DOE G 435.1-1 Attachment 1 7-09-99 Attachment 1 - Technical Basis and Considerations 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 Attachment 1 - Technical Basis and Considerations Page 2 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 3 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 4 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 5 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 6 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 7 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). CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 8 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 9 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 10 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 11 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 12 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 13 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 14 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 15 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1

5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 16 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 17 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. (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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 18 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, Compensation, 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 19 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 CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 20 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 21 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 22 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 23 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 24 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 25 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. CROSSWALK OF GENERAL REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 26 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 Attachment 1 - Technical Basis and Considerations Page 27 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 28 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 29 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 30 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. 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 430.1A, Life-Cycle Asset Management

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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 31 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. 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 430.1A, Life-Cycle Asset Management. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s)

435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 32 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; (c) Radionuclides or source information sufficient to describe the approximate radionuclide content of the waste; and (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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 33 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 34 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.

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 35 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) 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 36 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 37 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; CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 38 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 39 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: 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 40 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. 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.

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 41 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) 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 42 II.Q.(1) II.T. 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. 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 43

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: CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 44 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 45 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:

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. 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 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. Additionally, Section II.C.(1), Mixed High-Level Waste, invokes RCRA for high-level waste, unless demonstrated otherwise. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 46 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 47 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. 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

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 48 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. 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 49 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) 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 50 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)

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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 51 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. (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. 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. 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; CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 52 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 53 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:

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 54 (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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 55 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. (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; (c) Radionuclides or source information sufficient to describe the approximate radionuclide content of the waste; and

(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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 56 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. (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; (c) Radionuclides or source information sufficient to describe the approximate radionuclide content of the waste; and (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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 57 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.

(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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 58 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. (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; (c) Radionuclides or source information sufficient to describe the approximate radionuclide content of the waste; and (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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 59 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 60

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 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. In addition, the requirements in Section II.L (3) require that the waste be characterized in sufficient detail to identify hazardous characteristics that may degrade the ability of structures, systems and components to perform their radioactive waste management function. I.3.c.(2)(a) (cont.) II.L.(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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 61 I.3.c.(2)(b) Storage and transfer operations shall be conducted within the limits defined in the Safety Analysis Reports according to DOE 5481.1B. I. 1.E.(8) II. F. II.L.(3) 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. Radioactive Waste Management Basis. High-level waste facilities, operations, and activities shall have a radioactive waste management basis consisting of physical and administrative controls to ensure the protection of workers, the public, and the environment. The following specific waste management controls shall be part of the radioactive waste management basis: (1) Generators. The waste certification program. (2) Pretreatment and Treatment Facilities. The waste acceptance requirements and waste certification program.

(3) Storage Facilities. The waste acceptance requirements and the waste certification program. Waste Characterization. (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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 62 I.3.c.(2)(c) Engineered systems shall be incorporated to provide waste volume inventory data, consistent with the nature of the specific waste stored in singly contained tanks. Examples are surface level sensing devices and interstitial liquid level sensing devices. II. P.(2)(i) II. P.(2)(j) Instrumentation and Control Systems. Engineering controls shall be incorporated to provide volume inventory data and to prevent spills, leaks, and overflows from tanks or containment systems. Examples are level- sensing devices, liquid level alarms, anti-siphoning devices, and maintenance of sufficient freeboard. Volume Monitoring Systems. Monitoring and leak detection capabilities shall be incorporated in the design and engineering of systems to provide rapid identification of failed containment and/or other abnormal conditions. I.3.c.(2)(d) Singly contained pipelines: (see paragraph 3b(2) (b)) . 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 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.c.(2)(e) Where active ventilation is required systems-shall be provided to maintain radionuclide releases at the point of discharge within the guidelines specified in applicable EH Orders for offsite concentrations and DOE 5480.1B for onsite dose commitment considerations. 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. I.3.c.(2)(f) Nuclear criticality safety (see paragraph 3b(2) (I)). 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.c.2.g Each facility shall use remote maintenance features and other appropriate techniques to maintain personnel radiation exposure as low as reasonably achievable. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 63 I.3.c.2.h Electrical power loss (see paragraph 3b(2) (k)). None II.P.(2)(b)

II.N. This prescriptive requirement is unnecessary. The DOE M 435.1-1 performance-based requirements at paragraph II P (2) (a) that addresses safety and safety class systems, structures, and components would encompass this as well as other prescriptive requirements regarding system safety. 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 64 (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.c.3.a Monitoring and surveillance capability shall exist to provide liquid volume, waste inventory data, and identification of failed containment. II. P.(i) II. P.(j) Instrumentation and Control Systems. Engineering controls shall be incorporated to provide volume inventory data and to prevent spills, leaks, and overflows from tanks or containment systems. Examples are level- sensing devices, liquid level alarms, anti-siphoning devices, and maintenance of sufficient freeboard. Monitoring Systems. Monitoring and leak detection capabilities shall be incorporated in the design and engineering of systems to provide rapid identification of failed containment and/or other abnormal conditions I.3.c.3.b A method for periodically assessing waste storage tank integrity (e. g., coupons, photographic inspections, leak detectors, liquid level devices) shall be established and documented. II.Q.(2)(a) 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 65 I.3.c.3.c Emergency power (see paragraph 3b(3) (d)). None II.P.(2)(a) 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: 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 Analysis Reports. 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. 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.c.3.d Monitoring wells (see paragraph 3b(3) (f)). 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 I.1.E.(7), Environmental Monitoring. Additionally, Section II.C.(1), Mixed High-Level Waste, invokes RCRA for high-level waste, unless demonstrated otherwise. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 66 I.3.c.4.a A contingency action plan shall be maintained to respond to spills or leaks and other credible emergencies as identified in the Safety Analysis Reports. II. H. I. 1.E.(5) 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. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 67 I.3.c.4.b Leak mitigation (see paragraph 3.b(4) (b)). None I.2.E.(18) 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 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. 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 CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 68 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.c.4.c For emergency situations involving pumpable liquid in singly contained tanks, appropriate equipment (e.g., pumps) shall be maintained to provide removal of liquid. 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 69 I.3.c.5 Training. (see paragraphs 3b(5) (a) and (b)). 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.c.6 Quality Assurance. (see paragraphs 3b(6) (a)). II. G. I. 1.E.(12) 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.

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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 70 I.3.d Disposal. New and readily retrievable waste shall be processed and the high- level waste fraction disposed of in a geologic repository according to the requirements of the Nuclear Waste Policy Act of 1982 (Public Law 97-425) as amended. Options for permanent disposal of other waste, such as single shell tank waste, shall be evaluated and include such methods as in-place stabilization as well as retrieval and processing, as required for new and readily retrievable waste. Analytic predictions of disposal system performance shall be prepared and incorporated in the National Environmental Policy Act process. II. S. Disposal. Disposal of high-level waste must be in accordance with the provisions of the Nuclear Waste Policy Act of 1982, as amended, and any other applicable statutes. I.3.d.1 New and Readily Retrievable. New and readily retrievable existing high-level waste shall be processed to a final immobilized form in facilities such as the Defense Waste Processing Facility and the Hanford Waste Vitrification Plant preparatory to permanent disposal in a deep geologic repository. None The Nuclear Waste Policy Act of 1982, as amended, its implementing regulations, and Departmental documents, establish the requirements for the waste form to be disposed in the repository. The requirement at II.R.,Treatment, identifies the DOE implementing documents. I.3.d.1.a Waste acceptance specifications and criteria based upon the requirements outlined in 10 CFR 60. 113, 10 CFR 60. 131(b)(7), 10 CFR-60.135, 10 CFR 71.87 and 40 CFR 191 shall be developed for high-level waste forms prior to startup of facilities that generate the disposal waste form. Specifications and criteria shall be approved by RW-20 and DP-12 for Defense Programs high- level waste forms and by RW-20 and NE-20 for West Valley Demonstration Project product. As examples, specifications and criteria for the Defense Waste Processing Facility vitrified high-level waste form are documented in DOE/RW-0125; those for the West Valley Demonstration Project high-level waste form are documented in DOE/RW-0136. II. R. II.J.(1)(d) 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 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: (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.

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 71 I.3.d.1.b Interim storage for solidified high-level waste awaiting transport to the designated geologic repository shall comply with applicable requirements in paragraph 3b. 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.d.2 Other Waste. High-level waste that is not readily retrievable shall be monitored periodically in situ. Field offices shall reevaluate the safety of such waste to determine the need for corrective measures as necessary. Options for permanent disposal of singly contained tank waste shall be evaluated and include such methods as in-place stabilization as well as retrieval and processing, as required for new and readily retrievable waste in paragraph 3d(1). None This requirement has not be retained, current DOE policy is that all high- level waste shall be retrieved and treated to meet the requirements for disposal in a geologic repository. Residues that are not technically, or economically, practical to remove are addressed by the requirements in Section II.B., Waste Incidental to Reprocessing, and Section II.U., Closure. II.A. Definition of High-Level Waste. High-level waste is the highly radioactive waste material resulting from the reprocessing of spent nuclear fuel, including liquid waste produced directly in reprocessing and any solid material derived from such liquid waste that contains fission products in sufficient concentrations; and other highly radioactive material that is determined, consistent with existing law, to require permanent isolation. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 72 II.C.(2) TSCA-Regulated Waste. High-level waste containing polychlorinated biphenyls, asbestos, or other such regulated toxic components shall be managed in accordance with requirements derived from the Toxic Substances Control Act, as amended, DOE O 435.1, Radioactive Waste Management, and this Manual. II.D. Complex-Wide High-Level Waste Management Program. A complex- wide program and plan shall be developed as described under Responsibilities, 2.B and 2.D, in Chapter I of this Manual. II.E. Site-Wide Radioactive Waste Management Program. In addition to the items in Chapter I of this Manual, documentation of the Site-Wide Radioactive Waste Management Program shall include a description of the High-Level Waste Systems Engineering Management Program to support decision-making related to nuclear safety, including high-level waste requirements analysis, functional analysis and allocation, identification of alternatives, and alternative selection and system control.

II.K.(2) Waste Generation Planning. The following requirements are in addition to those in Chapter I of this Manual. (2) Waste With No Identified Path to Disposal. High-level waste streams with no identified path to disposal shall be generated only in accordance with approved conditions which, at a minimum, shall address: (a) Programmatic need to generate the waste; (b) Characteristics and issues preventing the disposal of the waste; (c) Safe storage of the waste until disposal can be achieved; and (d) Activities and plans for achieving final disposal of the waste (compliance with DOE/EM-0093, Waste Acceptance Product Specifications for Vitrified High- Level Waste Forms). CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 73 II.M. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving high-level waste for storage, pretreatment, treatment, and disposal are met. (1) Certification Program. The waste certification program shall designate the officials who have the authority to certify and release waste for shipment; and specify what documentation is required for waste generation, characterization, shipment, and certification. The program shall provide requirements for auditability, retrievability, and storage of required documentation and specify the records retention period. (2) Certification Before Transfer. High-level waste shall be certified as meeting the waste acceptance requirements before it is transferred to the facility receiving the waste. (3) Maintaining Certification. High-level waste that has been certified as meeting the waste acceptance requirements for transfer to a storage, pretreatment, treatment, or disposal facility shall be managed in a manner that maintains its certification status. II.O. Packaging and Transportation. The following requirement is in addition to those in Chapter I of this Manual. (1) Canistered Waste Form. Immobilized high-level waste shall meet 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. CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 74 II.P.(1) Site Evaluation and Facility Design. The following requirements are in addition to those in Chapter I of this Manual. (1) Site Evaluation. Proposed locations for high-level waste facilities shall be evaluated to identify relevant features that should be avoided or must be considered in facility design and analyses. (a) Each site proposed for a new high-level waste facility or expansion of an existing high-level waste facility shall be evaluated considering environmental characteristics, geotechnical characteristics, and human activities. (b) Proposed sites with environmental characteristics, geotechnical characteristics, or human activities for which adequate protection cannot be provided through facility design shall be deemed unsuitable for the location of the facility.

CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 75 II.U. Closure. The following requirements for closure of deactivated high-level waste facilities and sites are in addition to those in Chapter I of this Manual. (1) Decommissioning. Deactivated high-level waste facilities/sites shall meet the decommissioning requirements of DOE O 430.1A, Life-Cycle Asset Management and the requirements of DOE 5400.5, Radiation Protection of the Public and the Environment, for release; or (2) CERCLA Process. Deactivated high-level waste facilities/sites shall be closed in accordance with the CERCLA process as described in Section I.2.F.(5); or (3) Closure. Deactivated high-level waste facilities/sites shall be closed in accordance with an approved closure plan as specified below. Residual radioactive waste present in facilities to be closed shall satisfy the waste incidental to reprocessing requirements of this Chapter. (a) Facility/Site Closure Plans. A closure plan shall be developed for each deactivated high-level waste facility/site being closed that defines the approach and plans by which closure of each facility within the site is to be accomplished. This plan shall be completed and approved prior to the initiation of physical closure activities, and updated periodically to reflect current analysis and status of individual facility closure actions. The plan shall include, at a minimum, the following elements: 1. Identification of the closure standards/performance objectives to be applied from Chapter III or IV, as appropriate; CROSSWALK OF HIGH-LEVEL WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A CITATION 5820.2A REQUIREMENT 435.1-1 CITATION(s) 435.1-1 REQUIREMENT(s) Attachment 1 - Technical Basis and Considerations Page 76 2. A strategy for allocating waste disposal facility performance objectives from the closure standards identified in the closure plan among the facilities/units to be closed at the site; 3. An assessment of the projected performance of each unit to be closed relative to the performance objectives allocated to each unit under the closure plan; 4. An assessment of the projected composite performance of all units to be closed at the site relative to the performance objectives and closure standards identified in the closure plan; and 5. Any other relevant closure controls including a monitoring plan, institutional controls, and land use limitations to be maintained in the closure activity. II.V.(1) Specific Operations. Specific requirements are provided for the operation of lifting devices and facilities for receipt and retrieval of high-level waste. (1) Operation of Lifting Devices. Hoisting and rigging activities shall be conducted in accordance with the guidance provided in the DOE Standard “Hoisting and Rigging” (DOE-STD-1090-96). CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 Attachment 1 - Technical Basis and Considerations Page 77 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT II.1 PURPOSE. To establish policies and guidelines for managing DOE transuranic waste starting with its generation, continuing through closure of the Waste Isolation Pilot Plant, and finally the management of buried transuranic waste as defined in Attachment 1, page 3, paragraph 22.

Transuranic wastes that are also mixed wastes are subject to the requirements of the Atomic Energy Act and the Resource Conservation and Recovery Act. Additionally, buried transuranic wastes are subject to the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act, and the Superfund Amendments and Reauthorization Act. 1. III.B.(1) None 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. Mixed Transuranic Waste. Transuranic waste determined to contain both a hazardous component subject to the Resource Conservation and Recovery Act (RCRA), as amended, and a radioactive component subject to the Atomic Energy Act of 1954, as amended, shall be managed in accordance with the requirements of RCRA and DOE O 435.1, Radioactive Waste Management, and this Manual. Evaluations and management decisions regarding buried transuranic waste are environmental remediation issues addressed through the Comprehensive Environmental Response, Compensation, and Liability Act and therefore not a waste management activity addressed in DOE O 435.1 or DOE M 435.1-1. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 78 II.2 POLICY. Transuranic waste shall be managed to protect the public and worker health and safety, as well as the environment, and performed in compliance with applicable radiation protection standards and environmental regulations. Practical and cost effective methods shall be used to reduce the volume and toxicity of transuranic waste. Order 4.b. I.1.E.(20) I.2.F.(3) III.L.(2) 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. 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.

Waste Minimization and Pollution Prevention. Ensuring implementation of waste minimization and pollution prevention programs. Transportation. To the extent practical, the volume of waste and number of transuranic waste shipments shall be minimized. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 79 II.2.a. Transuranic waste shall be certified in compliance with the Waste Isolation Pilot Plant-Waste Acceptance Criteria, placed in interim storage (if required), and sent to the Waste Isolation Pilot Plant. III.I. III.J. III.P. There is not a corresponding 435.1 requirement that is as prescriptive as the 5820.2A requirement. Instead, 435.1 includes requirements that address certification that waste meets waste acceptance criteria and disposal in a facility that meets regulatory requirements. Waste Characterization. Transuranic 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. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met. Disposal. Transuranic waste shall be disposed in accordance with the requirements of 40 CFR Part 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 80 II.2.b. Transuranic waste that the Department of Energy has determined, with the concurrence of the EPA Administrator, does not need the degree of isolation provided by a geologic repository or, transuranic waste that cannot be certified or otherwise approved for acceptance at the Waste Isolation Pilot Plant, shall be disposed of by alternative methods. Alternative disposal methods shall be approved by DOE Headquarters (DP-12 and EH-1) and shall comply with the National Environmental Policy Act requirements and EPA/State regulations. III.A. IV.A. I.2.E.(1) I.1.D. Definition of Transuranic Waste. Transuranic waste is radioactive waste containing more than 100 nanocuries (3700 becquerels) of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for: (1) High-level radioactive waste; (2) Waste that the Secretary of Energy has determined, with the concurrence of the Administrator of the Environmental Protection Agency, does not need the degree of isolation required by the 40 CFR Part 191 disposal regulations; or(3)Waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with 10 CFR Part 61. Definition of Low-Level Waste. Low-level radioactive waste is radioactive waste that is not high-level radioactive waste, spent nuclear fuel, transuranic waste, byproduct material (as defined in section 11e.(2) of the Atomic Energy Act of 1954, as amended), or naturally occurring radioactive material.

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 for: (1) Disposal. Reviewing and approving, along with EH-1, transuranic waste disposal facility performance assessments and other disposal documents as required in waste specific chapters for which DOE is responsible for making compliance determinations. Reviewing and approving performance assessments and composite analyses, or appropriate CERCLA documentation, for low-level waste disposal facilities, and issuing disposal authorization statements. 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. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 81 II.2.b. (cont.) III.P. Disposal. Transuranic waste shall be disposed in accordance with the requirements of 40 CFR Part 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. II.3.a.(1) Any material that is known to be, or suspected of being contaminated with transuranium radionuclides shall be evaluated as soon as possible in the generating process, and determined to be either recoverable material, transuranic waste, low-level waste, mixed waste, or nonradioactive trash in order to avoid commingling the various material streams. I.2.F.(7) III.H. I.1.C. There is not a corresponding 435.1 requirement that is as prescriptive as the 5820.2A requirement. Instead, 435.1 includes requirements for planning the generation of any waste and for managing it within one of the Department’s waste type programs. Field Element Managers. Field Element Managers are responsible for: Radioactive Waste Generator Requirements. Ensuring development, review, approval, and implementation of a program for waste generation planning, characterization, certification, and transfer. This program shall address characterization of waste, preparation of waste for transfer, certification that waste meets the receiving facility’s radioactive waste acceptance requirements, and transfer of waste. 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 transuranic waste streams. 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. II.3.a.(2) The lower concentration limit for transuranic waste (>100 nCi/g of waste) shall apply to the contents of any single waste package at the time of assay. The mass of the waste container including shielding shall not be used in calculating the specific activity of the waste.

III.A. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement. This level of detail is included in the guidance that supports the following 435.1 Definition of Transuranic Waste: Definition of Transuranic Waste. Transuranic waste is radioactive waste containing more than 100 nanocuries (3700 becquerels) of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for: . . . CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 82 II.3.a.(3) Radioactive wastes with quantities of transuranic radionuclides in concentrations of 100 nCi/g of waste or less shall be considered to be low- level waste, and shall be managed according to the requirements of Chapter III of this Order. III.A. IV.A. I.1.C. Definition of Transuranic Waste. Transuranic waste is radioactive waste containing more than 100 nanocuries (3700 becquerels) of alpha-emitting transuranic isotopes per gram of waste, with half-lives greater than 20 years, except for: . . . Definition of Low-Level Waste. Low-level radioactive waste is radioactive waste that is not high-level radioactive waste, spent nuclear fuel, transuranic waste, byproduct material (as defined in section 11e.(2) of the Atomic Energy Act of 1954, as amended), or naturally occurring radioactive material. 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. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 83 II.3.a.(4) Mixed transuranic waste: (a) Mixed transuranic waste meeting the requirements of the Waste Isolation Pilot Plant-Waste Acceptance Criteria shall be sent to the Waste Isolation Pilot Plant. (b) The Data Package prepared by the generators for the Waste Isolation Pilot Plant shall include information on the kinds and quantities of hazardous components contained in a waste package in accordance with applicable Resource Conservation and Recovery Act regulations. III.J. III.B.(1) III.I. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement. Instead, 435.1 has more requirements for all transuranic waste (not just mixed) to meet waste acceptance criteria for any waste management facility to which it is transferred. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met. Mixed Transuranic Waste. Transuranic waste determined to contain both a hazardous component subject to the Resource Conservation and Recovery Act (RCRA), as amended, and a radioactive component subject to the Atomic Energy Act of 1954, as amended, shall be managed in accordance with the requirements of RCRA and DOE O 435.1, Radioactive Waste Management, and this Manual. Waste Characterization. Transuranic 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 stabilization or absorbent media; (c) Weight of the container and contents; CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 84 II.3.a.(4) (cont.) Mixed transuranic waste: (cont.) (c) The determination whether the transuranic waste exhibits any hazardous characteristics or contains listed hazardous components may be based on knowledge of the waste generating process when the performance of a chemical analysis would significantly increase the radiation hazard to personnel. III.I. Waste Characterization. (cont) (e) Characterization date; (f) Generating source; (g) Packaging date; and (h) Any other information which may be needed to prepare and maintain the disposal facility performance assessment or demonstrate compliance with applicable performance objectives. Waste Characterization. Transuranic 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. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 85 II. 3.b.(1) Technical and administrative controls shall be directed to reducing the gross volume of waste generated and/or the amount of radioactivity requiring disposal. Transuranic waste reduction efforts shall be based on the implementation of techniques such as process modification, process optimization, materials substitution, decontamination, assay of suspect waste, and new technology development. Volume reduction techniques, such as incineration, compaction; extraction, and shredding, shall be implemented wherever cost effective and practical. Treatment facilities shall be permitted by the appropriate regulatory authority. I.1.E.(20) I.2.F.(3) III.L.(2) Order 4.b.(4) III.B.(1) 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. Field Element Managers. Field Element Managers are responsible for: Waste Minimization and Pollution Prevention. Ensuring implementation of waste minimization and pollution prevention programs. Transportation. To the extent practical, the volume of waste and number of transuranic waste shipments shall be minimized. Radioactive waste shall be managed to:

Comply with applicable Federal, State, and local laws and regulations. These activities shall also comply with applicable Executive Orders and other DOE directives. Mixed Transuranic Waste. Transuranic waste determined to contain both a hazardous component subject to the Resource Conservation and Recovery Act (RCRA), as amended, and a radioactive component subject to the Atomic Energy Act of 1954, as amended, shall be managed in accordance with the requirements of RCRA and DOE O 435.1, Radioactive Waste Management, and this Manual. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 86 II.3.b.(2) Transuranic waste shall be assayed or otherwise evaluated to determine the kinds and quantities of transuranic radionuclides present prior to storage. Additionally, hazardous waste components shall be estimated or analyzed, whichever is appropriate. III.I. Waste Characterization. Transuranic 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 stabilization or absorbent media; (c) Weight of the container and contents; (d) Identities, activities, and concentrations of major radionuclides; (e) Characterization date; (f) Generating source; (g) Packaging date; and (h) Any other information which may be needed to prepare and maintain the disposal facility performance assessment or demonstrate compliance with applicable performance objectives. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 87 II.3.b.(3) Mixed transuranic waste shall be treated, where feasible and practical, to destroy the hazardous waste component. III.O. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement. Passage of the Waste Isolation Pilot Plant Land Withdrawal Act, as amended, which authorizes disposal of untreated transuranic mixed waste at WIPP, makes this requirement obsolete. Instead, 435.1 requires treatment as necessary to comply with applicable requirements: Treatment. Transuranic waste shall be treated as necessary to meet the waste acceptance requirements of the facility receiving the waste for storage or disposal. II.3.b.(4) Transuranic waste that is classified for security reasons shall be treated to remove or destroy the classified characteristic(s) prior to certification. Declassification should be performed by the generator. I.2.F.(17) Field Element Managers. Field Element Managers are responsible for: Material and Waste Declassification for Waste Management. Ensuring, to the extent practical, radioactive material and waste generated under a program that is classified for national security reasons is declassified or rendered suitable for unclassified radioactive waste management.

CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 88 II.3.c.(1) Transuranic waste shall be certified, pursuant to the Waste Isolation Pilot Plant-Waste Acceptance Criteria, placed in interim storage, and sent to the Waste Isolation Pilot Plant when it becomes operational. III.H. III.J. III.P. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement. Instead, 435.1 requires that decisions to generate a waste include an evaluation waste management all of the way through disposal, that waste be certified as meeting the applicable waste acceptance requirements, and that transuranic waste be disposed in a facility that meets 40 CFR Part 191. With its approval of the WIPP Compliance Certification Application, EPA has agreed that WIPP meets 40 CFR Part 191. 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 transuranic waste streams. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met. (1) Certification Program. The waste certification program shall designate the officials who have the authority to certify and release waste for shipment; and specify what documentation is required for waste generation, characterization, shipment, and certification. The program shall provide requirements for auditability, retrievability, and storage of required documentation and specify the records retention period. (2) Certification Before Transfer. Transuranic waste shall be certified as meeting waste acceptance requirements before it is transferred to the facility receiving the waste. (3) Maintaining Certification. Transuranic waste that has been certified as meeting the waste acceptance requirements for transfer to a storage, treatment, or disposal facility shall be managed in a manner that maintains its certification status. Disposal. Transuranic waste shall be disposed in accordance with the requirements of 40 CFR Part 191, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 89 II.3.c.(2) Uncertified transuranic waste shall not be sent to the Waste Isolation Pilot Plant except by special permission granted in response to a formal, documented request to the Waste Isolation Pilot Plant-Waste Acceptance Criteria Certification Committee and the Waste Isolation Pilot Plant Waste Operations. III.J. III.K. III.G. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement. Instead, 435.1 includes generally applicable requirements for ensuring certification and addressing waste that does not meet waste acceptance requirements. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met.

(2) Certification Before Transfer. Transuranic waste shall be certified as meeting waste acceptance requirements before it is transferred to the facility receiving the waste. Waste Transfer. A documented process shall be established and implemented for transferring responsibility for management of transuranic waste and for ensuring availability of relevant data. The following requirements are in addition to those in Chapter I of this Manual. (1) Authorization. Transuranic waste shall not be transferred to a storage, treatment, or disposal facility until personnel responsible for the facility receiving the waste authorize the transfer. 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 transuranic waste storage, treatment, or disposal facilities, operations, and activities shall specify, at a minimum, the following: (e) The basis, procedures, and levels of authority required for granting exceptions to the waste acceptance requirements, which shall be contained in each facility’s waste acceptance documentation. Each exception request shall be documented, including its disposition as approved or not approved. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 90 II.3.c.(3) All transuranic waste certification sites shall prepare a certification plan which describes how the waste meets each waste acceptance criterion described in the WIPP-DOE-069. I.2.F.(7) III.J. There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement regarding complying with a specific document. Instead, 435.1 includes generally applicable requirements for waste certification. Field Element Managers. Field Element Managers are responsible for: Radioactive Waste Generator Requirements. Ensuring development, review, approval, and implementation of a program for waste generation planning, characterization, certification, and transfer. This program shall address characterization of waste, preparation of waste for transfer, certification that waste meets the receiving facility’s radioactive waste acceptance requirements, and transfer of waste. Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met. II.3.c.(4) Each certification plan shall define controls and other measures to ensure that each element of the certification plan is performed adequately as described. Requirements for these quality assurance activities are described in the WIPP-DOE-120 (see Attachment 1, page 2, paragraph 19). III.J. I.1.E.(12) There is not a corresponding 435.1 requirement that is as specific as the 5820.2A requirement regarding complying with a specific document. Instead, 435.1 includes generally applicable requirements for waste certification as well as quality assurance requirements and requirements for facilities to ensure waste meets their requirements. If waste acceptance requirements invoke a particular quality assurance document, it would have to be implemented as part of the certification program.

Waste Certification. A waste certification program shall be developed, documented, and implemented to ensure that the waste acceptance requirements of facilities receiving transuranic waste for storage, treatment, or disposal are met. 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. CROSSWALK OF TRANSURANIC WASTE REQUIREMENTS DOE 5820.2A vs. DOE O 435.1/M 435.1-1 5820.2A Citation 5820.2A REQUIREMENT 435.1-1 Citation 435.1-1 REQUIREMENT Attachment 1 - Technical Basis and Considerations Page 91 II.3.c.(5) Certification plans, including associated quality assurance plans, shall be submitted for review, comment, and approval by the Waste Isolation Pilot Plant-Waste Acceptance Criteria Certification Committee. III.J. III.G. III.K. There is not a corresponding 435.1 re