DOE ORDER 435.1, IMPLEMENTATION AND COMPLIANCE DECLARATION AT THE SAVANNAH RIVER SITE AND ACROSS THE DOE COMPLEX IN CONTRAST TO CURRENT PUSHBACK EFFORTS FROM THE ''TOP-TO-BOTTOM'' REVIEW

DOE issued Order 435.1, ''Radioactive Waste Management,'' on July 9, 1999 for immediate implementation. The requirements for Low Level Mixed, Transuranic, and High Level Waste have been completely rewritten. The entire DOE complex has been struggling with how to implement these new requirements within the one year required timeframe. This paper will chronicle the implementation strategy and actual results of the work to carry out that strategy at the Savannah River Site. DOE-SR and the site contractors worked closely together to implement each of the new requirements across the SRS, crossing many barriers and providing innovative solutions to the many problems that surfaced throughout the year. The results are that SRS declared compliance with all of the requirements of the Order within the prescribed timeframe. The challenge included all waste types in SRS facilities and programs that handle LLW, MLLW, TRU, and HLW. This paper will describe the implementation details for development of Radioactive Waste Management Basis for each facility, Identification of Wastes with No Path to Disposal, Waste Incidental to Reprocessing Determinations, Low Level Waste 90-Day Staging and One Year Limits for Storage Programs, to name a few of the requirements that were addressed by the SRS 435.1 Implementation Team. This paper will trace the implementation, problems (both technical and administrative), and the current pushback efforts associated with the DOE ''Top-to-Bottom'' review