INCINERATION OF LOW-LEVEL RADIOACTIVE
            AND MIXED WASTES:

WASTE HANDLING AND OPERATIONAL ISSUES
                 Prepared for
        Office of Radiation and Indoor Air
       U.S. Environmental Protection Agency
              401 M Street, S.W.
            Washington, DC 20460
               Under Contracts
          68-D9-0170 and 68-DO-0102
m


^
 1-

*
t
r
April 1993

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                             ACKNOWLEDGEMENTS
This document was prepared for EPA's Office of Radiation and Indoor Air (ORIA)
through Work Assignments issued under contracts 68-D9-0170 and 68-DO-0102.

ORIA wishes to thank the following individuals for their technical assistance and review
comments on drafts of this report:

Bange, Marilyn S., Branch Chief.  U.S. Department of Energy, Waste Management
      Branch, Waste Management and Operational Surety Division, Albuquerque Field
      Office.

Bromm, Susan, Director.  U.S. Environmental Protection Agency, RCRA Enforcement
      Division, Office of Waste, Programs Enforcement.

Brunner, Calvin R., P.E., D.E.E., President. Incinerator Consultants Incorporated,
      Reston, Virginia.

Chow, Emily.  U.S. Environmental Protection Agency, Training and Guidance Section,
      RCRA Enforcement Division, Office of Waste Programs Enforcement.

Gale, L.G. EG&G,  Idaho  Waste Management Facility Projects Unit.

Halper, Martin P., Director. U.S.  Environmental Protection Agency, Radiation Studies
       Division, Office of Radiation  and Indoor Air.

Hutchins, David A. Atfartin Marietta Energy Systems, Inc., Central Waste Management
       Division, Oak Ridge, Tennessee.

 Kelly, Kathryn E., Dr. P.H., President. Environmental Toxicology International, Inc.,
        Seattle, Wastjington.

 Langford, J.E. EG&G, Idaho Waste Management Facility Projects Unit.

 O'Rear, Michaelfj., Director.  U.S.  Department of Energy, Solid Waste Division, Field
        Office, Savannah  River.

 Orlando, Domin|k  NRC, Decommissioning and Regulatory Issues Branch, Division of
        Low-Level Waste Management and Decommissioning.

 Rosnick, Reid. U.S. Environmental Protection Agency, Office of  Solid Waste.

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                      ACKNOWLEDGEMENTS (Continued)


Thurman, Robert C., Acting Chief. U.S. Environmental Protection Agency, Office of
      Research and Development, Risk Reduction Engineering Laboratory, Thermal
      Destruction Branch, Waste Minimization, Destruction, and Disposal Research
      Division.

Zygmunt, Stanley, section leader EM-7, Los Alamos National Laboratory, Los Alamos,
      New Mexico.

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                              EXECUTIVE SUMMARY

As part of a major effort to bring its facilities into compliance with environmental
regulations, the U.S. Department of Energy (DOE) is investigating options for managing
low-level radioactive and mixed waste (LLR/MW). The U.S. Environmental Protection
Agency (EPA), Office of Radiation and Indoor Air, in collaboration with DOE, Office of
Environmental Restoration, is assessing incineration as a treatment alternative for
LLR/MW produced during the  remediation/restoration of contaminated sites.  The
overall purpose of this examination is to identify and evaluate the fundamental technical
and operational issues associated with the effective, economical, and safe use of
incineration for treating both the hazardous and  radioactive constituents of these wastes,
while minimizing potential risks to human health, welfare, and the environment.

This document represents one component of this effort, focusing on technological and
operational issues associated with incineration. Other components of the EPA and DOE
effort focus on regulation and policy issues surrounding incineration, waste inventories
and incinerator capacity, comparative risks associated with incineration and other
treatment technologies, and the feasibility of innovative emission control technologies.

This report presents the results of a survey of DOE and commercial incinerators
currently operating or "on stand-by" that may play a role in the treatment of low-level
and mixed wastes from  remediation and restoration activities. Using this information, the
report identifies and discusses current operational and technological issues
                                         m

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                             TABLE OF CONTENTS

 1.  INTRODUCTION	  M

 2.  BACKGROUND  	                 2-1
       2.1   DOE WASTE MANAGEMENT	  2-1
            2.1.1  DOE Sites and Wastes	  2-1
            2.1.2  DOE's Waste Management Strategy  	  2-3
            2.1.3  The Role of Incineration	                2-4
       2.2   REGULATORY CONTEXT	'.'.'.'.'.'.'.'.  2-6
            2.2.1  Hazardous Waste  	  2-6
            2.2.2  Radioactive Waste	 . . . .  2-7
            2.2.3  Mixed Waste	'.'.'.'.'.'.'.'.'.'.'.  2-8

 3.  DESCRIPTION OF INCINERATOR OPERATIONS	         3.1
       3.1   OVERVIEW OF EXISTING INCINERATION SYSTEMS	.. .  3-1
            3.1.1  General Description of Incinerator Operations	  3-1
            3.1.2  Identity and Status of LLR/MW Incinerators	  3-2
            3.1.3  Schematic Presentation of the Various Units       '            3.4
       3.2   WASTE HANDLING	            	  3.5
       3.3   WASTE ACCEPTANCE CRITERIA  	!	  3.7
       3.4   CURRENTLY OPERATING OR "ON STAND-BY"
            INCINERATORS	3_10
            3.4.1  TSCA Incinerator	3_10
            3.4.2  Scientific Ecology Group (SEG) Incinerator	3-14
            3.4.3  Diversified Scientific Services, Inc. (DSSI) Cogeneration
                  Boiler	3_16
            3.4.4  Waste Experimental Reduction Facility (WERF) Incinerator  . . 3-18
            3.4.5  Controlled Air Incinerator (CAI)	3-23
            3.4.6  Mound Glass Melter	3_24
            3.4.7  Consolidated Incineration  Facility  	       3-25
      3.5   WASTE AND RESIDUAL MANAGEMENT	'.'.'.'.'.'.'.'.'. 3-27

4.  SUMMARY AND DISCUSSION OF ISSUES  	                   4_1
      4.1    OPERATIONAL ISSUES	'.'.'.'.'.'.'.'.'.'.'.'.  4-1
            4.1.1  Permitting Process Complexities  . . .	  4-1
            4.1.2  Cost-Effectiveness of Public vs. Private Incinerators	  4-2
            4.1.3  Waste Manifesting Practices 	  4_2
            4.1.3  Risk Assessment and Communication 	  4-2
                                     IV

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                      TABLE OF CONTENTS (Continued)

      4.2    TECHNICAL ISSUES	  4-3
            4.2.1   High-Efficiency Particulate Air Filters		  4-3
            4.2.2   Emissions Monitoring and Process Measurement	  4-4
            4.2.3   Residuals Management	  4-6
            4.2.4   Systematic Measurement of Metals and Radionuclide
                  Partitioning	  4-6
      4.3    CONCLUSION	 .	  4-7

REFERENCES	R-l

APPENDIX A     Incinerator Survey Forms	A-l
APPENDIX B     Excerpts from  DOE Order 5820.2A	 B-l
APPENDIX C     Schematics and Flow Diagrams of Selected Incinerator
                  Systems	 C-l
APPENDIX D     Chemicals Approved for Incineration at DSSI  	D-l
APPENDIX E     Proposed Mixed Waste Acceptance Criteria for WERF
                  Incinerator	E-l
APPENDIX F     Radionuclide Inventory Determination - GIF Tank Farm	 F-l
APPENDIX G     Chemical Inventory Determination - GIF	G-l

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                                LIST OF EXHIBITS

Exhibit

2-1    DOE Guidelines for Waste Acceptance Criteria	  2-5

3-1    US Radioactive and Mixed Waste Incinerators	  3-3

3-2    Simplified Block-Flow Diagram  	  3-6

3-3    Waste Stream/Incinerator Compatability Matrix 	  3-7

3-4    Acceptable Feeds for Radioactive and Mixed Waste Incinerators  	  3-8

3-5    Physical Characteristics of Waste Streams for K-25 TSCA Incinerators	3-11

3-6    Metals Contamination Limits for TSCA Incinerator Wastes  	3-13

3-7    Required Lower Limits of Detection (LLD) for Radionuclides in TSCA
       Incinerator Wastes	3-14

3-8    SEG General Waste Acceptance Criteria	3-16

3-9    SEG Waste Acceptable Limits for Contaminated Oil  	3-17

3-10   Allowable Quantities of Radioisotopes at DSSI	3-19

3-11   Package Specifications for WERF Low-Level Waste Feed  	3-20

3-12   WERF Incinerator Feeds Specified in Air Quality Permit to Construct	3-22

3-13   Sample Fissible Material Calculation -  GIF	3-26
                                        VI

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                                  ACRONYMS
AEA
ANL
APC
BDAT
BGI
BIF
CAA
CA
CAI
CEM
CFR
GIF
DAW
DHEC
DOD
DOE
DOT
ORE
DSSI
DWPF
DWTF
EA
EIS
EPA
ER
FBU
FFCA
FRP
FTIR
GC
GC-MS
HAZWRAP
HC
HEPA
HSWA
HWMF
HWT&P
ICRP
ID
IDLH
INEL
Atomic Energy Act of 1954
Argonne National Laboratory
Air Pollution Control
Best Demonstrated Available Technology
Beta/Gamma Incinerator
Boiler and Industrial Furnace
Clean Air Act (1991)
Controlled Air (at LLNL)
Controlled Air Incinerator (at LANL)
Continuous Emission Monitor(ing)
Code of Federal Regulations
Consolidated Incineration Facility (at SRS)
Dry Active Waste (DOE)
Department of Health and Environmental Control (South Carolina)
U.S. Department of Defense
U.S. Department of Energy
U.S. Department of Transportation
Destruction Removal Efficiency (RCRA)
Diversified Scientific Services, Inc.
Defense Waste Processing Facility
Decontamination and Waste Treatment Facility
Environmental Assessment
Environmental Impact Statement
U.S. Environmental Protection Agency
Environmental Restoration
Fluidized Bed Unit (at RFP)
Federal Facilities Compliance Act of 1992
Fiber Reinforced Plastic
Fourier Transform Infrared (spectroscopy)
Gas Chromatograph(y)
Gas Chromatograph/Mass Spectrograph
Hazardous Waste Remediation Action Program
Hydrocarbons
High-Efficiency Particulate Air (filter)
Hazardous and Solid Waste Amendments  of 1984
Hazardous Waste Management Facility
Hazardous Waste Treatment and Processing
International Commission on Radiological Protection
Induced Draft (fan)
Immediately Dangerous  to Life and Health
Idaho National Engineering Laboratory
                                      vn

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                            ACRONYMS (Continued)
 INPO

 K-25

 IWPF
 LANL
 LDR
 LHNF
 LLD
 LLNL
 LLR/MW
 LLW
 MFC
 MW

 MWSF
 MWTP
 NDIR
 NESHAPS
 NOD
 NPDES
 NRC
 NRHW
 ORIA
 ORD
 ORNL
 ORP
 OSHA
 OSWER
 OTA
 PCB
 PIC
 POHC
 PREPP
 PTC
 PVC
 QA/QC
 RCRA
 RFP
 RMI
SCC
SEG
 (Incinerator operator training program referenced by Scientific
 Ecology Group, SEG)
 Area at DOE's Oak Ridge Plant which contains former Gas
 Diffusion Plant
 Idaho Waste Processing Facility
 Los Alamos National Laboratory
 Land Disposal Restriction
 Low-hazard Nuclear Facility
 Lower Limits of Detection
 Lawrence Livermore National Laboratory
 Low-level Radioactive and Mixed Waste
 Low-level (radioactive) Waste
 Maximum Permissible Concentrations
 Mixed Waste (mixture of low-level radioactive and hazardous
 wastes)
 Mixed Waste Storage Facility
 Mixed Waste Treatment Project
 Nondispersive Infrared
 National Emissions Standards for Hazardous Air Pollutants (CAA)
 Notice Of Deficiency
 National Pollutant Discharge Effluent Standards (CWA)
 Nuclear Regulatory Commission
 Non-Radioactive Hazardous Waste
 Office of Radiation and Indoor Air (EPA)
 Office of Research and Development (EPA)
 Oak Ridge National Laboratory
 Office of Radiation Protection
 Occupational Safety and Health Administration
 Office of Solid Waste & Emergency Response (EPA)
 Office of Technology Assessment
 Polychlorinated Biphenyl
 Products of Incomplete Combustion (RCRA/HSWA)
 Principal Organic Hazardous Constituent  (RCRA/HSWA)
 Process Experimental Pilot Plant (at INEL)
 Permit To Construct
 Polyvinyl Chloride
 Quality Assurance/Quality Control
 Resource Conservation and Recovery Act
 Rocky Flats Plant
 Reactive Metal Inc. (former Ohio site of DOE sub-contractor)
Secondary Combustion Chamber
Scientific Ecology Group
                                      Vlll

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SRS
SWDA
TCC
TCLP
TFE
THC
TRU
TSCA
UV
WAC
WERF
WMIS
WROC
WWSB
Y-12
          ACRONYMS (Continued)

Savannah River Site
Solid Waste Disposal Act of 1965
Tertiary Combustion Chamber
Toxicity Characteristic Leaching Procedure (40 CFR 261)
Tetrafluoroethylene (Teflon)
Total Hydrocarbons
Transuranic
Toxic Substances Control Act
Ultra-violet
Waste Acceptance Criteria (DOE Order)
Waste Experimental Reduction Facility (at INEL)
DOE Waste Management Information System
Waste Reduction Operation Complex
WERF Waste Storage Building
Area at DOE's Oak Ridge Plant
                                      IX

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                                1.  INTRODUCTION

In 1989, the U.S. Department of Energy (DOE) launched a major effort to bring its
facilities into compliance with environmental regulations.  The effort includes both
remediation of existing contamination and the proper management of wastes from
current operations. Both activities produce low-level radioactive and mixed wastes
(LLR/MW) requiring treatment and disposal.

Incineration is an important component of DOE's strategy for managing LLR/MW from
these facilities.  The U.S. Environmental Protection Agency (EPA), Office of Radiation
and Indoor Air (ORIA), in collaboration with DOE, Office of Environmental
Restoration, has initiated a study of the incineration of LLR/MW. The overall goal of
this joint study  is to identify possible improvements in the process of incinerating
LLR/MW.

This document, one in a series of reports addressing incineration of LLR/MW at DOE
facilities, focuses primarily on technological and operational issues.  Specifically, it
presents the results of a survey of existing  DOE radioactive and mked waste incinerators
and two commercial incinerators handling  DOE wastes.  The purpose of the survey was
to collect data on current treatment systems, waste handling and acceptance criteria, and
operational shortcomings and program issues relevant to the use of these incinerators for
processing LLR/MW. The survey entailed a literature review, visits to selected locations,
and telephone interviews with key personnel.  A form was developed to provide a vehicle
for obtaining and maintaining information  developed in the course of the survey. The
model form and individual facility surveys are included in Appendk A.

While this report focuses primarily on technological and operational issues, these issues
must be considered in the context of current waste management programs and associated
regulations. For this reason, Section 2 provides a summary of DOE's waste management
programs and the associated regulatory environment. Section 2.1 gives an overview of
waste management at DOE, including DOE's waste management strategy and the role of
incineration in that strategy.  Section 2.2 describes the regulations applicable to the
management of LLR/MW.  Section 3.0 describes LLR/MW incinerator operations; it
provides a general description of typical operations at a LLR/MW incinerator, an
overview of existing incineration systems, and descriptions of waste handling, waste
acceptance criteria, and  currently operating incinerators.  Section 4.0 identifies and
discusses current issues associated with the use of incineration in waste management.
                                        1-1

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                                  2.  BACKGROUND

 To provide context for the technological and operational issues discussed in later
 sections, this section  presents background information on DOE's waste management
 programs and  the associated regulatory environment.

 2.1    DOE WASTE MANAGEMENT

 Proper management  of DOE's LLR/MW is a very complex task.  There is a large
 number of diverse  sites that generate and handle DOE's wastes. Additionally, the wastes
 themselves are highly varied and subject to a broad array of regulatory requirements.

 2.1.1  DOE Sites and Wastes

 DOE is responsible for waste management and cleanup at over 100 contaminated
 facilities in 36  States  and territories.1  These facilities include national laboratories and
 nuclear weapons production and testing facilities. The extent of contamination at the
 facilities varies widely, from limited contamination in laboratories to contamination
 throughout large processing plants and surrounding lands.  Several DOE facilities have
 literally hundreds of areas of contamination that are being investigated and cleaned up
 separately.  For example, DOE's Hanford facility, which encompasses 570 square miles, is
 divided into about  1,100 individual waste sites containing radioactive and/or hazardous '
 materials.  These sites range in size from 1 square foot to 1,800 acres and have been
 grouped into 78 operable units based on their waste characteristics or other factors.

 These sites may contain hazardous wastes, radioactive wastes, and/or mixed wastes.
 Hazardous waste is regulated under the Resource Conservation and Recovery Act
 (RCRA), as amended, and radioactive waste is regulated under the Atomic Energy Act
 (AEA), as amended.   Mixed wastes contain both hazardous components regulated
 under RCRA and radioactive components regulated under AEA.

 Hazardous Waste

 In developing RCRA, Congress established a two-pronged approach for determining
whether a waste is hazardous and therefore subject to RCRA jurisdiction.  Under Section
 1004 of RCRA, Congress indicated that, before a material can be considered a hazardous
waste, it must first meet the definition  of a solid waste. In the RCRA regulations, EPA
defines a solid  waste as a material that  is abandoned, recycled, or considered inherently
waste-like (40 CFR 261.2).  Incinerator ash or by-products that contain toxic constituents,
for example, would qualify as a solid waste if they are destined for disposal or considered
inherently waste-like (e.g., if they contain toxic constituents identified  in §261.2(d)).
    U.S. Department of Energy, Environmental Restoration and Waste Management Five-Year Plan- Fiscal Years
 1998. January, 1993, p. 1-8.                     "               	:	

   2 See Federal Facility Compliance Act (FFCA), Section 3021 (b).

                                        2-1

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Once a material is determined to be a solid waste, it may then be characterized as a
hazardous waste. A solid waste is a RCRA hazardous waste if it meets at least one of
two conditions:  (1) the waste is specifically "listed" in 40 CFR Part 261, Subpart D, or
(2) the waste exhibits one of the four characteristics identified in 40 CFR Part 261,
Subpart C. These characteristics  are toxicity, corrosivity, ignitability, and reactivity.
Incinerator ash or by-product would qualify as a hazardous waste, for example, if it
exhibited the characteristic of toxicity?

Radioactive Waste

AEA has established authority over the following radioactive materials:

       •      Source material: defined as uranium, thorium, or any other material that is
              determined pursuant to provisions of AEA to be source material, as well as
              ores containing one or more of these materials in such concentrations as
              may be determined;

       •      Special nuclear material: defined as (1) plutonium, uranium enriched in
              the 233 isotope or in the 235 isotope, and any other  material that is
              determined pursuant to AEA to be special nuclear material but which does
              not include source material;  or (2) any material that  is artificially enriched
              in any of the above, but which does not include source material; and

       •      Byproduct Material:  defined as (1) any radioactive material (except special
              nuclear material) yielded in,  or made radioactive by exposure to, the
              radiation incident to the process of producing or utilizing special nuclear
              material; and (2) the tailings or wastes produced by the extraction or
              concentration of uranium or thorium from any ore processed primarily for
              its source material content.

There are also several subclasses of radioactive waste that contain AEA materials.  These
include:

       •      High-level waste: The highly radioactive waste material that results from
              the reprocessing of spent nuclear fuel, including liquid waste produced
              directly in reprocessing and any solid waste derived from the liquid, that
              contains a combination of transuranic waste and fission products in
              concentrations requiring permanent isolation;
   3 40 CFR 261.3(b) specifies that a solid waste that is mixed with a listed hazardous waste, or is mixed with any material
and exhibits a characteristic, is a hazardous waste, except under certain conditions. 40 CFR 261.3(c) specifies that a solid
waste derived from treatment, storage, or disposal of a hazardous waste is a hazardous waste, except where certain criteria
are met. This is particularly relevant to incinerator ash.  If the incinerator ash results from the incineration of a listed
hazardous waste that is not excluded under §260.20 and 260.22, for example, the ash would be a RCRA hazardous waste.
However, materials that are reclaimed from solid waste and used beneficially are not solid waste unless burned for energy
recovery or used in a manner constituting disposal.

                                            2-2

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       •      Transuranic (TRU) waste:  Waste that is contaminated with alpha-emitting
              transuranium nuclides with half-lives greater than 20 years and
              concentrations greater than 100 nanocuries per gram of waste at the time
              of assay without regard to source or form; and

       •      Low-level waste  (LLW):  Radioactive waste not classified as high-level
              waste, transuranic waste, spent nuclear fuel, or certain byproduct
              material.

Mixed Waste

Mixed waste is radioactive waste also listed as hazardous or exhibiting a hazardous
characteristic under the RCRA Subtitle C program.  The radioactive component of
mixed waste is  source, special  nuclear, or byproduct materials as defined by AEA, which
are excluded from regulation under RCRA.

2.1.2  DOE's Waste Management  Strategy

DOE is involved in a major effort to bring Department activities into compliance with
applicable environmental requirements.  The effort involves two major programs:
Environmental  Restoration (ER) and Waste Operations (WO).5  Both ER and WO
produce and manage LLR/MW. The  ER program assesses and remediates facilities
contaminated with radioactive, hazardous and mixed  wastes generated by past DOE
nuclear operations.  Most remediation involves contaminated soil or groundwater, and
may produce large volumes of contaminated media requiring treatment and disposal.

The goal of DOE's WO program is the safe management and disposal of wastes
generated by current DOE operations. Another important objective of the WO program
is waste minimization, or reductions in the volume and toxicity of DOE's hazardous,
radioactive, mixed and other wastes.6  Operations wastes are less likely than ER wastes
to be in the form of contaminated media.
   4  See DOE Order 5820.2A.

   5  See D.OE's Five Year Plan, cited above, and U.S. Department of Energy, Environmental Restoration and Waste
Management (EM) Program, June, 1991.

   6  Pollution prevention is the preferred approach in EPA's "waste management hierarchy," and is the focus of the
Pollution Prevention Act of 1990. Recognizing the shift toward pollution prevention as a waste management strategy, DOE
has issued several internal orders to promote waste reduction and pollution prevention. In 1990, DOE consolidated these
orders in a "Waste Reduction Policy Statement", requiring all DOE program and Field Offices to "institute a waste reduction
policy to reduce the total amount of waste that is generated and disposed of by DOE operating facilities through waste
minimization (source reduction and recycling) and waste treatment."  DOE sees this statement as the first step in the
development of a comprehensive Department pollution prevention program., (U.S. Department of Energy, "Pollution
Prevention and Waste Minimization", in Environmental Restoration and Waste Management: Information Sheets November
1991).                                                                            '

                                           2-3

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 DOE estimates show very large quantities of mixed waste derived from ER and routine
 operations.  At the end of 1,991, DOE sites contained an estimated 13 million m3 of soil
 and 440,000 m3 of other solid wastes contaminated with LLR/MW and requiring
 remediation.7 DOE's estimated annual generation rate of LLR/MW wastes was 66,047
 m3 in 1991, with a cumulative inventory through 1991 of 101,375 m3.8

 Because of the different materials involved, the appropriate treatment of ER and
 operations waste differs significantly.  For instance, incineration may be used to destroy
 contaminants in soil from ER activities, but it will not significantly reduce the volume of
 the treated waste, since soil is inorganic and non-combustible.  However, for wastes not
 contained in media,  incineration may significantly reduce waste volume.9

 At DOE, management of radioactive waste is controlled by DOE Order No. 5820.2A,
 which establishes policy guidelines and minimum requirements for management of DOE
 LLR/MW and contaminated facilities. Excerpts from this Order are included as
 Appendix B.  Chapter III of that Order deals specifically with the management of LLW,
 and Section 3 of the Chapter identifies the basic requirements for LLW management,
. including waste acceptance criteria (WAC).  These basic requirements are listed in
 Exhibit 2-1.

 2.1.3  The Role of Incineration

 Incineration as a waste management strategy serves several purposes.  It destroys some
 hazardous materials by breaking them down into simpler chemical forms; it may
 eliminate liquids in  the waste that would otherwise complicate waste management; it
 decreases waste volume; and it may generate usable energy.

 Incineration is currently a critical component of DOE's strategy for managing LLR/MW.
 It is the primary treatment technology for both ER and operations wastes containing
 organic hazardous constituents.  Given the quantities of DOE wastes described above,
 and assuming a large proportion contain organic constituents, DOE will have to
 incinerate large volumes of waste.

 DOE's incinerators were originally constructed for research purposes, to test the design
 and use of incinerators for waste treatment.   They were not intended to process large
 volumes of waste on an operational scale. The facilities have since been modified and
 retrofitted to meet DOE's increasing demand for incineration capacity.  However, the
    7 In-place volumes.  Waste from remediation activity may be more or less depending on the remedy and technology
 selected.

    8 U.S. Department of Energy, Integrated Data Base for 1992: U.S. Spent Fuel and Radioactive Waste Inventories.
 Projections. Characteristics. October, 1992.

    ' See Section 4.2 for a discussion of technologies for treatment of ER wastes.

                                          2-4

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                                         Exhibit 2-1

          DOE GUIDELINES FOR WASTE ACCEPTANCE CRITERIA
                             (DOE Order 5820.2A - 9/26/88)

(1)     Waste shipment from one field organization to another for treatment, storage or disposal shall
        be done in accordance  with the requirements established by the operations office having
        responsibility for operations of the receiving facility.

(2)     Waste acceptance criteria shall be established for each low-level waste treatment, storage, and
        disposal facility, and submitted to the cognizant field organization.

(3)     Generators of waste shall implement a low-level waste  certification program to provide
        assurance that the waste acceptance criteria for any low-level waste  treatment, storage, or
        disposal facility used by  the generator are met.  Generators and facilities receiving the waste
        are jointly responsible for assuring compliance with waste acceptance criteria. Generators are
        financially responsible for actions required due to nonconformance.

(4)     Generator low-level waste certification programs shall be subject to a periodic audit by
        operators of facilities to which the waste is sent by the generator.

(5)     The waste acceptance criteria for storage, treatment, or disposal facilities shall address the
        following issues:

        (a)     Allowable quantities/concentrations of specific radioisotopes to be handled, processed,
               stored or disposed of;

        (b)     Criticality safety requirements (waste forms and geometries);

        (c)     Restrictions regarding low-level waste classified  for security reasons;

        (d)     External radiation and internal heat generation;

        (e)     Restrictions on  the generation of harmful gases, vapors,  or liquids in waste;

        (f)     Chemical and structural stability of waste packages, radiation effects, microbial activity,
               chemical reactions, and moisture;

        (g)     Restrictions for chelating and complexing agents having the potential for mobilizing
               radionuclides; and

        (h)     Quantity of free liquids.
                                             2-5

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constraints of their original design still limit their efficiency for large-scale waste
processing.

2.2    REGULATORY CONTEXT

Three separate sets of regulations apply to DOE's LLR/MW.  The hazardous wastes are
regulated under RCRA, the radioactive wastes are regulated under AEA, and the mixed
wastes are controlled jointly under both RCRA and AEA.

2.2.1   Hazardous Waste

Under RCRA Subtitle C, EPA and authorized States regulate the treatment, storage and
disposal of solid wastes that are hazardous.  In establishing the definition of solid waste
under RCRA, Congress exempted AEA source, special nuclear, and byproduct material
(S. 1004). Because these materials are not solid waste, they cannot be RCRA hazardous
waste. As a result, EPA and authorized States have the authority to regulate the
hazardous component of a mixed waste, but cannot regulate the radioactive component.
The RCRA regulations that are most relevant to DOE's incinerator operations are the
requirements for permitting, technical and operational requirements for incinerators, and
the Land  Disposal Restrictions.

RCRA requires that hazardous waste treatment, storage and disposal facilities operate
under permit. Owners or operators of facilities managing hazardous waste, are required
to obtain  permits containing design and operating standards for their facilities.  The
permit application consists of two parts. Part A includes general information about the
facility. Part B contains detailed technical information on how the applicant intends to
operate the facility to comply with EPA's relevant standards.  Facilities that existed when
EPA's hazardous waste rules went into effect receive "interim status" when they submit
Part A, and are subject to interim status standards until their permit is approved or
denied. New facilities cannot receive interim status; they must be permitted before they
can begin construction or operation.

In addition, RCRA contains specific technical and operational  requirements for
hazardous waste incinerators at permitted facilities.  These requirements include
restrictions on the composition  of waste feeds, performance standards  for efficiency in
destroying hazardous constituents, and emissions standards for particulates and acid
gases. A  trial burn is usually conducted to demonstrate that the facility can meet
performance and emissions standards.  EPA's incinerator requirements currently do not
restrict incineration or emissions of toxic metals.

In 1991 EPA began regulating boilers and industrial furnaces (BIFs) that  burn hazardous
waste as fuel.  The requirements of the BIF rule supplement RCRA's  general incinerator
requirements,  and do restrict the combustion and emissions of toxic metals, using health
risk-based standards. The current regulatory approach is to limit the metals content in
the waste feed, thus controlling the  amount discharged through the stack  (for a given
metals removal efficiency). Depending on the specific risk-based scenario chosen, the
                                        2-6

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 allowable limits in the feed may be based upon measured metal emissions during a
 compliance test. Though the BIF requirements do not currently apply to incinerators,
 permit writers may apply them to incinerators on a case-by-case basis.  In the future,
 EPA may consider revising RCRA incinerator regulations to address toxic metals at all
 facilities.

 Congress amended RCRA in 1984 through the Hazardous and Solid Waste Amendments
 (HSWA).  One  of the most significant new requirements of HSWA is the restriction on
 hazardous waste land disposal, defined to include any permanent or temporary
 placement of waste on or in land. The Land Disposal Restrictions (LDRs) require
 treatment of wastes to minimize toxicity before land disposal is permitted. Treatment
 standards are based on the performance of the Best Demonstrated  Available Technology
 (BOAT) for treating each hazardous waste.  These restrictions on land disposal have
 increased the role of incineration in waste management, both as a treatment technology
 and a means of reducing the volume of waste requiring land disposal.

 2.2.2  Radioactive Waste

 Several agencies have radioactive waste management programs.  These agencies include
 the U.S. Nuclear Regulatory Commission (NRC) and its Agreement States, EPA, DOE,
 the Department of Defense (DoD), and other Federal agencies.

 NRC regulates commercial (private-sector) activities through licenses to receive, possess,
 use (including storing, sampling, testing, and treating) and dispose of materials and
 wastes containing source, special nuclear, and byproduct material. Twenty-nine  States
 have entered into agreements with NRC (i.e., Agreement States), whereby the
 Commission has relinquished to the States its regulatory authority over source, byproduct,
 and small quantities of special nuclear material.  DOE is exempt from NRC regulations
 except as specified in Section 202 of the Energy Reorganization Act of 1974 (i.e., DOE
 facilities that accept commercial high-level waste).

 The AEA (42 U.S.C. 2011, et. seq.) provides broad authority to control the management,
 processing, and utilization of source, special nuclear, and byproduct  material. Section
 274(h) of the AEA established the Federal Radiation Council,  consisting of the  Atomic
 Energy Commission (AEC) and other agencies, to  advise the President with respect to
 radiation matters, directly or indirectly affecting health, including guidance for all Federal
 agencies in the formulation of radiation standards.  Reorganization Plan No. 3 of 1970
 (Appendix I, 5 U.S.C.A.) transferred from the AEC to EPA the responsibility for
 establishing generally applicable standards for the protection of the environment from
 radioactive material. EPA's guidance  and regulations under AEA apply to NRC and
Agreement State licensees, as well as to DOE and  other Federal agencies, although
implementation and enforcement  responsibilities are vested in other agencies, such as
NRC and DOE.   Of particular interest, EPA is in the process of developing regulations
that govern radiation site cleanup and the management and recycle/reuse of radioactively
contaminated materials. These regulations are likely to significantly  affect the volumes of
                                        2-7

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LLR/MW generated during DOE site remediations and how those wastes can be
managed.

DOE is primarily responsible for controlling the management and disposal of radioactive
material at Government-owned and -operated facilities.  DOE has instituted
requirements for hazardous and radioactive waste management in a series of internal
DOE orders.  These orders, which  commonly incorporate identical or slightly modified
provisions that appear in NRC and EPA regulations, have the same effect for DOE
facilities or "within DOE" as regulations.

DoD, through its Departments of Army, Navy, and Air Force, controls a large number of
sites both in and outside the contiguous United States. Additional military sites are
controlled by DOT through the U.S. Coast Guard. Most of DoD's radioactive waste
management activities are regulated by NRC and/or EPA. DoD's Defense
Environmental Restoration Program has been ongoing since  1983 to restore active sites
and formerly utilized  defense site.  Additionally, DoD's Installation Restoration Program
consists of over 17,500 potential hazardous waste sites located at 1,877 installations,
some of which are known to have radioactive contamination.

Other Federal agencies with programs applicable to radioactive waste include the
Department of Transportation (DOT), the Federal Emergency Management Agency
(FEMA), and the Department of the Interior (DOI). DOT has issued regulations that
set forth packaging, labeling, recordkeeping, and reporting requirements for the transport
of radioactive material (49 CFR Parts 171 through 179).   FEMA and DOI may play a
role in radioactive waste site cleanups in certain cases.

2.2.3  Mixed Waste

Mixed waste is regulated under both AEA and RCRA. Under AEA, DOE is primarily
responsible for the federal government's generation and possession of nuclear material,
while NRC is  mainly responsible  for the generation and possession of nuclear materials
at commercial facilities.   In addition, EPA is  authorized under Reorganization Plan
No. 3 to develop standards under the AEA, which NRC  and DOE implement by
incorporating  them into their regulations and orders.  These  EPA standards are intended
to provide a safe level of protection from radiological hazards for human  health and the
environment.   EPA also retains authority under RCRA over hazardous waste
generation, treatment, storage, and disposal. Thus, a joint regulatory approach has arisen
whereby EPA and either NRC or DOE are responsible for the radioactive (AEA)
   10 Baca, T.E., "DoD Environmental Requirements and Priorities," Federal Facilities Environmental Journal, Autumn
1992.

   11 A few gray areas cloud this clear division. For example, NRC has authority over several small federal facilities, such
as the National Institutes of Health and the Bureau of Standards.  Also, while DOE is responsible for developing and
operating the proposed high-level waste repository, NRC will have licensing authority for the facility.

                                         2-8

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component of mixed waste, and EPA is responsible for the hazardous (RCRA)
component.12

The 1992 Federal Facilities Compliance Act (FFCA) revised the definition of mixed
waste by amending Section 1004 of the Solid Waste Disposal Act (SWDA), adding the
following new paragraph: "The term 'mixed waste' means waste that contains both
hazardous waste and source, special nuclear, or byproduct material subject to the Atomic
Energy Act of 1954...."  In addition, recognizing the difficulties that DOE faced in coming
into compliance with both RCRA and AEA regulations after 1984, the FFCA exempted
DOE's mixed wastes from RCRA regulation for three years.
   12 See EP A's Clarification of RCRA Applicability to Mixed Waste. July 3,1986, and DOE's Clarification of the Definition
of Bv-Product Material, May 1, 1987.

                                         2-9

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                3.  DESCRIPTION OF INCINERATOR OPERATIONS

This section starts with a general introduction to incinerator operations and the particular
incinerators that DOE uses for LLR/MW treatment.  It then presents and discusses the
results of the survey of DOE and commercial incinerators, organized into different
subject areas.

3.1    OVERVIEW OF  EXISTING INCINERATION SYSTEMS

Section 3.1.1 describes the typical operations at a generic LLR/MW incinerator. The
particular incinerators used by DOE are then introduced in Section 3.1.2, followed by the
schematics  of each incinerator presented in Section 3.1.3.

3.1.1   General Description of Incinerator Operations

Incineration involves the introduction of wastes into an incinerator in a bulk form  (e.g.,
as boxes, bags,  or drums), shredded, in a sludge form (e.g., slurry), or injected as liquid
(EG&G  1988, ASME 1988).  The feed rate is governed by the combustible nature of the
material  and introduction of an additional source of fuel. If in a liquid f&rm, waste may
be introduced as a mixture of fuel and waste.  Processing rates generally range from 34
to 1,043 kg/h for currently operating or planned DOE incinerators (EPA 91c).  The
waste/fuel ratio is determined by the combustion properties of the waste and incinerator
capacity. The considerations noted above apply generally to all waste forms (mixed and
low-level wastes). As combustion occurs, oxygen is consumed and the combustion gases
are entrained in a secondary  combustion chamber. Proper combustion conditions  are
maintained by controlling the amount  of air, waste feed rate, and temperature. Special
attention is given to the residence time in order to ensure that complete oxidation occurs
and that the hazardous components are destroyed.

Suspended particulates,  fumes, and products of incomplete combustion, if any, are
captured in exhaust scrubbers and filtration devices before the combustion gases are
released  out the stack.  Off-gas treatment generally involves passing the hot flue gases
into a series of components to remove suspended particulates, acid gases, and
radionuclides.  Such systems include scrubbers (e.g., venturi scrubbers), heat-exchangers,
filters and separators, high efficiency particulate air (HEPA) filters, and adsorbers.
Other forms of off-gas cooling include quenching by water injection and dilution by
introducing air  at ambient temperature. Particulate emissions, depending on particle
sizes and exhaust velocity, are trapped in heat-exchangers, filters, or electrostatic
separators.  The chemical and radioactive constituents of the off-gas can vary significantly
from those of the input  waste. The combustion process  does not destroy the radioactivity
associated with the waste, only the chemical and physical forms of the radionuclides.

As the feed material is consumed, the ash is collected at the bottom of the combustion
chamber or in ash bins.   Some of the ash, however, is entrained with the off-gas and
settles or collects in various parts of the off-gas treatment system.  The deposition of
ashes in various parts of the system is dependent upon waste feed, off-gas velocity,
                                        3-1

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particle size and density, combustion process, residence time, and the efficiency of the
treatment system components. Frequently, the bulk of the ash is retained at the point of
combustion.  Smaller amounts are collected in other sections of the incinerator system
(e.g., post-combustion chamber, filter bags, and in precipitators).  Minimal amounts are
retained on HEPA filters, heat-exchangers cooling coils,  and at other unspecified
locations.

Usually ash handling is performed remotely, via a ram or conveyor, and the operator is
separated from the ash by a physical barrier. Ash generally  is removed through ash drop
out ports or other engineered designs for ash removal.  The  handling of ash is also
performed with proper ventilation to keep the ash from  being dispersed in the immediate
area. Sometimes, ashes are discharged into  a glovebox and chute connected to a drum.
Ashes may also be dumped directly into a treatment system  for processing (e.g., via
cement, or bitumen solidification).  Incinerator ashes are analyzed to characterize
radiological and chemical properties in order to verify compliance with waste acceptance
and  disposal criteria.

Incineration has been shown to yield varying volume reduction factors (VRF), commonly
4 to 40 for most types of compressible dry active waste (DAW) and combustible solids,
and  greater than 100 for liquids and most plastics.  Incineration yields waste residues that
are of much higher radionuclide concentrations than the original waste stream.
Consequently, ash containers or bins may have higher external radiation exposure rates.
When radiation exposure  levels are expected to be high, system designs strive to
minimize personnel interaction with equipment and ash bins. Shielding of ash collection
bins and other ash handling equipment may also be needed.

Actual airborne  radionuclide emissions are also known to vary for the reasons given
above.  In addition, many incinerators process wastes with radiological and physical
properties that vary as a function of time. Accordingly, it  is  difficult to characterize
emissions in generic terms.  A general perspective on the type and extent of airborne
emissions can, however, be  obtained from operating facilities.13  Unfortunately, little
information exists that directly compares the radiological properties of the waste
introduced in the incinerator with actual airborne emissions.   Generally, data  only
summarize airborne emissions on a yearly basis, with no correlation with waste
throughputs.

3.1.2 Identity and Status of LLR/MW Incinerators

This report focuses on the DOE and commercial incinerators listed in Exhibit 3-1.  The
report examines only those  units intended primarily for the processing of LLR/MW,
rather than for such activities as uranium recovery.
   13 A survey of several U.S. and European facilities indicates that stack releases and off-site exposures are well within
established limits (IAEA 1989). Typically, stack releases range from non-detectable levels to less than one percent of the
limits.

                                         3-2

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                                     Exhibit 3-1

                    U.S. Radioactive and Mixed Waste Incinerators
Unit

TSCA
Incinerator
WERF
CAI
Glass
Melter
GIF
Location

Oak Ridge
Gaseous
Diffusion Plant
Idaho National
Engineering
Laboratory
Los Alamos
National
Laboratory
Mound
Laboratory
Savannah River
Site
Current Status
Comments
D0Bl^M3!&f0mS.
In full-scale operation
since 1991
Facility closed since
Feb. 1991. Planned
restart in 1993.
On stand-by since 1987.
On stand-by. Planned
restart in 1993.
Under construction.
Planned operation in
January, 1996.
EPA Region 4 responsible for
compliance and enforcement.
Facility closed to update
Operational Safety Requirements.
Facility closed to upgrade.
Announced restart in 1993, likely
restart in 1995.
Awaiting RCRA Part B permit from
Ohio EPA
Startup deferred 2 to 3 years while
RCRA Part B permit negotiated.
COMMERCIAL INCHSnEitATORS
SEG
DSSI
Oak Ridge, TN
Kingston, TN
Full-scale operations
began 4th quarter 1989
In full-scale operation
RCRA Part B permit pending.
System modified to meet new BIF
regulations.
The operating status of the incinerators listed in Exhibit 3-1 varies. Several DOE
facilities that were active in the past have been shut down.  Two facilities are on stand-
by, awaiting RCRA permits.  DOE has cancelled several planned incinerator construction
projects for various reasons.  In addition, DOE has one operating incinerator and sends
wastes to two active commercial incinerators.

Since 1985, DOE has shut down three incinerators (the Beta/Gamma Incinerator at
Savannah River, the fluid bed unit (FBU) at Rocky Flats, and the controlled air
incinerator at Lawrence Livermore).  Two other incinerators have been closed until
technical, regulatory or administrative work can be completed:   the controlled air
incineration (CAI) system at Los Alamos, and the Waste Experimental Reduction
Facility (WERF) at INEL.

At the Mound Laboratory in  Miamisburg, Ohio, a small joule-glass melter (JGM) is
currently awaiting a permit from the Ohio EPA. DOE is planning to use the JGM to
                                        3-3

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treat site-generated wastes but not necessarily wastes from ER activities.  Construction of
the Consolidated Incineration Facility (GIF) at Savannah River, after it began in January,
1993, was deferred for several years while negotiating a RCRA Part B permit with
regulatory authorities.

DOE decided not to build a new incinerator as part of the Decontamination and Waste
Treatment Facility (DWTF) at Lawrence Livermore due, in part, to unfavorable public
reaction.  DOE also has canceled another unit in the final stages of construction, the
Process Experimental Pilot Plant (PREPP) at  Idaho National Engineering Laboratory
(INEL). One project in the planning stage (the LLR/MW incinerator at Los Alamos)
was canceled because alternative waste handling approaches were available.

DOE has an operating incinerator at one site. At the Oak Ridge Gaseous Diffusion
Plant (K-25), DOE brought on line a large rotary kiln incinerator which is permitted to
burn TSCA wastes in addition to LLW, mixed wastes, and hazardous waste.  The unit is
referred to as the TSCA incinerator.

Independent of DOE, two private sector plants have also recently come on line.  One is
the controlled-air incinerator operated by the Scientific Ecology Group (SEG ~ a
Westinghouse subsidiary) in Oak Ridge that is permitted to burn low-level waste.  The
other is the cogeneration boiler operated by Diversified Scientific Services Inc.  (DSSI) in
Kingston,  Tennessee,  that is permitted to burn mixed solvent-based wastes.  SEG has
announced tentative plans to build a second incinerator of essentially the  same design as
the existing  unit.

In addition to those operating, on stand-by and under-construction incinerators noted in
Exhibit 3-1,  DOE  expects to construct three additional incinerators.  If all of these units
come into operation as projected, DOE will have the following complement of
government-owned incinerators in operation for processing low-level and mixed wastes by
the turn of the century:

       •     Rotary Kiln - 2 units (TSCA, GIF);
       •     Controlled Air - 2 units (WERF, CAI);
       •     Glass Melter - 1 unit (Mound Laboratory); and
       •     System not yet determined - 3 units.

The SEG  and DSSI commercial incinerators and perhaps other commercial incinerators
also may be built in the near future. It is uncertain how many of these incinerators will
be significantly involved in treating ER wastes.

3.1.3   Schematic Presentation of the Various Units

Exhibit 3-2 provides simplified block diagrams for eight of the incinerators discussed
above. As shown, each of these  incinerators has a unique air pollution control  (APC)
train.   Of the systems with defined components, all except the TSCA rotary kiln use
                                        3-4

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 HEPA filters.  More detailed schematic diagrams for five of the systems are included in
 Appendix C.

 Over the years, incinerator designs have evolved from relatively simple to very complex
 systems.  It is also common practice for many incinerator designs to be essentially one of
 a kind. Accordingly, it is not possible to identify one design as a  representative or typical
 system.  The CAI system at Los Alamos, however, incorporates a broad  range of features
 and can serve as an illustrative model for other incinerators.

 The first part of the CAI system includes a waste inspection system. Wastes are initially
 characterized by a gamma spectroscopy system to evaluate their radiological
 characteristics.  Next, the waste package or container is passed through an x-ray scanner
 for visual inspection of its contents.  The next components include a waste inspection
 glove-box and feeder where the waste is prepared prior to being introduced into the
 incinerator. The incinerator itself is comprised of a primary and secondary combustion
 chamber. Connected to the bottom of  the incinerator is a self-contained ash handling
 unit.  Combustion gases are extracted from the top of the incinerator and channeled into
 the following major components:   a quench column, a venturi scrubber, a packed column
 scrubber, an off-gas  demister arid super-heater, a set of HEPA filter and* charcoal
 adsorber banks, a set of two exhaust fans, and an effluent stack.  The exhaust  stack is
 equipped with a continuous effluent sampling and monitoring system that measures gas
 emissions. These components are also  serviced by other subsystems which include
 cooling, scrubber operation, and process instrumentation and control.

 3.2    WASTE HANDLING

 A variety of DOE waste streams are treated by incinerators both  within the DOE
 complex and in  the private sector. The following sections include brief summary
 descriptions of some of these units; including discussion of their waste handling and
 acceptance criteria.  The descriptions are based on the information collected during the
 survey and incorporated in Appendix A.

 Not all .of these incinerators are equally suited to processing the waste forms expected
 from ER. An ad hoc working group within DOE has characterized the general
 applicability of various generic thermal treatment units to six general waste forms (DOE
 92a).  Exhibit  3-3 presents results that are relevant to incinerators, extracted from that
 study.  In the context of the DOE study, "dry solids" consist of items such as grouts,
 bricks, soils, concrete, asphalt, salts and ashes.  "Large heterogeneous" solids comprise
 items such as equipment, glove boxes, construction debris, wood, paper, plastics, rubber
 and synthetics.  "Small heterogeneous" solids include such items as filters, ceramic
materials, graphite, various combustibles and  inorganic wastes.  Organic and aqueous
 liquids generally connote relatively energetic and non-energetic pumpable liquids,
 respectively.

 Exhibit 3-3 shows that only the rotary kiln is capable of handling the variety of materials
 expected from ER activities; the unit can accept a wide variety of waste forms. Other

                                         3-5

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                    Waste Stream/Incinerator Compatibility Matrix
INCINERATOR
Controlled Air
Fluidized Bed
Liquid Injection
Rotary Kiln
Joule Melter
WASTE STREAMS
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Liquid





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treatment techniques will probably be required to process certain problem ER wastes,
particularly those generated in small volume.  Furthermore, there are other types of
incinerators that might be suitable for processing ER wastes, but which are not currently
in the DOE planning base and are not included in the summary table. None of the
incinerators listed are capable of processing aqueous feeds, because incineration is
generally not the preferred treatment technology for aqueous wastes of low organic
content.  Some aqueous liquids, however, are processed as supplementary feeds,
principally to control temperatures in rotary kilns and liquid injection incinerators.

3.3    WASTE ACCEPTANCE CRITERIA

Exhibit 3-4 summarizes available information on the types of feeds that are now or will
be accepted at existing and planned LLR/MW incinerators.  Information on all of the
DOE incinerators comes in part from the Treatment, Storage and Disposal Capabilities
Data Base maintained by the Hazardous Waste Remediation Action Program
(HAZWRAP)
                                        3-7

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Office managed by Martin Marietta Energy Systems, Inc. in Oak Ridge, Tennessee.  This
data base and the companion hazardous waste profiles data base are part of a larger
data base called Waste Management Information System (WMIS), also managed by
Martin Marietta.  Data on the two commercial incinerators are based on company
literature and staff interviews.

Acceptable feeds  in Exhibit 3-4 are denoted with an X.  These are feeds which have
been specifically identified for the respective units.  Feeds that are specifically denoted as
unacceptable are  designated with a dash. A number of feeds have not been specifically
identified as acceptable, but resemble other acceptable feeds; for these, it is reasonable
to presume acceptance.  For example, if an incinerator is approved for mixed wastes,
presumably it can also handle RCRA wastes.

Since wastes expected from future  ER activities have not been adequately characterized,
the current site- or unit-specific WACs are generally geared to wastes from  current
operations. The extent to which ER wastes will dictate  future changes in a  given WAC is
not known. The following section describes WACs and  waste handling criteria for
various incinerators which currently process or plan to process DOE wastes.

3.4    CURRENTLY OPERATING OR "ON STAND-BY' INCINERATORS

The following information on specific facilities is excerpted from the survey  forms
presented in Appendix A.

3.4.1   TSCA Incinerator (A-4)

System Description and Status

The TSCA Incinerator located at the Oak Ridge Gaseous Diffusion Plant is a 6-ft
diameter x 25-ft long rotary kiln unit  rated at 10 million Btu/hr with a secondary
combustion chamber rated at about 22 million Btu/hr; the total  system maximum heat
release rate is 28  million Btu/hr.  The incinerator uses a wet off-gas treatment system
comprised of a quench tower, venturi scrubber, demister, packed-bed scrubber, two-stage
ionizing wet scrubber, ID fan, and a 100-ft stack. The system is permitted to handle both
TSCA and RCRA wastes.

After initial startup problems involving ID fan failure, the system was restarted in early
1990.   It began full-scale operations about a year later, in April  1991.  The unit is
currently operating mainly on liquid wastes, with 2.2 million pounds processed in  FY-1991
and 2.8 million pounds in FY-1992.

The facility's maintenance procedures typically include two planned outages every year,
one in the spring  for a few weeks and a major one in the fall for 1  to 2.5 months,
depending on maintenance requirements. Maintenance  activities during these outages
include fiberglass  repair, replacement of pumps  and deteriorating equipment, and any
                                       3-10

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major upgrades. The facility also conducts routine maintenance activities (e.g., cleaning
nozzles in off-gas treatment systems) as needed throughout the year (ROG 93).

Waste Handling and Acceptance Criteria

Given its inherent flexibility, the rotary kiln incinerator at the K-25 site in Oak Ridge can
handle a variety of physical forms of waste including liquids (both organic and aqueous),
solids, and sludges, both containerized and in bulk (TSCA 91). In addition, the unit has
both RCRA and TSCA permits which enables the processing of hazardous wastes (or
mixed wastes) and PCB-containing wastes. The unit can accept solids such as
contaminated soils, absorbents, and biological materials; liquids such as waste oils,
solvents,  and water solutions; sludges; solids from wastewater treatment;  and degreaser
residues.  Waste may contain PCBs, hazardous organics, and low-level enriched uranium.

Liquid wastes are stored in 5,000-gal receiving tanks and then pumped to 10,000-gal
blending tanks for feeding to the incinerator burners or nozzles.  Drums  are deheaded
and drained of free liquids and then shredded.  Shredded waste is moved from the
storage bin with an automated crane/grapple and delivered to the feed ram.  Bulk solids
can also be fed to the ram by belt conveyor.   Sludge is pumped through  a nozzle from
drums. Organic and aqueous wastes are pumped to burners and nozzles in the
combustion train.

Exhibit 3-5 summarizes the physical characteristics of the various waste streams.  The
TSCA incinerator accepts wastes from the following DOE locations: K-25, Y-12, ORNL,
Paducah, Portsmouth, RMI, and Fernald.
                                     Exhibit 3-5

                      Physical Characteristics of Waste Streams
                             for K-25 TSCA Incinerator
Characteristic
Viscosity (cp at 100°F)
Solids (wt %)
Freezing Point (°F)
Boiling Point (°F)
Particle Size (in.)
Liquid a
< 5,000
< 10
< 40
> 100
N/A
Solid
N/A
> 50
N/A
N/A
< 1/16
Sludge
5,000 to 500,000
10 to 50
N/A
N/A
> 1/16
            Aqueous solutions contain > 90% water by weight.
                                        3-11

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Although the TSCA incinerator is capable of handling a variety of waste types and forms,
the near-term processing plan is to burn primarily liquid low-level mixed wastes, because
of concern about the handling and ultimate disposition of incinerator residuals derived
from off-site wastes. Under the operating strategy for the next few years, a significant
quantity of liquids will be processed through 1994; between 1994 and 1996 both liquid
and solid mixed wastes will be processed; and by the end of 1996, the inventory of mixed
waste liquids will have been incinerated (IT 92).

Current restrictions on wastes are as follows:

       •     Wastes must be free of dioxin wastes as defined in 40 CFR 268.31 and
             listed as waste codes F020 through F023 and F026 through F028 in 40 CFR
             261.

       •     Wastes must be free of cyanide wastes as defined in waste codes F007
             through F011 listed in 40 CFR 261.

       •     Waste must be free of explosive material which detonates on heating or
             percussion, ignites spontaneously in  dry or moist air, or meets the definition
             of reactive waste as defined in 40 CFR 261 or as designated by EPA
             hazardous waste code D003.

       •     Waste containing uranium with  U-235 enrichment of less than 1% must not
             exceed 0.08 Curies per shipment (i.e. per truckload).

       •     Waste containing uranium with  U-235 enrichment of more than  1% must
             have total uranium content of less than or equal to 5 ppm.

       •     In general, the waste form must be nonvolatile, such that it does not rapidly
             evaporate when the waste container is opened.

       •     If the boiling point of the waste is less than 100°  F, acceptance will be
             based on a case-by-case evaluation.

For liquid organic wastes the corrosivity must be limited to less than 6.35 mm/yr, and for
aqueous wastes the Ph must be greater than 6 for drummed liquids or between 8 and 10
for bulk liquids. Allowable metal contents are listed in Exhibit 3-6. Restrictions on
chloride, sulfur and fluoride in liquids are as follows:
             Total Chloride:
             Total Sulfur:

             Total Fluoride:
89 wt %
6 wt %  (drums)
3 wt %  (bulk)
85 wt % (drums)
25 wt % (bulk)
                                        3-12

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                                        Exhibit 3-6

                              Metals Contamination Limits
                           for TSCA Incinerator Wastes (ppm)
Metal
Aluminum
Beryllium
Cadmium
Chromiu
m
Lead
Mercury
Zinc
Plutonium
Liquid
(Drums)
20,000
10
, 1,500
6,000
2,500
200
65,000
0.004 a
Liquid
(Bulk)
11,000
5
500
3,300
2,000
60
65,000
0.004 a
Solids
80,000
5
800
6,000
1,000
120
65,000
0.004 a
Sludge
80,000
5
800
6,000
1,000
120
65,000
0.004 a
                 Or 246 pCi/g.
Solid materials in drums are required to be shreddable, which limits rebar, pipe and
concrete pieces to less than 2 inches in diameter.  Total chlorides, sulfur and fluorides
are limited to 75, 3, and 21 wt %, respectively.  Corrosivity limits  for sludges are the
same as for liquids.  Total chlorides, sulfur and fluorides are limited to 75, 10, and 21 wt
%, respectively.

Waste received for processing must be identified by radionuclide content.  Prior to
processing, TSCA incinerator staff analyzes the waste and determines whether or not,
when treated along with other wastes, it will create a situation where the annual
committed effective dose equivalent limits14 will be exceeded.  Required lower limits of
detection for specific nuclides are listed in Exhibit 3-7.
Waste shipping containers must meet the  following requirements:

       •      Maximum dose equivalent rate at contact - 50 mrem/hr;
       •      Maximum dose equivalent rate at 2 feet - 5 mrem/hr;
   14  10 CFR 20.1003 defines "committed effective dose equivalent" as the sum of the products of the weighting factors
applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or
tissues (i.e., Stissues/organs (tissue/organ weighting factor x committed dose equivalent)). The "committed dose equivalent" is
the dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an
individual during the 50-year period following the intake.
                                           3-13

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                                     Exhibit 3-7

                      Required Lower Limits of Detection (LLD)
                    for Radionuclides in TSCA Incinerator Wastes
Radionuclide
H-3
C-14
P-32
Co-57
Co-60
Kr-85
Sr-90
Tc-99
I-1313
Cs-137
Required LLD
(Pci/g)
60
60
5
0.1
0.5
5
5
20
0.7
1
Radionuclide
Pb-210
Th-228
Th-230
Th-232
Th-234
Pa-234m
U-alpha
Np-237
Pu-238
Pu-239
Required LLD
(pCi/g)
1
1
1
1
1
1
1
1
1
1
               1-131 not required if waste has been stored more than six months.

       •     Transferrable beta/gamma surface contamination - 1000 dpm/100 cm2; and
       •     Transferrable alpha surface contamination - 200 dpm/100 cm2.

3.4.2   Scientific Ecology Group TSEG^ Incinerator (A-8)

System Description and Status

The SEG incinerator is commercially owned and operated by the Scientific Ecology
Group (a Westinghouse subsidiary) in Oak Ridge, Tennessee. The system is a fixed-
hearth, controlled-air unit of Scandinavian design rated at 11 million Btu/hr. The
primary unit is coupled with secondary and tertiary combustion chambers, though the
tertiary chamber is seldom used. The off-gas treatment system consists of a fire-tube
boiler, baghouse, bank of HEPA filters, quench chamber,  packed-bed scrubber, ID fan,
and an exhaust stack.  Reheated air is added to the stack for plume suppression.

Primary feed to the system is low-level waste (dry active waste, or DAW), but  liquid
waste can be fed into a burner in the secondary combustion chamber.  SEG also has at
the site a liquid injection incinerator which typically handles low-level radioactive waste
oils.
                                       3-14

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 The unit began operation in late 1989 and in 1990 processed 2.6 million pounds of DAW
 and about 25,000 gallons of oil. In 1992 6.7 million pounds of DAW were burned.  All
 oil has been burned in the liquid injection incinerator since 1991. SEG is planning to
 obtain a RCRA permit to process mixed wastes.  They have incinerated wastes both from
 DOE sources and from the private sector and are considering adding a second solid
 waste incinerator.

 Waste Handling and Acceptance Criteria

 Most of the waste SEG handles is generated by nuclear power plants; less than five
 percent is from DOE. LLW received at SEG includes paper, cloth, wood, rubber with
 some metal particles, glass and plastics.  Typical heat content is 6,500 to 13,000 Btu per
 pound.  All solid waste is hand-sorted into wheeled containers holding about 50 ft3
 (about 300 Ibs). Twenty-two wheeled containers are loaded into a feeding magazine and
 then automatically fed into the incinerator. The wheeled containers ride up a vertically
 inclined trolley to a waste charging chute. The upper chute door opens, waste is  dumped
 into the chamber (air lock), and the upper door closes. When incinerator feed is
 required, the lower door opens and the waste falls into the furnace.

 The SEG controlled-air incinerator is designed  to handle DAW with no more  than 5%
 PVC. All dry wastes are hand sorted to remove metals, selected plastics and other
 undesirable feeds.  Animal carcasses, with their high tritium and C-14 contents, are not
 acceptable feeds (SEG). As an adjunct to the hand sorting program for removal  of acid
 gas-forming materials, SEG has worked with more than thirty suppliers to the  nuclear
 industry to ensure  that their products are acceptable for incineration at SEG.  These
 vendors supply "Certified Incinerable" items to their customers.

 Specific radionuclide limits for acceptance of DAW are presented in Exhibit 3-8.  In
 addition, waste containers received at the SEG facility must have contact radiation levels
 of less than 200 mR/hr and removable external contamination levels of less than 2,200
 dpm/100 cm2 for beta/gamma emitters and less than 220 dpm/100 cm2 for alpha emitters.

 Other excluded materials are gases, chelating agents, hazardous chemicals, pyrophorics
 and explosives. Solid wastes must not contain significant quantities of free-standing
 liquids.  Residuals  from any waste accepted by SEG must also be acceptable at the
 destination burial ground.

 Waste acceptance  criteria for contaminated oils are presented in Exhibit 3-9.  It should
be noted that the total halogens level can be as high as 4,000 ppm if the generator can
 demonstrate that the oil contains less than 100 ppm of any individual halogenated solvent
listed as an F001 or F002 waste and can certify that there has been no additional  mixing
 of hazardous constituents with the oil.
                                        3-15

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                                      Exhibit 3-8

                      SEG General Waste Acceptance Criteria a
Material
Mixed Fission and Activation
Products (Z < 84)
Ra-226
Th-232
U-238 as metal or oxide
U-233, U-235
Plutonium
Transuranics
Criterion
(radionuclide content
per package)
< 25 mCi/cf
< 0.1 Mci/cf and <
10 Nci/g
< 5 Mci/cf
< 15 Mci/cf
< 0.1 gm/cf
< 10 Nci/g
< 10 Nci/g
                     Additional incinerator-related limits may be imposed for H-3, C-
                   14, Tc-99 and 1-129.
3.4.3   Diversified Scientific Services, Inc. (DSSI) Cogeneration Boiler (A-3)

System Description and Status

Diversified Scientific Services,  Inc. (DSSI), a private, commercial concern, operates a
cogeneration boiler rated at 16.5 million Btu/hr (but limited by state air permit to 14.5
million Btu/hr) in Kingston, Tennessee.  The unit is currently in full-scale operation.  The
boiler's operation generates sufficient power to drive a 150-kw electrical generator, and
the excess is sold to the local electric utility. Off-gas treatment involves a semi-dry
scrubber system consisting of a spray dryer, baghouse, HEPA filter, carbon bed adsorber,
ID fan, and an exhaust stack.

Construction of the facility was initiated in mid-1989, and the off-gas  treatment system
was modified to conform to the new BIF regulations (56 CFR 7134) at the end of 1991.
The major fuel supply to the boiler is radioactively contaminated spent solvents such as
scintillation fluids.  DSSI has handled  wastes from DOE  sites and from commercial
sources, and at the time of the survey was bidding on additional DOE wastes.
                                         3-16

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                                       Exhibit 3-9

                SEG Waste Acceptance Limits for Contaminated Oil

Toxicity Characteristic

       Heavy Metals C40 CFR 261.241
               Arsenic
               Barium
               Cadmium
               Chromium
               Lead
               Mercury
               Selenium
               Silver
                    <5.00 mg/1
                  < 100.00 mg/1
                    < 1.00 mg/1
                    <5.00 mg/1
                    <5.00 mg/1
                     < 0.2 mg/1
                    <1.00 mg/1
                    <5.00 mg/1
       Organics
Total Halogens

PCB's

Flashpoint

Viscosity

Solids Content
Organic compounds listed in 40 CFR 261.24 must be certified absent by generator or
oil must be tested to meet the Toxicity Characteristic Leaching Procedure (TCLP).

              1000 ppm (max.)

                     2.00 ppm

                  140° F(min.)

                    <3000 ssu

                    <10vol %
Radiological Analysis (Averaged over truckload lot)

       All nuclidesclE-4 microcuries/ml
       Uranium  
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 Waste Handling and Acceptance Criteria

 DSSI's industrial boiler for electrical cogeneration is designed to handle mixed low-level
 solvent wastes without halogens or heavy metals.  Vials or containers of glass and plastic
 are crushed and the solvents separated and transferred to one of seven 250-gal holding
 tanks for testing. If the material meets the WAC, it is transferred to one of three 10,000-
 gal carbon steel storage tanks for feed to boiler.

 From a RCRA perspective, DSSI can handle waste solvents including EPA designations
 D001 and F001-F005 plus numerous D, U, and P listed materials.  A listing of these
 acceptable solvents is included as Appendix D.  Solvents containing halogens or heavy
 metals are unacceptable as fuels.  From an Atomic Energy Act perspective, DSSI can
 handle about 2,000 isotopes typical of those found in medical, institutional and nuclear
 power plant wastes. Wastes containing some source and special nuclear  materials from
 DOE and Department of Defense (DOD) facilities are also acceptable.  Waste can be
 received in containers varying from 5 to 85 gallons or in bulk from tanker trucks (DSSI).
 The radioactive materials license issued by the state of Tennessee specifies that the
 physical and/or chemical form of the wastes is "any as associated with liquid scintillation
 type fluids, solutes,  solvents, and associated materials."  Licensed isotopes are listed in
 Exhibit 3-10, as are the total quantities which can be held on the property at  any one
 time. The annual quantity of radioactive material which can be burned is limited  to 22.5
 Curies of H-3 and C-14 combined and 1.5 Curies of all  other approved isotopes
 combined.  In addition, the limiting concentrations for combustion are 0.05 microcuries
 per gram of H-3 and C-14, combined, and 0.002 microcuries per gram of all other
 authorized isotopes, combined.

 3.4.4   Waste Experimental Reduction Facility TWERF^) Incinerator (A-5)

 System Description and Status

 The Waste Experimental Reduction Facility (WERF) Incinerator at INEL is a dual-
 chambered controlled-air combustion system rated at 5 million Btu/hr. Solid and liquid
wastes are charged to the primary combustion chamber.  The incinerator off-gas
 treatment system consists of a shell-and-tube heat exchanger, baghouse, bank of HEPA
filters,  ID fan, and a 49-ft stack.  Acid gas removal facilities are not included, thus
limiting the throughput of halogen wastes.

The system began processing LLW in September 1984 and was shut down in February
 1991 to update Operational Safety Requirements. Restart is planned in 1993. The
system completed a RCRA trial burn of liquid wastes in 1988 and has an Interim Status
RCRA Permit.
                                       3-18

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                                     Exhibit 3-10

                    Allowable Quantities of Radioisotopes at DSSI
Item
1
2
3
4
5
6
7
8
Isotope
H-3, C-14, S-35, Cl-36, Ca-45, Fe-55, Fe-59, Cs-
137, Co-60, Co-58, Co-57, Gd-153, Zn-65, P-32,
P-33, Na-22, Rb-86, Hg-203, In-Ill, Ga-67, Mn-
54, Sc-46, Se-75, Cd-109, Ni-63, Cu-64, Sn-113,
Sn-119m, 1-125, 1-131, Bi-207, Ce-141, Au-195
Cr-51, Cs-134, Tc-99, Ge-68
Ra
Uranium (not U-233 or U-235), plus thorium
U-235
,U-233
Plutonium
Any radioisotope with atomic numbers 1 through
83 except as included in items 1, 2, and 3 above.
Allowable Quantity
Total of Item 1
combined: 10 Ci
Each isotope: 2 Ci
10 milliCi
Total of Item 4
combined: 200 kg
175 ga
100 g a
100 ga
Total of Item 8
combined: 1 Ci
          a The sum of the actual quantities of Items 5, 6, and 7 when each is
         shall not exceed unity.
divided by this quantity
Waste Handling and Acceptance Criteria

Combustible solids in cardboard boxes are placed on a roller conveyor, weighed and then
moved through air lock to an elevator and into a waste-loading chute.  Liquid waste in
drums is pumped to a burner.

LLW feed for the WERF incinerator is packaged in 2'  x 2' x 2' plastic-lined,
corrugated cardboard boxes.  Other package requirements are presented in Exhibit 3-11
(INEL 87).  Containers with free liquids are prohibited  in the boxes.  In addition, the
mercury content of the feed material  must be held to levels at which emissions do not
exceed 0.05 mg/m3 (HAZWRAP).

The WERF Air Quality Permit to Construct issued by the state of Idaho, Division of
Environmental Quality,  in October 1987 limits waste feeds to those included in the DOE
permit application (Richards).  Permitted  feeds are listed in Exhibit 3-12.

WERF  is currently developing mixed  waste acceptance criteria in anticipation of system
restart.  Draft waste acceptance criteria for mixed wastes are included in Appendix E
                                        3-19

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                     Exhibit 3-11




Package Specifications for WERF Low-Level Waste Feed
Characteristics
Gross weight
limit
Dimension
limit
Radiation
limit*
Contamination
limit
TRU content
Fissile material
limit
Box linerb
Box condition
Closure
Markings
Acceptable
materials
Prohibited
materials0
Corrugated Cardboard Boxes
60 Ib/box
2 ft by 2 ft by 2 ft (swelling due to excessive loading is not permitted)
Individual boxes shall not exceed 20 mR/h at contact. The shipping container shall
not exceed 200 mR/h at contact.
External box surfaces shall be less than 200 dpm/100 cm2 beta-gamma and 20
dpm/100 cm2 alpha removable.
Less than 10"1 nCi/g
Trace quantities only (less than 250 dpm/100 cm2 alpha)
Yellow polyethylene (4 mil minimum)
The filled boxes are to be free of rips and punctures. The box condition shall
provide for the integrity of the contents during normal handling and shall not have
been wetted or excessively weathered.
After removal of the box from the collection receptacle, twist the liner into a neck
and fold it over onto itself and tape it to provide a seal. Close both sets of lid flaps
and fully tape the exposed seam and edges. Use 2-in. cloth type tuck tape or carton
closure tape that does not contain PVC or other halogens.
Attach required radiological labels and include the following additional information:
Source facility and building or location.
Wood, paper, cloth, towels, polyethylene bags, sheeting and empty polyethylene
sample bottles with lids removed.
Items containing polyvinylchlorides (PVCs), glass, fiber glass, respirators, aerosol
cans, steel-toed boots and shoes and other metallic wastes. (Buttons, snaps, zippers,
small nails, staples and other similar items are acceptable.)
NOTE: Herculite and Tygon contain PVCs.
                         3-20

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                                      Exhibit 3-11  (continued)
Characteristics
Bulk wood waste
Mixed hazardous
flammable liquid
Corrugated Cardboard Boxes
The WERF can accept bulk wood waste materials such as shoring, temporary
containments and scaffolding to be sized at WERF and packaged in boxes for
burning. This type of material is to be shipped in WERF bins or D&D bins
and is not to be mixed with metallic waste. Nonstandard wood waste may also
be eligible in accordance with Section 8.3.
See Note d.
a.
b.
c.
Radiation limits are currently being evaluated and may be increased. These changes will be published as a
DRR or revision in the event that they should occur.

Box liners are not required for waste generators that collect the waste in 4 mil (minimum) bags. The bags
can be necked and tape sealed and be put directly in the boxes so long as the exterior of the bag is free from
contamination.

Complete segregation of this waste classification is required. Any chemicals or metals that can be
recombined with other elements as a result of the combustion process and that can result in chemical or
corrosive attack of the incinerator and off-gas components must be eliminated from the waste stream.

The WERF can accept flammable liquids for incineration that are contaminated with radioisotopes up to 3.4
x 10"5 Ci/1.  Other hazardous materials in flammable liquids are acceptable as long as the degree of difficulty
in destruction is not greater than that for organic chlorine.  The heat of combustion of the hazardous
constituent must be greater than 0.24 Kcal/g  (432 BTU/lb).  The fluid mixture must have minimum heat of
combustion of 10,000 BTU/lb. The hazardous  liquid materials that  are within the above concentrations may
also be included in boxed waste as long as  they are totally absorbed  in an eligible absorbent material with
100% excess  absorbent.  The total absorbed quantity cannot exceed  1 L/box.
                                                  3-21

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                  Exhibit 3-12
           WERF Incinerator Feeds
  Specified in Air Quality Permit to Construct

Degreasing Solvent (Stoddard Solvent)
Degreasing Sludge (Trichloroethane)
Thinners, Strippers and Paint Solids (Mineral Spirits,
Toluene, Xylene, Acetone)
De-inking Solvent Sludge (Tetrachloroethylene,
Naphtha)
Miscellaneous Ignitables
Mixed Organic Waste
Lab Wastes (Carbon Tetrachloride)
Mixed Formaldehyde and Mercuric Nitrate*
Formaldehyde from Analysis
Solvent Cleaning (Trichloroethylene)
Degreasing of Reactor Components (Acetone)
Paint Stripping (Methylene Chloride)
Combustible Wastes (Paper, Bottle Samples, Gloves)
Silver-Zeolite
Scintillation Fluid (xylene, toluene)
Degreasing Solvent (Freon 112)
Freon Decontamination Still Bottoms and Filters
Silver Nitrate and Potassium Chromate Solutions
Miscellaneous Lab Wastes
Laboratory Radiological Leach Solution (Hexone,
CC14)
a One-time Waste
                       3-22

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 (INEL 91). Tritium and carbon-14 specifications in this table are derived from
 Operational Safety Requirements, which set annual feed limits of 1000 Ci for H-3 and
 315 Ci for C-14, and assume 100% on-stream at a  feed rate of 400 Ibs/hr.  Fissile
 material at the WERF site is limited to 15 grams at any one time.  Tri-chlorofluoro-
 methane is specifically excluded from waste feeds.

 Waste acceptance criteria for WERF are undergoing a comprehensive review as  part of
 the program to prepare the incinerator for restart.   It is likely that the WAC information
 in Exhibits 3-11, 3-12, and Appendix E will change significantly (Reidesel).

 3.4.5  Controlled Air Incinerator (CAD (A-2)

 System Description and Status

 The CAI at Los Alamos National Laboratory (LANL) is a dual-chambered unit rated at
 1.5 million Btu/hr.  The off-gas treatment system includes an adiabatic saturation  quench,
 high-energy venturi scrubber, packed-bed absorber/demister, off-gas reheater, primary
 bank of HEPA filters, carbon bed adsorber, secondary HEPA filter, parallel ID fans, and
 stack. The primary HEPA filter bank contains four modules, two of which are
 operational while two are standby.  Each module contains a prefilter, a primary HEPA
 filter, and a secondary HEPA filter in series.

 The CAI began operation in 1979, was granted a TSCA permit in 1984, completed a
 RCRA trial burn in 1986 and has been shut down since  1987 for a complete  facility
 upgrade.  Operation is expected to resume in 1995. This is the only unit in the DOE
 complex capable of incinerating TRU wastes.

 Waste Handling and Acceptance Criteria

 The CAI can handle a broad range of liquid and low-density solid feeds including LLW,
 TRU, mixed waste, and waste containing PCBs.  Solid wastes are packed in 1' x  1' x 2'
 cardboard boxes. An x-ray unit is used for inspection of boxes of solid wastes for free
 liquids or non-combustibles prior to feeding.  Waste boxes are placed in a glove box,
 moved onto the side-ram elevator platform, and raised into  position in front of the main
 feeder ram. Boxes are fed one at a time at a predetermined rate into the incinerator.
 Liquids can also be injected through a burner or nozzle into the incinerator when solids
 are not being fed.

 The typical solid waste feed is 35% cellulose, 12% PVC, 23% polyethylene and 30%
 polyisoprene with a heat content of 6,900 Btu/lb. The heating value of any listed
 hazardous wastes in the feed stock must be at least 0.24 kcal/g (432 Btu/lb) if the
 concentration of the listed waste exceeds 0.01%.  When the heating value is too low,
 liquid feeds can be blended with diesel oil to meet this specification.  Quantities of tri-
 chloromonofluoromethane (Freon 11), tribromomethane, and dichlorodifluoromethane
 (Freon 12) in the waste feed are limited to 0.01%.  The physical forms of permitted
wastes include gases, liquids, solids and sludges.
                                       3-23

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Each batch of waste scheduled for incineration must be physically surveyed to determine
its radionuclide content; process knowledge is not acceptable.  Liquid wastes must be
analyzed to determine metals content, and the metals content must be sufficiently low
that the emissions screening limits specified in EPA "Guidance on Metals and Hydrogen
Chloride Controls for Hazardous Waste Incinerators," Vol. IV, March 1989 are not
exceeded.  The emission levels assume a facility in complex terrain with adjustment for
effective stack height.  Process knowledge can be applied to no more than 80% of such
wastes.

The chlorine content of the wastes,  plus that in any fuel which is simultaneously burned,
is limited to 99.4 pounds per hour.  In addition, the feed rates for liquid and solid
hazardous wastes are limited to ensure that the maximum thermal input does not exceed
1.5 million Btu/hr.

Allowable EPA waste codes include D001 (ignitables), D012 (Endrin), D016 (2,4-D),
F001-F005 (spent solvents), F027 (chlorophenols), F028 (soil treatment residues), and a
large number of listed U and P wastes.  Because of its size and design, this unit will not
play a major role in  processing ER  wastes.

3.4.6  Mound Glass Melter (A-6)

System Description and Status

Mound Laboratory operates a joule-heated glass melter. The melt chamber is 7' x 4' x
3.5' high and uses soda-lime-silica cullet as feed.  The off-gas treatment system  includes
a quench chamber, high-efficiency venturi scrubber, cyclone demister, a multistage bank
of HEPA filters, ID  fans, and stack.

The unit was placed in operation at the beginning of 1982.  In the past, it has been used
for limited processing of low-level wastes. Application has been made to the state of
Ohio for a RCRA permit, and full permitted operation is expected in 1993.

Waste Handling and Acceptance Criteria

Waste is fed  into the furnace through a port in the melt-chamber ceiling. Scintillation
vials are  crushed and fed into the furnace via two glove boxes.  One glove  box has a
water-cooled screw feeder and the other has a vibrating screw feeder (for IX resins).
Liquid wastes are injected directly into the furnace.

At this time,  formal  WAC for  the glass melter at the Mound Plant have not been
developed. Current  plans for the unit call for the processing of limited quantities of
mixed waste  and hazardous waste which have been or will be  generated on site.  This
includes vials of scintillation fluids in inventory, combustible solids, some oils, and some
Spent solvents.  Limited future generation is expected, and the available backlog should
be destroyed in about six years together with annually generated wastes (HAZWRAP).
There are no plans to burn imported low-level wastes in the glass melter although this is
                                        3-24

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deemed feasible and is so indicated in the WMIS data base. This unit will probably not
be used significantly for treatment of ER wastes.
3.4.7   Consolidated Incineration Facility (A-7)

System Description and Status

The unit planned for the Savannah River Site (SRS) is a 8 ft diameter x 25 ft long rotary
kiln incinerator rated at 18 million Btu/hr. The off-gas treatment system for the
Consolidated Incineration Facility (GIF) includes a spray adiabatic saturation quench
chamber, steam-driven free jet scrubber, cyclone separator, mist eliminator, reheater,
HEP A filter bank, ID fans, and stack.

Construction of the CIF has been deferred for several years due, in part, to the time
required to negotiate a  RCRA Part B permit with regulatory authorities.  The permit was
granted in September 1992, and SRS estimates that 39 months will be required for
construction, pre-operational check out, completion of the trial burn,  and .other startup
activities. This would put the start of normal operations at the beginning of 1996.

Waste Handling and Acceptance Criteria

The CIF unit will be fed low-level, mixed  and hazardous wastes including solids, sludges,
organic liquids, and aqueous liquids.  Solid wastes include filtered solids from paint
thinners, sludges and other chlorinated and non-chlorinated organics.  Major solids will
be rags, plastic and cloth work suits, shoe covers, PVC sheeting, mops, and floor cleaning
equipment.  Other solids include solvents, pesticides, and herbicides on absorbent
material and limited amounts  of contaminated soils.  Liquid wastes include solvents,
machine cutting and extrusion press oils, paints and thinners, motor and compressor
lubricating oils, lab wastes, pesticides, herbicides, and organic process waste streams.
Solid  wastes will be transported to the CIF in closed incinerable containers which are
placed on a conveyor, checked for radiation rate, weighed, x-rayed for foreign objects,
and assayed for radioisotope content.

Aqueous waste (mainly  sump waste) will be stored in a 6,500-gallon tank. Radioactive
benzene will be received by pipeline from storage tanks at the Defense Waste Processing
Facility (DWPF). Two  4,300-gallon agitated, insulated, and temperature-controlled tanks
for hazardous waste blending and feeding will also be provided.

Because the rotary kiln  incinerator at SRS will probably not be operational until early
1996,  detailed waste acceptance criteria have not yet been developed. However, a
general outline of acceptable wastes is available.  The CIF will  accept only wastes
generated at SRS. This will include low-level, mixed, and hazardous wastes in the form
of solids, sludges, organic liquids, and aqueous liquids.  A major feed will be
contaminated benzene from the DWPF. Although the kiln is capable of accepting soils,
operators do not plan to process significant quantities of such materials for two reasons:

                                        3-25

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       •     The backhoe device which removes wet ash from the ash pit has a limited
             capacity (250 Ibs/hr), based on ash density from burning paper and plastics;
             and

       •     There is concern about slagging fostered by soil constituents.

Waste acceptance criteria will be based on operating the GIF as  a Low-hazard Nuclear
Facility.  This decision, in turn, establishes allowable limits on the radiological and
hazardous chemical inventories at the facility (SRS 91).  In the event of a serious
accident involving release of waste inventory, personnel exposure would be within
acceptable limits. During operation a computational approach is used to set the
acceptable quantities of individual radioisotopes and chemicals which can be present at
the GIF at any one  time.  Separate inventories are established for the tank farm and for
the incinerator system.

For the tank farm, an accident resulting in release of the waste inventory must not
expose an individual 100 meters  away to a 50-year committed dose of more than four
rem.  ICRP-30 guidelines are used in this analysis. The analysis assumes a source
reduction factor of unity for tritium and 0.01 for all  other radionuclides during a two-hour
duration release. Exhibit 3-13 lists the acceptable radionuclides and the respective dose
conversions  adjusted by the appropriate source reduction factor.  The corresponding site
boundary exposure from this postulated release would be 0.007 rem.
                                    Exhibit 3-13

                      Sample Fissile Material Calculation - GIF
Nuclide

U-233
U-235
Pu-239
Pu-241
Segment
Inventory
(Ci)
(A)
0
3.66E-05
3.22E-02
0
Specific
Activity
(Ci/g)
(B)
9.5E-03
2.1E-06
6.2E-02
1.1E+02
Mass
Amount
(g)
(C=A/B)
0
1.74E+01
5.19E-01
0
Conversion
Factor
(Ref. 10)
(D)
1.20E+00
l.OOE+00
1.60E+00
2.40E+00
Total (Must be < 600 grains)
Equivalent
U-235
Mass
(g)
(E=CxD)
0
1.74E+01
8.31E-01
0
1.82E+01
                                        3-26

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Chemical hazards from a tank farm accident are treated in a similar manner. The
exposure criterion is that the maximally exposed individual at 100 meters will be
subjected to an airborne concentration of no more than 50% of the Immediately
Dangerous to Life and Health (IDLH) value or 50% of the Emergency Response
Planning Guideline-2 value. The analysis assumes a source reduction factor of unity for
gases and volatile liquids and 0.01 for nonvolatile liquids, precipitated solids, and
dissolved solids during a 30-minute release.  Details are included in Appendix F.

Inventories in the incinerator building are set in a similar manner and consider dry boxed
waste, dry ash in  the incinerator unit, and wet ash.  These three sources are summed to
determine if the exposure to an individual at 100  meters exceeds 4 rem for the suite of
radionuclides or 50% of the IDLH value. Radionuclide source reduction factors,
assuming a fire in the GIF  building, are as follows:

       •     1.0  for tritium;
       •     0.01 for all nuclides in boxed waste  and fly ash and Ru-106 in wet ash; and
       •     1E-4 for all other nuclides in wet ash.

Inventory limits on fissile materials will be set based upon criticality considerations.  The
principal fissile element expected in the GIF wastes is U-235, but trace amounts of U-
233, Pu-239 and Pu-241 may also be present. As  illustrated in Exhibit 3-13, limits on
each isotope  are set such that the equivalent U-235 mass in either the tank farm or the
incinerator building does not exceed 600 grams.

3.5    WASTE AND RESIDUAL MANAGEMENT

An important consideration when reviewing  the waste acceptance criteria discussed above
is whether or not the various facilities can, within the terms of their permits, accept off-
site waste.  Of those DOE  incinerators with  clearly defined plans, only the TSCA
incinerator at K-25 accepts wastes from other locations15 (Portsmouth,  Paducah,
Fernald, Reactive Metals Inc. (RMI), ORNL, and Y-12).  Even though the TSCA
incinerator can handle off-site wastes, open  issues remain with the state of Tennessee
and other agencies about the disposition of residuals derived from wastes imported from
out-of-state.  Consequently, the near-term emphasis is on incinerating liquid wastes which
produce very little ash.

A recent paper presented by Ross et al. (MWTP  92a) categorized wastes that would be
processed under the proposed Mixed Waste Treatment Project (MWTP).  This study
demonstrated that about 98% of the mixed waste volume is generated at 12 DOE sites
(Fernald, K-25, ORNL, Paducah, Portsmouth, Y-12, Savannah River, Hanford, Rocky
Flats, Los Alamos, Lawrence Livermore, and INEL).  As noted above,  the first six sites
on this list are permitted to process their wastes at the TSCA incinerator, assuming that
certain ash management issues are resolved.  Incinerators exist at INEL and Los Alamos,
   15 It is not clear at this time whether WERF will accept off-site waste feeds. Limited off-site shipments have been
handled in the past (Reidesel).

                                        3-27

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 and construction has begun on the GIF at Savannah River.  If the planned FBU at Rocky
 Flats is not constructed, this would leave only RFP, Hanford and LLNL without mixed
 waste incineration capability among the 12 major sites.

 The remaining 2% of the mixed waste volume is distributed among 21 other DOE sites.
 Unless DOE's policy is to process waste on-site  at every mixed waste location, it could
 consider shipping the small quantities of waste from these minor generators to other
 facilities.  DOE could also consider shipping wastes from the three major generators that
 are without incineration capacity (i.e RFP, Hanford, and LLNL) to off-site facilities,
 assuming capacity is available. If this were done, about 815 m3 of inventoried combustible
 wastes plus 153 m3 of annually generated combustible waste would probably require  off-
 site processing.  This approach would require  broadening the WAC and the underlying
 permits at the selected  off-site treatment locations and dictate further consideration of
 packaging, labeling and transportation criteria.

 The two commercial facilities handle wastes from a variety of sources and have, on a
 limited basis, processed DOE wastes. An issue that the commercial facilities must
 address when handling DOE wastes is how to comply with DOE Order No. 5820.2A,
 "Radioactive Waste Management." The DOE policy outlined in this Order specifies that
 LLR/MW shall, if practical, be  disposed of at the generator's site, or if on-site disposal is
 not available, at another DOE site. Ensuring  that all hazardous and radioactive
 constituents contained in residuals are returned to the generator is not a  trivial matter.
 It will entail campaigning of specific waste shipments for isolation of resulting residuals.
 This campaigning may diminish or preclude the benefits from mixing compatible wastes
 for processing reasons, including throughput, use of auxiliary fuel, control of effluent
 concentration, etc.

 As plans now stand three facilities would be capable of processing TRU wastes: the
 existing CAI at Los Alamos, the proposed FBU  at Rocky Flats, and the proposed IWPF
 incinerator at INEL. PCB treatment capability would exist at the TSCA incinerator at K-
 25, the CAI, and the proposed FBU.

 Wastes from ER activities are expected to contain large amounts of soil, rubble and
 debris.  As noted previously, of those  incinerators currently in the DOE operational,
stand-by and planning base, the rotary kiln is best suited to treat these types of materials.
The GIF rotary kiln, however, does not plan to process significant quantities of soils,  and
the TSCA kiln requires  some modifications to  its solids handling system to effectively
process  significant quantities of such materials (IT 92). Thus, additional thermal
treatment capacity, particularly  rotary kiln capacity, may be needed to accommodate
these materials.

A variety  of "problem" wastes exist within the DOE Complex.  In some cases
pretreatment of these waste will be required to meet incinerator WACs.  For example,
certain PCB-contaminated wastes from the Y-12 Plant contain quantities of mercury and
                                        3-28

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uranium in excess of levels acceptable at the TSCA incinerator (i.e. >5 ppm U and >200
ppm Hg).  If these wastes were to be incinerated for PCB destruction, treatment to first
remove the metals contamination would be necessary.  Alternative waste management
strategies may need to be developed for such wastes.
                                      3-29

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                   4. SUMMARY AND DISCUSSION OF ISSUES

Though incineration has become a major waste management technology, its use is
controversial, particularly for hazardous, radioactive and mixed wastes.  Incineration does
not destroy all the toxic constituents of the wastes burned.  Heavy metals and
radionuclides, for instance, are not destroyed.  Instead, they either remain in the residual
ash or volatilize and become entrained in the off-gases. The entrained  contaminants are
then either removed by pollution control equipment or captured in the  residual ash. The
incineration process also may create new products of combustion, which may be toxic.
The possibility of hazardous and. radioactive emissions from routine operations or from
accidents, and the difficulties in disposing of ash containing concentrated contaminants,
have generated public opposition to incineration as a waste management technology.

Some existing incinerators have successfully addressed the above concerns and have
reduced the potential  for environmental risks to acceptable levels. However, if
incineration is to become a practical technology for treating LLR/MW and other wastes,
changes need to occur.  Regulators and operators need to assure the operational safety
of incinerators, to address legitimate concerns about the risks they pose to human health
and the environment.  Further, the public needs to understand and accept the technology
and the remaining risks. This chapter presents  specific operational and technical issues
identified through the survey described in the report, and discusses possible
improvements that can help achieve the goals just described.

4.1   OPERATIONAL ISSUES

Major operational issues according to the survey results include permitting process
complexities, the cost-effectiveness of DOE versus commercial  incinerators, and
inaccuracies reported  in waste manifests. A lack of consensus on risk assessment
methods and difficulties in communicating risks to the public pose additional challenges
that must be faced if incineration is to become  an accepted treatment technology for
LLR/MW.

4.1.1  Permitting Process Complexities

The permitting process is one major constraint  on incinerator operations. Most facilities
surveyed, whether in the public or  the private sector, expressed concern about the
complex process required to obtain a permit for construction and operation of a
LLR/MW incinerator.  For Federal agencies, the process  is further complicated by
coordination requirements within the department and among facilities, and the time
involved in securing Congressional  funding.  For DOE in  particular, an  additional
constraint is that the modifications and retrofitting which  DOE facilities have undergone
make permitting more difficult than it is for new facilities constructed specifically to
process large volumes of waste. Finally, at the  permitting agencies, frequent staff turn
over and the dynamic nature of relevant regulations add to the difficulty of the process.
It appears that more coordinated effort among  Federal agencies is needed to effectively
address complexities of the permitting process.  One  approach for this coordination
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would be the establishment of a national, interagency team (including DOE, EPA, and
other Federal agencies), to address incinerator permitting issues specific to LLR/MW.

4.1.2  Cost-Effectiveness of Public vs. Private Incinerators

The incinerator operating procedures of the private sector and DOE differ greatly.
DOE's existing incinerators are relatively small, able to process small quantities of wastes
from particular sites rather than provide a large incineration capacity for the entire
Department. The cost per unit of waste processed by these small incinerators is
relatively high — they must be permitted individually, they have required  expensive
modifications and retrofittings to meet DOE's growing demand for incineration capacity,
and they cannot operate with the same  efficiency of larger-scale systems.  The private
sector, on the other hand, has been able to move forward more quickly with fairly large-
scale incinerators.  As a result, the cost per unit of waste processed is often lower at
commercial than at DOE facilities.

To alleviate this cost disparity, greater use of private-sector LLR/MW incinerators could
be considered for more cost-effective waste handling, especially for smaller DOE  and
other Federal facilities.  Such an approach would require DOE to revise  its current
requirement that LLR/MW and its residuals be disposed at the generator's site or
another DOE site  (See Section 3.5).  Alternatively, DOE could consider constructing
fewer incinerators  of larger scale.  Further study is needed to analyze these choices.  For
example, the permitting and operating cost savings that may be realized from a few large
incinerators would need to be weighed against potentially greater transportation costs
and risks.

4.1.3  Waste Manifesting Practices

Several of the survey sites reported that waste generators tend to overstate the levels of
radioactivity in their waste. For instance, generators may report the highest obtained
reading rather than an average when surveying a waste container.  If waste manifesting
practices consistently overstate radioactivity levels, then the estimates and public
perceptions of radiation risks from LLR/MW incineration may be needlessly inflated.
However, given the uncertainty of radiation measurements and risk assessment methods,
conservative assumptions may be appropriate to avoid understating risk.  DOE and EPA
should assess waste manifesting practices to ensure consistency and the appropriate
degree of conservatism.

4.1.4  Risk Assessment and Communication

Risk assessment is an essential step in determining the potential hazards  of incinerator
emissions to human health and the environment.  The appropriate risk assessment
methodology to use is a major issue, both within and outside the government.  EPA
alone has prepared numerous publications on various aspects of the process (see
references EPA 86a through EPA 91b in the reference list). The variety of
methodologies can lead to discrepancies in risk assessment results.  To address these
                                         4-2

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discrepancies, DOE could monitor attempts by outside groups to reach a consensus on
the appropriate risk assessment methodologies. Consideration also could be given to the
formation of a special task force, including top EPA and DOE risk assessors and
members of the scientific community, to reach consensus on major issues regarding risk
assessment methods.

Another issue related to risk assessment is the best way to communicate risk estimates to
the public. The mention of "radiation exposure" normally evokes concern and sometimes
fear in the public, regardless of the magnitude of the risks involved.  Moreover, people
are especially concerned about risks that they cannot control (i.e., involuntary risks), such
as the risks associated with environmental releases from LLR/MW processing. While risk
assessments may establish a scientifically credible basis for risk estimates, they are
difficult for the lay public to understand and appreciate. In addition, the public often
distrusts or rejects risk assessments as being highly uncertain and speculative, or simply
an attempt to technically justify a preordained decision. Dealing with public perception
requires development of the necessary program and tools for effectively communicating
risk to affected members of the public.  This includes  preparing materials and holding
public meetings to present information simply  and in a way that will reach target
audiences.

4.2   TECHNICAL ISSUES

The survey results indicate that the primary technical  issues associated with LLR/MW
incineration relate to emissions controls and mechanisms to detect and respond to
accidents.  In particular, the survey identified the following specific technical issues:

       •     HEPA filters;
       •     Emissions monitoring and process measurement;
       •     Management of residuals; and
       •     Systematic measurement of metals and radionuclide partitioning.

4.2.1   High-Efficiency Particulate Air Filters

Most of the currently operating, on stand-by and planned incinerators described in this
report use High Efficiency Particulate Air (HEPA) filters to remove particulate matter
from  off-gas. The HEPA filter medium is paper-based. Discussions with managers  of
currently operating and recently operated systems including WERF, DSSI, and SEG
indicate that properly designed, maintained, and operated HEPA filter systems show no
operational problems.  However, in spite of these satisfactory operational reports, some
concern may remain about using a combustible filter medium downstream of a
combustion system. In particular, the public may perceive it as being be undependable
and needlessly risky.

To allay these concerns, there has been considerable research and development over the
last several years to develop a non-combustible, sintered-metal filter equivalent in
performance to a conventional HEPA filter.  For example, LLNL has initiated testing of
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 a sintered-metal HEPA filter on a uranium grit blasting system. LLNL also compared
 the current filter structure to the particle size distribution found in incinerator off-gas,
 and concluded that the particulates would become deeply imbedded in the filter medium,
 making it impractical to clean (BER 92). Additional development work is needed to
 improve the structure of the sintered-metal filter to the point where such  filters can be
 field tested in an incinerator system.  Continued development, testing, and demonstration
 of sintered-metal filters also needs to be monitored.

 4.2.2  Emissions Monitoring and Process Measurement

 Monitoring incinerator operations is critical to ensure that routine emissions comply  with
 permissible (regulated)  levels.  A monitoring system that includes a detection system also
 provides an early warning of abnormal conditions (such as accidents), which may allow
 operators to prevent excessive emissions. Incinerator off-gas characteristics can be
 determined in two ways:

       •     Certain parameters are monitored continuously (continuous  emissions
             monitoring,  or CEM)16 and, through an appropriate control system,
             corrective actions such as waste feed cut-off are automatically implemented
             if a parameter departs from its prescribed limits.  Physical parameters such
             as temperature, flow rate, and opacity are often monitored in this way.
             Chemical  parameters that are frequently monitored continuously (and
             periodically  sampled) include oxygen, carbon monoxide, hydrocarbons,  acid
             gases, and NOX.

       •     Components of the off-gas such as particulates, heavy metals, and
             radionuclides (which may also include heavy metals) can be  sampled by an
             isokinetic  sampling system mounted in the exhaust stream and analyzed
             periodically.  Such a sampling and analysis program is conducted at
             intervals prescribed by the  regulatory agencies. Because this information is
             not available in real time, it cannot be used  to respond to system upsets.

Traditionally, many scientists and regulators have considered CEM the best and most
desirable form  of monitoring to ensure compliance with emissions limits.  Under RCRA
regulations, CEM is required for several  parameters at hazardous waste incinerators  (40
CFR Part 264,  Subpart  O).  Similarly, under the BIF requirements (which technically do
not apply to incinerators, but may be used for incinerators by permit writers) also require
continuous monitoring of CO and a number of other parameters.

Continuous monitoring of CO emitted from LLR/MW incinerators is required to ensure
that the combustion efficiency remains high.  After years of combustion research, EPA
has concluded that CO emissions are a conservative indicator of combustion conditions,
   16 Depending on the parameter being analyzed, CEM systems consist of a pollutant concentration monitor and sometimes
an emissions flow monitor, combined with an automated data acquisition and handling system for continuously measuring
and recording emission parameters.

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and that low CO emissions (less than 100 ppm on a rolling hourly average, corrected to
7% O2 on a dry volume basis) indicates high organic destruction and removal efficiency
(DRE) and low emissions of products of incomplete combustion (PICs). The converse,
however, is not always true; CO emissions greater than 100 ppm do not necessarily
indicate low DRE and high PIC emissions.  EPA has thus implemented a two-tiered
approach for control of PIC emissions, requiring continuous hydrocarbon (HC)
monitoring as an additional condition to determine PIC emissions when the CO exceeds
100 ppm.

Although CO is a very conservative indicator of the effectiveness of the incineration
process, it may also be desirable to measure individual organic species in the off-gas
directly.  Researchers at Argonne National Laboratory are studying the use of fourier
transform infrared spectroscopy (FTIR) to continuously monitor incinerator off-gas for
organic species (1C 89D,  1C 91).  Recent work, which was reported at the 1992
Incineration Conference,  has demonstrated that the process also works well on
chlorinated hydrocarbons. DOE planned to fund a test on an operating incinerator in
1992 (DEM 92).

Sandia Livermore National Laboratory recently began a program to study the feasibility
and detection limits for a continuous metal emission monitoring system based upon laser
spark emission spectroscopy (BRG 92). Initial work will  involve metals in aerosols and
will seek to demonstrate the sensitivity of the method.

The need exists to develop, test, and standardize monitoring methods for radionuclide
emissions. Incineration systems should incorporate monitoring devices both at the point
of emission from the stack and at earlier stages of the incineration process.  This will
allow early warning of filter breakthrough before the final filtering stage or stack release,
and allow shutdown before operations cause undue risk.

Further research and development is  needed for both CEM and periodic sampling of
LLR/MW incinerator emissions.  EPA and DOE should continue to monitor FTIR
development, testing, and demonstration for continuous emissions monitoring of
speciated organics, as well as the development of laser spark emission spectroscopy for
continuous emissions monitoring of metals.

At the same time, an automated and/or more frequent periodic sampling and analysis
program is a necessary complement to CEM.  At present, filter sampling and counting
methods allow detection of radionuclides at levels  4 to 6  orders of magnitude below that
of CEMs and should continue to be used  for more accurate measurement of actual
releases and assessment of risks from incineration.

4.2.3  Residuals Management

A key, but often under-emphasized, element in the safe and effective use of incineration
as a waste treatment process is management of the process residuals.  Incinerator ash is
usually the most prominent of the residuals. The main component of incinerator ash is

                                        4-5

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bottom ash discharged from the primary and secondary combustion chambers. Lesser
quantities of fly ash are collected from heat  exchangers, baghouses, and other devices.
Other wastes that must be considered include scrubber dry solids or blowdown liquids
and sludges, and spent HEPA filters.

Ash is not a hazardous waste if the waste treated in the incinerator was considered
hazardous solely because it exhibited a characteristic, and that characteristic was
destroyed during incineration.  However, if the incinerator is treating a mixed waste
where the hazardous component is a listed waste, then under the RCRA "derived-from
rule," the ash is also a listed waste unless it is subsequently delisted.17

In addition, the concentration of metals and radionuclides in the ash will be higher than
in the waste feed because of the substantial volume reduction inherent in the incineration
process. Thus, it is possible that when treating a waste that is not a hazardous waste, the
concentrating effects of the incineration process  may result in ash that is a hazardous
waste.  In either case, incinerator residues often  will require additional treatment to
remove or limit the mobility of metals. Post-incineration treatment may include
stabilization, solidification,  vitrification, extraction, or another treatment process that
allows the residue in final form to comply with LDRs and be placed in a secure landfill
for final disposal. Coordination and collaboration among appropriate entities (EPA,
DOE, NRC, etc.) is needed to  develop specific guidelines and procedures for identifying
appropriate regulatory requirements for the  management of incinerator residuals, as  well
as acceptable methods for  treating and disposing of the residuals.

4.2.4  Systematic Measurement of Metals and Radionuclide  Partitioning

The recognition that emissions  of metals and radionuclides from incinerator stacks can
represent a significant health and environmental risk has led to a considerable amount of
research to better characterize  the way they  partition between the various incinerator
effluents (off-gas, bottom ash, fly ash,  scrubber blowdown, etc.). Attempts to obtain  a
metals mass balance throughout the incinerator/APC train18 have so far proven difficult
(WAT 91). Further research and development activities are  needed to improve the
analysis of metals and radionuclides mass balance, possibly using non-radioactive isotopes
as surrogates for radioactive constituents.  Consideration could be given to sampling
before and after each piece of equipment in the incineration/APC train to determine the
partitioning of metals and radionuclides into different residual effluents.  Also, the
effectiveness of HEPA filters in reducing metal and radionuclide emissions from
incinerators could be measured.
   17 In Shell Oil v. EPA. No. 80-1532 (D.C. Cir. Dec. 6, 1991) the mixture and derived-from rules were vacated and
remanded to EPA for failure to provide adequate notice and opportunity for comment before their 1980 promulgation. In
response to the remand, EPA published an interim final rule in March 1992, which reinstated these rules until April 28,1993.
EPA is considering a number of alternative rulemaking options on hazardous waste identification that may affect waste
mixtures and residues.

   18 That is, to trace all the metals and radionuclides in an incinerator's inputs and determine their distribution in its
outputs.

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4.3    CONCLUSION

Incineration is a critical component of DOE's LLR/MW management strategy.  Though
the technology has been refined and its use has increased over the past decade,
additional work is required to ensure that it is a practical and accepted technology.
Resolution of remaining operational and  technical issues presented in this report is a
critical component of this effort. These issues are intended to facilitate discussion and
can serve as a starting point.
                                        4-7

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APPENDIX A-l
APPENDIX A-2
APPENDIX A-3

APPENDIX A-4
APPENDIX A-5
APPENDIX A-6
APPENDIX A-7
APPENDIX A-8
            APPENDIX A
        Incinerator Survey Forms

INCINERATOR SURVEY FORM	A-2
CAI-LANL	A-4
DSSI COGENERATION MIXED WASTE FUELED
BOILER	      A-10
K-1435 TSCA - ORGDP	'.'.','.'. A-15
WERF-INEL	   A-20
MOUND GLASS MELTER	 A-25
CONSOLIDATED INCINERATION FACILITY	 A-29
SEG INCINERATOR .	A-36
                               A-l

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                                 APPENDIX A-l
                         INCINERATOR SURVEY FORM

                     RADIOACTIVE AND MIXED WASTES
1.    KEY CONTACTS (name, address, position, telephone)

2.    SYSTEM DESCRIPTION

      A.    Waste Handling (including segregation, weighing, assay, feed types, etc.)
      B.    Incinerator (type, capacity, operating parameters)
      C.    Off-Gas Treatment
      D.    Off-Gas Monitoring
      E.    Ash Handling and Disposal
      F.    Ash Monitoring
      G.    Liquid Effluent Handling
      H.    Liquid Effluent Monitoring
      I.     Safety Systems and Redundancies
      J.     Planned Modifications (nature, reason for, schedule, cost)
      K.    Permit Types and Requirements

3.    OPERATING HISTORY

      A.    Preliminary Planning (basis for system and component selection, alternate
            approaches considered)
      B.    General Chronology (startup, trial burn, steady state, etc.)
      C.    Description of Upsets, Accidents and Corrective Actions
      D.    On-Stream Analysis - (actual versus nameplate capacity, on-stream time-
            historical and expected in future.)
      E.    Radionuclide Mass Balance
      F.    Staffing
      G.    Operating Cycle
      H.    Waste Disposal Issues (HEPA filters, scrubber liquor, etc.)

4.    OPERATING AND MONITORING PRACTICES (Current and Planned
      Changes)

      A.    Waste Classification and Handling  Procedures
      B.    Ash and Liquid Effluent Management
      C.    Stack Monitoring
      D.    Response to System Upsets (inc. management responsibilities, notifications,
            evacuation plans etc.)
      E.    Operator Training
      F.    Incinerator and APC System Operation
      G.    Maintenance Procedures (inc. special problems, high maintenance items)
                                      A-2

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7.
H.    Contingency Plans
I.     Operating and Maintenance Costs
J.     Environmental Monitoring

WASTE FEEDS

A.    Description - (type [LLW, Mixed, TRU], physical form, chemical character,
      nature and quantity of radionuclides)
B.    Source - (location, waste producing process)
C.    Quantity - (in inventory, currently produced, expected future production)
D.    Waste Acceptance Criteria - (current, planned changes, reasons for change,
      impact on feeds)

STACK MONITORING DETAILS

A.    Current Stack Sampling Procedures
B.    Laboratory Analysis - (instrumentation used, limits of detection and
      sensitivity, QA/QC procedures, analytical interferences effecting
      radionuclide mass balances)
C.    Prospects for Real Time Radioactive Emissions Monitoring

OTHER ISSUES

A.    Public Outreach
B.    Adverse Public Reactions (including state and local government
      involvement)
C.    Risk Assessments
D.    Regulatory and Permitting Requirements
                                       A-3

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                           APPENDIX A-2
                   INCINERATOR SURVEY FORM

                            CAI - LANL
KEY CONTACTS

Los Alamos National Laboratory
Los Alamos, NM, 87545

Stan Zygmunt (505) 667-7391
SYSTEM DESCRIPTION

A.    Waste Handling
      American Science and Engineering 90 kv x-ray unit for inspection of boxes
      of solid wastes for free liquids or non-combustibles.  Jomar Systems
      multiple energy gamma assay system for TRU isotopic species and
      concentrations.  Waste boxes placed in glove box and moved onto side ram
      elevator platform and raised into position in front of main feeder ram.
      Feed one box at a time at predetermined frequency into incinerator.

B.    Incinerator
      Dual chamber CAI (modified Environmental Control Products model  ECP
      500-T), designed by Joy Energy Systems  for solid and liquid waste feed.
      Incinerator is rated at 1.5 million Btu/hr for either solids or liquids (which
      are not fed simultaneously). Primary chamber operates at 1400 - 2000° F
      while secondary chamber operates at 2000 - 2200° F. No waste feed into
      secondary chamber. For fast shutdown 100 Ib/hr of steam is available for
      snuffing primary chamber.

C.    Off-Gas Treatment
      Components include water spray quench column to cool gases from 2000 -
      2200° F to  about 160° F, high energy venturi scrubber,  counter-current
      packed column absorber/demister, offgas superheater, primary HEPA
      filters (99.97% removal at 0.3 microns), carbon bed  absorber for residual
      organics, secondary HEPA filters, parallel ID fans, and vent stack.  Primary
      HEPA filter bank contains four modules, two of which operate in parallel
      and two are serve as backup. Each module contains a prefilter, a primary
      HEPA filter and a secondary HEPA filter in series.

D.    Off-Gas Monitoring
      Offgas sampled for CO, CO2 and water at station upstream of ID fans.
      Continuous stack monitoring system involving pseudo-isokinetic sampling
                                A-4

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      head and filter analyzed weekly for radionuclides.  Note that this stack also
      is the exhaust for room ventilation air which accounts for about 10,000
      acfm as compared to the incinerator which contributes about 1200 acfrn.

E.    Ash Handling and Disposal
      Ash from primary combustion chamber falls into an air-cooled hopper and
      then through two knife gate valve module into 55 gal drums.  After assay,
      ash is solidified in drum cementation  process with the details yet to be
      determined.

F.    Ash Monitoring
      Ash assayed for radionuclides and analyzed chemically.  Segmented gamma
      scanning used to measure TRU content of ash.

G.    Liquid Effluent Handling
      Scrub solution from quench, venturi, and packed column units is collected
      in sump tank, passed through a hydrocyclone for particulate removal,
      cooled in a heat exchanger and recirculated to the process. Slowdown is
      filtered through polypropylene filter bags and discharged into an on-site
      liquid waste treatment plant.

H.    Liquid Effluent Monitoring
      Blowdown sampled prior to discharge to on-site waste treatment plant.

I.     Safety Systems and Redundancies
      Automatic shutoff of waste feed if process upset or failure occurs. Feed
      cannot be restarted until proper operation is restored. System has
      uninterruptable power supply with diesel generator, and pressurized water.
      tanks to backup municipal water supply. Redundant pumps are provided
      for scrub solution circulation.  HEPA filter redundancy described in 2C
      above.  Building HEPA system provides additional backup.  Pressure drop
      across HEPA filters is continuously monitored and tied to high pressure
      alarm  which indicates need to switch from one bank to the other. Low
      pressure drop indicates breach of HEPA and need to switch to building
      HEPA system.

J.    Planned Modifications

K.    Permit Types and Requirements
      TSCA, NESHAPS (laboratory-wide), RCRA (State of NM).
                                 A-5

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       OPERATING HISTORY

       A.    Preliminary Planning

       B.    General Chronology
             Cold testing and modification from  1976 - 1980.
             Operation begun in  1979.
             TSCA permit granted in 1984.
             RCRA trial burn in  1986.
             Facility in standby mode for upgrade since 1987.
             RCRA permit from  state of New Mexico Health and Environment issued
               November 8,  1989

       C.    Description of Upsets and Accidents and Corrective Actions
             Superheater moved further upstream from HEPA filter bank to minimize
             filter blockage by liquid droplets. This provides about 1 sec of residence
             time in duct for droplet evaporation prior to HEPA bank.  Severe chloride
             corrosion found in impellers and housings of original ID fans.  Fans have
             been replaced with new units containing galvanized internals and
             incinerator shutdown procedures have been modified to eliminate post-run
             condensation in blowers.

       D.    On-Stream Analysis

       E.    Radionuclide Mass Balance
4.     OPERATING AND MONITORING PRACTICES

      A     Waste Classification and Handling Procedures
             Solid wastes packed in 1x1x2 ft cardboard boxes and shipped in DOT
             approved metal containers holding 32 boxes. Containers opened and
             checked for surface alpha.  No solid waste sorting operation; waste
             packages not accepted for incineration returned to generating group. Pu in
             CAI process administratively controlled to 400 g (400 g X 0.0714 Ci/g =
             28.56 Ci of alpha activity).  Combustible mixed waste liquid inventory
             limited to 4230 gal.

      B.     Ash and Liquid Effluent Management
             Ash handling system can accommodate large clinkers and non-combustibles
             up to about 12" dia. Ash from burning listed wastes must be cemented
             before disposal. Scrub solution is routinely monitored by specific gravity
             for build up of salts and when level reaches 1.03 blowdown is initiated.
             Scrubber solution continuously monitored for Ph and recycle water flow
             rate.  Liquid effluents and filters must be disposed of as hazardous wastes.
                                       A-6

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5.
C.    Stack Monitoring
      Continuous monitoring and/or recording devices observed hourly during
      waste feed operations and observations recorded.  Parameters include CO,
      total hydrocarbons and radioactivity. The CO limit is 100 ppmv with an
      allowable 5 minute excursion to 500 ppmv.  THC limit is 20 ppm for one
      hour rolling average with allowable excursion to 100 ppm for one minute
      max. and single reading of 500 ppm. Radioactivity may not exceed
      background by more than 10 % with allowable excursion to 50% above
      background for no more than one minute.

D.    Response to System Upsets
      Three shutdown modes (controlled, fast and scram) are provided with
      automatic and/or manual initiation. Loss of primary water supply initiates
      controlled shutdown of incinerator.

E.    Operator Training

F.    Incinerator and APC System Operation
      Approximately 70 process parameters monitored on real time basis
      including waste feed rate, primary combustion chamber temperature,
      secondary combustipn chamber temperature, SCC oxygen content, and
      combustion air flow.

G.    Maintenance Procedures
      Carbon absorber materials must be replaced every 2000 hours per RCRA
      permit. Automatic cutoff system must be tested every 2000 operating
      hours.

H.    Contingency Plans

I.    Operating and Maintenance Costs

J.    Environmental Monitoring
      LANL maintains 25 air monitoring stations in vicinity of lab as well as
      stations for ground water, surface water and soils monitoring. Incinerator
      building monitored and sampled for airborne releases  of alpha radioactivity
      using continuous air monitors and fixed head sampling devices.

WASTE FEEDS

A.    Description
      Primarily solid TRU waste (i.e. >100 Nci/g - mostly Pu-239 contamination)
      such  as rags, rubber gloves, booties, cheese cloth, etc.; some solid and
      liquid LLW and Mixed Wastes containing TRU isotopes; RCRA/TSCA
                                       A-7

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7.
       wastes.  Typical solid waste is 35% cellulose, 12% PVC, 23% PE and 30%
       polyisoprene with a heat content of 6900 Btu/lb. RCRA permit states that
       gases, solids, liquids and semi-solid sludges may be incinerated.  Chlorine
       content  of waste plus fuel for each batch must not exceed 99.4 Ibs/hr.

 B.     Source
       LANL only per RCRA permit.

 C.     Quantity
       See Tables 1-7 and 1-8 Radiation and Mixed Waste Incineration Report
       Volume 1.  (Ref. 3)

 D.     Waste Acceptance Criteria
       Maximum concentration of radioactivity in waste feed matrix limited to
       15000 nCi/g.

 STACK MONITORING DETAILS

 A.     Current  Stack Sampling Procedures
       Monitor for Pu-239 - alpha and mixed fission products - beta (weekly or
       monthly).  Pu-239 concentrations are  generally less that the lower limit of
       detection, and, when detected, almost always run at less than 10% of the
       MPC (in the period 1980-1990 one measurement was noted as high as
       25.5% of MPC).  This includes other  sources than just the incinerator.
       Total Pu release from 1979 through 1989 YTD was  0.4746 uCi.  Similarly
       the total release of mixed fission products from 1981 to 1989 YTD was
       8.846 uCi. (See Table TA-50-37 attached.)  Annual emissions of Pu and
       mixed fission products were 2 to 5 orders of magnitude below Radiation
       Concentration Guide limits in every year.  See Tables 1-15, 1-16, 1-17 and
       1-18 Radiation and Mixed Waste Incineration Report, Volume 1 for more
       details.

B.     Laboratory Analysis

C.     Prospects for Real Time Radioactive  Emissions Monitoring
       Looking  into purchase of Berthold LB-150-D Alpha/Beta particulate
       monitor  (or a continuous alpha monitor) as on-line check for HEPA filter
       integrity.

OTHER ISSUES

A.     Public Outreach
       Community meetings on incineration held in Los Alamos, Taos, and Santa
       Fe.
                                       A-8

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8.
B.    Adverse Public Reactions
      Citizens group protested lack of regulations by state of NM for incineration
      of radioactive wastes and the fact that environmental impact statement on
      incineration not prepared. Complained that Dallas Region of EPA is
      responsible for ongoing inspection and Dallas is too far away.

C    Risk Assessments
      Assessment of Radiation Doses and Resulting health Risks from the
      Controlled-Air Incinerator, Thomas Buhl - LANL, July 1989.

D.    Regulatory and Permitting Requirements

REFERENCES
Hazardous Waste Incineration at Los Alamos National Laboratory, LALP-89-30, July,
1989.

Letter From Charles V. Warner - Waste Management Group LANL to Richard Mayer
U. S. EPA Dallas TX dated August 23,  1989 with attachments.

Radiation and Mixed Waste Incineration Background Information Document Volume 1:
Technology, EPA 520/1-91-010-1, May 1991.

Hazardous Waste Facility Permit issued by State of New Mexico Health and
Environment Department, Environmental  Improvement Division dated November 8,
1989.  Permit NM 0890010515-1.
                                      A-9

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                           APPENDIX A-3
                   INCINERATOR SURVEY FORM

     DSSI CQGENERATION MIXED WASTE FUELED BOILER
KEY CONTACTS

Diversified Scientific Services, Inc.
P.O. Box 863
Kingston, Tennessee 37763
(615) 376-0084

James T. McVey, Executive Vice-President
Larry L. Hembree, 'Customer Service Representative
Joe Crider - Plant Manager

SYSTEM DESCRIPTION

A.    Waste Handling
      Feed is solvent waste containing low-level radioactivity. Wastes include
      D001, F001-005 plus numerous D, U, and P listed materials.  Solvents may
      not contain halogens or heavy metals.  Vials or containers of glass and
      plastic are crushed and the solvents separated and transferred to one of
      seven 250 gal. holding tanks for testing. If materials meets WAC, it is
      transferred to one of three 10,000 gal. carbon steel storage tanks for feed
      to boiler.  The crushed container material is washed with solvent and after
      radiation survey is sent to an outside recycle facility.

B.    Incinerator
      York-Shipley mixed waste  fueled boiler (three-pass) using natural gas as
      auxiliary fuel.  Boiler drives Seeco electrical generator.  Boiler rated at 16.5
      million Btu/hr max.  Minimum boiler operating temperature is 1800° F with
      1 second combustion chamber dwell time. Boiler limited to 14.5 million
      Btu/hr by state air permit.

C.    Off-Gas Treatment
      APC system consists of semi-dry scrubber (quench tower, packed  column
      scrubber, and baghouse), prefilter (95 % eff.), HEPA filter (99.97 % eff.)
      and  carbon adsorber.  Particulate emissions limited to  3.09 Ibs/hr and stack
      opacity may not exceed 20%.  Gas exhausted through stack which is 30 feet
      high, 3.25 ft in dia, with a volume of 33,000 cfm, an exhaust temperature of
      99° F and a velocity of 70  ft/sec.  Building is 20 ft high at center and 16 ft
      high at eaves.
                                A-10

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      D.    Off-Gas Monitoring
            Stack is continuously monitored for alpha, beta, and gamma radiation,
            tritium, carbon-14, particulates, uncombusted organic vapors and CO. All
            of these monitors will alarm at levels below licensed allowable limits and
            shut feed down when upper set point is reached.

      E.    Ash Handling and Disposal
            Ash will be solidified (at DSSI or Chem Waste Management) to meet
            TCLP and sent to Envirocare in Utah for burial.

      F.    Ash Monitoring
            TCLP testing.

      G.    Liquid Effluent Handling
            Dry scrubber.

      H.    Liquid Effluent Monitoring

      I.     Safety Systems and Redundancies

      J.     Planned Modifications
            Have just completed addition of scrubber and baghouse;

      K.    Permit Types and Requirements
            Radioactive Materials License - Tennessee Department of Conservation,
            Division of Radiological Health.
            APC Permit - Tennessee Department of Health and Environment,
            Tennessee APC Board.
            Treatment, Storage and Disposal (Type-B) Permit - Tennessee Department
            of Health and Environment, Division, of Solid Waste.
            National Emissions Standards  for Hazardous Air Pollutants (NESHAPs)
            Permit - U.S. EPA.
            Electrical Cogeneration Permit - Federal Energy Regulatory Commission.

3.     OPERATING HISTORY

      A.    Preliminary Planning

      B.    General Chronology
            Permitting  activities initiated in July 1987.  Construction initiated about July
            1989.

      C.    Description of Upsets,  Accidents and Corrective Actions
                                      A-ll

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4.
D.    On-Stream Analysis
      Design feed rate - 2 gpm.
      Annual capacity - about 1.1 million gallons at 100% on-stream.
      Processed about 4800 gal. through end of 1991.

E.    Radionuclide Mass Balance

F.    Staffing

G.    Operating Cycle
      Plan to run to run 24 hrs/day, 5 days per week now and 7 days per week
      later.

H.    Waste Disposal Issues

OPERATING  AND MONITORING PRACTICES

A.    Waste Classification and Handling Procedures

      Ash and Liquid Effluent Management
      B.

      C.
      Stack Monitoring
      CO, radionuclides, particulates and uncombusted organic vapors.  Current
      specifications include 6.96 Ibs/hr particulates, 5 Ibs/hr Hcl, 0.029 Ibs/hr C12
      and 0.0124 Ibs/hr HF.
      D.    Response to System Upsets

      E.    Operator Training

      F.    Incinerator and APC System Operation
            Sensors monitor fuel feed rate, boiler temperature, steam production, etc.
            Blowdown boiler daily collecting 200 gal. of water which is processed
            through IX bed and returned as makeup.

      G.    Maintenance Procedures

      H.    Contingency Plans

      I.     Operating and Maintenance Costs

      J.     Environmental Monitoring
                                      A-12

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WASTE FEEDS

A.    Description
      Waste solvents with low-level radioactivity. Feed limited to 0.05 Uci/g of
      H-3 and C-14 or 0.002 Uci/g of all other licensed isotopes.

B.    Source
      Have handled some hexone-water mixtures from Hanford with tritium and
      trace alpha.  Bidding on other DOE wastes.

C.    Quantity

D.    Waste Acceptance Criteria
      Solvents containing halogens or heavy metals are not acceptable. Typically
      handle D001, F001 to F005 fluids plus several listed D, U and P wastes.

STACK MONITORING DETAILS

A.    Current Stack Sampling Procedures

B.    Laboratory Analysis
      Have gamma spectrometer and GC.  Will add GC-MS soon.

C.    Prospects for Real Time Radioactive Emissions Monitoring

OTHER ISSUES

A.    Public Outreach
      Approximately 50 sessions were conducted with local regulatory officials,
      fire departments, neighbors, elected representatives (federal, state and
      local), near-by communities, radio, television, and newspaper reporters,
      chambers of commerce, professionals, interest groups and civic
      organizations. Notice of public gatherings with community residents was
      published in local newspapers and announced by distributed invitations to
      provide a question and answer forum. Public hearings were held per
      applicable regulations.

B.    Adverse Public Reactions
      Not a significant problem.

C.    Risk Assessments
      Risk assessment done using AIRDOSE and assuming worst case isotopic
      release of 2.7 times allowable annual limit and 33% of all food consumed
      being home produced resulted in total body dose of 13.2 mrem/yr.  If 100%
                                A-13

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      of all food consumed was home grown, the annual total body dose was 27.9
      mrem.

D.    Regulatory and Permitting Requirements
                               A-14

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                           APPENDIX A-4
                   INCINERATOR SURVEY FORM

                       K-1435 TSCA - ORGDP
KEY CONTACTS

Oak Ridge K-25 Site
Martin Marietta Energy Systems Inc.
Oak Ridge, Tennessee  37831

Tom Rogers, Div. Mgr. - (615) 574-9009
Dr.W.D. Bostick - (615) 574-6827, mass balance work
Brenda  Snyder - (615) 576-4976, WAC

SYSTEM DESCRIPTION

A.    Waste Handling
      Liquid wastes stored in 5000 gal receiving tanks then mixed in 10000 gal
      blending tanks. Drum deheading, emptying and draining facilities, as well
      as solid waste shredding provided.  Shredded waste is taken from bin with
      grapple and delivered to feed ram while other bulk material is fed to ram
      by belt conveyor.

B.    Incinerator
      Rotary kiln (6 ft ID x 25 ft long) with ram feeder for solids operating at
      1500 to 1800° F followed by secondary combustion chamber operating at
      1800 to 2200° F. Solids retention time is 23 to 90 minutes. SCC gas
      residence time is 4 sec. Incinerator and off-gas treatment systems were
      designed and constructed by International Waste Energy Systems.  The kiln
      has a maximum heat release rate of 10 million Btu/hr while the SCC is
      rated at about 22 million Btu/hr. The total system maximum  heat rate is 28
      million Btu/hr.

C.    Off-Gas Treatment
      Water quench tower cools gases from 2200° F to 188° F, venturi scrubber
      removes particles greater than 1 micron and some HC1,  demister removes
      water droplets, packed bed scrubber removes additional soluble and
      reactive gases, two-stage, horizontal crossflow wet ionizing scrubber
      removes particles under 1 micron before exhausting through 100 ft stack.
      No HEPA filters in system.  No redundant ID fan.  All ducting in APC
      system is FRP.
                                A-15

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      D.     Off-Gas Monitoring
             Stack is monitored for U, Tc, I, gross alpha, beta and gamma.
             Specifications include 99.5% HC1 removal, combined acid gas removal of
             99.2%,  particulates less than 0.06 gr/dscf.

      E.     Ash Handling and Disposal
             Solids leaving kiln fall into a water-filled sump from which they are
             removed by drag link conveyor to collection hopper and transferred into 55
             gal. drums.

      F.     Ash Monitoring
             Solids from E above assayed and stored for future disposal.

      G.     Liquid Effluent Handling
             Slowdown liquid is sent to 30,000 gal. purge tanks and then to a treatment
             facility for neutralization and solids removal. Carbon columns are available
             to remove organics as required.

      H.     Liquid Effluent Monitoring
             Analyzed  for organics to see if carbon treatment is required.

      I.      Safety Systems and Redundancies

      J.      Planned Modifications

      K.     Permit Types and Requirements
             NESHAPs - Monitor stack for U, Tc, I, and gross alpha, beta and gamma.
             RCRA  - for hazardous wastes.  TSCA - for PCBs. State of Tenn. for air.
             NPDES - for water.

3.     OPERATING HISTORY

      A.     Preliminary Planning
             See Report No. X-OE-141 for details.

      B.     General Chronology
             Public hearings for EIS held in  1981.
             EIS issued in June,  1982.
             Construction started in early 1984. System cost $26 million.
             Startup - June, 1987.
             TSCA permit received in March, 1989
             RCRA  trial burn completed in June, 1989.
             ID fan failure in June, 1989.
             Fan replaced and system restarted on March 23, 1990.
             Full-scale operation  since April, 1991.
                                       A-16

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      C.     Description of Upsets and Accidents and Corrective Actions
             Operations suspended in June 1989 due to failure of induced draft fan.
             New fan procured under improved QA plan.

      D.     On-Stream Analysis
             Feed rate for liquid wastes is 500-900 Ib/hr; for solid wastes is 700 Ib/hr;
             and for sludges is 450 Ib/hr.  Maximum combined feed rate for all products
             is 2618 Ibs/hr. State air permit limits annual incineration rates to 2562 tons
             for solids and 6954 tons for liquids.  In FY-1991 processed 2.18 million Ibs
             of waste mostly liquids.  In FY-1992 plan to process 2.5 million Ibs of
             liquids and ca. 100,000 Ibs of solids for test purposes.

      E.     Radionuclide Mass Balance
             In 1988 fed 9.5E-5 Ci of Tc-99 in liquid wastes and measured 1.6E-3 Ci out
             the stack. Have developed some data on U in feed and U in stack.

4,     OPERATING AND MONITORING PRACTICES

      A.     Waste Classification  and Handling Procedures
             RCRA and TSCA wastes stored in separate areas.

      B.     Ash and Liquid Effluent Management
             Ash generation is about 10 ft3/hr during operation, ash which is a mixed
             waste contains about 20% moisture and has a density of about 67 lbs/ft3.
             Ash is, for the interim, stored in 4x4x6 ft lined boxes which are traceable to
             specific burn campaigns. In FY-91 generated 26 drums of ash mostly from
             some soils testing.

      C.     Stack Monitoring

      D.     Response to System Upsets

      E.     Operator Training

      F.     Incinerator and APC System Operation
             Incinerator is required by permit to have Destruction Removal Efficiency
             (DRE) of 99.993% for non-PCBs and combustion efficiency of at least
             99.95%.

      G.     Maintenance Procedures

      H.     Contingency Plans

      I.      Operating and Maintenance Costs
                                       A-17

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J.      Environmental Monitoring
       Five long-standing air monitoring stations in place at ORGDP and
       additional stations to be added to support incinerator.

WASTE FEEDS

A.     Description
       Handles solids such as contaminated soils, absorbents, and biological
       materials; liquids such as waste oils, solvents and water solutions; as well as
       sludges including paint sludges, oil and grease sludges, solids from waste
       water treatment and degreaser residues.  Waste may contain PCBs,
       hazardous organics and low enriched uranium.

       Major radionuclides expected in feeds include H-3 - 1.58 Ci/yr; C-14 - 0.18
       Ci/yr; P-32 - 0.20 Ci/yr; S-35 - 0.076 Ci/yr; Cr-51 - 0.011  Ci/yr; Tc=99 - 14.6
       Ci/yr; 1-125  - 0.29 Ci/yr; 1-131 - 0.051 Ci/yr; and U - 0.42 Ci/yr.

       Feeds for 1988 and 1989 included 20490 gal and 19233 gal liquids and 160
       ft3 and 133  ft3 solids, respectively.

B.     Source
       Diffusion plants at Oak Ridge, Paducah and Portsmouth. The Y-12 Plant
       and ORNL in Oak Ridge.  The Feed Materials Production Center at
       Fernald, OH and the RMI Extrusion Plant at Ashtabula, OH.  As of 1Q
       1992 had processed no wastes from ORNL or RMI.

C.     Quantity
       Annual generation rates estimated to be 15.2 million Ibs/yr solids/sludges
       and 220,000 gal/yr of liquids.  Current inventory includes 3.2 million Ibs of
       liquids and  18.8 million Ibs of solids.

D.     Waste Acceptance Criteria
       All wastes from processes involving radionuclides  must be analyzed for
       those nuclides. See Report K/HS-252/r2 for details.

STACK MONITORING DETAILS

A.     Current Stack Sampling Procedures
       Continuously perform isokinetic sampling of stack for U, Tc, 1-125, 1-131,
       gross alpha, gross beta, and gross gamma for NESHAPS requirement using
       filter, condenser and impingers. Samples assayed weekly. Other test
       results include DRE for POHCs > 99.99% avg.  (7 tests); particulates 0.034
       gr/sdcf avg.  and 0.003 to 0.077 gr/sdcf range (24 tests); HC1 removal
       99.92% avg. and 99.66 to 99.99% range (25 tests); combustion efficiency
       >99.99% avg. (3 tests); CO in stack gas  <10 ppm avg. and 1-16 ppm range
       (24 tests).
                                 A-18

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      B.     Laboratory Analysis
             QA/QC procedures described in document K/PS-1032.

      C.     Prospects for Real Time Radioactive Emissions Monitoring

7.    OTHER ISSUES

      A.     Public Outreach
             Public hearings relative to EIS held in Oak Ridge, Kentucky and Ohio in
             1981.  Additional public meetings held in Oak Ridge in 1987 and  1988 and
             in Kingston, TN in 1988.

      B.     Adverse Public Reactions
             Not a major issue.

      C.     Risk Assessments

      D.     Regulatory and Permitting Requirements

8.    REFERENCES

National Emission Standard for Hazardous Air Pollutants Compliance Verification Plan
for the K-1435 Toxic Substances Control Act Incinerator, K/HS-109, M.L. Ambrose, July
28, 1986.

Analysis of the Environmental Significance Resulting From Changes in the K-25 Toxic
Substance Control Act Incinerator Design and Waste Streams Since the Issuance of the
Final Environmental Impact Statement, K/HS-109 Attachment 3, R.E. Saylor et. al,
August 16, 1985.

Waste Acceptance Plan and Analytical Protocol for the K-1435 Toxic Substance Control
Act Incinerator, Project No. 409371.25, IT Corp., October 1, 1986.

Untitled, K/SS-455, Undated Draft.

Letter from W.D. Adams, ORO to S.P. Cowan, Office of Waste Operations Dated
October 5,1990.

Startup and Trial-Burn Tests of the Oak Ridge TSCA/RCRA incinerator, Reter J. Kroll
and Tom O. Rogers, Presented at 1989 Incineration Conference, Knoxville, Tenn.
                                      A-19

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                           APPENDIX A-5
                   INCINERATOR SURVEY FORM

                            WERF-INEL
KEY CONTACTS

D.D. Cochran, Shift Supervisor
EG&G Idaho, Inc.
P.O. Box 1625
Idaho Falls, ID 83415
(208) 526-8008

SYSTEM DESCRIPTION

A.    Waste Handling
      Combustible solids in PE-lined cardboard boxes on roller conveyor
      automatically-scanned by X-ray for non-combustibles and beta/gamma
      monitor for radioactivity, weighed and passed through air lock to an
      elevator and into a waste-loading chute.  Solid wastes fed continuously for 4
      hours.  Can vary from 100% wood to 100% plastic.  Rely on waste
      segregation to remove acid-forming materials (no wet scrubber).  No
      chemical assay for low-level waste feed.  Liquid waste in drums is sampled,
      connected to liquid waste supply line and pumped to vortex burner.

B.    Incinerator
      Dual-chambered CA combustion unit (Model 1000TL) manufactured by
      Environmental Control Products (now Ecolaire) in Charlotte NC.
      Incinerator operates in sub-stoichiometric mode during solid waste feed
      then shifts to  excess air mode by providing underfire air  to burn fixed
      carbon. With liquid wastes always  runs with excess air.  System rated at 5
      million BTU/hr.

C.    Off-Gas Treatment
      Dry system with shell and tube heat exchanger  (flue gas  inside tubes), bag
      house filter, HEPA filters (stainless steel frame and glass media), parallel
      ID fans and 49 ft stack (North stack);  Separate South stack handles
      cooling air from HX and other building exhausts.

D.    Off-Gas Monitoring
      Annubar for stack gas volumetric flow, non-dispersive IR analyzer for
      continuous  CO and HC1, O2 monitor in SCC, CAM in stack.
                                A-20

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      E.    Ash Handling and Disposal
            Bottom ash passes into cooling hopper, then into a shredder to break up
            clinkers, and then through a gate valve into a drum. Flyash can be
            pneumatically-conveyed to a separate drumming station or handled
            manually.  All ash is solidified in cement.

      F.    Ash Monitoring
            Total C content runs less than 0.5%. Raw ash randomly sampled for gross
            radioactivity. Stabilized ash tested by TCLP.

      G.    Liquid Effluent Handling
            Dry system.

      H.    Liquid Effluent Monitoring
            Not required.

      I.     Safety Systems and Redundancies
            Spark arrester upstream of baghouse.  Automatic solid and liquid waste
            feed cutoffs. UV detector for propane pilot on auxiliary fuel system.
            Primary and secondary combustion chamber temperature controllers
            interlocked with burners, waste feeders and steam quench.

      J.     Planned Modifications
            Considering installation of larger capacity burners for faster startup and
            better burnout of carbon.  Have installed packed column scrubber for acid
            gas removal but have not piped it into incinerator system.  Installing
            distributive control system for better data keeping and reduced possibility
            of operator error.

      K.    Permit Types and Requirements
            Currently operating under RCRA Interim Status  permit after trial burn
            with liquid waste system in 1988.  INEL will submit facility-wide RCRA
            part B at end of 1992. Permit to Construct (PTC) from  state of Idaho
            specifies materials which can be incinerated.

3.     OPERATING HISTORY

      A.    Preliminary Planning
            Originally designed for solid waste only.

      B.    General Chronology
            Began processing radwastes in September 1984; limited operation through
            October,^ 1985; then began accepting from all INEL waste generators.
                                       A-21

-------
             Through May 1988 had operated about 4500 hours and burned 4250 m3 of
             waste.  Shut down February 1991 to update Operational Safety
             Requirements. Restart was scheduled for October 1991 but has now been
             delayed at least 15 months.

       C.     Description of Upsets and Accidents and Corrective Actions
             Ash removal system clogged with clinkers requiring replacement of system.
             Sporadic wet, sticky  flyash requires reduction of off-gas  cooling thereby
             raising baghouse from 149-177° C to 204-215° C for 30-60 minutes.
             Bridging across flyash hopper outlet requires immediate transfer after pulse
             cleaning or air jet breakup.  Slag buildup on lower chamber floor must be
             routinely chipped out or ash ram will jam. Some refractory wear noted
             around lower door to loading chute requires routine repair.  Heat
             exchanger tubes not properly cleaned during early operations.  Now
             reamed out after each 28 day burn cycle.

       D.     On-Stream Analysis
             Nameplate capacity is 400 Ib/hr (180  kg/hr). However, PTC limits average
             feed rate to 200 Ibs/hr.  On-stream time  in 1986 was 15% and  in 1987 was
             23%.  During the time actually on-stream the average feed rate in 1986 was
             76 kg/hr and in 1987 was 56 kg/hr.

       E.     Radionuclide Mass Balance
             Total radioactive releases were 0.27 uCi  in 1986, 1.8 uCi in 1987, 2.6 uCi in
             1988 and  1.3 uCi in 1989.  Waste feeds were 1620, 1475, 1996  and 1621
             m3/yr 1986-1989 respectively.

4.      OPERATING AND MONITORING PRACTICES

       A.     Waste Classification  and Handling Procedures
             All mixed waste is processed via  Mixed Waste Storage Facility or WERF
             Waste Storage Building. Boxes of waste feed checked by X-rays for
             booties, tygon tubing, masks, etc. (Cl  issue) and rejected if acid gas formers
             are excessive. Mixed wastes must be chemically assayed and, consequently,
             boxes are opened, sampled, visually inspected and repackaged.

       B.     Ash and Liquid Effluent Management
             Fly ash and bottom ash stabilized with Portland cement  using differing
             ash/cement ratios.  Fly ash handling system not currently approved for use
             by DOE-HQ.

       C.     Stack Monitoring
             During normal conditions NO2, CO and HC1 emissions run at 5-30 ppm
             each, SO2 is 15-25 ppm and HC  is 5-20 ppm.  Particulates are  0.0018
             gr/dscf.
                                      A-22

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5.
D.    Response to System Upsets

E.    Operator Training
      Safety training of operators is monthly. Operators also receive 40 hours
      OSHA training, 24 hours of OSHA hazardous facility training, rad worker
      training and respirator training.

F.    Incinerator and APC System Operation
      Currently installing computerized control system; until new system is
      installed data are recorded manually by operators.  Permit prohibits
      burning liquid and solid wastes simultaneously.

G.    Maintenance Procedures
      Preventive maintenance provided for all instrumentation and equipment
      which could cause unsafe condition.

H.    Contingency Plans
      Have spill contingency plan (SWIM) in case of waste feed spills.

I.    Operating and Maintenance Costs
      Crew consists of supervisor, console operator, field operator and health
      physicist each shift.

J.    Environmental Monitoring

WASTE FEEDS

A.    Description
      WERF originally handled solid LLW only; working on RCRA permit to
      handle liquid mixed and LLW; eventually will handle solid mixed and LLW.
      Solid wastes supplied in 2x2x2 ft- or 20" boxes weighing less than 60 Ibs.

B.    Source
      Currently handling only wastes produced at INEL. Have handled two
      shipments from LLNL in past.

C.    Quantity
      About 40,000 ft3 of combustibles currently at WERF (8/91).

D.    Waste Acceptance Criteria
       Chlorinated constituents must be held at low levels to insure that HC1
       emissions remain below 4 Ib/hr.
                                       A-23

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 6.     STACK MONITORING DETAILS

       A.    Current Stack Sampling Procedures
             Total radioactive releases in 1987 were 2 microcuries.  Measure HC1, CO,
             O2, volumetric flow, temperature, and gross radioactivity.

       B.    Laboratory Analysis
             For CO use NDIR, for O2 use ZrO probe made by Westinghouse-Hagan.

       C.    Prospects for Real Time Radioactive  Emissions Monitoring

 7.     OTHER ISSUES

       A.    Public Outreach
             Considering preparation of some descriptive material on facility.

       B.    Adverse Public Reactions
             Has not been an issue at WERF.

       C.    Risk Assessments

       D.    Regulatory and Permitting Requirements

 8.     REFERENCES

 Performance History of the WERF Incinerator, J.D. Dalton, H.A. Bohrer and G.R.
Smolik, International Conference on Incineration of Hazardous, Radioactive and Mixed
 Wastes, May 3-6, 1988, San Francisco, CA.

 Information transmitted to L. Coe, S. Cohen and Assoc. from EPA Regional Office,
Seattle, WA on March 7, 1989.

Status Report on the INEL RCRA Permit for Incineration of Hazardous Waste;
Conference on Incineration of Low-Level and Mixed Wastes, J.N. McFee, J.D. Dalton,
and H.A. Bohrer, April 1987, St Charles, IL.

Letter from J.E. Solecki, IOO to E. Jordan, EM-321 dated October 5, 1990.

Private Communication - A. Wollerman and D.D. Cochran, EG&G, August 15,  1991.
                                     A-24

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                           APPENDIX A-6
                   INCINERATOR SURVEY FORM

                     MOUND GLASS MELTER
KEY CONTACTS

Larry Klinger (513) 865-3078
Monsanto Research Corporation - Mound
P.O. Box 32
Miamisburg, Ohio  45342

SYSTEM DESCRIPTION

A.    Waste Handling
      Waste fed into furnace through port in ceiling.  Scintillation vials crushed in
      vial eater and fed into furnace via two glove boxes.  One glove box has
      water-cooled screw feeder and the other has vibrating screw feeder (for IX
      resins).  Liquid wastes injected directly.

B.    Incinerator
      Penberthy Electromelt, Inc. Pyroconverter (joule-heated glass melter) with
      operating temperature range of 730 to 1350° C. Propane burner (400,000
      BYU/hr) used for startup and melting of glass pool.  Melt chamber is 7 x 4
      x 3.5 ft high.  Uses soda-lime-silica cullet as feed.

C.    Off-Gas Treatment
      Wet off-gas scrubber consisting of spray tank, and high efficiency venturi
      scrubber followed by cyclone demister and several stages of HEPA
      filtration (99.97% efficient for 0.3 micron particles).

D.    Off-Gas Monitoring

E.    Ash Handling and Disposal
      Waste glass containing ash poured into molds for cooling at end of each
      run. Approximate volume reduction ratio is 15 to 1.

F.    Ash Monitoring

G.    Liquid Effluent Handling
      Sludge from scrubber reprocessed through glass melter (ca. 1 kg per 240 kg
      of wastes). Liquid effluents mixed with cement for disposal (ca. 1 L per 1.7
      kg of wastes).
                                A-25

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      H.    Liquid Effluent Monitoring

      I.     Safety Systems and Redundancies

      J.     Planned Modifications

      K.    Permit Types and Requirements
            Have applied to Ohio EPA for RCRA Part B permit.
            Will require NESHAPs permit.

3.     OPERATING HISTORY

      A.    Preliminary Planning

      B.    General Chronology
            Initial work begun in 1981.
            Furnace put in operation in January 1982.
            Did "simulated" RCRA trial burn in December 1984.

      C.    Description of Upsets, Accidents and Corrective Actions
            Drain failure occurred three times  (through ca. 1986).  Had two electrode
            failures in same period.  Have some concern about radioactive
            contamination in refractory.

      D.    On-Stream Analysis
            After startup, furnace was at idle temperature of 1000° C or operating
            temperature of  1300 to 1370° C for four years except for 24 week
            shutdown to prepare for some radwaste experiments and 4 weeks for
            furnace repair.  Operating feed rate is 23 kg/hr and annual treatment
            capacity is 181.6 m3.  Plan to operate 7 hours per day, five days per week,
            and 38 weeks per year (23x7x5x38  = 30,590 kg/yr).

      E.    Radionuclide Mass Balance

      F.     Staffing

      G.    Operating Cycle
            See D above.

      H.    Waste Disposal Issues
                                      A-26

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OPERATING AND MONITORING PRACTICES

A.    Waste Classification and Handling Procedures
      Scintillation vials crushed in commercial vial eater.

B.    Ash and Liquid Effluent Management

C.    Stack Monitoring
      Demonstrated 99.5% HC1 removal in scrubber. In 54 DRE measurements
      found only one that was less than 99.99%, problem was xylene (PIC from
      kerosene burning when kerosene was 90% of total feed). In repeat run got
      99.999% DRE for xylene.

D.    Response to System Upsets

E.    Operator Training

F.    Incinerator and APC System Operation

G.    Maintenance Procedures

H.    Contingency Plans

I.     Operating and Maintenance Costs
      For low-level waste (IX resins) Mound cost is $0.11  per kg.

J.     Environmental Monitoring

WASTE FEEDS

A.    Description
      Have done experimental work on DAW, wet IX resins (with 55% bound
      water), cartridge filters and filter sludge (ca. 80%  water).

B.    Source
      Plan to handle only on-site wastes.  Materials include scintillation cocktails,
      combustibles, fuel-cycle wastes, non-combustibles, plastics, rubber, and
      sludges.

C.    Quantity
      As  of mid-1991 had inventory of 43,000 kg of mixed waste and expect to
      generate 2.313 kg per yr of additional mixed waste and 39,322 kg per yr of
      non-radioactive solvent waste.  Backlog along with current generation will
      be worked off in six years.
                                A-27

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      D.    Waste Acceptance Criteria
            Mound waste only.  Can handle liquid and solid low-level and mixed waste.
            Solid feed must be significantly reduced in size.

6.    STACK MONITORING DETAILS

      A.    Current Stack Sampling Procedures

      B.    Laboratory Analysis

      C.    Prospects for Real Time Radioactive Emissions Monitoring

7.    OTHER ISSUES

      A.    Public Outreach

      B.    Adverse Public Reactions

      C.    Risk Assessments

      D.    Regulatory and Permitting Requirements

8.    REFERENCES

Private Communication from Lise J. Wachter - HAZWRAP dated September 11, 1991.

"Glass Furnace Project Final Report - An Evaluation of Operating Experience for Low-
level Nuclear Waste Processing," MLM-3229, Larry M. Klinger and Katherine M.
Armstrong, Monsanto Research Corporation-Mound, February 28, 1985.

"Application of a Glass Furnace System to Low-Level Radioactive and Mixed Waste
Disposal," Larry M. KJinger and Katherine M. Armstrong, Monsanto Research
Corporation-Mound, 1986.
                                     A-28

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                           APPENDIX A-7
                   INCINERATOR SURVEY FORM

            CONSOLIDATED INCINERATION FACILITY
KEY CONTACTS

Westinghouse Savannah River Company
P.O. Box 616
Aiken, SC  29802

William J. Maloney, Process Engineer, Environmental Protection Section,
 (803) 725-1086 (RCRA Permit);
William D. Thompson, (803) 557-2225, Senior Engineer, Solid Waste Facility
 Projects;
Deborah Salem, (803) 557-2222, Engineer, Solid Waste Facility Projects;
Heather Burns, (803) 557-2225.

SYSTEM DESCRIPTION

A.    Waste Handling
      Aqueous waste (mainly sump waste) stored in 6500 gallon tank.
      Radioactive benzene received by pipeline from storage tanks at DWPF.
      Two 4300 gallon agitated, insulated and temperature controlled tanks for
      hazardous waste  blending also provided. Tank farm includes 12,000 gallon
      fuel  oil storage tank; all tanks in separate bermed storage area.  Conveyor
      with weighing, radio-assaying and x-ray stations provided for solid waste
      containers (each  21 inches square) in incinerator building.

B.    Incinerator
      Rotary kiln rated at 18 million BTU/hr with separate nozzles for organic
      waste, auxiliary fuel oil and aqueous waste. Normal operating temperature
      is 1800° F. Kiln  is 8 ft ID x 25 ft long. Solids fed through air lock ram
      feeder.  Kiln seals shrouded to capture any gas leakage.  Minimum solids
      residence is 45 to 90 minutes. Secondary combustion chamber (6 ft ID x
      33 ft long) will use waste benzene as primary heat source with separate fuel
      oil backup. Minimum SCC residence, is 2 seconds and normal exit
      temperature is 2012° F. Kiln capacity is 12 tons per day of solid and liquid
      waste. System designed by Chas. T. Main.  Gas flow is 27,500 acfm at
      1800° F.

C.    Off-Gas Treatment
      Spray quench chamber for first stage particulate removal and acid-gas
      scrubbing followed by steam-driven free jet scrubber, cyclone separator and
      mist eliminator.  Gas is reheated above dew point (ca. 300° F),  passed
      through HEPA filters to ID fans and up the stack.

                                A-29

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      D.    Off-Gas Monitoring
            Stack continuously monitored for CO and O2.  Radioactivity monitoring will
            include tritium, gross alpha, gross beta/gamma and gamma scan of collected
            particulates.

      E.    Ash Handling and Disposal
            Ash discharged into water-filled trough. Cooled wet ash removed from
            trough with 250 Ib/hr backhoe type device, filled in drums to preset weight,
            and conveyed to solidification system where ash is mixed with cement and
            water. Drums placed in permitted storage area before final on-site
            disposition in planned mixed waste disposal facility.

      F.    Ash Monitoring
            Solidified ash in drums will be checked for surface contamination and given
            TCLP on random basis.

      G.    Liquid Effluent Handling
            Scrubber blowdown allowed to build to 10% suspended solids and then
            sent to one of two 6000 gallon hold tanks. Later will be transported to
            planned hazardous waste treatment and disposal facility for dewatering and
            stabilization with concrete. If waste water is clean, it will be directed to
            NPDES outfall.

      H.    Liquid Effluent Monitoring

      I.     Safety Systems and Redundancies

      J.     Planned Modifications

      K.    Permit Types and Requirements
            RCRA Part B - South Carolina DHEC
            APC - South  Carolina DHEC
            Domestic Water Distribution - South Carolina DHEC
            Sanitary Waste Water Collection - South Carolina DHEC
            NPDES Modification - South Carolina DHEC
            NESHAPs - EPA

3.     OPERATING HISTORY

      A.    Preliminary Planning
                                      A-30

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B.    General Chronology
      "Basic Data Report for Current Appraisal of Cost (Rev 1)" issued
      September 1986
      "Conceptual Design Report" issued October 1987
      Original DOE schedule (Ref 1):
             2/88 Title II design start
             6/88 RCRA Part B and NESHAPs applications submitted
             2/90 Construction start
             11/91 Project turnover from construction
             2/92 Trial burn
             5/92 Routine operation
      Revised schedule (early 1991):
             Revised scope of work issued in December 1989
             Title II design completed in May 1990
             Construction start  in fall 1991
             Component testing in September 1992
             Trial burn in July 1993
      Current schedule (2/92):
             Draft RCRA permit issued for  comments in spring 1992
             RCRA permit issued and construction begins in summer 1992
             Normal operations begin 39 months after RCRA permit issued

C.    Description of Upsets, Accidents and Corrective Actions

D.    On-Stream Analysis
      Plan to process 560,000 ft3/yr of solid waste and 35,700 ft3/yr of liquid
      waste and produce 35,700 ft3/yr of cement stabilized ash and blowdown foe
      overall VR ratio of 22 to 1.  Design basis is to  process (on the average) 720
      Ibs/hr of boxed waste plus 187  Ibs/hr (23 gph) of liquid waste (including 30
      Ibs/hr of no. 2 fuel oil) in primary combustion chamber and  139 Ibs/hr (19
      gph) of benzene and 130 Ibs/hr of no.  2 fuel oil in the SCC.  This equates
      to 5.3 million pounds annually  based on the operating schedule noted in G
      below.  More recently, the processing rate has been quoted as
      approximately 4 million pounds per year.  (Ref  3).

E.    Radionuclide Mass Balance
      See Table 2 from reference 2 attached for total mass balance.

F.    Staffing
      Total staff will be 45 to 50 including four  shift crews of five operators and a
      foreman.  Balance are technical, administrative and maintenance people.
                                A-31

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      G.     Operating Cycle
             Planned 3 shifts (four crews) per day, 7 days per week and thirty operating
             weeks per year. Other documentation suggests a 56.3% weighted
             availability for solid and liquid wastes or 4930 hours per year.

      H.     Waste Disposal Issues
             Blowdown from quench recirculation passed through cross flow filter to
             concentrate suspended solids to  10 wt% and then is pumped to one of two
             6000 gallon FRP hold tanks.  Blowdown waste transferred by tank truck to
             on-site cement stabilization facility and then to on-site disposal facility.

4.     OPERATING AND MONITORING PRACTICES

      A.     Waste Classification and Handling Procedures
             Solid wastes transported to GIF  in closed incinerable containers which are
             placed on conveyor, checked for radiation rate, weighed, x-rayed for foreign
             objects and assayed for radioisotope content.  Containers are not opened.

      B.     Ash and Liquid Effluent Management

      C.     Stack Monitoring

      D.     Response to System Upsets

      E.     Operator Training

      F.     Incinerator and APC System Operation

      G.     Maintenance Procedures

      H.     Contingency Plans

      I.      Operating and Maintenance Costs
             Capital cost was estimated in ca. 1987 to be $30  million with annual
             operating costs of $6.4 million (Ref 2). Current capital cost estimate  for
             GIF including ashcrete facility is $90 million.

      J.      Environmental Monitoring
                                       A-32

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5.     WASTE FEEDS

      A.     Description
             Low-level, mixed and hazardous wastes including solids, sludges organic and
             aqueous liquids.  Solid wastes include filtered solids from paint thinners,
             sludges and other chlorinated and non-chlorinated organics. Other solids
             include solvents, pesticides and herbicides on absorbent material and
             contaminated soils. Major solids will be rags, plastic and cloth work suits,
             shoe covers, PVC sheeting, mops and floor cleaning equipment. Liquid
             wastes include solvents, machine cutting and extrusion press oils, paints and
             thinners, motor and compressor lubricating oils, lab wastes, pesticides,
             herbicides and organic process waste streams. Radioactivity is mainly beta-
             gamma (fission products) with one stream containing trace amounts of
             uranium.

      B.     Source
             All wastes generated on site. Benzene comes from Defense Waste
             Processing Facility.

      C.     Quantity
             See attached table.

      D.     Waste Acceptance  Criteria
             No dioxins or PCBs.  Only SRS wastes.  Limited metals except benzene
             wastes which may contain up to 110 ppm Hg. No current plans to process
             any soils.  Ash backhoe limits rate of future soil processing.

6.     STACK MONITORING DETAILS

      A.     Current Stack Sampling Procedures

      B.     Laboratory Analysis

      C.     Prospects for Real  Time Radioactive Emissions Monitoring

7.     OTHER ISSUES

      A.     Public Outreach
             Have prepared video and literature in anticipation of public comment
             period on EA and  draft RCRA permit.  Have met with Aiken city council
             and participated  in other public fora.
                                       A-33

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8.
B.    Adverse Public Reactions
      Limited.  Being watched by Greenpeace and Energy Research Foundation
      who have apparently supplied input questions to South Carolina DHEC for
      NOD's.

C.    Risk Assessments

D.    Regulatory and Permitting Requirements

REFERENCES
"Consolidated Incineration Facility - Program Information Report to the South Carolina
Department of Health and Environmental Control," U.S. DOE - Savannah River Plant,
April 1988.

"The Savannah River Plant Consolidated Incineration Facility," Daniel A. Weber, E.I. du
Pont de Nemours and Co., Inc., ca. 1987.

"Startup, Operations and Maintenance Control for a Rotary Kiln Incinerator," William D.
Thompson, Proceedings of 1991 Incineration Conference, p. 687, May 1991.

"GIF Basic Project Data," OPS-WMP-4740, Project S-2787, Rev. 3, September 18, 1990.
                                      A-34

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                          Planned Waste Feeds for GIF

SOLIDS (ft3)
High Btu, drummed
Chlorinated,
drummed
Beta/Gamma, boxed

LIQUIDS (gal)
High Btu, drummed
Chlorinated,
drummed
Aqueous, drummed
Purex Solvent
Tritiated Oil
DWPF Organic
Naval Fuel Organic
Fuel Oil Flush
Aqueous Flush
Projected
Inventory (as of
1/1/93)

440
380
200,000


22,000
500
2,000
36,000
15,000
0
31,000
20,000
7,000
Projected Annual
Generation

440
380
560,000


22,000
500
2,000
8,000
7,000
50,000
0
9,000
1,000
Waste Type

NRHW
NRHW
10% Mixed, 90%
LLW


NRHW
NRHW
NRHW
LLW
Mixed
Mixed
Mixed
Mixed
Mixed
NRHW = Non-Radioactive Hazardous Waste
                                     A-35

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                           APPENDIX A-8
                   INCINERATOR SURVEY FORM

                        SEG INCINERATOR
KEY CONTACTS

Scientific Ecology Group, Inc.
P.O. Box 2530
1560 Bear Creek Road
Oak Ridge, Tennessee  37831
(615) 481-0222

H.W. Arrowsmith - President
Pete Keegan - Vice President, Sales and Marketing
Dewey E. Large - Senior Consultant
Walt Hipsher -  Vice President, Regulatory Services and Transportation

SYSTEM DESCRIPTION

A.    Waste Handling
      All waste hand-sorted on manual lazy-susan sorting table at SEG prior to
      incineration to minimize halogens and heavy metals.  PVC materials
      reduced to less than 5%. Sorted wastes packaged in wheeled containers
      holding about 50 ft3 (ca. 300 Ibs).  Twenty-two wheeled containers are
      loaded into feeding magazine and automatically loaded into incinerator.
      Wheeled containers ride up vertical inclined trolley to waste charging  sluice.
      Upper sluice door opens, waste is dumped into chamber and upper door
      closes. When feed is required lower door opens and waste falls into
      furnace.

B.    Incinerator
      Capacity is 800-1600 Ib/hr for DAW and can simultaneously burn 30 gallons
      per hour of radioactive, non-hazardous waste oil in a liquid waste injection
      system. Incinerator is fixed hearth unit, Envikraft EK 980 NC,  designed
      and built by Faurholdt Engineering and supplied by Studsvik Nuclear.
      Incinerator is rated at 11 million Btu/hr.  Primary unit operates in  pyrolysis
      mode at  1290 to 1650° F, feeding secondary combustion chamber which
      has 2 burners and operates at 1830 to 2200° F with 3-second residence
      time. Liquid wastes are fed into SCC burners. Auxiliary fuel is propane
      but will probably shift to natural gas. Unit also has tertiary combustion
      chamber operating at 900 to 1000° F but burner there is seldom used.
      Also have separate liquid injection incinerator in same building used mainly
      to burn radioactive oil.
                                A-36

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C.    Off-Gas Treatment
      Incinerator effluent (ca. 5000 scfm) enters 3-pass vertical carbon steel
      boiler and is quenched to about 360 to 430° F, then into 4-chamber bag-
      house with TFE-coated bags and next into a bank of parallel of HEPA
      filters. Essentially non-radioactive gas is quenched to about 200° F, run
      through a packed tower scrubber with caustic for acid gas removal, then
      through ID fan and into stack.  Heated building air is added downstream of
      the ID fan to rediice water vapor plume. Gas exits at about 350° F.  When
      burning radioactive oil, off-gas need only pass through HEPA filter bank.

D.    Off-Gas Monitoring
      Isokinetic nozzle in stack.

E.    Ash Handling and Disposal
      In addition to bottom ash, fly ash is collected from boiler and bag house.
      Ash transporter in furnace  moves hearth ash to ash sluice system where
      upper gate opens allowing ash to fall into air-cooled chamber.  When ash
      has cooled sufficiently lower gate opens and ash falls into tote bin attached
      to system through flexible air tight seal.  Ash supercompacted in containers,
      stacked in overpacks, sealed, inspected for defects, surveyed, checked for
      contamination and labeled  for shipment.

F.    Ash Monitoring
      See E above.

G.    Liquid Effluent Handling
      Slowdown from packed tower scrubber goes to liquid evaporator where
      excess water is removed.

H.    Liquid Effluent Monitoring

I.     Safety Systems and Redundancies
      On-site 120 kw diesel generator for emergency electrical power.  Parallel
      HEPA filters (with ability to switch from primary to secondary unit).
      Malfunction in waiste feed charging system shuts feed down.  Sluice doors
      interlocked to prevent upper and lower being open simultaneously.
      Auxiliary propane burner comes on if temperature in primary chamber falls
      below 1290° F. Pressure relief door on SCC. Cooling air provided to
      baghouse and/or HEPA filters if temperature rises above 440° F.
      Combustion air fans, cooling air fans,  induced draft fans, pressure
      indicators, level indicators and flue gas quality monitors all duplicated and
      automatically switched over by logic control system. Water tank for
      emergency water supply to spray cool incinerator.
                                 A-37

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      J.
Planned Modifications
      K.     Permit Types and Requirements
             NESHAPs - EPA Region IV
             Radioactive Materials License - Tennessee Division of Radiological Health
             Air Permit - Tennessee Division of APC

3.     OPERATING HISTORY

      A.     Preliminary Planning
             Proven design with extensive operational experience at Studsvik.

      B.     General Chronology
             General SEG licensing activities initiated in 1985.
             EPA granted permission to construct and operate incinerator under
               NESHAPs on November 23,1988.
             Project funded by Westinghouse in January 1989.
             Incinerator operation begun 4th Q 1989.

      C.     Description of Upsets, Accidents and Corrective Actions

      D.     On-Stream Analysis
             Capacity is about 6 million Ibs/yr of DAW depending on heat content of
             waste. Burned 2.6 million Ibs of DAW in 1990 and 25,000 gal of oil in
             liquid injection incinerator.  In 1991 burned 5.3 million Ibs DAW.  Plan for
             1992 is 6 million Ibs DAW.

      E.     Radionuclide Mass Balance
             Information reported quarterly to EPA.  Some info in NESHAPs permit
             application.  Major mass balance problems because generators always
             overstate activity levels.

      F.     Staffing
             Normal crew in incinerator building includes control room operator, field
             operator, two operators for liquid injection incinerator,and health physicist.
             Shift foreman serves entire plant.

      G.     Operating Cycle

      H.     Waste Disposal Issues
             HEPA filters compacted and sent to burial site.
                                       A-38

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4.     OPERATING AND MONITORING PRACTICES
      A.
      B.
      C.
      D.

      E.
      F.
      G.

      H.

      L

      J.
Waste Classification and Handling Procedures
All DAW manually sorted.

Ash and Liquid Effluent Management
All effluents except stack off-gas collected on property. Some fly ash has
leachable quantities of Pb and Cd and therefore all fly ash is be solidified
with epoxy in B-25 containers for ultimate land disposal.  Some hearth ash
is class B waste and must be stabilized per 10 CFR 61. Prior to off-site
shipment ash containers quantitatively analyzed for gamma-emitters.
Slowdown from spray scrubber sump is sent to thin film evaporator. Clean
water is recycled to system and wet salts are collected in plastic lined
containers for transport to burial site.

Stack Monitoring
Filters recovered from oil-burning off-gas sampler analyzed to determine
release rates for uranium, Tc-99, gross alpha and gross beta and gamma.
Filters from isokinetic sampler in incinerator stack analyzed (weekly) for
uranium, Tc-99, 1-125,1-129, 1-131, C-14, H-3, gross alpha, gross beta, and
gamma scan of particulates.  Scrubber removes 90% of HC1 and 60-70% of
S02.

Response to System Upsets

Operator Training
Initial operators trained in Sweden on Studsvik incinerator. All operators
now trained on site with in-house program similar to INPO including oral
boards.

Incinerator and APC System Operation
SCC monitored for temperature,  pressure, O2 and CO2.  Stack monitored
for opacity. Primary chamber monitored for temperature and pressure.
Bag house and HEP A filters monitored for temperature.

Maintenance  Procedures

Contingency Plans

Operating and Maintenance Costs

Environmental Monitoring
                                       A-39

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WASTE FEEDS
A.
Description
Low-level radioactive wastes including paper, cloth, wood, and rubber with
some metal particles, glass and plastics.  Typical heat content is 6500 to
13000 BTU per pound.
B.



C.

D.
                                            In 1991 91% from nuclear
Source
Nuclear power plants and some DOE locations.
utilities, 7% from brokers and 2% from DOE.

Quantity
Waste Acceptance Criteria
Unacceptable items include explosives, pyrophorics, shock sensitive or
highly reactive materials, TSCA and RCRA wastes. Other prohibited
materials include hospital waste and waste containing high concentrations
of H-3 and C-14. Oils must contain less than 1E-4 uCi/ml radionuclides
and less than 1E-5 uCi/ml uranium averaged over truckload lot. Have
handled some DOE materials.
STACK MONITORING DETAILS

A.    Current Stack Sampling Procedures

B.    Laboratory Analysis

C.    Prospects for Real Time Radioactive Emissions Monitoring

OTHER ISSUES

A.    Public Outreach
      Have promised city of Oak Ridge that nothing will be done at SEG site
      without permission from city.

B.    Adverse Public Reactions
      Has not been a major problem.

C.    Risk Assessments
      Conventional AIRDOS, plus two accident scenarios - failure of heat
      removal system and pressure excursion in incinerator. Based on burning 10
      million pounds of waste annually, whole body dose at property line
      calculated to be 2.3 mrem and 0.3 mrem for nearest potential resident.
                                A-40

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      Release fractions were 0.01% for all nuclides except C-14 and H-3 which
      were 100%.

D.    Regulatory and Permitting Requirements
      Plan to seek RCRA permit.
                                A-41

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         APPENDIX B
Excerpts from DOE Order 5820.2A
             B-l

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U.S. Department of  Energy
         Washington, D.C.
                 ORDER
                                                                    DOE 5820.2A
                                                                       9-26-88
SUBJECT:   RADIOACTIVE WASTE MANAGEMENT
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.

2.  CANCELLATION.  DOE 5820.2, RADIOACTIVE WASTE MANAGEMENT OF 2-6-84.

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 con-
    tracting 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).

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).

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,  transpor-
    tation, 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.

6.  REFERENCES.  (See Attachment 1.)

7.  DEFINITIONS.  (See Attachment 2.)

8.  RESPONSIBILITIES.

    a.  Assistant Secretary for Defense Programs (DP-1) has authority for estab-
        lishing 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
DISTRIBUTION:

All Departmental Elements
                                    B-2
INITIATED BY:

Office of Defense Waste and
  Transportation Management

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                                                               DOE 5820.2A

                                                                  9-26-88

OP-1 programmatic decisions  include waste management considerations when
appropriate.  Specific responsibilities  include:

(1) Assuring the safe storage and disposal of all DOE waste other than
    that managed by NE-1 and RW-1;

(2) Implementing new and alternative technologies and processes to improve
    management of OP waste;

(3) Developing and operating the Waste Isolation Pilot Plant, a facility
    near Carlsbad, New Mexico, for conducting research and development to
    demonstrate the safe disposal of radioactive waste from defense
    activities and programs of the United States exempted from regulation
    by the Nuclear Regulatory Commission;

(4) Conducting research and development  for DOE waste transportation
    systems and providing for safe, efficient, and economic transport of
    materials, pursuant to DOE 1540.1;

(5) Managing DP contaminated facilities, including those that are surplus
    to program needs;

(6) Assuring that the environmental, safety, health, transportation,
    quality assurance, unusual occurrence, construction project manage-
    ment, real estate management, and facility design requirements set
    forth in DOE Orders are Implemented for DP-1 waste management pro-
    grams; and

(7) Supporting the information needs of the Integrated Data Base program
    on defense program activities and jointly managing and funding the
    program in cooperation with NE-1 and RW-1 (see Attachment 1, page 3,
    paragraph 23).

Director of Defense Waste and Transportation Management (DP-12) Is charged
with carrying out OP-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.  Specific responsibilities
include:

(1) Management of storage, treatment, and disposal operations for defense
    waste;

(2) Managing defense contaminated facilities that are excess to program^
    matic needs;

(3) Reviewing and approving new or alternative waste management practices;
                                    B-3

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DOE 5820.2A

  9-26-88
    c.
 (4)  Conducting  research  and  development  for DOE waste transportation
     systems  and providing  for  safe,  efficient, and economic transport of
     materials,  pursuant  to DOE 1540.1;

 (5)  Conducting  independent health, safety, and quality assurance audits of
     field waste management organizations, in cooperation with EH-1  to
     assess compliance with the requirements of this Order;

 (6)  Issuing,  in consultation with EH-1,  approval of exemptions from the
     requirements of this Order (paragraph 9) that are proposed by other
     Headquarters or field  organizations;

 (7)  Issuing  in  consultation  with EH-1 and Headquarters program organiza-
     tions updated waste management guidance; and

 (8)  Approving documents, reports, and plans, as required by this Order,
     for DP programs and activities.

 Director of  Civilian Radioactive Waste Management (RW-U 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.  Specific
 responsibilities Include the following:

 (1) The long-term care, in cooperation with NE-1, of closed commercial
     low-level waste sites  transferred to DOE;

 (2) Lead responsibility, 1n cooperation with NE-1 and DP-1, for the Inte-
    grated Data Base program (see Attachment 1, page 3, paragraph 23);

 (3) Assurance that the requirements of DOE Orders are met for all waste
    management activities under RW-1 purview; and

 (4) Independent health, safety, and quality assurance audits of field
    waste management organizations In cooperation with EH-1, to assess
    compliance with the requirements of this Order.

Assistant Secretary for Nuclear Energy (NE-1) 1s responsible for assuring
that waste generated by operations funded by NE-1 1s managed according to
the requirements of this Order and that NE-1 program decisions include
waste management considerations, as appropriate.  Specific
responsibilities Include:

 (1) Managing OOE wastes from NE-1 operations and activities, Including the
    breeder reactor, space nuclear, naval reactor, and remedial action
    programs, as well as the Three Mile  Island and West Valley projects;
                                     B-4

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                                                                DOE 5820.2A

                                                                   9-26-88

 (2)  Managing waste generated by DOE enrichment operations and disposed at
     sites located at the Oak Ridge, Portsmouth, and Paducah gaseous
     diffusion plants;

 (3)  Managing any greater than Class C low-level waste, as defined in
     Section 3(b)(l)(0)  of Public Law 99-240,  which may be accepted by the
     Department for disposal in cooperation with DP-1;

 (4)  Developing and implementing alternative technologies  and processes to
     support storage and disposal  of waste or  spent fuel generated by NE-1
     operations;

 (5)  Managing NE-1 contaminated facilities, Including those that are
     surplus to program  needs, and waste storage/disposal  sites;

 (6)  Developing and implementing commercial applications for waste
     byproducts;

 (7)  Assuring that environmental,  safety, health, transportation,  quality
     assurance,  unusual  occurrence, construction project management,  real
     estate  management,  and facility design requirements set forth in DOE
     Orders,  are implemented for NE-1 waste management  programs;

 (8)  Conducting independent health, safety, and  quality assurance  audits  of
     field waste management operations in cooperation with  EH-1  to assess
     compliance with the requirements of this  Order; and

 (9)  Supporting the information needs of the Integrated Data Base  program
     on civilian nuclear program activities 1n cooperation  with  DP-1  and
     RW-1  (see Attachment 1, page  3,  paragraph 23).

Assistant Secretary for  Environment. Safety and Health .(EH-1) is responsible
for providing an  independent overview of DOE  radioactive waste manaaement and
decommissioning programs to determine compliance, with  DOE  environment,
safety, and  health requirements and  applicable  Environmental  Protection
Agency (EPA)  and  state  regulations.   Specific responsibilities  Include:

(1) Advising  the  Secretary of the status of Departmental compliance  with
    the requirements  of this Order and applicable  provisions  of DOE
     5480.18,  and  EH Orders.

(2) Conducting  independent appraisals  and  audits of DOE waste management
    and decommissioning programs  consistent with the requirements  of DOE
     5482.18.

(3)  Reviewing site Waste Management  Plans  and Decommissioning Project
     Plans with  regard to compliance  with DOE  environment,  safety,  and
     health  requirements.
                                   B-5

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DOE 5820.2A
  9-26-88
    1.
    j.
Director, Naval Nuclear  Propulsion Program;  Executive Order  12344,
statutorily prescribed by  PL 98-525  (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.

Directors of other Headquarters Program Organizations are responsible for
implementing the requirements of this Order  for all DOE waste generated by
their programs until it  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.

Office of General Counsel  (GC-1)  provides legal advice to program organi-
zations 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 Conser-
vation and Recovery Act, the Comprehensive Environmental Response, Compen-
sation, and Liability Act, the Superfund Amendments and Reauthorization
Act, and other legal authorities in conjunction with proposed waste
management and decommissioning activities.

Assistant Secretary, Management and Administration (MA-1) is responsible
for providing contractual  and business advice to program organizations
regarding DOE waste management activities, including use of DOE management
and operating contractors  in such activities.

Heads of Field Organizations are responsible for all activities that
affect the treatment, 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 certifi-
cation, 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
                                      B-6

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                                                                 DOE 5820.2A
                                                                  9-26-88
  operations  at  their  sites  are  conducted  in  compliance with the require-
  ments  of  this  Order  and comply with  all  applicable Federal, State,  and
  local  statutes.  Specific  responsibilities  include the following:

  (1)  Preparing  annual updates of the  Waste Management Plans for all  oper-
      ations  under their purview according to the  format in  the  Waste
      Management Plan  Outline, Chapter VI.    These Plans shall be submitted
      in December of each year and be  distributed  to DP-12,  EH-1,  and other
      appropriate Headquarters organizations  for review and  comment.

  (2)  Preparing  supplements  to this Order  that identify specific detailed
      requirements for waste management practices  and procedures conducted
      at their sites.

  (3)  Overseeing fiscal responsibility  for transporting waste and
      establishing of  fees to recover the  incremental  costs  for  storage  and
      disposal of DOE waste  at their sites.

  (4)  Establishing waste acceptance criteria  and reviewing waste minimiza-
      tion plans of other field organization's facilities that generate
      radioactive, hazardous, or mixed waste  that will  be treated, stored or
      disposed of at facilities under their purview.

  (5)  Auditing any waste generating organization that  ships waste to  their
      sites for treatment, storage, or disposal to assure compliance with
      established waste acceptance criteria.

  (6)  Maintaining environmental, safety, and  health programs for all DOE
     waste management operations under their purview.

  (7) Managing contaminated facilities under  their purview according to the
     requirements of this Order and guidance provided by Headquarters
     program offices,  providing program secretarial officers with the
     necessary characterizutlonal and engineering data for contaminated
     facilities, and developing site-specific priorities, schedules,  and
     costs for remedial  actions.

 (8) Assuring that the requirements of the Order,  applicable to contractors
     and subcontractors  whose contracts fall  within the scope of the  Order,
     are properly reflected 1n the contract  document.

 (9) Defining and assuring that required quality assurance activities are
     established and implemented for all  waste management activities  under
     their purview,  pursuant to the requirements of DOE 5700.6B and
     reporting unusual occurrences pursuant  to the requirements of DOE
     5000.3.

(10) Providing information, as requested,  to  the Integrated  Data Base Pro-
     gram,  Oak Ridge National  Laboratory,  for all  types of waste under

                                   B-7

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 DOE 5820.2A
7 (and 8)
    9-26-88

             their purview,  including:  high-level waste; transuranic waste;  low-
             level waste; naturally occurring  and accelerator produced  radioactive
             material; mixed waste; and wastes from decommissioning activities  (see
             Attachment 1, page 3, paragraph 23).

     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 activi-
         ties.  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 activi-
         ties leading to permanent isolation of transuranic waste from the
         biosphere.

  9* EXEMPTIONS.  Exemptions from the requirements of this Order may be granted
     only with the approval of OP-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 organi-
     zations and adopted with the approval of DP-12 and EH-1.

 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.

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.

BY ORDER OF THE SECRETARY OF ENERGY :
                                 LAWRENCE F. DAVENPORT
                                 Assistant Secretary
                                 Management and Administration

                                      B-8

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 DOE  5820.2A

   9-26-88
                                 TABLE OF CONTENTS
 CHAPTER  I  HIGH-LEVEL WASTE
                                                                               Page
   1.    PURPOSE	                                T  i
   2.    POLICY	          *  *	        ;  i
   3.    REQUIREMENTS	!!.*.*!!!!!.*!!        Jli
        a.  Design  .	!!!!!!        i_i
        b.  Storage Operations  -  Doubly Contained  Systems  ....!!!."        i~2
        c.  Storage Operations  -  Singly Contained  Tank
           Systems .	  ..........        1-6
        d.  Disposal	        1-7

CHAPTER II MANAGEMENT OF TRANSURANIC WASTE

   1.    PURPOSE	                   TT-I
   2.    POLICY	  .        "    *       n-1
   3.    REQUIREMENTS	...".**!       II-l
        a.  Waste Classification	 . .	       II-l
        b.  Transuranlc Waste Generation and Treatment	       11-2
        c.  Transuranlc Waste Certification	       II-3
        d.  Transuranlc Waste Packaging	       n_4
        e.  Temporary Storage at Generating Sites	.       11-4
        f.  Transportation/Shipping to the Waste Isolation
             Pilot Plant 	 ..... 	 .....       II-5
       g.  Interim Storage	       II_6
       h.  Waste Isolation Pilot Plant	       11-9
        1.  Burled Transuran1c-Contam1nated Waste  	 	     11-10
       j.  Quality Assurance .  . .  . „	     11-11

CHAPTER III MANAGEMENT OF LOW-LEVEL WASTE

  1.   PURPOSE	 .	       ni-1
  2.   POLICY	           III-l
  3.   REQUIREMENTS	     IH_1
       a.  Performance Objectives  .........	     III-l
       b.  Performance Assessment  .	     111-2
       c.  Waste Generation	     111-2
       d.  Waste Characterization  .	     III-3
       e.  Waste Acceptance Criteria .	     III-3
       f.  Waste Treatment ..........  		 .     III-4
       g.  Shipment	     III-5
       h.  Long Term  Storage	     111-5
       1.  Disposal   .	 .     III-6
                                      B-9

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11
DOE 5820.2A

  9-26-88
                          TABLE OF CONTENTS  (CONTINUED)
       j.  Disposal Site Closure/Post Closure  	     III-9
       k.  Environmental Monitoring  	     III-9
       1.  Quality Assurance  	    111-10
       m.  Records and Reports	    111-10

CHAPTER IV MANAGEMENT OF HASTE  CONTAINING NATURALLY OCCURRING
       AND ACCELERATOR PRODUCED RADIOACTIVE MATERIAL

  1.   PURPOSE	      IV-1
  2.   POLICY	      IV-1
  3.   REQUIREMENTS	      IV-1
       a.  Waste Management   	      IV-1
       b.  Quality Assurance  	      IV-2


CHAPTER V DECOMMISSIONING OF RADIOACTIVELY CONTAMINATED
       FACILITIES

  1.   PURPOSE	       V-l
  2.   POLICY	       V-l
  3.   REQUIREMENTS	       V-l
       a.  General	       V-l
       b.  Facility Design	       V-2
       c.  Post-Operational Activities 	       V-2
       d.  Decommissioning Project Activities  	       V-3
       e.  Quality Assurance  	       V-6

CHAPTER VI WASTE MANAGEMENT PLAN OUTLINE

  1.   PURPOSE	     VI-1
  2.   DISCUSSION	     VI-1
  3.   FORMAT FOR WASTE MANAGEMENT PLANS 	     VI-1
       a.  Executive Summary	     VI-1
       b.  General Site Information	     VI-2
       c.  Radioactive and Mixed Waste Management	     VI-2
       d.  Hazardous Waste Management (OP Facilities)  	     VI-3
       e.  Schedule and Cost Summary	     VI-4
       f.  Environmental Monitoring Programs . .	     VI-4
       h.  Related Subjects   	     VI-4
                     ATTACHMENT VI-I - WASTE MANAGEMENT
                     DOCUMENTATION REQUIREMENTS  	     VI-5
                                          B-10

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DOE 5820.2A


  9-26-88
III-l
                                    CHAPTER III

                           MANAGEMENT OF LOW-LEVEL WASTE
1.  PURPOSE.  To establish policies, requirements and guidelines, for managing the
    Department's solid low-level waste.

2.  POLICY.

    a.  DOE-low-level waste operations shall be managed to protect the health and
        safety of the public, preserve the environment of the waste management
        facilities, and ensure that no legacy requiring remedial action remains
        after operations have been terminated.

    b.  DOE-low-level waste shall be managed on a systematic basis using the most
        appropriate combination of waste generation reduction, segregation,
        treatment, and disposal practices so that the radioactive components are
        contained and the overall system cost effectiveness is maximized.

    c.  DOE-low-level waste shall be disposed of on the site at which it is gen-
        erated, if practical, or if on-site disposal capability is not available,
        at another DOE disposal facility.

    d.  DOE-low-level waste that contains non-radioactive hazardous waste
        components (mixed waste) shall conform to the requirements of this order,
        applicable EH Orders, and shall also be regulated by the appropriate
        regional authorities under the Resource Conservation and Recovery Act.

3.  REQUIREMENTS.

    a.  Performance Objectives.  DOE-low-level waste that has not been disposed of
        prior to issuance of this Order shall be managed on the schedule developed
        in the Implementation Plan (See page 7, paragraph 10) to accomplish the
        following:

        (1) Protect public health and safety in accordance with standards
            specified in applicable EH Orders and other DOE Orders.

        (2) Assure that external exposure to the waste and concentrations of
            radioactive material which may be released into surface water, ground
            water, soil, plants and animals results in an effective dose equiva-
            lent that does not exceed 25 mrem/yr to any member of the public.
            Releases to the atmosphere shall meet the requirements of 40 CFR 61.
            Reasonable effort should be made to maintain releases of radioactivity
            in effluents to the general environment as low as Is reasonably
            achievable.
                                    B-ll

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ni-2                                                                  DOE 5820.2A

                                                                         9-26-88

        (3)  Assure that the committed effective dose equivalents received by
            individuals who inadvertently may intrude into the facility after the
            loss of active institutional control  (100 years)  will  not exceed 100
            mretn/yr for continuous exposure or 500 mrem for a single acute
            exposure.

        (4)  Protect ground water resources, consistent with Federal,  State and
            local requirements.

    b.   Performance Assessment.

        (1)  Field organizations  with disposal  sites shall  prepare  and maintain a
            site specific  radiological  performance assessment for  the disposal of
            waste for the  purpose of demonstrating compliance with the performance
            objectives  stated  in paragraph 3a.

        (2)  Each field  organization shall, for each DOE reservation within its
            cognizance,  prepare  and maintain an overall  waste management  systems
            performance assessment supporting  the  combination of waste management
            practices used in  generation reduction,  segregation, treatment,  pack-
            aging,  storage,  and  disposal.   Background and  guidance on waste
            management  systems performance assessment is provided  in  Attachment  1,
            page 3,  paragraph  21.

        (3)  Where practical, monitoring  measurements  to  evaluate actual and pro-
            spective performance should  be made at locations  as  required,  within
            and  outside each facility and  disposal  site.   Monitoring  should also
            be used  to  validate  or modify  the  models  used  in  performance
            assessments.

   c.  Haste Generation.

       (1) Technical and  administrative controls  shall  be directed to reducing
           the  gross volume of  waste generated and/or the amount  of  radioactivity
           requiring disposal.  Waste reduction efforts shall include considera-
           tion of process modification,  process  optimization, materials  substi-
           tution and decontamination.

       (2) Waste Generation Reduction.  All DOE-low-level  waste generators  shall
           establish auditable  programs (goals, incentives,  procedures, and
           reports) to  assure that the  amount of  low-level waste  generated  and/or
            shipped  for  disposal  is minimized.

       (3) Waste Segregation.   Each DOE-low-level waste generator shall separate
           uncontamlnated waste from low-level waste  to facilitate cost effective
            treatment and  disposal.
                                         B-12

-------
DOE 5820.2A
  9-26-88
                                                                              111-3
        (4) Waste Minimization.  Each OOE-low-level waste generator preparing a
            design for a new process or process change shall incorporate
            principles into the design that will minimize the generation of low-
            level waste.

    d.  Waste Characterization.

        (1) Low-level waste shall be characterized with sufficient accuracy to
            permit proper segregation, treatment, storage, and disposal.  This
            characterization shall ensure that, upon generation and after pro-
            cessing, the actual physical and chemical characteristics and major
            radionuclide content are recorded and known during all stages of the
            waste management process.

        (2) Waste characterization data shall be recorded on a waste manifest, as
            required by paragraph 3m, and shall include:

            (a) The physical and chemical characteristics of the waste.

            (b) Volume of the waste (total of waste and any solidification or
                absorbent media).

            (c) Weight of the waste (total of waste and any solidification or
                absorbent media).

            (d) Major radionuclides and their concentrations.

            (e) Packaging date, package weight, and external volume.

        (3) The concentration of a radionuclide may be determined by direct
            methods or by indirect methods such as use of scaling factors which
            relate the inferred concentration of one radionuclide to another that
            is measured, or radionuclide material accountability, if there is
            reasonable assurance that the Indirect methods can be correlated with
            actual measurements.

    e.  Waste Acceptance Criteria.

        (1) Waste shipped from one field organization to another for treatment,
            storage or disposal shall be done in accordance with the requirements
            established by the operations office having responsibility for
            operations of the receiving facility.

        (2) Waste acceptance criteria shall be established for each low-level
            waste treatment, storage, and disposal facility, and submitted to the
            cognizant field organization.

        (3) Generators of waste shall implement a low-level waste certification
            program to provide assurance that the waste acceptance criteria for
                                     B-13

-------
II1-4                                                                  DOE 5820.2A

                                                                         9-26-88

            any low-level  waste treatment, storage, or disposal facility used by
            the generator  are met.  Generators and facilities receiving the waste
            are jointly responsible for assuring compliance with waste acceptance
            criteria.   Generators are financially responsible for actions required
            due to  nonconformance.

        (4)  Generator  low-level waste certification programs shall  be  subject to  a
            periodic audit by operators of facilities  to  which the  waste is sent
            by the  generator.

        (5)  The waste  acceptance criteria for storage, treatment, or disposal
            facilities shall  address the following issues:

            (a) Allowable  quantities/concentrations of specific radioisotopes to
                be  handled, processed,  stored or disposed of;

            (b) Criticality safety requirements (waste forms and geometries);

            (c) Restrictions  regarding  low-level waste classified for  security
                reasons;

            (d)  External radiation and  internal heat generation;

            (e)  Restrictions  on the generation of harmful gases, vapors,  or
                liquids in waste;

            (f)  Chemical and  structural  stability of waste  packages, radiation
                effects, microbial  activity,  chemical  reactions, and moisture;

            (g)  Restrictions  for chelating and complexing agents having  the
                potential  for mobilizing radionuclides; and

            (h)  Quantity of free liquids.

    f.   Waste  Treatment.

        (1)  Haste shall be treated  by appropriate methods so that the  disposal
            site can meet  the performance objectives stated in paragraph 3a.

        (2)  Waste treatment techniques  such as incineration, shredding,  and com-
            paction  to reduce volume and provide more  stable waste  forms shall be
            implemented as necessary to meet  performance  requirements.   Use of
            waste treatment techniques  to increase the life of the  disposal
            facility and improve long-term facility performance, by improved  site
            stability  and  reduction of  infiltrating water,  1s required to the
            extent  it  is cost effective.
                                        B-14

-------
  5820.2A
III-5
9-26-S
      (3) The development of large scale waste treatment facilities shall be
          supported by appropriate the National Environmental Policy Act
          documentation in addition to the following:

          (a) A document shall be prepared that analyzes waste streams needing
              treatment, treatment options considered and a rationale for selec-
              tion of proposed treatment processes;

          (b) A construction design report including projected waste throughputs
              and treatment methods, construction and operating cost estimates;
              and

          (c) A Safety Analysis Report.

      (4) Operation of waste treatment facilities shall be supported by adequate
          documentation including the following:

          (a) Operation and maintenance procedures;

          (b) Personnel training and qualification procedures;

          (c) Monitoring and emergency response plans; and

          (d) Records shall be maintained for each package of low-level waste
              that enters and leaves the treatment facility.

  g.  Shipment.

      (1) The volume of waste and number of shipments of low-level waste shall
          be minimized and the shipments will be conducted based on plans
          developed by field organizations.  Off site shipment of low-level
          waste shall be in compliance with DOE 1540.1.

      (2) Generators shall provide an annual forecast in the third quarter of
          the fiscal year to the field organizations managing the off-site
          disposal facility to which the waste is to be shipped.

      (3) Generators must receive advance approval from the receiving facility
          and shall certify prior to shipment that waste meets the receiving
          facility waste acceptance criteria.  The certification program shall
          be auditable and able to withstand  independent review.

      (4) Each package of waste must comply with the  labeling requirements of
          DOE  1540.1.

   h.  Lonq-Term  Storage.

      (1) Low-level waste  shall be  stored by  appropriate methods, to achieve  the
          performance objectives  stated  in paragraph  3a.
                                  B-15

-------
m-6
                                                                       DOE 5820.2A
                                                                        9-26-88
        (2)  Records shall  be maintained for all  low-level  waste that enters and
            leaves the storage facility, (see paragraph 3m).

        (3)  The development and operation of a waste storage  facility shall be
            supported by the following documentation (two  or  more of these may be
            combined for convenience):

            (a)  An analysis which identifies the need for  the storage facility;

            (b)  A Construction Design Report, including projected waste  planned
                for storage; construction and operating cost  estimates;

            (c)  A Safety Analysis Report and appropriate National  Environmental
                Policy Act documentation;  and

            (d)  Operational  procedures and plans.

        (4)  Storage of waste to allow for  nuclides  to decay or storage of  wastes
            until they can be disposed of  by approved methods are acceptable.

    i.   Disposal.

        (1)  Low-level  waste  shall  be  disposed of  by methods appropriate  to achieve
            the  performance  objectives stated in  paragraph 3a,  consistent  with the
            disposal  site  radiological  performance  assessment in  paragraph 3b.

        (2)  Engineered modifications  (stabilization,  packaging, burial depth,
            barriers)  for  specific waste types and  for specific waste compositions
            (fission products,  induced radioactivity, uranium,  thorium,  radium)
            for  each disposal  site shall be developed through the  performance
            assessment model  (see  paragraph 3b(l)).   In the course of this
            process, site  specific waste classification limits may be developed if
            operationally  useful  in determining how specific  wastes  should be
            stabilized and packaged for disposal.

        (3)  An Oversight and Peer  Review Panel of DOE,  contractor, and other
            specialists  in performance  assessments  will  be selected  by DP-12,  with
            participation  by EH-1  and operations office representatives.   Through
            consultation and review,  this  panel shall  ensure  consistency and tech-
            nical  quality  around the  DOE complex  in the development  and  applica-
            tion of performance assessment models that include  site  specific
            geohydrology and waste composition.

        (4)  Disposition of waste designated as greater-than-class  C,  as  defined in
            10 CFR 61.55,  must be  handled  as special  cases.   Disposal  systems  for
            such waste must  be justified by a specific performance assessment
            through the National Environmental Policy Act  process  and with the
            concurrence of DP-12 for  all OP-1 disposal  facilities  and of NE-20 for
            those disposal facilities  under the cognizance of NE-1.

                                         B-16

-------
OOE 5820.2A

  9-26-88
III-7
        (5) The following are additional disposal requirements intended either to
            Improve stability of the disposal site or to facilitate handling and
            provide protection of the health and safety of personnel at the disoo-
            sal site:

            (a) Waste  must not be packaged for disposal in cardboard or fiberboard
                boxes, unless such boxes meet DOT requirements and contain stabi-
                lized  waste with a minimum of void space.   For all types of con-
                tainers,  void spaces within the waste and  between the waste and
                its packaging shall be reduced as much as  practical.

            (b) Liquid wastes, or wastes containing free liquid,  must be converted
                into a form that contains as little freestanding  and noncorrosive
                liquid as is reasonably achievable,  but, in no case, shall  the
                liquid exceed 1 percent of the volume of the waste when the waste
                is  in  a disposal container, or 0.5 percent  of  the volume of the
                waste  processed to a stable form.

            (c)  Waste  must not be readily capable of detonation or of explosive
                decomposition or reaction at normal  pressures  and temperatures, or
                of  explosive reaction with water.

            (d)  Waste  must not contain,  or be capable of generating, quantities of
                toxic  gases,  vapors,  or  fumes harmful  to persons  transporting,
                handling,  or disposing of the waste.   This  does not apply to
                radioactive gaseous waste packaged as identified  in paragraph
            (e) Waste in a gaseous form must be packaged at a pressure that does
               not exceed 1.5 atmospheres at 20°C.

            (f) Waste must not be pyrophoric.  Pyrophoric materials contained in
               waste shall be treated, prepared, and packaged to be nonflammable.

       (6) Waste containing amounts of radlonuclides below regulatory concern, as
           defined by Federal regulations, may be disposed without regard to
           radioactivity content.

       <7) Disposal Site Selection.

           (a) Disposal site selection criteria (based on planned waste confine-
               ment technology) shall be developed for establishing new low-level
               waste disposal sites.

           (b) Disposal site selection shall be based on an evaluation of the
               prospective site 1n conjunction with planned waste confinement
               technology, and in accordance with the the National Environmental
               Policy Act process.
                                    B-17

-------
III-8
                                                                       DOE 5820.2A
                                                                         9-26-88
            (c)  The disposal site shall have hydrogeologic characteristics which,
                in conjunction with the planned waste confinement technology, will
                protect the groundwater resource.

            (d)  The potential  for natural  hazards  such as  floods, erosion, torna-
                does,  earthquakes, and volcanoes shall be  considered  in  site
                selection.

            (e)  Site selection criteria shall  address the  impact  on current  and
                projected populations, land  use resource development  plans and
                nearby public  facilities,  accessibility to transportation  routes
                and  utilities,  and the location of waste generation.

        (8)  Disposal Facility  and  Disposal Site Design.

            (a)  Design criteria shall  be established  prior to selection  of new
                disposal facilities, new disposal  sites, or both.  These design
                criteria shall  be  based on analyses of physiographic, environ-
                mental, and  hydrogeological data to assure that the policy and
                requirements of this Order can  be met.  The criteria  shall be also
                based  on assessments of projected waste volumes, waste character-
                istics, and  facility and disposal site performance.

            (b)  Disposal units  shall be designed consistent with disposal  site
                hydrology, geology, and waste characteristics and in accordance
               with the National Environmental Policy Act process.

       (9) Disposal Facility Operations.

           (a) Field organizations shall develop and implement operating pro-
               cedures for low-level waste disposal facilities that protect the
               environment, health and safety of the public, and facility person-
               nel; ensure the security of the facility;  minimize the need for
               long-term control; and meet the requirements of the closure/post-
               closure plan.

           (b) Permanent Identification markers for disposal  excavations and
               monitoring wells shall  be emplaced.

           (c) Operating procedures shall  include  training for disposal  facility
               operating personnel, emergency response plans,  and a system of
               reporting unusual  occurrences according to  DOE  5000.3.

           (d) Waste placement Into disposal  units should  minimize voids between
               containers.

           (e) Operations are  to  be conducted so that active waste disposal
              operations will  not have an adverse effect  on filled disposal
              units.
                                         B-18

-------
DOE 5820.2A
III-9
  9-26-88
        Disposal Site Closure/Post Closure.

        (1) Field organizations shall develop site-specific comprehensive closure
            plans for new and existing operating low level waste disposal sites.
            The plan shall address closure of disposal sites within a 5-year
            period after each is filled and shall conform to the requirements of
            the National Environmental Policy Act process.  Performance objectives
            for existing disposal sites shall be developed on a case-by-case basis
            as part of the National Environmental Policy Act process.

        (2) During closure and post closure, residual radioactivity levels for
            surface soils shall comply with existing JOE decommissioning
            guidelines.

        (3) Corrective measures shall be applied to new disposal sites or individ-
            ual disposal units if conditions occur or are forecasted that could
            jeopardize attainment of the performance objectives of this Order.

        (4) Inactive disposal facilities, disposal sites, and disposal units shall
            be managed in conformance with the Resource Conservation and Recovery
            Act, the Comprehensive Environmental Response, Compensation, and
            Liability Act, and the Superfund Amendments and Reauthorization Act,
            or, If mixed waste is involved, may be Included in permit applications
            for operation of contiguous disposal facilities.

        (5) Closure plans for new and existing operating low-level waste disposal
            facilities shall be reviewed and approved by the appropriate field
            organization.

        (6) Termination of monitoring and maintenance activity at closed facili-
            ties or sites shall be based on an analysis of site performance at the
            end of the Institutional  control period.

        Environmental Monitoring.

        (1) Each operational or non-operational low-level waste treatment,
            storage, and disposal facility shall be monitored by an environmental
            monitoring program that conforms with DOE 5484.1 and, at a minimum,
            meet the requirements of paragraph 3K(2) through 3K(4).

        (2) The environmental monitoring program shall be designed to measure:
            (a) operational effluent releases; (b) migration of radionuclides;
            (c) disposal unit subsidence; and (d) changes in disposal facility and
            disposal site parameters which may affect long-term site performance.

        (3) Based on the characteristics of the facility being monitored, the
            environmental monitoring program may include, but not necessarily be
            limited to, monirar*nci surf ace soil, air, surface water, and, in the
            subsurface, soil art* wter, both in the saturated and the unsaturated
            zones.
                                   B-19

-------
111-10
                                                                       DOE 5820.2A
                                                                         9-26-88
        (4) The monitoring program shall be capable of detecting changing trends
            in performance sufficiently in advance to allow application of any
            necessary corrective action prior to exceeding performance objectives.
            The monitoring program shall be able to ascertain whether or not
            effluents from each treatment, storage, or disposal  facility or
            disposal  site meet the requirements of applicable EH Orders.

    1-   Quality Assurance.  Consistent with DOE 5700.6B,  the low-level  waste
        operational and  disposal  practices shall be conducted in accordance with
        applicable requirements of American National  Standards Institute/American
        Society of Mechanical  Engineers Nuclear Quality As«:jrance-l  (See Attach-
        ment 1, page  5,  paragraph 48)  and other appropriate national  consensus
        standards.

    n>.   Records and Reports.

        (1)  Each field organization shall  develop and  maintain a record keeping
            system that  records the following:   a historical  record  of  waste
            generated, treated, stored,  shipped, disposed of,  or both;  at the
            facilities under its  cognizance.  The data maintained shall  include
            all  data  necessary to show that the waste  was properly classified,
            treated,  stored, shipped,  and/or disposed  of.  The data maintained in
            the system shall be based  on the data recorded on waste manifests.

        (2)  Haste  Manifest.  Records shall  be kept and accompany each waste
            package from generator through  final  disposal.   The  manifest shall
            contain data necessary to  document  the proper classification,  and
            assist in determining proper treatment, storage,  and disposal  of the
            waste.  Waste  manifests will  be kept as permanent  records.   At a
            minimum, the following data  will  be included:

            (a)  Waste physical  and chemical  characteristics,

            (b)  Quantity of each  major radionuclide present,

            (c)  Weight of  the  waste (total  of waste and any solidification or
                absorbent  media),

            (d)  Volume of  the  waste (total  of waste and any solidification or
                absorbent  media),  and

            (e)  Other data necessary to  demonstrate compliance with waste
                acceptance criteria.
                                            B-20

-------
                                  APPENDIX C
            Schematics and Flow Diagrams of Selected Incinerator Systems
Appendix C-l:

Appendix C-2:

Appendix C-3:

Appendix C-4:

Appendix C-5:
Glass Melter - Mound Laboratory

Consolidated Incineration Facility - Savannah River Site

Controlled Air Incinerator - Los Alamos National Laboratory

WERF Incinerator - Idaho National Engineering Laboratory

TSCA Incinerator - Oak Ridge Gaseous Diffusion Plant
                                      C-l

-------
        EXHAUSTER
       HEAT
     EXCHANGER I
     TO
WASTE SLUDGE •
  DISPOSAL
ABSOLUTE.

 FILTER  f ABSORBANT
           FILTER
                   EXHAUSTER


LIQUID
FILTER
V

SCRUB 1
                                            RECYCLE
                                             TANK
LIQUOR
PUMP
                  |
       !   1 - '
       >*X
                                                                      WATER
—*	CAUSTIC


.    DRAIN TO
 WASTE DISPOSAL
                                                                                           GLASS
                                                                                          WELTER
                                           Appendix C-l
                                Glass Melter - Mound Laboratory
                                                C-2

-------
        STEAU
                                                              SPRAY WATER*
                                                                            REHEATER
 SOLIDS —1 *


LIQUIDS	2 *
FUEL—S  «
OIL
•
ROTARY
KILN
           AIM


1
SCRUSSER
?UROE
ANK
                            IS
                   1
                                                      IT
  IT


MAKE-UP
 WATER
                                                                            IS
                                                                           HE»A
                                                                           WLTER
                                                                            IS
                                                   CROSSFLOW
                                                   FILTER
                                                   SYSTEM
                                                                                 TO STACK
                                                                            TO SLOWDOWN
                                                                            STORAGE TANKS
                   ASHOUT AND
                   CEMENTATION
                                           n

                                           DISPOSAL
                                     GIF PROCESS FLOWSHEET
                                       Appendix C-2

                  Consolidated Incineration Facility - Savannah River Site
                                          C-3

-------

                                                          1
                                                          i
                                                          1
                                                          .VJ
                                                                           «J

                                                                           O


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                                                                           G
                                                                           O

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C-4

-------
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               o
               00
               c
               •c
               
-------
                                                 o
                                                 O

                                                 
-------
             APPENDIX D
Chemicals Approved for Incineration at DSSI
                  D-l

-------
              Appendix D

Cfremfcih Approved for
                                                at OSSI
 14 DicfaloioetfaiM
 14 Dfefaloroeftat
 Ul-TtidUoroeftnt
                              UOTi
                              U077
 U^-THch
 U
                              RM3/U227
                              F001/POQ
 XtDtona*
 2-NitropropUM
                              U10WXTO
                              UQS
                              FDQVU17I
                              UD01

                                                UDOS
                                                UOM
                                                UOtt
                                                U007
                                                FOQS/DQtt
                                                FOQ3/KO!
                                                urn
                                                PDOW03B
                                                FOQ/U071
                                                mwm
                                               nut
                                               Don
                                               FOOWU2
BhylElhw
Etlqrko* gjycol
Fonnaldefaydt
Funa
                             Don
                             U122
                             U124
                                D-2

-------
Appendix D - Continued

                    ffazt
                                                         WftttA
HepUflt
Hexane
Isoimyl alcohol
Isobutyf alcohol
I$octane/2A4-Trimethylneataffle
Methane, brooo-
Methane, dibrooo
Methane, trichlofo
Methanol
Metbylene Chloride
Methyl Ethyl
Methyl bobutyl
Methyl Pyrrole
Mineral Spiriti
Naphthalene
Nitrobenzene
Nonane
                           0001
                           DOOl
                           D001
                           TOVU140
                           DOOl
                           UQ29
                           UD6I
                           U044
                           FOQ3AJ154
                           FXQ/
Peatane. __
Propane, l&dkhloro
2-Propeaal
JrfOpyiCQft ,
Pyridiae
Tetrahydroftma
I,li2-Tetrichloroethaae
1,1,1,2-Tetrachloroethaae
Tetrachloroethylene
Toluene
o»ToluidbM
                           PQ03/U161
                           DOOl
                           DOOl
                           UU5
                           F004/U10
                           DOOl
                           pooi
                           DOOl
                           DOOl
                                                       FDQS/P073KJ1*
                                                       U2B
                                                       U209
                                                       DQ01A1S2B
pToluidfe*
Trichloroethyteoe
Tricfaloroflyomimfthane
Triealoranethaae
m-Xyleae
o-Xyieae
p-Xyleas
Unlisted Igaftabte Watte
Spent Sohreats
Speat SoKeats
Speai Solveats
Spent Solvents
Spent Solvents
Arsenic
Barium
                           DOM/UIO _
                           F001/FOG2/UZ2S
                           U044/DOOI
                           f009/U23S||!DOOI
                           DOOl
                           FDOI
                           RRS
          D-3
                           FOQS
                           DOX
                           DOQS

-------
                          Appendix D • Continued
 Chromm
 Lead
 Merauy
 SelinhoB
 SOvtr
 Eadria
0007
TonpfasM
2,4-D
2.4,5-1? (tOv«x)
Cubo« TetncUoridft
GhlorduM
GhlonbcBzetMi
DOW
DOU
D012
DOS
DOM
D01S
DOM
DOIT
D01I
DOIf
M-DkUoroboaeai
U-XXeUoroethaat
U-DiehloreetlgrkM
Heptschlor (and to tsntida)
HczicfaSorobcimM
TticUocottigtoM
2,44-TkfcfaJonj

Vinyl ChJorid*
                                  D-4

-------
                                APPENDIX E
         Proposed Mixed Waste Acceptance Criteria for WERF Incinerator
ITEM
LIMIT/REQUIREMENT
SOLID - Operational
Generally Prohibited Items
Heating Value
Halogen
Sulfur
Free liquids
Blended/Repackaged wastes
Water Content
Classified Waste
Gases, Vapors, Liquids
Complexing and Chelating Agents
Not allowed*
No limit - value required
-Chloride - 1% by weight*
Other halogens - no limit - value required
No limit - analysis required
Not allowed
Must be compatible*
No limit - not allowed as free liquid
Security Plan*
Requires special evaluation*
Requires special evaluation*
SOLID - Radiological
Alpha Radionuclides
External Radiation on Contact
Fissile Material
Tritium
Carbon- 14
Heat Generation
External Contamination
Ignitability
a. 0.5 nCi/g average for 24 hour period*
b. 10 nCi/g maximum/box*
a. 10 mR/hr/box average*
b. 200 mR/hr/shipping container*
Trace quantities*
0.285 mCi/lb*
0.285 mCi/lb*
Requires special evaluation*
a. 200 dpm/100 cm2 beta/gamma
b. 20 dpm/100 cm2 alpha
Ignitable wastes allowed - flash point
required*
* Case-by-case evaluation to be applied.
                                     E-l

-------
                           APPENDIX E (Continued)
          Proposed Mixed Waste Acceptance Criteria for WERF Incinerator
ITEM
Ignitability
Corrosivity
Reactivity
Toxicity
Listed Mixed Waste
Principal Organic Hazardous
Constituents (POHCs)
Polychlorinated Biphenyl
LIMIT/REQUIREMENT
Ignitable wastes allowed - flash point required*
Corrosives not allowed
Reactives not allowed
Toxicity wastes allowed - constituent quantities
required*
Allowed according to permits*
POHCs must have heat of combustion greater
than 432 Btu/lb
Must be less than 50 ppm
LIQUID - Operational
Heating Value
Halogen
Blended/Repackaged Wastes
Water Content
Gases, Vapors, Liquids
Viscosity
Particulate
Phosphates
Ash content
Complexing and Chelating Agents
> 10,000 But/lb*
Chloride - requires special evaluation*
Other halogens - no limit - value required
Must be compatible*
No immiscible layer allowed*
Requires special evaluation*
150 SSU
si 00 microns particle size
<0.1 weight % suspended particulate
No limit - value required
si. 2 weight %
Requires special evaluation*
LIQUID - Radiological
Alpha Radionuclides
External Radiation on Contact
Requires special evaluation*
a. 10 mR/hr/drum average*
b. 200 mR/hr/shipping container*
* Case-by-case evaluation to be applied.
                                      E-2

-------
                        APPENDIX E (Continued)
       Proposed Mixed Waste Acceptance Criteria for WERF Incinerator
ITEM
Fissile Material
Tritium
Carbon-14
Internal Heat Generation
External Contamination
LIMIT/REQUIREMENT
Trace quantities*
0.285 mCi/lb*
0.089 mCi/lb*
Requires special evaluation*
a. 200 dpm/100 cm2 beta/gamma
b. 20 dpm/100 cm2 alpha
LIQUID - Hazardous
Ignitability
Corrosivity
Reactivity
Toxicity
Listed Mixed Waste
POHCs
Polychlorinated Biphenyl
Ignitable waste allowed - flash point required*
Corrosives not allowed
Reactives not allowed
Toxicity wastes allowed - constituent quantities
required
Allowed according to permits*
POHCs must have heat of combustion greater
than 432 Btu/lb
Must be less than 50 ppm
CONTAINER/PACKAGES
Solid Waste Package
Package Preparation
Solid Package Weight
External Radiation
External Contamination
Special Solid Repackaging
Liquid Waste Package
Cardboard box <; 2' x 2' x 2'*
Poly liner, tapes shut*
601bs*
a. 10 mR/hr/box*
b. 200 mR/hr/shipping container*
a. 200 dpm/100 cm2 beta/gamma
b. 20 dpm/100 cm2 alpha
Notify WROC Engineering*
DOT approved drums*
Case-by-case evaluation to be applied.
                                    E-3

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                           APPENDIX E (Continued)
         Proposed Mixed Waste Acceptance Criteria for WERF Incinerator
ITEM
Package Loading, Integrity
External Radiation
External Contamination
Special Liquid Repackaging
General Marking and Labeling
Box Marking and Labeling for
WERF
LIMIT/REQUIREMENT
Free of dirt, 2" headspace, 800 Ib*
a. 10 mR/hr/drum average*
b. 200 mR/hr/shipping container*
a. 200 dpm/100 cm2 beta/gamma
b. 20 dpm/100 cm2 alpha
Notify WROC Engineering*
According to WWSB or MWSF WAC
- Radiation reading
- Hazard type and/or waste code
- Chloride quantity in Ibs
SHIPPING
Palleting and Rigging
Box Shipping Container
General Documentation
Documentation for WERF
According to WWSB or MWSF WAC
Cargo container*
According to WWSB or MWSF WAC
- Form ID F 5480.1 A
- U.S. EPA Form 8700-22
- Manifest Attachment Sheet(s)
- Certification Statement
- LDR Notifications
- Form EG&G 669 and 669R
VARIANCE
Request for Variance
Special evaluation required*
* L,ase-by-case evaluation to be applied.
                                      E-4

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          APPENDIX F
Radionuclide Inventory Determination
          GIF Tank Farm
               F-l

-------
                   Appendix F
Radionuclide Inventory Determination CIF Tank Farm
Radionuclide

H-3
cr-51
Mn-54
CO-60
Ni-63
Zn-65
50-75
Se-79
Kr-85
Rb-87
5r-89
sr-90'
Y-90
Y-91
Nb-95
Zr-95
Tc-99
Rh-106
Ru-106
Ag-110m
Cd-115m
Sb-125
'e-125m
1-129
C3-134
6a-137m
Cs-137-
Ce-144
Pr-144
PM44m
Pm-147
Sm-151
Eu-154
Eu-155
Inventory
[Cl]
(A)


































Dose/Unit
Activity
[rem/CI]
(B)
1 .57E-04
4.35E-06
1 .07E-04
2.48E-03
4.96E-05
2.99E-04
1 .36E-04
1 .47E-04
2.94E-07
5.46E-05
6.12E-04
2.15E-02
1 .36E-04
7.28E-04
7.54E-05
3.15E-04
1.24E-04
1.08E-07
7.28E-03
8.80E-04
1.08E-03
1.63E-04
1.11E-04
2.98E-01
7.80E-04
6.42E-07
5.29E-04
5.79E-03
7.27E-07
3.04E-08
5.63E-04
4.80E-04
4.30E-03
6.45E-04
100-Meter
Dose
[rem]
(C=AxB)


































                   F-2

-------
                 Appendix F - Continued
Radlonuclide

Th-232
U-233
U-234
U-235
U-236
U-238
Np-237
Pu-238
Pu-239'
Pu-240
Pu-241
Pu-242
Am-241
Am-243
Cm-244
Cf-252
Inventory
[Ci]
(A)
















Dose/Unit
Activity
[rem/Ci]
(B)
2.65E+01
2.15E+00
2.15E+00
1.99E+00
1.99E+00
1.99E+00
8.11E+00
7.61 E+00
8.44E+00
8.44E+00
1.65E-01
7.94E+00
8.60E+00
8.60E-COO
4.47E+00
2.15E+00
Total Dose at
1 00 meters (Must be < 4.0 rem)
100-Meter
Dose
[rem]
(6=AxB)

















Waste identified only as alpha, beta, or gamma emitters should be
conservatively treated as the following individual radionuclides:
                 Alpha   -  Pu-239
                 Beta    -  Sr-90
                 Gamma  -  Cs-137
                       F-3

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-------
           APPENDIX G
Chemical Inventory Determination - GIF
               G-l

-------
             Appendix G
Chemical inventory Determination
CIF
Chemical

Acetonitrile
Acrylamide2-4
Acrylonitrile4
Allyl alcohol
Ammonium Sulfamate
Aniline
Arsenic
Barium
Benzene4
Benzyl chloride
Benzo pyrene
Bis (2-chloroethyl) ether
Bromoform2
Cadmium
Carbon disulfide3
Carbon tetrachloride4
Chlordane4
Chlorinated benzene
Chlorinated ethanes
Chlorinated fluorocarbons
Chloroacetaldehyde
Chloroform4
Chromium2-4
Chrysene
Cresols
Creosote
2,4-0, salts and esters
Crotonaldehyde3
Quantity
[kg]
(A)




























Air Cone./
Unit Inventory
[mg/kg m3]i
(B)
6.40E-02
1 .39E-05
2.16E-01
6.30E-02
2.97E-05
5.88E-04
9.48E-06
1.57E-05-
1.01E-01
2.16E-03
5.69E-08
1 .97E-06
2.58E-02
1 .36E-05
3.00E+00
2.77E-01
9.10E-10
6.34E-03
2.42E+00
6.11E-01
1.41E-01
4.54E-01
1.01E-05
3.43E-04
1.04E-04
1.11E-03
2.44E+00
1.29E-01
IDLH or
ERPG-2
[mg/m3i
(C)
6.84E+03
3.00E-01
1.11E+03
3.63E+02
5.00E+03
3".87E-i-02
1.00E*02
1.10E+03
9.75E*03
5.26E+1
7.00E+02
1 .49E+03
5.00E+01
5.00E+01
1.58E+02
1.92E*03
S.OOE-t-02
1.12E+04
5.36E+04
3.51 E+04
3.26E+02
4.96E+03
1.00E+01
7.00E+02
1.13E+03
7.00E-I-02
S.OOEi-02
2.91 E+01
Fraction
IDLH or
ERPG-2
(A X B)/C




























               G-2

-------
Appendix G • Continued
Chemical

DDT2.4
Oibutyl phtnaiate
o-DichloroDenzene
p-Dichlorobenzene
Dichlorodifluorometharve
1 ,2-Dichloroethylene
Dichloroethyl ether
Dichloropropane
Dieldrin4
1,4 Diethyleneoxide
Dimethylphthalate
Dimethyl sulfate
Dinitrotoluene
Diphenyl
Endrin
Epichlorohydrin3
2-Ethoxyethanol
Ethylene dibromide4
Ethylene dichloride
Ethylene oxide
Ethylidene dichloride
Ethyleneimine
Formaldehyde3
Formic acid
Heptachlor4
Hexachlorobutadiene3
Hexachloroethane4
Hydrazine4
Hydrogen cyanide
Hydrogen fluoride3
Isobutyf alcohol
Quantity
[kg]
(A)































Air Cone./
Unit Inventory
[mg/kg m3]1
(B)
9.39E-04
1.34E-10
5.75E-04
1 .03E-04
2.42E+00
3.29E-01
5.74E-04
3.50E-02
1 .64E-04
2.40E-02
4.11E-09
1.01E-04
2.47E-06
2.04E-03
1 .03E-04
4.38E-02
2.52E-03
1 .99E-02
1.18E-01
2.42E+00
4.48E-01
5.49E-01
1.21E+00
5.92E-02
6.66E-08
1.46E-04
3.06E-05
1 .30E-02
6.20E+00
1.21E+00
3.42E-03
IDLH or
ERPG-2
[mg/m3]
(C)
1.00E+01
9.30E-J-03
6.11 E+03
6.11E+03
2.52E+05
1.61E+04
1.49E-I-03
9.40E*03
4.50E+02
7.32E+03
9.30E+03
5.24E+01
2.00E+02
3.00E+02
2.00E+03
7.70E+01
2.25E+04
3.12E+03
4.11E+03
1 .46E+03
1.65E-t-04
1 .79E+02
1.25E*01
5.73E+01
7.00E+02
1.16E+02
3.00E+03
1 .06E+02
5.60E-8-01
1.66E+01
2.46E-I-04
Fraction
IOLH or
ERPG-2
(AXB)/C































        G-3

-------
Appendix G • Continued
Chemical

Lead compounds
Lindane
Maleic anhydride2
Mercury
Methoxychlor2
Methyl chloride4
Methyl chloroform
Methylene chloride
Methyl ethyl ketone
Methyl hydrazine
Methyl iodide3
Methyl isocyanate
Methyl methacrylate
Mineral spirits
Naphthalene
Nickel
p-Nitroaniline
Nitrobenzene
2-Nitropropane
Parathion
Pentachlorophenol
Phenol3
Phosgene3
Phthalic anhydride
Pyridine
Selenium2
Silver2
Sodium cyanide
Strychnine
Quantity
[kg]
(A)





























Air Cone./
Unit Inventory
[mg/kg m3]1
(B)
9.72E-06
3.86E-10
1 .33E-08
8.79E-08
2.96E-04
2.42E+00
1.94E-01
7.25E-01
1.00E-01
1.36E-01
3.63E+00
3.67E+00
2.88E-02
5.70E-02
1.33E-05
2.05E-05
3.46E-07
2.40E-03
1.04E-02
4.17E-06
1.43E-07
1.17E-01
1.21E+00
4.26E-08
1.03E-02
5.02E-05
8.43E-05
3.55E-05
9.45E-04
IOLH or
ERPG-2
[mg/m3]
(C)
7.00E+02
1 .OOE+03
1.00E+01
1 .OOE+01
1.00E+02
2.10E*04
5.55E+03
1.77E*04
9.QOE+03
9.60E-I-01
2.95E+02
4.74E+01
1 .66E+04
2.95E+04
2.50E+03
1.00E+00
3.00E-I-02
1 .02E+03
8.51 E+03
2.00E+1
1 .50E*02
1 .90E+02
8.22E-01
1 .OOE+04
1.18E+04
2.00E+00
1 .OOE-01
5.00E+01
3.00E+00
Fraction
IDLH or
ERPG-2
(A X B)/C










•


















        G-4

-------
                      Appendix C - Continued
Chemical

1 ,1 ,2,2-Tetrachloroethane
tetrachloroethylene4
Tetranitromethane
Thallium compounds
Toluene
Toluene diisocyanate
o-Toiuidine
Toxaphene4
Tributyl phosphate
1 ,1 ,2-Trichloroethane4
Trichloroethylene4
Trichlorofluoromethane
Vanadium pentoxide
Vinyl chloride
Xylene
Quantity
[Kg]
(A)















Air Cone./
Unit Inventory
[mg/kg m3!1
(B)
7.30E-03
1 .96E-02
5.65E-02
1.18E-04
2.78E-02
6.33E-05
1 .06E-04
2.41 E-03
1 .90E+00
2.79E-02
9.72E-02
2.42E+00
5.94E-05
2.42E+00
7.45E-03
Total Dose at
1 00 meters (Limit to < 0.3)
IDLH or
ERPG-2
[mg/m3]
(C)
1 .05E+03
3.45E+03
4.08E+01
2.00E+01
7.66E+03
7.24E+01
4.46E+02
2.00E+02
1 .38E+03
2.78E+03
5.46E+03
5.71 E*04
7.00E*01
2.60E+01
4.41E*03

traction
IDLH or
ERPG-2
(AXB)/C
















2
3
4
Any additional unlisted hazardous chemicals must be evaluated by a
methodology similar to what has been incorporated in this table for other
hazardous chemicals.                                            .   ,
Ten times the OSHA PEL value is used as the IDLH value for these chemicals.
Chemicals with listed ERPG-2 values.
An additional ICR Evaluation must be performed.
                               G-5

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