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DOE OSTI2020

Performance Assessment for the Environmental Restoration Disposal Facility (FY 2019 Annual Status Report)

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA), composite analysis, and disposal authorization statement (DAS) be annually, and it must consider the results of data collection and analysis from research, field studies, and monitoring as well as update any Radioactive Waste Management Basis documents. Beginning in 1996, the Environmental Restoration Disposal Facility (ERDF) has accepted low-level radioactive, hazardous, and mixed wastes that were generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells (currently 10) or disposal areas and can accommodate future design expansions as needed. During this reporting period (fiscal year 2019, October 1, 2018, to September 30, 2019). approximately 139,721 U.S. tons of waste was disposed at ERDF. From inception through September 30, 2019, ERDF has received approximately 18.5 million U.S. tons of waste, which equates to consumption of approximately 88% of the disposal volume. As a condition of the DAS, disposal operations within ERDF must be in accordance with the waste acceptance criteria (WAC) that provide specific radionuclide disposal limits, waste from restrictions, and descriptions of acceptable waste packages in compliance with DOE M 435-1.1 requirements. The ERDF WAC stipulates that waste destined for disposal at ERDF be controlled based on source, physical form, and containment concentration and activity levels

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DOE OSTI2022

Performance Assessment for the Environmental Restoration Disposal Facility (Annual Status Report FY 2021)

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA) (CP-60089), composite analysis (CA), and disposal authorization statement (DAS) be made on an annual basis, and that the determination must consider the results of data collection and analysis from research, field studies, and monitoring as well as the need to update any Radioactive Waste Management Basis (RWMB) documents. Beginning in 1996, the Environmental Disposal Facility (ERDF) started accepting low-level radioactive, hazardous, and mixed wastes that were generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells or disposal areas and can accommodate future design expansions as needed. Currently, there are eight cells and two supercells in ERDF. Each supercell is the equivalent of two cells. During this reporting period (fiscal year 2021, extending from October 1, 2020, through September 30, 2021), approximately 9.14E+04 metric tons (1.01E+05 U.S. tons) of waste was disposed at ERDF. From ERDF inception through September 30, 2021, approximately 16.9 million metric tons (18.9 U.S. tons) of waste has been disposed of at ERDF, which equates to consumption of approximately 88.7% of the currently constructed disposal volume. According to the design of ERDF, the facility has the ability to be expanded as needed. As a condition of the DAS, disposal operation within ERDF must be in accordance with the waste acceptance criteria (ERDF-00011) that provide specific radionuclide disposal limits, waste form restrictions, and descriptions of acceptable waste packages in compliance with the requirements of DOE M 435-1.1. The ERDF waste acceptance criteria stipulate that waste destined for disposal at ERDF be controlled based on source, physical form, and contaminant concentration and activity levels. There have been no changes to the physical configuration of ERDF or to the waste forms (source, physical form, etc.). No new unreviewed disposal question screenings or evaluations have been generated in this reporting period. Therefore, there are no noted impacts to the PA, CA, DAS, or RWMB resulting from the evaluations and screenings. Sum-of-fractions analysis shows that the disposed inventory meets both the concentration and inventory threshold requirements. A sum-of-fractions value is computed for ERDF sensitive radionuclides contributing to the all pathways and the air pathway inventory limits. Computed values were 7.63E-03 and 1.49E-03, respectively. The disposed waste inventory remained well under the PA imposed limits, as shown in Table 4 and Table 5 in the main text of this report. Required monitoring was satisfactorily completed during the fiscal year reporting period. Compliance with performance objectives were met as each of the reported values were well below the established limit. Overall, there are no substantive changes to primary PA assumptions or changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the DAS is maintained.

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DOE OSTI1978

An Assessment of the Nevada Test Site for Low-Level Waste Management

This report presents a summary of description information, facilities, and operating practices at the Nevada Test Site. It is concluded that NTS is not only a feasible location for surface and near-surface storage of low-level wastes, but also a potential site for underground storage of higher level wastes.

052002* -- Nuclear Fuels-- Waste Disposal & Storag↗
DOE OSTI2023

Performance Assessment for the Environmental Restoration Disposal Facility (Annual Status Report FY 2022)

DOE O 435.1 and DOE M 435.1-1 require that a determination of continued adequacy of the performance assessment (PA) (CP-60089), composite analysis (CA), and disposal authorization statement (DAS) be made on an annual basis, and that the determination must consider the results of data collection and analysis from research, field studies, and monitoring as well as the need to update any Radioactive Waste Management Basis (RWMB) documents. Beginning in 1996, the Environmental Restoration Disposal Facility (ERDF) started accepting low-level radioactive, hazardous, and mixed wastes that were generated during cleanup activities at the Hanford Site. ERDF is composed of a series of cells or disposal areas and can accommodate future design expansions as needed. Currently, there are eight cells and two supercells in ERDF. Each supercell is the equivalent of two cells. During this reporting period (fiscal year 2022, extending from October 1, 2021, through September 30, 2022), approximately 8.52E+04 metric tons (9.39E+04 U.S. tons) of waste was disposed at ERDF. From ERDF inception through September 30, 2022, approximately 17.0 million metric tons (18.7 million U.S. tons) of waste has been disposed at ERDF, which equates to consumption of approximately 89.1% of the currently constructed disposal volume. According to the design of ERDF, the facility has the ability to be expanded as needed. As a condition of the DAS, disposal operations within ERDF must be in accordance with the waste acceptance criteria (ERDF-00011) that provide specific radionuclide disposal limits, waste form restrictions, and descriptions of acceptable waste packages in compliance with the requirements of DOE M 435-1.1. The ERDF waste acceptance criteria stipulate that waste destined for disposal at ERDF be controlled based on source, physical form, and contaminant concentration and activity levels. There have been no changes to the physical configuration of ERDF or to the waste forms (source, physical form, etc.). No new unreviewed disposal question screenings or evaluations have been generated in this reporting period. Therefore, there are no noted impacts to the PA, CA, DAS, or RWMB resulting from the evaluations and screenings. Sum-of-fractions analysis shows that the disposed inventory meets both the concentration and inventory threshold requirements. A sum-of-fractions value is computed for ERDF sensitive radionuclides contributing to the groundwater pathways and the air pathway inventory limits. Computed values were 5.50E-04 and 3.30E-03, respectively. The disposed waste inventory remained well under the PA imposed limits, as shown in Table 4 and Table 5 in the main text of this report. Required monitoring was satisfactorily completed during the fiscal year reporting period. Compliance with performance objectives were met as each of the reported values were well below the established limit. Overall, there are no substantive changes to primary PA assumptions or changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the DAS is maintained.

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DOE OSTI2020

Panel Session 70: Nuclear Power Plant Waste Management, LLRW Processing Issues

This panel focused on senior utility managers discussing issues with commercial LLW processors. LLW processors had an opportunity to update utilities/NPPs on new or different services or technologies being offered to assist in their radioactive waste management goals, changes to their facility license, revisions to their acceptance guidelines, and emerging compliance issues. Panelists with presentations: UniTech - 'Expanding to Reduce Costs' LLW Processor Update (Gregg Johnstone); Veolia Nuclear Solutions Federal Services - Alaron Nuclear Services (Dave Garber); EnergySolutions Tennessee Processing Facilities (Fred Schulz); Complex Waste Management Issues Services and Treatment Facilities (George M. Taylor)

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DOE OSTI2021

OWL Change Control Process

The Online Waste Library (OWL) provides a consolidated source of information on Department of Energy-managed radioactive waste likely to require deep geologic disposal. With the release of OWL Version 1.0 in fiscal year 2019 (FY2019), much of the FY2020 work involved developing the OWL change control process and the OWL release process. These two processes (in draft form) were put into use for OWL Version 2.0, which was released in early FY2021. With the knowledge gained, the OWL team refined and documented the two processes in two separate reports. This report focuses on the change control process and discusses the following: (1) definitions and system components; (2) roles and responsibilities; (3) origin of changes; (4) the change control process including the Change List, Task List, activity categories, implementation examples, and checking and review; and (5) the role of the re lease process in ensuring changes in the Change List are incorporated into a public release.

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DOE OSTI2025

Graphite waste classification and disposal cost estimation for high temperature gas and salt reactors

As high-temperature reactor designs progress to demonstration, managing the radioactive wastes from these systems presents unique challenges. This work explores the irradiated graphite source term produced by three reactor designs: The Modular High Temperature Gas reactor (MHTGR), a pebble-bed High Temperature Gas Reactor (pb-HTGR), and a Fluoride-cooled High-temperature Reactor (FHR). We predicted a C-14 concentration of 4.3 Ci/m 3 for the MHTGR, 1.2 Ci/m 3 for the pebble bed HTGR, and 2.5 Ci/m 3 for the gFHR after 20 years of operation. The final C-14 concentration highly depended on the graphite nitrogen impurity, a major precursor for C-14. The C-14 concentration in all reactor types exceeded the 0.8 Ci/m3 threshold, resulting in a Class C waste classification. The costs associated with accepting the graphite after 20 years in a low-level waste disposal facility were projected to be 255 dollars per kWe for the MHTGR, 248 dollars per kWe for the pb-HTGR, and 56.8 dollars per kWe for the FHR.

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DOE OSTI2020

Special Analyses for the Hanford Integrated Disposal Facility Performance Assessment - 20102

In 2014, the Department of Energy (DOE) Office of River Protection and its contractors began to develop a performance assessment for the near-surface disposal of low-level and mixed low-level waste at the Hanford Site's Integrated Disposal Facility (IDF). The IDF is a doubly-lined landfill that was constructed between 2004 and 2006 to be the disposal facility for the vitrified low-activity waste that will be produced at the Waste Treatment and Immobilization Plant (WTP). IDF is also expected to receive solid secondary waste produced at the WTP and other solid wastes from site activities. The IDF has been in a preoperational state awaiting authorization from DOE and a RCRA permit modification from the State of Washington Department of Ecology to receive waste. Both the Disposal Authorization Statement and permit modification require a performance assessment demonstrating that the system of engineered and natural features will limit releases of radionuclides and hazardous chemicals from the IDF and be protective of human health and the environment. The simulated duration is 10,000 years. Based on the analyses presented in the 2017 Integrated Disposal Facility Performance Assessment, DOE issued a conditional Operating Disposal Authorization Statement for the IDF in June 2018. The long-term performance of the IDF to be protective of human health and the environment was evaluated under the requirements of DOE Order 435.1, Radioactive Waste Management. Computer simulations were performed to evaluate whether or not the IDF would comply with DOE requirements. In the time that has passed since the performance assessment was approved by DOE, new information has been discovered that had not been considered in the performance assessment. Since this new information has not been evaluated, the potential impact of the changes have not been taken into consideration in DoE's disposal authorization. DOE and its contractors follow a change control process to screen and, when necessary, evaluate new information that could potentially impact the conclusions of the completed performance assessment. This paper will describe the change control process and provide two examples of evaluations performed following the change control process. The first example evaluates a new waste form for liquid secondary waste that was not evaluated in the performance assessment. In the performance assessment, liquid secondary waste was assumed to be solidified with grout. A new recommendation to dispose of the liquid secondary waste after drying it to a powder was evaluated. The second example evaluates inventory implications from changes to the flow sheet that estimates the feed composition to the low-activity waste vitrification facility. The changes result in higher strontium concentrations in the vitrified waste stream. (authors)

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DOE OSTI2023

Performance Assessment for the Disposal of Low-Level Waste in the 200 West Area Burial Grounds (Annual Status Report FY 2022)

This annual review provides the projected dose estimates of radionuclide inventories disposed in the active 200 West Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-EP-0645). The estimates are compared with the performance objectives defined in U.S. Department of Energy requirements (DOE O 435.1 and its companion documents DOE M 435.1-1 and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063) and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 is expected. Within the active burial grounds, low-level and mixed low-level waste currently may be disposed only in two lined trenches in the 218-W-5 Burial Ground (Trenches 31 and 34) until they are either filled or a decision is made to close these trenches. Some mixed low-level waste is also disposed at the Environmental Restoration Disposal Facility in the 200 West Area (which is covered under a separate PA). During this (fiscal year 2022) reporting period (October 1, 2021, through September 30, 2022), waste was disposed to the 200 West Area LLBGs. Continued groundwater monitoring of the 200 West Area LLBGs indicates no groundwater contamination due to LLBG waste. Current assumptions about future land use at the Hanford Site are consistent with PA analysis assumptions of a postclosure facility that will not be degraded by human activity. The LLBGs are in an area identified for waste management and containment of residual contamination (DOE/EIS-0391). The current closure plan for the LLBGs (DOE/RL-2000-70) estimates that the 200 West LLBGs will be closed in the 2050 timeframe. The Disposal Authorization Statement, other technical basis documents, and the radioactive waste management basis are of continued adequacy to meet the performance objectives of DOE O 435.1. Overall, there are no substantive changes to primary PA assumptions and no changes to the PA analysis conclusion; therefore, compliance with DOE O 435.1 and the Disposal Authorization Statement is maintained. A new PA to evaluate the long-term impacts of three disposal trenches that are currently active within the 200 East and 200 West Areas (Trench 94 in the 200 East Area and Trenches 31 and 34 in the 200 West Area) was initiated in fiscal year 2019 and completed in fiscal year 2022. Corrective actions addressing 3 key issues and 31 secondary issues identified during the review process were developed and submitted to the Low-Level Waste Disposal Facility Federal Review Group Co-Chairs for review and approval. This PA provides additional technical basis for the continued adequacy of the existing Operating Disposal Authorization Statement.

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DOE OSTI2023

Performance Assessment for the E-Area Low Level Radioactive Waste Disposal Facility at the Savannah River Site: Chapter 1

This report documents the revised Performance Assessment (PA) analysis for the E-Area Low-Level Waste Facility (ELLWF) at the United States (U.S.) Department of Energy (DOE) Savannah River Site (SRS). A PA analysis is required for DOE-operated facilities that dispose of low-level radioactive waste. PA analyses simulate (1) the release of radionuclides from the disposal site after facility closure, (2) transport of those contaminants through the environment, and (3) exposure/impacts to potential receptors. The purpose of the PA analysis is to demonstrate that the facility is operated in a manner that ensures long-term environmental protection after facility closure, thereby providing for the protection of public health and safety in limiting doses to a hypothetical member of the public (MOP) or an inadvertent human intruder (IHI). DOE Manual (M) 435.1-1, Chg. 3, Radioactive Waste Management (U.S. DOE, 2021b) establishes quantitative post-closure environmental impact limits and requires a facility-specific PA analysis to demonstrate compliance with these limits for DOE low-level waste (LLW) disposed of after September 26, 1988. These limits are defined in terms of human health (e.g., dose limits) with respect to radioactive constituents in the waste.

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DOE OSTI2020

Panel Session 120: Roundtable: Waste Management - Energy Facilities Contractor Operating Group (EFCOG WM)

This Roundtable focused on the WM EFCOG working group as they met to discuss a variety of issues of importance to US DOE waste management operations. The purpose of the WM EFCOG is to seek out and promote the best management and operating practices, cost effective technologies and disposal options for all waste streams generated at US DOE facilities whether destined for US DOE or commercial facilities. Each site representative provided a radioactive waste management lessons learned briefing. Panelists with presentations: Savannah River Site (SRS) Solid Waste Program Update (Kerri Crawford); Idaho Clean-up Project Status (Frederick Hughes); West Valley Demonstration Project Update - EFCOG Waste Management Working Group (John Rendall); Key Project Challenges and Successes (Kalli Shupe); EFCOG WMWG Challenging Waste Subgroup Update (Tammy Monday); CH TRU Difficult Waste Stream Processing Challenges (Daniel Pancake); Argonne Building 350 Clean-up Success Using Effective Work Control (Daniel Dilday); Problematic Waste Streams on the Oak Ridge Reservation (John Wrapp)

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DOE OSTI2021

Annual Status Report (FY 2020): Performance Assessment for the Disposal of Low Level Waste in the 200 East Area Burial Grounds

This annual review provides the projected dose estimates of radionuclide inventories disposed in the 200 East Area Low-Level Waste Burial Grounds (LLBGs) since September 26, 1988. These estimates are calculated using the original dose methodology developed in the performance assessment (PA) analysis (WHC-SD-WM-TI-730). The estimates are compared with requirements of DOE O 435.1 Chg 1 and performance objectives defined in companion documents DOE M 435.1-1 Chg 1and DOE-STD-5002-2017). All performance objectives are currently satisfied, and operational waste acceptance criteria (HNF-EP-0063) and waste acceptance practices continue to be sufficient to maintain compliance with performance objectives. Inventory estimates and associated dose estimates from future waste disposal actions are unchanged from previous years’ evaluations that indicate potential impacts well below performance objectives; therefore, future compliance with DOE O 435.1 Chg 1 is expected. A new PA study was initiated in fiscal year (FY) 2019 for evaluation of active disposal sites within the 200 East and 200 West Areas (Trench 94 in 200 East; Trenches 31 and 34 in 200 West) due to extended time elapsing between the current annual status report and the original PA for the active disposal sites. The new PA for the active disposal sites is expected to be completed in FY 2021. Within the active burial grounds in the 200 East Area, low-level waste and mixed low-level waste will continue to be disposed of in the dedicated U.S. Navy reactor compartment trench at the 218-E-12B Burial Ground (Trench 94). During this reporting period (FY 2020, from October 1, 2019, through September 30, 2020), two reactor compartments were disposed in Trench 94. Results from sorption experiments are summarized for this reporting period to quantify the efficacy of concrete waste forms in retaining key radionuclides (e.g., technetium-99 and iodine-129). The test durations ranged from 1 to 3 months. Continued groundwater monitoring of the 200 East Area LLBGs indicates no groundwater contamination due to LLBG waste. Current assumptions about future land use at the Hanford Site are consistent with PA analysis1 assumptions of a post-closure facility that will not be degraded by human activity. The LLBGs are located in an area identified for waste management and containment of residual contamination. This area will remain after final environmental remediation and the proposed shrinkage of Hanford Site boundaries to small sections within the 200 East and 200 West Areas in the Central Plateau (DOE/EIS-0391). The current closure plan for the LLBGs (DOE/RL-2000-707) estimates that the 200 East LLBGs will be closed in the 2050 timeframe. The Disposal Authorization Statement, other technical basis documents, and the radioactive waste management basis are of continued adequacy to meet the performance objectives of DOE O 435.1 Chg 1. Overall, there are no substantive changes to primary PA assumptions nor the PA analysis conclusion; therefore, compliance with DOE O 435.1 Chg 1 and the Disposal Authorization Statement is maintained.

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DOE OSTI2024

Presentation on the INL Remote-Handled Low-Level Waste Disposal Facility FY-2023 Annual Summary Report

The abstract below is from the report INL/RPT-24-76103. The powerpoint presentation contains information taken from the report. This Fiscal Year (FY) 2023 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA) and associated operating disposal-authorization statement (ODAS) technical basis documents for the Remote Handled (RH) Low-Level Waste (LLW) Disposal Facility at Idaho National Laboratory. Annual review of the adequacy of the PA and CA for the RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2023, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility closure design, or institutional controls. Sixteen total waste-canister shipments were received at the RHLLW Disposal Facility, and 15 total waste canisters were emplaced.

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DOE OSTI2020

An Overview of R and D on Retrievability and Retrieval Technology in Germany - 20462

Retrievability is a term that is included in most radioactive waste management programs around the world. Although national definitions vary, the overall understanding of retrievability concerns the ability to recover waste packages from the repository mine after their emplacement. Different countries may implement retrievability in very different ways, ranging from a built-in reversibility into the emplacement process to the stipulation that retrievability may in no way impede passive safety in the post-closure phase. Germany takes a middle course such that retrievability in a HLW repository (repository for high level radioactive waste) may have no significant detrimental effect on passive safety. In Germany, the current siting process considers rock salt, clay rock, and crystalline rock as potential host rocks. Therefore, Research and Development (R and D) has been investigating repository concepts and retrievability in all host rocks. After introduction of retrievability in 2010, existing repository concepts were modified to facilitate retrieval. The changes made comprised, for example, equipping boreholes with steel liners, developing new technologies, and modifying existing emplacement devices. Apart from retrieval of HLW, retrieval of other wastes from underground repositories that were designed and operated without retrievability in mind, poses major technical and scientific challenges. Currently, studies are under way to investigate the feasibility and costs of partial retrieval of waste from an underground repository for hazardous and highly toxic waste in France, Stocamine. With regard to retrieval, the rock-mechanical conditions are deteriorating rapidly, so time is of the essence. In the Asse II mine in Germany, about 126,500 waste casks with low and intermediate level waste await retrieval. The repository mine suffers from difficult rock-mechanical conditions and inflow of brine, locally into emplacement areas. The Federal Company for Radioactive Waste Disposal (BGE) is legally required to retrieve all wastes from the Asse. Due to the specific challenges, R and D is needed to develop technical solutions for the safe retrieval from each of the emplacement chambers. R and D on retrievability and retrieval technology does not only address challenges in radioactive or toxic waste retrieval but may also help to germinate innovation to better master complex underground situations in general, e.g. in deep mining, tunneling, or repository construction. (authors)

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DOE OSTI2025

Presentation on the INL Remote-Handled Low-Level Waste Disposal Facility FY-2024 Annual Summary Report

The abstract below is from the report INL/RPT-24-82600. The powerpoint presentation contains information taken from the report. This Fiscal Year (FY) 2024 annual summary report (ASR) documents the continued adequacy of the performance assessment (PA), the composite analysis (CA), and associated operating disposal authorization statement (ODAS) technical basis documents for the Remote Handled Low Level Waste (RHLLW) Disposal Facility at Idaho National Laboratory (INL). Annual review of the adequacy of the PA and CA for RHLLW Disposal Facility ensures that conclusions of the analyses remain valid in accordance with requirements of the U.S. Department of Energy (DOE) Order 435.1, “Radioactive Waste Management.” In FY 2024, no significant operational changes or other activities occurred that would cause deviation from the assumptions in the PA and CA pertaining to disposal geometry, verification of waste characteristics, tracking disposal inventories against total limits, facility closure design, or institutional controls. Nineteen waste canister shipments were received at the RHLLW Disposal Facility, and all nineteen waste canisters were emplaced in disposal vaults.

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DOE OSTI2020

FY 2020 Radionuclide Migration Project Status

The Waste Management Project provides safe, compliant, and cost-effective waste management services for the Hanford Site and the U.S. Department of Energy (DOE) complex. Part of these services includes safe disposal of low-level waste and mixed low-level waste at the Hanford Low-Level Waste Burial Grounds in accordance with the requirements of DOE Order 435.1, Radioactive Waste Management. To partially satisfy these requirements, performance assessment analyses were completed and approved. DOE Order 435.1 also requires continuing data collection to increase confidence in the critical assumptions used in these analyses to characterize the operational features of the disposal facility that are relied on to satisfy the performance objectives identified in the order.

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DOE OSTI2026

Annual Summary Report (FY 2025) Performance Assessment for the Integrated Disposal Facility

The purpose of this Annual Summary Report (ASR) for fiscal year (FY) 2025 is to evaluate the continued adequacy of the Integrated Disposal Facility (IDF) Performance Assessment (PA) and Disposal Authorization Statement (DAS). This report consolidates relevant monitoring data, modeling analyses, and regulatory reviews to demonstrate a reasonable expectation that the PA objectives and performance measures will be met, as required under DOE O 435.1, Radioactive Waste Management. The ASR follows the guidance in DOE-STD-5002-2017, Disposal Authorization Statement and Tank Closure Documentation, which provides a framework for maintaining the validity of the DAS through periodic assessment of facility performance and compliance with waste disposal requirements.

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