摘要: |
A recent accomplishment of the Idaho National Laboratory (INL) Materials and Fuels Complex (MFC) Nuclear Safety analysis group was to obtain DOE-ID approval for the inter-facility transfer of greater-than-Hazard-Category-3 quantity radioactive/fissionable waste in Department of Transportation (DOT) Type A drums at MFC. This accomplishment supported excellence in operations through safety analysis by better integrating nuclear safety requirements with waste requirements in the Transportation Safety Document (TSD); reducing container and transport costs; and making facility operations more efficient. The MFC TSD governs and controls the inter-facility transfer of greater-than-Hazard-Category-3 radioactive and/or fissionable materials in non-DOT approved containers. Previously, the TSD did not include the capability to transfer payloads of greater-than-Hazard-Category-3 radioactive and/or fissionable materials using DOT Type A drums. Previous practice was to package the waste materials to less-than-Hazard-Category-3 quantities when loading DOT Type A drums for transfer out of facilities to reduce facility waste accumulations. This practice allowed operations to proceed, but resulted in drums being loaded to less than the Waste Isolation Pilot Plant (WIPP) waste acceptance criteria (WAC) waste limits, which was not cost effective or operations friendly. An improved and revised safety analysis was used to gain DOE-ID approval for adding this container configuration to the MFC TSD safety basis.In the process of obtaining approval of the revised safety basis, safety analysis practices were used effectively to directly support excellence in operations. Several factors contributed to the success of MFC鈥檚 effort to obtain approval for the use of DOT Type A drums, including two practices that could help in future safety basis changes at other facilities. 1) The process of incorporating the DOT Type A drums into the TSD at MFC helped to better integrate nuclear safety requirements with waste requirements. MFC鈥檚 efforts illustrate that utilizing the requirements of other disciplines, beyond nuclear safety, can provide an efficient process. Analyzing current processes to find better ways of meeting the requirements of multiple disciplines within a safety basis can lead to a more cost-effective, streamlined process.2) Incorporating the DOT Type A drums into the MFC TSD was efficient because safety analysts utilized a transportation plan that provided analysis that could also be used for the change to the TSD addendum. In addition, because the plan they used had already been approved and was in use by the Idaho Cleanup Project (ICP) at the INL, justification for the change to the TSD was more compelling. MFC safety analysts proved that streamlining a process can be made more feasible by drawing from analysis that has already been completed. |