SRNS Improperly Destroyed Necessary Waste Canister Records
WC Monitor
2/6/2015
Savannah River Nuclear Solutions, the managing contractor for the Savannah River Site, improperly destroyed thousands of records last year that are required to send canisters of vitrified high-level waste from the site to an eventual repository, according to a Department of Energy occurrence report. SRNS destroyed the hundreds of boxes of documents during an effort to clear up space by getting rid of hard copies of permanent records that also had electronic copies. “Poor execution of site procedures and federal requirements used to protect production records resulted in destruction of 17,000 total records including supporting documentation,” according to DOE’s FY’14 award fee scorecard for SRNS released last month.
While the boxes of Defense Waste Processing Facility Canister Waste Acceptance hardcopy documents did have electronic copies, the original production records are required to be presented to DOE’s Office of Environmental Management when waste canisters are sent to a repository and are “not to be destroyed,” according to the occurrence report. Savannah River’s Defense Waste Processing Facility processes high-level tank waste at the site into vitrified glass canisters. Those canisters are being stored on site for now, but once a repository for defense waste is established they will be slated for shipment there for disposal. In total, 285 out of 312 DWPF record boxes had been destroyed, according to the report.
The contractor has since reprinted the hard copies from the electronic versions, according to SRNS spokeswoman Barbara Smoak. “Electronic record copies of the hard copy records had been made and were available through the Electronic Records system. The canister production records have since been reproduced from the electronic copies,” Smoak said in a statement. “A Corrective Actions plan was developed and formal corrective actions were completed with QA verification in November of 2014. DOE-SR completed a review and concurred with all corrective actions.” Smoak added: “The records are currently being verified and the expectation is that the results will support ultimate disposal of the canisters in a future repository.”
Records Destroyed Last April
The DWPF records were found to be improperly destroyed in April 2014. The issue occurred during a cleanup effort in which other backed-up documents were properly disposed of. SRNS asked DOE Savannah River’s records officer if it could destroy permanent records of materials if there were electronic copies in the Electronic Document Workflow System. “With the written approval to destroy hardcopy permanent boxes from Solid Waste and the verbal approval from DOE-SR for other permanent records (even though the restriction remained for DWPF boxes and others), there was a change in the organization’s mindset restricting destruction of any boxes marked with the circle P, denoting permanent hardcopy,” according to the occurrence report.
DOE Analysis Pointed to Several Causes
DOE’s analysis team found several causes for the incident. One was a lack of proper management instruction, as not all records management personnel understood that the “circle P” mark on the boxes denoted permanent copies not to be destroyed. Several corrective actions for this are underway. Management “will develop a list of records that are currently known as required to be kept as hardcopies. This list will be posted in all Records Management Facilities where these records are stored. Training on this list will be provided to [records management personnel,” the report states.
The analysis also found a “lack of robust barriers” to prevent destruction of records. Records management is to establish checks and balances to verify records that are to be pulled and destroyed. Additionally, there was a “lack of formal, written processes regarding records destruction.” The report notes, “Destruction of permanent and nonpermanent records has been sanctioned by DOE-SR and used by [records management personnel] for years in order to comply with records retention requirements and to reduce the total volume of records being stored and maintained. However, the management expectations and the processes used by RMP for destroying hard copy records have not been proceduralized.”